Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, they shall comply with 1106
Scott Batson, P.E., August 12, 2002
Below please find my comments regarding proposed modern roundabout accessibility rules:
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
1105.6.1 Separation. Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
Comment: The guideline as specified is too broad. No guidance is provided regarding the boundary for where a roundabout intersection begins or ends and thus a barrier begins or ends. The nature of a roundabout intersection is similar to a curved section of roadway or a mid-block crossing. The requirement of a street-side barrier at a roundabout intersection to separate vision impaired pedestrians from the roadway seems arbitrary. The logical extension of such need for barrier would be to install barriers at the edge of every sidewalk which is adjacent to a street. No substantive argument or evidence has been provided that distinguishes a modern roundabout pedestrian crossing as inherently less safe than any other mid-block crossing design or intersection treatment, and thus warranting such barrier. Location of the pedestrian crossing can be accomplished with a depressed landing adjacent to the ramp that directs pedestrians into the marked crossing.
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
Comment: The guideline as specified is too broad. The guideline appears to apply to all sizes and types of roundabouts with pedestrian facilities regardless of the level of auto or pedestrian traffic use. As roundabouts have so many different applications, with a similar variety of pedestrian environments, a single protocol without regard to traffic volume or the number of entry or exit lanes a pedestrian is expected to cross will unduly limit the modern roundabout's application due to the cost of this guideline. This would be unfortunate as modern roundabouts have a clear record of reducing total crashes and crash severity as compared to standard signalized traffic control. I would suggest additional research into the methods used in Australia and Europe, where modern roundabouts are used at high pedestrian use locations with regular frequency.
The guideline singles out the modern roundabout intersection control geometry without a clear argument or evidence of a safety need. The logical extension of this guideline is the need for pedestrian actuated signals at all intersections, regardless of traffic volume.
Scott Batson, P.E.
Senior Engineering Associate
Portland Office of Transportation
Gilmer D. Gaston, P.E., PTOE, August 14, 2002
As a traffic engineering professional, I feel compelled to comment on the Access Board's proposed Draft Guidelines for Accessible Public Rights-of-Way. I formerly managed the traffic signals section for the City of Houston, so I have a feel for how severe these requirements will impact the agencies.
While the guidelines were undoubtedly prepared by a group of well meaning individuals. They contain several items that could have severe and unintended consequences. I have provided a few comments on some of what I feel are the more onerous sections of the document.
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
Is there actual crash data that supports the need for this measure? We know that there are a lot of pedestrian accidents at intersections; however, it is my understanding that in most of those instances the pedestrian is not using or following the guidance of the existing pedestrian signals. This item would probably put an unnecessary burden on agencies to retrofit existing intersections for little, if any, safety benefits, and a likely decrease in the operational benefits of right-turn lanes.
Something that I didn't see, that I believe could be useful is a recommended maximum distance from the crosswalk for the placement of pedestrian pushbuttons.
The US Congress is known for passing good intended legislation that often results in unintended actions by the public. This leads to more legislation and more requirements as it can produce unintended results. A possible,
unintended consequence of unnecessarily stringent requirements could be a reduction in the number of crosswalks. Some intersection crossings may be signed for no pedestrians because the disbenefits to intersection operations could outweigh providing a crossing that complies with these guidelines.
If you have any questions, or comments, let me know. I may provide additional comments later, as I have a chance to further review these materials.
Gilmer D. Gaston, P.E., PTOE
Sr. Transportation Manager
Pape-Dawson Engineers, Inc.
San Antonio, Texas
Comments to: Draft of Recommendations of The Access Board on Pedestrian Crosswalks At Roundabouts
Dear Committee Members:
I am since ten years a professor of transportation engineering in the United States. My training was in Sweden where I in 1982 presented my Ph.D.-thesis on Pedestrian Safety at Signalized Intersections. I have worked on research relating to pedestrian safety for 25+ years and parallel to this on roundabout safety for 20+ years and would like to give some comments to your proposed guidelines.
It seems like you write that wherever marked (and possibly unmarked) pedestrian crosswalks are provided at roundabouts, each shall meet the requirements set forth in this section, including: (C) Signals. A pedestrian actuated traffic signal complying with Section ? shall be provided for each segment of the crosswalk, including at the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
I will comment on this below, in connection to some direct comments to your discussion section. But first, inhttp://www.access-board.gov/rowdraft.htm#1106 you write, "Requiring the signal to be pedestrian activated may help limit the impact on traffic flow." In reality this may be true, but shouldn't the responsibility of lawmakers include that the code be made to be followed? Through education and/or enforcement activities if necessary? As far as I know, pedestrians, in all U.S. states, have the right-of-way in unsignalized marked crosswalks. In other words, the primary purpose of signalizing marked crosswalks should be to give automobile drivers the right-of-way part of the time so that automobile capacity does not become too low where pedestrian flows are high. In Germany, and some other European countries, this is clearly understood and given as the primary reason for signalizing crosswalks. Still, I acknowledge that we in the U.S. live in a country were many drivers do not stop for pedestrians in crosswalks, even for those carrying white canes, and I understand that we may have to 'accommodate' such illegal behavior, and have designs that make it reasonably safe for all pedestrians, including those in wheelchair or visually impaired, even when divers violate codes.
In Discussion (http://www.access-board.gov/prowac/commrept/part3-02-5.htm) you write:
"Modern roundabouts are ?. While this traffic pattern has been an asset to traffic planners in controlling and slowing the flow of traffic at intersections in lieu of having a signalized intersection, the absence of stopped traffic presents a major problem for blind and visually impaired pedestrians when crossing."
I would like that statement to be backed by facts in the form of crash statistics. If it were (only) a perceived "major problem" rather than an actual problem, then maybe education rather than engineering changes would be motivated. I do know that the 'sole' serious opposition to roundabouts in Sweden today stems from visually impaired people and their advocacy groups, and I do not mean that this is not a very important subgroup of the pedestrian population, but still, sub-optimization of our traffic environment is one of the reasons that the risk of fatality per mile walked is about ten times higher in the United States than in Sweden, where roundabouts are utilized frequently in the urban environment. I also know that signalized crosswalks or grade-separated passages are considered at roundabouts in Sweden, where there is a high demand by visually impaired pedestrians? But, to require signalization of all roundabouts is, in my opinion, definitely unwarranted. At least, it is my opinion, that all crosswalk locations away from roundabouts should be signalized prior to the ones adjacent to single-lane roundabouts getting this type of control.
Rather, you should consider requiring signalization of marked crosswalks (or grade-separated crossings) at multi-lane locations including at multi-lane roundabouts with high pedestrian volumes. I am fairly convinced that there is no crash data from the U.S. supporting the view that pedestrians are vulnerable to crashes at single-lane roundabouts. The only pedestrian crash at a U.S. roundabout was, as far as I know, the elderly person hit in Montpelier, VT, and that did not cause any serious injury. Rather, the roundabout prevented the injury. There is statistics from Sweden, showing that 'all' the country's (»700) single-lane roundabouts had a total of three pedestrian crashes (with not a single serious injury) in the 1994 to 1997 period. (Today there are a lot more roundabouts in Sweden, but I do not have any newer statistics.) If these locations had been signalized, there would have been at least 11 pedestrian crashes according to standard models. However, the two-lane roundabouts studied, had an actual safety very similar to signalized locations (10.4 predicted and 12 occurred at the 14 locations in Sweden that have considerable pedestrian traffic.)
You write: "Barriers or similarly distinct elements are needed to prevent blind persons from inadvertently crossing a roundabout roadway in an unsafe location. ? Because the pedestrian crosswalk is generally placed at least one car length from the entry point, in a location that is not immediately apparent to a blind or visually impaired pedestrian, a cue is needed for crosswalk location."
Again, I have no objection to the idea that pedestrians are guided to safe crossing points, but crossing outside the crosswalk at a roundabout is probably safer than crossing anywhere away from a roundabout, so there should be million of miles of barriers put up prior to the ones at roundabouts.
You write, "Pedestrians report that vehicles at roundabouts, right slip lanes, and other unsignalized pedestrian crosswalks often do not yield for pedestrians. Pedestrians with disabilities are particularly vulnerable in these situations. People who are blind or visually impaired are unable to make eye contact with drivers making it impossible to 'claim the intersection.' The driver's view of people using wheelchairs is often blocked by other vehicles. Pedestrians with slower than normal mobility may hesitate when entering the street. All of these situations may result in drivers misinterpreting the pedestrian's intention to cross."
I agree, but this is even truer away from roundabouts at non-signalized locations.
You write, "It is recognized, however, that the purpose of these types of unsignalized crosswalks is to keep traffic moving as continuously as possible."
That is one reason for constructing roundabouts, but I have for over a decade advocated the use of roundabouts for the primary purpose of improving pedestrian safety. That delays are reduces is a side effect rather than the primary purpose in my way of thinking.
You write, "Traffic flow can be achieved, while still affording pedestrians with disabilities the opportunity to cross safely, with the use of pedestrian actuated technologies that halt traffic only while the pedestrian is in the crosswalk. An advantage of passive detectors is that, when pedestrians cross slowly, more time can be automatically provided. When a pedestrian crosses quickly, the traffic is stopped only during the time the pedestrian is crossing, thereby eliminating the problem of traffic being held up when no pedestrian is in the crosswalk."
I agree fully with this strategy. Wherever it is economically feasible, I support the use of passive or active detection and stoplights. But, again, roundabouts should not be the first place to implement such systems.
I recently studied the safety of pedestrians at over a hundred locations in Maine. I counted pedestrian and vehicle volumes and predicted how many crashes there ought to have been if the layout was 'typical' (according to TRL models from England and VTI models from Sweden, which in parenthesis gave very similar results) and compared these estimates to actual crash experience involving pedestrians. I found that the risk of a pedestrian collision is
- roughly 25 times the 'average' where pedestrians cross multi-lane streets at unmarked locations with 25 mph speed limits but actual speeds around 30 to 40 mph
- roughly 10 times the 'average' where pedestrians cross multi-lane streets in marked crosswalks with 25 mph speed limits but actual speeds around 30 to 40 mph
- roughly 4 times the 'average' where pedestrians cross multi-lane streets at unmarked locations with 25 mph speed limits but actual speeds around 25 mph
- roughly 2.5 times the 'average' where pedestrians cross multi-lane streets in marked crosswalks with 25 mph speed limits but actual speeds around 25 mph
- signalization of the above listed locations reduces the risks by roughly 50%
- roughly half the 'average' where pedestrians cross 2-lane streets as an average for all speeds if the street is posted as 25 mph
- extremely low risk where pedestrians cross 2-lane streets in marked or unmarked crosswalks with 25 mph speed limits but actual speeds around 20 mph
There were no multi-lane streets with actual speeds below 25 mph.
All the figures above include visually impaired people but are not specifically true for that group by itself. In summary, 4- and 6-lane streets are very dangerous where speeds are high. Signalization reduces the risk, but the risk is still much higher than at a narrow low-speed location, especially since many of the crashes still occur at very high speeds (jaywalkers or drivers running red lights account for over 50% of the pedestrian crashes). For example, the risk of a pedestrian collision is about 5 to 12 times higher than 'average' at a signalized 4-lane crosswalk if cars are driven at 30 mph whereas it is maybe 20% of the average in the vicinity of a single-lane roundabout (2-lane street) handling the same traffic volume. That is a difference of roughly 50 times. And that is risk of collision, not risk of serious injury or fatality. The risk of fatality, for Maine streets and roads, vary as seen in the table here. In other words, the roundabout may be more than 50 times safer than the signalization.
Table 1 Speed limit and crash severity, Maine data
In conclusion to my comments. I may be wrong in my assessment that non-signalized crosswalks adjacent to roundabouts are very safe for visually impaired people. And I do not want to advocate accepting collateral damage. But, if the design procedures suggested here means that roundabouts will not be constructed, and this means that we will 'keep' signalization and see 500 additional pedestrian fatalities a year compared to if roundabouts were utilized, which would have led to (annually) one visually impaired person being killed at a roundabout, should we then celebrate the saving of that one life at a cost of 500? Maybe? But, what if I am correct, and there will not be any additional deaths among visually impaired people, and the result of this practice will be 500 more pedestrian fatalities and not a single saved life? Then we should feel bad about our choice, shouldn't we? Especially since some of the 500 will be visually impaired people.
Roundabouts are not the only way of slowing down traffic. There are other traffic-calming methods that can be used. Unfortunately, the experience with signalization as a traffic calmer is not encouraging. Even if the mean speeds are reduced, the top speeds are very high. And some of those top speeds are found just after the perpendicular walk signal indicates a clear crossing. And, what the roundabout has in its favor that most other traffic-calming measures don't have is that it allows for narrow streets, something very important for elderly pedestrians' safety.
Now, as my last words, if the suggested design criteria lead to no reduction in the rate of constructing roundabouts, and the proposed signals are such that pedestrians have the absolute right-of-way both when the signal is activated and deactivated (as is the formal rule today if they go blank) then the signalization should cause no bad safety-effects and we would all be winners. My concern is that the cost for such systems will be prohibitive, and the construction of roundabouts will be delayed.
Thank you for listening to my thoughts,
Per Gårder, Professor
Department of Civil Engineering
University of Maine
Jennifer Campos, October 25, 2002
City of Vancouver
Transportation Services
On behalf of the City of Vancouver, Washington, I am submitting comments regarding the recently released Draft Guidelines for Accessible Public Rights-of-Way by the Access Board. The City is very supportive of the Board's decision to create guidelines for the public right-of-way, but we do have some concerns over several of the proposed requirements.
Below I have listed our comments below by section number. Assume that if any part of the guidelines is not mentioned, that we support what you have proposed.
1104.3.2 Detectable Warnings. Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.
We strongly feel that this requirement is unnecessary and over burdensome. Detectable warnings should not be placed at all curb ramps or landings, but only in those cases where it would be difficult for someone to detect where the sidewalk ends and the street begins. This would be at rail crossings, platform edges, blended transitions, or ramps that have a slope of 1:15
1105.2.2 Cross Slope. The cross slope shall be 1:48
EXCEPTION: This requirement shall not apply to mid-block crossings.
1105.2.3 Running Slope. The running slope shall be 1:20
Both of these requirements would place a huge burden on the City in trying to meet the standards since it would apply to all streets regardless of any outside circumstances that we would have no control over. This should be a guideline that jurisdictions should strive for while designing their roadways in order to improve pedestrian safety, but it would be impossible for many if not most areas to meet it in all cases.
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Requiring this change in signal timing would ensure much higher delays for all users. The requirement would be applicable on streets that were not overly wide and had curb returns over 25', but unfortunately this is not how many of our streets are built today. We currently respond to the request for more crossing time on a case by case basis, or any place we feel there are users who will benefit from the change.
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
1105.6.1 Separation. Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
This portion of the proposed guidelines has to be the most excessive and unnecessary part of the entire guidelines. To require signals at all legs of roundabouts completely defeats the purpose of building a roundabout in the first place. The board mentions that roundabouts have become popular in the U.S because they "add vehicle capacity and reduce delay." These are not the only reasons and it would be careless of you to not recognize the most important benefits.
Roundabouts have become so successful because the virtually eliminate all accidents at intersections. This is not just automobile accidents, but pedestrian accidents as well. They do so by reducing the number of conflict points and more importantly reduce the speeds of motorists entering the intersection. When motorists drive slower they are more able to take account of their surroundings, making conditions much safer for pedestrians for crossing. We recognize that blind or visually impaired pedestrians can have difficulties crossing at roundabouts, but to install signals at all legs would make them cost prohibitive compared to a regular signalized intersection.
Because navigating the sidewalks around the edge of a roundabout is not different than navigating any other intersection, the need for barriers is completely unnecessary. Curb ramps are installed at roundabouts to indicate crossing locations just as they are for any other type of intersection.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
Rather than require signals at slip lanes for pedestrians, why not just prohibit their use? This would make much more sense, and would completely eliminate the pedestrian/auto conflict that a signal probably would not prevent.
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
We know that most of the controversy surrounding these guidelines has revolved around the audible signal requirement and we feel that to require an audible signal at every intersection with a WALK interval is cost burdensome and unrealistic. For new signals the installation cost would not be significant, but the impacts to the environment would be enormous. Imagine walking in the downtown of a city with a 200 ft
We work with the local blind community to prioritize needed audible signal locations, and try to install as many devices as we can. We get requests from people who have difficulty reading a certain intersection, and they have made it clear that they do not want audible signals at every intersection.
1109.2 Parallel Parking Spaces. An access aisle at least 60 inches
It would be impossible to install and maintain a disabled parking spot on each block of parallel parking. In areas where the block faces are around 200 feet
If you have any questions regarding our comments please don't hesitate to contact me at [ ... ]
Sincerely,
Jennifer Campos
Associate Transportation Planner
Lynn B. Jarman, October 24, 2002
ACCESSIBILITY IN THE PUBLIC RIGHT-OF-WAY DRAFT GUIDELINES
(Response to the Access Board's request for review and comment)
Salt Lake City Public Services has reviewed the proposed guidelines and respectfully submits the following recommended revisions and statements of concern:
1102.3, 1111.3 Alternate Circulation Path
Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
Recommended Revision: The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street, unless in the judgment of the engineer, significant pedestrian safety issues exist, then the alternate circulation path shall be provided on the opposite side of the street.
1102.14 On Street Parking. Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.
Concern: Block lengths are not consistent across the country; the ratio of accessible stalls to non-accessible stalls will vary from city to city based on the standard block length. The proposed guideline does not clearly define whether the requirements apply to all block faces within a city, or only those locations with pavement marked stalls. The cost to identify accessible stalls on all block faces, including residential areas would be extreme.
1104 Ramps and Blended Transitions
1104.2.2.1 Running Slope
EXCEPTION: A parallel curb ramp shall not be required to exceed 15 feet
Recommended Revision: A parallel curb ramp shall not be required to exceed 16 feet
(The proposed minimum pedestrian access width is 48 inches; therefore, the common sidewalk scoring pattern would occur every 48 inches
1104.3.2 Detectable Warnings (see 1108)
1105 Pedestrian Crossings
1105.2 Crosswalks
1105.2.2 Cross Slope. The cross slope shall be 1:48
Concern: This requirement will create "tabled areas" in the roadway, potentially creating vehicular traffic hazards, particularly in areas where roadways have steep running slopes.
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Recommended Revision: All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Concern: Some consideration has been given to a walk speed of 2.5 feet
1105.5 Pedestrian Overpasses and Underpasses
1105.5.3 Approach. Where the approach exceeds 1:20
Concern: Overpasses and underpasses exceeding the maximum stated approach rise should not require the installation of an elevator. The extreme cost for installation, maintenance, and security makes this requirement an unjustifiable burden on municipalities with limited resources. Efforts should be made to meet ramping requirements, but site conditions may present a situation of infeasibility.
1105.6 Roundabouts
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
Concern: Installation of pedestrian signals at each roundabout crossing negates the intended benefits of installing a roundabout. Additional signalization does not always result in greater pedestrian safety. Instead of requiring signals at all roundabouts, local engineers should evaluate roundabout installations to determine which locations would logically benefit from the installation of pedestrian signals.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
Concern: Additional signalization does not directly equate to improved pedestrian safety. Well-engineered slip lanes (channelized turn lanes) with properly established pedestrian crossing times will result in improved safety. The slip lane design may or may not include additional signalization; the engineer should make this decision.
1108 Detectable Warning Surfaces
Concern: Considerable concern appears to exist from both the professional and public sectors regarding the installation of truncated domes. The major organizations representing the blind community cannot come to agreement on this issue. Initial installation costs and ongoing maintenance costs, especially in areas experiencing ice and snow, present real concerns regarding this proposed standard. Further evaluation is needed to ensure implementation of this guideline will provide the desired benefit.
Salt Lake City Public Services appreciates the opportunity to provide comment on the proposed guidelines. The Board's efforts in this matter are admirable. Hopefully, with feedback from local jurisdictions, guidelines meeting the true needs of our communities will be developed and adopted by those enforcing construction standards.
Sincerely,
Lynn B. Jarman
Salt Lake City Public Services
Engineering Division
Planning and Programming Manager
Lawrence T. Hagen, P.E., PTOE, October 22, 2002
As a general comment, too much of the guidelines are attempts to eliminate any engineering judgment in determining what is the appropriate traffic control treatment. This leads to "cookbook engineering" where everyone just blindly implements the cookbook approach. This one-size-fits-all approach is not good engineering, is not good public works, and is usually not serving the overall best interest of the public. Many of the recommended guidelines also seem to have been done with no consideration of the fiscal impact. However, with the ever-increasing demands and less money, operating agencies will have difficulty implementing the proposed guidelines
Alternate Circulation Path - (1102.3, 1111)
I would suggest that an exception for short-duration blockages of pedestrian paths should be included. If construction activities will block the path for a few hours or maybe one day, you could spend more time and disrupt more people by the installation and removal of the accessible and protected alternate path than by the actual construction activity. Short-term closure of a pedestrian path, where the pedestrian could utilize the other side of the road is a reasonable alternative.
Minimum Clear Width (1103.3)
48" width exclusive of curbs will be difficult to obtain in many areas with already-constrained right-of-way. I agree with some of the other posted comments that perhaps we should look to including the curbs.
Pedestrian Crossings (1105.2.1)
I do not support the widening of crosswalks in a sweeping blanket mandate. In many cases at large intersections, traffic engineers struggle to get the signal indications located within the 40 - 150' distance from the stop line as mandated by the MUTCD. Adding a couple of feet doesn't sound like much, but in many instances that could be the difference between four and eight signal structures (mast arms). I would prefer to see the 72 inch
Pedestrian Signal Phase Timing (1105.3)
I am adamantly opposed to mandating a walk speed of 3.0 feet
have crossed.
Pedestrian Crossing Length (1105.4.1)
This requirement would seem to mandate the removal of unsignalized crossings where the median width is less than 72 inches
Pedestrian Overpasses and Underpasses (1105.5)
I believe that requiring elevators where there is a elevation change over 60 inches
Roundabouts (1105.6)
I think mandating signalized pedestrian crossings at all roundabouts is one of the silliest ideas imaginable. Many roundabouts do not warrant signalization, so they would certainly not meet the warrants for the pedestrian crossings on the approaches. There certainly are some roundabouts with poor pedestrian performance, but many of those have design flaws in the roundabout. Many I have seen have the pedestrian crossing at the circulating roadway edge. By properly designing and constructing the pedestrian crossings at roundabouts, I believe that peds can be properly and safely accommodated without signals at most roundabouts. I think "YIELD TO PEDS" signs at the crosswalks should be tried first, and signalized ped crossings should only be a last resort if nothing else seems to work. However, either of these treatments should only be installed after an engineering study determines that they are the most appropriate traffic control device. I am also unsure what type of barrier is needed around roundabouts. Would a small strip of grass or other landscaping (like that shown in the picture) be an appropriate barrier? Guidance on the barrier is needed.
Turn Lanes at Intersections (1105.7)
Among other things, installation of the pedestrian activated signal at each segment of the crosswalk crossing slip lanes creates a maintenance problem. Large trucks routinely hit poles or devices that are out in the refuge island, so the maintaining agency has to repeatedly replace the equipment. Also, with the requirements of 1106.2.1, there is not room on most slip lane channelization islands to accommodate the spacing requirements. Similar to roundabouts above, I believe that if there is a problem, an engineer should study to determine the most appropriate traffic control and be able to choose the best answer for that intersection from the available solutions.
Accessible Pedestrian Signal Systems (1102.8, 1106)
My only comment here is related to the fiscal issue. In large metropolitan areas where there are large numbers of signals, the costs of retrofitting all of the signals with upgraded pedestrian features can be staggering, especially in this day and age when everyone's budget is being cut. Additionally, by replacing a simple pushbutton switch with a more sophisticated device that also vibrates and emits sounds, you will incur more maintenance expense. Please understand, I wholly support having accessible pedestrian devices where they are needed. However, given the additional capital and maintenance costs, is it good public works to install these devices where they may not be needed? Again, my objection is basically the one-size-fits-all approach.
Thank you for the opportunity to comment. Please let me know if you need additional information.
Larry Hagen
Lawrence T. Hagen, P.E., PTOE
Program Director - ITS, Traffic Operations, & Safety
Center for Urban Transportation Research (CUTR)
University of South Florida, College of Engineering
Richard A. Retting, October 25, 2002
Architectural and Transportation Barriers Compliance Board
Draft Guidelines for Accessible Public Rights-of-Way
In response to the Draft Guidelines for Accessible Public Rights-of-Way (June 17, 2002) proposed by the Architectural and Transportation Barriers Compliance Board (Access Board, 2002), the Insurance Institute for Highway Safety opposes the provisions that would mandate installation of traffic signals on pedestrian crosswalks at all roundabouts.
Background
Modern roundabouts are designed to function safely and efficiently without traffic signals and, in most cases, are constructed to replace less safe and less efficient stop sign-controlled intersections. Roundabouts are circular intersections with specific design and traffic control features that eliminate the need for traffic signals. These features include yield control of all entering traffic, channelized approaches with raised splitter islands, and geometric curvature to ensure slow travel speeds for vehicles entering into and within the roundabout.
Roundabouts are relatively new in the United States. Las Vegas, Nevada, built the first modern U.S. roundabout in 1990 (Jacquemart, 1998), and since then only 200-300 roundabouts have been constructed nationwide. In comparison, Australia and many European countries have been installing roundabouts extensively for decades, with, for example, more than 2000 roundabouts built in the Australian state of Victoria alone.
Effects on road safety of converting intersections to roundabouts has been the subject of extensive research in the United States and abroad. Results clearly indicate that roundabouts are an extremely safe form of intersection traffic control. For example, an Institute-supported evaluation of 23 U.S. intersections converted from stop sign or traffic signal control reported large reductions in motor vehicle crashes after roundabouts were installed (Persaud et al., 2001). Overall, crashes were reduced by an estimated 40 percent, injury
crashes declined by 80 percent, and crashes resulting in fatal or
incapacitating injuries were reduced by 90 percent. A recent meta-
analysis of 28 separate roundabout safety evaluations from outside the United States concluded that roundabouts were associated with a 30-50 percent reduction in the number of injury crashes and a 50-70 percent reduction in fatal crashes (Elvik, in press).
Although these studies do not provide conclusive evidence of the safety of pedestrians at roundabouts (primarily because of small samples of pedestrian crashes), available research suggests roundabouts can provide a relatively high degree of safety compared with intersections with stop sign and traffic signal control. For example, in the Persaud et al. (2001) study, four pedestrian crashes were reported during the before period and one was reported during the period after roundabouts were built (this difference was not significant due to the small sample size). Brude and Larsson (2000) analyzed pedestrian crash data at 72 roundabouts in Sweden and concluded that roundabouts pose no problems for pedestrians compared with conventional signal control intersections. For single-lane roundabouts, the observed numbers of pedestrian crashes were 3-4 times lower than for comparable signalized intersections, controlling for pedestrian volumes and traffic flow. Jordan (1985) examined pedestrian crash patterns at roundabouts in Victoria, Australia for the 4-year period 1980-83. A total of 35 pedestrian crashes were reported (average 9 crashes per year) at approximately 800 roundabouts. The author characterized this as an extremely low rate of pedestrian crashes and concluded that "concern for pedestrian safety at roundabouts, while well intentioned, is unfounded." Tumber (1997) conducted a review of pedestrian safety at roundabouts, also in Australia. The study focused on roundabouts constructed on arterial roads within the Melbourne metropolitan area during 1987-94. During this period, 64 pedestrian crashes were reported at approximately 400 roundabouts, for an average crash rate of 0.02 crashes per roundabout per year. The severity of pedestrian crashes (as indicated by the proportion of injuries classified as either serious or fatal) also was lower for roundabouts than for intersections with other forms of traffic control.
The safety of blind pedestrians at roundabouts has been questioned by some advocates of the visually impaired, but direct evaluations of crash data are not available. In an indirect evaluation of the issue, Guth et al. (2002) collected data regarding the ability of blind pedestrians to use their hearing to distinguish "crossable" gaps in traffic at roundabouts from gaps that were considered by the authors too short to afford a safe crossing. This work was supported by the Access Board. Three study sites in Maryland included a low-volume, single-lane roundabout; a large, urban, high-volume, two-lane roundabout; and an urban, intermediate-volume, two-lane roundabout. Six blind and four sighted pedestrians observed traffic at roundabout crosswalks and indicated by pressing a button whenever they believed they could complete a crossing before the arrival of the next vehicle. For the low-volume, single-lane roundabout, gaps between vehicles longer than 10 seconds
2-3 seconds
Despite the finding by Guth et al. (2002) that blind pedestrians can adequately judge gaps at single-lane roundabouts with little difficulty and as well as sighted individuals, the Access Board is proposing guidelines that would require signalization of pedestrian crosswalks at all roundabouts on the basis that the safety of blind pedestrians mandates such devices. This proposed requirement would apply even in rural settings where pedestrian activity is infrequent and where blind pedestrians may be nonexistent. However, traffic signals appear to be unnecessary at single-lane roundabouts and, if mandated, actually could be detrimental to highway safety. It is likely that the arbitrary addition of traffic signals to well designed roundabouts could increase the risk of injury crashes due to disruptions in traffic flow. Also, substantial costs associated with installation and maintenance of traffic signals might discourage some communities from constructing roundabouts. Even for high-volume, two-lane roundabouts, the Guth et al. field study does not make a compelling case for traffic signals because of weaknesses in the research methodology. Blind pedestrians were driven to roundabouts and then observed after minimal exposure to these unfamiliar locations. This is unrealistic because blind pedestrians typically do not wander into such areas without a guide to provide initial orientation. Guth et al. merely provides evidence of the perception of risk, not actual risk. The blind pedestrians may have been more willing to press a button when they believed they could complete a crossing than to begin crossing, thus inflating the numbers of "risky" judgments. Also, comparable data were not collected for intersections controlled by traffic signals or stop signs.
Compared with conventional intersections, roundabouts can provide improved access and safety for blind pedestrians as well as sighted individuals because of specific roundabout design and operational characteristics. First and foremost, traffic speeds within roundabouts are very low -- typically 15-20 mph -- compared with considerably higher traffic speeds at most traffic signal and stop sign-controlled intersections. Pedestrian refuge islands at roundabouts provide for short crossing distances. Also, roundabouts are relatively simple intersections that eliminate left turns, right turns, and the associated turning-vehicle conflicts common at conventional intersections. By comparison, conventional intersections are characterized by higher traffic speeds, longer crossing distances, and are more complex due to two-way traffic flow and frequent vehicle turning movements. Preusser et al. (2002) reported that 25 percent of motor vehicle-pedestrian collisions in Washington D.C. involve turning vehicles.
The combination of low traffic speeds, short crossing distances, and absence of turning vehicles in conjunction with White Cane Laws - laws in 47 states that require drivers to yield the right-of-way to a person carrying a white cane or accompanied by a guide dog --- provide safe crosswalks for blind pedestrian at many roundabouts. Additional measures that could enhance safety include textured pavement in conjunction with ramps to help lead blind pedestrians to crosswalks, raised crosswalks that can further slow entering and exiting traffic, and pedestrian yield signs in both directions of the crossing that require drivers to stop for pedestrians waiting on the crosswalk. Also, specific training can be developed and provided to help the visually impaired perceive gaps in traffic and to give drivers cues to stop.
Signalizing roundabout crossings can be justified when the combined volumes of pedestrians and vehicles are high or at locations with complex geometry such as high-volume school zones. In Australia and Europe, the vast majority of roundabouts are unsignalized, but some roundabouts in urban areas do have pedestrian signals. The recommended threshold for signalizing pedestrian crossings in the United Kingdom is:
PV2 > 1 ? 108,
where
P = Pedestrian volumes per hour (average of peak 4 hours)
V = entering vehicles per hour (average of peak 4 hours)
Rather than adopting the Access Board's recommendation to require signalization on pedestrian crosswalks at all roundabouts, regardless of need or justification, the Institute supports the Australian and European practice of installing pedestrian signals at appropriate locations based on objective criteria.
Opposition to Draft Guidelines
The Access Board indicates that the absence of stopped traffic presents a problem for pedestrians with vision impairments in crossing streets. It is true that traffic signals at conventional intersections establish a stop-and-go pattern that can assist blind and visually impaired pedestrians in crossing busy streets by producing audible cues about vehicle movements. However, a large majority of U.S. intersections are not controlled by traffic signals. Most intersections are governed by one-way or two-way stop sign control, which only require vehicles traveling on minor intersection approaches to stop. At most stop sign-controlled intersections, vehicles traveling on major intersection approaches are not required to stop, and at such locations travel speeds often can exceed 40-50 mph. So clearly, the absence of stopped traffic, while potentially problematic for pedestrians with vision impairments, is a frequently encountered condition. Like countless other crossings where traffic does not stop, blind pedestrians primarily rely on hearing to identify gaps in traffic.
The draft guidelines also suggest that crossing at a roundabout requires a pedestrian to visually select a safe gap between cars that may not stop. This statement is inaccurate as well as insulting to pedestrians who are blind. With proper training, blind pedestrians use their hearing to identify and select gaps in traffic at a wide range of unsignalized crossings where traffic may not stop. Even the Access Board-sponsored research by Guth et al. (2002) reported that blind individuals can cross single-lane roundabouts with relatively little difficulty and with few "risky" judgments (and more than half of U.S. roundabouts are single-lane, as reported by Jacquemart (1998)).
The Access Board claims that people who are blind or visually impaired are unable to make eye contact with drivers making it impossible to "claim the intersection." Blind pedestrians obviously are unable to make eye contact with drivers, regardless of the type of intersection traffic control. However, because roundabouts produce low travel speeds, short crossing distances, and eliminate turning vehicles, pedestrian crossings at roundabouts should be safer for blind pedestrians relative to many other unsignalized crossings. White Cane Laws, which require drivers to yield the right-of-way, further enable blind pedestrians to claim the intersection at roundabout crossings despite the inability to make eye contact.
Summary
The Institute opposes provisions of the draft guidelines that would require installation of traffic signals on pedestrian crosswalks at all roundabouts. The Access Board has provided no scientific evidence in support of this proposed requirement and, furthermore, it is likely that the arbitrary addition of traffic signals to well-designed roundabouts could increase the risk of motor vehicle crashes, in particular rear-end collisions, due to disruptions in traffic flow. Substantial costs associated with installation and maintenance of traffic signals might discourage some communities from constructing roundabouts or installing pedestrian crossings. Compared with conventional intersections, roundabout design and operational characteristics can provide improved access and safety for blind as well as sighted pedestrians, and additional measures can be taken to further improve the safety of blind pedestrians at unsignalized roundabout crossings such as textured pavement, raised crosswalks (speed tables), and increased lighting. Rather than adopting the Access Board's recommendation to mandate signalization on pedestrian crosswalks at all roundabouts -- regardless of need or justification -- the Institute supports the practice of installing pedestrian signals at appropriate locations where needed, based on objective criteria.
Sincerely,
Richard A. Retting
Senior Transportation Engineer
References
Architectural and Transportation Barriers Compliance Board. 2002. Draft guidelines for accessible public rights-of-way. Washington, DC. Available: http://www.access-board.gov/rowdraft.htm#DRAFT.
Brude, U. and Larsson, J. 2000. What roundabout design provides the highest possible safety? Nordic Road & Transport Research 12:17-21
Elvik, R. 2002. Effects on road safety of converting intersections to roundabouts: A review of evidence from non-US studies. Transportation Research Record. Washington, DC: Transportation Research Board, in press.
Guth, D.; Long, R.; Ponchilla, P.; Ashmead, D.; and Wall, R. 2002. Non-visual gap detection at roundabouts by pedestrians who are blind: a summary of the Baltimore roundabouts study. Washington, DC. Available: http://www.access-board.gov/publications/roundabouts/ research-summary.htm.
Jacquemart, G. 1998. Modern roundabout practice in the United States. Synthesis of Highway Practice 264. Washington, DC: Transportation Research Board.
Jordan, P.W. 1985 Pedestrians and cyclists at roundabouts. Proceedings of Local Government Engineers Conference. Perth, Australia.
Persaud, B.N.; Retting, R.A.; Garder, P.E.; and Lord, D. 2001. Safety effects of roundabout conversions in the United States: empirical Bayes observational before-after study. Transportation Research Record 1751, 1-8. Washington, DC: Transportation Research Board
Preusser, D.F.; Wells, J.K.; Williams, A.F.; and Weinstein, H.B. 2002. Pedestrian crashes in Washington, DC and Baltimore. Accident Analysis and Prevention 34:703-10
Tumber, C. 1997. Review of pedestrian safety at roundabouts. Victoria, Australia: VicRoads, Road Safety Department.
Arthur Slabosky, P.E., September 25, 2002
There is no need to put pedestrian actuated signals at all roundabout crosswalks. Both sides on this issue are approaching it mechanistically as only a design issue, with no recognition of a role for education and enforcement. Access for pedestrians with vision impairments should be accomplished at roundabouts by enforcement of the law, with motorist and police education devoted to that purpose.. The anti-signal people seem to think that no education is necessary. The pro-signal people seem to think that no education is enough.
The description of the problem as expressed by the Access Board are misleading because they do not recognize that drivers are required to yield for pedestrians in crosswalk, although admittedly this is not enforced in the U.S.
Let us examine the following excerpt from http://www.access-board.gov/rowdraft.htm in section (1105.6) on Roundabouts: "...Because crossing at a roundabout requires a pedestrian to visually select a safe gap between cars that may not stop, accessibility has been problematic...." A pedestrian is not required to cross between cars that may not stop. A pedestrian that steps into the crosswalk legally mandates cars to stop. That is a legally available option to crossing in a gap in traffic.
A later phrase on the same page mentions that ..., the absence of stopped traffic presents a problem for pedestrians with vision impairments in crossing streets." Out of context this is a true statement. In the context of a roundabout with marked crosswalks it is again not quite on target because of the pedestrian's legal power to stop traffic as mentioned above. Furthermore it is not true that automobile traffic is never stopped in the absence of pedestrian demand. During busy times automobile traffic yields for vehicles inside the circle until there is a gap. This creates a stop-and-go queue in which vehicle drivers are amenable to leave a gap at the crosswalk (because they have to stop anyway).
The major premise of the Access Board's approach is that a red light displayed in front of a driver will cause them to stop, but a human being will not. The law on red lights is no higher a law than the one on pedestrians in a crosswalk. Then we can apply the Access Board's own argument also to a red light, and say that this is traffic that "may not stop." Red light running is a documented phenomenon on our streets.
Even red light compliance depends upon awareness of police enforcement presence. The same traffic police who now monitor red light running and speeding in the vicinity of signalized intersections have a simpler task at roundabouts. Failure-to-yield is almost the only violation that can occur in a roundabout. Unlike stop sign and speed violations, which are symbolic most of the time, failure to yield is never victimless. This means more efficient use of traffic police forces where they count; it also means that there should be plenty of police resources available to enforce respect for crosswalks in roundabouts.
Opening of the first roundabout in a community is already a time of change. Such openings are usually accompanied by scads of publicity on how to use the roundabout. Part of such publicity must include a message that at these facilities crosswalk observance will be enforced. Then the police must follow up with some actual enforcement. A few weeks of pedestrian testers followed and cops lying-in-wait should send the message of behavior that is expected.
A tangible suggestion of what the access board's proposal should be:
The design of every new roundabout in a community shall carry a surcharge a of (fill in number) percent up to (Fill in amount of money) that the road authority must use for publicity, police and testers to train the public to use the roundabout in a safe and legal manner with special attention to yields to pedestrians.
Such publicity and training should include but not be limited to:
1. Explaining to the police chief that replacement of signals with roundabouts relieves police of enforcement of stops and substitutes yield requirements which are just as critical for a roundabout's proper operations as are stops for a signal.
2. Placement of temporary signs that emphasize yielding to pedestrians in crosswalks.
3. Printed brochures in public places and radio and TV ads that describe motorist obligations.
4. Literature aimed at pedestrians that emphasizes the importance of crossing roundabouts at the crosswalk.
5. Deployment of pedestrian testers shadowed by uniformed police. The testers can even be police. This is similar to the method where police in unmarked cars spot violators on the road and notify officers in marked cars who issue the citation.
The Access Board 's recommendation for pervasive roundabout ped signals is justified if we assume the best features of perpendicular intersections and the worst features (including driver behavior) of roundabouts. The above recommendation seeks to effect the best features of roundabouts. The roundabout at its best is safer than a signalized intersection for any kind of pedestrian AND motorist.
There are also some things worth mentioning about the side-effects and extremely small cost-effectiveness of the would-be signals as proposed by the Access Board.
In terms of reasonableness of application, the universe in which the pedestrian signals would provide any benefit are very narrow. It would be under the following circumstances:
1. There is a blind pedestrian at the roundabout.
2. Such blind pedestrian doesn't have a dog.
3. The roundabout is busy enough that gaps are not obvious to his/her ears. (There may be NO cars present).
4.. The roundabout is not busy enough to slow speeds to a point where all drivers will observe the crosswalk.
This is a very tight set of conditions to provide at massive expense solution, and certainly stretches the limits of the meaning of reasonable accommodation. In contrast the pervasive signalization requirement offers the following negative side-effects:
1. More injuries and loss of life at the signals that will continue to be built at locations where roundabouts would have been affordable but for the required ped signals.
2. Rear end crashes at roundabouts where pedestrians unnecessarily activated the signals.
3. Increased delay because of persistence of red display after pedestrian has crossed.
4. Fewer pedestrian facilities, e.i. sidewalks and crosswalks at roundabouts.
5. Decreased safety in general for persons who are blind.
6. The death blow to respect for pedestrians in traffic.
Items number 1 through 3 above are well known already. I explain items 4 and 5 and 6 below.
4. Fewer pedestrian facilities. Proposed item 1105.6 requires the actuated signals only "where pedestrian crosswalks and pedestrian facilities are provided at roundabouts. " If you really want the roundabout but can't afford it with the signals, leave out the sidewalk. Now ALL pedestrians are worse off. There must be a specification somewhere describing where a sidewalk is required, but everybody knows how to play the specs game. The temptation to decide that a sidewalk is not required will be strong if the sidewalk involves $100,000 in
5. Decreased safety in general for persons with visual impairments. . This is not a simple trade-off between people in cars whose overall safety is enhanced vs. blind pedestrians whose safety is decreased. Although the Access Boards proposed measure may increase safety and access for blind pedestrians, these are people who do not spend 24 hours a day as pedestrians without any interest in the survivability of motor vehicle users. . They are also passengers in motor vehicles at times. Also the blind persons' friends, drivers, plumbers, mail carriers and everyone else with whom they interact gains enhanced survivability in motor cars when a roundabout is built instead of a signal. Therefore the blind person has a substantial interest as a member of a whole community not only for their own direct safety but for those in society around them. Everyone who interacts with the blind person, including the blind person themself benefits from the increased safety of the roundabout.
If this proposal is adopted, the blind persons will also benefit from police presence at non-roundabout locations. This notion is expanded in the following section.
6. The death blow to respect for pedestrians in traffic.
Some people will say that these signals are needed because respect for pedestrians is already dead. I submit that these signals will insure that such respect will never return. On the good side of things, emphasis of ped laws at roundabouts as herein proposed can become a beachhead for expanding enforcement to other locations. (Note again the freed-up police time as roundabouts replace signals) No matter what happens at major intersections, the majority of road crossings will remain without signal protection.
Roundabouts contain features (unnecessary to mention here) that are the best achievable for pedestrian consideration. If we can't expect drivers to yield to pedestrians at roundabouts, where will they yield to them? The answer is NOWHERE.
Pedestrian and walkability advocates have complained for a long time that drivers do not show pedestrians respect. This is coupled with the fact that the pedestrian laws are rarely if ever enforced. If the American community throws in the towel now and ASSERTS that a driver has to see a big glowing red ball in order to stop for a pedestrian, we can forget about ever re-asserting pedestrian consideration into our driving behavioral culture.
The blossoming of roundabouts is an opportunity to re-assert a pedestrian-aware culture on Americans, not to throw it away.
Related suggestion: Find ways to equip pedestrians to be more attention-getting to motorists.
There are technical opportunities to improve the signals that pedestrians send. Do blind people still walk streets with a non-illuminated red-tipped cane? Aren't there LED devices that the blind people can carry that will alert cars positively to their presence? There must be economical ways to put the signalizing power in the hands of the people who need it, rather than outfit the intersection at great expense in case a person in need comes along.
In fact, Dan Burden of Walkable Communities present slides of a low-tech device in one city. There are red flags on short sticks in umbrella holders at both ends of a non-signalized urban crosswalk. . The pedestrian uses the flag to signal an intent to cross. The person carries the flag across the street and leaves it in the holder on the other side.
In a few years we may be able to equip cars and blind pedestrians with transmitters to send signals that would replace the absent visual knowledge of car movements. Such as-needed features are by their nature more economical and more reliable than sweeping general "solutions."
The debate over pedestrians and yielding should be part of the bigger issue of where traffic law enforcement has gone. The big enforcement actions now are red-light running, speeding and stop sign violations. Without demeaning the importance of such control devices, enforcement of these laws is usually symbolic, as mentioned earlier. That is, most of the time someone violates a stop or speed limit, there is no potential victim. It is easy for police to go to a place where most people "speed" and hand out tickets. It is easy to sit by a stop sign and find people who only came to a rolling stop even with no opposing traffic in sight. . In absence of a victim at the moment, the safety benefit of these enforcement actions is unknown. That is because we don't really know whether the rolling-stop driver would have yielded to an opposing vehicle or pedestrian. The speeder may be violating a politically low speed limit and might very well slow down when conditions warrant.
Implementation of roundabouts without signals coupled with yield-to-pedestrian enforcement emphasizes driver behavior where it counts. If there is no would-be victim, no the driver may proceed ahead.
A quote that followed a tragedy from Michigan illustrates how far we have gone from a culture of responsible responsive driver behavior. In August 2002 a driver hit a construction sign on the shoulder of an active highway work zone The sign hit two members of a crew, killing one and seriously injuring the other. The Detroit News (Macomb Section, 8-14-2002) quoted the director of safety services for the Michigan Road Builders Association thus: "For some reason, people are not getting the message that these are human beings out there, not just barrels with arms."... Maybe this is because drivers have been trained to consider lights and signs in front of them as more important than people.
Comments of Arthur Slabosky, P.E.
Michigan Department of Transportation
Deborah Brown, October 22, 2002
Many of the items in the draft guidelines for public rights-of-way are
premature, and many will not help the problem of public access for blind
pedestrians.
I am a member of the National Federation of the Blind living and working in
the Washington area. I have previously lived in south Florida, where there
are no sidewalks. I moved to the Washington area mainly because of improved
pedestrian access.
I appreciate the advocacy for the 3 feet
signals. This is the kind of requirement that would benefit all pedestrians.
No disability accommodations will help pedestrians if there are no signals
or designated pedestrian zones in the first place. Creating expensive
requirements for access may result in a decision not to signalize an
intersection or not to provide sidewalks on the grounds that these
requirements are too expensive. It is also pointless to have a politically
correct ramped, marked, and signalized intersection which is surrounded by
streets that cannot be navigated or crossed.
About intersection design: Poorly designed ramps are a problem for blind
pedestrians. It is better for the ramp to have steeper sides that can be
felt. Also, an ambulatory blind pedestrian is more likely to stay out of a
wheelchair user's way if he does not feel he must stand inside the ramped
area to be assured of crossing the street in the crosswalks.
The issue of raising the street level at intersections is an interesting
one. The main reason we want cars to slow down is to make the roads safe for
pedestrians and other drivers. Raising the street level to the level of the
sidewalk may make it unsafe for blind pedestrians. Why should law-abiding
citizens have to make this accommodation to criminals?
On accessible pedestrian signals: The rule for blind pedestrians is that
when the parallel traffic moves, the blind pedestrian moves. If this rule
can be applied safely, no APS is needed. (Of course this rule cannot be
applied 100% safely because not all drivers are law-abiding. We can never
hope to protect pedestrians or any other group from people who break the
law.)
APSs are complicated to use; therefore, the complexity of the
intersection
must merit the use of a complicated tool like an APS. For example, in
Montgomery County, Maryland, an ordinary four-way intersection, Fenton Street
and Wayne Avenue, has an APS. Anyone wishing to use the APS must find the
button using the locator tone, and then either listen for the signal or feel
the vibrotactile indicator. If the APS is not correctly placed, the
vibrotactile indicator is useless. Any blind pedestrian not using the APS
simply listens to the traffic. Anyone who could not manage to cross the
street without the APS could not cross it with the APS, making the APS
unnecessary.
The design of APSs is made much more complicated than necessary by the
presence of the locator tone. Locator tones are necessary because of
misplacement of the APS. Simply requiring the APS to be located within reach
of the pedestrian waiting to cross the street would make locator tones
unnecessary and APSs much more useful. Poor placement also makes the APS
much less useful because the sound is often coming from behind the person
crossing the street.
APSs should be installed only where the normal rules of street-crossing would
not apply. Examples might be (1) where there is little or no parallel
traffic; (2) where a pedestrian is given a walk signal ahead of the parallel
traffic; (3) where the length of the signal is long enough to cross only
when a pedestrian-activated signal is used. How would a blind pedestrian
know if a pushbutton APS is present without a locator tone? If a pole with a
signal is properly placed, the blind pedestrian would simply look at each new
intersection to find the signal.
Detectable warnings: I am concerned about the use of textures to send
messages. Does the textured surface mean "Walk here," "Don't walk here," or
nothing at all? It is preferable to use grass or sand, or some nonpaved
surface, if a barrier is intended.
Some people have recommended that textured surfaces be used only when a
surface is perceived as flat.
However, it is not the actual slope of the ramp, but the unnatural feel of
it, that tells a blind pedestrian that an area is a street crossing (in
addition to traffic noise). If the surrounding terrain is hilly, a gentle
slope is no different from surrounding areas. If the surrounding terrain
is flat, a gentle slope is quite noticeable. I recommend that other methods,
such as properly designed curb cuts, be used to indicate street crossings.
In Montgomery County wheelchair users are troubled by brick streets in the
downtown Rockville area. I know that many wheelchair users do not complain
about truncated domes, but I believe they are simply being courteous about
what they perceive to be someone else's access need. I fail to see how a
textured surface will be maintained through rain, snow, dirt and traffic.
I believe that many of the accommodations that will help blind pedestrians
are those that will help all pedestrians. These include (1) increasing the
timing on walk signals; (2) taking into account the auditory environment
when determining where to place pedestrian signals; (3) holding drivers
accountable for following the laws of the road; (4) providing public
education to all citizens, including those with disabilities, about
safe travel. Montgomery County, Maryland, where I live, is taking
initiatives in defending the rights of pedestrians. Without the human
interest in the issue, all fancy gadgets will simply cost money and fail to
improve the situation.
the APS is not necessary.
Paul Plotas, P.E., PTOE, October 24, 2002
Re: Draft Guidelines for Accessible Public Right-of-Way (June 17, 2002) Roundabout Alternative Design Strategies
Dear Access Board:
Although I certainly would not classify myself as a roundabout expert, I am a practitioner of traffic engineering with 16 years of experience. During my review of the "Draft Guidelines for Accessible Public Rights-of Way (June 17, 2002)", the following passage in particular caught my attention:
To provide safer crossing at roundabouts, the draft guidelines would require pedestrian activated crossing signals at each roundabout crosswalk, including those at splitter islands. (The draft guidelines would ensure that such signals are usable b with vision impairments under requirements in section 1106 discussed below.) Although roundabouts are typically used to avoid signalization, the Board is not aware of alternatives that would allow safe passage for pedestrians with disabilities. Aside from accessibility, the use of roundabouts in areas of high pedestrian use has been questioned 4 some in the industry. Requiring the signal to be pedestrian activated may help limit the impact on traffic flow. Signal technologies are available that can further minimized the impact, such as devices that halt traffic only while a pedestrian is in the crosswalk. The Board seeks information on alternative design strategies and available technologies that can improve access at roundabouts for persons with disabilities, particular those with vision impairments.
I developed the attached summary of my thoughts on this subject and respectfully submit it for your review.
Please give me a call at [...] if you would like to discuss my thoughts further.
Very truly yours,
Paul Plotas, PE, PTOE
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Section 1 ? Introduction
Introduction
All at-grade pedestrian crossings of roadways are handled in one of the following two ways:
Vehicular traffic is stopped, allowing the pedestrians to cross ? example: signalized intersections
Pedestrians judgment determines appropriate crossing opportunities ? example: unsignalized intersections
Typically, in both cases vehicles are already expecting to stop at an intersection and pedestrian crossings are accommodated. Roundabouts present a different challenge since vehicular traffic at the egress crosswalks will never be stopping for other vehicles, see Figure 1. Additionally, roundabouts present a particular challenge to visually impaired pedestrians since the geometrics of a roundabout distort audio information from vehicular traffic giving unclear audio clues. To aid pedestrians at roundabouts, one can either attempt to control vehicular traffic or improve the information provided to pedestrians. This report discusses these two alternatives.
Referring to Figure 1, for the purposes of the following discussion, it is assumed that the pedestrian crosswalk is located approximately I to 2 car lengths from the edge of the central circle, which is the typical layout.
Alternatives
In this section various roundabout alternatives for both controlling vehicular traffic and for improving information available to pedestrians will briefly be explored.
Control Vehicular Traffic
There are at least four alternatives available to control vehicular traffic and give pedestrians the right-of-way at a roundabout egress pedestrian crossing.
a. Stop sign
b. Yield sign
c. Traffic signal
d. No control/Understanding that vehicle driver yields right-of-way to pedestrian
a. A stop sign alternative breaks the basic principals of roundabouts: all traffic control of a roundabout is yield controlled. Additionally, with low pedestrian traffic, stop signs will serve no useful purpose the majority of the time, will eventually be ignored by drivers, and will eventually function as a yield sign, and probably as an uncontrolled intersection.
b. As discussed for the sop sign alternative, at low pedestrian volume locations, vehicle drivers will also eventually ignore the yield sign, resulting in an uncontrolled intersection.
c. A third method for controlling vehicles at the egress pedestrian crossing is a traffic signal, however, two issues immediately come to mind. The first is the issue that there is only storage for up to two vehicles before additional vehicles in the queue impede vehicular flow around the roundabout. Even with minimum timings for a signal, a roundabout with relatively low vehicular volumes will experience some blockage.
Having the call for the signal solely dependent on pedestrian demand without regard to vehicular flow in the roundabout could have significant impacts to the capacity of the roundabout. It may be possible to place additional vehicle detectors strategically about the roundabout to delay the pedestrian call to a convenient time for vehicles; however, additional study will be required to determine if a suitable location is actually available.
The second issue that comes to mind with signalized control is driver expectation, especially with low pedestrian volume roundabouts. If a driver continuously meets a green indication at a signal, driver expectation is that a green signal will be met every time. My personal observations are that at low pedestrian volume, mid-block, stand alone pedestrian signals, it is the combination of the physical person and the signal that alert drivers to the signal. My personal observations are that most pedestrians instinctively realize this and will not begin to cross a road, even with the signal giving the right- of-way, until they visually receive confirmation that vehicles are stopping. Sight distance for the mid-block pedestrian signal is very important. Although the same sight distance may be available at a roundabout, the curvature of the intersection at times focuses drivers' attention on negotiating the curves of the road and away from the distant cross walk. The bottom line of this discussion is that due to driver expectations, a signalized crossing could actually give visually impaired pedestrians a false sense of security, and further study is necessary to determine if this is true.
d. Based on the discussion above, the final alternative, No control/Understanding that driver yields right-of-way to pedestrian is the alternative that the unsignalized alternatives default to, particularly at locations with low pedestrian volumes.
Control Pedestrian Traffic
There are at least two alternatives to control pedestrians while maintaining virtually free-flow conditions for vehicular traffic.
a. No control, pedestrian judgment determines acceptable gaps
b. "All Clear" Signal to pedestrians
a. Due to distorted sound the no control alternative is unacceptable.
b. The concept for the "All Clear" alternative is that vehicle detectors can be placed in the pavement upstream of the crosswalk as shown on Figure 2. The upstream detector could be coordinated with a pair of downstream detectors to determine when no vehicles are within the clear zone. When no vehicles are within the clear zone pedestrians would be given an "All Clear" signal.
While it is possible to build such a system, the following issues deserve additional research.
1. Do pedestrians have enough time to cross the egress lane in the scenario where a vehicle is just before the detector just as the pedestrian steps off the curb?
2. Is it prudent to depend on technology to this extent to determine when conditions are all clear?
3. What liability is involved with this alternative? (Is it really any different from a standard signalized intersection?)
Conclusions
The following problem with roundabouts has been identified: the circular portion of the roundabout creates confusing sound patterns. Being able to clearly read these sound patterns is essential for visually impaired pedestrians to safely cross the road. While it is possible to control vehicular traffic to enable pedestrians to cross, it is not obvious, at least to me, that the pedestrians will be safer. Instead of trying to control the vehicular traffic, I propose to improve the information available to pedestrians. It appears that by strategically placing detectors visually impaired pedestrians can have the same information as all other pedestrians to make informed decisions about when to cross.
J. Tom Coleman Jr., October 25, 2002
Georgia Department of Transportation
Subject: Comments on the proposed "Guidelines for Accessible Public Rights-of-Way"
Dear Mr. Windley:
The Georgia Department of Transportation (GDOT) completely agrees with the concept of the ADA that no person should be denied services because that person has a disability. The GDOT has reviewed the proposed "Guidelines for Accessible Public Rights-of-Way" dated June 17, 2002. Based on the review, some of the requirements should be given further consideration before implementation.
The GDOT has also reviewed the AASHTO comments on the proposed ADA guidelines and agree with their recommendations. The GDOT comments were developed independently but address many of the same issues.
Several of the proposed requirements will have major impacts on project design on required Rights-of-Way. If the plans for a project are near completion, the plans would need to be changed, the Environmental Document would need to be reevaluated and additional R/W would need to be acquired which will result in a considerable delay in letting the project for construction. When the text of the document has been finalized, the required implementation date should be given careful consideration.
Attached are the GDOT comments on the proposed ADA guidelines for public Rights-of-Way.
Sincerely,
Signed by Commissioner Coleman
J. Tom Coleman Jr.
Commissioner
Attachments
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Comments on the Proposed ADA Guidelines for Accessible Public R/W
The Georgian Department of Transportation (GDOT) completely agrees with the concept of the ADA that no person should be denied services because that person has a disability. However, the proposed "Guidelines for Accessible Public Rights-of-Way" dated June 17,2002 specify some requirements that we feel should be given further consideration before implementation.
The GDOT has reviewed the AASHTO comments on the Proposed ADA Guidelines and agrees with their recommendations. The GDOT comments were developed independently but address many of the same issues.
Overview:
Several of the major issues are addressed in general in the Synopsis. More specific comments are addressed in the responses to the individual sections.
The ACCESS BOARD has received many comments that have been posted on their website.
The comments seemed to fit into two categories. The first type response was from persons with disabilities or groups representing persons with disabilities. These comments were generally short and contained references to specific items. Sometimes the comments were in support of or opposed to an item. For example, the visually impaired groups generally supported the detectable warnings at the bottom of the ramps and the groups representing persons with mobility and balance disabilities considered the detectable warnings a tripping hazard to walkers and an inconvenience to persons in wheelchairs. The varied responses from the persons with different viewpoints indicate that there is no solution that satisfies all users in all situations.
The second type of response was from persons or groups that will implement the design requirements. These responses were generally longer and pointed out that many of the requirements would have consequences that the Access Board and the individual members of the Board had not intended or anticipated. Often these responses could be summarized by the following statement: Change the "design requirements" to "design recommendations." This will allow the Engineer to consider all the factors influencing the area in the design of the project.
Following the same thought, as written the only allowable reason for not meeting ALL the design requirements is if it is "Technically Infeasible" to meet the requirements. (And this is only allowed on "alterations", new construction must meet all the Design Requirements.) Technically Infeasible is not defined in the ROW section but a definition is needed. Also, the DOJ Title II Technical Assistance Manual specifically states that when determining Technical Infeasibility, cost is not to be considered. When a roadway type project is being constructed on the R/W, and enough money is available, anything can be built, therefore nothing is technically infeasible. In a slight contradiction, the DOJ CFR states that if you have to remove a load bearing wall in a building then complying with the design requirements is Technically Infeasible. More guidance is required.
The Dept. of Justice, Housing and Urban Development, Dept. of Interior, Dept. of Labor and possibly other agencies have included guidance for not meeting the ADA design requirements in their respective CFRs. Some of the guidance is not in complete agreement but generally they allow deviation from the Design Requirements due to "Technical Infeasibility", "Conflicts with existing law to protect historic resources", "Disproportionality" of the cost of satisfying all the ADA design requirements with the project cost, "Undue Administrative Burden", "Undue Financial Burden" and "Fundamental Alteration of the Nature of the Service". The various CFRs generally require that the head of the agency approve the deviation from the Design Requirements. The FHWA CFR simply states that "wheel chair ramps and other features that may be required to meet ADA are required". The FHWA is the agency that oversees most federal monies spent on public R/W. The FHWA has not provided any usable guidance (that the ADA required them to provide by 1992) on when exceptions to the ADA Design Requirements are justified therefore, the guidance must be included in this document. Also, it is unclear whether guidance included it this document or guidance included in the various CFRs will control.
To follow up on the "unintended consequences" of these requirements, if cost cannot be considered when determining technical infeasibility and if the design parameters are adopted exactly as written, many urban projects will not be built. The disruption to the adjacent properties and the surrounding communities will be too severe. The end result of these requirements (to provide a high level of accessibility) will be less accessibility in areas that would have been improved. The changes to the proposed ADA Design Requirements that the GDOT proposes are to ensure that this is not the result of the ADA Design Requirements.
Whether or not cost can be DIRECTLY considered when determining whether it is necessary to comply with the ADA Design Requirements, the cost of compliance WILL be considered. The funding of projects for new roadways and roadway improvements may seem to be infinite to persons not familiar with the magnitude of these projects, however there is a limited amount of money available and an infinite demand for these funds. Also, the funding is usually divided into categories and specified for certain uses. (For example, resurfacing, intersection improvement, Interstate Highways, bridge rehabilitation, etc.) If one project is very costly, either the project will not be constructed or other projects in that funding category will not be constructed in order to fund the project that is constructed.
The GDOT believes that the intent of the ADA was to provide better access (and service) to everyone (including persons with disabilities), not lower the level of access (and service) to everyone equally.
There is an article in the 9/19/02 edition of the Govt. Computer News about problems providing GIS maps over the Internet. The information has to be provided in usable form to all users to comply with Section 508 of the 1998 ADA Amendment. It would be unfortunate (but not unexpected) if this service was withheld from all citizens in order to comply with the ADA. There is no technology available for blind users to obtain the same information (in an easily useable format) that sighted users obtain, therefore the result may be less service for everyone. (Including the blind person that previously had a sighted friend or family member obtain and interpret the information.)
The ADA does not require that sidewalks be included in roadway projects but if sidewalks are provided the ADA requires that they must be useable by all users. If this premise is used to judge the requirements listed in the "Guidelines for Accessible Public Rights-of-Way", some of the requirements do not appear to fall under ADA regulation. For example, requirements for traffic signals where none would be required except by these guidelines. The GDOT recommends that all the requirements be reviewed and any requirements that are not definitely issues covered by the ADA be removed or changed to recommendations.
There appear to be some discrepancies in the commentary and between the commentary and the proposed text. For example: Commentary 1102.1 "The draft guidelines would not require the provision of sidewalks, street crossings, street furniture, parking or other pedestrian elements where none are intended." Commentary 1105.2 - Crosswalks - "?specifications apply to both marked and unmarked crossings, wherever pedestrian travel is not prohibited." TEXT 1102.1 "All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities ? shall comply with Chapter 11.
The final document should be clear and concise. The commentary provided should clarify and provide examples for the Design Requirements. All discrepancies in the commentary (from the text of the requirements) should be omitted or clearly noted as minority opinions.
There are also some discrepancies between the proposed Chapter 11 requirements the previous sections (Ramps are also addressed in Chapter 405 and Curb Ramps are also addressed in Chapter 406). If the requirements are different on public R/W it should be noted in the other chapters whenever there is a difference.
Several of the design requirements for cross slope, grade breaks, etc. are covered in "1103 Pedestrian Access Route". The same requirements are duplicated other sections (ramps, transitions, crosswalks etc.). Consider eliminating the requirements from the other sections since by definition these areas are part of the "Pedestrian Access Route".
The guideline commentary stated "guidelines depart from the advisory committee's report in several areas, which are detailed in the following discussion." There are several items that differ from the Jan. 2001 report in the proposed text that are not discussed. (Possibly "Changes in level" (1103.8) should be "Grade Breaks" and "Grade Breaks" (1104.3.40) should be omitted.)
As an aside: There was an ADA seminar presented in Atlanta last year. Several of members of the Public R/W committee were present. Several questions were posed about the effect of implementing various design parameters. A common answer was "Oh, you would not have to meet that requirement, it isn't reasonable in that case". As written, the requirements do not allow for that solution. The only acceptable solution is "MEET THE DESIGN PARAMETERS".
The SCOPING REQUIREMENTS section needs to be expanded and clarified. Chapter 1102.2.2 states "Where existing elements or spaces in the public R/W are altered, each altered element shall comply with the applicable provisions of Chapter 11."
When a road is resurfaced the crosswalks are altered. This provision requires the cross slope to be less that 2.08% in the crosswalk. This requires that the intersection be "tabletopped" and requires vertical grade changes all of the approach roadways. This requirement will essentially prohibit any resurfacing projects in urban areas where any existing grade or crossslope in the intersection exceeds 2%. (Even if the project would remove severe ruts, vertical lips, and potholes in the crosswalk that make the existing crosswalk unusable for pedestrians with disabilities.)
The "tabletopping requirement will have severe negative impacts on all projects where the natural terrain slopes exceed 2%.
The commentary on 1105.2 - Crosswalks - that states that "?specifications apply to both marked and unmarked crossings, wherever pedestrian travel is not prohibited." If this is intended to be a true statement, it should be reconsidered. Other sections require a pedestrian activated signal where a right turn slip lane is present. A "slip lane" definition should be added but the figures show a right turn movement separated by an island. This would require a traffic signal at nearly every intersection on a multilane road. Also, when a business obtains a driveway access permit on a corner, GDOT requires the addition of a right turn lane. This provision would also require a signal at the intersection (which the developer would be happy to do since it would increase the value of his business). The MUTCD has very specific warrants for the installation of signals that are based on years of experience to provide the best compromise between motorist safety, pedestrian safety and overall usability of the Rights-of-Way. If the Access Board decides that these warrants should be ignored, the decision to ignore them should be based on documented research.
Most GDOT projects are "alterations" in some (or many) respects. For instance even a new roadway on a new location generally follows the existing terrain and crosses existing roads that have homes and businesses near the newly created intersection (or interchange). In the design process we attempt to minimize the impact on these homes and businesses while providing a road that is safe for the traveling public.
As written, the guidelines only allow a deviation from the design parameters when the project is an "alteration" (or where an "addition" project connects with existing construction) and when it is "technically infeasible" to meet the requirement. (Although the Chapter 2 Scoping Requirements in the ABA/ADA final draft commentary (p16) mentions "disproportionality" it is not mentioned in the actual text.)
Additional guidance on what is "technically infeasible" should be provided. When building a road it is usually "technically feasible" to do anything if enough money is available.
The 1999 publication "Accessible Rights of Way, A Design Guide" has a more realistic approach for not meeting the ADA design requirements. "Technically Infeasible", "Fundamental Alteration of the Nature of the Project" and "Undue Burden" were mentioned as justification for not fully complying with the design requirements.
Note that the GDOT has a finite amount of money available. If complying with all of the ADA design parameters adds excessive cost to a project then fewer projects will be built. The overall effect will be fewer projects constructed and fewer accessibility improvements therefore there will be less overall benefit provided to disabled users. (For example, table-topping an intersection in a lightly populated area as part of a major roadway reconstruction project could easily cost an additional $ 2 million on a $20 million contract. That $ 2 million could upgrade 2 or 3 intersections in a highly urbanized area with large numbers of pedestrians.)
The CFR for the Dept. of Justice, Labor, HUD give guidelines on when exceptions to the ADA design parameters are justified. (But the justifications are not the same.) In order to provide consistency in implementing these requirements this information should be included in the Accessibility Guidelines.
For example:
CFR 35.150 states:
A public entity shall operate each service, program, or activity so that the service, program, or activity, when viewed in its entirety, is readily accessible to and usable by individuals with disabilities. This paragraph does not --
(1) Necessarily require a public entity to make each of its existing facilities accessible to and usable by individuals with disabilities;
(2) Require a public entity to take any action that would threaten or destroy the historic significance of an historic property; or
(3) Require a public entity to take any action that it can demonstrate would result in a fundamental alteration in the nature of a service, program, or activity or in undue financial and administrative burdens. In those circumstances where personnel of the public entity believe that the proposed action would fundamentally alter the service, program, or activity or would result in undue financial and administrative burdens, a public entity has the burden of proving that compliance with § 35.150(a) of this part would result in such alteration or burdens. The decision that compliance would result in such alteration or burdens must be made by the head of a public entity or his or her designee after considering all resources available for use in the funding and operation of the service, program, or activity, and must be accompanied by a written statement of the reasons for reaching that conclusion. If an action would result in such an alteration or such burdens, a public entity shall take any other action that would not result in such an alteration or such burdens but would nevertheless ensure that individuals with disabilities receive the benefits or services provided by the public entity.
The GDOT recommends the wording in this section be expanded to address situations where it is not necessary to meet all the design requirements and included in these guidelines. This section should describe and give guidance on "Technically Infeasible", "Fundamental Alteration of the Nature of the Project", "Undue Burden", Undue Financial Burden", and "Disproportionality". The section should also address how to handle conflicts with other Federal laws that deal with preserving historical and archeological sites, wetlands, and other natural resources. This section should also address the level of documentation and level of approval required.
Making the design parameters "recommendations" instead of "requirements" would solve many of these problems.
As written it is not defined precisely where pedestrians must be accommodated on the public R/W. This should be addressed.
GDOT Commentary: It seems that the disruption to the surrounding area, cost, and impacts on the safety of the motorists should be weighed against the need for pedestrian accommodation. This should be an Engineering Decision not a mandated requirement. The GDOT often uses curb and gutter and sidewalks to minimize the R/W requirements (or stay on existing R/W) not to provide pedestrian accommodations. Without relaxation of the design requirements (or allowing engineering judgement) many projects will not be built. The projects improve usability (even though they might not meet all the design requirements) for disabled users.
When the text of the document has been finalized, the required implementation date should be given careful consideration. Several of the proposed requirements will have major impacts on the design of the project and on the required Rights-of-Way. A lead time of 2 years would not be unreasonable for full compliance with some of the proposed requirements. This would allow time to reevaluate the Environmental Document, change the plans and acquire the additional Rights-of-Way.
The following is the Text of the Draft Guidelines for Accessible Public Rights-of-Way with GDOT comments and recommended changes noted.
1101 Application and Administration (referenced standards and defined terms)
1102 Scoping Requirements
1103 Pedestrian Access Route
1104 Curb Ramps and Blended Transitions
1105 Pedestrian Crossings
1106 Accessible Pedestrian Signal Systems
1107 Street Furniture
1108 Detectable Warning Surfaces
1109 On-Street Parking
1110 Call Boxes
1111 Alternate Circulation Path
1101 Application and Administration
1101.1 General. For the purposes of these requirements, the terms listed in section 1101.3 shall have the indicated meaning.
1101.2 Referenced Standards.
1101.2.1 MUTCD. Copies of the referenced standards may be obtained on-line from the Federal Highway Administration at http://mutcd.fhwa.dot.gov/.
MUTCD 2000-Millennium Edition Manual on Uniform Traffic Control Devices.
GDOT Comment - Add AASHTO 2001 Design Guide to the list on standards
1101.3 Defined Terms.
GDOT Comments -
Add definitions for:
Slip Ramp
Perpendicular Curb Ramp
Parallel Curb Ramp
Addition
Alteration
Blended Transition
Technically infeasible
Disproportionality
Undue Financial Burden
Undue Administrative Burden
Fundamental Alteration of the Nature of the Project
Agency that approves ADA design requirements exceptions
GDOT Recommended Definitions -
New facility: A new roadway on new alignment where the horizontal or vertical alignment, or crossslope are not controlled by an existing facility.
Alteration: A project or portion of a project where the horizontal or vertical alignment or crossslope of the roadway are controlled by an existing facility is an "alteration". No alterations may be done that have the effect of decreasing accessibility.
Fundamental alteration in the nature of a project: An improvement that changes the basic concept for the project.
Program Accessibility: If the facility is accessible to people with disabilities through another method or alternative routes, the facility may not be required to comply with all ADA design parameters. Note that curb cut ramps are specifically named as a required element and cannot be excluded.
Undue financial burden: If the cost of providing or maintaining a facility that fully complies with ADA design parameters is prohibitively expensive or the required future funding is not guaranteed, full compliance with the ADA design parameters may be considered an undue financial burden.
For small projects, if complete compliance with the ADA design parameters adds over 20% to the total cost of the project, complete compliance is not required (but should be considered). However, the facilities shall be improved to the maximum extent possible using the 20% additional costs.
For large projects, if complete compliance with the ADA design parameters adds over 20% to the cost of the area of the project where the improvement is needed, complete compliance is not required (but should be considered). However, the facilities shall be improved to the maximum extent possible using the 20% additional costs. (This is intended to address major alteration projects where small areas are not in compliance with the ADA design parameters.)
Disproportional: If the cost of constructing a project (or portion of a project) that fully complies with ADA design parameters is prohibitively expensive full compliance with the ADA design parameters may be considered Disproportional.
For small projects, if complete compliance with the ADA design parameters adds over 20% to the total cost of the project, complete compliance is not required (but should be considered). However, the facilities shall be improved to the maximum extent possible using the 20% additional costs.
For large projects, if complete compliance with the ADA design parameters adds over 20% to the cost of the area of the project where the improvement is needed, complete compliance is not required (but should be considered). However, the project shall meet the ADA Design Requirements to the maximum extent possible using the 20% additional costs. (This is intended to address major projects where small areas are not in compliance with the ADA design parameters.)
Technically infeasible: If complying with the ADA design parameters require that the roadway alignment, grade, sight distance or clear zone not to meet AASHTO desirable requirements then complying with ADA design parameters is "technically infeasible".
Conflicts with other laws that protect historical, cultural, or natural resources make complying with ADA design parameters "technically infeasible".
Note that if complete compliance is "technically infeasible" the facility shall be modified to comply with ADA design parameters to the "maximum extent possible".
Accessible Pedestrian Signal. A device that communicates information about the pedestrian WALK phase in non-visual format.
Accessible Route. A continuous, unobstructed path that complies with Chapter 4.
GDOT Comment:
The definition of Accessible Route should be clarified. It is not clear whether shoulders are an "accessible route" on a road with no curb and gutter and/or no sidewalk.
Channelizing Island. Curbed or painted area outside the vehicular path that is provided to separate and direct traffic movement, which also may serve as a refuge for pedestrians.
Cross Slope. The slope that is perpendicular to the direction of travel. This is usually called superelevation on curves in the public right-of-way (see superelevation).
Crosswalk. That part of a roadway at an intersection that is included within the extensions of the lateral lines of the sidewalks on opposite sides of the roadway, measured from the curbline or, in the absence of curbs, from the edges of the roadway or, in the absence of a sidewalk on one side of the roadway, the part of the roadway included within the extension of the lateral lines of the sidewalk at right angles to the centerline. Also, any portion of a roadway at an intersection or elsewhere that is distinctly indicated for pedestrian crossing by lines or other markings on the surface.
GDOT Comment:
The definition of crosswalk appears to say that a crosswalk is only present if there is sidewalk present or if there is a "marked" crosswalk. While this definition makes it easier to comply with the ADA Design Requirements, it appears to conflict with the text of in other sections of the requirements and with the commentary.
Curb Line. A line at the face of the curb that marks the transition between the sidewalk and the gutter or roadway.
Curb Ramp. A ramp cutting through a curb or built up to it.
Detectable Warning. A surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path.
Dynamic Envelope. The clearance required for a rail vehicle and its cargo overhang due to any combination of loading, lateral motion, or suspension failure.
Element. An architectural or mechanical component of a building, facility, space, site or public right-of-way.
Facility. All or any portion of buildings, structures, improvements, elements and pedestrian or vehicular routes located on a site or in a public right-of-way.
Grade. (See running slope).
Grade Break. The meeting line of two adjacent surfaces of different slope (grade).
Locator Tone. A repeating sound that identifies the location of the pedestrian push button.
Pedestrian Access Route. An accessible corridor for pedestrian use within the public right-of-way.
GDOT Recommended Definition
Pedestrian Access Route. An accessible route, designated by the responsible agency, for pedestrian use within the public right-of-way.
This will allow the "rural" projects to be excluded from ADA requirements.
Public Right-of-Way. Land or property, usually in a corridor, that is acquired for or devoted to transportation purposes.
Roundabout. A circular intersection that has yield control of entering traffic, channelized approaches, counterclockwise circulation, and appropriate geometric curvature to limit travel speeds on the circulatory roadway.
Running Slope. The slope that is parallel to the direction of travel expressed as a ratio of rise to run. In the public right-of-way, this is usually called grade, and is expressed in percent.
Sidewalk. That portion of a public right-of-way between the curb line or lateral line of a roadway and the adjacent property line that is improved for use by pedestrians.
GDOT Comment:
What does "improved for use by pedestrians" mean? We are concerned that this could be interpreted to mean shoulders on "rural" projects or the flat graded area behind the curb if no concrete sidewalk is present.
This definition is critical. For instance if the paved shoulder is a "sidewalk", the ADA design requirements apply to rural projects. The GDOT requires separate right turn lanes on multilane rural roads at all intersections as a safety feature to allow the right turning traffic to move out of the high speed travel lanes. These requirements would mandate that pedestrian activated signals with locator tones be provided at essentially all intersections.
Splitter Island. A flush or raised island that separates entering and exiting traffic in a roundabout.
Street Furniture. Elements in the public right-of-way that are intended for use by pedestrians.
Superelevation. Cross slope on a curve in the roadway (see cross slope).
Walk Interval. That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and its audible equivalent.
1102 Scoping Requirements
1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way shall comply with Chapter 11.
GDOT Recommended wording:
1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way that include provisions for pedestrians shall comply with Chapter 11.
GDOT Comment:
The SCOPING REQUIREMENTS need to be expanded and clarified. If the exceptions recommended in 1102.2.2 (specifically Fundamental Alteration of the Nature of a Project are not allowed, when a road is resurfaced the crosswalks are altered. This provision requires the cross slope to be less that 2.08% in the crosswalk. This requires that the intersection be "tabletopped" and requires vertical grade changes all of the approach roadways. This requirement will essentially prohibit any resurfacing projects in urban areas where any existing grade or crossslope in the intersection exceeds 2%. (Even if the project would remove severe ruts, vertical lips, and potholes in the crosswalk that make the existing crosswalk unusable for pedestrians with disabilities.)
The same situation will exist if a traffic signal needs to be upgraded. As written, a signal could not be upgraded to allow for protected pedestrian movements without "tabletopping" the intersection.
1102.2 Existing Public Rights-of-Way. Additions to existing public rights-of-way shall comply with 1102.2.1. Alterations to existing public rights-of-way shall comply with 1102.2.2.
1102.2.1 Additions. Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2.
1102.2.2 Alterations. Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11.
GDOT Comment: Define Spaces as used above.
EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible.
GDOT Recommended Wording
EXCEPTION: In alterations, the project shall comply with applicable provisions unless the following applies. If full compliance is not required, the alteration shall comply to the maximum extent feasible.
A public entity shall operate each service, program, or activity and construct each project so that the service, program, or activity, and constructed project when viewed in its entirety, is readily accessible to and usable by individuals with disabilities. This paragraph does not --
(1) Necessarily require a public entity to make all areas of its existing facilities accessible to and usable by individuals with disabilities; or
(2) Require a public entity to take any action that would threaten or destroy the historic significance of an historic property; or that conflict with other laws that protect natural or archeological resources or cemeteries; or
(3) Require a public entity to take any action that is technically infeasible; or
(4) Require a public entity to take any action that it can demonstrate would result in a fundamental alteration in the nature of a service, program, or activity or in undue financial and administrative burdens or in a fundamental alteration of the nature of the project. Also, if the additional cost of fully complying with the ADA Design Requirements exceeds 20% of the cost of the project in the area affected by the improvement, full compliance may be considered "Disproportional" to the cost of constructing that area of the project. In those circumstances where personnel of the public entity believe that the proposed action would fundamentally alter the project, service, program, or activity, or the cost is disproportional or would result in undue financial and administrative burdens, a public entity has the burden of proving that compliance would result in such alteration or burdens. The decision that compliance would result in such alteration or burdens must be made by the head of a public entity or his or her designee after considering all resources available for use in the funding and operation of the service, program, or activity, and must be documented by a written statement of the reasons for reaching that conclusion. If an action would result in such an alteration or such burdens, a public entity shall take any other action that would not result in such an alteration or such burdens but would nevertheless ensure that individuals with disabilities receive the benefits or services provided by the public entity.
1102.2.2.1 Extent of Application. An alteration of an existing element, space, or area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction.
1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way, below the requirements for new construction at the time of the alteration is prohibited.
GDOT Comment: As worded it appears redundant. The GDOT wording states that regardless of what exceptions may be approved the accessibility cannot be less that before the project was constructed.
GDOT Recommended wording:
1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way is prohibited.
1102.3 Alternate Circulation Path. An alternate circulation path complying with 1111 shall be provided whenever the existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary conditions.
GDOT Comment: The amount of time of the closure and the expected pedestrian usage should be a factor. As written this would require a pedestrian bridge to be constructed if the entire bridge had to be closed for just 10 minutes.
See other comments on 1111
1102.4 Sidewalks. Where sidewalks are provided, they shall contain a continuous pedestrian access route complying with 1103. The pedestrian access route shall connect to elements required to comply with Chapter 11.
1102.5 Protruding Objects. Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes.
1102.5.1 Protrusion Limits. Objects with leading edges more than 27 inches
EXCEPTION: Handrails shall be permitted to protrude 4-1/2 inches
1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps.
1102.5.3 Reduced Vertical Clearance. Guardrails or other barriers shall be provided where the vertical clearance is less than 80 inches
EXCEPTION: Door closers and door stops shall be permitted to be 78 inches
1102.6 Curb Ramps and Blended Transitions. A curb ramp or blended transition complying with 1104, or a combination of curb ramps and blended transitions, shall connect the pedestrian access routes to each street crossing within the width of each crosswalk.
1102.7 Pedestrian Signs. Signs for pedestrian use shall comply with 1102.7.
1102.7.1 Bus Route Identification. Bus route identification signs shall comply with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to the maximum extent practicable, bus route identification signs shall comply with 703.5.5. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with 703.2, and shall have rounded corners.
EXCEPTIONS 1: Bus schedules, timetables and maps that are posted at the bus stop or bus shelter shall not be required to comply with 1102.7.
2: Signs shall not be required to comply with 703.2 where audible signs are user- or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual.
1102.7.2 Informational Signs and Warning Signs. Informational signs and warning signs shall comply with 703.5.
1102.8 Pedestrian Crossings. Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, they shall comply with 1106.
1102.9 Street Furniture. Street furniture that is intended for use by pedestrians and installed on or adjacent to a sidewalk shall comply with 309 and 1107.
1102.10 Stairs. Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
1102.11 Handrails. Where provided, handrails shall comply with 505.
1102.12 Vertical Access. Where provided elevators shall comply with 407, limited-use/limited-application elevators shall comply with 408, and platform lifts shall comply with 410. Vertical access shall remain unlocked during the operating hours of the facility served.
1102.13 Bus Stops. Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with 810.3.
GDOT comment: The bus stop locations are determined (and often changed) by the local transit authority. The GDOT does not have control on where these are placed and often the bus stops a several locations along a block. In many areas that have bus service there is not space available to provide these landings at all bus stops without severe disruption of the community. Consider requiring one accessible bus landing per block or every ¼ mile.
1102.14 On-Street Parking. Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.
GDOT Comment: The requirement will generally be achievable. However many of the small towns in Georgia are built with a small square. The blocks are very short and the sidewalks are often elevated. In this situation the addition of the accessible parking space (and an access route to the elevated sidewalk) would eliminate most or all the remaining spaces in the block. This would effectively put the businesses on the Town Square out of business. Often the entrances to the businesses are not accessible from the sidewalk due to steps. This requirement would provide access to the sidewalk in front of the businesses but would not provide access to the business.
This is another example of where "Engineering Judgement" should be used instead of a mandated requirement.
1102.15 Passenger Loading Zones. Where passenger loading zones are provided, they shall connect to a pedestrian access route and shall provide a minimum of one passenger loading zone in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof, complying with 302, 503.2, 503.3, and 503.5.
1102.16 Call Boxes. Where provided, call boxes shall comply with 1110.
1103 Pedestrian Access Route
1103.1 General. Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103.
1103.2 Components. Pedestrian access routes shall consist of one or more of the following components: walking surfaces, ramps, curb ramps, blended transitions, crosswalks, pedestrian overpasses and underpasses, elevators, and platform lifts. All components of a pedestrian access route shall comply with the applicable portions of this chapter.
1103.3 Clear Width. The minimum clear width of a pedestrian access route shall be 48 inches
1103.4 Cross Slope. The cross slope of the pedestrian access route shall be 1:48
Also, see comments on crosswalks (which are a part of the pedestrian access route).
The requirement for a 1:48
1103.5 Grade. The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway.
EXCEPTION: The running slope of a pedestrian access route shall be permitted to be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 1:20
1103.6 Surfaces. The surfaces of the pedestrian access route shall comply with 302.
1103.7 Surface Gaps at Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the horizontal gap at the inner edge of each rail shall be constructed to the minimum dimension necessary to allow passage of railroad car wheel flanges and shall not exceed 2-½ inches (64 mm).
EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch
1103.7.1 Detectable Warnings. Where rail systems cross pedestrian facilities that are not shared with vehicular ways, a detectable warning shall be provided in compliance with 1108.
1103.8 Changes in Level. Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
GDOT Comment: 303 allows a ¼" max vertical lip, ¼" to ½" beveled on 1:2
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings.
GDOT Comment: What horizontal separation requirement? It is unclear what this means even if a horizontal separation requirement is specified.
1103.8.1 Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the surface of the pedestrian access route shall be level and flush with the top of the rail at the outer edge and between the rails.
1104 Curb Ramps and Blended Transitions
1104.1 General. Curb ramps and blended transitions shall comply with 1104.
1104.2 Types. Perpendicular curb ramps shall comply with 1104.2.1 and 1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended transitions shall comply with 1104.2.3 and 1104.3.
1104.2.1 Perpendicular Curb Ramps. Perpendicular curb ramps shall comply with 1104.2.1, and shall have a running slope that cuts through the curb at right angles or meets the gutter grade break at right angles.
1104.2.1.1 Running Slope. The running slope shall be 1:48
1104.2.1.2 Cross Slope. The cross slope shall be 1:48
EXCEPTION: This requirement shall not apply to mid-block crossings.
1104.2.1.3 Landing. A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.
EDITORIAL COMMENT: The cross slope and running grade requirements do not apply at mid-block crossings 1104.2.1.3). If "Engineering Judgement" cannot be used, all pedestrian crossings at intersections can be prohibited and mid-block crossings provided. Is this the intention of these requirements?
1104.2.1.4 Flares. Flared sides with a slope of 1:10
1104.2.2 Parallel Curb Ramps. Parallel curb ramps shall comply with 1104.2.2, and shall have a running slope that is in-line with the direction of sidewalk travel.
1104.2.2.1 Running Slope. The running slope shall be 1:48
EXCEPTION: A parallel curb ramp shall not be required to exceed 15 feet
1104.2.2.2 Cross Slope. The cross slope shall be 1:48
1104.2.2.3 Landing. A landing 48 inches
GDOT Comment: This is a major problem. See comments on crosswalk cross slope 1105.2.2. Since this area at the edge of the curb, this can sometimes be accomplished by increasing the radii at the corners to get this are away form the travel lanes to allow room for warping the slope, but this increases the length of the crosswalk. Consider that this will require tradeoffs for the pedestrian.
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.
1104.2.2.4 Diverging Sidewalks. Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments shall be protected with a barrier.
1104.2.3 Blended Transitions. Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
1104.3 Common Elements. Curb ramps and blended transitions shall comply with 1104.3.
1104.3.1 Width. The clear width of landings, blended transitions, and curb ramps, excluding flares, shall be 48 inches
1104.3.2 Detectable Warnings. Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.
1104.3.3 Surfaces. Surfaces of curb ramps, blended transitions, and landings shall comply with 302. Gratings, access covers, and other appurtenances shall not be located on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route.
1104.3.4 Grade Breaks. Grade breaks shall not be permitted on curb ramps, blended transitions, landings, and gutter areas within the pedestrian access route. Surface slopes that meet at grade breaks shall be flush.
GDOT comment: Where did this come from? It appears to be impossible to meet this requirement unless the entire intersection is on the same slope (no crown in the roadways). Also, does flush mean less than the 1/4" vertical lip allowed in the pedestrian access route?
1104.3.5 Changes in Level. Vertical changes in level shall not be permitted on curb ramps, blended transitions, landings, or gutter areas within the pedestrian access route.
GDOT comment: If the intent is to require no vertical lips (0" allowable) in these areas it is impossible to meet. If the ¼" allowed in the pedestrian access path it is OK this requirement is redundant.
1104.3.6 Counter Slopes. The counter slope of the gutter area or street at the foot of a curb ramp or blended transition shall be 1:20
GDOT comment: This is OK but it is not what the 2001 report recommended. A definition or picture of "counter slope" would be good.
1104.3.7 Clear Space. Beyond the curb line, a clear space of 48 inches
GDOT comment: The 4x4 clear area is required to begin beyond the curb line. Since the gutter slope only is required to be 5% or less in this area, Can the 4x4 area can include the gutter if the gutter slope is 2.08%? This should be clarified.
1105 Pedestrian Crossings
1105.1 General. Pedestrian crossings shall comply with 1105.
1105.2 Crosswalks. Crosswalks shall comply with 1105.2.
1105.2.1 Width. Marked crosswalks shall be 96 inches
1105.2.2 Cross Slope. The cross slope shall be 1:48
GDOT comment: This is a major problem, especially if reasonable grounds for exceptions are not provided. This requires "tabletopping" the intersection and adjusting the grades on the approaches. If one of the roads is in a curve where the superelevation is greater than 2.08% it requires a change in the horizontal alignment.
GDOT recommendation: Change "The cross slope shall" to "When practical the cross slope should".
EXCEPTION: This requirement shall not apply to mid-block crossings.
1105.2.3 Running Slope. The running slope shall be 1:20
GDOT comment: This is a problem, especially if reasonable grounds for exceptions are not provided and the cross slope requirements are changed. If the cross slope requirements are not change this requirement is meaningless and will not control. This requires changing the grade in the intersection and adjusting the grades on the approaches to less than 5 %. If one of the roads is in a curve where the superelevation is greater than 5% it requires a change in the horizontal alignment.
GDOT recommendation: Change "The running slope shall" to "When practical the cross slope should".
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
GDOT comment: Currently the GDOT normally uses 3.5 fps that was recommended in the Jan. 2001 report. The speed is reviewed on a case by case basis and 3.0 fps or sometime less is used depending on the type of the pedestrians at the intersection. It is possible to set the signal timing for a pedestrian speed of 3 feet
1105.4 Medians and Pedestrian Refuge Islands. Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying with 1104 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches
1105.4.1 Length. Where signal timing is inadequate for full crossing of all traffic lanes or where the crossing is not signalized, cut-through medians and pedestrian refuge islands shall be 72 inches
GDOT Comment: The 6 foot
1105.4.2 Detectable Warnings. Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24 inch
EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing.
1105.5 Pedestrian Overpasses and Underpasses. Pedestrian overpasses and underpasses shall comply with 1105.5.
1105.5.1 Pedestrian Access Route. Pedestrian overpasses and underpasses shall contain a pedestrian access route complying with 1103.
1105.5.2 Running Slope. The running slope shall not exceed 1:20
1105.5.3 Approach. Where the approach exceeds 1:20
GDOT Comment: The requirement to require elevators at pedestrian overpasses / underpasses where the total rise / fall of the ramps is over 60 inches
1105.5.4 Stairs. Stairs shall comply with 504.
1105.5.5 Escalators. Escalators shall comply with 810.9.
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
GDOT Comment: The GDOT agrees that it is a challenge for a pedestrian (especially a vision-impaired pedestrian) to cross a roundabout. However adding pedestrian signals to the roundabout not only decreases the capacity of the intersection it violates driver expectations and provides the pedestrians with a false since of security. The GDOT feels that this requirement would increase vehicular accidents (mostly rear-end collisions) and increase pedestrians accidents. The only advantage to it would be that the driver could be charged with running a traffic light in addition to failing to yield to a pedestrian. As an aside, the definition of roundabout states "an intersection that has yield control?". If this requirement is implemented the definition is wrong.
1105.6.1 Separation. Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
If the discussion in the commentary that states crosswalks are wherever pedestrians crossing are not prohibited is true, the requirement for a pedestrian actuated signal at right and left turn slip lanes should be reconsidered. On most multilane roads the GDOT constructs right turn lanes to allow the turning traffic to get out of the through lanes. This is done to reduce accidents by providing a safer right turn. As written, this requires a pedestrian activated signal (even if a pedestrian is at the intersection just once every 6 months). This is not only very costly and provides very little benefit; it violates driver expectations and will result in increased accidents and probably increase pedestrian accidents. (see roundabout discussion)
Another consideration for not providing the pedestrian activated signal at all slip lanes and roundabouts: In some area of the state, persons (and sometimes organized groups of persons) solicit handouts at intersections. These persons benefit from stopped traffic. The pedestrian signal would continually be activated by these persons (resulting in traffic congestion) even if no pedestrian was attempting to use the crosswalk.
1106 Accessible Pedestrian Signal Systems
1106.1 General. Pedestrian signal systems shall comply with 1106.
The signal that re
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
1106.2.1 Location. Pedestrian signal devices shall be located 60 inches
EXCEPTION: The minimum distance from other signal devices shall not apply to signal devices located in medians and islands.
1106.2.2 Reach and Clear Floor or Ground Space. Pedestrian signal devices shall comply with 308. A clear floor or ground space complying with 305 shall be provided at the signal device and shall connect to or overlap the pedestrian access route.
1106.2.3 Audible Walk Indication. The audible indication of the WALK interval shall be by voice or tone.
1106.2.3.1 Tones. Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds
1106.2.3.2 Volume. Tone or voice volume measured at 36 inches
1106.3 Pedestrian Pushbuttons. Pedestrian pushbuttons shall comply with 1106.3.
1106.3.1 Operation. Pedestrian pushbuttons shall comply with 309.4.
1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
1106.3.3 Size and Contrast. Pedestrian pushbuttons shall be a minimum of 2 inches
1106.3.4 Optional Features. An extended button press shall be permitted to activate additional features. Buttons that provide additional features shall be marked with three Braille dots forming an equilateral triangle in the center of the pushbutton.
1106.4 Directional Information and Signs. Pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal.
1106.4.1 Arrow. Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 inch
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.
1106.4.3 Crosswalk Configuration. Where provided, graphic indication of crosswalk configuration shall be tactile and shall comply with 703.5.1.
1107 Street Furniture
1107.1 General. Street furniture shall comply with 1107.
1107.2 Clear Floor or Ground Space. Street furniture shall have clear floor or ground space complying with 305 and shall be connected to the pedestrian access route. The clear floor or ground space shall overlap the pedestrian access route 12 inches
1107.3 Drinking Fountains. Where drinking fountains are provided, they shall comply with 602.
1107.4 Public Telephones. Where public telephones are provided, they shall comply with 1107.4.
1107.4.1 Single Telephone. Where a single public telephone is provided, it shall comply with 704.2 and 704.4
1107.4.2 Multiple Telephones. Where a bank of public telephones is provided, at least one telephone shall comply with 704.2, and at least one additional telephone shall comply with 704.4.
1107.4.3 Volume Controls. All public telephones shall provide volume controls complying with 704.3.
1107.5 Public Toilet Facilities. Permanent or portable public toilet facilities shall comply with 603. At least one fixture of each type provided shall comply with 604 through 610. Operable parts, dispensers, receptacles, or other equipment shall comply with 309.
EXCEPTION: Where multiple single-user toilet facilities are clustered at a single location, at least 5 percent, but no fewer than one single-user toilet at each cluster shall comply with 603 and shall be identified by the International Symbol of Accessibility complying with 703.7.2.1.
1107.6 Tables, Counters, and Benches. Tables, counters, and benches shall comply with 1107.6.
1107.6.1 Tables. Where tables are provided in a single location, at least 5 percent but no fewer than one, shall comply with 902.
1107.6.2 Counters. Where provided, counters shall comply with 904.
1107.6.3 Benches. Where benches without tables are provided at a single location, at least 50 percent, but no fewer than one, shall comply with 903 and shall have an armrest on at least one end.
1108 Detectable Warning Surfaces
1108.1 General. Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.
1108.1.1 Dome Size. Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches
1108.1.2 Dome Spacing. Truncated domes in a detectable warning surface shall have a center-to-center spacing of 1.6 inches
1108.1.3 Contrast. Detectable warning surfaces shall contrast visually with adjacent walking surfaces either light-on-dark, or dark-on-light.
1108.1.4 Size. Detectable warning surfaces shall extend 24 inches
1108.2 Location.
1108.2.1 Curb Ramps and Blended Transitions. The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches
1108.2.2 Rail Crossings. The detectable warning surface shall be located so that the edge nearest the rail crossing is 6 inches
1108.2.3 Platform Edges. Detectable warning surfaces at platform boarding edges shall be 24 inches
1109 On-Street Parking
1109.1 General. Car and van on-street parking spaces shall comply with 1109.
1109.2 Parallel Parking Spaces. An access aisle at least 60 inches
GDOT comment: The vehicular travel lane should not include the bike lane, if present.
EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet
1109.3 Perpendicular or Angled Parking Spaces. Where perpendicular or angled parking is provided, an access aisle 96 inches
1109.4 Curb Ramps or Blended Transition. A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route.
1109.5 Obstructions. There shall be no obstructions on the sidewalk adjacent to and for the full length of the space.
EXCEPTION: This provision shall not apply to parking signs complying with 1109.6 and parking meters complying with 1109.7.2.
1109.6 Signs. Parking spaces shall be designated as reserved by a sign complying with 502.6. Signs shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer.
1109.7 Parking Meters. Where parking meters are provided, they shall comply with 1109.7.
1109.7.1 Operable Parts. Operable parts shall comply with 309.
1109.7.2 Location. A parking meter shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer.
EXCEPTION: Where parking meters are not provided at the space, but payment for parking in the space is included in a centralized collection box or paying station, the space shall be connected to the centralized collection point with a pedestrian access route.
1109.7.3 Displays and Information. Displays and information shall be visible from a point located 40 inches
1110 Call Boxes
1110.1 General. Call boxes shall comply with 1110.
1110.2 Operable Parts. Operable parts shall comply with 308 and 309.4. Where provided, labeling shall comply with 703.2 and 703.3.
EXCEPTION: Mechanically operated systems in which the signal is initiated by a lever pull shall be permitted to have an activating force of 12 lbf
1110.3 Turning Space. A turning space complying with 304 shall be provided at the controls.
1110.4 Edge Protection. Edge protection complying with 405.9.2 shall be provided where the area at the call box is adjacent to an abrupt level change.
1110.5 Motor Vehicle Turnouts. Where provided, a motor vehicle turnout shall have a minimum paved area of 16 feet
1110.6 Two-Way Communication. Where provided, two-way voice communication shall comply with 1110.6, 708.2 and 708.3.
1110.6.1 Volume Controls. Volume controls complying with 704.3 shall be provided.
1110.6.2 TTY. A TTY complying with 704.4 shall be provided.
1111 Alternate Circulation Path
1111.1 General. Alternate circulation paths shall comply with 1111.
Also see comment in 1102.3
1111.2 Width. The alternate circulation path shall have a width of 36 inches
1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
GDOT comment: This should be a recommendation and subject to Engineering judgement. This will require additional easement and may cause additional displacements. Providing a pedestrian route on the same side of the road for a few hours, weeks or months should be weighed against the community impacts. Especially since many existing sidewalks were built to avoid taking homes and there is limited pedestrian usage.
This requirement may reduce the overall safety to the pedestrians since it will provide path near the construction equipment.
On a project where existing bridges with sidewalk on both sides are being widened, this requirement will require pedestrian accommodations on both sides, which will often require a temporary pedestrian bridge (or 2 temporary bridges).
1111.4 Protection. The alternate circulation path shall comply with 307 and shall be protected with a barricade complying with 1111.6 to separate the pedestrian access route and alternate circulation path from any adjacent construction, drop-offs, openings, or other hazards.
GDOT comment: This needs clarification. In the permanent condition the pedestrian on the sidewalk is only protected from traffic by curb(2 feet
1111.5 Signs. Signs complying with 703.5 shall be provided at both the near side and the far side of the intersection preceding a disrupted pedestrian access route.
1111.6 Barricades. Barricades shall be continuous, stable, and non-flexible and shall consist of a solid wall or fence or a Type II or Type III barricade as specified in MUTCD section 6F-60 with the bottom or lower rail 1-1/2 inches
Bill Baranowski, P.E., August 9, 2002
I have read the proposed ADA rules for pedestrian crossings at roundabouts. I believe it is in the best interest of the public in the USA to
The 20 roundabouts that I have designed and that were built in the last 8 years in the USA have not experienced any pedestrian crashes. In special situations where a high number of pedestrians cross I would consider an manually or passively activated signal and I have successfully used raised crosswalks and activated flashing warning LED lights and additional illumination. It was used because of the perceived need and was not dictated to me by the ADA. I would prefer that the access board allow engineers to use the good judgement they are paid to use.
Will this mandate be applied to all regular traffic signal controlled intersections and any marked crosswalk at intersections or mid-block locations on our road system?
Roundabouts are accessible to all users, and the solution should not be dictated but considerations open to site conditions, engineering judgement, and further research. Such a ruling at this point in time is premature and may serve to inhibit the use of roundabouts which I believe have great potential to reduce injury crashes to pedestrians and thus save many lives in the USA. An example of crash reductions due to roundabouts is contained in a recent study of two roundabouts located in Howard, Wisconsin. The study may be accessed at the following link: http://www.co.brown.wi.us/Planning/transportation_division.html
This study shows the successful implementation of two roundabouts directly adjacent to an elementary school, a middle school and a new high school. The roundabouts achieved dramatic crash reductions and the school crossing guard indicated that the intersection is easier to cross since the roundabouts were installed. I would ask the board if it would be difficult to conduct similar trials if the proposed rule was enacted and enforced.
Bill Baranowski, P.E.
RoundaboutsUSA
August 15, 2002
Please add the following to your public input on the access board review of pedestrian safety at roundabouts. The attached designs for two 180' diameter roundabouts located in Riverdale, Utah are shown to illustrate the use of raised pedestrian tables at the entry and exits to roundabouts. The raised, textured and colored surface provides a tactile surface for pedestrian crossing. The gentle rise of the crossing area provides a decrease in speed to vehicles without reducing intersection capacity while creating a very visible crossing area that vehicles can see better than a painted crosswalk. It is possible that this design is superior to that of a pedestrian signal as well because flashing lights are often ignored by drivers.
See attached photos from grand opening parade held in July 2002.
Bill Baranowski
RoundaboutsUSA
Dwight Kingsbury, Ph.D., October 28, 2002
Comment on Draft Guidelines for Accessible Public Rights-of-Way, published in the Federal Register, 17 June 2002.
As a pedestrian safety analyst, I support the goals of this effort, but share the concerns expressed by others (e.g., AASHTO) that in some sections, the draft guidelines propose inflexible, "Gordian knot" criteria to the application of pedestrian crossing features that are more appropriately and effectively evaluated through the application of engineering judgment, in the light of the "Manual on Uniform Traffic Control Devices" and other engineering guidance documents.
Specifically, I am concerned about the following.
S. 1105.3 would require calculation of pedestrian signal phase timing using a pedestrian walking speed of 3.0 ft
S. 1105.5.3 would require installation of elevators where the rise of a ramped approach exceeds 60 inches
S. 1105.6.2 would require provision of a pedestrian activated signal at each segment of a roundabout crosswalk. Although pedestrians often expect they will have difficulty using such crosswalks, prior to construction, I have never heard of any pedestrian request for a signal at a signal-lane roundabout, after it has opened. Adoption of this requirement could result in a reduction of the use of marked crosswalks at roundabouts. I concur with AASHTO that this section should be reserved, pending completion of NCHRP Project 3-65, "Applying Roundabouts in the United States."
S. 1105.7 would required provision of a pedestrian activated signal where crosswalks are provided at right or left turn slip lanes. The problem is that, if the slip lane is designed to facilitate a high speed turn, and the signal is used infrequently, it will be ineffective; many drivers simply fail to heed signal indications they are not used to seeing. The failure of drivers to yield to pedestrians in slip lane crosswalks is better addressed through design, e.g., greater use of high-entry-angle slip lanes such as those used in Australia (cf. the Austroads "Guide to Traffic Engineering Practice," Part 5). Let us hope that NCHRP Project 3-72, "Lane Widths, Channelized Right Turns, and Right Turn Deceleration Lanes in Urban and Suburban Areas," will produce some useful recommendations for the pedestrian crossing problem at slip lanes.
S. 1106 would require all pedestrian signal systems to use audible and vibrotactile indications. In Florida, there have been differences among visually impaired pedestrians as to the usefulness of audible signal systems. Some blind persons believe these features are unnecessary, or create a false sense of security, or make it difficult to hear traffic (at least, if not installed properly). They must also be maintained. It is probably better to continue with the current practice of considering installation of such systems on request.
I also concur with AASHTO that the hard conversion of dimensions stated in US customary units into their SI equivalents lends itself to impractical inferences with respect to tolerances. Metric tolerances need to be clarified.
Dwight Kingsbury, Ph.D.
Willamette Pedestrian Coalition, October 28, 2002
Comments by the Willamette Pedestrian Coalition on the Draft Guidelines for Accessible Public Rights-of-Way
Willamette Pedestrian Coalition
Ellen Vanderslice, President
Doug Klotz, Policy Analyst
We are pleased to support the Draft Guidelines for Accessible Public Rights-of-Way. In general this document represents an advance for accessibility on public streets. Our specific comments follow and are also attached as a Word document for your convenience.
1102.14 On-Street Parking
We support the provision of accessible on-street parking. However, we respectfully disagree with the proposed requirement of one space per block. Blocks vary so greatly in size (including average variation between cities) that this is an inherently inequitable requirement. Perhaps the requirement should be something like one for every six hundred feet of on-street parking provided. Also, there should be a better definition of "where on-street parking is provided," whether this means where it is allowed or where it is marked or signed. The guidelines should clarify whether this requirement applies on every street, even low-volume residential streets where parking is permitted but not designated.
1103.3 Clear Width (of the Pedestrian Access Route)
We support widening the minimum clear width requirement in the public right-of-way, with the understanding that larger scooters may be used in this environment and that there should be room for two wheelchairs to pass. We would support the PROWAAC recommendation for 60 inches
1104.3.2 Detectable Warnings (in Common Elements of Curb Ramps and Blended
Transitions)
We support the requirement for detectable warnings at curb ramps and blended transitions. See additional comments on 1108.
1105.2 Crosswalks
We support all the crosswalk provisions, including the minimum width of 96 inches
intersections) and the maximum running slope of 1:20
1105.2 Pedestrian Signal Phase Timing
While we support reducing the walk speed used to calculate crossing times, as well as the inclusion of one ramp in the value of the length of the crosswalk used in the calculation, we suggest that there might be an exception included for signals that use either passive or active detection to extend the pedestrian clearance interval on demand. If the system can provide the added crossing time only when needed, this will benefit those crossing in the perpendicular direction and reduce overall delay for pedestrians.
1105.4 Medians and Pedestrian Refuge Islands
We support the requirement for alignment of the cut-through with the direction of the crosswalk for a minimum of 24 inches
1105.5 Pedestrian Overpasses and Underpasses
We are supportive of the needs of users who experience fatigue but we are concerned about the effect of the 60 inch
We respectfully suggest that the terms "pedestrian overpass" and "pedestrian underpass" be defined in section 1101.3. Without a definition, it is not clear which facilities require an elevator.
1105.6 Roundabouts
We respectfully suggest a definition in 1101.3 of "barriers" as used in 1105.6.1 Separation. We believe landscaping should be allowed as separation. The extent of the required separation should be specified more clearly.
We support 1105.6.2 Signals (at Roundabouts). As noted in the discussion, there currently is no alternative that allows for safe passage of pedestrians with disabilities.
Although this may not be an accessibility issue, we suggest that adding a new tool to the pedestrian signal arsenal could be helpful in this situation. There is currently no provision for pedestrian signals where "pedestrian yield," rather than "don't walk," is the default state. We believe such a signal would be useful in a situation like a roundabout where most pedestrians will use available gaps rather than request the walk signal.
1105.7 Turn Lanes at Intersections
We support the requirement for pedestrian signals with the same suggestions as we made for signals at roundabouts.
1106.2 Pedestrian Signal Devices
We support the requirement for accessible signal devices at all crosswalks with pedestrian signal indication.
1106.3 Pedestrian Pushbuttons
We would like to note that these draft guidelines do not require the use of pedestrian pushbuttons, and that signals without pedestrian pushbuttons are much better for all pedestrians.
The PROWAAC recommended (in "Building a True Community," section X02.5.1.3) that "the control face of the push button shall be parallel to the direction of the crosswalk controlled by the push button?" We believe this guideline should include a requirement for the directionality of pushbuttons.
1108 Detectable Warnings
We respectfully suggest that the language in this section be strengthened to clarify that the "square" grid pattern must be aligned with the direction of the ramp. We also suggest that, in deference to wheelchair users, the range of permitted center-to-center dome spacing under 1108.1.2 be reduced to the largest end of the range and that the minimum base-to-base spacing be increased to 1 inch
Kimberly Pawling, COMS & RTC, October 28, 2002
To Whom It May Concern:
My name is Kimberly A. Pawling. I hold a certification in Orientation & Mobility (O&M) and in Rehabilitation Teaching with the Academy for Certification of Vision Rehabilitation & Education Professionals. I am an active member of AERBVI (the Association for Education and Rehabilitation of the Blind and Visually Impaired), and I am currently employed at CITE, Inc. in Orlando, Florida as the O&M Specialist and Rehabilitation Teacher. I have reviewed the following comments written by my colleage Mrs. L. Dianne Ketts, a member of the Environmental Access Committee for AERBVI, and I would like to submit comments on the Draft Public Rights-of-Way Accessibility Guidelines.
Curb Ramps and Blended Transitions (1104)
Detectable Warning (1104.3.2)
I support inclusion of specifications in the draft guidelines for detectable warnings and urge The Board to include requirements for detectable warnings at ALL slopes and curb ramps where a pedestrian way intersects with a vehicular way regardless of grade.
Pedestrian Signal Phase Timing (1105.3)
I support The Board's draft guideline for Pedestrian Signal Phase Timing, stating that "signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Medians and Pedestrian Refuge Islands - Detectable Warnings (1105.4.2)
I do not support the EXCEPTION to this recommended guideline stating that "Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing." It is my recommendation that this EXCEPTION be removed from the proposed guidelines.
Turn Lanes at Intersections (1105.7)
I whole heartedly support the recommendation for pedestrian activated traffic signals at these locations.
Accessible Pedestrian Signals - General (1106.1)
I support the inclusion of specifications for Accessible Pedestrian Signal (APS) systems.
Many intersections in the central Florida area are typical of intersections that can be found throughout the country. Minor, lightly traveled streets often intersect with major arteries. When a visually impaired pedestrian's intention is to cross the major artery, there is often little or no parallel traffic movement on the minor street to indicate that it is the appropriate time for the pedestrian to begin crossing. Accessible Pedestrian Signal technology provides information critical to determining when to begin a crossing in a format that is accessible to the visually impaired pedestrian.
I recommend that The Board use the term "Accessible Pedestrian Signal (APS)" when referring to these types of devices as opposed to "pedestrian signal systems" or "pedestrian signal devices." This terminology would more closely match the language in the MUTCD and current terminology. As a result, engineers and others utilizing the MUTCD when building public rights-of-way will be less likely to encounter conflicting or misguiding terminology.
Once again, thank you for the opportunity to comment.
Kimberly Pawling, COMS & RTC
CITE, Inc.
Laura Oftedahl, October 27, 2002
I am a competent blind pedestrian - and strongly support accessible pedestrian signals. It is a very scary world crossing the street. I want to live, but need some help from this new technology. Thank you.
Laura Oftedahl
Roger Petersen, October 28, 2002
My name is Roger Petersen and I live at [ ... ].
I am totally blind since birth and serve as Chairman of the Information
Access Committee of the American Council of the Blind. I am also
Vice-Chair of the Santa Clara County Commission for People with
Disabilities and the City of Mountain View Bicycle and Pedestrian Advisory
Committee.
I am strongly in favor of accessible intersections as defined by the draft
guidelines. As a blind pedestrian, I have learned the work-arounds that
some people mention as ways of doing without audible ped signals. But I
can tell you that it is much less stressful to cross intersections where
they exist. It has been the practice to provide walk signals for sighted
pedestrians, even though they are better equipped than blind pedestrians to
judge the traffic and watch the traffic signals. It seems only logical
that the same information should be available to blind pedestrians. In
many cases, there is turning traffic that is competing with pedestrians for
the crosswalk. In such situations, it is very helpful to know the exact
moment when the walk interval begins. Otherwise, while I am figuring out
that the ped interval has begun, the traffic will start turning in front of me.
In the area where I live, there are many of the old "cuckoo" type audible
signals. I have heard a lot about how these are not preferred. But I find
even those signals very helpful. Often the one on the corner to which I am
crossing gives some guidance in crossing. After all, the crosswalk lines
are also information that is provided to sighted pedestrians and to which I
believe I have the right. I would encourage the board to continue to
concern itself with best practices wayfinding information in crossing
intersections, such as tactile wayfinding or audible beacons.
I hope you find these observations helpful. I would be glad to answer
further questions you may have.
Sincerely,
Roger D. Petersen
Brian R. Searles, October 25, 2002
STATE OF VERMONT
AGENCY OF TRANSPORTATION
OFFICE OF THE SECRETARY
Brian R. Searles, Secretary
Dear Members of the Access Board:
We have reviewed the Draft Guidelines for Accessible Public Rights-of-Way released on June 17, 2002. We are entirely supportive of the development of guidelines to assist transportation engineers and planners in providing a transportation system that provides access to all users. However, we have some reservations with the draft guidelines as presented. We have been made aware of the comments and recommendations being made by AASHTO on the draft guidelines and, in general, we concur with the proposed changes and concerns adopted by their Board of Directors on October 14, 2002.
In addition, we have the following specific comments:
1. Section 1103.3 - Clear Width - It is unclear how this provision is to be coordinated with existing ADAAG minimum width of 36 inches
2. Section 1105.3 - Pedestrian Signal Phase Timing - The use of the slower walking speed and longer crossing distance in calculating pedestrian signal phases will certainly have an impact on overall operation of traffic signals. The guideline, as written, does not address the situation of an exclusive pedestrian phase, in which all motor vehicle traffic is stopped. If multiple crosswalks exist, which one should be used to calculate the length of the exclusive pedestrian phase? We suggest that using 3.5 feet
3. Section 1105.5.3 - Approach (Pedestrian Overpasses and Underpasses) - The trigger of 60 inches
4. Section 1105.6.1 - Separation (at roundabouts) - As written, it is not clear what portion of the roundabout is considered as having "prohibited" pedestrian crossings. Would this be the area between marked crosswalks? Would any of the approach leading up to a marked crosswalk be included in the "prohibited" area? If visually impaired pedestrians generally use curbs to discern where it is unsafe to cross, why would roundabouts be treated differently than other intersections? Assuming that the circular nature of roundabouts is confusing to those with visual disabilities, maybe other technologies like audible messages could be used to clarify where marked crosswalks are and what type of intersection treatment is present.
5. Section 1105.6.2 - Signals (at roundabouts) - The requirement for signals at roundabout crosswalks will negate many of the traffic flow and traffic calming benefits that roundabouts offer over traditional signalized intersections.
6. Section 1105.7 - Turn Lanes at Intersections - The requirement for signals at all crosswalks that cross slip lanes will have significant impacts on overall traffic flow, in addition to significant cost increases.
7. Section 1106.3.4 - Optional Features (of pedestrian pushbuttons) - It is unclear what additional features could be activated by pedestrian pushbuttons. A listing of these potential features would be helpful.
8. Section 1111.3 - Location (of alternate circulation path) - It is proscriptive to state that the alternate route must be on the same side of the street as the closed sidewalk. It may be more helpful to state that the preferred route is the same side of the street, unless it is unsafe to do so, in which case nearby parallel routes may be provided.
We appreciate the opportunity to comment on the draft guidelines. Please do not hesitate to contact me if you have any questions or require additional information.
Sincerely,
Brian R. Searles
Secretary of Transportation
Brian K. Copeland, P.E., October 25, 2002
I commend your efforts on the development of the new accessibility guidelines. However, there are a few instances where implementation of these guidelines would be cost prohibitive or may not be feasible from an engineering standpoint. The needs of public agencies and designers need to be balanced with needs of disabled persons. My comments are as follows:
1. Protruding Objects (1102.5). Traffic signal controller cabinets are frequently mounted on signal poles, especially in downtown areas where space is constrained. These cabinets would violate your proposed 4" guideline. I agree that these cabinets and other attachment to poles should be kept outside of the pedestrian circulation path, but there need to be provisions for allowing cabinets to be mounted on poles if they are outside the main pedestrian path. For example, the City of Portland has hundreds of these types of controllers mounted on poles. As written, this guideline would severely cramp design efforts and would be very costly to agencies.
2. Detectable Warnings (1104.3). Truncated domes are used in the Portland area for pedestrian/at-grade LRT crossings. When a blind pedestrian experiences truncated dome treatments in the Portland area, they know they are about to cross a rail alignment. Other options should be evaluated for curb ramps outside of at-grade rail crossings (I have seen horizontal raised strips in some areas that seem to be effective). There needs to be distinction between crossing a road and crossing an LRT/heavy rail trackway.
3. Pedestrian Signal Phase Timing (1105.3). Changing the pedestrian walk time from 4.0 ft/sec to 3.0 ft/sec will have significant, far-reaching impacts on our nation's transportation system. By reducing the walk speed, green time will be taken away from vehicle movements and the capacity of many intersections will be reduced. This would lead to the need for costly capacity improvements at intersections which most agencies cannot afford. Where did the 3.0 ft/sec come from? How much has this been studied? We need data/proof that lives will be saved if we do this...
4. Roundabouts (1105.6). What type of signals are we talking about? Requiring all pedestrian crossings at roundabouts to include standard pedestrian signals would be a mistake and would defeat the purpose of the roundabout altogether. There are other ways (pedestrian activated warning flashers or signage, for example) to help create a safe pedestrian crossing. However, there needs to be flexibility to address this on a case by case basis. A signal of some type may be desired on a multilane roundabout, whereas a low-speed, single lane roundabout may only call for signage.
I have worked as an transportation engineering/planning consultant in the Portland, OR area for the past 10 years and have broad experience in transportation design. Please consider the above input as you
finalize the guidelines. Thank you.
Brian K. Copeland, P.E.
DKS Associates
Brant Williams, P.E., October 28, 2002
Comments of the Draft Guidelines
Portland Office of Transportation
Brant Williams, P.E.
Director
1101 Application and Administration
1102 Scoping Requirements
1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way shall comply with Chapter 11.
1102.2 Existing Public Rights-of-Way. Additions to existing public rights-of-way shall comply with 1102.2.1. Alterations to existing public rights-of-way shall comply with 1102.2.2.
1102.2.1 Additions. Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2.
PDOT COMMENT: Recommend that this term be deleted because it does not add any clarity to the draft regulation. Keep just two terms in this section: NEW CONSTRUCTION and ALTERATIONS.
1102.2.2 Alterations. Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11.
EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible.
PDOT COMMENT: Both "technically infeasible" and "maximum extent feasible" need to be clearly stated in 1101.3 Defined Terms.
1102.5 Protruding Objects. Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes.
PDOT COMMENT: The end phrase of the above sentence should be corrected to read " ... pedestrian access routes."
1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
PDOT COMMENTS: The proposed standard for a 4 inch
The second sentence is not clear in its application. We assume that the Board means that where signs have multiple posts or pylons that are spaced more that 12 inches
Some agencies utilize a vertical sign structure consisting of vertical, horizontal, and diagonal elements that are attached together to form a truss or frame. Signs can be mounted from the walking surface to the top of the structure. If this vertical sign structure is detectable, it should not be a problem for blind travelers.
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps.
1102.14 On-Street Parking. Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.
PDOT COMMENTS: This requirement means that at least one accessible on-street parking space be provided on every single newly constructed block face. This requirement is problematic for several reasons. First, using the measurement of "block face" as its basis will result in an inconsistent application of this requirement. The City of Portland typical block face is 200 feet
Secondly, given the small block sizes in Portland, the number of accessible parking spaces compared to the total number of spaces on the block face is excessive. Best case scenario in our downtown, we can provide 9 on-street parking spaces per block face. However, on average, this number is significantly less due to driveways, loading zones, curb extensions at corners, etc. The average is more likely to be around 6 spaces per block. Providing one accessible space for every 6 on-street spaces is again excessive. We would recommend that this rule be consistent with the requirements for private parking areas; i.e. a similar proportion of accessible on-street spaces to the total number of on-street spaces for both off-street and on-street parking areas.
Thirdly, as it reads, this rule includes all residential streets as well as other classifications of streets. This appears to be an oversight in writing the draft guidelines.
And lastly, the original Section 14 and the recommendations of PROWAAC limit this requirement to central business districts of cities. We recommend that this requirement be revised to include the provisions identified both in Section 14 and the PROWAAC report.
1103 Pedestrian Access Route
1103.8 Changes in Level. Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
PDOT COMMENT: This proposed standard needs to be more clearly defined in its application. Consider changing the term "changes in slope" because all surfaces in the public right-of-way are actually built on sloping surfaces. Very rarely in the outdoor environment would one encounter a truly "level" situation.
We assume that the Board is attempting to regulate the frequency of slope changes or "grade breaks" ( a more common term ) in the longitudinal Pedestrian Access Route.
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings.
1104 Curb Ramps and Blended Transitions
1104.1 General. Curb ramps and blended transitions shall comply with 1104.
1104.2 Types. Perpendicular curb ramps shall comply with 1104.2.1 and 1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended transitions shall comply with 1104.2.3 and 1104.3.
1104.2.1 Perpendicular Curb Ramps. Perpendicular curb ramps shall comply with 1104.2.1, and shall have a running slope that cuts through the curb at right angles or meets the gutter grade break at right angles.
PDOT COMMENTS: PROWAAC spend countless hours with the issue of directionality and it was discussed in 2 pages of the report to the Board. It was not fully resolved because the needs of the wheelchair users and blind travelers were at odds. The question that could not be resolved was as follows:
1. Should a perpendicular ramp be aligned with the direction of travel and benefit the blind and sighted travelers and create a potential problem for wheelchair users. OR
2. Should a perpendicular ramp be aligned at a right angle to the radius of a corner to the benefit of wheelchair users and lose a directionality for blind travelers.
There are many arguments for both cases depending upon which group is being viewed as receiving preferential treatment. The draft regulation gives preference to wheelchair users and has the following undesirable impacts:
. Ramp alignment at a right angle to the radius forces the ramp to be skewed from the direction of travel
. Blind travelers lose directionality that could have been provided if the ramp were aligned in the true direction of travel. [ We continuously receive comments from members of our blind community that ramps should be build to align with the straight direction of travel. ]
. Sighted travelers lose the benefit of the ramp and will encounter a portion of the curb on the ramp flare if they chose to travel in a straight line. This creates a tripping hazard for both sighted and low vision pedestrians.
. Ramp alignment on the radius creates a very complicated design and an extreme construction challenge and contributes significantly to the design and construction cost of each ramp.
. Ramp alignment on the radius calls for shifting the ramp a few feet left or right of the true direction of travel. This realignment does not improve cross-slope and warping problems. Most ramps will have some warping between the level landing and the street gutter because the outdoor environment is rarely level.
. Ramp alignment on the radius has a poor architectural appearance and violates "form" without contributing to improved "function."
. Wheelchair users need to take an out of direction travel path upon leaving the landing to proceed down the ramp and enter the crosswalk. They then need to make another direction change to align with the crosswalk direction of travel. This path of travel resembles an "S."
. Persons with limited mobility skills that tend to shuffle as they travel, will need to follow an "S" path of travel to utilize the benefit of a curb ramp and avoid the vertical rise of the curb in the flare section of a ramp when it is aligned on the axis of the radius
We feel that the Access Board should abandon the right angle with radius alignment requirement or better yet, support the ramps being aligned with the direction of travel. The very worst thing that could happen is that wheelchair users would make the smaller "S" path of travel as they proceeded down the ramp to allow the wheelchair to align the front caster wheels at a right angle with the street gutter. All other users, blind, low vision, persons with limited mobility skills, and sighted pedestrian would benefit from the ramp being aligned with the direction of travel.
1104.2.1.4 Flares. Flared sides with a slope of 1:10
PDOT COMMENT: The term slope is erroneous because in infers that one of the components is dead level. This does not happen in the public right-of-way because unlike the building environment where dead level is common, it rarely happens in the street area. PROWAAC discussed this issue extensively and came to the conclusion that the curbed portion of the flare needed to transition from the curb ramp base [ zero curb exposure ] to the top of the full curb [typically 6 inch
This provision can be rewritten as follows: "Curb ramp flares adjacent to curb ramps that are provided where a circulation path crosses the curb ramp, shall have the curb exposure, as measured along the gutterline, rise from zero-exposure at the ramp to full curb exposure on a ratio of 1 foot
1104.2.2 Parallel Curb Ramps. Parallel curb ramps shall comply with 1104.2.2, and shall have a running slope that is in-line with the direction of sidewalk travel.
1104.2.2.4 Diverging Sidewalks. Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments shall be protected with a barrier.
PDOT COMMENT: It would be far better to not allow this type of curb ramp design at intersections rather than require a continuous barrier. Since "barrier" is not defined, we will assume that it means a fence, handrail, roadway guardrail, raised landscape planter, or any other type of acceptable barrier. A schematic drawing would be helpful to understand this parallel ramp concept.
At a typical corner where a parallel ramp is used, this regulation would essentially divide the pedestrian area in half running parallel to the curb as it curves around a corner. Persons wanting to cross at the intersection must make a decision on the approach to the corner to chose the "low road" to the ramp or the "high road" to stay on the sidewalk and avoid the crossing. Those persons choosing to cross at the intersection must utilize the parallel curb ramp to reach the crosswalk. This means that all "crossers", disabled or not, will need to descend the ramp to the crosswalk.
The divided sidewalk will certainly cause problems for blind travelers because if they miss the parallel ramp, they could not reach the crosswalk because of the barrier. Likewise, if the blind traveler did not want to cross the street, the barrier could divert them down to street level at the crosswalk where they did not want to go.
This design is also unsafe in that it removes any means of escape for pedestrians in the event a vehicle cuts too close to the ramp. Without the barrier, pedestrians that recognize the danger of an approaching errant vehicle could move to the back of the sidewalk to avoid being injured. With the barrier, the pedestrian could not move out of harm's way. In fact, they would be trapped between the oncoming errant vehicle and the barrier.
In tangent areas, where isolated parallel ramps are the best design solution, such as access to an on-street disabled parking space from sidewalk level, it could be beneficial to utilize a barrier. There certainly other examples where a barrier would be helpful. However, the Access Board must answer the question: What persons are you attempting to protect? Blind persons using long canes will likely find the ramp and the adjacent curb and not be in danger. Sighted persons, including mobility device users, will see the ramp and the adjacent sidewalk. So who really needs the barrier? The fall into the parallel curb ramp would be the same as a fall from the curb at sidewalk level to the adjacent street level. But the Board is not recommending barriers between sidewalk level and street level.
1104.2.3 Blended Transitions. Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
PDOT COMMENT: As we understand a blended transition, it is simply a large landing that runs parallel to the curb radius. This landing more resembles the landing used on a parallel curb ramp, only that is probably larger and is not necessarily served by a parallel ramp. It more typically models the street surface extended into the corner pedestrian area with a drainage slope pitched to the street.
Because of the running and cross slope limitations, this blended transitions could only fit if the street gutter grade were 2% or flatter. Further, because of drainage issues, this type of landing would rarely be used. This blended transition would afford little protection to pedestrians because it is level with the roadway and excludes barrier curbs.
We question why the Board would offer this as an accessibility improvement when it has so many limiting and detrimental characteristics.
1104.3 Common Elements. Curb ramps and blended transitions shall comply with 1104.3.
1104.3.4 Grade Breaks. Grade breaks shall not be permitted on curb ramps, blended transitions, landings, and gutter areas within the pedestrian access route. Surface slopes that meet at grade breaks shall be flush.
PDOT COMMENT: The PROWAAC report specifically recommended that where a curb ramp meets the street surface at the gutter, the two sloping surfaces must be flush so that there is not a vertical "lip" on the curb ramp. This may be implied in either 1104.3.4 or in 1104.3.5, but it is not clearly stated.
1104.3.7 Clear Space. Beyond the curb line, a clear space of 48 inches
PDOT COMMENT: We understand that this requirement will provide a 4' X 4' refuge area on the street pavement beyond the curb ramp where a pedestrian would not be struck by parallel traveling vehicles and bicycles. However, geometrically, this will not always work. Take the case of a small corner radius of 10' and a sidewalk built adjacent to the curb. A parallel ramp design is the only possible alternative. The bottom landing of the curb ramp is centered on the diagonal of the radius. It is then mathematically impossible to create the refuge area on the pavement and be wholly outside the parallel vehicle travel lane.
Since a parallel curb ramp already has a level landing / refuge within the sidewalk and adjacent to the street, we suggest that the clear space requirement be removed for all parallel curb ramps. If this condition is not removed, the Board will have automatically excluded parallel curb ramps at corners with a radius of less than 15'.
1105 Pedestrian Crossings
1105.1 General. Pedestrian crossings shall comply with 1105.
1105.2 Crosswalks. Crosswalks shall comply with 1105.2.
1105.2.1 Width. Marked crosswalks shall be 96 inches
1105.2.2 Cross Slope. The cross slope shall be 1:48
PDOT COMMENTS: This one sentence provision potentially has more impact that any other part of Chapter 11. Without directly stating it, this regulation will require that all future intersections be essentially flat. Construction of flat intersections and steep intersection approaches and departures are technically infeasible, extremely expensive, environmentally unsound, and are in conflict with safe roadway design.
The outdoor environment, all formed at the whim of Mother Nature, cannot be made to conform to the indoor environment that man builds. In Portland, as well as many other cities across this nation, we build streets with centerline grades that range from 0.5% to as much as 22%. We do this to make the developable land with the confines of our urban growth boundary available for its highest and best use. The Tualatin Mountains, within our city limits, rises more than 1000 feet
Even if the excessive cost factors were ignored and construction to meet these standards were attempted, the environmental damage would be staggering. To create a tabled or flat intersection in hilly terrain, calls for major excavations into uphill slopes and massive fill sections on downhill slopes. The combined work for a single intersection could involve the clear cutting of all vegetation and earth disturbances on at least 2 acres [ 87,120 square feet ] of land to create one intersection. The resultant "flat intersection" would have street slopes far steeper that if the roadway were build to conform to the natural grade of the existing terrain. Disabled persons could certainly be able to use the intersection but would not be able to get to the intersection or leave it because the roadway / sidewalk slopes would be too steep.
Flat intersection design requires the use of long vertical curves to smooth out longitudinal grade breaks. These curves are a function of the roadway speed, safe stopping sight distance, and roadway running slopes. The length of smoothing out one intersection will exceed the distance to the next intersection. This means that the next intersection must be moved farther away to make the running grades work with the flat intersections. In some cases, this flat intersection requirement has the effect of eliminating subdivisions on steep terrain because the land area cannot be reformed to fit the platting of lots and blocks because "accessible" intersections cannot be designed.
Roadway designers must take into consideration multiple variables that affect the safe usability of the facilities. These variables include, but are not limited to: horizontal alignment, vertical alignment, safe stopping sight distance, existing terrain, environment, design speeds, maximum grades, critical length of grades, and many others. Roadway alignments with numerous breaks because of successive intersections is poor design. Although it may be beneficial to reduce grades at intersections, attempting to make them "flat", is flawed design. The Green Book points out that "? the gradeline of the major highway should be carried through the intersection, and that of the crossroad should be adjusted to it. This design requires transition of the crown of the minor highway to an inclined cross section at its junction with the major highway." In other words, even on local streets, one street follows the natural gradeline downhill, and intersecting streets are warped to fit.
EXCEPTION: This requirement shall not apply to mid-block crossings.
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
PDOT Comment: This requirement could have severe consequences regarding the timing of signals, vehicular delays, overall congestion, and pollution levels.
In Portland, an intersection that is 60 ft
Complaints regarding traffic congestion are common in urban areas such as Portland. The reduction in the pedestrian crossing rate used to calculate the timing of traffic signals would undoubtedly result in increased congestion, and longer delays.
A couple of other unintended consequences of the slower crossing speed could include shorter "Walk" intervals (the "Walk" phase being shortened to help absorb the longer "Flashing Don't Walk phase), and pedestrian pushbuttons where none currently exist (to avoid serving the ped phase when no pedestrians are present). Pedestrians who push the pedestrian button and then proceed to cross the street when an adequate gap occurs are often long gone by the time the pedestrian phase is served. Providing shorter walk times at locations where pedestrians may be tempted to cross against the signal indication can help to reduce unnecessary delay to motorists.
We often hear complaints that the pedestrian crossing time is too short from pedestrians who do not understand the meaning of the pedestrian signal indications. Most pedestrians are more comfortable with the pedestrian signal timing after they are educated on the meaning of the signal indications. Most complaints are regarding the short "Walk" phases. Few people complain about the "Flashing Don't Walk" clearance intervals.
One other consequence of lengthened flashing don't walk intervals will be increased non-compliance by the majority of pedestrians. Today we already have a severe problem with pedestrians disregarding the pedestrian signals. Using the 3 fps rate for the flashing don't walk lengths will generate crossing intervals that can be easily met by over 95% of the population. Users will see this exceeding long length as unnecessary and pay even less attention to pedestrian signals.
It is our recommendation that the policy be modified to allow agencies to implement pedestrian crossing times based off of local knowledge using crossing speeds ranging from 3.0 fps for a disabled person to 4.0 fps for an average pedestrian. The City of Portland has already made accommodations for slower than average and disabled pedestrians at several signalized intersections, and would prefer to work directly with these groups to identify problem locations where pedestrian needs could be better met. This would allow us to balance the needs of ALL users of the ROW to maximize the safety and efficiency of the signal for all users.
1105.4 Medians and Pedestrian Refuge Islands. Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying with 1104 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches
1105.4.1 Length. Where signal timing is inadequate for full crossing of all traffic lanes or where the crossing is not signalized, cut-through medians and pedestrian refuge islands shall be 72 inches
PDOT COMMENT: The meaning of this regulation is not clear and should be revised to say: "Where pedestrians are expected to wait because signal timing is inadequate for full crossing of the traffic lanes or where the crossing is not signalized and a pedestrian must wait for gaps in the vehicle traffic flow, a refuge area, 72 inches
1105.5 Pedestrian Overpasses and Underpasses. Pedestrian overpasses and underpasses shall comply with 1105.5.
PDOT COMMENT: This condition is not entirely clear to most readers. There are a number of situations that need to be evaluated before specific regulations can be set. Otherwise, the Access Board is attempting to force fit one solution to fit all situations. A sampling of common overpass / underpass situations is as follows:
. At-grade intersections where pedestrians are routed over a bridge structure. These are built in to provide pedestrian only access over a busy arterial street. A good example is the intersection of the Las Vegas Boulevard [ the Strip ] and Tropicana Boulevard in Las Vegas, NV. Four separate bridge structures exist to safely route pedestrians between the various casinos at this very busy street intersection. All have escalators and elevators.
. At-grade intersections where pedestrians are routed under the roadway through an underpass or tunnel. Portland used to have several of these pedestrian only tunnels beneath busy arterial streets. However, most have been closed because pedestrians felt unsafe using these isolated facilities.
. Grade separated intersections where one street is on a bridge structure and the other roadway or pedestrian route is below the bridge. In some situations, pedestrian connections are made using pedestrian stairways between the two levels. An example of this type of route exists in downtown San Antonio, TX along the "Riverwalk" where the San Antonio River frontage includes a pedestrian route.
. Grade separated intersections where one street is in a tunnel beneath the surface street. Again, in some situations where both streets have pedestrian sidewalks, the two levels may be connected with pedestrian stairways.
. Pedestrian only connections using stairways between roadways at different levels. These usually occur in areas with steep terrain. These stairways usually create a non-accessible "shortcut" to avoid a longer, more circuitous route on surface sidewalks.
. Pedestrian only connections that are made beneath or over multiple roadway bridge structures. These more resemble "catwalk" type bridges connected under or over larger bridges. These occasionally occur where a pedestrian route crosses a complex freeway interchange that includes multiple roadway bridges at different levels.
. Pedestrian only bridge structures over water, canyons, railroad facilities, and other obstacles.
. There are other possible combinations of roadways and pedestrian routes not discussed.
The Board needs to clearly define the conditions where elevators and escalators are needed. Consideration must be given to the purpose of the pedestrian route and a variety of other factors. Clearly, the pedestrian bridges in Las Vegas that carry thousands of daily pedestrian trips that avoid conflict with traffic volumes exceeding 50,000 cars per day should have both escalators and elevators. However, pedestrian stairways between streets in steep terrain, that carry less that 25 pedestrian trips per day, should not warrant the need for an elevator.
1105.5.3 Approach. Where the approach exceeds 1:20
PDOT COMMENT: This is a very broadly written requirement that requires the installation of elevators if the ramps at overpasses or underpasses exceed 60 inch
It appears that the Access Board is setting a requirement for the public right-of-way that does not exist for buildings. Elevators are being required in the outdoor environment when they are NOT REQUIRED in the indoor environment.
Elevators in buildings are the obvious mode of choice because they are build in a space that is typically secure and environmentally controlled. Elevators are the most cost efficient means to move persons between different levels. The benefit of an elevator in an interior space typically outweighs the cost of construction and maintenance. However, this is not the case for elevators in an outdoor environment.
Elevators in the public right-of-way are subject to multiple adverse conditions. These adverse conditions can easily affect the working parts of this type of machine and cause them to fail. Excessive heat or cold can damage or destroy hydraulic systems. Precipitation, in the form of rain, ice, or snow can stop moving parts with rust or ice seizure. Dust and debris in the outdoor environment can also stop moving parts from moving. Exterior elevators cannot always be secured and are subject to damage by vandalism, which in turn causes failures.
Interior elevators simple attach to the interior structure of the building. Exterior elevators are considerably more expensive because they need their own exterior structural support system.
We request that the Board reconsider this proposed requirement. The public right-of-way is not a square or rectangular space that is confined by exterior building walls. It is a longitudinal or linear space that affords public agencies the ability to make accessible connections using sidewalks and ramps. Public works agencies should be given the option to choose different options that provide accessible connections. Ramps and sidewalks could be used where space is available. Elevators and escalators could be used where space is severely constrained.
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
1105.6.1 Separation. Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
PDOT COMMENTS: Continuous barriers need to be defined here or in section 1101.3 Defined Terms. Continuous barriers should include, and not be limited to: landscape buffers that do not contain a walkable surface as defined by 302.1, fences, pedestrian railings, and vehicular guardrails.
No guidance is provided regarding the boundary for where a roundabout intersection begins or ends and thus a barrier begins or ends. The nature of a roundabout intersection is similar to a curved section of roadway or a mid-block crossing. The requirement of a street-side barrier at a roundabout intersection to separate vision impaired pedestrians from the roadway seems arbitrary. The logical extension of such need for barrier would be to install barriers at the edge of every sidewalk which is adjacent to a street. No substantive argument or evidence has been provided that distinguishes a modern roundabout pedestrian crossing as inherently less safe than any other mid-block crossing design or intersection treatment, and thus warranting such barrier. Location of the pedestrian crossing can be accomplished with a depressed landing adjacent to the ramp that directs pedestrians into the marked crossing.
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
PDOT COMMENT: The guideline appears to apply to all sizes and types of roundabouts with pedestrian facilities regardless of the level of auto or pedestrian traffic use. As roundabouts have so many different applications, with a similar variety of pedestrian environments, a single protocol without regard to traffic volume or the number of entry or exit lanes a pedestrian is expected to cross will unduly limit the modern roundabout's application due to the cost of this guideline. This would be unfortunate as modern roundabouts have a clear record of reducing total crashes and crash severity as compared to standard signalized traffic control. We suggest that the Board conduct additional research into the methods used in Australia and Europe, where modern roundabouts are used at high pedestrian use locations with regular frequency.
The guideline singles out the modern roundabout intersection control geometry without a clear argument or evidence of a safety need. The logical extension of this guideline is the need for pedestrian actuated signals at all intersections, regardless of traffic volume.
Signalizing each approach to a roundabout could also have several negative consequences including increased congestion, queues extending into the roundabout, rear-end accidents, and increased costs. Adding signals to each approach of a roundabout could easily add over $150,000 to the cost of the roundabout installation, not counting added annual maintenance and operation costs.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
PDOT COMMENTS: The correct term for "slip lanes", as used by the AASHTO Policy on Geometric Design of Highways and Streets [ the Green Book ], is auxiliary lanes.
For right turn auxiliary lanes, traffic is not always controlled with signals. Below are some of the methods currently used in this application:
. Signal control of through traffic lanes and signal control of the auxiliary right turn lane.
. Signal control of the through lanes and "yield" control of the turn lane.
. Signal control of the through lanes and "stop" control of the turn lane.
. Stop control of the through lanes and "yield" control of the turn lane.
. No control of the through lanes and no control of the turn lane.
. Other combinations are possible.
The proposed regulation requires a pedestrian traffic signal for all situations without considering the variety of variables involved. The Board needs to study this further before setting a requirement that one solution fits all applications.
1106 Accessible Pedestrian Signal Systems
1106.1 General. Pedestrian signal systems shall comply with 1106.
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
PDOT COMMENTS: We do not believe that every signalized crosswalk with pedestrian signals needs to have accessible signals as well. In downtown Portland we have numerous small, yet closely spaced signalized intersections. Many of the crossing distances are less than 30 feet
That said, we also agree that many of our signalized intersections do need accessible signals. We just ask that the Board add language to allow exceptions where accessible signals would not be required. Wording for this exception could read something like the following: "An accessible signal may not be required if an engineering study shows that visually impaired pedestrians using skills taught by orientation and mobility specialists can easily use the crosswalk in question. Factors for not needing an accessible signal may include short crossing distances, simple signal phasing, other clear audible queues, and simple intersection geometrics. The engineering study must provide compelling reasons for not installing an accessible pedestrian signal."
1106.4 Directional Information and Signs. Pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal.
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.
PDOT COMMENT: We strongly object to this requirement in that it is inconsistent with other requirements. Street name signs are not required at any other type of intersection. Use of a traffic signal at certain intersections to give traffic flow specific timed intervals of having the right-of-way is still only a form of traffic control. Stop controlled or yield controlled intersections are not much different, yet tactile signs for pedestrians are not required. If the Board wants to provide guidance information for blind travelers, then all intersections should have tactile signs that identify the street names.
1107 Street Furniture
1108 Detectable Warning Surfaces
PDOT COMMENTS: After spending $20,000 to test products, make over 100 installations, and conduct opinion surveys with more than 40 blind persons, we are not convinced that requiring detectable warnings at all curb ramps is good public policy.
Our findings indicate that blind persons could not depend upon the detectable warnings even if every ramp included them. Blind travelers use so many other cues to travel that detectable warning would only provide minor benefit. Most of the persons that we worked with were reasonably well trained and travel quite well without detectable warnings. The opinions of our blind public pertaining to detectable warnings are not any different than the comments received by the Board in response to the proposed draft guidelines. Many liked them, many did not.
From a cost perspective, installation of detectable warnings will be a very expensive endeavor. We found that it would cost between $25 - $30 per square foot of detectable warning surface. A single ramp installation would be at least $200. A typical intersection with 8 individual ramps will cost $1,600. Portland alone has 15,000 intersections. Over time we will spend $24 million (in equivalent 2002 dollars) to complete all of the detectable warning installations in Portland. The national investment in this effort will certainly exceed $10 Billion.
Based upon the input of our blind citizens, we support the discretionary application of detectable warnings only at certain locations. These locations include:
. On perpendicular curb ramps that have grades (slopes) flatter that 5%
. In advance of all active railroad tracks that cross the pedestrian access route of a sidewalk area
. At all other areas where the pedestrian sidewalk area is not clearly delineated from the roadway by curbs or other channelizing barriers.
We also found that detectable warnings were almost useless on all diagonal curb ramps and most ramps that were not aligned directly in-line with the direction of travel. Our blind traveling public seldom strayed off-course to even find diagonal curb ramps. Other types of ramps with radial alignments were easily found by long cane users as they detecting a curb on the flare of the ramp. None of our blind travelers wanted to waste their time searching for the detectable warning surface in these locations.
The Access Board needs to give greater consideration to this issue. It is very clear that some locations should have detectable warning. Most other locations do not need them. Portland would rather utilize members of our blind community to evaluate all questionable locations and would follow their guidance on whether detectable warnings should be installed or not. We feel that this would be a better alternative that having the nation needlessly spend billions of dollars for detectable warnings that provide no benefit to the users.
1108.2 Location.
1108.2.1 Curb Ramps and Blended Transitions. The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches
PDOT COMMENT: Alignment of the detectable warnings is not discussed. Detectable warnings need have the square grid pattern aligned with the direction of travel.
On ramps that intersect the street surface on a radius, the detectable warning surface should also be correctly aligned for pedestrian travel but should not be required to exactly follow the radius of corner. Companies manufacture detectable warning products to meet the square grid pattern. These products cannot be installed to meet a horizontal curved area. An exception needs to be noted and a graphic provided.
1109 On-Street Parking
1110 Call Boxes
1111 Alternate Circulation Path
1111.1 General. Alternate circulation paths shall comply with 1111.
1111.2 Width. The alternate circulation path shall have a width of 36 inches
1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
PDOT COMMENTS: It is very shortsighted for the Access Board to decide that one alternative circulation path on the same side of the street will fit all situations. There are a variety of work zones in pedestrian areas that we encounter daily. Most could not accommodate a same side of street alternate circulation path. Sidewalk work zone examples include, but are not limited to:
1. Complete demolition and full reconstruction of roadways including the removal of all existing vehicular travel lanes, bike paths, furnishing zones, and sidewalks. All travelers are detoured to parallel alternate streets.
2. Similar to #1 above, but only half of the street width is being demolished and reconstructed at one time. All travelers are detoured to the opposite side of the street or to parallel streets.
3. Utility connections from the street to a building. This work zone crosses vehicle travel lanes, bike lane, furnishing zone, and sidewalk. The safety of all public users prevents access to the work zone. Users are shifted to the opposite side of the street.
4. Intersection closures for street paving. All users are detoured to parallel open streets.
5. Installation of curb ramps or new sidewalk facilities the prevent the public from using these facilities until the concrete has sufficiently cured.
6. New building construction which utilizes the full sidewalk width and portions of the street area. Pedestrians and vehicles are either moved to the opposite side of the street or detoured to parallel open streets.
We suggest that this condition be amended to read: "1111.3 Location. An alternate circulation path shall be provided to the disrupted pedestrian access route, on the same side of the street, on the opposite side of the street, or on a parallel street with a marked detour route.
Mark Richert, October 28, 2002
Attached for the Board's consideration are the comments of the Association for Education and Rehabilitation of the Blind and Visually Impaired (AER). These comments were prepared after long and thoughtful scrutiny by members of AER's Orientation and Mobility Division. Please direct requests for further information to Janet M. Barlow [...]
AER and its members appreciate the opportunity to submit these comments and commend the Access Board for its diligence in addressing these pressing issues.
Sincerely,
Mark Richert
Executive Director
Association for Education and Rehabilitation of the Blind and Visually Impaired
Alexandria, VA
Contact: Janet M. Barlow
SUBJECT: Draft Guidelines for Accessible Public Rights-of-Way (June 17, 2002)
The Association for the Education and Rehabilitation of the Blind and Visually Impaired (AER) is an international membership organization of approximately 4600 professionals. Its mission is "to develop and promote professional excellence through support of those who provide education and rehabilitation services to people with visual impairments". The Orientation and Mobility Division of AER represents over 1000 orientation and mobility specialists, individuals who teach independent travel skills to persons who are blind or visually impaired. Certified Orientation and Mobility Specialists (COMS) are graduates of specialized college degree programs in education and/or rehabilitation. The following information and recommendations have been developed by the members of the Environmental Access Committee of AER's Orientation and Mobility Division.
We are delighted that guidelines for the public rights-of-way are now being developed that will address the needs of pedestrians who are blind or visually impaired. Following these recommendations is a resolution passed at the AER conference this summer in support of these guidelines. The transportation and public works community needs guidelines and specific direction to provide facilities that are accessible to pedestrians who are visually impaired or blind.
We are particularly pleased that specifications for detectable warnings and accessible pedestrian signals have been included. As representatives of a profession that has taught travel skills to individuals who are blind over the past 50 years, we recognize the evolution of intersection design and traffic control that now necessitates some of the modifications and accommodations that these guidelines require. Comparing a photo of an intersection in the 1960's with a photo of a current intersection makes it clear that the tasks and issues have changed. While individuals who are blind do cross streets without accessible pedestrian signals and do manage to locate the street edge without detectable warnings, these two tasks, in particular, have become much more difficult, and sometimes impossible, in the past twenty years due to changes in intersection design and signalization.
We strongly support the draft guidelines. The implementation of the draft recommendations on Accessible Pedestrian Signals (APS) and the resultant improvement in predictability and accessibility will go a long way towards insuring that the pedestrian environment remains accessible into the future. Please note in our comments, however, that we recommend that the Access Board add additional language specifying types of intersections where APS should be installed. In addition, we recommend some wording changes in the section on walk messages and suggest a more precise requirement for pole location than that in the PROWAAC report or the MUTCD. We feel that in new construction a tighter specification is possible, and necessary, to make the interface as unambiguous and quiet as possible.
Many who have provided comments seem to be misinformed regarding the types of APS recommended in these guidelines. Their comments and objections to "screeching signals" and "bird calls" indicate that they are unaware of the new types of signals recommended by PROWAAC and these draft guidelines. While many NFB members are expressing opposition to 'beeping signals' on every corner, the Access Board may wish to review articles by NFB President Mark Mauer in which he discusses signals in Australia and Sweden favorably ("World Blind Union Fifth General Assembly" The Braille Monitor, Vol. 44, No.3, March 2001 and "Blindness, Travel, the Environment, and Technology", The Braille Monitor, Vol. 42, No. 9, November, 1999, posted at www.nfb.org). The signals in Australia and Sweden include locator tones and audible and vibrotactile walk indications, installed close to each crosswalk location. This type of signal is exactly what these draft guidelines are calling for.
We have provided our response to the Board's question regarding detectable warnings in the section of these comments regarding the 'Discussion of Provisions'. We have also provided a response to the questions on roundabouts later in these comments. Many specific wording changes and the rationale for the suggested change are included later in this letter as well.
While the Board did not ask for specific comment on the issue of 'directionality' of curb ramps, we urge consideration of issues expressed in the PROWAAC discussions and research to develop solutions. Pedestrians who are blind or visually impaired try to avoid using the slope of the curb ramp as a cue to the direction of the crossing. However, it is difficult to avoid traveling and aligning in the direction of the slope. The detectable warning, as specified, is not an alignment cue, but a 'stop' indication.
The provision of additional alignment information at some types of curb ramps and blended transitions, particularly where the ramp is not aligned with the crosswalk direction, is needed. In addition, the PROWAAC committee was unable to agree on a specification for a tactile cue in the sidewalk to indicate the location of midblock crossings and roundabout crossing to pedestrians who are blind or visually impaired. Research is needed to identify solutions and address concerns of persons with mobility impairments as well as the needs of individuals who are blind or visually impaired. This research should evaluate the ability of pedestrians who are blind or visually impaired to detect and align with various surfaces, such as the bar tiles used in Europe and Japan, line tiles sold by US manufacturers, and other possible alignment surfaces, as well as the ability of wheelchair users and those with mobility impairments to navigate over and around such surfaces.
The Access Board should move as quickly as possible to implement this draft as a rule. Some in the transportation industry may urge waiting for the completion of additional research. Travelers who are blind or visually impaired are required to use the sidewalks and street crossings in their daily travel, usually in conjunction with the use of public transportation. They are at risk in traveling, due to the lack of consideration in current intersection and sidewalk designs. As additional research is completed, it can be incorporated into designs and provisions. These guidelines need to be completed and published as a final rule.
We encourage your consideration of the following specific comments as rulemaking process continues:
DISCUSSION OF PROVISIONS
Detectable Warning
The Board asks for response on a question regarding installation of detectable warnings only on curb ramps with a slope of 1:15
RESPONSE: We support the requirement for detectable warnings on ALL ramps and sidewalk/street transitions leading to crosswalks, regardless of slope. AER resolutions 98-01 and 94-08, supporting this requirement, follow.
Rationale: Two studies confirmed that removal of the curb was problematic for travelers who are blind. Barlow and Bentzen, found that 39% of blind travelers did not detect the street and stop when they approached the crosswalk on a curb ramp. Repeating their analysis using only the ramps that met ADA requirements at that time, (those that had a slope of 1:12
Roundabouts
We applaud the Board's strong stance on signalization of roundabout crossings. We expect that there are alternative solutions to provide accessibility, however, roundabout proponents have been slow to respond to concerns of pedestrians with disabilities. Proponents of roundabouts often quote the reduction in crashes as support for the safety of the installations. Crash data do not tell the whole story; there is little or no information on pedestrian avoidance of roundabout locations. Anecdotal information from Europe and Australia, as well as from US installations, indicates that pedestrians who are blind or visually impaired avoid crossing at roundabouts.
While there is ongoing research on the challenges for pedestrians who are blind or visually impaired and potential solutions, there is a need to slow the proliferation of inaccessible roundabouts in the United States. We believe that traffic engineers and designers who desire to solve this problem can do so, however, the will did not seem to be present until the draft guideline was published which required their attention to the issue. Many designers and governments who are complaining about the problems of signalization seem unable to consider pedestrian signals that function differently than those that have traditionally been installed in the US, as considered by the PROWAAC and the Access Board. The experience of England and other countries with signalization of pedestrian crossings at roundabouts should be considered.
Designers who develop better solutions can always install solutions that provide better accessibility, in full compliance with guidelines. We urge the Board to continue to require signalization of the pedestrian crossings.
1101.3 DEFINED TERMS
Detectable warning
ADD: standardized
Detectable Warning. A standardized surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path.
Rationale: Those reading the definition need to understand that the surface of the detectable warning is specified in ADAAG and that various textured surfaces may not meet the requirements of a detectable warning.
Locator tone:
CHANGE to: Pushbutton Locator Tone?a repeating sound that informs approaching pedestrians that they are required to push a button to actuate pedestrian timing and that enables pedestrians who have visual disabilities to locate the pushbutton.
Rationale: The above definition is the definition and term used in the MUTCD.
1102. SCOPING
1102.5.2 Protruding objects
1102.5.2 Post-Mounted Objects.
ADD: Where a sign or other obstruction is mounted between posts or pylons and the clear distance between post or pylons is greater than 12 inches
Rationale: We are delighted with the reduction of distance that objects can protrude from posts. This will eliminate many hazards in the sidewalk area. Pedestrians who are blind or visually impaired may travel on any part of the public sidewalk and are not limited to the pedestrian access route, a fact which many designers do not seem to understand.
The sentence regarding posts and pylons seemed to be missing a section regarding the distance between posts and pylons. In addition, we encourage the addition of the requirement for a lower bar on such signs. Signs between poles, and railings with their leading edges higher than 15 inches
The three principal cane techniques are: 1) the touch technique, where the cane is lifted slightly off the ground and moved in an arc from side-to-side and touches the ground at points outside both shoulders; 2) the constant contact technique, where the cane is slid from side-to-side in a path extending just beyond both shoulders; and 3) the diagonal technique, where the cane is held in a stationary position diagonally across the body with the tip just above the ground at a point outside one shoulder and the handle extended to a point outside the other shoulder. When one of these techniques is used and the element is in the detectable range, it gives a person of average adult stature, who uses proficient technique with a long cane, sufficient time to detect the element with the cane before there is body contact. The typical cane techniques do not locate objects extending into the travel path above the hips. For persons of short stature, including children, simple geometry indicates that they will be unlikely to detect objects with a long cane before contacting them with the body when the leading edge is as high as 27 inches
1102.7.1 Bus Route Identification. Exception 2
ADD: If portable receivers are required to access the signs, receivers must be freely distributed persons with disabilities who cannot read print signs.
Rationale: Allowing such an exception does not provide accessible information unless there is a concomitant requirement to distribute the receivers to those who may wish to access the information.
1102.8 Pedestrian crossings
CHANGE TO: Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, where pedestrian signal timing is actuated by pedestrian detectors (pushbuttons) or by passive pedestrian detection, or where leading pedestrian intervals or exclusive pedestrian phasing is used, pedestrian signals shall comply with 1106.
Rationale: The draft language does not require accessible information to be provided at intersections unless pedestrian signals are installed. The Manual on Uniform Traffic Control Devices (MUTCD) only requires (using 'shall' language) the installation of pedestrian signals at limited locations, such as school zones, crossings where a signal is installed due to high pedestrian volumes, and where there is exclusive pedestrian phasing. Other locations are discussed in 'should' language. We are concerned that this rule may encourage traffic engineers to limit the installation of pedestrian signals, in order to avoid installing accessible pedestrian signals. In the MUTCD, pedestrian signals are not required at some locations because the vehicular signal can be considered adequate, under provisions in the MUTCD, to provide information to pedestrians. Under the current draft guidelines, therefore, there would be no imperative to make the "green ball" information accessible. These locations may not provide adequate information for pedestrians who are blind without installation of accessible pedestrian signals.
The locations suggested above and in the PROWAAC report are ones at which the signal features make it hard to detect the pedestrian crossing phase without provision of accessible information. Locations such as those are known to be problematic for pedestrians who are blind or visually impaired. In addition, there may be other locations where the traffic movement does not provide sufficient information for pedestrians who are blind or visually impaired.
We are unable at this time to suggest language that will cover all possible situations in which accessible information may be needed by an individual pedestrian who is blind. Therefore we recommend that at signalized intersections in new construction where pedestrian facilities such as sidewalks are provided but pedestrian signalization is not, that conduit piping be installed in relation to the curb ramps such that a retrofit with APS if required could be easily accomplished.
As we stated previously, many who have provided comments seem to be misinformed regarding the types of APS recommended in these guidelines as well as the types of intersection signalization typically used now. (see our opening comments). Most newly installed intersections will be traffic actuated and will have complex traffic patterns. Pedestrian actuated traffic signals change with each cycle and usually require the pedestrian to push a button to get enough time in the cycle to cross the street. As well, the vehicular patterns and pedestrian timing may vary, depending on the signal timing plan of the intersection. The pedestrian timing may be concurrent with the traffic moving parallel to the pedestrian's path, or at a totally different time in the cycle. Pedestrians who misjudge the starting traffic pattern may find themselves in the street when cars are moving perpendicular to their path with a 'green arrow'. These changes have resulted in our advocacy for Accessible Pedestrian Signals to provide individuals who are blind or visually impaired with the signal information provided to persons who are sighted.
At the public information meeting in Portland, APS device costs of $4000 per device were suggested by some individual commenters. These estimates are incorrect. The cost of a pushbutton integrated APS, such as referred to in the draft guidelines, is currently approximately $400. per device. As with many items, that estimate may be reduced with quantity purchasing.
1102.10 Stairs
We agree with this addition that will make stairs in the public rights-of-way more visible to all pedestrians. We suggest a slight revision in the language.
DELETE: 'of color'
INSERT: "contrasting with the tread and riser, dark on light or light on dark,"
1102.10 Stairs. Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
Rationale: Light/dark contrast is the important feature, not color or hue.
1104 CURB RAMPS AND BLENDED TRANSITIONS
1104.3 Common Elements
MOVE: 1104.3 Common elements to 1104.2 and Types to 1104.3
Rationale: The common elements need to be more clearly described before the details of the various types of ramps. In addition, blended transitions may need additional language to clarify that a raised intersection or raised crosswalk could provide a blended transition.
1104.2.1 Perpendicular curb ramps.
ADD: Where possible, the slope of the curb ramp shall be aligned with the sidewalk and crosswalk direction.
Rationale: The orientation of curb ramps toward the intersection can be disorienting for travelers who are blind or visually impaired. In addition, they require an extra turn for wheelchair users. We believe that the guidelines need to encourage orientation of the ramp in the direction of travel on the crosswalk.
PROWAAC debated at great length on the issue of curb ramp orientation. While travelers who are blind or visually impaired do not use the slope of the ramp to determine their crossing alignment, it is difficult to prevent the slope from influencing travel direction. Advocates for pedestrians with visual impairments recognize the safety issues for wheelchair users of warping at the gutter/ramp intersection, however, whenever possible, the slope of the ramp should be aligned with the crosswalk and the grade break should be aligned perpendicular to the crosswalk alignment. The language of the guidelines needs to state that and encourage two ramps more strongly.
1105 PEDESTRIAN CROSSINGS
1105.4.2 Medians and Pedestrian Refuge Islands - Detectable Warnings
DELETE: Exception
Rationale: Detectable warnings inform the pedestrian who is blind or visually impaired about the presence of a cut-through island or median. They should be required at all medians and islands. Although the pedestrian may not need to stop at that location when the signal timing is adequate for a full crossing, slower pedestrians may prefer to stop and wait, if they know the refuge exists. In the absence of an APS, blind pedestrians frequently begin crossing during the clearance interval because of the difficulty of determining the exact onset of the walk interval, and the resulting inability to "claim" the crosswalk before vehicles turning across the crosswalk. Hence, they may have insufficient time to cross the street. Denying them the information that they have a safe refuge constitutes discrimination and endangers the life safety of pedestrians who are blind in such situations. Even in the presence of APS, because they are unable to make eye contact with drivers, pedestrians with visual impairments have difficulty claiming the crosswalk during the walk interval, and may be delayed in starting crossings relative to sighted pedestrians.
In addition, contacting the side edge unexpectedly when traveling within the cut-through section of the median can be disorienting and confusing if pedestrians do not realize they are within a median area. The detectable warning provides the pedestrian with information about the location of the cut-through refuge area.
1105.6 Roundabouts
1105.6.1 Separation
CHANGE TO: Continuous barriers landscaping separation or railings shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. When railings are used, they shall have a bottom rail 15 inches
Rationale: Use of the word barriers is confusing. Landscaping can be an appropriate guide to guide individuals to the crosswalk location, instead of a barrier or guardrail.
1105.6.2 Signals
We urge the Board to keep this language and requirement for signals at each crossing of roundabouts. See previous comments in answer to the question in the Preamble.
1105.7 Turn lanes at Intersections
We also applaud the inclusion of pedestrian activated signals at these locations, which have been problematic for pedestrians who are blind for years.
1106. ACCESSIBLE PEDESTRIAN SIGNAL SYSTEMS
1106. 1 General.
We recommend the use of the term "Accessible Pedestrian Signal (APS)", rather than Signal Systems or Pedestrian Signal Devices in this text to more closely conform to the MUTCD language and typical current terminology.
Rationale: The Board has introduced new language in these guidelines that does not match with language typically used in either the traffic engineering or the orientation and mobility professions. 'Signal system' is a defined term in the MUTCD ("Signal System - two or more traffic control signals operating in signal coordination"). 'Signal system' is not used with that meaning in these guidelines. It is important that engineers and those who are familiar with the MUTCD understand these guidelines properly.
1106.2 Pedestrian Signals.
CHANGE: Each crosswalk with pedestrian signal indication, or where pedestrian signal timing is actuated by pedestrian detectors (pushbuttons) or by passive pedestrian detection, or where a leading pedestrian interval or exclusive pedestrian phasing is used, shall have a signal device an Accessible Pedestrian Signal which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device Accessible Pedestrian Signal and shall comply with 1106.3.
Rationale: As stated earlier in our discussion of scoping, 1102.8, pedestrian signals are not required at some locations because the vehicular signal can be considered adequate, under provisions in the MUTCD, to provide information to pedestrians. These locations may not provide adequate information for pedestrians who are blind without installation of accessible pedestrian signals.
The term 'signal device' has a different meaning in the traffic engineering profession and may not be understood to mean a device that is commonly known as an Accessible Pedestrian Signal. There's no need to introduce confusion.
1106.3 Location.
CHANGE: Pedestrian signal devices Accessible Pedestrian Signals shall be located 60 inches
Rationale: In new construction, the location for the APS can and should be restrictive and consistent. The 'box' in the MUTCD was developed in consideration of retrofit situations and local practice; it is a large area 10 feet
The requirement of location more than 30 inches
1106.2.3 Audible Walk Indication
CHANGE: The audible indication of the WALK interval shall be by voice speech message or tone.
Rationale: The use of the term 'speech message' is more accurate. We are concerned that use of 'voice' will be considered to require the recording of human voice messages. Some methods of digital speech may provide more consistent messaging than individual recordings. Currently, AT&T provides text to speech messaging capabilities on the web and in commercially available software. (http://www.naturalvoices.att.com/demos/index.html)
1106.2.3.1 Tones.
CHANGE: Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds
Rationale: The current wording of the duration and repetition rate could be understood to indicate a continuous tone. We assume that the Board intended to require a tone such as is used in the Swedish or Australian signals. These repeat at rates of around 7 to 10 repetitions per second with short bursts of sound, with silence between tones of around 50 milliseconds. A repetition rate of 0.15 seconds
1106.2. Speech WALK Messages.
ADD A NEW SECTION
ADD: 1106.2._ Speech WALK Messages.
ADD: 1106.2. WALK signals may be in the form of speech messages.
1106.2._._ Speech WALK messages shall contain the words "WALK SIGN."
1106.2._._ Speech WALK messages shall repeat throughout the WALK interval or be combined with a repeating WALK tone.
Exception: Speech messages may be limited to a maximum of seven seconds in duration where pedestrian signals rest in WALK.
1106.2._._ At intersections having concurrent pedestrian phasing, speech messages shall follow the model: "Howard. Walk sign is on to cross Howard." Designation of "street, "avenue," etc. shall be used whenever its omission could lead to ambiguity.
Rationale: The language of speech walk messages must be consistent and these guidelines should repeat at least the same specifications as in the MUCTD. The MUTCD specifies that speech WALK messages should say 'Walk sign', in order to provide information about the status of the walk indication without providing a command, such as 'walk now'. Accessible Design for the Blind completed a survey of pedestrians who are blind, traffic engineers and orientation and mobility specialists last year and developed recommendations for speech WALK messages, as well as pushbutton informational messages. The recommended wording for WALK messages was "Howard. Walk sign is on to cross Howard."
In the US, speech WALK messages are commonly used in newer accessible pedestrian signal installations. All of the pushbutton-integrated devices on the market in the US are capable of providing speech messages. Speech WALK messages are not necessary to providing unambiguous information regarding which crosswalk has the WALK interval, provided that pushbuttons are installed in the locations specified, and they will be unintelligible to some users in some ambient noise conditions. However, speech walk signals are perceived as being more user-friendly than tonal WALK signals. Good installation has a number of requirements.
Speech WALK messages should continue to repeat throughout the WALK interval, or be combined with a WALK tone for the balance of the WALK interval so that pedestrians with visual impairments will know when the WALK interval ends, they will be aware of its full duration, and be able to initiate street crossings in knowledge of the status of the pedestrian signal. Combination of a speech WALK signal with a tone signal may have some of the advantages of both. It should be clear that this is permitted.
At many intersections of an arterial with a minor street, the pedestrian signal on the minor street "rests in WALK" during the vehicular green of the arterial, until a pedestrian or vehicle actuates the signal to enter or cross the arterial. WALK signals that sound continuously during what is sometimes a walk interval some minutes long will be particularly objectionable in neighborhoods. Most of the pushbutton-integrated APS have means to limit the WALK signal to a certain number of seconds. Pedestrians may be able to actuate the audible WALK signal multiple times during the same (rest-in-)WALK interval.
1106.2.3.2 Volume
ADD: Exception: When special activation is used to provide audible beaconing, the volume may exceed 5dB above ambient noise level.
Rationale: Special activation of louder signals may be useful in some situations to provide beaconing. If it is provided by special activation, such as a long press of the pushbutton, as suggested by PROWAAC and provided by several US manufacturers of APS, the louder signal will only sound when someone requests such a feature. Allowing a volume increase in response to special activation will provide some flexibility as these features develop in response to needs and as research continues on these issues.
Additional speakers mounted at pedhead might be found to provide directional information to pedestrians who are blind or visually impaired; we do not want these guidelines to prevent further evaluation of that option.
1106.2.3.3 Duration
ADD: WALK tones shall repeat throughout the WALK interval.
Exception: WALK tones may be limited to a maximum of seven seconds in duration where pedestrian signals rest in WALK.
Rationale: At many intersections of an arterial with a minor street, the pedestrian signal on the minor street "rests in WALK" during the vehicular green of the arterial, until a pedestrian or vehicle actuates the signal to enter or cross the arterial. WALK signals that sound continuously during a walk interval that is often several minutes long will be particularly objectionable in neighborhoods. Most of the pushbutton-integrated APS have means to limit the WALK signal to a certain number of seconds. Pedestrians can actuate the audible WALK signal multiple times during the same rest-in-WALK interval, if needed.
1106.3.2 Pushbutton Locator Tone.
ADD: Exception: When special activation is used to provide audible beaconing, the volume of the locator tone for the succeeding clearance interval may exceed 5dB above ambient noise level
Rationale: When special actuation of louder signals is used to provide beaconing, having the loudness of the pushbutton locator tone increased for the remainder of the pedestrian phase is essential to enabling those who need this assistance to home in on the opposite corner while they are still in the middle of the crossing.
1107.4 Arrow
ADD: more specific information on contrast
1106.4.Arrow. Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 (0.8 mm) minimum and shall be 1-1/2 inches
Rationale: Contrast in hue may not be perceptible but light/dark will be perceptible for most who use visual information.
1106.4.2 Street name
CHANGE TO READ: Accessible pedestrian signals shall include street name information aligned parallel to the crosswalk direction and complying with 703.3, or shall provide street name information in audible format.
Rationale: Street name information provided in audible format will be usable by more individuals than street name information provided in tactile format.
Providing street name information in tactile characters will result in signs that are very large. Most persons who read by touch read Braille. If there is a requirement for tactile street name information, it is more reasonable to require Braille information than tactile characters. It will serve those who will use it better, and require smaller, less expensive signs.
1108. DETECTABLE WARNINGS
1108.1.2 Size
CHANGE Add a maximum depth:
1108.1.4 Size. Detectable warning surfaces shall extend 24 inches
Rationale: We assume the Board did not establish a maximum depth of detectable warning because there is some research evidence that deeper warnings are more detectable. However, while research by Bentzen and others consistently found that blind persons more reliably detected detectable warnings at 30 inches
Failure to specify a maximum depth could result in continued installation of detectable warnings on the full surface of curb ramps. Installing such large areas of detectable warning surfaces as entire curb ramps provides less precise information to blind pedestrians than installing a smaller amount in a very predictable location. In addition, larger depth may result in increased expense and greater possible adverse impact on persons with mobility impairments.
1108.2.1 Curb Ramps and Blended Transitions
ADD EXCEPTION:
Exception: At cut-through islands and medians, the detectable warning may be located so that the edge nearest the crosswalk is at the curb line.
Rationale: The PROWAAC recommendation that detectable warnings be 6-8 inches
However, requiring that detectable warnings be 6-8 inches
1108.2.2 Rail Crossings
ADD EXCEPTION.
Exception: Where automatic gates across pedestrian ways bar pedestrian access to the crossing when rail vehicles are approaching or at a crossing, the detectable warning surface shall be located to the side of the automatic gate farthest from the crossing.
Rationale: Automatic gates can cause serious head injury to blind pedestrians approaching crossings. There is currently no reliable way for pedestrians who are blind to be notified of the location of automatic gates. Gate support is typically outside the normal pedestrian route and not likely to be encountered by blind pedestrians. Where there is a gate, a blind pedestrian may become trapped between the gate and the crossing, with the gate barring the way for the blind pedestrian to move farther away from the crossing.
Thank you for opportunity to comment. It is important that the needs of pedestrians, including those who are visually impaired or blind, are considered in the ADA guidelines.
Following: AER Resolutions
Resolution 2002 - 05
WHEREAS people with disabilities and in particular those who are blind or visually impaired have difficulties negotiating Public Rights of Way in the United States and in Canada; and
WHEREAS, in the United States, the Architectural and Transportation Barriers Compliance Board (Access Board) has developed draft design guidelines to ensure that access for persons with disabilities is provided wherever a pedestrian way is newly built or altered, and to insure that the same degree of convenience, connection, and safety afforded the public generally is available to pedestrians with disabilities; and
WHEREAS street crossings at signalized intersections are often inaccessible to pedestrians with vision impairments; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for
accessible pedestrian signals at all crosswalks with pedestrian signal
information, and guidelines to make all pedestrian pushbuttons accessible; and
WHEREAS in Canada, recommendations for revised standards for accessible
pedestrian signals and accessible pedestrian pushbuttons are currently being developed by the Canadian National Committee on Accessible Pedestrian Signals; and
WHEREAS where boundaries between pedestrian and vehicular ways are not
reliably detectable to pedestrians with vision impairments, these
pedestrians may be unaware when they move from the pedestrian way into the vehicular way; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for defining the boundary between the pedestrian way and the vehicular way by the use of truncated dome detectable warnings where curb ramps, landings and blended transitions connect to crosswalks, and at cut-through medians and islands, and at level rail crossings in the pedestrian way; and
WHEREAS crossings at roundabouts and slip lanes are often inaccessible to pedestrians with vision impairments because of difficulties inherent in determining safe crossing times based on acoustic information, and because of difficulties in locating crosswalks; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for
accessible pedestrian signals for each segment of each crosswalk, and
barriers where crossing is not permitted; and
WHEREAS pedestrians with vision impairments are at an equally great risk from objects protruding from poles and from walls; and
WHEREAS the U.S. Access Board has therefore proposed guidelines in which the amount by which objects may protrude from both poles and from walls is four inches; and
WHEREAS temporary circulation paths are independently usable by persons with vision impairments only if they know about them, and temporary barriers that are not detectable by the use of a long cane do not adequately protect pedestrians with vision impairments, or channelize them along an alternate route if they are not readily detectable by the use of a long cane; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for signs, and guidelines for barricades that are readily detectable by persons traveling with the aid of a long cane; and
WHEREAS persons with low vision are at particular risk of falling at stairs because of inability to visually determine the depth of tread and height of riser; and
WHEREAS the U.S. Access Board has therefore proposed a guideline for
contrasting color along the nosings of stairs, that will increase the
perceptibility of tread depth and riser height;
Therefore be it resolved that on this 21st day of July, 2002, in the city of Toronto, Ontario, that the Association for Education and Rehabilitation of the Blind and Visually Impaired (AER) commends the Access Board for attending carefully to the unique access needs of persons with vision impairments in the preparation of the Draft Guidelines for Accessible Public Rights-of-Way.
Be it further resolved that AER urges the U.S. Federal Highway Administration to bring the Manual on Uniform Traffic Control Devices into harmony with the Draft Guidelines for Accessible Public Rights-of-Way.
Be it further resolved that the AER urges the Transportation Association of Canada to incorporate the recommendations of the Canadian National Committee on Accessible Pedestrian Signals into the Canadian Manual of Uniform Traffic Control Devices.
Be it further resolved that the AER urges the Canadian Standards Association to consider harmonizing Canadian standards with the recommendations in the U.S. Draft Guidelines for Accessible Public Rights-of-Way concerning detectable warnings, protruding objects, temporary circulation paths, roundabouts and stair nosings.
RESOLUTION 94-08
WHEREAS professionals in Orientation and Mobility have observed that when visually impaired pedestrians approach streets at curb ramps they are at risk of walking unaware into the path of moving traffic, since there is no clearly defined distinction at curb ramps between the roadway and sidewalk; and
WHEREAS research has now been conducted which confirms that for persons who are visually impaired, there is a high level of risk of inadvertent street entry associated with the presence of curb ramps, particularly those having slopes of 1:12
WHEREAS it has been demonstrated that detectable warnings complying with ADAAG 4.29.2 are highly detectable by persons with visual impairments, and can provide an effective stop signal for persons who are blind or visually impaired which can be used to determine the end of the sidewalk and the beginning of the vehicular way; and
WHEREAS research has now been conducted which addresses concerns about safety of detectable warnings, indicating that detectable warnings on slopes have minimal impact on the safety and ease of travel for persons having physical disabilities (Bentzen, et al. 1994); and
WHEREAS research has demonstrated that 24 inches
WHEREAS consistency in dimensions and placement of detectable warnings is of critical importance in successful interpretation by the user in varied settings;
THEREFORE BE IT RESOLVED on this 13th day of July, 1994, in the city of Dallas, Texas, that AER urges the Architectural and Transportation Barriers Compliance Board (Access Board) to issue a rule requiring a 24 inch
BE IT FURTHER RESOLVED that AER urges the Access Board to issue a rule requiring a similar 24 inch
Resolution 98-01
WHEREAS Orientation and Mobility Specialists have observed that when visually impaired pedestrians approach streets at curb ramps they are at risk of walking unaware into the path of moving traffic, since there is no clearly defined distinction at curb ramps between the roadway and sidewalk; and
WHEREAS research has now been conducted which confirms that for persons who are visually impaired there is a high level of risk of inadvertent street entry associated with the presence of curb ramps, particularly those having slopes of 1:12
WHEREAS it has been demonstrated that detectable warnings complying with ADAAG 4.29.2 are highly detectable by persons with visual impairments, and can provide an effective stop signal for persons who are blind or visually impaired which can be used to determine the end of the sidewalk and the beginning of the vehicular way; and
WHEREAS research has now been conducted which addresses concerns about safety of detectable warnings, indicating that detectable warning on slopes have minimal impact on the safety and ease of travel for persons having physical disabilities (Bentzen, B., Nolin, T., Easton, R., Desmaris, P., and Mitchell, P., 1994; Hauger, et al, 1996); and
WHEREAS research has demonstrated that 24 inches
WHEREAS it was the nearly unanimous recommendation of the workshop on curb ramps and detectable warnings sponsored by the U.S. Access Board and Project ACTION in January, 1995, that no additional research was needed on detectable warnings at curb ramps and that a detectable warning should forthwith be required on the full width of curb ramps beginning at the curb line and extending back 24"; and
WHEREAS numerous municipalities in the United States have installed detectable warnings on curb ramps and have reported no instances in which safety has been compromised by the presence of detectable warnings on curb ramps;
THEREFORE BE IT RESOLVED on this 12th day of July, 1998, in Atlanta, Georgia that AER urges the U.S. Access Board to provide specific opportunity for public comment on detectable warnings at curb ramps and hazardous vehicular ways when the notice of proposed rulemaking for the revised ADA Accessibility Guidelines is published.
BE IT FURTHER RESOLVED that AER continues to strongly advocate the provision of a 24" wide detectable warning surface at the bottom of curb ramps and at hazardous vehicular ways, particularly where those hazardous vehicular ways are blended curbs or raised crossings at intersections.(See AER Resolution 94-08).
BE IT FURTHER RESOLVED that AER urges Transport Canada to require a 24" wide detectable warning surface at the bottom of curb ramps and at hazardous vehicular ways, particularly where those hazardous vehicular ways are blended curbs or raised crossings at intersections.
Resolution 98-02
WHEREAS the Americans with Disabilities Act guarantees the right of access to information to persons with disabilities; and
WHEREAS many signalized intersections provide information to pedestrians with sight which is not provided to pedestrians with visual impairments; and
WHEREAS it has been demonstrated ( Crandall, W., Bentzen, B.L., and Myers, L., 1998) that competent, independent, blind pedestrians at unfamiliar signalized intersections may initiate as many or more than 34% of crossings during the clearance or DON'T WALK intervals if those intersections are not equipped with accessible pedestrian signals; and
WHEREAS accessible pedestrian signals have been widely used for more than 10 years in countries including Australia, Japan, Sweden, and the United Kingdom and are considered by traffic engineers to be widely effective not only in providing information to blind pedestrians but also in decreasing general pedestrian delay and facilitating vehicular flow at signalized intersections; and
WHEREAS increasing numbers of quiet vehicles, including electric vehicles and those with quiet internal combustion engines, make acoustic information from vehicles inconsistent, resulting in the inability of pedestrians who are blind to reliably detect the onset of the WALK interval by listening for a surge of vehicles; and
WHEREAS inexpensive technologies exist to make Accessible Pedestrian Signals which are automatically responsive to ambient sound , being very quiet at night and in low traffic situations, while still loud enough to be heard above vehicular sound in high traffic situations; and
WHEREAS accessible vibrotactile and speech transmission signal systems exist which add no noise to the environment; and
WHEREAS the Transportation Equity Act for the 21st Century provides that "Transportation plans and projects . . . shall include the installation, where appropriate, and maintenance of audible traffic signals and audible signs at street crossings;"
THEREFORE BE IT RESOLVED on this 12th day of July, 1998, in Atlanta, Georgia that AER urges the U.S. Federal Highway Administration and Transport Canada to develop recommended practices for installation of pedestrian signals which make information which is regularly provided to other pedestrians, accessible to pedestrians who are visually impaired, including but not limited to: information specifying WALK and DON'T WALK intervals; information indicating the presence and location of push-buttons; and information unambiguously indicating the street to which the signal applies.
Resolution 98-03
WHEREAS traffic engineers are increasingly utilizing signal systems in which the only safe time to cross signalized intersections is provided in response to pedestrian use of a push button; and
WHEREAS persons who are visually impaired consistently identify location of the push button as the major problem they experience at pedestrian actuated intersections (American Council of the Blind survey, 1998; City of San Diego, Department of Transportation, 1994; and Tauchi, M., Sawai, H., Takato, J., Yoshiura, T., and Takaeuchi, K., 1998 ); and
WHEREAS persons who are visually impaired often have insufficient time when pedestrian push buttons are far from associated crosswalks, to actuate push buttons and then prepare to cross before the onset of the WALK interval (American Council of the Blind survey, 1998); and
WHEREAS unobtrusive technologies exist for providing information in accessible format, specifying the presence and location of push buttons;
THEREFORE BE IT RESOLVED that AER urges the U.S. Federal Highway Administration and Transport Canada to develop standards for push button location technology such as quiet audible locator tones, and to require the placement of newly installed pedestrian push buttons in close proximity to the top landing of the curb ramp serving that crossing, within accessible reach range for use from a wheelchair, and near enough to the curb line that persons with visual impairments can actuate the push button and then align and prepare for crossing before the onset of the WALK interval.
RESOLUTION 2000-05
WHEREAS there are roundabouts in many states in the United States, and many more are proposed or under construction; and
WHEREAS roundabouts have been shown to reduce the rate of serious personal injury crashes to drivers and passengers relative to similar signalized intersections, and thus have demonstrated their usefulness as an option for intersection design; and
WHEREAS despite the benefits to motorists, recent research at roundabouts in the U.S. indicates that blind pedestrians have difficulty at some roundabouts in determining appropriate times to begin crossing, and also may have difficulty locating crosswalks, aligning to cross the street, and maintaining their heading while crossing; and
WHEREAS focus groups of blind pedestrians conducted by U.S. researchers in the United Kingdom and France reported that the many roundabouts in those countries caused serious access problems for pedestrians who are blind or visually impaired; and
WHEREAS persons with blindness or visual impairments have the right to full access to public rights of way, including roundabouts;
NOW THEREFORE BE IT RESOLVED, this 19th day of July, 2000 in
BE IT FURTHER RESOLVED that, as research identifies best practices concerning roundabouts and blind pedestrians, these practices be implemented by traffic engineers and planners, and included in all U.S. and Canadian design manuals covering roundabouts.
Unanimously Approved
David Harrell, P.E., October 25, 2002
Per our conversation, attached are comments from the City of Knoxville's Department of Engineering on the Draft Guidelines on Accessible Public Rights-of-Way. I will follow this up with a hard copy and cover letter via regular mail.
Sincerely,
David Harrell, P.E.
Chief Civil Engineer
City of Knoxville
Dept. of Engineering
CITY OF KNOXVILLE, TENNESSEE
DEPARTMENT OF ENGINEERING
Comments on Draft Guidelines on Public Rights-of-Way
SECTION 1102.2.2 Alterations. It is noted that alterations must not be fully compliant "where compliance is technically infeasible". We find the statement to be too vague and believe it needs further clarification. The examples of technical infeasibility given in the "Discussion of Provisions" are extreme cases. For example, would adding a left turn signal to a signalized intersection that has a pedestrian signal system require making the pedestrian signal system fully accessible? If so, this could potentially turn a $400 upgrade into a $10,000 upgrade. We would consider this just as technically infeasible as "altering a load-bearing member of a structural frame". While technically this could be done, the cost to make the area within the alteration fully compliant compared to the cost of the alteration itself would make the project no longer viable.
SECTION 1104.3.2 Detectable Warnings. We concur with the advisory committee's comments on using detectable warnings on only those ramps that are the least distinguishable. While the revised specifications are an improvement we believe the truncated domes to be hazardous for elderly pedestrians and will still cause difficulties in maneuvering for wheelchairs.
SECTION 1104.3.3 Surfaces. When altering an existing facility such as adding a curb ramp where none exists, it is not always possible to locate the ramp to avoid manhole covers for utilities. While the elevation of these covers can be adjusted to match the slope and elevation of the ramp, it is impractical to have these manholes relocated. We would expect this situation to fall under the "technically infeasible" category.
SECTION 1104.3.6 Counter Slopes. Integral curb and gutter sections are typically slip-formed and typically have a cross-slope of 1:12
SECTION 1105.2.2 Cross Slope. With terrain such that is typical in East Tennessee, profile grades of 9 or 10 percent are very common. This requirement would be extremely difficult, it not impossible, to implement for roads having grades of this magnitude. In order to make an intersection design work for a road of this type, the profile grade must be changed by 7 or 8 percent along a vertical curve that maintains the design speed of the road. Typically, the cross-slope of the intersecting street is often sloped as much as 4 percent to minimize the required change in profile grade of the through street.
SECTION 1105.4 Medians and Pedestrian Refuge Islands. The cut through concept is a good idea to provide access for pedestrian access but the need for pedestrian storage needs to be considered as well, e.g., when crossing pedestrians to the refuge island on one phase and then the remainder of the crossing under another phase. The situation could arise where several pedestrians would be crossing but not enough space is provided in the island crossing area and would leave some of the pedestrians in the roadway until the next pedestrian crossing phase.
SECTION 1105.7 Turn Lanes at Intersections. Most right-turn slip lanes have no signalized control other than a yield sign. It would not be practical to locate a pedestrian signal system at these locations as the slip lanes are not signalized. Signalizing the slip lane to enable the use of a pedestrian signal system would effectively remove the reason for providing the slip lane.
SECTION 1102.8 and 1106 Accessible Pedestrian Signal Systems. Is the requirement to install these devices at all existing signalized intersections that currently provide pedestrian signal systems or at only that intersection that will be constructed and/or upgraded. If the Board is advocating that all the pedestrian signal systems be upgraded then there needs to be some consideration to phasing in a program over time to help defer the cost of these upgrades. The cost could exceed $20,000 per intersection for the accessible pedestrian signal system at complex signalized intersections and could be much higher if the relocation of existing signal poles or the addition of pedestrian signal poles is required. Considerations should take for the cost of initial installation and the need for additional maintenance personnel to maintain this type of facility to insure proper operation.
Victor M. Mendez, P.E., October 21, 2002
Arizona Department of Transportation
Intermodal Transportation Division
RE: COMMENTS ON AMERICANS WITH DISABILITIES ACT DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
Dear Mr. Windley:
The Arizona Department of Transportation (ADOT) has reviewed the Americans With Disabilities Draft Guidelines for Accessible Rights-of-Way published on 17 Jun 2002. ADOT endorses the Board's aim of ensuring that access for persons with disabilities is provided wherever a pedestrian way is newly built or altered, and that the same degree of convenience, connection, and safety afforded the public generally be available to pedestrians with disabilities.
Noting our endorsement of the Board's aim, we have taken the time to comment on each of the sections and sub sections to the draft guidelines in hope of assisting in the rulemaking process. The comments are enclosed for consideration by the Architectural and Transportation Barriers Compliance Board. We understand that the Board will review all the comments submitted prior to continuing with the proposed rulemaking.
Please contact Kenneth Cooper at [...] if you or the Board have any questions or if you wish to discuss the comments.
Sincerely yours,
Victor M. Mendez, P.E.
Director
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COMMENTS FROM ARIZONA DEPARTMENT OF TRANSPORTATION
AMERICANS WITH DISABILITIES ACT
DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
PUBLISHED JUNE 17, 2002
General Comments:
A. The Arizona Department of Transportation (ADOT) supports the position expressed in the Introduction to the Draft Guidelines for Accessible Public Rights-of-Way that, "The guidelines do not require alterations or retrofits to existing public rights-of-way, but would apply where a pedestrian route or facility is altered as part of a planned project to improve existing public rights-of-way.";
B. ADOT recommends the inclusion of graphics to help clarify and explain the guidelines; and
C. ADOT strongly recommends that maximum crosswalk, landing, and ramp slopes be redefined to take into account the grade of the adjacent facility. It may be technically infeasible and poor engineering practice to provide running and/or cross slopes of 1:48
Sec. 1101 Application and Administration
Sec. 1101.1 General: For the purposes of these requirements, the terms listed in section 1101.3 shall have the indicated meaning.
ADOT has "No comment" on this section.
Sec. 1101.2 Referenced Standards
Recommend that the following manuals also be included by reference into the guidelines as they provide nationally accepted guidance regarding the design of roadways and pedestrian facilities:
A. American Association of State Highway and Transportation Officials (AASHTO), A Policy on Geometric Design of Highways and Streets 2001;
B. AASHTO, Roadside Design Guide 2002; and
C. Federal Highway Administration, Highway Design Handbook For Older Drivers and Pedestrians 2001.
Sec. 11012.1 MUTCD: Copies of the referenced standards may be obtained on-line from the Federal Highway Administration at http://mutcd.fhwa.dot.gov. MUTCD 2000-Millennium Edition Manual on Uniform Traffic Control Devices.
The Arizona Department of Transportation (ADOT) supports the inclusion of the Manual on Uniform Traffic Control Devices (MUTCD) into the guidelines by reference.
Sec. 1101.3 Defined Terms:
ADOT requests a definition be added that clarifies where slope maximum and minimum values are provided, "maximum" and "minimum" refer to the steepness of the slope.
Accessible Pedestrian Signal. A device that communicates information about the pedestrian WALK phase in non-visual format.
Accessible Route. A continuous, unobstructed path that complies with Chapter 4.
Channelizing Island. Curbed or painted area outside the vehicular path that is provided to separate and direct traffic movement, which also may serve as a refuge for pedestrians.
Cross Slope. The slope that is perpendicular to the direction of travel.
This is usually called superelevation on curves in the public right-of-way (see superelevation).
ADOT requests clarification of this definition as the second sentence is not wholly correct. Curves in the public right-of-way may have a normal crown and not be superelevated. Superelevation usually occurs, but not exclusively, in rural settings and where the prevailing speed is greater than 35 miles per hour.
Crosswalk. That part of a roadway at an intersection that is included within the extensions of the lateral lines of the sidewalks on opposite sides of the roadway, measured from the curbline or, in the absence of curbs, from the edges of the roadway or, in the absence of a sidewalk on one side of the roadway, the part of the roadway included within the extension of the lateral lines of the sidewalk at right angles to the centerline. Also, any portion of a roadway at an intersection or elsewhere that is distinctly indicated for pedestrian crossing by lines or other markings on the surface.
ADOT requests clarification of this definition as it appears to conflict with the requirements for crosswalk width as detailed in Sec. 1105.2.1 Width since existing sidewalks are often less than ninety-six inches (96-in) in width. Sidewalks location is quite variable in relation to the curb line while the location of the crosswalk should be established beyond the stop bar, if present, and stop bar location is a function of the radius of the intersection. Therefore, ADOT recommends that the location of the crosswalk not be defined in relation to the sidewalk location.
Curb Line. A line at the face of the curb that marks the transition between the sidewalk and the gutter or roadway.
Curb Ramp. A ramp cutting through a curb or built up to it.
Detectable Warning. A surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path. Dynamic Envelope. The clearance required for a rail vehicle and its cargo overhang due to any combination of loading, lateral motion, or suspension failure.
Element. An architectural or mechanical component of a building, facility, space, site or public right-of-way.
Facility. All or any portion of buildings, structures, improvements, elements and pedestrian or vehicular routes located on a site or in a public right-of-way.
Grade. (See running slope).
Grade Break. The meeting line of two adjacent surfaces of different slope (grade).
Locator Tone. A repeating sound that identifies the location of the pedestrian push button.
Pedestrian Access Route. An accessible corridor for pedestrian use within the public right-of-way.
Public Right-of-Way. Land or property, usually in a corridor, that is acquired for or devoted to transportation purposes.
ADOT recommends adding the phrase "and under the jurisdiction of a public agency." As written, the definition could also define parking lots or private transportation facilities such as found in gated communities.
Roundabout. A circular intersection that has yield control of entering traffic, channelized approaches, counterclockwise circulation, and appropriate geometric curvature to limit travel speeds on the circulatory roadway.
Running Slope. The slope that is parallel to the direction of travel expressed as a ratio of rise to run. In the public right-of-way, this is usually called grade, and is expressed in percent.
Sidewalk. That portion of a public right-of-way between the curb line or lateral line of a roadway and the adjacent property line that is improved for use by pedestrians.
Recommend replacing the word "lateral" with "edge" and the term "adjacent property" with "right-of-way".
Splitter Island. A flush or raised island that separates entering and exiting traffic in a roundabout.
Street Furniture. Elements in the public right-of-way that are intended for use by pedestrians.
Superelevation. Cross slope on a curie in the roadway (see cross slope).
Recommend deletion of this term.
Walk Interval. That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and its audible equivalent.
Sec. 1102 Scoping Requirements
Sec. 1102.1 General: All areas of newly designed and newly constructed facilities in public rights- of-way and altered portions of existing facilities in public rights-of-way shall comply with Chapter 11.
ADOT supports the position that the new guidelines apply to areas of newly designed and constructed facilities in public rights-of-way and requires provision of sidewalks, street crossings, street furniture, parking, or other pedestrian elements only where they are provided as part of construction or improvement projects. ADOT supports clarification of the guideline explicitly stating that pavement-surface treatment projects such as seal coats, friction-course overlays, and mill-and-replace projects not be considered as construction or improvements triggering compliance with these guidelines.
Sec. 1102.2 Existing Public Rights-of-Way. Additions to existing public rights-of-way shall comply with 1102.2.1. Alterations to existing public rights-of-way shall comply with 1102.2.2.
Sec. 1102.2.1 Additions: Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2.
ADOT has "No comment" on this section.
Sec. 1102.2.2 Alterations: Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11.
EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible.
ADOT supports the position that the guidelines apply to alterations to existing facilities only in relation to the scope of the project. We think the term "technically infeasible" should be expanded to clearly include consideration of site conditions and topography. We also support the position that lack of existing public right-of-way may be a sufficient reason to prevent the widening of sidewalks and would like to see language in the guideline relieving agencies of any obligation to purchase additional right-of-way. ADOT could support sidewalk widening through the use of no-cost, dedicated pedestrian easements over private land. ADOT also supports the position that new facilities should smoothly transition into older ones.
Sec. 1102.2.2.1 Extent of Application: An alteration of an existing element, space, or area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction.
ADOT supports the position that an alteration of an existing area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction.
Sec. 1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way, below the requirements for new construction at the time of the alteration is prohibited.
ADOT supports the position that an alteration shall not decrease the accessibility of a public right-of-way below the requirement for new construction at the time of the alteration.
Sec. 1102.3 Alternate Circulation Path: An alternate circulation path complying with 1111 shall be provided whenever the existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary conditions.
ADOT strongly opposes adoption of this section as written. The current language could require the construction of an alternative circulation path for situations such as the short-term maintenance of the sidewalk or adjacent road. See Section 1111 Alternate Circulation Path for further comments. Compliance would present an unacceptable burden upon the State and local jurisdictions, and the motoring public without a commensurate benefit to pedestrians.
Sec. 1102.4 Sidewalks: Where sidewalks are provided, they shall contain a continuous pedestrian access route complying with 1103. The pedestrian access route shall connect to elements required to comply with Chapter 11.
ADOT supports the position that where sidewalk is provided it should contain a continuous pedestrian access route (PAR) connecting to elements required to comply with Chapter 11.
Sec. 1102.5 Protruding Objects: Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes.
ADOT has "No comment" on this section.
Sec. 1102.5.1 Protrusion Limits. Objects with leading edges more than 27 inches
EXCEPTION: Handrails shall be permitted to protrude 4-1/2 inches
ADOT has "No comment" on this section.
Sec. 1102.5.2 Post-Mounted Objects: Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps.
ADOT requests clarification of this guideline in the form of a graphic representation. It appears that the last sentence contradicts guidance given in the first sentence by allowing the lowest edge of a sign to be mounted at 27 inches
Sec. 1102.5.3 Reduced Vertical Clearance: Guardrails or other barriers shall be provided where the vertical clearance is less than 80 inches
EXCEPTION: Door closers and door stops shall be permitted to be 78 inches
ADOT requests clarification of this proposed guideline. Does the term "guardrail" refer to vehicular w-beam or thrie beam, or is it a pedestrian-type barrier? Regardless of the definition, we are concerned that guardrail installed at twenty-seven inches (27 in), adjacent to the PAR, could constitute a tripping hazard for the visually impaired.
Sec. 1102.6 Curbs and Blended Transitions: A curb ramp or blended transition complying with 1104, or a combination of curb ramps and blended transitions, shall connect the pedestrian access routes to each street crossing within the width of each crosswalk
ADOT supports the proposed guideline requiring that curb ramps be placed in-line with the crosswalk they serve; curb cuts at the mid-point of the curb radius will normally not be allowed. This may effectively double the number, and cost, of curb ramps required on construction projects, but the total cost of such ramps is minimal in terms of the larger project. We note however that sound engineering judgment may dictate the use of only one ramp at a particular intersection due to site geometry and conditions.
Sec. 1102.7 Pedestrian Signs: Signs for pedestrian use shall comply with 1102.7.
ADOT supports the proposed guideline as written. It reiterates guidance given in the MUTCD.
Sec. 1102.7.1 Bus Route Identification: Bus route identification signs shall comply with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to the maximum extent practicable, bus route identification signs shall comply with 703.5.5. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with 703.2, and shall have rounded corners.
EXCEPTIONS.
1. Bus schedules, timetables and maps that are posted at the bus stop or bus shelter shall not be required to comply with 1102.7.
2: Signs shall not be required to comply with 703.2 where audible signs are user- or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual. (Sec. 703 Signs can be found on the Access Board website at http://www. access-board.gov/ada-aba/htm l/tech-0 7. html).
ADOT has "No comment" on this section.
Sec. 1102.7.2 Informational Signs and Warning Signs: Informational signs and warning signs shall comply with 703.5.
ADOT has "No comment" on this section.
Sec. 1102.8 Pedestrian Crossings: Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, they shall comply with 1106.
ADOT strongly opposes this guideline. See Sec. 1105 Pedestrian Crossings for further comment.
Sec. 1102.9 Street Furniture: Street furniture that is intended for use by pedestrians and installed on or adjacent to a sidewalk shall comply with 309 and 1107. (Sec. 309 Operable Parts can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-03.html)
ADOT has "No comment" on this section.
Sec. 1102.10 Stairs: Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
ADOT has "No comment" on this section.
Sec. 1102.11 Handrails: Where provided, handrails shall comply with 505. (Sec. 505 Handrails can be found on the Access Board website at http.//www.access-board.gov/ada-aba.html/tech-05.hmtl)
ADOT has "No comment" on this section.
Sec. 1102.12 Vertical Access: Where provided elevators shall comply with 407, limited use/limited-application elevators shall comply with 408, and platform lifts shall comply with 410. Vertical access shall remain unlocked during the operating hours of the facility served (Sections 407, 408 & 410 can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-04.hmtl)
ADOT has "No comment" on this section.
Sec. 1102.13 Bus Stops. Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with 810.3. (Sections 810.2 & 810.3 can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-08.html)
ADOT has "No comment" on this section.
Sec. 1102.14 On-Street Parking: Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.
ADOT strongly opposes this guideline. See Sec. 1109 On-Street Parking for further comments.
Sec. 1102.15 Passenger Loading Zones: Where passenger loading zones are provided, they shall connect to a pedestrian access route and shall provide a minimum of one passenger loading zone in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof complying with 302, 503.2, 503.3, and 503.5.
ADOT has "No comment" on this section.
Sec. 1102.16 Call Boxes: Where provided, call boxes shall comply with 1110.
See Sec. 1110 Call Boxes for comments.
Sec. 1103 Pedestrian Access Route
Sec. 1103.1 General: Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103.
ADOT supports the proposed guideline as written.
Sec. 1103.2 Components: Pedestrian access routes shall consist of one or more of the following components: walking surfaces, ramps, curb ramps, blended transitions, crosswalks, pedestrian overpasses and underpasses, elevators, and platform h/is. All components of a pedestrian access route shall comply with the applicable portions of this chapter.
ADOT has "No comment" on this section.
Sec. 1103.3 Clear Width: The minimum clear width of a pedestrian access route shall be 48 inches
ADOT supports the proposed guideline as written.
Sec. 1103.4 Cross Slopes: The cross slope of the pedestrian access route shall be 1:48
ADOT supports the goal of the proposed guideline, but requests clarification of how the term "technically infeasible" will be applied to pedestrian access routes in areas with greater than a two percent (2%) grade.
Sec. 1103.5 Grade: The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway.
EXCEPTION: The running slope of a pedestrian access route shall be permitted to be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 1:20
ADOT cannot support the proposed guideline because the exception requires the maximum running slope of the PAR to be less than 1:20
Sec. 1103.6 Surfaces: The surfaces of the pedestrian access route shall comply with 302. (Sec. 302 Floor or Ground Surfaces can be found on the Access Board website at http://www. access- board.gov/ada-aba/htm l/tech-03.hmtl).
ADOT supports the proposed guideline as written.
Sec. 1103.7 Surface Gaps at Rail Crossings.' Where the pedestrian access route crosses rail systems at grade, the horizontal gap at the inner edge of each rail shall be constructed to the minimum dimension necessary to allow passage of railroad car wheel flanges and shall not exceed 2-'/2 inches
EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch
ADOT has "No comment" on this section.
Sec. 1103.7.1 Detectable Warnings: Where rail systems cross pedestrian facilities that are not shared with vehicular ways, a detectable warning shall be provided in compliance with 1108.
ADOT supports the proposed guideline as written.
Sec. 1103.8 Changes in Level.' Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
ADOT requests clarification of this guideline. What is meant by "Changes in level shall be separated horizontally 30 inches
Sec. 1103.8.1 Rail Crossings.' Where the pedestrian access route crosses rail systems at grade, the surface of the pedestrian access route shall be level and flush with the top of the rail at the outer edge and between the rails.
ADOT supports the proposed guideline as written.
Sec. 1104 Curb Ramps and Blended Transitions
Sec. 1104.1 General.' Curb ramps and blended transitions shall comply with 1104.
ADOT has "No comment" on this section.
Sec. 1104.2 Types: Perpendicular curb ramps shall comply with 1104.2.1 and 1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended transitions shall comply with 1104.2.3 and 1104.3.
ADOT cannot support this section because it does not include provision for curb ramps that are in-line with a crosswalk, but neither perpendicular nor parallel. Good engineering practice may include design and construction of non-perpendicular and non-parallel curb ramps.
Sec. 1104.2.1 Perpendicular Curb Ramps: Perpendicular curb ramps shall comply with 1104.2.1, and shall have a running slope that cuts through the curb at right angles or meets the gutter grade break at right angles.
ADOT supports this guideline as written.
Sec. 1104.2.1.1 Running Slope: The running slope shall be 1:48
ADOT cannot support this guideline as written because it ignores the possibility of site-specific conditions which could result in running slopes greater than 1:12
Sec. 1104.2.1.2 Cross Slope: The cross slope shall be 1:48
EXCEPTION: This requirement shall not apply to mid-block crossings.
ADOT cannot support this guideline and requests that the guideline be reworded to allow the cross slope to match the existing roadway grade. The proposed guideline has an unanticipated and unacceptable consequence when a curb ramp is provided on a facility with greater than a 1:48
Sec. 1104.2.1.3 Landing: A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.
ADOT supports the requirement for a minimum of a 48-inch by 48-inch landing at the top of the curb ramp. However, we cannot support the guideline language for maximum running and cross slopes of 1:48
Sec. 1104.2.1.4 Flares: Flared sides with a slope of 1:10
ADOT cannot support the proposed guideline as written because it ignores site-specific conditions that might require a flare slope of greater than 1:10
Sec. 1104.2.2 Parallel Curb Ramps: Parallel curb ramps shall comply with 1104.2.2, and shall have a running slope that is in-line with the direction of sidewalk travel.
ADOT supports this guideline.
Sec. 1104.2.2.1 Running Slope: The running slope shall be 1:48
EXCEPTION: A parallel curb ramp shall not be required to exceed 15 fret (4570 mm) in length.
ADOT cannot support this guideline as written as it would require extensive engineering and construction efforts in areas where the sidewalk and PAR were adjacent to a roadway with a grade greater than eight and one-third percent (8.33%). We do support a maximum ramp length of fifteen feet (15 ft).
Sec. 1104.2.2.2 Cross Slope: The cross slope shall be 1:48
ADOT cannot support this guideline as written as it ignores site-specific conditions that could result in the cross slope being greater than 1:48
Sec. 1104.2.2.3 Landing: A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid- block crossings.
ADOT supports the guideline requirement for a minimum 48-inch by 48-inch landing at bottom of the parallel ramp. However, we oppose the guideline for maximum running and cross slopes of 1:48
Sec. 1104.2.2.4 Diverging Sidewalks: Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments shall be protected with a barrier.
ADOT supports the proposed guideline as written, but requests clarification of what constitutes a "barrier".
Sec. 1104.2.3 Blended Transitions: Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
ADOT cannot support the guideline because of its call for maximum running and cross slopes of 1:48
Sec. 1104.3 Common Elements: Curb ramps and blended transitions shall comply with 1104.3.
Sec. 1104.3.1 Width: The clear width of landings, blended transitions, and curb ramps, excluding flares, shall be 48 inches
ADOT supports the proposed guideline as written.
Sec 1104.3.2 Detectable Warnings: Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.
ADOT supports the proposed guideline, noting however the comments we've provided pertaining to Sec. 1108 Detectable Warning Surfaces.
Sec. 1104.3.3 Surfaces: Surfaces of curb ramps, blended transitions, and landings shall comply with 302. Gratings, access covers, and other appurtenances shall not be located on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route.
ADOT requests a rewording of second sentence of this guideline to acknowledge that circumstances will occur that may require the placement of gratings, access covers, and other appurtenances within the PAR.
Sec. 1104.3.4 Grade Breaks: Grade breaks shall not be permitted on curb ramps, blended transitions, landings, and gutter areas within the pedestrian access route. Surface slopes that meet at grade breaks shall be flush.
ADOT requests clarification of the last sentence and what is meant by "surface slopes" and how they shall be "flush".
Sec. 1104.3.5 Changes in Level: Vertical changes in level shall not be permitted on curb ramps, blended transitions, landings, or gutter areas within the pedestrian access route.
ADOT requests clarification of "vertical changes in level".
Sec. 1104.3.6 Counter Slopes: The counter slope of the gutter area or street at the foot of a curb ramp or blended transition shall be 1:20
ADOT requests that definition of the term "counter slope" be provided.
Sec. 1104.3.7 Clear Space: Beyond the curb line, a clear space of 48 inches
ADOT strongly opposes this guideline. This guideline would result in an increase in the roadway width by forty-eight inches (48 in) on each side of the road at every ramp location for a total of ninety-six (96 in
Sec. 1105 Pedestrian Crossings
Sec. 1105.1 General: Pedestrian crossings shall comply with 1105.
Sec. 1105.2 Crosswalks: Crosswalks shall comply with 1105.2.
Sec. 1105.2.1 Width: Marked crosswalks shall be 96 inches
ADOT cannot support the proposed guideline as written because it mandates a minimum width contrary to that called for in the MUTCD. Section 3B.17 Crosswalk Width of the MUTCD calls for a minimum width of six feet (6 ft), which is research based. Nothing has been presented to show the necessity of widening a crosswalk to eight feet (8 ft).
Sec. 1105.2.2 Cross Slope: The cross slope shall be 1.48 maximum measured perpendicular to the direction of pedestrian travel.
EXCEPTION: This requirement shall not apply to mid-block crossings.
ADOT strongly opposes this guideline. The effect of this guideline could be monumental in locations where the longitudinal grade of the roadway exceeds two percent (2%, 1:48
Sec. 1105.2.3 Running Slope: The running slope shall be 1.20 maximum measured parallel to the direction of pedestrian travel in the crosswalk
ADOT cannot support this guideline as it would have a negative effect on the placement of marked pedestrian crossings on roadways with grades steeper than five percent (5%, 1:20
Sec. 1105.3 Pedestrian Signal Phase Timing: All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3. 0 feet
ADOT cannot support this guideline as it would impact the pedestrian signal phase timing of almost every traffic signal in the State and two of the consequences would be overwhelming. First, almost every traffic signal in Arizona would have to be re-timed to account for the increase in pedestrian travel length. The current MUTCD guidelines for pedestrian signal phase timing allow the length to be measured from the curb face to the center of the furthest through travel lane. This guideline would add a minimum of fourteen feet (14 ft) to the length which equates to a minimum addition of 4.67 seconds
Sec. 1105.4 Medians and Pedestrian Refuge Islands: Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying withllO4 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches
ADOT cannot support this guideline because the language in Sec. 1104 Curb Ramps is already overly restrictive at locations with roadway grade is greater than two percent (2%) (see comment for Sec. 1104.2.1.2 Cross Slope, above).
Sec. 1105.4.1 Length: Where signal timing is inadequate for full crossing of all traffic lanes or where the crossing is not signalized, cut-through medians and pedestrian refuge islands shall be 72 inches
ADOT cannot support this guideline as our current standard width for medians at intersections is forty-eight inches (48 in).
Sec. 1105.4.2 Detectable Warnings: Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24 inch
EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing.
ADOT cannot support this guideline as our current standard width for medians at intersections is forty-eight inches (48 in
Sec. 1105.5 Pedestrian Overpasses and Underpasses: Pedestrian overpasses and underpasses shall comply with 1105.5.
Sec. 1105.5.1 Pedestrian Access Route: Pedestrian overpasses and underpasses shall contain a pedestrian access route complying with 1103.
ADOT supports the proposed guideline as written.
Sec. 1105.5.2 Running Slope: The running slope shall not exceed 1:20
ADOT cannot support the proposed guideline as written as it could require the running slope of the PAR to be independent of the longitudinal grade of the adjoining roadway. To require a PAR running slope less than 1:20
Sec. 1105.5.3 Approach: Where the approach exceeds 1:20
ADOT supports the part of the guideline pertaining to minimum ramp width. We strongly oppose that part calling for a limited-use/limited-application or standard elevator where the rise of the ramped approach exceeds sixty inches (60 in). We are deeply concerned that about the safety of pedestrians using such elevators and think it inadvisable to install elevators if we cannot guarantee pedestrian security. In Arizona there are also regular, but unplanned interruptions in electrical service due to electrical storms in the summer and snow storms in the winter. These interruptions could trap people in the elevators without any simple means of extricating them until power is restored. Equally as important in our opposition to the requirement for elevators are their exorbitant costs and the notion we should provide a facility for disabled pedestrians which is well beyond what we'd provide for pedestrian traffic in general.
Sec. 1105.5.4 Stairs: Stairs shall comply with 504. (Sec. 504 Stairways can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-05.hmtl)
ADOT has "No comment" on this section.
Sec. 1105.5.5 Escalators: Escalators shall comply with 810.9.
ADOT has "No comment" on this section.
Sec. 1105.6 Roundabouts: Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
Sec. 1105.6.1 Separation: Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
ADOT strongly opposes this guideline as written because of its possible negative impacts on motorist and pedestrian safety. If handrail is used as a barrier on sidewalks abutting the curb it could present a spearing hazard to motorists. Other types of barrier could present tripping hazards to pedestrians if placed lower than twenty-seven inches (27 in) and a sight restriction to motorists if places above that point. We would like to know why sidewalk at a roundabout is being treated differently from that at any other street intersection?
Sec. 1105.6.2 Signals: A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
ADOT cannot support this guideline as written. It is inadvisable to promulgate a guideline that would mandate the installation of any traffic control signal without an engineering study to confirm the need for such a signal. Warrants for installation of a signal would investigate such variables as sight distance, traffic volume, pedestrian volume, vehicle speed, and vehicle gap.
Sec. 1105.7 Turn Lanes at Intersections: Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
ADOT cannot support this guideline as written. We request a definition for the term "slip lane" be added to Sec. 1101.3 Terms. Within the Arizona highway system unrestricted right turns are sometimes provided at freeway ramps to handle the volume of exiting traffic. The installation of a signal could cause a dangerous situation where off-ramp traffic would back up onto the freeway. Again, without a case-by-case engineering study, as detailed in the MUTCD, it would be inadvisable to mandate installation of a signal at these locations.
Sec. 1106 Accessible Pedestrian Signal Systems
Sec. 1106.1 General: Pedestrian signal systems shall comply with 1106.
Sec. 1106.2 Pedestrian Signal Devices: Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
ADOT strongly opposes this guideline as written. We see no added value to implementing this guideline, and a possible increased liability due to system failure and application inconsistency.
Sec. 1106.2.1 Location: Pedestrian signal devices shall be located 60 inches
EXCEPTION: The minimum distance from other signal devices shall not apply to signal devices located in medians and islands.
ADOT cannot support the proposed guideline as written because locating all traffic control devices should be done as part of a site-specific engineering study. We think it would be poor engineering practice to utilize this guideline without an investigation of the site and analysis thereof.
Sec. 1106.2.2 Reach and Clear Floor or Ground Space: Pedestrian signal devices shall comply with 308. A clear floor or ground space complying with 305 shall be provided at the signal device and shall connect to or overlap the pedestrian access route. (Sec. 308 Reach Ranges and Sec. 305 Knee and Toe Clearance can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-03.html)
ADOT has "No comment" on this section.
Sec. 1106.2.3 Audible Walk Indication: The audible indication of the WALK interval shall be by voice or tone.
ADOT cannot support this guideline as written. Because of the number of different languages spoken in Arizona it would be technically infeasible to provide any message, in every language, in a timely manner. To arbitrarily decide not to offer the message in a particular language could also leave this Department open to charges of not providing equal access to public services. Also, as noted above, advocacy groups for the visually impaired have not achieved a clear consensus regarding the need for and design of audible and vibrotactile indications.
Sec. 1106.2.3.1 Tones: Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds
ADOT has "No comment" on this section.
Sec. 1106.2.3.2 Volume: Tone or voice volume measured at 36 inches
ADOT cannot support this section of the guidelines because the sound level produced could be considered a nuisance, particularly in the evening hours and at locations in residential neighborhoods.
Sec. 1106.3 Pedestrian Pushbuttons: Pedestrian pushbuttons shall comply with 1106.3.
Sec. 1106.3.1 Operation. Pedestrian pushbuttons shall comply with 309.4. (Sec. 309.4 Operation can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-03.hmtl)
ADOT has "No comment" on this section.
Sec. 1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
ADOT cannot support the proposed guideline because the sound level produced could be considered a nuisance, particularly in the evening hours and at locations in residential neighborhoods.
Sec. 1106.3.3 Size and Contrast. Pedestrian pushbuttons shall be a minimum of 2 inches
ADOT supports the proposed guideline as written.
Sec. 1106.3.4 Optional Features: An extended button press shall be permitted to activate additional features. Buttons that provide additional features shall be marked with three Braille dots forming an equilateral triangle in the center of the pushbutton.
ADOT has "No comment" on this section.
Sec. 1106.4 Directional Information and Signs. Pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal.
ADOT cannot support this section as the name of streets served by a particular crosswalk is not currently provided at any location. Each location would require costly, custom-made signs which would have to be replaced if damaged or otherwise vandalized.
Sec. 1106.4.1 Arrow: Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 inch
ADOT can support this guideline.
Sec. 1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2. (Sec. 703.2 Characters That Are Both Tactile and Visual can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-07.html)
ADOT cannot support this section of the guidelines because it puts an unreasonable burden on the State and other jurisdictions to produce costly, custom-made signs for each location.
Sec. 1106.4.3 Crosswalk Configuration: Where provided, graphic indication of crosswalk configuration shall be tactile and shall comply with 703.5.1. (Sec. 703.2 Location can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT can support this section as long as there is no requirement to provide graphic indication of the crosswalk configuration.
Sec 1107 Street Furniture
Sec. 1107.1 General: Street furniture shall comply with 1107.
Sec. 1107.2 Clear Floor or Ground Space: Street furniture shall have clear floor or ground space complying with 305 and shall be connected to the pedestrian access route. The clear floor or ground space shall overlap the pedestrian access route 12 inches
ADOT support this section of the guidelines.
Sec. 1107.3 Drinking Fountains: Where drinking fountains are provided, they shall comply with 602. (Sec. 602 Drinking Fountains and Water Coolers can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-06.hmtl)
ADOT has "No comment" on this section.
Sec. 1107.4 Public Telephones: Where public telephones are provided, they shall comply with 1107.4.
ADOT has "No comment" on this section.
Sec. 1107.4.1 Single Telephone: Where a single public telephone is provided, it shall comply with 704.2 and 704.4. (Sec. 704.2 Wheelchair Accessible Telephones and Sec. 704.4 TTYs can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-07.html)
ADOT has "No comment" on this section.
Sec. 1107.4.2 Multiple Telephones: Where a bank of public telephones is provided, at least one telephone shall comply with 704.2, and at least one additional telephone shall comply with 704.4.
ADOT has "No comment" on this section.
Sec. 1107.4.3 Volume Controls: A 11 public telephones shall provide volume controls complying with 704.3. (Sec. 704.3 Volume Control Telephones can be found on the Access Board website at http.//www. access-board.gov/ada-aba/html/tech-0 7.html)
ADOT supports the proposed guideline as written.
Sec. 1107.5 Public Toilet Facilities: Permanent or portable public toilet facilities shall comply with 603. At least one fixture of each type provided shall comply with 604 through 610. Operable parts, dispensers, receptacles, or other equipment shall comply with 309.
EXCEPTION: Where multiple single-user toilet facilities are clustered at a single location, at least 5 percent, but no fewer than one single-user toilet at each cluster shall comply with 603 and shall be identified by the International Symbol of Accessibility complying with 703.7.2.1. (Sec. 603 Toilet and Bathing Rooms and Sections 604 through 610 can be found on the Access Board website at http.//www.access-board.gov/ada-aba/html/tech-06.html, Sec. 309 Operable Parts at http.//www.access-board.gov/ada-aba.html/tech-03.html and Sec. 703.7.2.1 Finish and Contrast at http.//www. access-board.gov/ada-aba/html/tech-07.html.)
ADOT has "No comment" on this section.
Sec. 1107.6 Tables, Counters, and Benches: Tables, counters, and benches shall comply with 1107.6.
Sec. 1107.6.1 Tables: Where tables are provided in a single location, at least 5 percent but no fewer than one, shall comply with 902. (Sec. 902 Dining Surfaces and Work Surfaces can be found on the Access Board website at http.//www.access-board.gov/ada-aba/html/tech-09.hmtl)
ADOT has "No comment" on this section.
Sec. 1107.6.2 Counters: Where provided, counters shall comply with 904. (Sec. 904 Sales and Service Counters can be found on the Access Board website at http://www. access-board.gov/ada-aba/html/tech-09.hmtl)
ADOT has "No comment" on this section.
Sec. 1107.6.3 Benches: Where benches without tables are provided at a single location, at least 50 percent, but no fewer than one, shall comply with 903 and shall have an armrest on at least one end (Sec. 903 Benches can be found on the Access Board website at http://www. access-board.gov/ada-aba.html/tech-09.hmtl)
ADOT has "No comment" on this section.
Sec 1108 Detectable Warning Surfaces
Sec. 1108.1 General: Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.
ADOT cannot support this guideline because it would restrict the free market development of truncated dome systems by prohibiting the diamond pattern. While the argument arises that the square pattern is friendlier to vibration- sensitive people, there is no research on the possible number of individuals affected. Depending on the dimensions used in the square or diamond pattern and the width of the wheelchair, its wheels will either hit or miss the truncated domes. Therefore, we see no reason to favor one pattern over another in the rulemaking process.
Sec. 1108.1.1 Dome Size: Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches
ADOT supports the proposed guideline as written.
Sec. 1108.1.2 Dome Spacing: Truncated domes in a detectable warning surface shall have a center-to-center spacing of 1.6 inches
ADOT supports this guideline while recommending removal of reference to "square grid" from the last sentence (see comment on Sec. 1108.1 General, above).
Sec. 1108.1.3 Contrast: Detectable warning surfaces shall contrast visually with adjacent walking surfaces either light-on-dark, or dark-on-light.
ADOT supports the proposed guideline as written.
Sec. 1108.1.4 Size: Detectable warning surfaces shall extend 24 inches
ADOT supports the proposed guideline as written.
Sec. 1108.2 Location
Sec. 1108.2.1 Curb Ramps and Blended Transitions: The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches
ADOT supports the proposed guideline as written.
Sec. 1108.2.2 Rail Crossings: The detectable warning surface shall be located so that the edge nearest the rail crossing is 6 inches
ADOT supports the proposed guideline, but recommends the term "vehicle dynamic envelope" be used consistent with the term "dynamic envelope" as shown in Sec. 1103 Terms.
Sec. 1108.2.3 Platform Edges: Detectable warning surfaces at platform boarding edges shall be 24 inches
ADOT has "No comment" on this section.
Sec 1109 On-Street Parking
Sec. 1109.1 General: Car and van on-street parking spaces shall comply with 1109.
ADOT has "No comment" on this section.
Sec. 1109.2 Parallel Parking Spaces: An access aisle at least 60 inches
EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet
ADOT requests further clarification of this guideline before deciding whether we support it.
Sec. 1109.3 Perpendicular or Angled Parking Spaces: Where perpendicular or angled parking is provided, an access aisle 96 inches
ADOT cannot support this guideline as written because the incremental value of a ninety-six (96-in) wide access aisle over the currently used sixty-inch (60-in) wide access aisle has not been established.
Sec. 1109.4 Curb Ramps or Blended Transitions: A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route.
ADOT supports this guideline in concept, noting however the comments regarding the 1:48
Sec. 1109.5 Obstructions. There shall be no obstructions on the sidewalk adjacent to and for the full length of the space.
EXCEPTION: This provision shall not apply to parking signs complying with 1109.6 and parking meters complying with 1109.7.2.
ADOT supports the proposed guideline as written.
Sec. 1109.6 Signs: Parking spaces shall be designated as reserved by a sign complying with 502.6. Signs shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer. (Sec. 502 Parking Spaces can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-05.hmtl)
ADOT supports the proposed guideline as written.
Sec. 1109.7 Parking Meters: Where parking meters are provided, they shall comply with 1109.7.
ADOT supports the proposed guideline as written.
Sec. 1109.7.1 Operable Parts. Operable parts shall comply with 309. (Sec. 309 Operable Parts can be found on the Access Board website at http://www.access board.gov/ada-aba/html/tech-03.hmtl)
ADOT supports the proposed guideline as written.
Sec. 1109.7.2 Location: A parking meter shall be located at the head or foot of the parking space so as not to interfere with the operation of a side l or a passenger side transfer.
EXCEPTION: Where parking meters are not provided at the space, but payment for parking in the space is included in a centralized collection box or paying station, the space shall be connected to the centralized collection point with a pedestrian access route.
ADOT supports the proposed guideline as written.
Sec. 1109.7.3 Displays and Information.' Displays and information shall be visible from a point located 40 inches
ADOT supports the proposed guideline as written.
Sec. 1110 Call Boxes
Sec. 1110.1 General: Call boxes shall comply with 1110.
ADOT has "No comment" on this section..
Sec. 1110.2 Operable Parts: Operable parts shall comply with 308 and 309.4. Where provided, labeling shall comply with 703.2 and 703.3. (Sec. 703 Signs can be found on the Access Board website at http.//www.access-board.gov/ada-aba/html/tech-07.hmtl)
EXCEPTION: Mechanically operated systems in which the signal is initiated by a lever pull shall be permitted to have an activating force of 12 lbf
ADOT supports the proposed guideline as written.
Sec. 1110.3 Turning Space: A turning space complying with 304 shall be provided at the controls. (Sec. 304 Wheelchair Turning Space can be found on the Access Board website at http.//www. access-board.gov/ada-aba/htm l/tech-03.hmtl
ADOT supports the proposed guideline as written.
Sec. 1110.4 Edge Protection: Edge protection complying with 405.9.2 shall be provided where the area at the call box is adjacent to an abrupt level change. (Sec. 405.9.2 Curb or Barrier can be found on the Access Board website at http://www.access-board.gov/ada-aba.html/tech-04.hmtl)
ADOT supports the proposed guideline, but would request further clarification regarding the terms "abrupt level change" and "edge protection".
Sec. 1110.5 Motor Vehicle Turnouts: Where provided, a motor vehicle turnout shall have a minimum paved area of 16 feet
ADOT supports the basic guideline, but question the requirement of a sixteen-foot (1 6-ft) wide paved area. Provision of a thirteen-foot (1 3-fl) wide paved area is sufficient to provide for an eight-foot (8-ft) wide parking space and a five-foot (5-fl) wide access and the incremental value of an eight-foot (8-ft) wide access route has not been established route (see comment for Sec. 1109.2 Parallel Parking Spaces, above).
Sec. 1110.6 Two- Way Communication: Where provided, two-way voice communication shall comply with 1110.6, 708.2 and 708.3. (Sec. 708 Two-Way Communication Systems can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT has "No comment" on this section.
Sec. 1110.6.1 Volume Controls: Volume controls complying with 704.3 shall be provided (Sec. 704.3 Volume Control Telephones can be found on the Access Board website at http.//www. access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT has "No comment" on this section..
Sec. 1110.6.2 TTY A TTY complying with 704.4 shall be provided (Sec. 704.4 TTYs can be found on the Access Board website at http://www.access-board.gov/ada-aba.html/tech-07.hmtl)
ADOT has "No comment" on this section.
Sec. 1111 Alternate Circulation Path
Sec. 1111.1 General: Alternate circulation paths shall comply with 1111.
ADOT supports the proposed guideline as written.
Sec. 1111.2 Width: The alternate circulation path shall have a width of36 inches
ADOT strongly supports the guideline requirement for the alternate circulation path minimum width of thirty-six inches (36 in).
Sections 1111.3 Location: The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
ADOT strongly opposes this guideline's requirement for the "Alternate Circulation Path" to be located on the same side of the street as the disrupted PAR. This provision would impose a central-planning approach to traffic control for construction and maintenance operations, and would negatively impact pedestrian comfort and safety while creating an unreasonable burden upon State and local agencies. This provision does not appear to consider the following: A) the length of time a project is underway; B) the type and nature of the project; C) the probable negative impact upon the other users of the transportation facility due to reduced roadway capacity; D) the advisability of and risk inherent in moving pedestrians adjacent to construction or maintenance operations; E) the impact of noise on the pedestrian; nor F) the impact to construction programs, in terms of time and money spent on meeting this guideline.
This proposed guideline is also contrary to guidance provided by the Manual on Uniform Traffic Control Devices (MUTCD), Section 6D.O I Pedestrian Considerations This section of the MUTCD delineates three considerations, of which the first two address this matter. They are as follows:
A. Pedestrians should not be led into conflicts with work site vehicles, equipment, and operations. and
B. Pedestrians should not be led into conflicts with vehicles moving through or around the work site.
Further clarification is provided in the MUTCD on page 6D- 1 as, "Pedestrians should be appropriately directed with advance signing that encourages them to cross to the opposite side of the roadway." (emphasis added) and 6D-2 as, "Whenever it is feasible, closing off the work site from pedestrian intrusion may be preferable to channelizing pedestrian traffic along the site with temporary traffic control devices such as cones, tubular markers, barricades and drums, or other suitable fencing."
Sec. 1111.4 Protection: The alternate circulation path shall comply with 307 and shall be protected with a barricade complying with 1111.6 to separate the pedestrian access route and alternate circulation path from any adjacent construction, drop-offs, openings, or other hazards.
ADOT cannot support this guideline because the Alternate Circulation Path should not be adjacent to construction or maintenance operations (see comment on Sec. 1111.3 Location, above).
Sec. 1111.5 Signs: Signs complying with 703.5 shall be provided at both the near side and the far side of the intersection preceding a disrupted pedestrian access route. . (Sec. 703.5 Braille can be found on the Access Board website at http://www.access-board.gov/ada-aba/html/tech-07.hmtl)
ADOT strongly supports the placement of signs, at both the near side and far side of the intersections preceding a disrupted PAR, encouraging all pedestrians to cross to the opposite side of the roadway wherever possible (see comment on Sec. 1111.3 Location, above).
Sec. 1111.6 Barricades: Barricades shall be continuous, stable, and non-flexible and shall consist of a solid wall or fence or a Type II or Type III barricade as specified in MUTCD section 6F-60 with the bottom or lower rail 1-1/2 inches
ADOT cannot support this guideline as written because no temporary barricade system is totally "non- flexible"; temporary barricades differ by how much rigidity they provide. The proposed guideline would also prohibit the use of both Type II and Type III temporary barricades to define the alternative circulation path because they use "T-type" supports that would encroach into the path. Temporary concrete barrier (TCB), which can move up to three feet (3 ft) laterally when struck, would meet most of the intent of this guideline, however, TCB should not be used arbitrarily. Sound engineering judgment should be used to determine, on a case-by-case basis, the advisability of introducing another hazard (the TCB itself) onto the project. Indiscriminate use of TCB could put the public's health, safety, and welfare at risk.
Billy L. Hattaway, P.E., July 1, 2002
I have reviewed the proposed language requiring pedestrian activated signals at each roundabout crosswalk and would like to comment on the proposed language. While I am now in the private sector, I spent the last 23+ years working at Florida Department of Transportation in positions such as the District Five Design Engineer, State Roadway Design Engineer and most recently, Director, Office of Design. I have been a strong advocate for pedestrian and bicycle issues during my tenure, and will continue to be. I am involved in the Congress for New Urbanism, and have a serious commitment to walkable and livable communities. I would like you to consider my comments in view of my background.
While I have concerns for the safety of all pedestrians using transportation facilities, I believe the proposed requirement would create an undue constraint on the use of roundabouts, potentially eliminating their use in many locations at the state and local level. The budgets of all government entities are already stretched thin, so maximizing the opportunities for safety improvements is very important. Roundabouts improve safety for vehicles compared with traditional intersections by keeping the speeds low and reducing conflict points. The article states that often "Pedestrians report that vehicles at roundabouts, as well as at other unsignalized crossings, often do not yield for pedestrians." I believe that to be true, and believe that those who would not yield to a pedestrian (sighted or otherwise) in a roundabout are the same who will not stop for the same pedestrian in any crosswalk, whether in a roundabout, a yield condition, stop sign, or signals with right turn on red. There are many factors that impact pedestrian use of roundabouts and their exposure, such as the volume of traffic, the roundabout's geometry - which affects entry and exit speeds, and the volume of pedestrian traffic.
Before requiring pedestrian activated signals at every crosswalk within a roundabout, we should allow practicing engineers to deal with each site individually and do what is best for that location. We have a responsibility to provide improved safety for everyone using our transportation systems, and since money is always an issue in making those decisions, we need to use it wisely, where it is most needed. Thanks for the opportunity to comment.
Billy L. Hattaway, P.E.
Vice President, Transportation Program Manager Baskerville-Donovan, Inc.
Randy Hoskins, P.E., October 23, 2002
Please consider the attached comments regarding the draft guidelines. A hardcopy version will be sent to you in the mail.
Randy Hoskins, P.E.
City Traffic Engineer
Lincoln, NE
Scott Windley
Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board
1331 F St. NW, Suite 1000
Washington, DC 20004-1111
RE: Draft Guidelines on Accessible Public Rights-of-Way
Mr. Windley:
The City of Lincoln has reviewed the Draft Guidelines for Accessible Public Rights-of-Way. We realize that Title II of the ADA requires governments to not discriminate against people with disabilities and we support the efforts to improve existing conditions. However, the guidelines as proposed would have serious consequences that would impose significant costs on local governments. It is also our feeling that these would be overly restrictive and would not allow sufficient latitude to design on a case by case basis.
Our comments and concerns are as follow:
Curb Ramps and Blended Transitions (1102.6, 1104)
- Also, drivers may not be as alert to persons crossing at the apex of a corner.
It would seem drivers would be much more alert at this point in the roadway than after driving around a corner and encountering a pedestrian when their vehicle has attained a higher speed than at the apex of the corner.
Other Requirements for Curb Ramps and Blended Transitions (1104.3.3 - 1104.3.7)
- prohibit the placement of ...utility and sewer access covers, and similar fixtures on ramps, landings, transitions and portions of the gutter within the pedestrian access route;
If these items meet the criteria set forth for changes in level, why would they not be allowed?
- prohibit grade breaks on ramp runs, blended transitions, landings, and gutter areas within the pedestrian access route;
How will the gutter work if it must be at the same grade as the ramp? That will either force all the water out into the street or funnel it all back onto the sidewalk.
- prohibit any vertical changes in level on curb ramps, landings and gutter areas within the pedestrian access route;
Again, if the vertical change is within the requirements for changes in level, it should be allowed. To keep nuisance water from ponding within a ramp area, a minimal lip is often maintained to keep the water off the ramp and moving around the corner.
- require clear space at least 48 by 48 inches
This is confusing as to intent.
Crosswalks (1105.2)
- The cross slope is limited to 1:48
This may be fine for new areas, but it is often not realistic in built environments. Changing slopes of streets to accommodate this ruling may not be feasible.
Pedestrian Signal Phase Timing (1105.3)
- The draft guidelines would require pedestrian signal phase timing to be calculated according to a walking speed of 3.0 feet
This would have a major negative impact on traffic. Requiring this change would more than offset the gains our jurisdiction has made through expenditures of hundreds of thousands of dollars to improve the traffic carrying capabilities of our streets, which has been a mantra of the FHWA for years. To make this change system-wide would increase energy consumption, pollution and vehicular costs to motorists to accommodate a small percentage of the population who might use a signal. It would seem that if the route is used by handicapped individuals who cannot cross in the 3.5 ft/sec time, then the change to a 3.0 ft/sec crossing time COULD be used as needed.
Pedestrian Overpasses and Underpasses (1105.5)
- The draft guidelines address access to pedestrian overpasses and underpasses, which would be required to provide a pedestrian access route. A ramp would be required where the running slope exceeds 1:20
Implementation of this rule would practically kill off the installation of underpasses and overpasses for pedestrian crossings. Since it is quite rare where the grade change of such a structure would be less than five feet, nearly every one constructed would require an elevator. The major reason stated for not installing these structures is cost. When you add the cost of providing elevators at each end to the already high price, you have just made these infeasible except in the most extreme cases. By doing so, this would increase the hazard to all pedestrians, handicapped and able-bodied alike, forcing them to cross using at-grade crossings.
Roundabouts (1105.6)
- To provide safer crossing at roundabouts, the draft guidelines would require pedestrian activated crossing signals at each roundabout crosswalk, including those at splitter islands.
This requirement sounds as if it was written by a group of people scared of new ideas and who have absolutely no clue what they are talking about. We have just completed a roundabout to replace a signal at one of the highest accident locations in the City. A lot of people opposed to this installation stated it would be dangerous for pedestrians to cross. Quite the opposite is true. Pedestrians only have to cross one lane at a time, they are crossing at a point where traffic is moving slowly entering or leaving the roundabout and the driver is alert because of the increased requirements placed on them. To now have to signalize these would completely waste the advantages they naturally provide pedestrians. In certain areas where high volumes of pedestrians and vehicles exist, crossing lights may be of use, but a requirement for all or even most locations can only benefit signal suppliers.
Since vehicles would be moving at higher speeds and pedestrians would have longer crossing distances, by using the same logic, we should put in crossing signals at every unsignalized intersection also.
- Barriers or similarly distinct elements are needed to prevent blind persons from inadvertently crossing a roundabout roadway in unsafe locations. The draft guidelines would require a continuous barrier along the street side of the sidewalk where pedestrian crossing is prohibited. If a railing is used, it must have a bottom rail no higher than 15 inches
Since vehicles would be moving at higher speeds and peds would have longer crossing distances, by using the same logic, we should put in barriers at every unsignalized intersection also. Again, this just doesn't make sense. By following the sidewalk, pedestrians are directed to the safest crossing locations.
Turn Lanes at Intersections (1105.7)
- The draft guidelines also include a requirement for a pedestrian activated signal at each segment of a crosswalk that crosses right or left turn slip lanes.
This will likely increase vehicular crashes. In order to place the signals where turning vehicles can see them an adequate distance in advance of the crossing, they will also be visible to through vehicles who may become confused by several conflicting indications. Rear end and side-swipe crashes will likely result.
This should not be mandatory at all locations, but rather should be considered on a case by case basis. If signals are not needed for non-handicapped persons, there is a question as to whether or not they would be needed for handicapped individuals.
Accessible Pedestrian Signal Systems (1102.8, 1106)
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
Obviously these add cost to signal installation/ maintenance. Where will the funding for this come from in these tight economic times?
1106.2.1 Location. Pedestrian signal devices shall be located 60 inches
This will require major reconstruction of many traffic signals. In many locations, it is not possible to comply with this due to existing obstructions in the way of the signal, including underground utilities.
1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
This is another cost concern. It is also sometimes a concern with nearby residents/businesses as to the addition of noise pollution.
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.
Another cost concern.
On-Street Parking (1102.14, 1109)
- The draft guidelines would require access to at least one parking space on each block face.
In an area with 150 foot
This also does not specify if this would be required city-wide or only in commercial areas. Providing the required handicapped parking space with signing, pavement markings and ramps on every block in the city would create an astronomical cost.
- Requirements address adjoining access aisles at spaces, accessible connecting routes, signs, and parking meters. An accessible parallel space and access aisle, which must be flush with the street, can be achieved by indenting the curb line, similar to a loading zone.
This will create problems during snow events. Plows will come along and push snow into the indented area, making them useless. These will also create discontinuities in the sidewalks in downtown areas where sidewalks normally run from the face of buildings to the edge of the curb. In high ped areas, this will have a major negative impact. I think the cost of lawsuits related to trips and falls in these inset areas each year will greatly outweigh any benefits derived from their installation.
Passenger Loading Zones (1102.15)
- ADAAG requirements for passenger loading zones would be applied to loading zones in the public right-of-way. Where a long loading zone is provided, at least one area in every 100 continuous feet must comply with requirements in ADAAG section 302 and 503 which address the surfacing, the size of vehicle pull-up spaces (8 by 20 feet
These will not work well at schools where it is important to provide curbs to create barriers to vehicles running onto sidewalks and hitting pedestrians.
- 1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
This is a costly unfunded mandate. Providing parallel ped access on the same side of the street as the existing path is often not practicable. Based on costs and usage, it is often impossible to justify not moving pedestrians, both able bodied and disabled, to an adjacent route.
- 1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
The MUTCD allows secondary signs to have a minimum height of 72", vs. 80" required here. This would require major work to change signs throughout the city.
Again, we support reasonable access for disabled pedestrians and continually review our standards and processes to assure that what we are doing is reasonable and safe. We are concerned that these draft guidelines, if adopted, would create major consequences for communities of all sizes. We would ask that these consequences be considered more carefully before enacting any changes to the existing requirements.
Randy Hoskins, P.E.
City Traffic Engineer
City of Lincoln, Nebraska
CITY OF LINCOLN NE
RE: Draft Guidelines on Accessible Public Rights-of-Way
The City of Lincoln has reviewed the draft Guidelines on Accessible Public Rights-of-Way. While we applaud efforts to improve mobility for all citizens, we are concerned that the draft guidelines currently under consideration will have numerous consequences, many of which are negative.
You will find enclosed a copy of a letter compiled by Randy Hoskins, the City's Traffic Engineer. The letter outlines the concerns the City of Lincoln has with proposed guidelines. These concerns have been raised through Public Works Department and City Council review.
We would encourage you to take another look at the guidelines. Many are excellent and will provide needed improvements. Others may have unintended consequences that will be difficult to enforce, apply and/or fund. Still others may make for less safe conditions for all pedestrians, along with increasing delay, costs and pollution of vehicular traffic.
Sincerely,
Don Wesely
Mayor of Lincoln
October 20, 2002
Scott Windley
RE: Draft Guidelines on Accessible Public Rights-of-Way
Dear Mr. Windley:
The City of Lincoln has reviewed the Draft Guidelines for Accessible Public Rights-of-Way. We realize that Title II of the ADA requires governments to not discriminate against people with disabilities and we support the efforts to improve existing conditions. However, the guidelines as proposed would have serious consequences that would impose significant costs on local governments. It is also our feeling that these would be overly restrictive and would not allow sufficient latitude to design on a case by case basis.
Our comments and concerns are as follow:
Curb Ramps and Blended Transitions (1102.6, 1104)
- Also, drivers may not be as alert to persons crossing at the apex of a corner.
It would seem drivers would be much more alert at this point in the roadway than after driving around a corner and encountering a pedestrian when their vehicle has attained a higher speed than at the apex of the corner.
Other Requirements for Curb Ramps and Blended Transitions (1104.3.3 - 1104.3.7)
- prohibit the placement of... utility and sewer access covers, and similar fixtures on ramps, landings, transitions and portions of the gutter within the pedestrian access route;
If these items meet the criteria set forth for changes in level, why would they not be allowed?
- prohibit grade breaks on ramp runs, blended transitions, landings, and gutter areas within the pedestrian access route;
How will the gutter work if it must be at the same grade as the ramp? That will either force all the water out into the street or funnel it all back onto the sidewalk.
- prohibit any vertical changes in level on curb ramps, landings and gutter areas within the pedestrian access route;
Again, if the vertical change is within the requirements for changes in level, it should be allowed. To keep nuisance water from ponding within a ramp area, a minimal lip is often maintained to keep the water off the ramp and moving around the corner.
- require clear space at least 48 by 48 inches
This is confusing as to intent.
Crosswalks (1105.2)
- The cross slope is limited to 1:48
This may be fine for new areas, but it is often not realistic in built environments. Changing slopes of streets to accommodate this ruling may not be feasible.
Pedestrian Signal Phase Timing (1105.3)
- The draft guidelines would require pedestrian signal phase timing to be calculated according to a walking speed of 3.0 feet
This would have a major negative impact on traffic. Requiring this change would more than offset the gains our jurisdiction has made through expenditures of hundreds of thousands of dollars to improve the traffic carrying capabilities of our streets, which has been a mantra of the FHWA for years. To make this change system-wide would increase energy consumption, pollution and vehicular costs to motorists to accommodate a small percentage of the population who might use a signal. It would seem that if the route is used by handicapped individuals who cannot cross in the 3.5 ft/sec time, then the change to a 3.0 ft/sec crossing time COULD be used as needed.
Pedestrian Overpasses and Underpasses (1105.5)
- The draft guidelines address access to pedestrian overpasses and underpasses, which would be required to provide a pedestrian access route. A ramp would be required where the running slope exceeds 1:20
Implementation of this rule would practically kill off the installation of underpasses and overpasses for pedestrian crossings. Since it is quite rare where the grade change of such a structure would be less than five feet, nearly every one constructed would require an elevator. The major reason stated for not installing these structures is cost. When you add the cost of providing elevators at each end to the already high price, you have just made these infeasible except in the most extreme cases. By doing so, this would increase the hazard to all pedestrians, handicapped and able-bodied alike, forcing them to cross using at-grade crossings.
Roundabouts (1105.6)
- To provide safer crossing at roundabouts, the draft guidelines would require pedestrian activated crossing signals at each roundabout crosswalk, including those at splitter islands.
This requirement sounds as if it was written by a group of people scared of new ideas and who have absolutely no clue what they are talking about. We have just completed a roundabout to replace a signal at one of the highest accident locations in the City. A lot of people opposed to this installation stated it would be dangerous for pedestrians to cross. Quite the opposite is true. Pedestrians only have to cross one lane at a time, they are crossing at a point where traffic is moving slowly entering or leaving the roundabout and the driver is alert because of the increased requirements placed on them. To now have to signalize these would completely waste the advantages they naturally provide pedestrians. In certain areas where high volumes of pedestrians and vehicles exist, crossing lights may be of use, but a requirement for all or even most locations can only benefit signal suppliers.
Since vehicles would be moving at higher speeds and pedestrians would have longer crossing distances, by using the same logic, we should put in crossing signals at every unsignalized intersection also.
- Barriers or similarly distinct elements are needed to prevent blind persons from inadvertently crossing a roundabout roadway in unsafe locations. The draft guidelines would require a continuous barrier along the street side of the sidewalk where pedestrian crossing is prohibited. If a railing is used, it must have a bottom rail no higher than 15 inches
Since vehicles would be moving at higher speeds and peds would have longer crossing distances, by using the same logic, we should put in barriers at every unsignalized intersection also. Again, this just doesn't make sense. By following the sidewalk, pedestrians are directed to the safest crossing locations.
Turn Lanes at Intersections (1105.7)
- The draft guidelines also include a requirement for a pedestrian activated signal at each segment of a crosswalk that crosses right or left turn slip lanes.
This will likely increase vehicular crashes. In order to place the signals where turning vehicles can see them an adequate distance in advance of the crossing, they will also be visible to through vehicles who may become confused by several conflicting indications. Rear end and side-swipe crashes will likely result.
This should not be mandatory at all locations, but rather should be considered on a case by case basis. If signals are not needed for non-handicapped persons, there is a question as to whether or not they would be needed for handicapped individuals.
Accessible Pedestrian Signal Systems (1102.8, 1106)
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
Obviously these add cost to signal installation/maintenance. Where will the funding for this come from in these tight economic times?
1106.2.1 Location. Pedestrian signal devices shall be located 60 inches
This will require major reconstruction of many traffic signals. In many locations, it is not possible to comply with this due to existing obstructions in the way of the signal, including underground utilities.
1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
This is another cost concern. It is also sometimes a concern with nearby residents/businesses as to the addition of noise pollution.
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.
Another cost concern.
On-Street Parking (1102.14, 1109)
- The draft guidelines would require access to at least one parking space on each blockface.
In an area with 150 foot
This also does not specify if this would be required city-wide or only in commercial areas. Providing the required handicapped parking space with signing, pavement markings and ramps on every block in the city would create an astronomical cost.
- Requirements address adjoining access aisles at spaces, accessible connecting routes, signs, and parking meters. An accessible parallel space and access aisle, which must be flush with the street, can be achieved by indenting the curb line, similar to a loading zone.
This will create problems during snow events. Plows will come along and push snow into the indented area, making them useless. These will also create discontinuities in the sidewalks in downtown areas where sidewalks normally run from the face of buildings to the edge of the curb. In high ped areas, this will have a major negative impact. I think the cost of lawsuits related to trips and falls in these inset areas each year will greatly outweigh any benefits derived from their installation.
Passenger Loading Zones (1102.15)
- ADAAG requirements for passenger loading zones would be applied to loading zones in the public right-of-way. Where a long loading zone is provided, at least one area in every 100 continuous feet must comply with requirements in ADAAG section 302 and 503 which address the surfacing, the size of vehicle pull-up spaces (8 by 20 feet
These will not work well at schools where it is important to provide curbs to create barriers to vehicles running onto sidewalks and hitting pedestrians.
- 1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
This is a costly unfunded mandate. Providing parallel ped access on the same side of the Street as the existing path is often not practicable. Based on costs and usage, it is often impossible to justify not moving pedestrians, both able bodied and disabled, to an adjacent route.
- 1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
The MUTCD allows secondary signs to have a minimum height of 72", vs. 80" required here. This would require major work to change signs throughout the city.
Again, we support reasonable access for disabled pedestrians and continually review our standards and processes to assure that what we are doing is reasonable and safe. We are concerned that these draft guidelines, if adopted, would create major consequences for communities of all sizes. We would ask that these consequences be considered more carefully before enacting any changes to the existing requirements.
Sincerely,
Randy Hoskins, P.E.
City Traffic Engineer
City of Lincoln, Nebraska
Kathryn Moore Ridley, October 21, 2002
I would like to provide my support for the accessible pedestrian signals. I have a sister who is blind and these are extremely useful for her and have helped her tremendously in the areas they exist. I also find them useful. I notice that drivers are more aware of pedestrians because of the noise.
Thank you for your attention to this matter.
Kathryn Moore Ridley
American Institute of Architects, October 28, 2002
The American Institute of Architects
Introduction
The American Institute of Architects, founded in 1857, is the professional organization for more than 70,000 licensed architects and associated professionals. With headquarters in Washington, D.C., and more than 300 state and local chapters worldwide, the AIA seeks to promote a more humane built environment through education, government advocacy, community redevelopment, and public outreach activities.
As part of its commitment to making the built environment fully accessible for the safe, enjoyable use of everyone, the AIA supports the goal of the Draft Guidelines.General CommentsAccessible Pathways to and through the Built Environment
AIA architects recognize the value of developing a network of accessible pathways to and through the built environment, including those in the public rights-of-way, within a site, and within buildings and facilities. Accessible pedestrian routes, approaches, and entrances are often important aspects of an architect's design of a building or space, and development of a seamless pedestrian path is a desirable goal.Clarity and Certainty
The AIA advocates clear and certain guidance to help ensure compliance with the ADA.
Clearly written, concise guidelines will help ensure that architects understand the requirements of ADAAG and, even more important, will provide them with a high degree of certainty that their designs meet its accessibility standards. The AIA urges the U.S. Architectural and Transportation Barriers Compliance Board (Access Board) to continue to strive for clarity and certainty in the ADAAG.Curb Ramps
The Draft Guidelines are inconsistent in their treatment of curb ramps. In particular, the draft is inconsistent in the way it handles the allowable slopes for parallel curb ramps and perpendicular curb ramps running parallel to street grades. The maximum-length exception for parallel curb ramps is not applied to perpendicular curb ramps. When the direction of street grade is parallel to the curb ramp, however, it should not matter which type of curb ramp is used. Both should be required to have the same maximum required distance. Otherwise, to stay within the maximum slope requirements, a curb ramp would have to be extremely long.Grade of Pedestrian Access Routes
The Draft Guidelines prohibit slopes on pedestrian access routes from exceeding the grade established for the adjacent roadway. However, where parallel or perpendicular curb ramps are installed in line with the direction of sidewalk travel, the curb ramp on the uphill side of a landing at mid-block and the perpendicular curb ramp on the uphill side of an intersecting street will have to exceed the grade of the adjacent street. Exceeding the grade of the street is necessary in order to overcome the difference in elevation from the street to the top of the curb/sidewalk.Changes in Level
The Draft Guidelines address the issue of changes in level in several places. The current ADAAG acknowledges the reality of changes in level, addresses how they should be accomplished, and provides minimum acceptable standards for accessible floor and ground surfaces. In contrast, the Draft Guidelines prohibit changes in level in most areas.
The Draft Guidelines do not permit changes in level along accessible routes more often than every 30 inches
The Draft Guidelines also prohibit changes in level to regulate the unevenness of the surface, although the Access Board has decided this is premature until measurable technical specifications are identified. The discussion says, "this would not rule out the use of bricks or other small pavers, installed in a manner that provides a relatively flush surface and that are properly maintained." This assumption is inaccurate. Particularly in exterior applications, installing unit pavers without a change of level within a 30-inch zone would be almost impossible. The pavers would have to be installed with extreme precision, and the joints would have to be grouted exactly flush with the top of the pavers. In addition, such materials and the supporting substrates are subject to movement due to changes in temperature and moisture content, as well as inherent differences in the materials. It is unrealistic and unreasonable to expect that such a surface could be maintained in a "perfectly" smooth condition.
Vertical changes in level at curb ramps, blended transitions, landings, and gutter areas along pedestrian routes are also prohibited in the Draft Guidelines. This requirement would prohibit the use of any material whose texture had even the smallest groove or crack and would essentially eliminate the use of many materials. Unit pavers, for example, could not be used because they would create tremendous problems in trying to achieve and maintain perfect flatness. Even scored concrete would not be allowed under this requirement, regardless of how narrow the score. Square, metal utility covers measuring less than 30 inches by 30 inches
Whereas the current ADAAG specifies minimum requirements, the Draft Guidelines?by allowing no changes in level and requiring perfectly flat surfaces?up the ante considerably by moving to optimum requirements.Pedestrian Overpasses and Underpasses
The requirements for pedestrian overpasses and underpasses in the Draft Guidelines are linked to the rise of the ramped approach. The vague terms used in the guidelines do not define the "approach" and do not appear to consider the distance over which the approach might span. There are no such limitations on ramp rise in other areas of the built environment. Elevators are expensive to install and maintain in such environments. Moreover, elevators in unsupervised public areas are subject to vandalism and may pose a security threat by providing hiding spaces for criminals. Given these problems, it is unlikely that pedestrian overpasses and underpasses will be built.Conclusion
Accessibility in the public rights-of-way is an important and highly complex subject. It is important that the impact of regulations be completely understood before development of a final rule. It is equally important that requirements be written in clear and concise language in order to achieve the desired accessibility without misinterpretations and misunderstandings.Comments to Specific Text
The following table includes comments to the specific text of the Draft Guidelines.
Draft Guidelines for
Accessible Public Rights-of-Way The American Institute of Architects Comments
1101 Application and Administration
1101.1 General. For the purposes of these requirements, the terms listed in section 1101.3 shall have the indicated meaning.
1101.2 Referenced Standards.
1101.2.1 MUTCD. Copies of the referenced standards may be obtained on-line from the Federal Highway Administration at http://mutcd.fhwa.dot.gov. The reference to where it can be obtained is not necessary in a code. This is good commentary information.
MUTCD 2000-Millennium Edition Manual on Uniform Traffic Control Devices.
1101.3 Defined Terms.
Accessible Pedestrian Signal. A device that communicates information about the pedestrian WALK phase in non-visual format.
Accessible Route. A continuous, unobstructed path that complies with Chapter 4. This definition is superior to the one in the 2 April 02 draft ADAAG.
Channelizing Island. Curbed or painted area outside the vehicular path that is provided to separate and direct traffic movement, which also may serve as a refuge for pedestrians. Delete the last part of the definition?"which also may serve as a refuge for pedestrians." This is clearly not what defines the channelizing island and should be left to commentary.
Cross Slope. The slope that is perpendicular to the direction of travel. This is usually called superelevation on curves in the public right-of-way (see superelevation). The added text about superelevation is advisory and as such unfit for the definition. Recommendation: Place this text in a commentary if there is value in the explanation. Also, see comment under definition of "Superelevation."
Crosswalk. That part of a roadway at an intersection that is included within the extensions of the lateral lines of the sidewalks on opposite sides of the roadway, measured from the curbline or, in the absence of curbs, from the edges of the roadway or, in the absence of a sidewalk on one side of the roadway, the part of the roadway included within the extension of the lateral lines of the sidewalk at right angles to the centerline. Also, any portion of a roadway at an intersection or elsewhere that is distinctly indicated for pedestrian crossing by lines or other markings on the surface. This definition is unnecessarily confusing.
There is no need to introduce a new term, "roadway," when ADAAG already has a defined term "vehicular way."
"Lateral lines of the sidewalk" is not a common term and is confusing. It might be clearer to say the "edges of the sidewalk," if that is what is meant.
It is unclear why the measurement method is given in the definition. This might be pertinent in some technical criteria and, if so, should be included in the technical provisions, not the definition. However, no place was found in this document where the measurement of the crosswalk was needed.
In addition, the measurement method is included in the middle of the definition, breaking the thought of what defines a crosswalk.
The phrase "?within the extension of the lateral lines of the sidewalk at right angles to the centerline" is unclear. Right angles to the centerline of what?
The last sentence is too open-ended. If this is intended to capture mid-block crosswalks, a new definition should be added. If it is intended to capture all marked crosswalks, then it will likely negate the rest of the definition when it is applied in the real world. For example, the intersection could have a meandering marked path across the intersection that is outside the area of the defined crosswalk, and it would qualify under this part of the definition as a crosswalk.
Proposed definition:
Crosswalk: That part of the vehicular way that is included within the projection of the line of the sidewalk edges across the intersection. Where sidewalks occur on both sides of the intersection, the imaginary lines connect the sidewalk edges across the intersection.
Alternate proposal:
Crosswalk: That part of a vehicular way at an intersection that is included within the imaginary lines connecting sidewalk edges across the vehicular way. In the absence of a sidewalk on one side of the roadway, it is the part of the vehicular way that is included in the projection of the line of the sidewalk edges across the intersection.
Curb Line. A line at the face of the curb that marks the transition between the sidewalk and the gutter or roadway. The definition of curb line needs clarification. Is this line the top back of the curb, the top front, or the toe of the curb? Some curb faces are sloped, raising the question of where the curb line falls.
Curb Ramp. A ramp cutting through a curb or built up to it. A transition at a curb that has a running slope of less than 1:20
A curb ramp is a feature that is more commonly understood than a "blended transition," which is not defined. Recommend defining blended transition, at least in commentary.
Detectable Warning. A surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path.
Dynamic Envelope. The clearance required for a rail vehicle and its cargo overhang due to any combination of loading, lateral motion, or suspension failure. The suspension failure is a little perplexing. Isn't that covered under lateral motion? If not, how is it an enforceable part of the guidelines? Does the envelope include the area of trains that have derailed due to suspension failure? If this is not a necessary part of the definition, it is best deleted or moved into commentary.
Element. An architectural or mechanical component of a building, facility, space, site or public right-of-way. See comments at right-of-way.
Facility. All or any portion of buildings, structures, improvements, elements and pedestrian or vehicular routes located on a site or in a public right-of-way. See comments at right-of-way.
Grade. (See running slope). The term "grade" is probably not necessary in this document, but if found to be necessary, consistency of use will be extremely important. If it is necessary, then it should be differentiated from the term "running slope" by definition. Grade is commonly used by industry for sitework and roadwork. So, if it is necessary to use the term, define it as the slope or running slope of the vehicular way, whichever is appropriate. As shown here, it appears to include only the running slope and not the cross slope. It is unclear how that can be, at an intersection where the running slope of two streets cross, but nonetheless, the definition should be separated from "running slope," which is typically used for the sidewalk or pedestrian access route. Another problem with identifying this term with a running slope is the following definition of "grade break," which is not limited to running slope.
In addition, the term should not be used for other purposes in the rule. For example, the term "grade" is used with a completely different meaning in two places?sections 1103.7 and 1103.8.1?in the draft guidelines. Another term should be used here.
Grade Break. The meeting line of two adjacent surfaces of different slope (grade). "Grade" now becomes the same as any slope, not just running slopes. See comments to the definition of "Grade."
Locator Tone. A repeating sound that identifies the location of the pedestrian push button. A message that says "the button is on the other side of the intersection" satisfies this definition, though clearly not the intended result.
Alternative text:
Locator Tone. A repeating sound originating from a location adjacent to the pedestrian push button for purposes of identifying the location of the pedestrian push button.
Pedestrian Access Route. An accessible corridor for pedestrian use within the public right-of-way. The term "corridor" adds unnecessary questions to the definition. Corridors in buildings have space defining walls. Corridors in transportation planning have a definition relating to roadways (as used in the next definition). Recommendation: For clarity, use a more common term such as path, pathway, or route. A term commonly used for the setting will help avoid questions about what is meant.
Recognizing that there has been a huge effort not to use the term "accessible route" in this document, it is still a logical term that simply has different technical criteria in the public right-of-way.
Public Right-of-Way. Land or property, usually in a corridor, that is acquired for or devoted to transportation purposes. ADA in general and ADAAG in particular are rather loose in the use of the word "public." Does this imply that the public owns the underlying property? Or simply has an easement? Alternatively, this could be read to suggest that it is the public who has the right of transportation, or it could be read that he who acquires has the right of transportation. The word "transportation" carries the strong suggestion (almost to the point of being a necessary part of the definition of the word) that something is carried. This tends to exclude pedestrian sidewalks from the definition of public right-of-way.
As written, the definition could include many things that are not intended, such as bicycle paths, skateboard parks, etc.
"Land" is a subset of "property," so why use both words?
The "usually in a corridor" is advisory text unfit for a definition. Many people will not understand the term "corridor" in this context, particularly since the term as used here has a different meaning than the one used in the definition of "Pedestrian Access Route."
This definition could include land that a property owner buys from his neighbor for transporting timber to the highway.
This definition is crucial to scoping the regulation, but without better coordination with the definition of site it will weaken accessibility. The proposed definition describes something that can exist on sites, so using the rule that the specific requirements trump the general requirements, it follows that designers will be permitted to use the weaker requirements of rights-of-way where previously they were required to provide a higher level of accessibility.
Roundabout. A circular intersection that has yield control of entering traffic, channelized approaches, counterclockwise circulation, and appropriate geometric curvature to limit travel speeds on the circulatory roadway.
Running Slope. The slope that is parallel to the direction of travel expressed as a ratio of rise to run. In the public right-of-way, this is usually called grade, and is expressed in percent. Delete the phrase "expressed as a ratio of rise to run" and the second sentence as advisory material inappropriate for a definition.
Again, the term "grade" appears as running slope only. See comments to definitions of "Grade" and "Grade Break."
Sidewalk. That portion of a public right-of-way between the curb line or lateral line of a roadway and the adjacent property line that is improved for use by pedestrians. This is poor code drafting, because the intent of the designer is the triggering condition. If the designer improved the shoulder of the road to make life easier for the snowplow, it is not a sidewalk even though it looks like a sidewalk and its use by pedestrians is tolerated.
In addition, it can be read in two different ways: It can be read to be only the improved portion of that area, or the entire area if any of it is improved. Clarification of this definition is critical to the definition of "Crosswalk," as well as the technical criteria for on-street parking in Section 1109.2 (Exception).
Splitter Island. A flush or raised island that separates entering and exiting traffic in a roundabout.
Street Furniture. Elements in the public right-of-way that are intended for use by pedestrians. This definition might be too broad. There can be many things intended for use by pedestrians that would also be defined as elements, such as pedestrian push buttons and pedestrian overpasses. Yet those are not intended to be covered by the definition of street furniture. It might be best simply to delete the definition.
Superelevation. Cross slope on a curve in the roadway (see cross slope). Delete definition. The term is not used in this document, except in commentary in the definition of the term "Cross Slope." Inclusion of a definition that is not used in the technical requirements is inappropriate.
Walk Interval. That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and its audible equivalent.
The term "Walk Interval" logically includes the time interval for walking all the way across an intersection, or at least to a refuge island. However, that is not what the definition says. This causes confusion. The definition, coupled with the technical provisions where the term is used, appears to define a specific time to start the walk across the intersection. After that interval it is not safe to start. For the blind this is an important feature of the signal.
Because the term does not indicate the definition, it is confusing. Recommend a new term that is indicative of the definition, such as:
Start Walk Phase: That time interval of a traffic signal cycle . . . etc.
1102 Scoping Requirements
1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way shall comply with Chapter 11. Most newly constructed public rights-of-way are designed and constructed by ADA title III entities, while most alteration projects are conducted by ADA title II entities.
Due to a window between the effective dates for various parts of the original ADAAG through which projects could have avoided ADA compliance, the original ADAAG took the nonsensical position that an addition was some sort of alteration. This window has long since closed, so there is no good reason to continue with that approach.
Additions should be treated as new construction. An addition should not be treated as an alteration, like the approach taken by the current ADAAG 4.1.5.
The form of the charging statements is not consistent with the remainder of ADAAG.
Replace 1102.1 through 1102.2.2 with:
1102.1 General. Rights-of-way shall comply with Chapter 11.
1102.2 Existing Public Rights-of-Way. Additions to existing public rights-of-way shall comply with 1102.2.1. Alterations to existing public rights-of-way shall comply with 1102.2.2. See Comment to 1102.1.
1102.2.1 Additions. Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2. See Comment to 1102.1. The only valid piece in this section is the guidance given on how to deal with the interface of new additions to the existing construction.
1102.2.2 Alterations. Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11. See Comment to 1102.1.
EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible. Delete because the general text at ADAAG 202.3 controls this.
1102.2.2.1 Extent of Application. An alteration of an existing element, space, or area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction. Delete because the general text at ADAAG 202.3.2 controls this.
1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way, below the requirements for new construction at the time of the alteration is prohibited. Delete because the general text at ADAAG 202.3.1 controls this.
This is particularly confusing and open-ended. In an alteration, if, in order to make a sidewalk accessible, one would decrease the accessibility of the site arrival point, this section would prohibit that.
However, if by making the same site arrival point accessible will make the sidewalk less accessible than the requirements for new construction, this section would prohibit that as well. This leaves the designers in the position of not being able to meet the rule either way. And someone will be required to make a decision about which is the most important piece of the route to be accessible. For example, it might have to be decided whether the cross slope of the sidewalk becomes too steep or the landing at the building door includes a step.
1102.3 Alternate Circulation Path. An alternate circulation path complying with 1111 shall be provided whenever the existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary conditions. Delete, because it is an operational issue better contained in the regulations issued by DOJ, DOT, DOD, HUD, GSA, and USPS.
1102.4 Sidewalks. Where sidewalks are provided, they shall contain a continuous pedestrian access route complying with 1103. The pedestrian access route shall connect to elements required to comply with Chapter 11.
1102.5 Protruding Objects. Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes. Delete all of 1102.5 because ADAAG 204 controls this issue.
1102.5.1 Protrusion Limits. Objects with leading edges more than 27 inches
EXCEPTION: Handrails shall be permitted to protrude 4-1/2 inches
1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps. See above
1102.5.3 Reduced Vertical Clearance. Guardrails or other barriers shall be provided where the vertical clearance is less than 80 inches
EXCEPTION: Door closers and door stops shall be permitted to be 78 inches
1102.6 Curb Ramps and Blended Transitions. A curb ramp or blended transition complying with 1104, or a combination of curb ramps and blended transitions, shall connect the pedestrian access routes to each street crossing within the width of each crosswalk.
1102.7 Pedestrian Signs. Signs for pedestrian use shall comply with 1102.7.
1102.7.1 Bus Route Identification. Bus route identification signs shall comply with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to the maximum extent practicable, bus route identification signs shall comply with 703.5.5. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with 703.2, and shall have rounded corners. Delete all material covered elsewhere in ADAAG (e.g., signs are now in 810.4 in
EXCEPTIONS 1: Bus schedules, timetables and maps that are posted at the bus stop or bus shelter shall not be required to comply with 1102.7. Delete?see above.
2: Signs shall not be required to comply with 703.2 where audible signs are user- or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual. Move to 810.4 (Draft ADAAG number)
1102.7.2 Informational Signs and Warning Signs. Informational signs and warning signs shall comply with 703.5. Delete
1102.8 Pedestrian Crossings. Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, they shall comply with 1106. "Pedestrian crossings" is an undefined term. How can one know if one is provided? Should define the term and include what is being crossed.
1102.9 Street Furniture. Street furniture that is intended for use by pedestrians and installed on or adjacent to a sidewalk shall comply with 309 and 1107. Delete the phrase "that is intended for use by pedestrians," since this text is part of the definition. The phrase "or adjacent" is problematic because the land adjacent may be outside the right-of-way, thus violating the definition and illegally requiring work on property not under the control of the entity responsible for the right-of-way.
1102.10 Stairs. Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
1102.11 Handrails. Where provided, handrails shall comply with 505.
1102.12 Vertical Access. Where provided elevators shall comply with 407, limited-use/limited-application elevators shall comply with 408, and platform lifts shall comply with 410. Vertical access shall remain unlocked during the operating hours of the facility served. Delete because ADAAG 407 controls this issue. Delete the hours of service material as better suited to the adopting agency's regulation.
1102.13 Bus Stops. Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with 810.3. Delete
1102.14 On-Street Parking. Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109. There is no substantiation given for a parking space on every block face. The ratio of the number of accessible parking spaces to the overall number of on-street parking spaces in the area varies with the length of the block face and type of parking. There is no credit given to public off-street parking made available, for example, by a city. There is no exception given for blocks that feature nothing but a parking garage containing a number of accessible parking spaces. Many businesses provide parking garages with accessible spaces for their clients. The requirement to provide an accessible parking space on each block face needs further study.
As stated in earlier comments, most streets are developed by Title III entities for residential areas. It does not seem logical to require accessible on-street parking on each block face for these areas as well. The effects of this requirement and the justification for the numbers need further clarification.
1102.15 Passenger Loading Zones. Where passenger loading zones are provided, they shall connect to a pedestrian access route and shall provide a minimum of one passenger loading zone in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof, complying with 302, 503.2, 503.3, and 503.5. Delete. This is already covered in ADAAG.
1102.16 Call Boxes. Where provided, call boxes shall comply with 1110.
1103 Pedestrian Access Route
1103.1 General. Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103. This could be confused as scoping and as requiring pedestrian access routes where pedestrian routes are not planned. This needs to be clarified.
1103.2 Components. Pedestrian access routes shall consist of one or more of the following components: walking surfaces, ramps, curb ramps, blended transitions, crosswalks, pedestrian overpasses and underpasses, elevators, and platform lifts. All components of a pedestrian access route shall comply with the applicable portions of this chapter.
1103.3 Clear Width. The minimum clear width of a pedestrian access route shall be 48 inches
1103.4 Cross Slope. The cross slope of the pedestrian access route shall be 1:48
1103.5 Grade. The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway. The grade and the running slope are the same. See comments to definition of "Grade."
See General Comment at the beginning of this paper regarding limitations on pedestrian access routes and how they cannot comply with this at curb ramps.
This requirement is an absolute that precludes making the pedestrian access route more accessible by increasing or decreasing the slope. If the roadway is dead level or negative, there is no reason the slope of the pedestrian access route should not exceed the slope of the roadway.
In addition, the approach to a pedestrian underpass could warrant exceeding the adjacent roadway to accomplish the additional height to take the accessible pedestrian route over something.
EXCEPTION: The running slope of a pedestrian access route shall be permitted to be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 1:20
Consider again the place where most new streets are built: the residential development. Again, if there is reason to have the sidewalk any steeper than the roadway, you will end up with ramps and handrails along the street in front of the houses. Or, more likely, you will not have any sidewalks in the development.
1103.6 Surfaces. The surfaces of the pedestrian access route shall comply with 302.
1103.7 Surface Gaps at Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the horizontal gap at the inner edge of each rail shall be constructed to the minimum dimension necessary to allow passage of railroad car wheel flanges and shall not exceed 2-½ inches (64 mm). The term "grade" is used here in a manner different than the definition. See comments to definition of "Grade."
EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch
1103.7.1 Detectable Warnings. Where rail systems cross pedestrian facilities that are not shared with vehicular ways, a detectable warning shall be provided in compliance with 1108. This could be read to require detectable warnings at pedestrian overpasses and underpasses.
1103.8 Changes in Level. Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
Note also that even unit pavers that are 30 X 30 inches
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings. Here is a real conflict in thinking. The guideline states that there can be no changes in level, not even a very narrow scored line in the concrete, yet it mandates changes in level at every curb ramp and intersection of a pedestrian access route and rail crossing with the inclusion of detectable warnings.
1103.8.1 Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the surface of the pedestrian access route shall be level and flush with the top of the rail at the outer edge and between the rails. The term "grade" is used here in a manner different from the definition. See comments to definition of "Grade."
1104 Curb Ramps and Blended Transitions
1104.1 General. Curb ramps and blended transitions shall comply with 1104.
1104.2 Types. Perpendicular curb ramps shall comply with 1104.2.1 and 1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended transitions shall comply with 1104.2.3 and 1104.3.
1104.2.1 Perpendicular Curb Ramps. Perpendicular curb ramps shall comply with 1104.2.1, and shall have a running slope that cuts through the curb at right angles or meets the gutter grade break at right angles. A grade break occurs when two slopes meet. A running slope doesn't "meet the grade break" but rather meets the gutter. The meeting of the ramp slope and the gutter slope forms the grade break.
Delete "grade break" in the last sentence.
This section is in direct conflict with1104.3 Common Elements, which prohibits grade breaks in gutter areas.
Note also that "Perpendicular Curb Ramp" is not defined except by these technical criteria. There is no obvious difference to distinguish it from a "parallel curb ramp." See comments to Section 1104.2.2 Parallel Curb Ramps.
1104.2.1.1 Running Slope. The running slope shall be 1:48
There should be an exception for running slopes at mid-block crossings in accordance with the exception at 1104.2.1.3.
1104.2.1.2 Cross Slope. The cross slope shall be 1:48
EXCEPTION: This requirement shall not apply to mid-block crossings.
1104.2.1.3 Landing. A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings. This exception appears to be misplaced. It appears that there should be a separate exception for running and cross slopes beneath their respective sections.
1104.2.1.4 Flares. Flared sides with a slope of 1:10
1104.2.2 Parallel Curb Ramps. Parallel curb ramps shall comply with 1104.2.2, and shall have a running slope that is in-line with the direction of sidewalk travel.
1104.2.2.1 Running Slope. The running slope shall be 1:48
EXCEPTION: A parallel curb ramp shall not be required to exceed 15 feet
1104.2.2.2 Cross Slope. The cross slope shall be 1:48
1104.2.2.3 Landing. A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.
1104.2.2.4 Diverging Sidewalks. Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments shall be protected with a barrier.
1104.2.3 Blended Transitions. Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
1104.3 Common Elements. Curb ramps and blended transitions shall comply with 1104.3.
1104.3.1 Width. The clear width of landings, blended transitions, and curb ramps, excluding flares, shall be 48 inches
1104.3.2 Detectable Warnings. Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk. There has been much testimony and debate regarding the benefits and necessity of detectable warnings. Before there is a requirement for detectable warnings to be provided in so many places, the Board should be certain that it is not creating a less accessible walking surface for anyone. Some people have to drag their feet when they walk, and this document is riddled with requirements prohibiting level changes for people who use wheelchairs. It is counterintuitive that such opposing requirements are both so important, and yet both are required in the same location within the pedestrian access route.
1104.3.3 Surfaces. Surfaces of curb ramps, blended transitions, and landings shall comply with 302. Gratings, access covers, and other appurtenances shall not be located on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route.
1104.3.4 Grade Breaks. Grade breaks shall not be permitted on curb ramps, blended transitions, landings, and gutter areas within the pedestrian access route. Surface slopes that meet at grade breaks shall be flush. Another misuse of the term "grade break." The first sentence says that grade breaks are not permitted, and then says that surface slopes that meet at grade breaks must be flush. This is either a conflict or, at best, confusing because it can be read to mean that it is the same area. For example, a grade break is not allowed in a gutter area, which can be considered an area with a surface, which would then be allowed, but regulated by the last sentence. If surface slopes are other than the listed areas, then that term should be defined and addressed in a new section. And if the problem with them is vertical changes in level, then that should be addressed in 1104.3.5. Otherwise the idea of "flush" is unclear in this application.
Another conflict is that grade breaks are not allowed on curb ramps. Built-up curb ramps that have flares will by their nature have grade breaks at the sides where the flare meets the running slope of the ramp. The definition of ramp causes the flare to be considered a ramp, where a pedestrian circulation path crosses the curb ramp, as allowed by 1104.2.1.4.
1104.3.5 Changes in Level. Vertical changes in level shall not be permitted on curb ramps, blended transitions, landings, or gutter areas within the pedestrian access route. How is it that curb ramps and blended transitions are not allowed to have even the slightest vertical changes in level, but are required to have detectable warnings, which by definition consist of a bunch of level changes. This is counterintuitive.
1104.3.6 Counter Slopes. The counter slope of the gutter area or street at the foot of a curb ramp or blended transition shall be 1:20
This is a conflict.
1104.3.7 Clear Space. Beyond the curb line, a clear space of 48 inches
A clear space of 48 inches
Also, it is unclear what the "parallel" vehicle travel lane is. Parallel to what?
1105 Pedestrian Crossings "Pedestrian crossings" is an undefined term.
1105.1 General. Pedestrian crossings shall comply with 1105. "Pedestrian crossings" is an undefined term.
1105.2 Crosswalks. Crosswalks shall comply with 1105.2.
1105.2.1 Width. Marked crosswalks shall be 96 inches
1105.2.2 Cross Slope. The cross slope shall be 1:48
The requirement for a crosswalk to have a minimal cross slope will increase the width of every intersection in sloping terrain, because of the need to create this tabletop effect.
EXCEPTION: This requirement shall not apply to mid-block crossings. If it is acceptable to have a cross slope at the mid-block crossing, why not at the intersection? The establishment of crosswalks at mid-block seems to have different requirements because of their effect on vehicular traffic safety. This certainly needs to be a consideration at intersections as well.
1105.2.3 Running Slope. The running slope shall be 1:20
As this tabletop and running slope limitation continues for intersection after intersection up a hill or mountain, it will require that the hill or mountain be removed to a large degree. Otherwise, at some point, the natural slope will depart from the street grade, separating the adjacent sites from the sidewalk/street by a vertical barrier.
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
What effect will longer crossing times?and the concomitant increases in engine idling time and vehicle trip times?have on clean air requirements?
1105.4 Medians and Pedestrian Refuge Islands. Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying with 1104 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches
1105.4.1 Length. Where signal timing is inadequate for full crossing of all traffic lanes or where the crossing is not signalized, cut-through medians and pedestrian refuge islands shall be 72 inches
1105.4.2 Detectable Warnings. Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24 inch
EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing.
1105.5 Pedestrian Overpasses and Underpasses. Pedestrian overpasses and underpasses shall comply with 1105.5.
1105.5.1 Pedestrian Access Route. Pedestrian overpasses and underpasses shall contain a pedestrian access route complying with 1103.
1105.5.2 Running Slope. The running slope shall not exceed 1:20
1105.5.3 Approach. Where the approach exceeds 1:20
1105.5.4 Stairs. Stairs shall comply with 504. For buildings, the only stairs that are required by ADAAG 210 to comply with 504 are those used in the accessible means of egress. If an accessible pedestrian route is provided by ramps or elevators, it does not seem that the stairs in these locations should be required to meet 504.
1105.5.5 Escalators. Escalators shall comply with 810.9.
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
1105.6.1 Separation. Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island. Crosswalk is a defined term that seems to indicate that there is a crosswalk at every intersection that has a sidewalk on any part of the intersection. That definition does not mention the use by pedestrians. The term "pedestrian crosswalk" is not defined. See earlier comment about the term "pedestrian crossing."
It is unclear whether this is for crossing the slip lane or for crossings that parallel the direction of the slip lane.
1106 Accessible Pedestrian Signal Systems
1106.1 General. Pedestrian signal systems shall comply with 1106.
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
1106.2.1 Location. Pedestrian signal devices shall be located 60 inches
The control face must face the intersection, so people standing in front of it will have their backs to the intersection. With the face of the device facing the intersection, it is unclear how it will also be parallel to the direction of the crosswalk it serves.
Ten feet from other signal devices seems like a lot when the right-of-way might not be that wide.
EXCEPTION: The minimum distance from other signal devices shall not apply to signal devices located in medians and islands.
1106.2.2 Reach and Clear Floor or Ground Space. Pedestrian signal devices shall comply with 308. A clear floor or ground space complying with 305 shall be provided at the signal device and shall connect to or overlap the pedestrian access route.
1106.2.3 Audible Walk Indication. The audible indication of the WALK interval shall be by voice or tone.
1106.2.3.1 Tones. Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds
1106.2.3.2 Volume. Tone or voice volume measured at 36 inches
1106.3 Pedestrian Pushbuttons. Pedestrian pushbuttons shall comply with 1106.3.
1106.3.1 Operation. Pedestrian pushbuttons shall comply with 309.4.
1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
1106.3.3 Size and Contrast. Pedestrian pushbuttons shall be a minimum of 2 inches
1106.3.4 Optional Features. An extended button press shall be permitted to activate additional features. Buttons that provide additional features shall be marked with three Braille dots forming an equilateral triangle in the center of the pushbutton.
1106.4 Directional Information and Signs. Pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal.
1106.4.1 Arrow. Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 inch
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2. With all of the requirements for push buttons, arrows, signs, and street names, as well as distances from other devices, the area at the intersection could become cluttered with items that will possibly block the view of motorists, a safety problem that could jeopardize pedestrians as well as motorists. Consideration should be made for the clutter that might occur.
1106.4.3 Crosswalk Configuration. Where provided, graphic indication of crosswalk configuration shall be tactile and shall comply with 703.5.1.
1107 Street Furniture
1107.1 General. Street furniture shall comply with 1107.
1107.2 Clear Floor or Ground Space. Street furniture shall have clear floor or ground space complying with 305 and shall be connected to the pedestrian access route. The clear floor or ground space shall overlap the pedestrian access route 12 inches
1107.3 Drinking Fountains. Where drinking fountains are provided, they shall comply with 602.
1107.4 Public Telephones. Where public telephones are provided, they shall comply with 1107.4.
1107.4.1 Single Telephone. Where a single public telephone is provided, it shall comply with 704.2 and 704.4
1107.4.2 Multiple Telephones. Where a bank of public telephones is provided, at least one telephone shall comply with 704.2, and at least one additional telephone shall comply with 704.4.
1107.4.3 Volume Controls. All public telephones shall provide volume controls complying with 704.3.
1107.5 Public Toilet Facilities. Permanent or portable public toilet facilities shall comply with 603. At least one fixture of each type provided shall comply with 604 through 610. Operable parts, dispensers, receptacles, or other equipment shall comply with 309.
EXCEPTION: Where multiple single-user toilet facilities are clustered at a single location, at least 5 percent, but no fewer than one single-user toilet at each cluster shall comply with 603 and shall be identified by the International Symbol of Accessibility complying with 703.7.2.1.
1107.6 Tables, Counters, and Benches. Tables, counters, and benches shall comply with 1107.6.
1107.6.1 Tables. Where tables are provided in a single location, at least 5 percent but no fewer than one, shall comply with 902.
1107.6.2 Counters. Where provided, counters shall comply with 904. It is unclear where counters might occur in a public right-of-way. The guidelines should not attempt to address temporary vendor operations, but only the permanent street furniture.
1107.6.3 Benches. Where benches without tables are provided at a single location, at least 50 percent, but no fewer than one, shall comply with 903 and shall have an armrest on at least one end. It is unclear why 50% of the benches should comply with the provisions of 903. Also, there is no reason given in the discussion why an armrest is required on 50% of the benches in the public right-of-way, when these have not been and are not required in ADAAG.
1108 Detectable Warning Surfaces
1108.1 General. Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108. Delete because this material is covered elsewhere in ADAAG.
Note also that the requirement that the domes be on a square grid is nearly meaningless. A square grid can be applied over the domes at an angle and they would meet the provision. A square grid can be applied over the domes with only certain domes hitting on the grid and, because the grid is moved over the domes, the other domes meet the grid. Some domes might be aligned by a square grid of one size and the other domes aligned to a different size square grid.
1108.1.1 Dome Size. Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches
1108.1.2 Dome Spacing. Truncated domes in a detectable warning surface shall have a center-to-center spacing of 1.6 inches
1108.1.3 Contrast. Detectable warning surfaces shall contrast visually with adjacent walking surfaces either light-on-dark, or dark-on-light. Delete because this material is covered elsewhere in ADAAG.
1108.1.4 Size. Detectable warning surfaces shall extend 24 inches
1108.2 Location.
1108.2.1 Curb Ramps and Blended Transitions. The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches
1108.2.2 Rail Crossings. The detectable warning surface shall be located so that the edge nearest the rail crossing is 6 inches
1108.2.3 Platform Edges. Detectable warning surfaces at platform boarding edges shall be 24 inches
1109 On-Street Parking
1109.1 General. Car and van on-street parking spaces shall comply with 1109.
1109.2 Parallel Parking Spaces. An access aisle at least 60 inches
EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet
1109.3 Perpendicular or Angled Parking Spaces. Where perpendicular or angled parking is provided, an access aisle 96 inches
1109.4 Curb Ramps or Blended Transition. A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route. This will likely result in a curb ramp cutting into the sidewalk, which will require additional right-of-way space.
1109.5 Obstructions. There shall be no obstructions on the sidewalk adjacent to and for the full length of the space. This does not make sense for perpendicular or angled parking (i.e., the parking space is not parallel to the sidewalk, and the access aisle is connected to the pedestrian access route).
EXCEPTION: This provision shall not apply to parking signs complying with 1109.6 and parking meters complying with 1109.7.2. If the obstructions are a problem for the parallel parked cars, why wouldn't the signs and parking meters be obstructions?
1109.6 Signs. Parking spaces shall be designated as reserved by a sign complying with 502.6. Signs shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer. Delete "so as not to interfere with the operation of a side lift or a passenger side transfer." This is commentary.
1109.7 Parking Meters. Where parking meters are provided, they shall comply with 1109.7.
1109.7.1 Operable Parts. Operable parts shall comply with 309.
1109.7.2 Location. A parking meter shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer. Delete "so as not to interfere with the operation of a side lift or a passenger side transfer." This is commentary.
EXCEPTION: Where parking meters are not provided at the space, but payment for parking in the space is included in a centralized collection box or paying station, the space shall be connected to the centralized collection point with a pedestrian access route.
1109.7.3 Displays and Information. Displays and information shall be visible from a point located 40 inches
1110 Call Boxes
1110.1 General. Call boxes shall comply with 1110.
1110.2 Operable Parts. Operable parts shall comply with 308 and 309.4. Where provided, labeling shall comply with 703.2 and 703.3.
EXCEPTION: Mechanically operated systems in which the signal is initiated by a lever pull shall be permitted to have an activating force of 12 lbf
1110.3 Turning Space. A turning space complying with 304 shall be provided at the controls. Most of these devices will be located in remote areas along a highway. An accessible pedestrian route to the device is not likely to be there. Why require a turning space? Why not a simple pull-in and back-out clear floor space?
1110.4 Edge Protection. Edge protection complying with 405.9.2 shall be provided where the area at the call box is adjacent to an abrupt level change. "Adjacent to an abrupt level change" needs to be clarified. An abrupt level change is a compliant ¼-inch vertical change in level. An abrupt change in level can also mean a rock wall in front of the area. An abrupt change in level can also be the curb that is provided for edge protection. If it means a substantial drop off, then say that.
In addition, what is meant by "the area at the call box is adjacent"? This gives no guidance as to what is under consideration. The turning space required at 1110.3 probably is the area of concern.
1110.5 Motor Vehicle Turnouts. Where provided, a motor vehicle turnout shall have a minimum paved area of 16 feet
1110.6 Two-Way Communication. Where provided, two-way voice communication shall comply with 1110.6, 708.2 and 708.3. The only two-way communications systems within right-of-ways appear to be pay phones and duress call boxes. Does this mean that every pay phone in the right-of-way must have a TTY? Most duress call boxes do not support free-form communication for those who hear, so why is a TTY necessary?
1110.6.1 Volume Controls. Volume controls complying with 704.3 shall be provided.
1110.6.2 TTY. A TTY complying with 704.4 shall be provided.
1111 Alternate Circulation Path Please note that circulation paths are not regulated for running or cross slopes, so this section greatly lowers the level of accessibility that must be provided.
1111.1 General. Alternate circulation paths shall comply with 1111.
1111.2 Width. The alternate circulation path shall have a width of 36 inches
1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street. Why on the same side of the street? If the disruption that triggered a need for an alternate circulation path is the replacement of the old sidewalk, why force the city to lose a travel lane?
1111.4 Protection. The alternate circulation path shall comply with 307 and shall be protected with a barricade complying with 1111.6 to separate the pedestrian access route and alternate circulation path from any adjacent construction, drop-offs, openings, or other hazards. Delete reference to 307, because all circulation paths are already obliged to follow 307. Delete the phrase "pedestrian access route," because this section concerns alternate circulation paths. Justify the requirement that barricades be provided at drop-offs adjacent to alternate circulation paths when regular circulation paths are not similarly regulated.
Further, as worded this will require barricades along all curbs, thereby forcing parkers to walk in traffic until they reach an intersection before they can join the sidewalk.
1111.5 Signs. Signs complying with 703.5 shall be provided at both the near side and the far side of the intersection preceding a disrupted pedestrian access route. The "near side and the far side of the intersection" is confusing. Where is that? Could it be said as "both sides of the intersection, preceding, and on the same side of the street as a disrupted pedestrian access route"?
1111.6 Barricades. Barricades shall be continuous, stable, and non-flexible and shall consist of a solid wall or fence or a Type II or Type III barricade as specified in MUTCD section 6F-60 with the bottom or lower rail 1-1/2 inches
Jeffrey A. Hillegonds, P.E., August 14, 2002
In response to the proposed rule to signalize all cross walks at roundabouts.
Comments:
I am distressed to hear about the proposed rule to signalize all cross walks at roundabouts.
Not only would this be a large financial burden to place at these intersections, it is likely not needed at the vast majority of locations. This type of condition should not be placed as a blanket rule. Signalization, where warranted, can enhance safety for pedestrians and vehicular traffic alike. However, where it is not warranted, it will sometimes increase the risk to pedestrians by confusing drivers or, if the signal is seldom used, creating a dangerous situation because vehicles get used to ignoring unused signals in areas with very few pedestrians.
In addition, the function of the modern roundabout, to promote uninterupted flow through the intersection, particularly at the exits, could be effected, thereby impacting the capacity and safety for pedestrians and motorists alike.
Roundabouts have been constructed, without signalization for pedestrians, in locations like college campuses and other high pedestrian areas with great success.
In my opinion, this rule is not needed at all. A prudent design professional will add signalization where it is warranted. At the very least, the language should be changed significantly, to provide warrants and guidelines for the designer, not a blanket statement that this is required at all locations.
Please consider my comments and re-consider this rule. It is a very bad idea to dictate this type of design at all locations when it really is only needed a very small percentage of the time.
Jeffrey A. Hillegonds, P.E.
Senior Project Manager
Progressive AE
Grand Rapids, MI
Howard R. Della, September 21, 2002
I would like to express my support for audible pedestrian signals. I have been fortunate to be able to use one near the Baltimore Inner Harbor. Believe me, it has made the experience of crossing such a very busy intersection much easier and safer for me. I just wish there could be more of them. Personally, I wish every intersection had one.
Sincerely,
Howard R. Della