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
(1830 mm) minimum in length in the direction of pedestrian travel
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
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
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.
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
John R. Tobin, P.E., P.T.O.E., October 28, 2002
U. S. Access Board Comments
These comments pertain to proposed rule making on pedestrian signal phase timing (1105.3).
The proposed walking speed criteria coupled with the proposed crossing distance criteria would nearly double the pedestrian clearance time requirements in many instances (see enclosed calculations for six-lane/six-lane arterial intersections). Such large increases in pedestrian crossing times would increase the minimum signal cycle length to unreasonable levels that would often create excessive delays, excessive queuing, and serious degradation in existing signal coordination plans. Enclosed calculations indicate that existing signal systems incorporating large six-lane/six-lane arterial intersections would likely need to operate on cycle lengths three minutes in length in order to meet the proposed criteria. The excessive queuing and poor signal coordination that would result could also be expected to significantly increase vehicular accident rates. It is likely that pedestrian safety would suffer as well. As noted in the HCM 2000 (page 18-7), pedestrians' propensity for taking "risk taking behavior" increases as delays increase.
In view of the serious adverse impacts (including adverse safety concerns) that the proposed changes would impose on many existing arterials, it is concluded that the proposed changes will often be "technically infeasible" in many existing signal systems incorporating large six-lane/six-lane arterial intersections. Many arterials have simply not been designed and constructed with short enough crossing distances to feasibly accommodate the changes. Other measures such as "count-down" pedestrian signals or passive crosswalk detection (to extend the pedestrian clearance only when needed) may be appropriate for these existing facilities.
Accommodating the proposed changes on new six-lane arterial facilities will require significant changes in design standards and strategies in order to avoid excessively long pedestrian clearance requirements. Use of corner channelizing islands and/or median refuge islands will likely be needed (see enclosed concept drawing). These treatments break pedestrian crossings into shorter components that can be accommodated within a reasonable system cycle length. However, these treatments often require additional right-of-way for the corner channelization and additional roadway width. Implementing these treatments on existing facilities will also be expensive and disruptive in many instances.
John R. Tobin, P.E., P.T.O.E.
1555 So. Rainbow Boulevard
Las Vegas, NV 89146
Minimum Cycle Length Calculations for
Six lane/Six-lane Arterial Intersections
Assumptions: 1) Approaches include dual left-turn lanes (24' median) and an
exclusive right-turn lane.
2) Left-turn phase demands require no more than 40% of the signal
cycle.
Current Criteria:
Xng distance = (10' spandral) +6(12') + (24' median) + ½ (12') = 112'
Mini. ped clearance = 112' ÷ 4 fps = 28 sec
Min. cycle length = [2(28" + 7" Walk)] ÷ 0.60 = 117 sec
Proposed Criteria:
Xng Dist. = 2(10' spandral) + 7(12') + (24' median) + 1(8' ramp) = 136'
Min. ped. clearance = 136' ÷ 3 fps = 46 sec
Min. cycle length = [2(46" + 7" walk)] ÷ 0.60 = 177 sec
Impacts: Pedestrian clearance is increased 64% from 28 sec
Minimum cycle length is increased 51% from 117 sec
Intersection Channelization to Reduce
Pedestrian Signal Clearance Time
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
--------------------------------------------------------------------------------
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.
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
Patrick J. Burke, October 27, 2002
I am writing in regard to the Access Board Draft Guidelines on Accessible Public Rights-of-Way, particularly Section 1106 and other sections affecting accessible pedestrian crossings. I applaud the work of the Access Board in this area and could only wish that the regulations were more extensive. These regulations will help make true freedom of movement possible for blind pedestrians.
I am totally blind and have had mobility training since age 5. At age 6 I was able to walk independently to school along a short route that involved three residential street crossings. According to instructors in more recent years I still have good white cane technique and excellent spatial perception.
Yet even after more than thirty years of experience, street crossings at traffic signals remain the most challenging daily task I face in independent travel. There are no signals with audible or tactile signal indicators in my immediate area, and without these aids it is very difficult to determine when to cross using traditional mobility methods (primarily listening for the presence and direction of parallel traffic). On weekends there is often not enough traffic to get an unambiguous cue to make a safe crossing. During the week there is a large amount of turning traffic and a many busses throughout the area, all of which obscure the parallel traffic sounds. The result is that I often have to wait through several cycles of a signal to get a clear indicator of when to cross. This can nearly double my travel time in many instances.
While I may live in a particularly difficult urban environment for street crossings, my experience is that a majority of crossings have either too much traffic or not enough to give a reliable indication of when the visual signal on the desired crossing is green. Audible and tactile signal indicators get blind pedestrians one step closer to the freedom of movement that sighted pedestrians enjoy. The decibel and ambient noise regulations in 1106.2.3 would guarantee that signal indicators are unobtrusive to anyone who does not need or wish to use them.
Many thanks to the Access Board for its work on these Guidelines.
Sincerely,
Patrick J. Burke
Charlie Krajicek, P.E., October 24, 2002
City of Omaha
Public Works Department
This letter is in regard to the proposal to require traffic signals at the pedestrian crossings in roundabouts.
The City of Omaha is against this proposal to signalize the pedestrian crossings in roundabouts. This would defeat the whole purpose of a roundabout. Also, it would be very difficult to signalize it in such a way as to prevent traffic from exiting a roundabout and if traffic was forced to stay in the roundabout, it could cause a capacity problem.
Before a roundabout is constructed, factors such as the number of pedestrians crossing and the age/type of pedestrian at that particular intersection needs to be part of the overall decision to design a roundabout. In the City of Omaha, roundabouts are not used at all locations. They are used more as a traffic calming devise on low volume roads in residential subdivisions. Signalizing these types of intersections would not make any sense.
Also, it would be against the current Uniform Manual on Traffic Control Devices that states that a traffic signal and a stop sign/yield sign cannot be installed at the same intersection.
If you would like to discuss this further, I can be reached at [...].
Sincerely,
Charlie Krajicek, P.E.
Traffic Engineer
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
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.
Edmund Waddell, August 14, 2002
Roundabouts have been shown to reduce intersection injury crashes by 76% compared to signals, and to reduce fatalities by 90% (Retting et al, 2001). Results of these American studies, published by the Insurance Institute for Highway Safety, and by the American Journal of Public Health, are identical to findings from decades of overseas research. Put another way, comparable crossroad intersections have FOUR TIMES AS MANY INJURIES - including severe brain and spinal cord injuries - and about TEN TIMES AS MANY FATALITIES as a roundabout. Where roundabouts have replaced signals, repeated studies have shown they reduce pedestrian accidents by 30-50% (Lalani 1975, Daley 1981, O'Brien 1985).
In lay terms, roundabouts can keep people out of hospitals, wheelchairs, and graveyards, and that's a common reason they're built.
Unfortunately, these safety facts were not emphasized in Dr. Richard Long's report to the Access Board: a report which was used to develop the Access Board's current design proposals. The proposed new unfunded federal mandate would require complex signals and barrier systems at every roundabout crosswalk, regardless of how easily the crosswalk operates or whether a blind person ever uses it. At $100,000 or more per intersection, that's an expensive proposal, and since it has serious ramifications on public safety, it bears close examination.
Like more than 90% of US crosswalks, most roundabout crosswalks are not signalized. Because a pedestrian refuge is provided mid-crossing (shortening the crossing distance), and because vehicles operate at unusually low speeds (typically 15-20 MPH), the overwhelming majority of roundabout crosswalks are extremely easy to use, and like the vast majority of all crosswalks in the US, they simply don't need signals. In such locations, even if signals were provided, pedestrians wouldn't use them.
Traffic engineers have known for decades that, if unwarranted and infrequently used, signals can confuse drivers, become ineffective, and INCREASE accidents, causing more injuries to pedestrians and vehicle occupants alike. That's bad for public safety, but too few lay people understand it. People tend to think that signals always improve safety, but signals can increase speeding, distract drivers' eyes away from traffic and pedestrians, and create a false sense of security for pedestrians. Signals do not put a concrete wall between vehicles and pedestrians: pedestrians are struck at traffic signals with sickening regularity.
In locations where pedestrian and traffic volumes warrant them, crosswalks should have signals, and many roundabouts in the United Kingdom and Europe have pedestrian signals. They're common in London, Birmingham, and other cities. Examples of appropriate locations for signalized crosswalks include high-volume urban roundabout crosswalks, and locations where pedestrians (both blind and sighted) are most frequent. These factors are easily quantifiable. At rural intersections or low-volume locations, and locations where pedestrians are infrequent, signals are not used because they confuse drivers and unnecessarily increase highway construction, maintenance, and operating costs.
To assure that traffic signals are only installed where prudent, "warrants" have been developed for traffic signal installation in the United States. In the United Kingdom - a country with decades of experience with roundabouts in a wide variety of locations - the warrant for a signalized pedestrian crosswalk at a roundabout is where PV squared is greater than 1*10^8 (in words, where the number of pedestrians, times the number of vehicles per hour squared, exceeds a value of 100 million). Use of appropriate signal warrants assures that signals are provided only where needed, and not where they are unnecessary and potentially harmful.
The ramifications of an ill-considered intersection design policy can negatively impact the general public in unintended ways. For example, if ALL roundabout crosswalks were required to have signals, about $100,000 would be added to the cost of each roundabout, making them unnecessarily expensive in comparison to other intersection alternatives. As a result, far fewer roundabouts would be built, and many more of the common alternative - a signalized crossroad - would be built instead. As stated previously, studies show these have FOUR TIMES as many injuries, and TEN TIMES as many fatalities as a roundabout. The United States currently has about 15,000 deaths and about 1 million injuries at intersections every year, and installation of well-designed roundabouts might prevent countless human tragedies. Meanwhile, signals at unwarranted locations may help no one at all, and could in fact be harmful.
A single-user approach to traffic engineering would be a mistake. All users of an intersection must be taken into account, and the appropriate solution needs to be provided that will provide the greatest benefit to the public in each specific situation. No one wants more people injured or killed because we impose an ill-considered intersection design policy.
The Access Board proposal to require signals at all roundabout crosswalks needs to be reconsidered. Signals should be installed where they are warranted, and where there is no better alternative. In specific locations where users have special needs, the needs should be evaluated and provisions should be made in the design.
The opinions expressed above are those of the author, and do not represent an official policy statement of the State of Michigan or the Michigan Department of Transportation.
Edmund Waddell, Senior Transportation Planner
MDOT Project Planning Division
Lansing MI
Laurie Mehta, October 24, 2002
Dear Members of the Access Board,
I am a blind American and I support the recommendations of the PROWAC. I use audible signals
weekly, and would not be able to safely access the bus stop near my computer classes without them.
I have been blind for twenty years or so. I travel very well with either a long cane, or a guide dog.
When I had sight, I did a lot of pedestrian travel, and was immensely benefited by illuminated walk
signals. There are many pedestrian crossings, nowadays, that require more than just the traffic
signal to indicate safe crossing. As a blind taxpayer, I would like my tax dollars to be extended
toward providing this same benefit to me and others. Making walk signals audible will save lives, and each life saved is precious.
Since it is increasingly necessary to employ technology to keep traffic flowing, it is even more
necessary than ever to keep pedestrian signals effective. For those who cannot see, making signals
audible solves this problem. Such audible signals are especially necessary where traffic regulation is complex, at T-intersections, and at pedestrian crossings where traffic is stopped for pedestrians though there is no through cross-traffic.
I am aware that there are some who claim to speak for the blind, and oppose audible signals. I strongly
urge you to employ common-sense, and realize that these individuals can choose to ignore an audible
signal if they wish, but those of us whose lives and independence will be preserved by these signals cannot always avoid the dangerous crossings where audible signals could be placed. I know that audible signals are the singular factor enabling me to cross at certain places. I also know that there are places I must go to which I cannot reach independently, simply because a crossing signal is required but is not currently audible.
Please support the recommendations of the PROWAC, because they will make life more safe and independent for me and thousands of other people who cannot see.
Thank you for your consideration of this matter.
Sincerely,
Laurie Mehta
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
I support the safety signals for busy intersections as many of our intersections are wide with 3 or 4 traffic lanes with turning lanes right at the intersections. Signals telling the blind traveler when the light has changed and when it is safe to cross will prevent having to totally rely on traffic sounds alone and at these crossings it can be confusing at times. Audible traffic signals will minimize tragedy.
Tracy Son.
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
Deborah Wood, October 29, 2002
I am a member of The American Council of the Blind. I am writing to express my desire for the use of audible pedestrian traffic signals to become common practice. Traffic is becoming more and more complex, and many traffic signals are set up for the benefit of drivers rather than of pedestrians. This often means walk lights that are so short in duration that by the time a person who is blind realizes they have the light, the light has changed or is about to change, and they must wait for the next walk light. this situation can repeat itself again and again at such an intersection, which can make crossing such streets difficult, if not impossible. I was recently hit by a car while crossing the street to go home from work. Thankfully, I was not hurt. But I already felt unsafe crossing busy streets, and I now feel even more unsafe. Furthermore, I understand that several people who are blind have been killed while crossing such streets in the last several years. These fatalities might have been prevented had there been audible traffic signals where they crossed. Those who are sighted do not need to use the movement of the traffic to decide when it is safe to cross, they have a signal they can easily use to let them know when it's safe to cross. Pedestrians who are blind do not always travel with others; we often find ourselves traveling alone. Please do all that you can to give us the security and safety that is given to those who do not have visual impairments.
I am Deborah Wood. My address is 1[...].
Thank you for your consideration.
Deborah Wood.
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.
Bruce E. Friedman, P.E., PTOE and the NCUTCD Signals Technical Committee, October 23, 2002
The attached are the collective comments of the Signals Technical Committee of the National Committee on Uniform Traffic Control Devices regarding 36 CFR Parts 1190 and 1191 [Docket No. 02-1] as published in the Federal Register on 6/17/02.
Bruce E. Friedman, P.E., PTOE
Vice President
Kimley-Horn and Associates, Inc.
Signals Technical Committee
National Committee on Uniform Traffic Control Devices
Memo to: Mr. Scott Windley, U.S. Access Board
From: Signals Technical Committee, NCUTCD
Date: October 23, 2002
Re: Comments on the portions of the June 17, 2002 " Draft Guidelines for Accessible Public Rights-of-Way" that relate to traffic control signals
The Signals Technical Committee of the National Committee on Uniform Traffic Control Devices has reviewed the above draft guidelines and has the following comments about the portions pertaining to traffic control signals and related items. We compliment the Access Board on tackling a wide array of impediments to the mobility of all citizens, particularly those with disabilities. Our concerns and comments relate to what we believe is a prudent response to these needs.
Section 1105.3 Pedestrian Signal Phase Timing
This section states that all pedestrian phase timing shall be calculated using a maximum pedestrian walking speed of 3.0 feet
We object to this requirement being applied to "all" intersections. Traffic engineers have always used judgment to decide when and where to apply devices, based on an engineering study of need. Where needs are documented, there are many tools available to the traffic engineer to serve populations that require more time to cross the street. If intersections have pedestrian signals that operate pretimed, pushbuttons can be installed to assist those with a need for more time to complete their crossing. If persons who need more time frequent an actuated intersection, longer clearance times can be provided by supplemental actuation, such as pushing and holding the pushbutton to distinguish those calls from ones requiring only routine timing. To require longer pedestrian clearance timing at all traffic control signals (since all signals, even those without pedestrian signals, must provide adequate time for pedestrians to cross a street if pedestrian movements regularly occur) is a total over-reaction to a need that may exist at some locations, but certainly not at all locations. At most locations there will be a price to pay (in the form of a reduced level of service on the arterial, increased congestion, and increased accident rate) with no offsetting benefit.
Likewise, including the curb ramps in the calculation includes the addition of 3 seconds
To universally apply these new guidelines, at 100,000 or more signalized intersections, whether needed or not, is, in our opinion, like providing STOP signs or traffic control signals at all intersections regardless of the need.
It would be interesting to know if the 3.0 feet
Section 1105.6.2 Roundabouts - Signals
This section requires a pedestrian activated signal for each crosswalk at a roundabout. The narrative clearly points out that some believe roundabouts should not be used in areas of high pedestrian activity. This is an accurate conclusion, and these new devices have limited application in urban areas because of that. In areas of heavy pedestrian activity, all pedestrians, not just those with disabilities, will have trouble crossing at roundabouts, especially those with multiple-lane approaches. But to require traffic control signals at these crosswalks would be the same as requiring a pedestrian actuated traffic control signal at every marked crosswalk, regardless of the difficulty of crossing, regardless of the amount of pedestrian traffic, and without any study indicating that they would be justified.
Few roundabouts would ever be built under these circumstances if this requirement stands. To discourage the use of an effective tool that can be used to minimize delay and congestion at locations that would otherwise have a higher crash rate is contrary to all sound traffic engineering principles. European roundabouts built to the new modern standards, with funneling to slow traffic, do not add pedestrian signals automatically. If a roundabout is built in the U.S., and pedestrian traffic experiences difficulties, actuated pedestrian signalization may well be justified, but it should not be required on every roundabout where pedestrian traffic of all abilities may not have any problem. The STC is opposed to this recommendation. Roundabouts should only be signalized where a need is shown. Other solutions, such as wider splitter islands or in-roadway warning lights, might be more helpful than signalization for pedestrians. Language pointing out the incompatibility of roundabouts and heavy pedestrian activity should be included.
Section 1105.7 Turn Lanes at Intersections
This section requires a pedestrian actuated traffic signal at right or left turn slip lanes (bypasses) for the crosswalk across these lanes, including the channelizing island. This again requires all situations be treated the same, regardless of need, and is counter to all traffic engineering principles that required study and justification for the installation of traffic control devices. The fact that these signals would seldom be actuated and drivers would not expect a red light at these locations does not create a safe situation for such crosswalks. Furthermore, these channelized lanes are typically 15 feet
There is an implication in these guidelines that somehow traffic control signals will improve safety and accessibility for all when applied. Traffic engineers know this is not true, and that often the opposite occurs. Proliferation of devices breeds disrespect and wastes resources that could better be used to provide facilities where the need is greater. The STC is opposed to this recommendation, and believes that it is not well-founded.
Section 1106 (and 1102.8) Accessible Pedestrian Signal Systems
The STC has been working with representatives of the blind community and mobility education specialists, as well as representatives of the US Access Board, on this for more than three years. Some language has been put into the MUTCD already. We have standardized certain functions of Accessible Pedestrian Signals (APS) where we know or want to shape good practice. What we do not yet know is how to standardize on these devices. We are aware that the Access Board has pioneered work on a synthesis of current technology. We know some of the current technologies are not effective or lack in certain features that we believe to be important. For that reason the NCUTCD has requested funding for research to answer the questions of effectiveness. We do not want to see a proliferation of such devices until the research is completed. The Transportation Research Board, under its National Cooperative Highway Research Program (NCHRP) has launched a comprehensive study to obtain this information. We are probably about 24 months away from implementing these results. In addition, the National Institute of Health has research underway that will complement that of the NCHRP. Two members of the STC serve on the NCHRP panel to ensure that the research provides the traffic engineering profession with the information we need to adopt standards governing the installation and operation of APS. The two research teams have overlapping membership, so we are confident that we can continue to work with members of the Access Board and the blind community to improve mobility. We have to deal with issues of where and under what conditions they will be installed. Perhaps a way to start is to standardize all pedestrian pushbutton locations for all traffic signals, and our STC task force is working on that. But it is premature and not in the public interest to adopt the guidelines now until such research is completed. Even the standardization of the location of APS is not yet answered, and to spell out exact locations for them as proposed in Section 1106.2.1 is premature, and may not be the correct location for certain complex intersections. The above mentioned research is also addressing that.
Section 1106.3 Pedestrian Pushbuttons
This matter is still being studied by the STC and we request a delay until we can obtain input from the research mentioned above. We agree that there needs to be more standardization of pushbutton locations, recognizing that corner radius geometry sometimes limits the options, and we hope to have all typical conditions covered. Certainly, prescribing the location of pushbuttons needs to take into account the minimum clear width also required, and this may be more important than meeting the exact requirements of the dimensions shown for pushbutton locations. We also need to find out more about locator tones before we can standardize on their sound levels and aiming.
Conclusion
In conclusion, we believe the Access Board is making progress in implementing the requirements of ADA. We are willing to work with all the stakeholders to help, but are concerned with "across-the-board" requirements that are unrealistic to achieve. Specifically, a 3.0 feet
Another important consideration is that the Access Board needs to recognize that agencies responsible for the installation of traffic control devices have limited resources. The requirements for Accessible Pedestrian Signals at all locations should not be applied universally, at the time of reconstruction or alteration, without prioritizing needs. We believe this will not be in the best interests of the very community that is being served by these new guidelines. Traffic engineers can evaluate and prioritize needs, with help from the affected community, as now provided for in the MUTCD. These guidelines ought to support that direction. To do less would not serve the community with disabilities.
Thank you on behalf of all of the members of the STC for your consideration of our collective comments.
Sincerely,
Bruce E. Friedman, P.E., PTOE
Chairman
Signals Technical Committee of the NCUTCD
cc: STC members
Sent in via e-mail by:
Bruce E. Friedman, P.E., PTOE
Kimley-Horn and Associates, Inc.
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
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
Judy Prociuk, September 28, 2002
To Whom it may concern,
Even though I am not a U.S. citizen, I frequently visit the United States and therefore would like to submit my comments on accessible pedestrian signals. I am a blind person living in Canada and very much appreciate the audible component in traffic signals to indicate when the walk light is on and therefore safe to cross the street. I look upon this as an access to information issue. If there is a visual signal to alert sighted pedestrians when to walk or not walk, the same should be true for blind pedestrians. Blind pedestrians should not have to depend on listening for traffic noises or for someone to help them across the street if an accessible signal is not present. In my opinion accessible signals should be at every intersection where a visual signal is present. If blind pedestrians don't need to know when the signal is on, then sighted pedestrians should also be made to rely on other means to determine when to cross a street. I trust my comments will be given some consideration, thank you for your time and attention, respectfully,
Judy Prociuk
Saskatoon, Saskatchewan
Edgar Facemyer, October 23, 2002
Edgar Facemyer
As a citizen of the United States of America who happens to be visually impaired I am strongly in support of audible traffic signals being installed in heavily traveled intersections which are dangerous even for the sighted pedestrians. The first time I encountered an audible traffic signal was when I arrived on the campus of Indiana University of Pennsylvania in the fall of 1962. As I was learning my way around the campus and the town I kept hearing this bell ringing at regular intervals. When I reached the corner of seventh and Philadelphia streets I was amazed to discover that this bell rang when all traffic stopped which allowed me to cross with complete safety. During my four years there I depended on that signal which was wisely placed at the most dangerous intersection in down town Indiana. To my knowledge no one ever complained about the noise it produced. That was the only cross walk in town with such a signal. No other intersection in the business district really needed another signal. I would not be in favor of these signals at every intersection in even the largest communities. Technology has come a long way from the bell signal in Indiana. Several manufacturers can produce signals which operate only when a blind person or anyone else who wishes to use it activates it. Most emphasis has been placed on improving the flow of vehicular traffic and little on pedestrian safety. In years past blind persons could cross streets more safely because traffic lights cycled in a predictable manner. Now, however, with programmability signals can be set to operate in many different ways to accommodate traffic flow. These intersections are particularly hazardous to those who don't have the advantage of seeing the change of the light and who can use their sight to monitor the flow of traffic. I believe it is time for the PROWAC report to be given the consideration it deserves and that the right thing should be done. Other countries like Australia have already made significant progress in this area and we should follow their lead.
Patricia A Kepler, September 18, 2002
I read yesterday that members of the NFB are launching a letter writing campaign to attempt to persuade the access board against Audio pedestrian traffic devices. As a independent blind traveler, I wanted to take the opportunity to let my own feelings be heard.
I was successful in petitioning my state for an "APS for a crossing that I must cross daily. This is a busy mid block crossing, with no parallel traffic to help me out. When I first moved here it was a quiet street, and was not a concern to me, but as the area grew, so did the traffic and it was no longer a crossing that I felt I could safely cross.
I regularly give presentations on disabilities to my local schools. Many of the children I have spoken to have asked about the signal and several have told me that they feel safer crossing there now that it sends off an alert.
There are some that say there is no such thing as an intersection that people with good traffic skills can't cross. The fact is, that not all blind people are capable of developing those skills, just like not all drivers are equal. They are good enough to pass that test and get on the road, but there are certain things society has adopted, such as road signs, traffic lights and cross walks to give them visual reminders of what they should be doing. We would not ask our sighted children to cross a busy intersection that was not properly lighted for them. Why should a blind person be denied the audio cues to alert them to the changed light?
I do a lot of travel and have found that APS in unfamiliar areas have helped me orient myself to my new surroundings independently. Last summer I traveled to Oakland Ca, for the first time in many years. I was impressed by how accessible the city has become and easy it was for me accustom myself to my new surroundings and get to my many destinations with minimal assistance from strangers. The audio signals made it easy for me to determine traffic patterns and spared me the need to wait two or three light cycles to determine if there turning signals, separate lights for north and south traffic, or even if there was a signal at all.
Many blind individuals hesitate before traveling into an area they have not received formal orientation in. The increase of APS will give many people the courage to venture into unfamiliar territory.
Since I have no residual vision, I would appreciate it if the button locator feature would become a standard part of the APS. I have discovered that there is no rhyme or reason behind where the cross pole is place at an intersection; especially T intersections. A locator signal would allow me to confidentially approach the pole and activate the signal without the need to grope around or swing my cane in search of the pole.
The increased popularity of light rail systems nationwide has been a long time concern of mine. At least in Oregon the bells that ring as the gates go down turn off as soon as the gates are blocking traffic. These gates do not block pedestrians. So, we have quiet trains and no signal, either audio or tactile to let us know we should stop walking and wait for the train. In my area we often will have the east bound train go by and then the west bound train will come shortly after. A blind person could easily think it is safe to cross the tracks after hearing one train only to be struck by the second. An APS at these crossing could save many lives. Not just blind pedestrians, but anyone who is in a hurry and might not think to wait for a second train. Four years ago a sighted 14 year old boy was killed under these very circumstances not too far from my house.
Thank you for taking the time to read my Letter.
Sincerely,
Patricia A Kepler
Thomas Bickford, October 13, 2002
Following are my comments on the Draft Guidelines for Public Rights of Way, June 17, 2002Thomas BickfordDraft Guidelines for Accessible Public Rights of way June 17, 2002
1103.6 Surfaces
Even though recommendations are not yet formalized, the concerns of people in wheeled mobility aids should not be "Overtaken By Events." I refer to the desire of some blind people, to place truncated domes everywhere possible. I am blind, but I do not share that desire. The domes I have observed at transit and rail station platforms have more than ½-inch gaps, cause a bumpy ride under wheels, and are a hazard for people with medical conditions causing balance problems. My experience as an assistant to a wheelchair-bound person demonstrated to me that the wheels can not be guided through the gaps between domes. The bumps simply cannot be avoided. People will always be coming at angles and need to be dodging other pedestrians. The board should not rush ahead with "speed bumps for the blind" only to find that they should be filled in and smoothed out for the needs of other disability groups. We blind people need to learn to use our canes, our brains, and our dogs.
For the most part we blind people need to learn to take responsibility for ourselves to learn to live in the built environment. Sighted pedestrians and drivers learn to live in the built environment and do so.
Roundabouts 1105.6
"Because crossing at a roundabout requires a pedestrian to visually select a safe gap between cars that may not stop, accessibility has been problematic."
AS a blind person I do nothing "visually" and yet I travel successfully.
Drivers know the rules even though they may not follow or want to follow the rules that they should yield to pedestrians at roundabouts. A blind pedestrian must use senses other than sight to judge whether and when it is safe to cross a street or a roundabout. The sense of hearing and general familiarity with the way traffic moves are the first two senses to use. There are, of course, times and places where it is not ]]]]]]safe for any pedestrian which may be at roundabouts or other places. a roundabout is no place for a beginneror the faint of heart. Those people must find another way to go. There have been times and places that I had to do so myself. I, as an experienced traveler, tried the roundabout in Towson, Maryland, just as a test. I found it necessary to be careful and attentive, and I circled the whole thing safely. Sighted observers with me noticed a blind woman using a dog guide who was crossing by herself and on her own business. She managed the roundabout safely, too.
Turning Lanes at Intersections 1105.7
As a blind cane traveler of many years I have had to learn about turning lanes at intersections. Pedestrians must learn that vehicles can and do come from all directions, so the pedestrian must allow for the possibility. Careful attention simply must be maintained. Regular turning lanes are no great problem.
Slip lanes are another issue. It is my experience that drivers using slip lanes at intersections proceed at as high a speed as possible. The blind pedestrian who is crossing a slip lane to a traffic island is at greater danger than when crossing the main part of the intersection which is signalized. Slip lanes are usually installed at major intersections where traffic noise is sufficient to mask the sound of vehicles approaching from behind fast-moving perpendicular traffic and waiting parallel traffic. A steady stream of traffic would not be a problem. The problem comes from irregular and, therefore, unpredictable traffic. A demand light at a slip lane would be a definite safetyadvantage.
1106
As a blind pedestrian using along white caneIt has been my experience that pedestrian activated signals have been a help, not a hinderance, for crossing streets.
As a blind pedestrian I am in agreement with the Advisory Committee that installation of audible signals be limited to certain types of intersections. Locations where vehicles come at high speed, around curves, over hills, and, especially, at irregular intervals near the signalized intersection, are those where audible signals would be appropriate. There is only a small minority of intersections where these conditions are met. If a talking or vibrating signal box is properly placed, there is no need for it to have a constantly beeping locator tone to add to the noise polution of the neighborhood.
It is very easy to say "Just put them in everywhere." Such a commitment is hugely expensive and, as a practical matter, unnecessary. A flat rectangular intersection with moderate or even heavy traffic is the kind of location where audible signals are superfluous. Sighted as well as blind pedestrians can be frightened by heavy traffic, but the brain, the cane, and the dog guide are what will make the difference, not a machine that tells them when the light changes. Traffic, itself, tells what is necessary.
Location 1106.2.1
As a blind cane traveler I am opposed to constantly beeping traffic signals. The locator tone is a distraction from traffic sounds which are far more important as a crossing guide. With standardized locations, adjacent to the curb and the line of the crosswalk away from the intersection, there is no need for the noise pollution caused by constantly beeping locator tones. Allowing push buttons to be placed as much as 120 inches
Proper curbside and crosswalkside placement of signal boxes would also reduce the time needed for crossing the street since the walker could start five to ten feet closer to the crosswalk.
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
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
Susan Grossman, October 28, 2002
I am writing to express my support for the PROWAC's (Public Right of Way Advisory Committee) recommendations on accessible pedestrian signals and detectable warnings. I have visited cities in the United States that are in the vanguard of giving information available to sighted pedestrians to non-sighted pedestrians via audible signals. These signals are distinct and make it very easy for non-sighted pedestrians to cross intersections with much greater safety. I do not find these signals confusing and they do not interfer with traffic noise, which is used by some non-sighted pedestrians
use as an indicator. I also think that these signals are a much more effective means of determining whether it is safe to proceed than traffic noise. In very large and busy intersections it is extremely difficult to discern the difference in direction for traffice. Finally, with the recent introduction of electric and gas and electric cars which make little or noise, it is imperative that another means of notification other than traffic noise be instituted.
Thank you for taking my comments.
Susan Grossman
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
Frederick M Chambers, October 4, 2002
My name is Fred Chambers. I am blind, and I oppose most installations of audible crosswalk signals. The common cuckoo & chirp audible signals are not as useful as the newer tactile and audible signals. I favor the newer crossing indicators that provide accommodations for deaf and deaf-blind, as well as blind pedestrians. The system I'm most familiar with is made in Orange County. I think it's called the APS, for Accessible Pedestrian Signals. This system doesn't make distracting bird calls. It does identify the intersection verbally, and announces the walk signal with words. In addition to telling us where we are, and which directions are
walkable, it also has a vibrating arrow on the button. Lastly, if the pedestrian wants to mute it to listen to traffic sounds, they can do that too.
Most intersections don't need accommodations, but for those that do, I want the APS. Perhaps the bird call signals work well in dense urban, snowswept permafrost, scortching deserts and underwater environments, but the bird call signals are a very bad idea for San Diego County. We have well over 200 song bird species that live here at least part of the year. Several of them are parrots, mynas, mockingbirds, and others known to mimic birds and environmental sounds. I was almost hit near my home. A mockingbird in a tree near the intersection began making the east-west crossing sound. Several cars had stopped, so it seemed right. As I walked, a big white SUV came blazing through the intersection, huge tires howling, horn honking. It missed me by a few feet. After I was safely across, it was obvious what happened. A driver also got out of his car to explain from his angle. We could both hear the mockingbird mimicking the crossing signal. He asked, "What kind of a moron would install crossing indicators that sound like birds?"
We do not need the audible walk signals at every intersection. Usually, traffic provides plenty of audible indicators about which light is green. A few lonely stretches of road around here have the bird call crossing signals. One of them on Carlsbad Village Drive at Valley is where I was nearly hit.
The extra noise is distracting. That's the main reason why I want talking signals with a vibrating arrow at the few intersections that need anything.
Thanks for your attention,
Frederick M Chambers
Jane Elder, September 21, 2002
To whom it may concern:
I am writing to urge you to reconsider your proposal concerning accessible pedestrian signals and detectable warnings for the blind. I believe the guidelines set forth in this proposal are extreme and generally unnecessary for the majority of blind travelers. Many travelers, including myself, are able to navigate intersections safely by listening to the traffic patterns around us. Audible traffic signals should only be used in those rare cases when the traffic does not provide reliable auditory information that indicates when it is safe to walk. I further believe that fibrotactile warnings are not necessary at every intersection. I believe that they are applicable only at intersections where the slope is 1-15 (one inch of rise or fall for every 15 inches
I am writing to ask you to reconsider your proposal regarding audible traffic signals and vibrotactile warnings. The guidelines you have set forth would require the implementation of these signals at every intersection. This is an extreme measure that does not justify the high cost that will be involved. The Majority of blind pedestrians are competent travelers who are able to safely cross intersections using the traffic patterns as sound cues. The noise created by these signals would obscure the sounds of the traffic and might prove more dangerous to us. I also believe that the assertion that audible signals can be used as a directional aid is a false one. The eight beeping points that would be generated by APS at each intersection would only be confusing and hazardous to our traveling ability. Furthermore, there is no research currently in existence that demonstrates the effect of audible signals on blind pedestrians. Your guidelines would require consistent placement of these signals, which should make the locater tones unnecessary. These tones would also prove to be exceedingly noisy and unpleasant for many pedestrians, whether they are blind or sighted. For these reasons, I strongly urge you to abandon this proposal.
Sincerely,
Jane Elder
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
To whom it may concern:
I am writing to ask you to reconsider passing a rule which would place accessible pedestrian signals at every lighted intersection in the country. The cost of such an operation is not only unnecessary, but also demands an exorbitant sum of money.
To date, there has been no research on accessible pedestrian signals which states their benefits. However, many of the negative consequences which will result from mass installation of these signals can be drawn from simple inference.
Accessible pedestrian signals are often equipped with a beeping locator tone so that the blind can find them with greater ease. However, the constant beeping of four separate signals on four separate corners of an intersection can be confusing to a traveler. Furthermore, the repeated tones produced by these devices often serve as a nuisance and an annoyance to the sighted public.
When a blind person crosses the street, he or she must listen to traffic patterns not only to determine when it is safe to cross, but also to determine of vehicles are turning in front of him or her. The chirps and tones produced by accessible pedestrian signals can often occlude the sounds of traffic, especially when large structures in the immediate area amplify the sound by means of echoes.
The truncated domes which are proposed to be placed on every corner in America will not always prove useful. In Nebraska, where I am from, the ground is frequently covered by snow and ice in Winter. When this occurs, the tactile warnings will be absolutely useless.
Again, I urge you to consider the factors which surround this situation, and I strongly urge you to withdraw this upcoming ruling. The blind do not need accessible pedestrian signals; they simply need training.
Cordially Yours,
Ryan Strunk
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
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
David Mostello, October 7, 2002
National Federal of the Blind of New Jersey
Re: Comments regarding Regulations for Accessible Pedestrian Signals (Audible Pedestrian Signals)
Dear Access Board:
The Accessible Pedestrian Signal Regulations which are scheduled to be put in affect, are worthy of the following
Comments:
1) The National Federation of the Blind of New Jersey has been aware of the audible pedestrian signal for over thirteen years. These signals, though thought to assist the blind, are an obstruction to the alternative technique used by blind people in crossing streets.
When a blind person arrives at an intersection, he listens to the flow of traffic entering and leaving the intersection. When the traffic in front of him stops, and the traffic which is parallel to him starts, the blind person can be certain that the street in front of him is safe for him to cross.
The Accessible Pedestrian Signals pose additional safety issues. These include the increase in noise generated by each of the eight signals at a traditional four-way intersection. This increased noise detracts from the traditional sounds on which a blind person relies to cross a street.
This increased noise is also a distraction to residents and other persons who live / work nearby. In situations where Accessible Pedestrian Signals have been installed, workers can not open windows during warm days, and residents who live in the area where the signals are installed, complain about the noise during the night.
Installation of Accessible Pedestrian Signals forces a blind person to rely on that device in order to cross a street. What would happen if the Accessible Pedestrian Signal malfunctioned?, or if the blind person located to an area which was not equipped with Accessible Pedestrian Signals? Our methods of determining clear right-of-ways are less costly and more versatile.
The National Federation of the Blind does acknowledge that in certain situations, where a group of blind people agree, an Accessible Pedestrian Signal can be installed.
I also understand that the Access Board is accepting Comments regarding detectable warnings at intersections. The opinion of the NFBNJ is that these proposed regulations and warnings are unnecessary, because blind pedestrians have functioned without such warnings, by relying upon the sound of traffic, the slope of the ramps built for pedestrians in wheelchairs, and through the use of a guide dog or long white cane.
On a personal note, I traveled Washington, D.C. during the Summer of my Junior Year of college when I interned with the Federal Communications Commission. If I was unable to independently judge the traffic flow and time to cross, someone who was crossing the street with me indicated when to cross the street by crossing themselves.
The proposed rules and large support for installation of such devices are only the efforts of the manufacturer of the Accessible Pedestrian Signal and ill-informed professionals to undermine and increase the dependence of blind people on another unnecessary device.
If you have any questions, please contact James McCarthy, Assistant Director, Governmental Affairs at [....].
Sincerely,
David Mostello
Legislative Coordinator & Board Member
NFBNJ, Inc.
Nancy Johnson, September 9, 2002
I've been blind since birth. I'm an independent traveler in my community as well as an occasional traveler to other parts of the country. My most recent journeys away from home were trips from Topeka, Kansas to
Washington, D.C. and to Houston, Texas. Both of these major cities were totally unfamiliar to me.
I traveled to Washington with a visually impaired friend who has more vision than I and some experience with Washington's Subway system. I experienced subway travel for the first time. Without his assistance, I would have been lost. I cannot read signs, identify vehicles, or locate customer assistance areas. I would have been at the mercy of other travelers. That is as it has been throughout my life. When I go to unfamiliar places, I must ask whomever I can find for instructions. The information I receive is not always reliable.
In Houston, I was able to cross a busy intersection independently because an accessible pedestrian signal had been placed at the corner. This gave me the freedom to come and go between the convention hotel and the overflow hotel at will. Also available at the convention were talking signs that allowed people to locate the vendors' booths of their choice without having to ask each vendor whom they represented.
New traffic plans are making it more and more difficult to navigate busy areas as a pedestrian. The most recent development of which i'm aware are the round-abouts. Traffic travels round and round a circle and cars apparently enter and leave without making the traffic stop. These are extremely difficult for a blind pedestrian. My hearing is good, and I have the intelligence, training and skill to travel independently. Every day someone in our country loses their sight. They must give up their cars, and they are frightened of traveling in busy areas as pedestrians. Blind people can - have - been traveling by attending to the movement of traffic for generations. Unless we know where the pole is to press a pedestrian signal, we can't use it. There are more and more cars on the road, and traffic patterns are changing. The right
turn on red is a hazzard we have had to learn to manage.
The technology now exists to eliminate the dangers and fears involved with being a blind pedestrian. Individuals using wheel chairs have curb cuts to make crossings accessible to them. (These made life more difficult for blind pedestrians.) We need accessible pedestrian signals and detectable
warnings so we can safely cross busy intersections. Why should I be limited in where I can go as a pedestrian simply because I don't have the same safety information that everyone else has? Before the
technology existed, we had no choice. All intersections should be accessible to us. We should know where the edge of the street begins so we don't accidentally walk into traffic. And we should know where the signal post is and when the pedestrian signal is in our favor. We should be able to identify instantly when we are as near as is safe to a subway track. It would be extremely helpful to be able to locate ticket booths and customer service areas. Some have suggested braille signage. Not every blind
person knows braille. Those of us who do can't read the braille sign if we can't locate it.
Admittedly, this kind of accessibility is expensive. (Are curb cuts not expensive?) And can we put a dollar price on any life lost because the victim didn't have the necessary information to keep safe? Without
detectable warnings and accessible pedestrian signals, that's the direction we will go.
Thank you for considering my concerns.
Nancy Johnson
L. Dianne Ketts, COMS, CLVT, October 28, 2002
My name is L. Dianne Ketts. I hold a certification in Orientation & Mobility (O&M) and in Low Vision Therapy with the Academy for Certification of Vision Rehabilitation & Education Professionals. I serve as a member of the Environmental Access Committee of the Orientation and Mobility Division of AERBVI (the Association for Education and Rehabilitation of the Blind and Visually Impaired.) I am currently employed at CITE, Inc. in Orlando, Florida as the O&M and Low Vision Programs Coordinator. Please accept my 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 (1108 Detectable Warning Surfaces) 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.
Rationale: In my experience as an orientation and mobility instructor of visually impaired adults, even slopes greater than that of 1:15
Pedestrian Signal Phase Timing (1105.3)
I support The Board's draft guideline for Pedestrian Signal Phase Timing (1105.3) stating that "signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Rationale: Because I serve many senior individuals and persons with other mobility impairments in addition to their vision loss, I often consider the benefit that a longer walk and pedestrian clearance phase would offer. Many clients I serve are not able to complete the crossing of multiple lanes of traffic in the normally allotted time of 4.0 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.
Rationale: Detectable warnings located at a median or refuge island give the visually impaired or blind pedestrian critical information regarding their location in relation to the crossing. The presence of detectable warnings may inform the pedestrian that the island is a place of refuge where they could possibly stop and rest if it were necessary. This may be especially important for a pedestrian who moves more slowly or with more difficulty.
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.
Rationale: 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."
Rationale: 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.
Detectable Warning Surfaces (1108)
As I stated above, I support the inclusion of specifications for detectable warning surfaces.
Once again, thank you for the opportunity to comment.
L. Dianne Ketts, COMS, CLVT
CITE, Inc.
Jacqueline A Hayes, October 28, 2002
To whom it may concern:
I believe that you should spend your money on other things besides automated traffic signals, and truncated domes. The automated traffic signals are more harmful then helpful to the blind community. The chirping and beeping signals can get very confusing to us because, we count on the sound of the traffic. When we are trying to count on the automated traffic signals it is frustrating because the signals going off at the same time really cause us to loose our sense of direction. The truncated domes are also harmful to us because, we use the curb to indicate where the street is . We do not need something else to prevent us from crossing streets independently.
Jacqueline A Hayes
Kristal Platt, M.S., October 27, 2002
Dear Members of the Access Board:
I was trained under sleep shades fifteen years ago to use a white cane. At that time, I would not have supported the idea of accessible pedestrian signals, but much has changed in the past fifteen years. Today it seems roads are much wider , traffic is much heavier, and automobiles are much quieter and faster than ever before. Today there is more ambient noise with construction (including road construction), airplanes, emergency vehicles, and other municipal vehicles making listening for traffic noises more difficult than in the past. Today there seems to be a general disregard for laws, including coming to a complete stop before turning right on a red light, and the fundamental law of stopping at a red light. Of course, accessible pedestrian signals will not protect all pedestrians from drivers who violate traffic laws, but it will help take some of the "guess work" out of a blind person's decisions about when and where to cross streets.
When I learned cane travel we were taught that if we were uncertain of when to cross an intersection, we should simply wait for another cycle of the light. This is no longer a realistic or safe strategy as today, many times the traffic cycle lengths and lane turn signals vary depending upon traffic volume, time of day, etc. Again, ambient noises may interfere with the ability to cross for multiple walk cycles.
I consider myself to be a proficient traveler using buses, cabs, and private automobiles; still my feet are my primary mode of transportation. I do not feel I can walk as safely today. Perhaps fifteen years ago were the "Good Old Days" or maybe the "Dark Ages"; in either case, things have changed and unless we can adapt and change to manage the differences in the environment, the potential alternatives are literally risk-taking behaviors. Therefore I support the recommendations made by the Public Right of Way Advisory Committee to the U.S. Access Board regarding accessible pedestrian signals and detectable warnings.
Kristal Platt, M.S.
Michael D. Barber, October 20, 2002
I wish to express my opposition to audible pedestrian warnings and detectable warnings (truncated domes) at street crossings. I object for the following reasons: 1. While I believe there may be a few of the newer type intersections (such as roundabouts and some five-way intersections) which may necessitate some sort of audible crossing signals, I don't believe every
intersection necessitates them. And I definitely do not approve of the
continuous, obnoxious signals which annoy neighbors and impede safe crossing of intersections because it's difficult to hear the traffic patterns when these signals are emitting their churps and other noises.
I have traveled with the long white cane for over 40 years and have successfully crossed many hundreds of major and not so major intersections in many different cities, all without audible signals to assist me. As I indicated above, some of the more modern intersections may require some sort of audible signals, such as an audible voice indicating when it's okay to cross. But even though these signals may be used, one still must depend on the traffic pattern to be sure. For instance, just because the light turns green in hyour favor, it doesn't mean you don't look carefully before you cross to be sure someone isn't running a light. The same is true with a blind person. We're taught to listen carefully to traffic patterns so we can cross successfully. 2. I do not support the use of truncated domes at crosswalks where the gradient doesn't meet certain standards. In those cases, I suggest that the gradients of those crosswalks be changed so that there is no doubt that you are coming to an intersection.
Thank you.
Sincerely,
Michael D. Barber
Nancy Oltman, September 21, 2002
To whom it may concern:
I am writing to ask you to reconsider your proposal regarding audible traffic signals and vibrotactile warnings. The guidelines you have set forth would require the implementation of these signals at every intersection. This is an extreme measure that does not justify the high cost that will be involved. The Majority of blind pedestrians are competent travelers who are able to safely cross intersections using the traffic patterns as sound cues. The noise created by these signals would obscure the sounds of the traffic and might prove more dangerous to us. I also believe that the assertion that audible signals can be used as a directional aid is a false one. The eight beeping points that would be generated by APS at each intersection would only be confusing and hazardous to our traveling ability. Furthermore, there is no research currently in existence that demonstrates the effect of audible signals on blind pedestrians. Your guidelines would require consistent placement of these signals, which should make the locater tones unnecessary. These tones would also prove to be exceedingly noisy and unpleasant for many pedestrians, whether they are blind or sighted. For these reasons, I strongly urge you to abandon this proposal.
Sincerely,
Nancy Oltman
Denise Mackenstadt, October 27, 2002
I am an educator of blind children. I am also a student of Orientation and
Mobility. I do not agree with the proposals for audible traffic signals or
with the detectable warnings as proposed by the board. In my experience of
some 30 years I have found that without the clear indication of auditory input
from the traffic flow the blind pedestrian has difficulty knowing when it is
safe to cross an intersection. It is naive to think that just because a person
knows when the walk signal has turned on that it is safe to cross. I have a
five year old grandson. I and his mother have taught him that he must stop,
look and listen at all times even if the signal is green and it indicates a
walk signal. When additional sounds are introduced into the environment the
ability to stop and listen is hampered for the blind person. This makes for a
more unsafe environment for crossing the intersection. The walk sign gives a
false sense of security to the sighted person who must look and observe the
traffic flow before crossing. This is no different for the blind person.
However, if you take away the feature of being able to listen in an effective
manner then we are making the crossing more unsafe. I am amazed at the
inability of sensible individuals to understand this basic concept. If the
time comes that the board can guarantee that every driver will obay traffic
signals and drive in a safe legal manner at all times then maybe pedestrians
can only depend on the walk signal.
Peter D. Callahan, Esq., October 21, 2002
I am writing to you as a blind pedestrian in the city of Boston. I live in the Beacon Hill area of Boston, Massachusetts, and travel to work every day in the Financial District, approximately 1.25 miles away. I want to let you know that audible traffic signals are an extremely helpful tool in my traveling around the city. There is such a signal which alerts me when to cross Tremont Street on my way to work. Tremont Street is a very busy road which I must cross in order to get to work. The signal was previously not active, which made crossing the busy street quite a chore, and extremely dangerous.
I understand that the National Federation of the Blind has opposed the use of such helpful tools. I cannot understand their position, and am adamantly opposed to their stance. Please mark me down as a vehement supporter of Audible crossing signals, and other aids that assist blind pedestrians travel as safely as possible. My information is as follows:
Peter D. Callahan, Esq.
Charles T. (Tom) Stevens, October 15, 2002
SUBJECT: Audible Traffic Signals
It is proposed that audible traffic signals be installed at many traffic lights in the United States. The presumed reason is for the safety of blind pedestrians.
It is a curiosity: how many blind pedestrians have been killed in traffic in this nation in the last TEN years?
What is the comparison of that with sighted persons killed while crossing busy streets by blind or indifferent drivers? I am asking as Tom Stevens, 1203 S
This proposal is one of the most impractical proposals I have ever heard. It presupposes that blind pedestrians are unsafe travelers and also presumes that audible traffic signals will add a great amount of safety to their passage across those busy intersections.
I know that a blind person was killed in Richmond, VA while trying to cross a six-lane and extremely busy street. I also know that three sighted pedestrians were killed at the very same intersection within a few day of the other death. The reason for the deaths can be attributed to the fact that they tried to cross all six lanes at one time? Audible traffic signals will not atone for poor judgment in these instances.
BUT STOP. How many millions of dollars will be spent on a non-existent problem?
One of the tasks of the National Architectural and Transportation Barriers Board is to RESEARCH and quantify a problem FIRST and to not let pity, sympathy and custodialism rule.
By the way, I oppose these signals. I have traveled for more then thirty years with a cane and have been more endangered by bikes than by cars. Besides, I am not nearly as endangered by traffic as I am from distractions, which these signals will present. These signals not only will cost hugely, be worthless or dangerous in practical application, but will also distract from the alertness to traffic and safety of crossing.
YOUR CONSIDERATION OF THESE FACTS GREATLY APPRECIATED.
Sincerely,
Tom Stevens
The subject of this email is detestable to me, Tom Stevens, [ ...] It is my understanding that the Access Board is ready to require installation of these "devices" at all intersections in the United States where a crosswalk or sidewalk meets a street. This decision will cost tax payers hundreds of millions of dollars and is absolutely unnecessary.
I am a blind person who has traveled for many years with cane. I have encountered a few detectable warnings and have NEVER found them to be helpful. In fact, they are especially dangerous in wet or cold weather because they are slick. I have never had problems crossing intersections in cities like Washington, D.C., Denver, Atlanta, Columbia, MO and in innumerable others.
Please delete these unnecessary and patronizing warning devices.
Destene Noller, October 14, 2002
I am writing to express my fervent support of accessible audible pedestrian signals and detectable warnings! Many years ago when most signals were simple two-way signals these things may not have been necessary, but now, in the fast paced world in which we live, where almost any major intersection is extremely complex with many lanes to cross and turners to be aware of; it would seem to me that making traffic signals accessible to all people is of utmost importance! We are not asking for anything more than what sighted people already have available to them all the time. I am horrified to think that there are those who would have you believe that to have the very same information that is already available to sighted people somehow compromises our dignity! I am totally blind, a very good and efficient traveler, and am looking forward with great anticipation to a day when I will not have to be surprised to find audible signals in the places where I travel. Audible and accessible pedestrian signals will become more and more necessary to the safety of all pedestrians as the amount of vehicle traffic continues to spiral higher and higher!
Thank you so much for taking the time to consider my comments!
Very Sincerely Yours,
Destene Noller
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.
Daniel Tonge, October 21, 2002
I am a totally blind person, 51 years old. I have been an independent traveler for 22 years, and intersection signals have changed tremendously over my traveling years. One of the basic tenants of blind gravel is listening for the traffic, in order to know when it is safe to cross the street. Of course, this relies upon the premise that motorists are obeying the signals. There are a growing number of intersections which allow turning traffic at the same time pedestrians can walk. This makes it practically impossible to determine the status of the signal by simply listening to the traffic. Accessible pedestrian signals (not on every corner) are necessary to allow us as blind people to have direct input (as do sighted persons). We also need to know if and where there are push buttons to control the walk signal. The buttons are not uniformly located a certain distance from the crosswalk, so those intersections need to have beeps or some other method to allow us to know that there is a button and to know where it is.
Thank you for taking the time to read this note. Please vote to approve the recommends in the PROWAC Report.
Dan
Lloyd Rasmussen, October 14, 2002
I am filing my comments with regard to the Draft Guidelines for Accessible Public Rights of Way of June 17, 2002.
I am a member of the National Federation of the Blind, and support most of the recommendations contained in these guidelines. I am an electronics engineer, and have traveled in many places in the United States, using a long white cane, for forty years. This travel has included fair weather as well as foul, broken-down sidewalks, intermittent sidewalks, multi-lane street crossings, non-controlled street crossings, and much more. In 1992 I was one of the instigators of an NFB resolution that expressed some flexibility regarding the need for audible pedestrian signals. In 2001 I had the privilege of serving on a panel of the Maryland State Highway Administration which developed a set of warrants for the installation of "accessible" pedestrian signals.
I support the construction of more and better sidewalks, and a greatly increased understanding of the needs of pedestrians (particularly those who cannot drive) when vehicle ways and mass transit are being planned, re-purposed, reassessed and constructed.
I would not like to see these guidelines increase the cost of pedestrian accommodations so greatly that pedestrian access projects are not carried out or are postponed due to a lack of funds. I have the feeling that, even though thousands of hours have gone into the process of writing these guidelines, there are still too many proposed requirements that are "nice to have's" without properly delineating the "must-have's" of pedestrian access.
Blended transitions, perpendicular and parallel curb ramps: I am concerned that people are going to make blended transitions between sidewalks and streets the norm. Where is water supposed to drain?
Vehicles can tolerate more water on their paths than pedestrians can. I support the deprecation of "split the difference" curb ramps which dump pedestrians into the intersection instead of into the crosswalk.
If a blended transition is built, and detectable warnings are placed around the corner, in front of both crosswalks, how are blind pedestrians expected to know the direction of these crosswalks. This would seem to be problematic at intersections with little traffic, where the intersection is offset or not at right angles. Remember that most intersections will not have pedestrian signals of any kind installed, due to the lack of traffic.
When a parallel curb ramp is built, dividing a sidewalk into a portion sloping downward toward street level and a part which is not, what sort of "barrier is contemplated between the two adjacent sidewalk segments? A raised row of bricks? A guard-rail? I can't really picture this.
"Accessible" Pedestrian Signals: I have major reservations regarding the usefulness, safety, and consistent application of these devices.
I support the NFB's position on APS's whole-heartedly. But many NFB statements have mistakenly said that a pedestrian signal "informs a pedestrian when it is safe to cross." It does no such thing. It only informs pedestrians that they have an enhanced right of way for a specific period of time, which may or may not be noticed by drivers. Blind people must be enabled to engage in "defensive walking" as much as drivers are encouraged to drive defensively. In developing these standards, we must not forget the phenomenon that people (pedestrians and drivers) can only pay attention to a small number of stimuli at any particular moment. The unexpected event is usually the most dangerous one. I would hypothesize that a tactile stimulus does not compete for attention among audible stimuli as strongly as an audible stimulus does. Knowing when the pedestrian "start walking" interval occurs is important and useful. Knowing what vehicles around you are doing, and walking in the proper direction, is critical.
Many of the comments you are receiving on the guidelines are from people who have never experienced what is being proposed. You see far too many references to "chirping birds" and other sounds which are not proposed. Nobody should be told that these signals are good or bad until they know how they are supposed to work, and they have tried them.
In my opinion, the studies which the Access Board has conducted have involved really small numbers of blind people, and in many cases the work was carried out under artificial conditions, or only in good weather. And in some studies, the opinions and performance of sighted orientation and mobility instructors are counted as just as important as those of the people who will use the equipment--blind people. In the Washington, DC area, as of this writing, I don't think there are ANY intersections containing the proposed types of APS's, whose crosswalks, curb ramps and other pedestrian features comply with the proposed guidelines. Why should anyone be expected to endorse a system when it stands on several unstable legs, and has not been tested as a whole? Why should the Access Board mandate the installation of APS when they are poorly understood by the Americans who need to build and use them? I support further research and limited installations, to address problems such as we identified in our Maryland Highway Administration warrants system. But I believe that mandating "accessible" pedestrian signals across the board, in all cases, is premature, expensive, foolish and dangerous.
Locator tones: These ought to be called "locator clicks" because they ought to be short enough not to have a well-defined pitch. If the locations of these new signals can become standardized, no tones should be necessary. A cane or guide dog can find APS pedestals, if they are in predictable locations. Even though the guideline and the studies state that the sound pressure level at a distance of three feet should be "plus 2 to plus 5 dB" above the ambient sound level, there is no mention of the time constant of the gain control circuit which maintains this level, and where the ambient noise level is measured in order to control the APS's audio output. The investigators have forgotten that these signals, especially the locator tones, could be set several dB below the noise level and still be heard, because the human ear and brain can detect weak signals having specific frequencies and amplitude profiles. If the levels were reduced 5 or more DB below what is proposed, and the time constant for gain control shortened, there would be less tendency to hear "ping-ponging" signals from several APS around one intersection. Researchers and blind people must also decide, once and for all, whether they expect to use these signals as beacons while out in the middle of the street, or not. The new signals seem to be designed to "launch" a person into the intersection at the designated time and in a specific direction, and not to provide a beacon as the pedestrian is approaching the opposite side of the street. That's how I think they should work, but I don't know whether that is the expectation of the people who want to use these signals. And I don't know whether enough research has been done to verify that this concept works well for intersections which are extremely wide and/or extremely complex.
I am not yet confident that traffic engineers and their contractors will be able to install and maintain APS devices. Will shortcuts be taken in the interest of not burying cable, such as wirelessly controlled signals which are occasionally mis-activated or blocked by radio interference? Signals whose timing has gotten out of sync with the visual signal timing, but an inspector didn't notice or didn't know how to properly check? Directional arrows not lined up with the crosswalk for which the device is signaling? Devices mounted to the existing pole for the pedestrian activation button, even though the existing pole is several feet away from the "starting line" which the pedestrian should be on? But speaking of starting lines, I'm happy that the guidelines posit a slower walking speed, and therefore a longer pedestrian clearance interval.
It is often asserted that traffic is becoming quieter, especially with the advent of electric cars and better mufflers. It is true that the difference in noise output at idle between the loudest and quietest vehicles is increasing. Many trucks and buses are getting louder without limit. In other locations, the noise of building ventilation systems can mask much of the traffic noise. This situation, particularly electric cars, deserves somewhat more study.
Clearly, electric cars will make tire noise while they are moving. I might support the concept that such cars be required to emit some noise while stopped and ready to accelerate or turn. In other words, rather than create more noise and put new pedestals on the sidewalks, it may make more sense to insure that motor vehicles are audible, and also that the greatest contributors to noise pollution be muffled.
Detectable Warnings: I think there may be some intersections and islands where truncated domes would be useful. But again I would rather see ramps and curved edges for walkways, which can provide as much information as the domes can. The installation of detectable warnings at all covered intersections seems wasteful and unnecessary, unless "flat" or "raised" intersections are to become the norm.
Thank you for your consideration of all of these comments. I hope that sanity will prevail when these guidelines become a proposed rule.
Sincerely,
Lloyd Rasmussen
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.
I'm writing to give my reasons for why I support audible pedestrian safety signals. First of all I am blind and a pedestrian. The traffic patterns are changing and becoming more complex. The environment is becoming noisier. I depend on hearing to cross streets. Having audible traffic signals would enable me and other individuals to cross streets easier and the environment would hopefully be safer. We blind folks are equal to sighted folks. There are traffic signals for people who can see, and since technology exists to make traffic signals audible, then those of us who are blind need to have them in order to have a safer environment and function as equals.
Phil Jones
Jenine Stanley, October 11, 2002
I am writing in support of the concept and implementation of both accessible pedestrian signals and detectable warnings. As a blind person who has traveled extensively around the United States, I value these features that provide me with the same access to information about my environment as printed signage and visual features do for sighted pedestrians.
I lost the majority of my sight at age 19 and underwent standard, state-funded rehabilitation where I had approximately 12 weeks of orientation and mobility training. During this time, I was taught how to incorporate accessible pedestrian signals into my travel skill set. This training in 1983 made use of rudimentary audible signals that often covered up sounds of turning traffic. My instructor was very quick to note that no one should rely solely on the sound of a buzzer or bell to know when it was safe to cross any street with such a signal. He trained all of his students, as did other orientation and mobility instructors in this facility, to listen to traffic flow before, during and after the audible signal to determine when it was safe to enter and complete a crossing. He also explained the value of knowing at which point in the signal, as indicated by the audible buzzer, it was safe for all pedestrians to cross.
My travel skills literally grew with the development of audible and tactile signal technology but at no time did they rely primarily on the presence of that technology for proper street crossing. That is, until recently.
At age 22 I trained with my first guide dog and have worked with 5 dogs over the subsequent years. The key to working successfully with a guide dog is being an active part of a team. My job in street crossings is to know when to command the animal into the street. Then we both must listen and the dog must actively watch traffic as we complete our crossing. For years, this was possible at most intersections without the aid of an accessible signal. Where such signals were present though, they aided me in more accurately kno wing when to command my dog into the street, thus giving us both more confidence about completing the crossing safely.
In the past 5 years, intersection design and street layout has changed to accommodate more and more cars. I have noticed just in my travel around Columbus, Ohio that the number of lanes and patterns of traffic are not as easy to read as in past years. Traffic management features such as wide, rounded curbs for turning lanes, round-abouts and "porkchop islands" have made the act of approaching a corner, lining up with parallel traffic and making a straight street crossing more and more difficult.
I think of myself as a good traveler. I am now totally blind and have traveled alone to Australia and throughout this country. I feel I have had appropriate training from rehabilitation professionals and have read about new traffic situations such as those mentioned above and about the rules of actuated intersections, "claiming the intersection" and other pedestrian issues. In other words, I am not in need of any training simply to use my environment. What I am in need of is information.
I need to know when I as the pedestrian have the "walk sign." I need to know where the actual pedestrian crosswalk is when not located at a 90-degree
It is crucial for people who work with guide dogs not only to understand and use the orientation and mobility cues already present, such as traffic sounds and contextual layout of outdoor spaces, train and subway stations, etc., but to have other information about how to navigate. The dog, contrary to popular fiction, does not do all of the work of getting the team from one place to another. The guide dog is analogous to a smart automobile in that I must steer it and get it moving in a certain direction, but it automatically avoids all of the potholes and other cars in its way without me having to direct it.
Due to the complex nature of traffic today, many dogs working in urban environments are "burning out" earlier and earlier. Why? Because their human partner has less and less information with which to support them when entering streets, causing the dog to make more decisions on its own. Over time, this vigilance to traffic and need to make quick decisions takes its toll on a dog.
We as guide dog handlers also can suffer serious lapses in confidence when constantly faced with traffic situations that we cannot interpret, such as the multi-phase intersection, rounded curbs, crossing halfway down a block to accommodate a round-about design, etc.
Rather than making us more independent, this frustration over lack of information about such streets and other areas tends to cause people not to travel for fear of finding themselves at a situation they cannot interpret safely. This fear leads to a dependence on paratransit and other services once thought not to be needed by blind people with functional travel skills.
I have had the honor and pleasure over the past ten years of interacting with hundreds of blind people around the United States, and corresponding via email with thousands more around the world. We all value our independence and inclusion in society. That independence and inclusion takes many forms. The one thing we cannot deny though is that the built environment is becoming far more complex than what most of us learned to handle in our initial orientation and mobility training. Blind children today have the advantage of being able to incorporate many new travel skills, including the appropriate use of accessible pedestrian signals and detectable warnings.
Over the same ten year period, I have also seen very poorly designed and implemented accessible pedestrian signals and detectable warnings, embodying all of the features their critics detest. Like poorly printed or contrasted signage for sighted people, poorly designed accessible signals that are too loud, easily confused with environmental sounds such as birds or not located in appropriate places for people to activate them and return to the beginning of the crosswalk to cross a street, are dangerous and detract from the area as a whole and its use by everyone, not just blind people.
When saying that I support the concepts of accessible pedestrian signals and detectable warnings, I mean that I support their appropriate implementation, with consideration to the surrounding area and use patterns, but not taking one individual's or organization's point of view as the sole arbiter of that community in their installation. No single organization can possibly represent all people with a given distinction. Making intersections and platforms safe for everyone, not just the prototypical blind person, elderly person or child, should be the goal of any civil engineer and city.
I end by relating 2 stories of the importance of accessible pedestrian signals and detectable warnings in my life.
My husband and I are both legally blind. We both work with guide dogs. We live in a standard, housing subdivision in a suburban area of Columbus, Ohio. Bordering our subdivision are 2 arterial roads that come together at a four-way intersection. This intersection has fairly rounded corners and carries a very high volume of traffic at peak periods. There are no sidewalks leading along these arterial roads or at the intersection.
Across the other three sides of this intersection, small businesses form the core of services we can readily reach on foot. These places include a pharmacy, veterinary clinic, dry cleaner and restaurant. When requesting accessible pedestrian signals for this very complex and often very busy intersection with actuated signals, several configurations of turning cycles and approximately 1.5 to 3 miles of non-stop roadway before reaching the intersection, we were told that only the leg we traveled most would or could be made accessible. This necessitates that we be particularly alert at reading traffic. This is not normally a problem but because we do not have reliable access to information about this intersection's changing walk cycle, we simply do not attempt to cross there during peak traffic times, thus limiting our access to those businesses.
The accessible signal at this intersection is a loud buzzer, nothing like the newer, more discrete signals. It is only activated when a pedestrian presses the button for crossing, something that luckily must not be done to actually give a walk sign, but is done as an afterthought by many people crossing here on foot.
In this neighborhood, no one walks outside of the well-kept sidewalks of the subdivisions. They rarely are seen on foot along the arterials. There is, however, a high population of school-aged children, grades K through 12. These children must cross at this and other intersections in the area. When observing who actually did press the button to get the accessible signal recently, we noticed that all of the children pressed the button. They had been taught to do so by their parents and teachers, we discovered, in part because the sound of the signal was thought to alert drivers to look for pedestrians and also that sound brought children who were not paying attention to visual signals back to the business of crossing the street.
These children do not need any special training at an organization to cross the street. They are able to do so more safely because of an accessible pedestrian signal, the same signal that makes it much safer for me to cross this intersection. Could I cross without the signal? Yes, but it is much more stressful.
Regarding detectable warnings, during training with my current guide dog in New York City, we worked in the subway system. On prior training trips to the subway, my past dogs had picked up on my fear of falling or misjudging the distance to the edge of the platform. Although we as teams are taught to walk with the dog between us and the edge of the platform, I often feared inadvertently pushing my dog off that edge into a sometimes 8-foot deep pit. This made me very reluctant to use the subway during business trips to New York and Washington DC. This angered me as I thought of myself as a confident traveler who knew, in general, the design of such places and who could, academically, handle them.
It was such a relief and pleasure to travel recently in the New York City and Washington DC subway systems with their detectable warning strips along the platforms. I no longer felt the stress of knowing exactly where that edge was. I could relax and my dog could relax and do its work. I observed other people walking along the platform, obviously not looking at their surroundings, being caught up short upon feeling the tactile warning. Several during my trips even exclaimed at being so close to the platform edge. I can only assume they were reading or otherwise looking at something other than their feet or the platform and would have fallen into the pit without this warning strip. These people had neither cane nor guide dog.
Properly installed and maintained accessible pedestrian signals and detectable warnings, used with common sense in design and placement blend easily into the environment and become second nature, features everyone looks for and uses, not something that separates blind people or distinguishes us in a negative way. Without these simple methods of gaining information about the environment, many blind people do not travel and are not as mobile as they could be, increasing the load on social service and government agencies. It's not about more training. It's about more information.
The old saying about giving a man a fish and him eating for a day applies here. I already know how to "fish." I just need a fishing pole.
Jenine Stanley
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
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.
Janet M. Barlow, COMS, October 25, 2002
Dear Members of the Access Board,
Thank you for your work on these guidelines. As an Orientation and Mobility Specialist for the past 30 years, I have spent many hours on the streets and sidewalks of my community, usually with a pedestrian who is blind or visually impaired. During that time, I've seen major changes in the traffic environment, including the advent of right turn on red, curb ramps, blended corners, left and right turn arrows, raised crossings, right turn slip lanes, and actuated traffic signals. None of those intersection features were much of an issue when I began teaching. They are common at intersections now.
I first became aware of actuated traffic signals in 1992 when I got a call from a former client. He said that he kept getting caught in the middle of the street when the light changed and requested that I meet him at the intersection. He was convinced that he was misjudging traffic and that his hearing had gotten worse (he had a hearing loss in addition to vision loss). After spending an hour at the intersection with him, I realized that his hearing wasn't worse and he wasn't misjudging the traffic. However, he was doing something wrong. He wasn't pushing the pushbutton that was located 25 feet
That student and that situation began my interaction with traffic engineers and audible traffic signals. I called the traffic engineer in charge of that intersection to find out what the signals were doing. He educated me about actuated signals and I educated him about pedestrians who are blind and travel skills they used. Working with my client, we developed a solution for that street crossing; it was an audible signal to tell my client when the walk phase began. It worked. He still needed to use the travel skills we'd worked on and listen to be certain that traffic on the arterial was stopping; he still needed his orientation skills to walk in a straight line across the street. However, he knew when the light changed and that he did have a predictable amount of time to cross the street. He could again cross the street comfortably, and ride the regular fixed route bus, which he preferred. And we both learned how actuated traffic signals worked.
My discussions with that traffic engineer led to a presentation at the conference of the Institute of Transportation Engineers and continued work with engineers on access issues. That involvement has continued as a member of the Institute of Transportation Engineers (ITE), a member of the executive committee of the Pedestrian and Bicycle Council of ITE, chair of the Environmental Access Committee of the Orientation and Mobility Division of the Association for Education and Rehabilitation of the Blind and Visually Impaired (AER), and as AER's representative on the PROWAAC committee.
The modifications required by these guidelines are now needed. I urge the Access Board to move forward quickly to implement the requirements for accessible pedestrian signals and detectable warnings in these guidelines.
Those who state that all we need is more training don't seem to fully understand the environment we're dealing with. All the training in the world will not provide the skills to cross at the correct time at many actuated intersections or to locate the street at a blended corner. Nor will it equalize the differences that are common among people, including people who are blind or visually impaired. Suggesting that more training will solve the problem and we won't need accessible pedestrian signals or detectable warnings is like suggesting that wheelchair users who can't jump curbs just need more training in how to jump curbs so we won't need to build curb ramps. There are some individuals who could do that all of the time, some who might be able to do that some of the time, but there are many who would be denied access by such a stance. I have the utmost faith and respect in the ability of blind pedestrians to travel independently and safely and I support that strongly. I want to be able to continue to encourage it.
The traffic engineering and transportation community needs clear directives from you about what is needed to make the streets and sidewalks accessible. There are individual engineers and planners who are aware and responsive to the needs of pedestrians with disabilities. However, there are many more who will do nothing more than what is required. Many transportation planning and engineering courses are just beginning to include discussion of the needs of pedestrians. The education of most of the practicing engineers did not include discussion of pedestrians, much less pedestrians with disabilities. While budget is always an issue for any public works department, we need to insist that the needs of pedestrians with disabilities are a higher priority. Right now, there seems to be plenty of money for expensive signs and lights for vehicular traffic and pretty business center redesigns and very little for those who are pedestrians. These priorities need to be reordered by guidelines that spell out what an accessible street crossing looks and sounds like and what an accessible sidewalk looks like.
You have many comments on this draft. You had a very diverse, talented, knowledgeable, and interested group on the PROWAAC committee. You had good guidance going into this phase. Please move quickly to get the NPRM out. These guidelines need to be out there and implemented. We can't afford to wait much longer.
Sincerely,
Janet M. Barlow, COMS
Certified Orientation and Mobility Specialist
Jay Grossman P.E., October 11, 2002
I am concerned about two of the proposed changes, first concerning crosswalks: Limiting the crosswalk cross slope to 2% at intersections, and hence the roadway's profile grade to that same level, will significantly increase the cost of infrastructure improvements. Even here in flat Indiana, it is not unusual to have profile grades over 2% through an intersection. I would suggest that 5% (1:20) is a better number, consistent with current maximum grades on major routes.
As pedestrian accessible routes at mid-block are apparently all right with a cross slope that matches the road profile grade, whatever it may be, perhaps a more tempered approach to cross slopes at intersections is appropriate.
The grading required to flatten out an intersection will be extensive as vertical curvature requirements for roads don't allow for abrupt changes. Using Indiana design standards, at a 35 mph design speed typical in urban areas, flattening a 5% slope out to 2% at an intersection will require reconstruction of 180 feet
My second concern is with roundabouts. First, the requirement for a barrier on the street side of the sidewalk seems unfounded. In lengthy reading on roundabouts in other countries, who have 30 or more years of experience using them, providing a physical barrier for detectability was never mentioned as having been a safety concern. As a detectable pattern at ground level is sufficient at a crosswalk or train station platform, why is the edge of a roundabout any more dangerous? Traffic in a roundabout generally circulates at 15 mph, much less than the 35-40 mph of traffic rushing for a green light at a signalized intersection.
If a pedestrian steps over a curb into a roundabout, there is a much better chance that motorists will have a chance to stop or swerve than when a pedestrian steps into a crosswalk at a signal just as the light changes and a motorist is speeding to make the light. Furthermore, the accident data I have seen has never shown any instances of accidents involving pedestrians inadvertently straying into the circulatory roadway. Is it prudent to protect against a type of accident that has never occurred?
Finally, the requirement for pedestrian activated signals at roundabout crossings also seems extreme. As stated before, traffic at roundabouts is going much slower than that at signals on a green phase, and the accident data reflect how these lower speeds affect safety. Watching a video of a roundabout at Michigan State University shows how, with 5000 pedestrian crossings a day, roundabout crosswalks are generally safer than those at signals. When a pedestrian steps into the crosswalk traffic has time, and does, slow to allow them to cross. Observing roundabouts in Colorado showed the same yielding to pedestrians in the crosswalks by traffic.
A colleague participated in a visual impairment understanding exercise at a roundabout in Wisconsin. Blindfolded and with a cane, after a couple of tries with a guide, he was able to learn to listen for traffic and safely cross the roundabout approaches without aid. If a person blindfolded for less than half an hour can learn to cross safely at roundabouts, is it unreasonable to think those with permanent disabilities can learn to do the same?
Thank you for the opportunity to comment,
Jay Grossman P.E.
I would like to comment on the proposed signalization rule for roundabouts (1105.6.2). I believe this rule is not sufficiently warranted and should be eliminated. Instead, proposed rule 1106 should be used to ensure that pedestrian signals, if otherwise provided, would be meet the needs of the disabled, and further research should be done to find other ways to improve roundabout safety for disabled pedestrians.
Proposed rule 1105.6.2, if enacted, may well end the use of roundabouts in the U.S. There is little reason to construct a traffic circle if you have to signalize anyway. I am not a professional roundabout advocate, but as a city planner with close to twenty years of working experience I know that there are important benefits to society that roundabouts can provide. Vehicles flow through roundabouts at a measured pace without idling at red lights. As the Board indicates, this reduces congestion, but it also reduces air pollution. Second, the high cost of traffic signal electricity and maintenance is eliminated. Third, roundabouts provide a center pubic space that can serve an aesthetic, historic, and/or civic function. Fourth, my understanding is that roundabouts can improve safety over traffic signals for certain types of traffic movements; certainly they calm traffic and reduce vehicle speeds.
I would note that properly designed roundabout crosswalks are no more inherently dangerous to pedestrians with disabilities than signalized intersections that allow right turns when left turns are also allowed from the other direction. The driver turning right may still be looking left to see if there is another vehicle with which to contend, and the right-turning driver thus may not be sufficiently aware of a pedestrian in the crosswalk of the street onto which s/he is turning. Nevertheless, completely shutting down a signalized intersection for pedestrian movements in many cases is seriously impractical. Therefore, the contention that roundabouts are more dangerous for disabled pedestrians is questionable.
Using the services of a traffic consultant, my community did install a roundabout at an intersection because it is an intersection with 5 legs and a traffic signal would not have made sense. We used the "Australian" treatment for the crosswalks which was to place them one car length behind each entrance to the roundabout so that pedestrians would be visible to drivers before the drivers got to the circle and started looking exclusively to the left for oncoming vehicles. The location of the roundabout is in a mixed-use area with a specific revitalization vision that includes being pedestrian friendly. There are several people who live in the neighborhood who use wheel chairs, and other disabled people also are frequently seen using the roundabout's crosswalks, including folks with vision impairment. There have been no pedestrian accidents in the four years the roundabout has been operating.
I feel proposed rule 1105.6 is very drastic and implore the Board to work with engineers and others in seeking refinements in roundabout designs that can allow this fledgling innovation to continue to be implemented and improved without the completely antithetical resort to signalization.
Sincerely,
Tex Haeuser, Planning Director
Kimberly Avila M.A., COMS, October 28, 2002
Dear Access Board,
As a visually impaired teacher for the vision impaired, my concerns for pedestrian safety extend beyond my own needs. I have happily served students who are blind for Fairfax County Public Schools in Virginia for a few years. Prior to this, I taught Orientation and Mobility in Colorado. It was during my time in Colorado that I began to appreciate audible pedestrian signals when one was installed a few blocks from my home at a difficult intersection. The nursing home next to the intersection asked for the audible signal so their residents could cross the street independently to get to a grocery store and other shopping. It was a blessing! Many of these people were losing some vision and just needed a little extra help to cross the street.
I am an excellent traveler, but do encounter situations where drivers making turns do not yield to the pedestrian, which they were not looking for. With the audible signal, drivers are alerted that a person with a vision impairment is crossing the street, which promotes safety.
The school system I work for serves over 250 students who are blind, all with differing abilities and travel skills. Although a small number of these students can cross the a standard street without a signal, many cannot. It is the majority I worry about when I hear that pedestrian signals are being debated. Some people who are blind say that these audible signals distort the sounds made by parallel traffic and inhibit one from crossing the street in a straight line. Although this may be true, I feel the signals are vital at street crossings where one cannot use parallel traffic as an indicator to cross the street.
Furthermore, many people who are blind are unable to cross the street with parallel traffic due to their own skill level. I think a compromise should be made. A push button should be placed at intersections where one is needed. If someone wants the signal, press the button, if they don't, than don't press the button!
Sincerely,
Kimberly Avila M.A., COMS
Teacher for the Vision Impaired
Fairfax County Public Schools
Karen S. Wilcox, October 23, 2002
In regards to the PROWAC recommendations,
I am a certified Orientation and Mobility Specialist in the state of Indiana. I strongly endorse the use of detectable warnings at all intersections to assist in the safety of travelers who are blind. In the past few years, curb cuts have become more smooth and rounded at many intersections making it very difficult for some travelers who are blind to identify where the sidewalk ends and the street begins creating safety issues. Dectectable warnings are invaluable to travelers who have difficulties in this area. Also, auditory pedestrian signals are important, especially at very difficult intersections. An example of these intersections include T intersections, 5-point intersections and round-abouts. In addition, cars are being made more efficiently every year causing quieter and quieter cars and traffic sounds. As this continues, auditory pedestrian signals will become especially important for travelers who are blind to determine the correct time to cross streets. There are many different types and styles of auditory pedestrian signals and new ones are being invented all the time to make the technology benfitial for everyone. It is important that the corrrect types of auditory pedestrian signals are used at specific intersections to help the population for which they are intended and not interfer with travelers who do not need the assistance of the signals.
If you have any questions, please feel free to call me at (317) 232-4748.
Sincerely,
Karen S. Wilcox, O&M Specialist
Barbara Johnson, September 27, 2002
I am a blind pedestrian, and I work as a specialist in blind rehabilitation. Please consider my comments.
You are considering the proposal to mark each curb to indicate where the street is. In many cases this is not necessary. People can detect sloping ground as they walk, as long as the slope is steep enough to decline at least an inch for every fifteen inches of curb run. Rather than requiring curb indicators on most intersections, do the following:
PLEASE require that curb ramps be aligned with crosswalks. Where I live, curbs are haphazardly constructed, with no relationship at all to the crosswalks. A blind pedestrian can cross outside the crosswalk without knowing it. I have. If curb ramps point in the direction of crosswalks, blind pedestrians would know exactly where the crosswalks are. They would also use the direction of the slope to confirm what their ears are telling them about the direction of traffic flow. Doing this one thing would contribute more to pedestrian safety than anything else you could do.
Concerning audible traffic signals: Two thirds of the legally blind people in this country are senior citizens, and most of them have hearing problems as well. They have to listen as closely to traffic patterns as their impaired ears will allow. Audible traffic signals would mask the sounds of traffic, making it doubly hard for hearing-impaired people to cross streets safely. In other words, a blind pedestrian could step into the path of oncoming traffic, because a noisy signal distorted the sound of the cars. People think that audible signals would help a blind person know which way to walk to reach the opposite side of the street. Having heard audible traffic signals echoing against buildings, I know from experience that they scramble a pedestrian's sense of direction. Instead of calling for audible traffic signals, do the following:
1. Leave busy intersections alone. The sounds of constantly flowing traffic are themselves the best guides possible.
2. Where one street is always busy and another is only intermittently busy, install vibrating signals. These would indicate a light change but would confuse no one.
3. PLEASE require that pedestrian signal buttons be placed in predictable locations NEAR the crosswalks. It can be disorienting to have to look ten feet away for a signal pole, then re-locate the curb and re-align oneself for crossing.
Thank you for considering these comments. I am appending my street address, in case you send a written response.
Barbara Johnson
Audra Kramer and Others, October 17, 2002
To whom it may concern:
I am writing to urge you to reconsider your proposal concerning accessible pedestrian signals and detectable warnings for the blind. I believe the guidelines set forth in this proposal are extreme and generally unnecessary for the majority of blind travelers. Many travelers, including myself, are able to navigate intersections safely by listening to the traffic patterns around us. Audible traffic signals should only be used in those rare cases when the traffic does not provide reliable auditory information that indicates when it is safe to walk. I further believe that vibrotactile warnings are not necessary at every intersection. I believe that they are applicable only at intersections where the slope is 1-15 (one inch of rise or fall for every 15 inches
Sincerely,
Audra Kramer
[Identical letter submitted by others; similar letter below submitted by additional commenters - Access Board]
To whom it may concern:
I am writing to ask you to reconsider your proposal regarding audible traffic signals and vibrotactile warnings. The guidelines you have set forth would require the implementation of these signals at every intersection. This is an extreme measure that does not justify the high cost that will be involved. The Majority of blind pedestrians are competent travelers who are able to safely cross intersections using the traffic patterns as sound cues. The noise created by these signals would obscure the sounds of the traffic and might prove more dangerous to us. I also believe that the assertion that audible signals can be used as a directional aid is a false one. The eight beeping points that would be generated by APS's at each intersection would only be confusing and hazardous to our traveling ability. Furthermore, there is no research currently in existence that demonstrates the effect of audible signals on blind pedestrians. Your guidelines would require consistent placement of these signals, which should make the locater tones unnecessary. These tones would also prove to be exceedingly noisy and unpleasant for many pedestrians, whether they are blind or sighted. For these reasons, I strongly urge you to abandon this proposal.
Sincerely,
[signature]
United States Architectural and Transportation Barriers Compliance Board:
I am writing this letter in opposition to the current proposal to mandate the placement of audible traffic signals at all intersections with a walk/don't walk signal. I also oppose the placement of detectable warnings at every street crossing without exception. I have worked professionally with blind people of all ages (birth-senior citizen) for nearly ten years now. For five of those years I taught travel (Orientation and Mobility) to blind adults and teenagers at the Colorado Center for the Blind. My personal experience as a blind person and my professional experience in working with clients who are blind lead me to the conclusion that in most cases audible traffic signals are unnecessary, and in some cases may even be more of a safety hazard to the pedestrian. Detectable warnings at street crossings are also unnecessary for most intersections, unless the downward slope of the curb, median or island is 1:15
A blind person relies on sound cues from the flow of parallel traffic and the idling of perpendicular traffic that has stopped in order to cross a street efficiently and safely. Audible traffic signals should not be installed except on the rare occasion when an intersection has signals, traffic patterns or a layout that makes it impossible for a blind person to use the traffic cues to tell when to cross a street and/or to stay within the designated crosswalk. A vibrotactile indicator should be used instead of an audible traffic signal when such cases arise. The sound emitted from audible traffic signals make it much more difficult for the blind person to monitor traffic patterns. The problem is intensified when you factor in noisy locater tones and add the quieter engines of newer cars to the mix. The addition of these audible traffic signals will only add to the confusion of the blind pedestrian, increasing the difficulty to successfully cross the street.
The masking of traffic cues is not the only problem associated with audible traffic signals. One past example of a travel lesson I taught with students illustrates just how problematic an audible traffic signal can be. While working with two students on crossing intersections in the city of Denver, we came to an audible signal (I believe the signal was at Broadway and Bates). Both students had been in the program for a couple of months, so they had the basic alternative skills of blindness to be able to use traffic to cross a street safely. In this case, the street we were crossing (Broadway) was much busier than the parallel street (Bates), so the students had to rely more heavily on the perpendicular, idling traffic to determine when to cross the intersection. The audible signal did work when the button was pushed, signaling the students and myself that it was time to cross. Unfortunately, the signal masked the sound of the idling traffic, making it extremely difficult to use the stopped traffic as an indicator that it is truly safe to cross the street. A crucial part of safely crossing an intersection for any pedestrian is being able to double-check that traffic has stopped before proceeding across the street. This safety measure was weakened for us as blind pedestrians because of the difficulty we had in hearing traffic cues, and this intersection did not even have a locater tone. The point that audible traffic signals can be confusing was driven home near the end of the lesson as we headed back to the Colorado Center for the Blind. The Center was located just North of Illiff on Broadway at that time. We had some time before class was finished, so I decided to work with the students on this intersection before returning to the Center. On the Northwest corner of Illiff and Broadway was a self-serve hand car wash, which was operated by paying change in order to activate a hose that was used for washing cars. As we stood at the corner listening for traffic cues to tell us when it was safe to cross, we heard a beeping sound that lets people know that the time the hose would squirt water was almost up. The sound that was emitted from this corner car wash was almost exactly the same sound that we had heard at Broadway and Bates earlier in the lesson, causing some confusion and difficulty when trying to use the traffic cues that would enable us to safely cross street. For my money, the safest way to cross almost all intersections is to use the proven method of listening for traffic cues.
The installation of audible traffic signals at the vast majority of lighted intersections and the placement of detectable warnings at most streets will not have a positive impact on the pedestrian population (disabled or otherwise), will not lower the incidence of driver error in pedestrian/motorist accidents and will not make the crossing of most intersections any safer for the blind pedestrian. Unfortunately, the proponents of audible traffic signals and detectable warnings have claimed that it is a safety issue for blind people to not have these audible signals and detectable warnings at intersections. The fact is that such devises will not lower the incidence of driver error in auto/pedestrian accidents, and will not provide blind people with the skills they need to cross intersections safely. The idea that an audible signal will improve safety is not only misleading, but it can provide the sighted public with a negative view of the abilities of blind people to safely travel using alternative techniques. These false perceptions of the abilities of blind people can have a lasting negative impact when blind people attempt to find jobs and participate as equal members in society. The best way to ensure the safety of blind people is to provide them with the skills of blindness needed to safely locate and cross intersections using environmental and traffic cues. Countless successful blind students, professionals and leaders throughout the United States (and the World) employ these techniques to safely travel in all types of conditions without assistance on daily basis.
I strongly urge contacting and working with the National Federation of the Blind when determining possible environmental changes or to learn about the abilities and needs of blind people. Please do not waste time and resources on ineffective and often hazardous audible traffic signals and unneeded detectable warnings. Thank you for taking the time to consider this document.
Dan Wenzel
Jeffrey Turner, October 22, 2002
I am writing to express my support for pedestrian signals and detectable warnings in our nation's infrastructure. Although it is most certainly impractical to provide signals at every crossing, there are definitely crossings where they are crucially important for the safety of blind and/or deaf/blind independent travelers. If you can think of intersections where you are particularly appreciative of the Walk Signal, you should be able to imagine what it would be like without that signal. Please do not be swayed by a vocal minority of blind people whose false sense of pride compells them to object to these signals for everybody. Just because they don't feel the need for the help doesn't mean it isn't crucial to others.
Cordially,
Jeffrey Turner
Craig L. Phillips, MS Ed., COMS, October 23, 2002
Please add my name to those that support your draft of regulations for the public rights of way, especially the installation of APS at all signals with WALK signals, consistent placement of pedheads, and pedestrian activated signal installations at roundabouts.
Intersections have changed from predictable and simple crossings to crossings that are complex and intricate with a variety of confounding factors. RTOR has increased the danger for blind travelers as well as children, the aged, and those individuals with physical disabilities that involve motor function. APS will foster equal access.
Blind individuals are at a disadvantage when they have to search for a pedestrian button every time they cross an unfamiliar street because there is no consistency in location. By setting standards of accessibility for location, the blind traveler can equally access the environment.
Roundabouts are cited for their dangers. Yes, they calm traffic, but they don't STOP it. Let's act to eliminate those dangers for all individuals. Traffic might move slower. Balanced with minimizing risk of injury for all, the result could be beneficial for all. Pedestrians need to be considered as well as vehicles.
Craig L. Phillips, MS Ed., COMS
Shawnee Mission School District
District Office Mohawk
James W. Sparks, P.E., August 19, 2002
Just a short note of concern to the very detailed proposed "accessibility requirements" being advertised in the Federal Register. Please see to it that these comments get considered prior to going forward with the proposal.
(1) Input regarding accessibility FROM the accessibility community is essential, and it is good that those efforts are underway.
(2) How those concerns are addressed is an engineering issue as well as an accessibility issue, and any final rules regarding attainment of the issues needs to be processed using the very same procedure all engineering features of that control the public rights of way. While I am sure each proposal is well intended, there are inadvertent SERIOUS consequences that can result from failure to benefit from the years of experience the National Committee on Uniform Traffic Control Devices offers. I can recall an accessibility proposal years ago that would have enlarged signalized intersections by 30% due to a proposal that would set the crosswalks way back from the intersecting streets. Doing so would have adversely affected safety for not only the disabled community but the entire public at large. Fortunately this got resolved.
(3) One current proposal falls victim to the myth that traffic signals are in some way safety devices. THEY ARE NOT. The collision rate at signals is double that of similar unsignalized intersections. Signals are essential (no choice) in some instances, but unless essential are bad medicine and counterproductive to traffic safety. The proposal to have to signalize crosswalks near roundabouts is unwise and counterproductive.
(4) Similarly, the requirement for signalization of right turn lanes is an emotional proposal rather than one conducive to safety of all concerned. To ignore that fact puts all users at risk.
(5) Requiring a specific walking speed other than what has been found to be a good compromise considering all aspects of making signals function safely, is WRONG. There is nothing wrong with making such a proposal, but the final decisions should be made by trained engineers familiar with the upsides and downsides of traffic signals.
Thank you for listening.
James W. Sparks, P.E.
October 22, 2002
Good morning again:
Below I have re-included my comments sent to you in August regarding the Access Board proposals. While I know they are offered up as well intended changes, it is clear that some carry with it some adverse unintended consequences for everybody (including the disabled).
When I sent this to you in August you asked for information as to name and address so I will provide it below again and then paste into this message some more specific comments on signal timing. Before the details begin, let me summarize by saying that the wider streets become, the signal engineer loses flexibility on being able to allocate the green time splits to the proper direction of flow. Also when longer clearance times are used (including when nobody is present to benefit from them) it too eats into the flexibility of allowing the signal to match the demands of users. The longer signal cycles become, the less synchronizable the signals get which in turn increases the crash potential for everybody including those with impairments.
No traffic engineer wants to slight the needs of the impaired in any way, but the traffic engineers are accountable to the public trust to provide as efficient of operation for everybody as they can. Doing so is not only important to safety, but other global goals as well (air quality, energy conservation etc.). What the engineers and Access Board folks need to do is to work together with a myriad of ideas that would help accomplish the goals of everybody. For example, fortunately and because people have common sense, older drivers choose to drive slower than others. The drivers are responsible and know they have slower reaction times, reduced vision, etc that they can cope just fine but must drive slightly slower to allow their reaction times and vision to "fit" the circumstances. This results in our senior citizens having even a better driving record (crashes per million vehicle miles) than do younger drivers. One area that traffic engineers and the Access Board need to work on is educating our mutual constituents that it is not just the clearance times at signals that provides for time to cross the street. In addition there is the WALK time and sometimes additionaly all-red time (not always). The current clearance time walking speeds used for signal timing are conservative now, but still there are folks we are mutually concerned with who cannot cross in that time. Both the Access Board and traffic engineers should be working together to get the word out to those that want more crossing time to wait and begin their crossing at the beginning of the WALK time rather than entering the street at or after the clearance time has begun. Doing so drops the effective clearance time to even a lower rate than proposed.
Below are additional more detailed comments on signal timing prepared by the Phoenix staff. These comments are submitte in my name:
James W. Sparks
Deputy Street Transportation Director
Phoenix Arizona
October 22, 2002
City of Phoenix official comments on the Notice of Availability of Draft Public Rights-of-way Accessibility Guidelines provided by the United States Access Board.
Guideline's impact on traffic signal operation:
Pedestrian Signal Phase Timing (1105.3)
Creating a standard pedestrian clearance rate of 3 feet
On a typical major intersection with a street width of 96 feet
If left turn arrows are added into our intersection with the 96' street width on all four approaches the timing would be as follows:
East/west left-turn arrows: 13 seconds
East/west through: 39 seconds
North/south left-turn arrows: 13 seconds
North/south through: 39 seconds
This gives us a minimum cycle length of 104 seconds
Perhaps a more flexible policy, like the Phoenix policy, that does not rely on a feet per second requirement, but instead uses a hands-on approach of meeting with citizens and determining what help (if any) they actually need, would be a more reasonable approach. Each situation for ADA can be different and we need to keep this in mind during the engineering process.
Accessible Pedestrian Signal Systems (1102.8, 1106)
Installing audible indicators at all signalized intersections can be confusing to pedestrians. Not all intersections have the same geometry and large-scale installations of such devices would be a detriment to the people they are trying to serve. Also, there would be no method to determine if people were using them in the proper manner. This could potentially put the untrained pedestrian at risk.
The City of Phoenix installs audible devices only upon request by visually impaired individuals. When a request is made, the need is confirmed by a local mobility trainer with confirmation that the individuals requesting the device have the proper mobility skills to utilize it. Then the on-site training is competed. This process for each location ensures success for all parties and has proven successful for many years. Blanket deployment of audible devices would not serve the visually impaired pedestrians and would be a waste of tax dollars.For these reasons Phoenix is strongly opposed to blanket deployment of such devices.
Directional Information and Signs (1106.4)
The City of Phoenix works closely with visual impaired people and mobility trainers to ensure pedestrians have the tools needed at the locations needed to maneuver throughout Phoenix. Phoenix has 922 signalized intersections equipped with over 7,000 signs giving pedestrians street-crossing guidance. Currently signs are standard and meet MUTCD guidelines. Requiring custom signs for each intersection seems like a proactive idea but is not practical. It would take an estimated five years and $1 million to complete such a project. Even if federal funding is provided the City of Phoenix does not recommend blanket deployment of such signs.
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
I am the traffic engineer for a city of 185,000 in
1103.3
The width of curbs should not be excluded from the 48 inch
1105.3
Reducing the assumed pedestrian crossing speed would have great societal costs in air pollution and safety because of unnecessary vehicle idling, and congestion related crashes.
1105.7 Signalization of turning lanes should not be mandated because of societal impacts on air pollution and safety.
1106 Accessible pedestrian signals should not be mandated.
1102.14 On Street disabled parking stalls should not be mandated.
Joe Genoves
City of Oxnard
Christine L. Boone, Esq., September 20, 2002
Please accept these comments in opposition to the Access Board's current proposal regarding audible traffic signals.
The Pennsylvania Bureau of Blindness & Visual Services, Office of Vocational Rehabilitation, Department of Labor & Industry will not take a position in favor of audible traffic signals, for the following reasons:
1. The signals, as proposed by the Access Board, constitute a violation of the Americans With Disabilities Act, as the law requires that an individual may accept or decline any offered accommodation (42 U.S.C. Sec. 12101 et seq.).
2. Audible Pedestrian Signals, as proposed by the Access Board constitute a clear and present danger to blind pedestrians as they mask and/or obscure the traffic sounds and other reliable sound cues which these individuals use in order to travel safely and efficiently through the built environment.
The proposed signals are apparently being recommended under the premise that down town intersections are too dangerous for blind pedestrians. In actuality, the signals make intersections which are otherwise safely negotiable by persons who are blind unsafe, and non-ADA-compliant. Further, municipalities may now be liable for injuries sustained by pedestrians, blind or sighted, while crossing intersections which are equipped with audible signals because the distraction created by the noise emitted from the signals may constitute a contributory factor in such injuries.
The proposed signals sound automatically, making it impossible for any pedestrian to "decline" to use them.
The technology exists to install pedestrian activated audible signals which would only sound if a traveler pressed a button other than the standard "walk" button. These devices would be ADA compliant, as they are a reasonable accommodation which can be accepted or declined by the traveler. They would also eliminate the problem of liability, as individuals would need to choose to use the signals, negating any contributory negligence argument that might attach fault to a municipality.
The audible pedestrian signal which can only be activated intentionally by an individual will enable properly trained persons who are blind and visually impaired to safely negotiate intersections using environmental sound cues which are proven to be safe, effective and reliable. These signals will also offer an alternative crossing cue to those pedestrians who are blind and visually impaired who are uncomfortable or untrained in crossing unmodified intersections.
Thank you for the opportunity to comment on the Access Board's proposal. I would be pleased to provide any additional information upon request.
Christine L. Boone, Esq., Director
Bureau of Blindness & Visual Services
Office of Vocational Rehabilitation
Department of Labor & Industry
Marjorie Miller, September 9, 2002
I hereby express my support of the PROWAC report. Detectable warning signs where vehicular traffic is a danger, and audible traffic signals are an integral part of ensuring that persons with visual impairments will be able to travel safely on pedestrian walkways.
As a totally blind person I have many times walked out into traffic because there was no discernible curb, and risked crossing busy intersections when I wasn't sure the "walk" signal was in my favor. Detectable warning signals and audible traffic signals would contribute greatly toward making my pedestrian travel, and those of my peers a safe and trouble-free endeavor.
Marjorie Miller
Tarno Coleman, P.E., October 28, 2002
From: Tarno Coleman, P.E.
Civil Engineering Associate
Marion County Department of Public Works
Marion County Department of Public Works strongly supports the comments and recommendations found in the document dated October 14, 2002 submitted by the American Association of State Highway and Transportation Officials. This document is attached as an appendix of our submittal. We have the following additional comments:
_____________________________________________
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.
Background
The following definition is found in 3.5 Definitions of the ADA Accessibility Guidelines (ADAAG): "Technically Infeasible. Means, with respect to an alteration of a building or a facility, that it has little likelihood of being accomplished because existing structural conditions would require removing or altering a load-bearing member which is an essential part of the structural frame; or because other existing physical or site constraints prohibit modification or addition of elements, spaces, or features which are in full and strict compliance with the minimum requirements for new construction and which are necessary to provide accessibility."
While this definition is adequate for buildings, it does not address the issues arising from problems associated with natural terrain and topography.
Recommendations
Expand the definition. "Technically Infeasible. Means, with respect to an alteration of a transportation facility, that it has little likelihood of being accomplished because existing vertical and horizontal limitations would require violation of existing standards relating to vertical and horizontal alignment; or because other existing physical or site constraints prohibit modification or addition of elements, spaces, or features which are in full and strict compliance with the minimum requirements for new construction and which are necessary to provide accessibility."
_____________________________________________
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.
Background
The wording of this section may imply that adjacent buildings or facilities must be brought up to the requirements for new construction. An existing private access to a building may not be in compliance and should not be brought into compliance at public expense.
Recommendation
Reword the section for clarification. "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 to or site arrival points for 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.
_____________________________________________
1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
Background
Requiring that an alternate circulation path is on the same side of the street creates logistical problems. Pedestrian routes are usually located between the right of way and the traffic lane. Construction access, or easements, is usually not available from the adjacent private property due to buildings, etc. This would require enough right of way space to move the pedestrian access to allow for 1) the new pedestrian access being constructed, 2) room to allow for required adjacent construction equipment access, 3) room to allow the temporary pedestrian access and 4) room for the displaced traffic travel lanes.
Recommendation
Reword the requirement to the following. 1111.3 Location. The alternate circulation path shall, where feasible as determined by an engineering study, parallel the disrupted pedestrian access route on the same side of the street.
_____________________________________________
1105.2 Crosswalks. Crosswalks shall comply with 1105.2.
...
1105.2.3 Running Slope. The running slope shall be 1:20
Background
This requirement is reasonable at intersections where the natural terrain can accommodate this transition. An exception needs to be provided where the natural terrain is so steep that changes in vertical alignment cannot be accommodated using existing highway design and construction standards.
Recommendation
Reword the requirement to the following.
1105.2.3 Running Slope. The running slope shall be 1:20
EXCEPTION: The grade of the pedestrian access route within a crosswalk shall not exceed the grade established for the adjacent roadway.
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
Background
Reading this section is confusing. Is the purpose to specify the length of cut-through medians and pedestrian refuge islands or to require all un-signalized pedestrian crossings to be provided with refuge islands? In areas with many un-signalized intersections, this would require an additional obstruction placed in the roadway with corresponding changes in horizontal alignment.
Recommendation
Delete the reference to un-signalized intersections. 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, where provided, shall be 72 inches
_____________________________________________
1105.5 Pedestrian Overpasses and Underpasses. Pedestrian overpasses and underpasses shall comply with 1105.5.
...
1105.5.3 Approach. Where the approach exceeds 1:20
Background
A pedestrian overpass is not defined. A highway grade separation structure with sidewalks could be considered a pedestrian overpass or underpass. These structures typically exceed a 60-inch ramped approach. Placing elevators in these circumstances would be extremely costly and unlikely to occur in most cases.
Recommendation
Change the section as follows. 1105.5.3 Approach. Where the approach exceeds 1:20
_____________________________________________
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.
Background
Many intersections are un-signalized. A motorist approaching such an intersection does not expect a signalized stop on an otherwise uncontrolled intersection.
Recommendation
Marion County concurs with AASHTO's recommendation of "reserving" Section 1105.7, "Turn Lanes at Intersections," until further research can be conducted.
_____________________________________________
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.
Background
There seems to be a lack of consensus among persons with visual disabilities as to the best method to accommodate their needs. These signal features require additional initial expense and maintenance. It would be very costly to retrofit existing signals. Experiments in various urban areas have met with much resistance from the disabled community.
Recommendation
Marion County recommends "reserving" Section 1106.2 "Pedestrian Signal Devices." until further research can be conducted and a consensus reached on the methodology to be used.
_____________________________________________
1108 Detectable Warning Surfaces
...
1108.1.1 Dome Size. Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches
Background
ADAAG states "3.1 Graphic Conventions. Graphic conventions are shown in Table 1. Dimensions that are not marked minimum or maximum are absolute, unless otherwise indicated in the text or captions. 3.2 Dimensional Tolerances. All dimensions are subject to conventional building industry tolerances for field conditions." The standard gives no tolerances for dimensions due to normal wear. It could be argued that any reduction in height of the truncated dome would put out of compliance for height requirements. "Conventional building industry tolerances" are of no help due to normal wear.
Recommendation
Modify this section as follows. 1108.1.1 Dome Size. Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches
Respectfully submitted
Tarno Coleman, PE
Seville Allen, September 17, 2002
I write to comment on the proposed audible traffic signals and detectable warnings:
The proposal to install audible traffic signals at all intersections is excessive and would cause more harm than good because: with such a stringent requirement the economic burden would be too high; each signal costs approximately $650 and thus four times that figure is $2600 (rounded) for each intersection; such then, would cause decision makers to replace traffic signals with stop signs leading to less safety for pedestrian travel whether by blind or sighted pedestrians.
The need for audible traffic signals needs to be determined by criteria regarding complexity of intersections and not by the presence of a controlled intersection as it appears in the current draft proposal. Criteria need to be developed to determine where traffic patterns are complex enough that an audio cue would signal the pedestrian that the walk light is on (notice only indicating that the light has changed, not determining when it is safe to cross); signals can only indicate status of control lights and not safety factors such as moving vehicles.
Such criteria need to be developed with the assistance of competent blind pedestrians who can assist the Board in identifying type of traffic patterns were the audible cue would be helpful such as intersections where traffic is constantly moving in more than one direction.
Criteria would eliminate installation of many audible signals thus keeping economics of using such devices within costs that local jurisdictions may consider and thus keeping controlled intersections which are most safe for pedestrian traffic since vehicles are required to remain stopped for a given period of time.
In terms of locator audio cues: These can be eliminated as push buttons can be located on the light signal pole located near the intersection. Adding additional noise is not desirable since there are already many noises to sort through while traveling depending on audio cues when visual cues are not available. We who are blind are most safe when we can distinguish between all the varying environmental cues and adding more makes discriminating needed sounds more difficult thus making travel less safe. We need to keep noise from beeping and buzzing at a minimum.
With regard to detectable warnings, these are only necessary where gradient is 15 degree
Sincerely,
Seville Allen
Anthony Todd, October 28, 2002
I will try to be brief.
* Widening crosswalk widths indiscriminately has a real cost. It is
unnecessary in many locations and the requirement should either be recommended or have criteria on the number of pedestrians using the crosswalk. The infrequent occurrence at most locations will probably not be improved by moving a white line over two feet.
* The cross slope requirement is not only very nearly impossible in
many locations in eastern Tennessee (and many other areas across the country), the cost to implement would be well in excess of the community's ability to fund. Johnson City allows subdivision streets to have a maximum grade of 14% and requires sidewalks. New subdivisions would either be virtually eliminated in hilly terrain or sidewalks that lead to street crossings would have to be prohibited in these locations; this seems to be moving backwards (not forward to better accessibility).
* Pedestrian timing is an important issue but a requirement of 3.0
feet per second be used in the calculations without regard to the anticipated users is inappropriate. It increases driver frustration, congestion, potential accidents and is unnecessary in many locations.
* It would seem that at least one study should be conducted before
setting the requirements for the maximum length of ramps for pedestrian overpasses and underpasses.
* A blanket requirement for pedestrian activated signals at roundabouts is more dangerous for the pedestrian and the driver. Infrequently used signals blend into the background and go unnoticed. A pedestrian anticipating a vehicle stopping that does not will be a victim of the requirement and will be the one suffering the consequences. Also for the same reason the driver that does notice the signal and stops will have a great probability of being hit from behind if the following vehicle does not notice that the signal has changed. The is a purpose behind the use of traffic signal warrants. Better guidance to appropriate crossing locations could be a real solution.
* What constitutes a barrier?
* Turn lane signals? See the comment on roundabouts.
* Briefly stated: There needs to be significant studies done on the effectiveness of accessible pedestrian signal systems before many cities spend millions of dollars.
* The location of pedestrian pushbuttons cannot always be positioned where it is desired. We have many locations where trucks make lazy turns where they can get by with it and frequently have knocked down pedestrian signal poles -- forcing us to move the pole (buildings prevent widening of some radii).
* Alternate circulation paths on the same side of the road are often impossible due to the location (sidewalk repair in downtown areas is a good example).
* Signal timing based on a 3 feet
* I fully support the resolution from the Tennessee Section Institute
of Transportation Engineers.
Thank you for your consideration.
Anthony Todd
Traffic Division
City of Johnson City
Suzanne Westhaver, October 24, 2002
I strongly support audible traffic signals in high traffic crossing areas or in areas where traffic may be difficult to judge due to right turns on red, to-intersections with left turn indicators or right turn indicators, and similar situations, but do not feel that all crossings should be mandated to have these audible signals. The signals should only be added in the above described scenarios, taking into account the volume of traffic, right-of-ways, and the flow of traffic. In addition, the signal should not be obnoxiously loud or interfere with the visually impaired person's ability to hear the traffic. A subtle tone should indicate when it is safe to cross and should only sound when the pedestrian presses for a walk signal. In addition, intersections with audible signals should be clearly marked on the button so that the blind pedestrian knows the audible signal is available.
In addition, the current system of off-setting wheelchair ramps from corner curbs is very effective. Markers should only be necessary in areas with a slope of less than 1/15 in
Sincerely yours,
Suzanne Westhaver
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
Jason Holloway, October 16, 2002
Dear Access board,
Hello! I am Jason Holloway. [ ... ] I am a member of the National Federation of the blind. I had he privilege of attending the access board hearings regarding audible traffic signals. I found the hearings in Portland very informative. I personally believe that there are some intersections that are tricky and audible signals that let the pedestrian know what direction they need to cross could be beneficial. However, to put audible traffic signals in every intersection is unnecessary. Most intersections are easy to cross and chirping sounds that do not give a clue to what direction to cross is useless.
I urge the board to recommend installing audible traffic signals in only the most difficult intersections. To put audible signals in every intersections would be expensive and unnecessary.
thank you,
Jason Holloway
Kathryn Woodford, October 26, 2002
I was alarmed to read of opinion that street crossing accessibility
improvements are not needed or wanted by the blind. I am blind and do not
share this feeling. Frankly, I wish there were more. I have one in my
travels here in Atlanta, and in great peril in all the other intersections
I use on a regular basis. It is VERY difficult for me to know when to cross
streets. The old fashioned way of setting the signals has changed. Now, to
improve trafic flow, there are a multitude of signal combinations and they
very from block to block. Since I cannot see the walk signals, I do not
know often if it is safe to cross.
Please put your efforts into helping to make these safer crossings
available everywhere. Our lives depend very much on what you do.
Thank you
Kathryn Woodford
Carolyn J. Brock, October 2, 2002
Dear Access Board members,
I urge you NOT to mandate the use of audible traffic signals and truncated domes. These devices serve no purpose for blind pedestrians in most situations, and their use should be implemented only when the necessary information cannot be obtained by other means. Most importantly, the cost of implementing such a mandate would be an outrageous waste of the taxpayers' money.
I moved here to Portland, Oregon just over a year ago. From Missoula, Montana. My experience with audible traffic signals had been on visits to other cities. I found the signals confusing and distracting; many were so noisy as to make it impossible to hear the traffic sounds well enough to cross the street safely while the signal was sounding. When I encountered the truncated domes, I had no idea what they were other than just one more obstacle cluttering up the sidewalks.
A couple of years ago one audible traffic signal was installed in Missoula, near the rehabilitation agency for the blind. It was at a busy intersection which my blind colleagues and I had never found difficult to navigate. We invited the city street department to send a representative to a meeting of the Montana Association for the Blind. When we explained that the noisy signal was of no help to us and was actually a dangerous distraction, the city engineer surprised us by saying that he understood exactly what we meant. He then told us the story of a town where the highway passed through the center of town but where there had never been painted crosswalks. The town installed the crosswalks at several intersections and put up crosswalk signs. They were shocked to find that in the first year there were MORE pedestrian accidents at these intersections than there had been before the crosswalks were painted. The reason was obvious: people felt a false sense of security in the crosswalks.
No one actually believes that a painted line on the pavement provides any real protection against tons of moving metal; the same can be said for audible traffic signals. But I am reminded of this story every time I hear a blind person with poor mobility skills say, "Oh, I feel so much safer when there is an audible signal." If September 11 has taught us one lesson, it should be this: just FEELING safe is of no value whatsoever!
When I arrived in Portland, I was appalled to find audible traffic signals all over the city, especially at intersections which are very busy and therefore easy to cross just by listening to the traffic. Most offensive was the intersection of S.E. 122nd Avenue and Division, where I have to change busses when I go to visit my mother. It is a very busy intersection, with heavy traffic in all four directions and a most predictable traffic pattern. But just as the light changed in my favor, the signal would emit a piercing "Screeeeeee," drowning out the sound of the traffic and making it especially hard to detect cars preparing to make a right turn on red--the most dangerous factor at such an intersection. My only option was to stay on the curb until the screeching stopped, thereby losing valuable crossing time. Recently lights at this intersection have been re-programmed and the traffic pattern changed. In addition, the audible signal has been turned down so low that it is almost impossible to hear at all. While that makes the crossing much safer for a blind pedestrian, it is still a waste of the city's money!
I discovered the most ridiculous example of an audible signal this past summer when I was leaving on a trip by plane early in the morning. Rather than drive me all the way to the airport, my husband took me to the Lloyd Center, not far from our house, to catch the first MAX (Portland's light rail train) of the morning at 4:15
Ironically, I have encountered a couple of intersections in the Portland area where an audible signal would be helpful. The most notable is in Vancouver, near the Fisher's Landing transit center where I take the bus to visit my two daughters. It is a pedestrian crossing across a busy road leading to a freeway ramp, and there is no cross traffic. I have seen other such intersections in Portland, and none of them have audible signals. The traffic engineers are using a very strange set of criteria in judging which intersections need audible signals and which ones do not!
Most disturbing is the publicity campaign launched by the companies which stand to make a great deal of money if these mandates are implemented. They sponsor tables at conventions of blind people and have convinced many rehabilitation professionals to advocate for them. Especially vulnerable to this pressure are newly blind people who do not yet know that they can learn the necessary skills to travel safely without such expensive devices. We all know that high-pressure advertising can convince us that we really need to be drinking soda pop instead of water, popping vitamin pills instead of eating fruits and vegetables, and playing video games instead of reading books. The same kind of advertising can convince unskilled blind people that audible traffic signals and truncated domes will solve their mobility problems.
I am not one of these citizens, so vocal in recent years, who want to cut taxes in whatever way possible. I am happy to pay my fair share, as I agree with Oliver Wendell Holmes that, "Taxes are the price we pay for a civilized society." I would eagerly pay higher taxes to make life better for all of us: better schools, better law enforcement, better roads, better health care, better mass transit, better access for all pedestrians. In particular, I would love to see better mobility training for all blind people so that everyone can travel confidently and safely. If the tax money were spent for this kind of training, audible traffic signals and truncated domes would be necessary in only a few situations. Let's put our efforts where they will do the most good for the most people.
I urge you to reject the proposed mandates.
Carolyn J. Brock
Tammi Swiantek, October 28, 2002
COMMON-SENSE SUGGESTIONS ON PEDESTRIAN ACCESS GUIDELINES
Introduction:
I am a totally blind traveler with good basic mobility skills. Though I cross streets almost every day, I have only had direct experience with a few APSs, and those, unfortunately, were the old-fashioned kind with the loud cucoo that seems to come from every direction at once. I look forward to the newer models. In considering the arguments I make below, please note that I am not an expert in any field related to traffic or pedestrian safety issues and that my knowledge of the relevant terminology may be incomplete, though I have read the guidelines and done some general research. Also, I am not affiliated with any blindness organization but have kept up-to-date on the recent debate through E-mail lists and various publications.
APSs:
By now, you are, no doubt, shaking your heads at the tremendous split within the blindness community about the use of APSs. If my understanding is correct, your guidelines would require their use only where pedestrians actually have "Walk" and "Don't Walk" signals. If that is true, then the argument made by some that traffic cues provide sufficient information is seriously in error, except in cases where the traveler is familiar with a particular intersection. Picture a blind man approaching an unfamiliar crossing. He stops at the curb and hears cars whizzing by in front of him. Then, suddenly, nothing for about a minute. The next thing he hears are two cars pausing beside him, then zipping around the corner. My point? As you probably know but may be questioning by now, we blind travelers do gather most of our crossing information via traffic patterns. However, this method is most useful where signals consist of simple green and red lights. When cars are moving in front of me, I know they have a green light, and, therefore, I must have a red light. Similarly, at stop signs, we can simply listen for the absence of traffic or for cars waiting near the intersection. "Walk" signals, however, produce a whole different kind of challenge. In downtown Pittsburgh, for instance, I may, within a few blocks, find several different types of signals, making it risky to trust my overloaded memory after a long day of work. One signal might behave much like the usual traffic light, thus allowing me to go with my parallel traffic. Another shows "Walk" when all trafic stops, making my usual crossing with the traffic a dangerous game of chicken against turning cars. Still another is patiently waiting for me to push a button I have forgotten is there. I just might have a long walk home from work!
Recommendation:
Remember how you yourselves cross the street -- stop, look, and listen. In other words, you use as many cues as you can to keep you out of harm's way. Thus, in the long run, combinations of vibrotactile and audible signal information would surely be most useful. Personally, I like the idea of talking signs, since this would eliminate distractions for those choosing not to use the APS and for the general public, while allowing the individual to have detailed, spoken and/or tactile information at the desired volume. Receivers could be made available at libraries, agencies for the blind, or certain government offices, perhaps for a nominal fee, with partial support coming from public sources. Whatever type of APS you choose, there will surely be some drawbacks. Please do not allow the shouting about the dangers of old-fashioned and, perhaps, distracting signals to persuade you that APSs should be abandoned altogether. This only means that, as is the case with all technology, research and improvements should be encouraged. Meanwhile, let's make the best APSs available today standard equipment at all those pedestrian signals that are puzzles to so many of us today. Sidewalk smoothness and detectable warnings: One way to provide guidelines leading to smoother sidewalks for people using wheelchairs might be to require that certain types of concrete or other smooth surfaces be used in any new construction. You might also take the preliminary step of disallowing certain surfaces, such as brick. As for detectable warnings, I think they are very helpful in all places where a sidewalk gently slopes into the street. Please remember that there are blind wheelchair users, some using guide dogs and, thus, having very little sense of the slope beneath them. Contrary to popular belief, those dogs don't automatically know where the street is or when to cross it. They simply try not to run in front of moving cars. In conclusion, I wish to thank you for your detailed consideration of how to make the pedestrian environment safer and more accessible for all pedestrians, including those of us with all types of disabilities. This is an incredibly complex task but one that I believe we can and must accomplish.
Kevin Kraly, September 18, 2002
My name is Kevin Kraly, and I am one of many blind pedestrians whose safety will be affected by your decision whether or not to encourage the installation of audible signals at intersections. I feel that these audible signals are very important to all blind pedestrians! Traffic patterns aren't always the same, and the lack of traffic is just as important. If there is no traffic at all, it is impossible to know whether the light is green or red. If an audible signal is present, it's much easier to determine when it's safe to cross, and the chances of Walking out into an intersection against the light are slim to none. There are also intersections with signals for left turn traffic which can sometimes be mistaken for a green light. This is another situation where an audible signal would be of great help to any blind pedestrian. Intersections involving more than two streets can present mass confusion and great danger to blind pedestrians also. We need all of the help that we can get! Without these devices, it would be impossible to navigate many intersections, much like it is when drivers have to go through a city where all of the traffic signals are broken. We, the blind pedestrians in America, are just asking for a signal of our own!
Kevin Kraly,
Hillsboro, Oregon
John N. LaPlante, P.E., P.T.O.E., October 14, 2002
Attached are my comments on the Draft Guidelines for Accessible Public Rights-of-Way. Overall, I think this is an excellent and long overdue document. However, I do have a few very specific comments and recommendations that I urge be given careful consideration.
Please contact me at this e-mail address or you can call me at 773-792-9000 if you have any difficulty in opening this document or if you have any questions. Thank you this opportunity to comment on this important and valuable document.
John N. LaPlante, P.E., P.T.O.E.
Chief Traffic Engineer
TY Lin International, Inc.
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.
Need clarification regarding how accessible facilities "connect" to existing construction. Does the "connection" refer only to the sidewalk, or does it include the pedestrian signals and/or other features?
Recommend clarification of the types pf treatments necessary when "connecting" with existing construction.
1102.5.1 Protrusion Limits.
Objects with leading edges more than 27 inches
Some safety features within the right-of-way, such as fire hydrants, may not adhere to the protrusion requirements
1102.5.2 Post-Mounted Objects.
Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
1.) The existing ADAAG (Section 307.3) allows a 12-inch maximum overhang of post-mounted objects into the circulation path; thus, the 4-inch requirement in the draft guidelines is a significant restriction. 2.) Some features required in other sections of the guidelines, such as the street name requirement on Accessible Pedestrian Signal poles, may not meet these protrusion requirements.
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.
Consideration needs to be given as to when and how this will be implemented. Bus route identification signing is normally done by transit agencies and is completely independent of any other roadway or sidewalk improvements at a given location or along a route.
Recommend that consideration be given as to how this can be implemented separate from a sidewalk or roadway improvement.
1102.7.2 Informational Signs and Warning Signs.
Informational signs and warning signs shall comply with 703.5.
Signs at signal pushbuttons should also include Braille messages. Should not this note also be included here?
Recommend the following change: Informational signs and warning signs shall comply with 703.5. Signs located at accessible pushbuttons shall comply with 703.2.
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.
Providing 20 feet
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.
Providing 20 feet
1103.3 Clear Width.
The minimum clear width of a pedestrian access route shall be 48 inches
I would prefer a desirable minimum clear width of 60 inches
Revise wording to say: The minimum clear width shall be 60 inches
1104.2.1.1 Running Slope.
The running slope shall be 1:48
In hilly terrain, due to the slope of the sidewalk and/or the roadway, it may not be possible to provide a perpendicular curb ramp with a running slope between 1V:48H and 1V:12H.
Recommend adding the following text to Section 1104.2.2.1: "EXCEPTION: A perpendicular curb ramp shall not be required to exceed 15 feet
1104.2.1.2 Cross Slope.
The cross slope shall be 1:48
Constructing maximum 1V:48H cross slopes on perpendicular curb ramps will be very costly in areas of hilly terrain.
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.
I disagree with the suggestion to permit the use of a 1:15
Recommend no change to this section..
1104.3.7 Clear Space.
Beyond the curb line, a clear space of 48 inches
1.) Is this clear space required for a parallel curb ramp or is it redundant? 2.) From where is 'beyond the curb line' measured? Front or back of curb or other? In addition, in which direction from the curb line is it measured for each type of ramp -- toward the street or toward the sidewalk?
1.) Recommend that this clear space "beyond the curb line" not be required for parallel curb ramps as it would be a duplication of the landing space. 2.) Recommend clarification of where to measure clear space from for perpendicular curb ramps (assumed to be face of curb).
1105.2.1 Width.
Marked crosswalks shall be 96 inches
Why not use 8 feet
Recommend the following change: Marked crosswalks shall be 6 feet
1105.2.2 Cross Slope.
The cross slope shall be 1:48
Including every intersection along a constant grade street would result in extremely unsafe vehicular movements where there is no signal or when a traffic signal is green. This will likely lead to cars going out of control, and an out of control car is a risk to everyone, especially pedestrians both in the street and on adjacent sidewalks. I am absolutely opposed to this suggestion!
Recommend dropping this provision.
1105.3 Pedestrian Signal Phase Timing.
All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
While I agree that 4.0 ft/sec is too fast a walking speed, I cannot agree with lowering the speed to 3.0 ft/sec. This will result in 25% added delay to any signalized intersection where pedestrian crossing time governs. This delay would also apply to pedestrians wishing to cross the street, leading to the likelihood of pedestrians disobeying the ped signal. I suggest as a compromise solution, requiring a minimum total ped crossing time (Walk and Flashing Don't Walk) be based on 3.0 ft/sec and the Flashing Don't Walk be based on 3.5 ft/sec.
In addition, including the length of the ramp in the crossing distance can increase the crossing distance by as much as 12 feet
Recommend the following change: All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
1105.5.3 Approach.
Where the approach exceeds 1:20
Given the high cost of installing and maintaining elevators, particularly in outdoor locations and often not near a likely power source, the 60-inch rise seems unworkable.
Recommend some further research as to a more workable rise differential or some more reasonable exception included in this section.
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.
Traffic signals at roundabouts would completely eliminate both the traffic flow and traffic safety benefits of roundabouts, thus effectively precluding their use in any urbanized areas. Since they usually eliminate so many vehicular crashes, eliminating roundabouts does not seem to be a viable solution. However, I recognize that roundabouts are a very real problem for the visually impaired, as well as other less mobile pedestrians. This is particularly true at multi-lane roundabouts. We quickly need further research on how to enforce vehicular yielding at pedestrian crosswalks.
Recommend the following change for the time being: 1105.6.2 Signing. "Yield to Pedestrians" signs and visible pavement markings shall be provided for each segment of the crosswalk, including the splitter island.
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.
Similar to the roundabout discussion above, there are many locations where signalizing a separate turn lane is neither feasible nor safe. However, there are probably too many free flow turn lanes in urban areas that could and should be signalized. This is currently the subject of a new NCHRP study (Project 3-72) and the signalization recommendation should be deferred until that study is complete.
Recommend the following change for the time being: Where pedestrian crosswalks are provided at right or left turn slip lanes a "Yield to Pedestrians" sign or a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
1106.2.1 Location.
Pedestrian signal devices shall be located 60 inches
1.) Space limitations may make it difficult to place separate signal components at the required spacing. 2.) Clarify what is meant by "pedestrian signal device" -- Is this just the push-button, or does it include other items such as the auditory tone, pole, walk/don't walk signs, etc.? 3.) Is "control face" a recognized term for pedestrian signals? It appears to refer to the "walk/don't walk" panel. This section could be reworded for clarity.
1.) Recommend developing illustrative standard drawings for intersections using required spacings to determine feasibility and reasonability of spacing. 2.) Recommend defining "pedestrian control device" or rewording first sentence. 3.) Recommend rewording second sentence to state: "The face of the pedestrian signal should face the crosswalk it serves."
1109.2 Parallel Parking Spaces.
An access aisle at least 60 inches
Bike lanes should not be considered travel lanes with regard to the restriction that "the access aisle shall not encroach on the vehicular travel lane". And the use of inches to define street space implies a level of accuracy that is neither needed nor practical to achieve.
Recommend the following change: An access aisle at least 5 feet
1109.3 Perpendicular or Angled Parking Spaces.
Where perpendicular or angled parking is provided, an access aisle 96 inches
It appears that these requirements apply to all parking spaces, instead of only to the accessible spaces.
Recommend rewording beginning of section to state, "Where accessible perpendicular or angled parking is provided,?"
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.
It is unclear how far back on the sidewalk from the accessible parking space this restriction applies, i.e., how far back is "adjacent to...the space"?
Recommend clarifying verbiage.