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
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
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
RoseAnn Faber, October 26, 2002
The purpose of this e-mail is to submit comments regarding proposed guidelines for the use of audible traffic signals and detectable warnings.
In most instances audible traffic signals are not needed.In fact they mayactually be hazardous.Audible traffic signals could produce a false sense of security for the blind pedestrian. The noise of such signals could interfere with the blind pedestrian's ability to hear traffic movement. The bottom line is to know what traffic is doing regardless of the status of the traffic light. Finally, if audible traffic signals were common place there is the potential that drivers would feel that they need to pay less attention to the presence of pedestrians.
Audible traffic signals should be considered for those intersections with complex layouts, complex signalization, or varied signalization for each lane. Vibrotactile indicators should be used in preference to audible signals in order to minimize noise distractions and better promote safety.
Locator tones should not be included in the final guidelines and may be subject to further research.
At most intersections the built environment provides enough accessible cues to determine the difference between the sidewalk and the street.
However, a slope of less than 1:15
warning.
Your consideration of my comments is appreciated.
RoseAnn Faber
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
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
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.
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
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.
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
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
Joe and Ginny Sorenson, October 22, 2002
We need to have audible traffic signals
Joe and Ginny Sorenson.
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
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
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
RaLynn Harris, October 18, 2002
To Whom It May Concern:
I am a legally blind college student. I cross many busy streets every day. Although I am fully capable of crossing these streets without audible traffic signals there are many advantages to having these signals present. Several of these signals were just put in by my campus. They have not only been able to improve my sense of safety but I have also heard other students comment about the convenience of the signals. I urge you to please understand that there are those out there who are afraid of change and would wish that these signals not be put out on the streets. But please hear me, many people will feel safer, lives can be saved, and the confidence in travel of not just a few but all blind and visually impaired people will be improved. No one is saying that by adding these signals that the way in which we learn to cross streets will be changed. These signals are just an added tool to improve our safety. No one will be hurt by adding these signals, but the contrary can not in good concience be said.
Sincerely,
RaLynn Harris
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
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
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
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
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
Vickie Burke, October 23, 2002
I would like to speak out in favor of audible traffic signals. I am a totally blind guide dog user. While I have had training in crossing streets by listening to the flow of traffic, I like the confirmation that the audible traffic signals give. I do not believe that these signals in any way demean me as a blind person because I am still having to use my skills to listen in case someone is running the light. I urge you to put the traffic signals in place.
Cordially,
Vickie Burke
Please do not discontinue any detectable traffic signals now in place. I am blind and know how important thoose signals are when needing to cross busy thoroughfares. Thank you
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
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
Anthony R. Candela, October 28, 2002
To Whom It May Concern:
I am writing to request full and due consideration be given to establishing
regulations and guidelines for audible pedestrian signals at unusual and
dangerous street intersections. This is not a black and white issue and
apparent divisions among the blindness community should not be allowed to
eliminate this issue from the landscape.
Audible pedestrian signals are a form of technology that is evolving. In
unusual or dangerous street intersections -- more numerous as modern
traffic control systems are being designed to move automobile traffic more
quickly -- additional help is needed if the non-visual person is to
navigate safely. Since artificial construction is often at the root of the
problem, artificial construction (e.g., easily visible and tactual
crosswalks, more elaborate and audible pedestrian signals, protective
barriers to shield pedestrians from vehicles, etc.) is required to
compensate for the added complexity.
Arguments in favor of and against audible pedestrian signals often overlook
the real problem -- appropriate and easily interpretable signals are
needed, inappropriate and ambiguous signals are harmful. Instead, the
argument becomes black and white. Regulators must not throw out the baby
with the bathwater. Please move forward to develop appropriate regulations
and guidelines. Don't let the 'with -em' or 'agin' 'em' style of argument
distract you from your duty.
Thank you.
Anthony R. Candela
National Program Associate
AFB West
Cheryl Fischer, October 16, 2002
Dear Access Board:
I am writing to say that, while there are intersections, especially those with actuated traffic signaling systems, where audible signaling devices are necessary for a blind person to gain the information they need to cross safely, these audible signals are not needed everywhere. I am blind and have worked with a community group in my neighborhood and with the City of Cleveland to promote audible signals being installed at two very treacherous intersections. We considered whether such devices were needed at other intersections, some of which are very busy ones, and determined that special signals were not required as the traffic patterns were predictable. I would hate to see money wasted by putting such signaling systems everywhere!
Cheryl Fischer
Pat Gormley, September 21, 2002
I have read a few of the comments regarding audible pedestrian signals andtruncated domes proposed for new construction. From my perspective, further research needs to be done to determine the effectiveness of audiblepedestrian signals. It is my further belief that these signals should onlybe employed at intersections where it's impossible for a blind person to determine from listening to traffic patterns whether it's safe to cross a particular intersection. I also feel the same way about truncated domes since their usefulness on train platforms and the increased costs of maintenance and upkeep are also a major concern. Truncated domes on train platform edges exposed to the elements such as ice and snow over time unbond and the residue including parts of the truncated dome edge from theplatform at Penn Station in Baltimore stayed on my boots one time all the way home from Baltimore to New Carrolton station and caused me to pay fora new carpet to be placed in the apartment I moved out of in 1992. In my estimation, more research involving persons affected by these devices withvarying skill levels needs to be undertaken.
September 23, 2002
My name is Patrick Gormley. I find that tuse and placement of audible traffic signals as currently proposed in the rights of ways guidelines is excessive. The need for audible signals as currently proposed needlessly drives the costs up for intersections. These signals should only be utilized in the most complex of intersections and only on two sides of a 4-sided intersection. Any noise that distracts a blind user from listening to traffic is not a lifesaver but could be life threatening. I have had experience with these signals to substantiate this claim. In this particular situation the audible signal masked the sound of a truck backing up and I narrowly avoided being hit by that vehicle. I also feel that truncated domes are only needed if the drop off is greater than 50 degrees
To Whom It May Concern:
I am totally blind, a Guide Dog user who has received training in how to travel safely within my environment. I support the installation of audible traffic signals wherever possible and ask you to support the installation and funding of such equipment.
In The American Council of the Blind's The Braille Forum, May 2002's article entitled "AFFILIATE NEWS" it states:
"Albany Becomes More Accessible a Step at a Time
"Another step toward improved pedestrian safety was achieved recently when the first in a series of audible traffic signals was installed, and turned on at the intersection of Washington Avenue and Hawk Street, near the Capitol Building in Albany, N.Y., one of Albany's busiest intersections. While there are a few widely scattered audible traffic signals on the outer edges of Albany, the intersection of Washington Avenue and Hawk Street is the first high-volume intersection to receive an audible traffic signal. Several additional key intersections are expected to receive accessible pedestrian signals in the near future.
"While the audible traffic signal project has been a very important endeavor of the Capital District Chapter of the American Council of the Blind of New York, the real winners are the members of the blind and visually impaired community, not merely any particular agency."
I have worked in this area of Albany for over ten years. Until the audible traffic signal was placed at this particular corner, I did not cross this intersection without assistance, since it is not one you dare cross at unless you know precisely when it begins or you will be caught out in the middle of the street in very heavy traffic.
Audible traffic signals let me know, just as the red lights and green lights let my sighted counterparts know, when it should be safe to cross. I am still responsible for making the decision whether to cross the street, just as I am now. The audible traffic signals just give me more help, more of an idea of my safety margins.
When considering supporting or funding audible traffic signals, please think of those of us who wish to use these signals as tools to keep ourselves and/or our service animals safe.
Thank you.
Tina Murphy
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
As a blind traveler, I am strongly opposed to the blanket installation of audible traffic signals, of whatever kind, on every corner where walk/don't walk traffic signals are present. The signals I have encountered up to this point, whether they beep, chirp or buzz, have not been helpful in determining the true traffic patterns. In fact, they have often distracted me, or masked the sounds of traffic moving near me, which is a much safer means of determining when to cross an intersection. Only occasionally have I encountered an intersection which is so wide or complicated that traffic patterns cannot be used as my guide; in these cases, I've often noticed that drivers are as confused as I am, or are over-eager to beat the light, so an audible traffic signal could give a false sense of security and mask the sound of on-coming traffic.
For those few complicated intersections, I would prefer a tactile signal, which would be pedestrian activated. This would assist deaf-blind travelers, as well, since they, rather than the blind, are at a disadvantage in most cases.
Too often, people believe that gadgets are the panacea for all ills that beset the blind. Rather it is the confidence resulting from proper training which is most needed. By adopting this blanket requirement, The Access Board will be doing a dis-service to the blind--allowing government officials to feel that gismos can solve all our problems, and giving them an excuse to fail to provide what we need most--sufficient, competent training to instill confidence in our own mobility skills.
Please modify any rule you adopt to only apply to complicated intersections where audible cues are not sufficient to provide complete information, and provide tactile rather than audible signals where some accommodation is needed.
Tami Jones
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
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
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
Steve Jacobson, October 28, 2002
By now, your office has received many letters on the subject of audible and tactile traffic
signals. As you know it is an emotional issue for each of us for widely divergent reasons. The
easiest thing to do emotionally would be to place audible and tactile traffic signals anywhere
there is a signal. However, I don't believe this will serve us as blind people in the long run
nor will it serve society at large. Doing this avoids some questions that need to be asked and
could, in actual fact, increase the likelihood of injury to blind persons. Please allow me to
briefly address these points.
While there is some agreement among blind people that there are now some intersections that are
very difficult to cross, there are many, many intersections that blind people have been
successfully crossing for years. Contrary to the position some have taken, such intersections
are not being crossed only by those with superior travel skills, but by a wide range of blind
people. Our ability to succeed is based upon our ability to find other ways of doing things
that others do with vision. Therefore, before taking a position that every signal must have a
tactile or audible add-on, we need to understand better who will benefit from such signals?
What about those blind persons who feel that they cannot safely cross a standard intersection
without signals. Do we put special signals in for those people or do we just write them off? I
don't believe we do either. Again, contrary to most of what I read, there is really not a good
understanding as to why some people have difficulty crossing certain kinds of intersections. In
some cases, difficulty hearing or a lack of the ability to recognize spacial relationships can
contribute to such a difficulty, but to what degree will an audible signal help them cross an
open area? I suspect that sometimes special signals will help and some times they won't.
However, I submit that nobody knows exactly how much. And there is a real down side of not
knowing which is my third and final point.
If this issue is not studied carefully, the likelihood of injury or even death could be
increased by audible or tactile traffic signals. Without good quality travel training and/or
without understanding the role played in ones ability to travel by other types of disabilities,
an audible or tactile signal is nothing more than a push off the curb when the light is green.
The signal doesn't know who is turning right on a red signal, who is approaching the red light
at too high a speed, who stopped beyond the crosswalk thereby blocking it, and more. In some
cases, special signals will provide the edge that some need, there is little doubt of that in
specific situations, but it is essential that some of the difficulties being encountered must be
sudied and overcome through training matching their specific disability. Part of our ability to
travel safely depends upon our ability to derive information about our environment. To send
people who cannot derive adequate information about their environment into a busy intersection
based solely on whether the light has turned green is irresponsible. Doing so will result in
injuries that would not otherwise occur because of the false sense of security that such signals
offer persons with inadequate travel training or with disabilities whose impact we do not fully
understand.
Therefore, I call upon you to avoid requiring audible and/or tactile traffic signals at every
corner having a signal. Further, do what you can to foster a true understanding of this problem
by recognizing that training techniques need to be explored for those feeling that crossing a
standard intersection is not possible or safe. Develop standards for the incorporation of of
audible or tactile signals so the installation of such signals is done so in a uniform manner
that will truly help people and not just make people feel better while possibly endangering
them.
Thank you for your time and attention.
Sincerely,
Steve Jacobson
To Whom it may concern,
I am writing in regards to Audio Signals. My name is Nancy Perry and I have RP and am Legally Blind. I currently have a guide dog. I wanted to have my voice heard in regards to the audio signals at intersections. I currently requested to have a couple audio signals put due to the dangers of the intersections in my neighborhood. O'Hara, guide dog and myself have had a few close calls. Due to the audio signals that were installed O'Hara and I are safer.
Thank you for your time.
Nancy Perry
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
Debra Chandler, October 22, 2002
Hi. I wish to express my support of the recommendations of the Prowac report. I am in favor of accessible traffic signals for blind people. Such signals can also benefit other groups such as the elderly. My name is Debra Chandler and my address [ ... ]
Steven C. Jenkins, September 17, 2002
Dear Board,
My name is Steve Jenkins, President of the Flatirons Chapter of the National Federation of the Blind (NFBC) which meets in Boulder, Colorado on the first Saturday of each month. We have had some discussions about the "Crosswalk Signals" and the rules that the Board is proposing. It appears from a users standpoint that the rules will disregard the wishes of the end users in spite of themselves. We have come to the conclusions that on occasions and only when requested should "Tactile Warnings" be installed. NEVER and under NO circumstances should "Audio Signals" be used and definitely not on "Every" corner where a Traffic light appears should a crosswalk light of any sort be placed. One of the problems several of our members and I myself am included in this is the more noise you add to a single area the more distorted the sound becomes. This in the long run becomes the hazard that you are trying to avoid. The other big problem seems that the people that are in charge of ordering the crosswalk signals and the people who are requesting the signals are not aware of the Tactile crosswalk signals. I would like to reiterate that as a chapter and as blind human beings who are quite capable of taking care of ourselves and our needs we do not want or need mandates in place requiring "Audio Crosswalk Signals". If you must put something in place please make it Tactile signals and only where requested.
Respectfully submitted,
Steven C. Jenkins, President
Flatirons Chapter of the NFBC
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
Daryl Swinson, October 28, 2002
Greetings to the members of the Access Board!
My name is Daryl Swinson and I would like to offer these comments, as a blind citizen and as a tax payer, on the proposed regulations regarding audible traffic signals and tactile warnings.
First, I live in Conway, Arkansas, a town of about 40,000, much of it suburban. Other than in the older downtown area, there is very little access to a sidewalk, which discourages a great deal of pedestrian traffic even where traffic signals exist. The use of audible signals which are not activated by a pedestrian would be wasteful of valuable civic funds. Such signals should only be used in areas where the traffic pattern is not easily distinguishable or where conditions are otherwise hazardous to a competently trained blind traveler. Additionally, such audible signals could best serve the blind as tactile directional indicators, leaving the sense of hearing free for more necessary uses.
Secondly, a proliferation of truncated domes to mark what are easily detectable transitions in pavement height would not only deter blind individuals from obtaining a broader mobility skillset, but cause a nuisance and possible hazard to the mobility impaired and sighted pedestrian.
I thank you for your consideration and hope you make a well informed and fiscally responsible decision on these matters.
Daryl Swinson
John A. Horst, October 23, 2002
It is our understanding that the Access Board is considering the need for audible pedestrian signals at busy intersections. Please be advised that I, as a legally blind person, find these audible signals very helpful. In downtown Harrisburg we have had these signals for several years. Many blind, disabled and older persons have expressed appreciation for them.
With the volumn of traffic increasing and traffic signals controlled electronically based on traffic flow, audible signals become more and more important for safe mobility for blind people. If sighted persons need traffic signals, stop and go signs etc., it naturally follows that blind people need signals that are audible.
These signals do not make blind people dependent. They enable them to accept employment and be active in social and community activities.
The Pennsylvania Council of the Blind is an organization of hundreds of blind and visually impaired people across Pennsylvania. We strongly support the PROWAC report.
Thank you for your attention to this email.
John A. Horst
Executive Director
Pennsylvania Council of the Blind
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
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.
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
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
Ramona Walhof, October 29, 2002
Audible traffic signals cost a lot of money. Eight signals would be necessary for a simple intersection. Detectible warnings also cost money. Some have estimated billions of dollars. Blind people do not believe this is a good use of money.
The intersection next to my office would need ten to fourteen signals, and this would make it more dangerous for the blind. The streets come from five directions, and there are at least five islands. There is no crosswalk on the north side of the intersection, but this would not be indicated by bird calls or beepers. There is a lot of turning traffic, and buzzers and beepers would make it harder to hear the turning traffic. The traffic provides the best information for blind people. The intersection next to my office is a difficult one, but blind people cross it when they need to.
I have recently spoken to several people who visited in Victoria, Canada. They found the ATS's there both unclear and troublesome because they interfere with normal traffic sounds. This is dangerous!
In Boise, Idaho there are currently 326 intersections with traffic signals. At the prices I have been quoted it would cost more than 10 million dollars to purchase ATS's for these signals. This may not include installation, maintenance, or detectible warnings.
According to a study done in 1991 by the Institute of Traffic Engineering, there are about 1.24 signaled intersections for every 1,000 of the population nationwide. I could find no newer statistics, but new signal lights are being installed as fast as the population increases. If you figure the U.S. population at 270 million people, this would mean there are more than 334,000 signaled crossings in the country. If you figure the cost of equipping each intersection at between $30,000 and $40,000, the price tag approaches 11 billion dollars for the country. That is between four and five times as much as an entire year's federal appropriation for rehabilitation. This includes rehabilitation funds not just for blind people but for all people with disabilities. Such an expenditure would be far out of proportion to any value it could have.
Not long ago I was in San Diego walking along Pacific Highway downtown, and the birds were trilling. I urged my sighted companion to cross the street when the bird calls indicated we should go. He refused, saying the light was red. I pointed out that the birds said: Go. He was horrified! "If you go, you'll get killed!" he said. According to my friend the birds were set the opposite to the traffic signals. Apparently maintenance had not been done. If I had been alone I could have been in extreme danger. The lesson for me is not to rely on audible signals if I can possibly hear the traffic. Traffic sounds cannot be wrong.
I have observed items bounce out of grocery carts and strollers when they were pushed quickly over "humpy bumpy" slopes at exits at grocery stores. I have observed women wearing high heels and people on crutches slip and lose their balance on truncated domes. The blind do not wish to be the cause of making the world less safe for others! There are far more blind seniors than younger people, and they need secure footing, not humpy bumpy surfaces. If the slope at a curb is one inch down to 12 inches
At a limited number of intersections safety for the blind might be improved by a special signal. If so, it should be quiet! Vibrating signals in the shape of arrows are available and can be mounted on poles thus providing information about when to cross and which direction to go. They could be activated by a button, so that only those who wish to use them do so. These would still cost money, so they should be installed only at intersections which are difficult to navigate by listening to the traffic sounds. It is important to consider that they would not disturb a neighborhood with undesirable noise 24 hours a day. Do you want to hear a bird or a beeper outside your bedroom or office window? Not only would most people find this irksome, but they would blame the blind. They might be charitable and sympathetic, but the blind want to be respected as responsible citizens, not pitied because people think we cannot cross the streets with other pedestrians. We all know that technology is changing rapidly. The vibrating signals are newer than the audible signals. Because they add information about direction, they are better, and the vibrating signals make it possible to eliminate the excess noise.
In order not to waste money, city and county transportation departments must be required to confer with knowledgeable blind people about difficult intersections. Audible signals should be prohibited. Vibrating ones whould be installed in consultation with the blind. Detectible warnings should be installed only where the slope is 1 to 15 or less. We need city transit (buses and trains)-many more than we now have and far worse than we need special signals or detectible warnings.
When vibrating signals are to be used, a certain type of pole should be agreed upon, and it should be located as close to the curb as possible, as close to the crosswalk as possible, on the side away from crossing traffic. If there is no crossing traffic, the right-hand side might be preferred. But if the pole is distinctive, only a few seconds would be required to check both sides of the crosswalk.
I presented remarks similar to this letter in Portland. I have tried to clarify what I said at the hearing. However, I repeat what I said in conclusion. I know the Board and the staff have done a lot of work up to this point, but the proposed regulations should not be adopted. Please redraft them. If I can be of help, I would be glad to participate in any way you wish.
Cordially,
Ramona Walhof
LuAnne Bullington, October 21, 2002
I support the PROWAC report. I strongly feel we need to have detectable warnings at places where vehicular traffic is likely to be found and we need accessible pedestrian signals.
I live in Ann Arbor, Michigan. We have a few of the devices and I can't start to tell you how important they have been to my safety and sanity.
Ann Arbor is a college town. Some of our drivers are very distracted. The talking pedestrian signals have made a big difference. That verbal cue seems to sneak through their foggy brains and stop them from turning when they shouldn't and running me down. It has reduced the number of accidents I have encountered at the corner where I use the talking signals the most.
I need to cross very busy intersections where it is difficult to tell if it is safe to walk. The audible signals let me know when I can cross. It has been wonderful and I wish my city would put in many more.
If curb cuts can be made mandatory to help wheel chair users, why can't the blind and visually impaired have these life saving devices?
Please help us stay safe and insist cities put in audible signals just like cities put in curb cuts.
Thank you,
LuAnne Bullington
Lloyd E. Neal, P.E., October 17, 2002
RE: Draft Public Rights-of-Way Accessibility Guidelines
Dear Mr. Windley:
The City of Plano has assembled a group of city planners, traffic engineers, civil engineers and public works officials to review the Draft Public Right-of-Way Guidelines proposed by the Access Board. The City fully supports the goal of increased accessibility and has spent many capital improvement dollars retrofitting curb ramps and sidewalks to make the city streets as accessible as possible. However, we do have concerns about the application and practicality of some of the proposed standards, and offer the following comments and suggestions for consideration:
1101 Application and Administration
1101.3 Defined Terms
Curb Line - this definition assumes that the sidewalk, if there is a sidewalk, is always adjacent to the curb. This is not the case in most suburban and residential areas.
Element & Facility - The definition of "element" includes the term "facility" and the definition of "facility" includes the term "element." Therefore, these appear to be circular references with no clear definition. Traffic control signs (and their supports) and traffic signals (and their supports) are located in public right-of-way. Is it intended that they be included in the definition of element, facility, or both?
Sidewalk - In
Street Furniture - the "elements in the public right-of-way that are intended for use by pedestrians" definition is too general. The sidewalk is in the public right-of-way and is intended for use by pedestrians, but it should not be considered street furniture. Street name signs and traffic signals are located within the public right-of-way and are intended for use by pedestrians (as well as drivers). These also should not be considered street furniture. A specific definition of those things specifically considered street furniture should be prepared.
Walk Interval - this definition should be modified to read as follows: "That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and, where provided, its audible equivalent.
1102 Scoping Requirements
1102.2.1 Additions & 1102.2.2 Alterations
It appears that the proposed wording of these sections would require the installation of audible pedestrian signals and audible/vibrotactile pedestrian detector buttons/poles for any new traffic signal installation and for modifications to existing traffic signals. See later comments for 1106 concerning pedestrian signals.
1102.3 Alternate Circulation Path
Sidewalk repairs often involve numerous locations along a block, but only a few short sections of walk may be removed and for only a short period of time. This would result in several separate alternative paths being created and maintained in the same block, and in many instances, the alternate circulation path would place pedestrians immediately adjacent to fast-moving traffic lanes on major arterial streets. We suggest that if sidewalks are available on both sides of the street, the sidewalk on the opposite side of the street should be permitted as an alternate circulation path.
1102.5.2 Post Mounted Objects
For right-of-way areas near traffic signal controlled intersections, this section needs to permit the installation of the traffic signal control cabinet on a post. Although some controller cabinets are ground mounted, many in a CBD area are post mounted. These are likely to be mounted with the bottom higher than 27 inches
1102.14 On-Street Parking
Outside of downtowns or high-density mixed-use districts, individual parking spaces are not typically marked, especially on residential streets. The proposed wording does not distinguish between locations where on-street parking is provided with marked parking spaces versus locations where on-street parking is provided but there are no marked spaces. It is not clear whether or not this requirement is intended to apply to blocks with unmarked spaces. This situation is typical in residential subdivisions where parking is permitted on the street but no specific parking spaces are marked. Under these conditions, the provision of a marked on-street accessible parking space should not be required. Cities should have the option to respond to individual requests for parking, so that spaces are placed in a location most convenient to disabled residents.
1104 Curb Ramps and Blended Transitions
1104.3.3 Surfaces
The prohibition of access covers and other appurtenances on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route may discourage the installation of additional sidewalks in some cases. If this prohibition includes traffic signal pull boxes and a traffic signal currently exists at a location proposed for new sidewalk installation, relocating existing pull boxes out of the prohibited areas can be both costly and disruptive. Since pull boxes are used to connect conduits, route the control cables around the intersection, and connect vehicle loops to the detector cables, the relocation of a pull box also requires modifications to the underground conduit and either replacing or splicing the cables. During the cable work, the traffic signal will likely have to be operated in either flashing mode or turned off depending on the cables involved. Similar extensive underground work would be required where various access covers exist for other underground items such a telephone or communications cables, sanitary or storm sewers, or other utility items.
If the access cover is made flush with the surrounding walkway area, it should be permitted to be in these areas. When faced with a decision to undertake such a degree of work on an existing signal or utility facility to accommodate the installation of a sidewalk, many agencies may choose to not install the sidewalk. When new traffic signal and utility facilities are being installed, the design can typically locate the access covers outside the curb ramp, landing, blended transition, and gutter areas. However, relocating existing items involves extensive work and expense.
Are traffic signal, utility, street light, and other such poles intended to be included in this prohibition? The use of the work "appurtenances" in the list of prohibited items could be interpreted to include these. As with the access covers, the relocation of these can be both costly and disruptive. Also, underground and overhead utility lines often influence or control the location of these poles. Existing poles should be permitted to remain. New poles should be recommended to be located outside these areas but flexibility needs to exist for cases where the placement of the pole is controlled by existing underground and overhead utilities.
1105 Pedestrian Crossings
1105.3 Pedestrian Signal Phase Timing
Jurisdictions should be allowed to determine the necessity for the slower pedestrian walk speed, based on surrounding land uses and on the needs of individuals in the area. A requirement to use a maximum of 3.0 feet
1105.4 Medians and Pedestrian Refuge Islands
The proposed wording "medians and refuge islands in crosswalks" is good in that this section and its subsections would not be applied to medians that are not in crosswalks. In order to avoid possible confusion about a minimum 6 foot
1105.6 Roundabouts
1105.6.1 Separation
The requirement to provide a continuous barrier along the street side of the sidewalk where pedestrian crossing is prohibited is excessive. This requirement applies whether or not operational experience indicates a problem with crossings at inappropriate locations. Crossing at mid-block locations or at intersections where crossings are prohibited by signs may also be dangerous to pedestrians. However, physical barriers are not proposed to be required at these locations. If it is desired to treat prohibited pedestrian crossing areas at roundabouts differently than at other locations, the proposed wording should be in the form of guidance or option rather than an across the board requirement.
1105.6.2 Signals
The proposed wording requires the installation of a traffic signal for each crosswalk at a roundabout. This requirement is made without the benefit of any engineering study of traffic operations or level of pedestrian activity at the location. Visibility of the traffic signal to drivers approaching the roundabout should be similar to other traffic signals. However, drivers exiting the roundabout will have greater difficulty in seeing and responding to the traffic signal since they will be negotiating around the roundabout as they approach. They will not be able to view the signal indications from as great a distance as drivers on a straight approach. Additionally, traffic may back up around the roundabout while stopped for a red signal at the pedestrian crosswalk signal when departing the roundabout. In the event there is more than one crosswalk at the roundabout, it may be necessary to limit when the crosswalk signals can respond to a pedestrian call to avoid congestion if separate crosswalk signals served pedestrian demand consecutively.
1105.7 Turn Lanes at Intersections
The proposed requirement to provide a pedestrian activated traffic signal where pedestrian crosswalks are provided at right or left turn slip lanes is excessive. First, there should not be a requirement to install a traffic signal at an intersection simply because a crosswalk crosses a left or right turn slip lane. The proposed wording will require signal installation even if the intersection is operating well without a traffic signal. As in 1105.6.2, the signal installation requirement is not based on an engineering study of actual operating conditions at the location. Second, even if there is a traffic signal at the intersection, there should not be an automatic requirement to control the pedestrian crossing movement across a left or right turn slip lane. This requirement would force the turning movement to be controlled by a signal indication rather that the Yield or Stop signs that are commonly used in such cases. During the green signal indication for the adjacent through movement, using signal control for the turning movement has little or no impact whether a Stop or Yield sign has previously been used. The replacement of a Stop sign with a signal indication may lead to a slight operational improvement, at least during the time the signal is green, as the vehicles would no longer have to come to a stop before proceeding. However, the replacement of a Yield sign with a signal indication would have a significant impact. While the signal indication was red, vehicles would be required to come to a complete stop before making the permitted turning movement versus simply slowing to yield with the previous Yield control. The proposed control of turning movements in slip lanes should be modified to list signal control as an option but not as a requirement.
1106 Accessible Pedestrian Signal Systems
1106.2 Pedestrian Signal Devices
The proposed wording requires that all crosswalks with pedestrian signal indications have both audible and vibrotactile indications for the WALK interval. Audible signals at intersections in neighborhood settings, even those with volumes that respond to ambient noise, may annoy nearby residents at night when background noise levels are not high enough to dampen the sound. Audible signals should be activated only on a demand basis. Additionally, the installation of audible and vibrotactile indications of the WALK interval should not be required under all conditions. Rather, specific conditions requiring such devices could be listed but their use at other locations should be optional.
1106.2.1 Location
Typically, the standard pedestrian signal devices (pedestrian heads and pedestrian push buttons) serving both crosswalks will be located on one pole at that corner. The requirement that accessible pedestrian signal devices be separated by a minimum of 120 inches
1106.3 Pedestrian Pushbuttons
1106.3.2 Locator Tone
The proposed wording requires every pushbutton to be equipped with a locator tone. Whereas the audible WALK indication tone would only operate during the WALK periods, the push button locator tone is required to operate during the DON'T WALK and flashing DON'T WALK intervals. In residential settings or where the WALK interval is served only upon demand, the continuous operation of the detector locator tone may lead to complaints.
1106.4 Directional Information Signs
Revised wording is needed for this section. The existing wording of "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" implies that each of the pedestrian signal devices must have these signs. This requirement should not be applied to typical WALK/DON'T WALK pedestrian signal heads. If required, the tactile and visual signs should be provided as part of the push button assembly or adjacent to the pushbutton assembly.
This proposed wording adds a requirement for the street names that is not otherwise required. There would be no street name information provided at an intersection that was not controlled by a traffic signal. The requirement to include the street name means unique signs must be installed for each corner with pedestrian signal devices. The provision of an arrow indicating the direction of the controlled crosswalk without the street name included would permit the use of the same device at multiple locations.
1109 On-Street Parking
It should be specified that this applies to accessible parking spaces and not all parking spaces. Otherwise, it could be interpreted that an access aisle is required adjacent to every parking space.
1109.2 Parallel Parking Spaces
The exception for when an access aisle is not required appears to assume there is a paved sidewalk. In some residential and other areas, paved sidewalks are not provided. Also, the proposed wording permits the exclusion "where the width of the sidewalk between the extension of the normal curb and the boundary of the public right-of-way is less than 14 feet
1109.3 Perpendicular or Angled Parking Spaces
Is a separate access aisle required for each parking space or can a single access aisle between two spaces serve both spaces? It is noted that there is no requirement on whether the access aisle is on the right side or left side of the parking space. It seems that a single aisle between two adjacent spaces would provide the needed access to the parking spaces.
1111 Alternate Circulation Path
1111.3 Location
The requirement that the alternate circulation path parallel the disrupted pedestrian access route and be on the same side of the street is impractical in many cases. If sidewalks in a residential area are being repaired or if utility work has caused the sidewalk to be closed, the right-of-way is often too narrow to provide the required 3-foot wide alternate path on the same side of the street. An alternate circulation path using the opposite side of the street may be the only practical choice. If faced with the alternatives of an unpaved path on the same side of the street or an existing paved sidewalk on the opposite side of the street, the paved sidewalk provides a superior option even if it is across the street.
It is noted that there does not seem to be a requirement that the alternate circulation path be paved. In fact, it would be impractical to include such a requirement for many cases. Repair of damaged sidewalk sections in residential areas may be completed in a couple of days. If the construction of a paved alternative path on the same side of the street were required, both the overall time and cost would increase.
Although the document title indicates it contains guidelines, the proposed wording actually establishes requirements rather than guidelines in many cases. It also includes several items that address the installation and/or operation of various traffic control devices. Since the MUTCD provides the standards, guidance, options, and support information for traffic control devices, any proposed additions or changes to the standards, guidance, options, or support information should also be reflected in the MUTCD.
Thank you for the opportunity for the city to comment on these proposals. If you have any questions or need additional information, please feel free to contact Ronnie Bell, Senior Traffic Engineer at [...].
Sincerely,
Lloyd E. Neal, P.E.
Transportation Engineering Manager
City of Plano
Kenneth Gatteys, September 29, 2002
To whom it may concern:
I'm opposed to audible traffic signals being installed at some intersections where there are "walk/don't walk" signs. There are a couple of reasons I feel this
way.
1. It is an unnecessary expense. As a taxpayer I cannot support it. I would rather see the money spent on better training and services for the blind.
2. I believe that some people could become very dependent on these audible signals; and when the signal doesn't work they may have forgotten some of their skills therefore putting them in danger.
There are places where vibrotactile signals could be used such as intersections where traffic patterns are not steady. I believe that detectable warnings are necessary only when curbs are flat and hard to distinguish from the street. I hope that you consider these points when making your decision.
Yours truly,
Kenneth Gatteys
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
Ronnie Bell, P.E., October 17, 2002
I was a member of a committee composed of representatives from various City departments that reviewed the Draft Public Rights-of-Way Accessibility Guidelines. Comments from the City of Plano, Texas are included in the attached file. We appreciate the opportunity to participate in this important process. Please feel free to contact me if you have any questions or need any additional information.
Ronnie Bell, P.E.
Senior Traffic Engineer
City of Plano
October 17, 2002
Mr. Scott Windley, Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, NW, Suite 1000
Washington DC 20004-1111
RE: Draft Public Rights-of-Way Accessibility Guidelines
Dear Mr. Windley:
The City of Plano has assembled a group of city planners, traffic engineers, civil engineers and public works officials to review the Draft Public Right-of-Way Guidelines proposed by the Access Board. The City fully supports the goal of increased accessibility and has spent many capital improvement dollars retrofitting curb ramps and sidewalks to make the city streets as accessible as possible. However, we do have concerns about the application and practicality of some of the proposed standards, and offer the following comments and suggestions for consideration:
1101 Application and Administration
1101.3 Defined Terms
Curb Line - this definition assumes that the sidewalk, if there is a sidewalk, is always adjacent to the curb. This is not the case in most suburban and residential areas.
Element & Facility - The definition of "element" includes the term "facility" and the definition of "facility" includes the term "element." Therefore, these appear to be circular references with no clear definition. Traffic control signs (and their supports) and traffic signals (and their supports) are located in public right-of-way. Is it intended that they be included in the definition of element, facility, or both?
Sidewalk - In
Street Furniture - the "elements in the public right-of-way that are intended for use by pedestrians" definition is too general. The sidewalk is in the public right-of-way and is intended for use by pedestrians, but it should not be considered street furniture. Street name signs and traffic signals are located within the public right-of-way and are intended for use by pedestrians (as well as drivers). These also should not be considered street furniture. A specific definition of those things specifically considered street furniture should be prepared.
Walk Interval - this definition should be modified to read as follows: "That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and, where provided, its audible equivalent.
1102 Scoping Requirements
1102.2.1 Additions & 1102.2.2 Alterations
It appears that the proposed wording of these sections would require the installation of audible pedestrian signals and audible/vibrotactile pedestrian detector buttons/poles for any new traffic signal installation and for modifications to existing traffic signals. See later comments for 1106 concerning pedestrian signals.
1102.3 Alternate Circulation Path
Sidewalk repairs often involve numerous locations along a block, but only a few short sections of walk may be removed and for only a short period of time. This would result in several separate alternative paths being created and maintained in the same block, and in many instances, the alternate circulation path would place pedestrians immediately adjacent to fast-moving traffic lanes on major arterial streets. We suggest that if sidewalks are available on both sides of the street, the sidewalk on the opposite side of the street should be permitted as an alternate circulation path.
1102.5.2 Post Mounted Objects
For right-of-way areas near traffic signal controlled intersections, this section needs to permit the installation of the traffic signal control cabinet on a post. Although some controller cabinets are ground mounted, many in a CBD area are post mounted. These are likely to be mounted with the bottom higher than 27 inches
1102.14 On-Street Parking
Outside of downtowns or high-density mixed-use districts, individual parking spaces are not typically marked, especially on residential streets. The proposed wording does not distinguish between locations where on-street parking is provided with marked parking spaces versus locations where on-street parking is provided but there are no marked spaces. It is not clear whether or not this requirement is intended to apply to blocks with unmarked spaces. This situation is typical in residential subdivisions where parking is permitted on the street but no specific parking spaces are marked. Under these conditions, the provision of a marked on-street accessible parking space should not be required. Cities should have the option to respond to individual requests for parking, so that spaces are placed in a location most convenient to disabled residents.
1104 Curb Ramps and Blended Transitions
1104.3.3 Surfaces
The prohibition of access covers and other appurtenances on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route may discourage the installation of additional sidewalks in some cases. If this prohibition includes traffic signal pull boxes and a traffic signal currently exists at a location proposed for new sidewalk installation, relocating existing pull boxes out of the prohibited areas can be both costly and disruptive. Since pull boxes are used to connect conduits, route the control cables around the intersection, and connect vehicle loops to the detector cables, the relocation of a pull box also requires modifications to the underground conduit and either replacing or splicing the cables. During the cable work, the traffic signal will likely have to be operated in either flashing mode or turned off depending on the cables involved. Similar extensive underground work would be required where various access covers exist for other underground items such a telephone or communications cables, sanitary or storm sewers, or other utility items.
If the access cover is made flush with the surrounding walkway area, it should be permitted to be in these areas. When faced with a decision to undertake such a degree of work on an existing signal or utility facility to accommodate the installation of a sidewalk, many agencies may choose to not install the sidewalk. When new traffic signal and utility facilities are being installed, the design can typically locate the access covers outside the curb ramp, landing, blended transition, and gutter areas. However, relocating existing items involves extensive work and expense.
Are traffic signal, utility, street light, and other such poles intended to be included in this prohibition? The use of the work "appurtenances" in the list of prohibited items could be interpreted to include these. As with the access covers, the relocation of these can be both costly and disruptive. Also, underground and overhead utility lines often influence or control the location of these poles. Existing poles should be permitted to remain. New poles should be recommended to be located outside these areas but flexibility needs to exist for cases where the placement of the pole is controlled by existing underground and overhead utilities.
1105 Pedestrian Crossings
1105.3 Pedestrian Signal Phase Timing
Jurisdictions should be allowed to determine the necessity for the slower pedestrian walk speed, based on surrounding land uses and on the needs of individuals in the area. A requirement to use a maximum of 3.0 feet
1105.4 Medians and Pedestrian Refuge Islands
The proposed wording "medians and refuge islands in crosswalks" is good in that this section and its subsections would not be applied to medians that are not in crosswalks. In order to avoid possible confusion about a minimum 6 foot
1105.6 Roundabouts
1105.6.1 Separation
The requirement to provide a continuous barrier along the street side of the sidewalk where pedestrian crossing is prohibited is excessive. This requirement applies whether or not operational experience indicates a problem with crossings at inappropriate locations. Crossing at mid-block locations or at intersections where crossings are prohibited by signs may also be dangerous to pedestrians. However, physical barriers are not proposed to be required at these locations. If it is desired to treat prohibited pedestrian crossing areas at roundabouts differently than at other locations, the proposed wording should be in the form of guidance or option rather than an across the board requirement.
1105.6.2 Signals
The proposed wording requires the installation of a traffic signal for each crosswalk at a roundabout. This requirement is made without the benefit of any engineering study of traffic operations or level of pedestrian activity at the location. Visibility of the traffic signal to drivers approaching the roundabout should be similar to other traffic signals. However, drivers exiting the roundabout will have greater difficulty in seeing and responding to the traffic signal since they will be negotiating around the roundabout as they approach. They will not be able to view the signal indications from as great a distance as drivers on a straight approach. Additionally, traffic may back up around the roundabout while stopped for a red signal at the pedestrian crosswalk signal when departing the roundabout. In the event there is more than one crosswalk at the roundabout, it may be necessary to limit when the crosswalk signals can respond to a pedestrian call to avoid congestion if separate crosswalk signals served pedestrian demand consecutively.
1105.7 Turn Lanes at Intersections
The proposed requirement to provide a pedestrian activated traffic signal where pedestrian crosswalks are provided at right or left turn slip lanes is excessive. First, there should not be a requirement to install a traffic signal at an intersection simply because a crosswalk crosses a left or right turn slip lane. The proposed wording will require signal installation even if the intersection is operating well without a traffic signal. As in 1105.6.2, the signal installation requirement is not based on an engineering study of actual operating conditions at the location. Second, even if there is a traffic signal at the intersection, there should not be an automatic requirement to control the pedestrian crossing movement across a left or right turn slip lane. This requirement would force the turning movement to be controlled by a signal indication rather that the Yield or Stop signs that are commonly used in such cases. During the green signal indication for the adjacent through movement, using signal control for the turning movement has little or no impact whether a Stop or Yield sign has previously been used. The replacement of a Stop sign with a signal indication may lead to a slight operational improvement, at least during the time the signal is green, as the vehicles would no longer have to come to a stop before proceeding. However, the replacement of a Yield sign with a signal indication would have a significant impact. While the signal indication was red, vehicles would be required to come to a complete stop before making the permitted turning movement versus simply slowing to yield with the previous Yield control. The proposed control of turning movements in slip lanes should be modified to list signal control as an option but not as a requirement.
1106 Accessible Pedestrian Signal Systems
1106.2 Pedestrian Signal Devices
The proposed wording requires that all crosswalks with pedestrian signal indications have both audible and vibrotactile indications for the WALK interval. Audible signals at intersections in neighborhood settings, even those with volumes that respond to ambient noise, may annoy nearby residents at night when background noise levels are not high enough to dampen the sound. Audible signals should be activated only on a demand basis. Additionally, the installation of audible and vibrotactile indications of the WALK interval should not be required under all conditions. Rather, specific conditions requiring such devices could be listed but their use at other locations should be optional.
1106.2.1 Location
Typically, the standard pedestrian signal devices (pedestrian heads and pedestrian push buttons) serving both crosswalks will be located on one pole at that corner. The requirement that accessible pedestrian signal devices be separated by a minimum of 120 inches
1106.3 Pedestrian Pushbuttons
1106.3.2 Locator Tone
The proposed wording requires every pushbutton to be equipped with a locator tone. Whereas the audible WALK indication tone would only operate during the WALK periods, the push button locator tone is required to operate during the DON'T WALK and flashing DON'T WALK intervals. In residential settings or where the WALK interval is served only upon demand, the continuous operation of the detector locator tone may lead to complaints.
1106.4 Directional Information Signs
Revised wording is needed for this section. The existing wording of "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" implies that each of the pedestrian signal devices must have these signs. This requirement should not be applied to typical WALK/DON'T WALK pedestrian signal heads. If required, the tactile and visual signs should be provided as part of the push button assembly or adjacent to the pushbutton assembly.
This proposed wording adds a requirement for the street names that is not otherwise required. There would be no street name information provided at an intersection that was not controlled by a traffic signal. The requirement to include the street name means unique signs must be installed for each corner with pedestrian signal devices. The provision of an arrow indicating the direction of the controlled crosswalk without the street name included would permit the use of the same device at multiple locations.
1109 On-Street Parking
It should be specified that this applies to accessible parking spaces and not all parking spaces. Otherwise, it could be interpreted that an access aisle is required adjacent to every parking space.
1109.2 Parallel Parking Spaces
The exception for when an access aisle is not required appears to assume there is a paved sidewalk. In some residential and other areas, paved sidewalks are not provided. Also, the proposed wording permits the exclusion "where the width of the sidewalk between the extension of the normal curb and the boundary of the public right-of-way is less than 14 feet
1109.3 Perpendicular or Angled Parking Spaces
Is a separate access aisle required for each parking space or can a single access aisle between two spaces serve both spaces? It is noted that there is no requirement on whether the access aisle is on the right side or left side of the parking space. It seems that a single aisle between two adjacent spaces would provide the needed access to the parking spaces.
1111 Alternate Circulation Path
1111.3 Location
The requirement that the alternate circulation path parallel the disrupted pedestrian access route and be on the same side of the street is impractical in many cases. If sidewalks in a residential area are being repaired or if utility work has caused the sidewalk to be closed, the right-of-way is often too narrow to provide the required 3-foot wide alternate path on the same side of the street. An alternate circulation path using the opposite side of the street may be the only practical choice. If faced with the alternatives of an unpaved path on the same side of the street or an existing paved sidewalk on the opposite side of the street, the paved sidewalk provides a superior option even if it is across the street.
It is noted that there does not seem to be a requirement that the alternate circulation path be paved. In fact, it would be impractical to include such a requirement for many cases. Repair of damaged sidewalk sections in residential areas may be completed in a couple of days. If the construction of a paved alternative path on the same side of the street were required, both the overall time and cost would increase.
Although the document title indicates it contains guidelines, the proposed wording actually establishes requirements rather than guidelines in many cases. It also includes several items that address the installation and/or operation of various traffic control devices. Since the MUTCD provides the standards, guidance, options, and support information for traffic control devices, any proposed additions or changes to the standards, guidance, options, or support information should also be reflected in the MUTCD.
Thank you for the opportunity for the city to comment on these proposals. If you have any questions or need additional information, please feel free to contact Ronnie Bell, Senior Traffic Engineer at (972) 941-7151.
Sincerely,
Lloyd E. Neal, P.E.
Transportation Engineering Manager
City of Plano
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
Melissa Riccobono, October 4, 2002
Dear Sirs:
I am writing to express strong opposition for the proposed guideline for placing an audible traffic signal at every intersection with a traffic light. I have been totally blind all of my life. Growing up, I lived in a medium sized town with a few traffic lights. I learned to cross the streets with traffic lights safely by listening to the flow of traffic. It was easy to tell when the light turned and it was safe for me to walk across the street. I strongly believe that traffic flow is the best way to tell if the light has changed at simple intersections such as the one's in the town in which I grew up. Not only that, but I am sure that adding audible signals would be much too expensive for many smaller towns and cities across the country. Therefore, traffic lights would be replaced by stop signs in many instances, making it less safe for all pedestrians to travel.
In college I lived in a larger city. Again, I found it easy to tell when it was safe to cross at controlled intersections by using traffic cues. I also realized how much noise can be present on a city street. I believe that audible signals at every intersection would add needlessly to the noises which already exist. The signals would be distracting, and having so many going at one time would make paying attention to the correct signal a challenge.
I also question the wisdom of teaching blind people to rely on these signals to tell them when it's safe to cross a street. What if a signal is broken? What if it malfunctions? If a blind person has learned to rely on these signals and does not pay attention to traffic patterns he or she will be more likely to be hurt if a signal malfunctions than if that signal was never installed at all.
I also oppose the use of truncated domes at every intersection. The vast majority of the time, a curb or ramp is all that is needed to tell me that there is a street ahead. I travel with a guide dog the majority of the time, and a long white cane when I am not using my dog. Both methods are effective in giving me clues that there is a street ahead. Again, adding these domes adds expense to cities and towns where staying within a budget is often difficult when simply meeting the needs of annual street maintenance. I also find many domes slippery, especially when they are wet. Therefore, I see them as more of a danger than a help most of the time.
Do I believe that audible signals and truncated domes should never be used? Absolutely not. But I believe these things should be used only when blind residents of a community see the need and ask for them.
Thank you for reading these comments, and for taking them into consideration.
Sincerely,
Melissa Riccobono
President, Wisconsin Association of Blind Students
Marsha and David Anderson, October 5, 2002
This is to provide comments about Audible Traffic Signals as well as Detectable Warning Strips.
In most cases Audible traffic Signals are not needed for blind persons to safely cross the intersections. In fact they may be a distraction. The added noise of the Audible Signal may mask other traffic or environmental noises which are necessary clues for the safe navigation of the intersection. While there may be some occasions where there are not sufficient clues where these Signals may be helpful, I believe they are few and far between.
When there are places such as medians or islands where there are no other detectable markings, Detectable Warning Strips could be of use: however, in most cases, proper use of a cane or dog guide should provide quite adequate warning for the blind traveler.
If it is decided that there needs to be audible Traffic signals on almost every corner, I feel, this would be a tremendous waste of limited funds. The funds which would be allocated to these projects might be more effectively used for a widespread educational program to better inform both drivers and pedestrians of proper safety rules.
Sincerely
Marsha and David Anderson
Mary Ellen Halverson, October 21, 2002
Dear Board members,
I am totally blind and am writing in regards to the proposed audible traffic signals for all intersections.
I travel around Boise, Idaho using a white cane, and my most valuable traffic clue is the traffic itself. I have heard the audible signals in Salt Lake City and find them very confusing. The traffic is noisy and it is hard to determine where the audible bird sounds are coming from.
I have heard that in Japan there are audible signals in certain areas. The blind are expected to travel in these areas where it is believed they will be safe. This could become very limiting to blind individuals.
I also think it is unreasonable to spend millions of dollars on such signals.
Perhaps a vibrating traffic signal on difficult intersections would be helpful.
Thank you for considering my input.
Sincerely,
Mary Ellen Halverson
Yanilza Gonzalez, October 28, 2002
Hi my name is Yanilza Gonzalez, and I am writing to give my opinion about this audible traffic signals.
As a visually impaired person, I think is a really stupid idea, because we have been doing fine till now, and if there is any problem with the way things are now, Those signals will just make things much worse.
Thank-you,
Yanilza Gonzalez
Raymond Halverson, October 22, 2002
Dear Board Members:
I am a blind person living in Boise, Idaho, and have traveled independently around this city for many years. I am writing in opposition to any kind of audible traffic signals on all
intersections. With all the traffic noise and other environmental
noises going on, it would be very confusing trying to listen to an audible signal.
The cost of such signals is appalling! I would recumbent that the millions of dollars that would be spent on traffic signals be used to improve training programs for the blind in every major city. Once a person is trained to use either a cane or guide dog, he can travel when and where he wants to with confidence.
Thank you for considering my opinions.
Cordially,
Raymond Halverson
Catherine H. Randall, August 13, 2002
To whom it concerns:
My letter addresses the proposed changes to the Guidelines for Accessible Pedestrians Rights of 'day. I write as a blind person to oppose the universal installation of audible traffic signals. These signals are simply unnecessary at every crossing. In fact, they can pose a danger as they make it more difficult to hear cars turning. Spending money on these signals given our economic situation at this time defies common sense. It makes more sense to install special expensive signals on a case-by-case basis where they are beneficial rather than extraneous or outright dangerous.
Sincerely,
Catherine H. Randall
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