Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6
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
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
Pamela Drake, October 25, 2002
I support the recommendations of the PROWAC report. Pedestrian safety is of the utmost importance to all pedestrians.
Most Sincerely,
Pamela Drake
Billy L. Hattaway, P.E., July 1, 2002
I have reviewed the proposed language requiring pedestrian activated signals at each roundabout crosswalk and would like to comment on the proposed language. While I am now in the private sector, I spent the last 23+ years working at Florida Department of Transportation in positions such as the District Five Design Engineer, State Roadway Design Engineer and most recently, Director, Office of Design. I have been a strong advocate for pedestrian and bicycle issues during my tenure, and will continue to be. I am involved in the Congress for New Urbanism, and have a serious commitment to walkable and livable communities. I would like you to consider my comments in view of my background.
While I have concerns for the safety of all pedestrians using transportation facilities, I believe the proposed requirement would create an undue constraint on the use of roundabouts, potentially eliminating their use in many locations at the state and local level. The budgets of all government entities are already stretched thin, so maximizing the opportunities for safety improvements is very important. Roundabouts improve safety for vehicles compared with traditional intersections by keeping the speeds low and reducing conflict points. The article states that often "Pedestrians report that vehicles at roundabouts, as well as at other unsignalized crossings, often do not yield for pedestrians." I believe that to be true, and believe that those who would not yield to a pedestrian (sighted or otherwise) in a roundabout are the same who will not stop for the same pedestrian in any crosswalk, whether in a roundabout, a yield condition, stop sign, or signals with right turn on red. There are many factors that impact pedestrian use of roundabouts and their exposure, such as the volume of traffic, the roundabout's geometry - which affects entry and exit speeds, and the volume of pedestrian traffic.
Before requiring pedestrian activated signals at every crosswalk within a roundabout, we should allow practicing engineers to deal with each site individually and do what is best for that location. We have a responsibility to provide improved safety for everyone using our transportation systems, and since money is always an issue in making those decisions, we need to use it wisely, where it is most needed. Thanks for the opportunity to comment.
Billy L. Hattaway, P.E.
Vice President, Transportation Program Manager Baskerville-Donovan, Inc.
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
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
Kathryn Moore Ridley, October 21, 2002
I would like to provide my support for the accessible pedestrian signals. I have a sister who is blind and these are extremely useful for her and have helped her tremendously in the areas they exist. I also find them useful. I notice that drivers are more aware of pedestrians because of the noise.
Thank you for your attention to this matter.
Kathryn Moore Ridley
Willamette Pedestrian Coalition, October 28, 2002
Comments by the Willamette Pedestrian Coalition on the Draft Guidelines for Accessible Public Rights-of-Way
Willamette Pedestrian Coalition
Ellen Vanderslice, President
Doug Klotz, Policy Analyst
We are pleased to support the Draft Guidelines for Accessible Public Rights-of-Way. In general this document represents an advance for accessibility on public streets. Our specific comments follow and are also attached as a Word document for your convenience.
1102.14 On-Street Parking
We support the provision of accessible on-street parking. However, we respectfully disagree with the proposed requirement of one space per block. Blocks vary so greatly in size (including average variation between cities) that this is an inherently inequitable requirement. Perhaps the requirement should be something like one for every six hundred feet of on-street parking provided. Also, there should be a better definition of "where on-street parking is provided," whether this means where it is allowed or where it is marked or signed. The guidelines should clarify whether this requirement applies on every street, even low-volume residential streets where parking is permitted but not designated.
1103.3 Clear Width (of the Pedestrian Access Route)
We support widening the minimum clear width requirement in the public right-of-way, with the understanding that larger scooters may be used in this environment and that there should be room for two wheelchairs to pass. We would support the PROWAAC recommendation for 60 inches
1104.3.2 Detectable Warnings (in Common Elements of Curb Ramps and Blended
Transitions)
We support the requirement for detectable warnings at curb ramps and blended transitions. See additional comments on 1108.
1105.2 Crosswalks
We support all the crosswalk provisions, including the minimum width of 96 inches
intersections) and the maximum running slope of 1:20
1105.2 Pedestrian Signal Phase Timing
While we support reducing the walk speed used to calculate crossing times, as well as the inclusion of one ramp in the value of the length of the crosswalk used in the calculation, we suggest that there might be an exception included for signals that use either passive or active detection to extend the pedestrian clearance interval on demand. If the system can provide the added crossing time only when needed, this will benefit those crossing in the perpendicular direction and reduce overall delay for pedestrians.
1105.4 Medians and Pedestrian Refuge Islands
We support the requirement for alignment of the cut-through with the direction of the crosswalk for a minimum of 24 inches
1105.5 Pedestrian Overpasses and Underpasses
We are supportive of the needs of users who experience fatigue but we are concerned about the effect of the 60 inch
We respectfully suggest that the terms "pedestrian overpass" and "pedestrian underpass" be defined in section 1101.3. Without a definition, it is not clear which facilities require an elevator.
1105.6 Roundabouts
We respectfully suggest a definition in 1101.3 of "barriers" as used in 1105.6.1 Separation. We believe landscaping should be allowed as separation. The extent of the required separation should be specified more clearly.
We support 1105.6.2 Signals (at Roundabouts). As noted in the discussion, there currently is no alternative that allows for safe passage of pedestrians with disabilities.
Although this may not be an accessibility issue, we suggest that adding a new tool to the pedestrian signal arsenal could be helpful in this situation. There is currently no provision for pedestrian signals where "pedestrian yield," rather than "don't walk," is the default state. We believe such a signal would be useful in a situation like a roundabout where most pedestrians will use available gaps rather than request the walk signal.
1105.7 Turn Lanes at Intersections
We support the requirement for pedestrian signals with the same suggestions as we made for signals at roundabouts.
1106.2 Pedestrian Signal Devices
We support the requirement for accessible signal devices at all crosswalks with pedestrian signal indication.
1106.3 Pedestrian Pushbuttons
We would like to note that these draft guidelines do not require the use of pedestrian pushbuttons, and that signals without pedestrian pushbuttons are much better for all pedestrians.
The PROWAAC recommended (in "Building a True Community," section X02.5.1.3) that "the control face of the push button shall be parallel to the direction of the crosswalk controlled by the push button?" We believe this guideline should include a requirement for the directionality of pushbuttons.
1108 Detectable Warnings
We respectfully suggest that the language in this section be strengthened to clarify that the "square" grid pattern must be aligned with the direction of the ramp. We also suggest that, in deference to wheelchair users, the range of permitted center-to-center dome spacing under 1108.1.2 be reduced to the largest end of the range and that the minimum base-to-base spacing be increased to 1 inch
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
J. Tom Coleman Jr., October 25, 2002
Georgia Department of Transportation
Subject: Comments on the proposed "Guidelines for Accessible Public Rights-of-Way"
Dear Mr. Windley:
The Georgia Department of Transportation (GDOT) completely agrees with the concept of the ADA that no person should be denied services because that person has a disability. The GDOT has reviewed the proposed "Guidelines for Accessible Public Rights-of-Way" dated June 17, 2002. Based on the review, some of the requirements should be given further consideration before implementation.
The GDOT has also reviewed the AASHTO comments on the proposed ADA guidelines and agree with their recommendations. The GDOT comments were developed independently but address many of the same issues.
Several of the proposed requirements will have major impacts on project design on required Rights-of-Way. If the plans for a project are near completion, the plans would need to be changed, the Environmental Document would need to be reevaluated and additional R/W would need to be acquired which will result in a considerable delay in letting the project for construction. When the text of the document has been finalized, the required implementation date should be given careful consideration.
Attached are the GDOT comments on the proposed ADA guidelines for public Rights-of-Way.
Sincerely,
Signed by Commissioner Coleman
J. Tom Coleman Jr.
Commissioner
Attachments
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Comments on the Proposed ADA Guidelines for Accessible Public R/W
The Georgian Department of Transportation (GDOT) completely agrees with the concept of the ADA that no person should be denied services because that person has a disability. However, the proposed "Guidelines for Accessible Public Rights-of-Way" dated June 17,2002 specify some requirements that we feel should be given further consideration before implementation.
The GDOT has reviewed the AASHTO comments on the Proposed ADA Guidelines and agrees with their recommendations. The GDOT comments were developed independently but address many of the same issues.
Overview:
Several of the major issues are addressed in general in the Synopsis. More specific comments are addressed in the responses to the individual sections.
The ACCESS BOARD has received many comments that have been posted on their website.
The comments seemed to fit into two categories. The first type response was from persons with disabilities or groups representing persons with disabilities. These comments were generally short and contained references to specific items. Sometimes the comments were in support of or opposed to an item. For example, the visually impaired groups generally supported the detectable warnings at the bottom of the ramps and the groups representing persons with mobility and balance disabilities considered the detectable warnings a tripping hazard to walkers and an inconvenience to persons in wheelchairs. The varied responses from the persons with different viewpoints indicate that there is no solution that satisfies all users in all situations.
The second type of response was from persons or groups that will implement the design requirements. These responses were generally longer and pointed out that many of the requirements would have consequences that the Access Board and the individual members of the Board had not intended or anticipated. Often these responses could be summarized by the following statement: Change the "design requirements" to "design recommendations." This will allow the Engineer to consider all the factors influencing the area in the design of the project.
Following the same thought, as written the only allowable reason for not meeting ALL the design requirements is if it is "Technically Infeasible" to meet the requirements. (And this is only allowed on "alterations", new construction must meet all the Design Requirements.) Technically Infeasible is not defined in the ROW section but a definition is needed. Also, the DOJ Title II Technical Assistance Manual specifically states that when determining Technical Infeasibility, cost is not to be considered. When a roadway type project is being constructed on the R/W, and enough money is available, anything can be built, therefore nothing is technically infeasible. In a slight contradiction, the DOJ CFR states that if you have to remove a load bearing wall in a building then complying with the design requirements is Technically Infeasible. More guidance is required.
The Dept. of Justice, Housing and Urban Development, Dept. of Interior, Dept. of Labor and possibly other agencies have included guidance for not meeting the ADA design requirements in their respective CFRs. Some of the guidance is not in complete agreement but generally they allow deviation from the Design Requirements due to "Technical Infeasibility", "Conflicts with existing law to protect historic resources", "Disproportionality" of the cost of satisfying all the ADA design requirements with the project cost, "Undue Administrative Burden", "Undue Financial Burden" and "Fundamental Alteration of the Nature of the Service". The various CFRs generally require that the head of the agency approve the deviation from the Design Requirements. The FHWA CFR simply states that "wheel chair ramps and other features that may be required to meet ADA are required". The FHWA is the agency that oversees most federal monies spent on public R/W. The FHWA has not provided any usable guidance (that the ADA required them to provide by 1992) on when exceptions to the ADA Design Requirements are justified therefore, the guidance must be included in this document. Also, it is unclear whether guidance included it this document or guidance included in the various CFRs will control.
To follow up on the "unintended consequences" of these requirements, if cost cannot be considered when determining technical infeasibility and if the design parameters are adopted exactly as written, many urban projects will not be built. The disruption to the adjacent properties and the surrounding communities will be too severe. The end result of these requirements (to provide a high level of accessibility) will be less accessibility in areas that would have been improved. The changes to the proposed ADA Design Requirements that the GDOT proposes are to ensure that this is not the result of the ADA Design Requirements.
Whether or not cost can be DIRECTLY considered when determining whether it is necessary to comply with the ADA Design Requirements, the cost of compliance WILL be considered. The funding of projects for new roadways and roadway improvements may seem to be infinite to persons not familiar with the magnitude of these projects, however there is a limited amount of money available and an infinite demand for these funds. Also, the funding is usually divided into categories and specified for certain uses. (For example, resurfacing, intersection improvement, Interstate Highways, bridge rehabilitation, etc.) If one project is very costly, either the project will not be constructed or other projects in that funding category will not be constructed in order to fund the project that is constructed.
The GDOT believes that the intent of the ADA was to provide better access (and service) to everyone (including persons with disabilities), not lower the level of access (and service) to everyone equally.
There is an article in the 9/19/02 edition of the Govt. Computer News about problems providing GIS maps over the Internet. The information has to be provided in usable form to all users to comply with Section 508 of the 1998 ADA Amendment. It would be unfortunate (but not unexpected) if this service was withheld from all citizens in order to comply with the ADA. There is no technology available for blind users to obtain the same information (in an easily useable format) that sighted users obtain, therefore the result may be less service for everyone. (Including the blind person that previously had a sighted friend or family member obtain and interpret the information.)
The ADA does not require that sidewalks be included in roadway projects but if sidewalks are provided the ADA requires that they must be useable by all users. If this premise is used to judge the requirements listed in the "Guidelines for Accessible Public Rights-of-Way", some of the requirements do not appear to fall under ADA regulation. For example, requirements for traffic signals where none would be required except by these guidelines. The GDOT recommends that all the requirements be reviewed and any requirements that are not definitely issues covered by the ADA be removed or changed to recommendations.
There appear to be some discrepancies in the commentary and between the commentary and the proposed text. For example: Commentary 1102.1 "The draft guidelines would not require the provision of sidewalks, street crossings, street furniture, parking or other pedestrian elements where none are intended." Commentary 1105.2 - Crosswalks - "?specifications apply to both marked and unmarked crossings, wherever pedestrian travel is not prohibited." TEXT 1102.1 "All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities ? shall comply with Chapter 11.
The final document should be clear and concise. The commentary provided should clarify and provide examples for the Design Requirements. All discrepancies in the commentary (from the text of the requirements) should be omitted or clearly noted as minority opinions.
There are also some discrepancies between the proposed Chapter 11 requirements the previous sections (Ramps are also addressed in Chapter 405 and Curb Ramps are also addressed in Chapter 406). If the requirements are different on public R/W it should be noted in the other chapters whenever there is a difference.
Several of the design requirements for cross slope, grade breaks, etc. are covered in "1103 Pedestrian Access Route". The same requirements are duplicated other sections (ramps, transitions, crosswalks etc.). Consider eliminating the requirements from the other sections since by definition these areas are part of the "Pedestrian Access Route".
The guideline commentary stated "guidelines depart from the advisory committee's report in several areas, which are detailed in the following discussion." There are several items that differ from the Jan. 2001 report in the proposed text that are not discussed. (Possibly "Changes in level" (1103.8) should be "Grade Breaks" and "Grade Breaks" (1104.3.40) should be omitted.)
As an aside: There was an ADA seminar presented in Atlanta last year. Several of members of the Public R/W committee were present. Several questions were posed about the effect of implementing various design parameters. A common answer was "Oh, you would not have to meet that requirement, it isn't reasonable in that case". As written, the requirements do not allow for that solution. The only acceptable solution is "MEET THE DESIGN PARAMETERS".
The SCOPING REQUIREMENTS section needs to be expanded and clarified. Chapter 1102.2.2 states "Where existing elements or spaces in the public R/W are altered, each altered element shall comply with the applicable provisions of Chapter 11."
When a road is resurfaced the crosswalks are altered. This provision requires the cross slope to be less that 2.08% in the crosswalk. This requires that the intersection be "tabletopped" and requires vertical grade changes all of the approach roadways. This requirement will essentially prohibit any resurfacing projects in urban areas where any existing grade or crossslope in the intersection exceeds 2%. (Even if the project would remove severe ruts, vertical lips, and potholes in the crosswalk that make the existing crosswalk unusable for pedestrians with disabilities.)
The "tabletopping requirement will have severe negative impacts on all projects where the natural terrain slopes exceed 2%.
The commentary on 1105.2 - Crosswalks - that states that "?specifications apply to both marked and unmarked crossings, wherever pedestrian travel is not prohibited." If this is intended to be a true statement, it should be reconsidered. Other sections require a pedestrian activated signal where a right turn slip lane is present. A "slip lane" definition should be added but the figures show a right turn movement separated by an island. This would require a traffic signal at nearly every intersection on a multilane road. Also, when a business obtains a driveway access permit on a corner, GDOT requires the addition of a right turn lane. This provision would also require a signal at the intersection (which the developer would be happy to do since it would increase the value of his business). The MUTCD has very specific warrants for the installation of signals that are based on years of experience to provide the best compromise between motorist safety, pedestrian safety and overall usability of the Rights-of-Way. If the Access Board decides that these warrants should be ignored, the decision to ignore them should be based on documented research.
Most GDOT projects are "alterations" in some (or many) respects. For instance even a new roadway on a new location generally follows the existing terrain and crosses existing roads that have homes and businesses near the newly created intersection (or interchange). In the design process we attempt to minimize the impact on these homes and businesses while providing a road that is safe for the traveling public.
As written, the guidelines only allow a deviation from the design parameters when the project is an "alteration" (or where an "addition" project connects with existing construction) and when it is "technically infeasible" to meet the requirement. (Although the Chapter 2 Scoping Requirements in the ABA/ADA final draft commentary (p16) mentions "disproportionality" it is not mentioned in the actual text.)
Additional guidance on what is "technically infeasible" should be provided. When building a road it is usually "technically feasible" to do anything if enough money is available.
The 1999 publication "Accessible Rights of Way, A Design Guide" has a more realistic approach for not meeting the ADA design requirements. "Technically Infeasible", "Fundamental Alteration of the Nature of the Project" and "Undue Burden" were mentioned as justification for not fully complying with the design requirements.
Note that the GDOT has a finite amount of money available. If complying with all of the ADA design parameters adds excessive cost to a project then fewer projects will be built. The overall effect will be fewer projects constructed and fewer accessibility improvements therefore there will be less overall benefit provided to disabled users. (For example, table-topping an intersection in a lightly populated area as part of a major roadway reconstruction project could easily cost an additional $ 2 million on a $20 million contract. That $ 2 million could upgrade 2 or 3 intersections in a highly urbanized area with large numbers of pedestrians.)
The CFR for the Dept. of Justice, Labor, HUD give guidelines on when exceptions to the ADA design parameters are justified. (But the justifications are not the same.) In order to provide consistency in implementing these requirements this information should be included in the Accessibility Guidelines.
For example:
CFR 35.150 states:
A public entity shall operate each service, program, or activity so that the service, program, or activity, when viewed in its entirety, is readily accessible to and usable by individuals with disabilities. This paragraph does not --
(1) Necessarily require a public entity to make each of its existing facilities accessible to and usable by individuals with disabilities;
(2) Require a public entity to take any action that would threaten or destroy the historic significance of an historic property; or
(3) Require a public entity to take any action that it can demonstrate would result in a fundamental alteration in the nature of a service, program, or activity or in undue financial and administrative burdens. In those circumstances where personnel of the public entity believe that the proposed action would fundamentally alter the service, program, or activity or would result in undue financial and administrative burdens, a public entity has the burden of proving that compliance with § 35.150(a) of this part would result in such alteration or burdens. The decision that compliance would result in such alteration or burdens must be made by the head of a public entity or his or her designee after considering all resources available for use in the funding and operation of the service, program, or activity, and must be accompanied by a written statement of the reasons for reaching that conclusion. If an action would result in such an alteration or such burdens, a public entity shall take any other action that would not result in such an alteration or such burdens but would nevertheless ensure that individuals with disabilities receive the benefits or services provided by the public entity.
The GDOT recommends the wording in this section be expanded to address situations where it is not necessary to meet all the design requirements and included in these guidelines. This section should describe and give guidance on "Technically Infeasible", "Fundamental Alteration of the Nature of the Project", "Undue Burden", Undue Financial Burden", and "Disproportionality". The section should also address how to handle conflicts with other Federal laws that deal with preserving historical and archeological sites, wetlands, and other natural resources. This section should also address the level of documentation and level of approval required.
Making the design parameters "recommendations" instead of "requirements" would solve many of these problems.
As written it is not defined precisely where pedestrians must be accommodated on the public R/W. This should be addressed.
GDOT Commentary: It seems that the disruption to the surrounding area, cost, and impacts on the safety of the motorists should be weighed against the need for pedestrian accommodation. This should be an Engineering Decision not a mandated requirement. The GDOT often uses curb and gutter and sidewalks to minimize the R/W requirements (or stay on existing R/W) not to provide pedestrian accommodations. Without relaxation of the design requirements (or allowing engineering judgement) many projects will not be built. The projects improve usability (even though they might not meet all the design requirements) for disabled users.
When the text of the document has been finalized, the required implementation date should be given careful consideration. Several of the proposed requirements will have major impacts on the design of the project and on the required Rights-of-Way. A lead time of 2 years would not be unreasonable for full compliance with some of the proposed requirements. This would allow time to reevaluate the Environmental Document, change the plans and acquire the additional Rights-of-Way.
The following is the Text of the Draft Guidelines for Accessible Public Rights-of-Way with GDOT comments and recommended changes noted.
1101 Application and Administration (referenced standards and defined terms)
1102 Scoping Requirements
1103 Pedestrian Access Route
1104 Curb Ramps and Blended Transitions
1105 Pedestrian Crossings
1106 Accessible Pedestrian Signal Systems
1107 Street Furniture
1108 Detectable Warning Surfaces
1109 On-Street Parking
1110 Call Boxes
1111 Alternate Circulation Path
1101 Application and Administration
1101.1 General. For the purposes of these requirements, the terms listed in section 1101.3 shall have the indicated meaning.
1101.2 Referenced Standards.
1101.2.1 MUTCD. Copies of the referenced standards may be obtained on-line from the Federal Highway Administration at http://mutcd.fhwa.dot.gov/.
MUTCD 2000-Millennium Edition Manual on Uniform Traffic Control Devices.
GDOT Comment - Add AASHTO 2001 Design Guide to the list on standards
1101.3 Defined Terms.
GDOT Comments -
Add definitions for:
Slip Ramp
Perpendicular Curb Ramp
Parallel Curb Ramp
Addition
Alteration
Blended Transition
Technically infeasible
Disproportionality
Undue Financial Burden
Undue Administrative Burden
Fundamental Alteration of the Nature of the Project
Agency that approves ADA design requirements exceptions
GDOT Recommended Definitions -
New facility: A new roadway on new alignment where the horizontal or vertical alignment, or crossslope are not controlled by an existing facility.
Alteration: A project or portion of a project where the horizontal or vertical alignment or crossslope of the roadway are controlled by an existing facility is an "alteration". No alterations may be done that have the effect of decreasing accessibility.
Fundamental alteration in the nature of a project: An improvement that changes the basic concept for the project.
Program Accessibility: If the facility is accessible to people with disabilities through another method or alternative routes, the facility may not be required to comply with all ADA design parameters. Note that curb cut ramps are specifically named as a required element and cannot be excluded.
Undue financial burden: If the cost of providing or maintaining a facility that fully complies with ADA design parameters is prohibitively expensive or the required future funding is not guaranteed, full compliance with the ADA design parameters may be considered an undue financial burden.
For small projects, if complete compliance with the ADA design parameters adds over 20% to the total cost of the project, complete compliance is not required (but should be considered). However, the facilities shall be improved to the maximum extent possible using the 20% additional costs.
For large projects, if complete compliance with the ADA design parameters adds over 20% to the cost of the area of the project where the improvement is needed, complete compliance is not required (but should be considered). However, the facilities shall be improved to the maximum extent possible using the 20% additional costs. (This is intended to address major alteration projects where small areas are not in compliance with the ADA design parameters.)
Disproportional: If the cost of constructing a project (or portion of a project) that fully complies with ADA design parameters is prohibitively expensive full compliance with the ADA design parameters may be considered Disproportional.
For small projects, if complete compliance with the ADA design parameters adds over 20% to the total cost of the project, complete compliance is not required (but should be considered). However, the facilities shall be improved to the maximum extent possible using the 20% additional costs.
For large projects, if complete compliance with the ADA design parameters adds over 20% to the cost of the area of the project where the improvement is needed, complete compliance is not required (but should be considered). However, the project shall meet the ADA Design Requirements to the maximum extent possible using the 20% additional costs. (This is intended to address major projects where small areas are not in compliance with the ADA design parameters.)
Technically infeasible: If complying with the ADA design parameters require that the roadway alignment, grade, sight distance or clear zone not to meet AASHTO desirable requirements then complying with ADA design parameters is "technically infeasible".
Conflicts with other laws that protect historical, cultural, or natural resources make complying with ADA design parameters "technically infeasible".
Note that if complete compliance is "technically infeasible" the facility shall be modified to comply with ADA design parameters to the "maximum extent possible".
Accessible Pedestrian Signal. A device that communicates information about the pedestrian WALK phase in non-visual format.
Accessible Route. A continuous, unobstructed path that complies with Chapter 4.
GDOT Comment:
The definition of Accessible Route should be clarified. It is not clear whether shoulders are an "accessible route" on a road with no curb and gutter and/or no sidewalk.
Channelizing Island. Curbed or painted area outside the vehicular path that is provided to separate and direct traffic movement, which also may serve as a refuge for pedestrians.
Cross Slope. The slope that is perpendicular to the direction of travel. This is usually called superelevation on curves in the public right-of-way (see superelevation).
Crosswalk. That part of a roadway at an intersection that is included within the extensions of the lateral lines of the sidewalks on opposite sides of the roadway, measured from the curbline or, in the absence of curbs, from the edges of the roadway or, in the absence of a sidewalk on one side of the roadway, the part of the roadway included within the extension of the lateral lines of the sidewalk at right angles to the centerline. Also, any portion of a roadway at an intersection or elsewhere that is distinctly indicated for pedestrian crossing by lines or other markings on the surface.
GDOT Comment:
The definition of crosswalk appears to say that a crosswalk is only present if there is sidewalk present or if there is a "marked" crosswalk. While this definition makes it easier to comply with the ADA Design Requirements, it appears to conflict with the text of in other sections of the requirements and with the commentary.
Curb Line. A line at the face of the curb that marks the transition between the sidewalk and the gutter or roadway.
Curb Ramp. A ramp cutting through a curb or built up to it.
Detectable Warning. A surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path.
Dynamic Envelope. The clearance required for a rail vehicle and its cargo overhang due to any combination of loading, lateral motion, or suspension failure.
Element. An architectural or mechanical component of a building, facility, space, site or public right-of-way.
Facility. All or any portion of buildings, structures, improvements, elements and pedestrian or vehicular routes located on a site or in a public right-of-way.
Grade. (See running slope).
Grade Break. The meeting line of two adjacent surfaces of different slope (grade).
Locator Tone. A repeating sound that identifies the location of the pedestrian push button.
Pedestrian Access Route. An accessible corridor for pedestrian use within the public right-of-way.
GDOT Recommended Definition
Pedestrian Access Route. An accessible route, designated by the responsible agency, for pedestrian use within the public right-of-way.
This will allow the "rural" projects to be excluded from ADA requirements.
Public Right-of-Way. Land or property, usually in a corridor, that is acquired for or devoted to transportation purposes.
Roundabout. A circular intersection that has yield control of entering traffic, channelized approaches, counterclockwise circulation, and appropriate geometric curvature to limit travel speeds on the circulatory roadway.
Running Slope. The slope that is parallel to the direction of travel expressed as a ratio of rise to run. In the public right-of-way, this is usually called grade, and is expressed in percent.
Sidewalk. That portion of a public right-of-way between the curb line or lateral line of a roadway and the adjacent property line that is improved for use by pedestrians.
GDOT Comment:
What does "improved for use by pedestrians" mean? We are concerned that this could be interpreted to mean shoulders on "rural" projects or the flat graded area behind the curb if no concrete sidewalk is present.
This definition is critical. For instance if the paved shoulder is a "sidewalk", the ADA design requirements apply to rural projects. The GDOT requires separate right turn lanes on multilane rural roads at all intersections as a safety feature to allow the right turning traffic to move out of the high speed travel lanes. These requirements would mandate that pedestrian activated signals with locator tones be provided at essentially all intersections.
Splitter Island. A flush or raised island that separates entering and exiting traffic in a roundabout.
Street Furniture. Elements in the public right-of-way that are intended for use by pedestrians.
Superelevation. Cross slope on a curve in the roadway (see cross slope).
Walk Interval. That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and its audible equivalent.
1102 Scoping Requirements
1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way shall comply with Chapter 11.
GDOT Recommended wording:
1102.1 General. All areas of newly designed and newly constructed facilities in public rights-of-way and altered portions of existing facilities in public rights-of-way that include provisions for pedestrians shall comply with Chapter 11.
GDOT Comment:
The SCOPING REQUIREMENTS need to be expanded and clarified. If the exceptions recommended in 1102.2.2 (specifically Fundamental Alteration of the Nature of a Project are not allowed, when a road is resurfaced the crosswalks are altered. This provision requires the cross slope to be less that 2.08% in the crosswalk. This requires that the intersection be "tabletopped" and requires vertical grade changes all of the approach roadways. This requirement will essentially prohibit any resurfacing projects in urban areas where any existing grade or crossslope in the intersection exceeds 2%. (Even if the project would remove severe ruts, vertical lips, and potholes in the crosswalk that make the existing crosswalk unusable for pedestrians with disabilities.)
The same situation will exist if a traffic signal needs to be upgraded. As written, a signal could not be upgraded to allow for protected pedestrian movements without "tabletopping" the intersection.
1102.2 Existing Public Rights-of-Way. Additions to existing public rights-of-way shall comply with 1102.2.1. Alterations to existing public rights-of-way shall comply with 1102.2.2.
1102.2.1 Additions. Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2.
1102.2.2 Alterations. Where existing elements or spaces in the public right-of-way are altered, each altered element or space shall comply with the applicable provisions of Chapter 11.
GDOT Comment: Define Spaces as used above.
EXCEPTION: In alterations, where compliance with applicable provisions is technically infeasible, the alteration shall comply to the maximum extent feasible.
GDOT Recommended Wording
EXCEPTION: In alterations, the project shall comply with applicable provisions unless the following applies. If full compliance is not required, the alteration shall comply to the maximum extent feasible.
A public entity shall operate each service, program, or activity and construct each project so that the service, program, or activity, and constructed project when viewed in its entirety, is readily accessible to and usable by individuals with disabilities. This paragraph does not --
(1) Necessarily require a public entity to make all areas of its existing facilities accessible to and usable by individuals with disabilities; or
(2) Require a public entity to take any action that would threaten or destroy the historic significance of an historic property; or that conflict with other laws that protect natural or archeological resources or cemeteries; or
(3) Require a public entity to take any action that is technically infeasible; or
(4) Require a public entity to take any action that it can demonstrate would result in a fundamental alteration in the nature of a service, program, or activity or in undue financial and administrative burdens or in a fundamental alteration of the nature of the project. Also, if the additional cost of fully complying with the ADA Design Requirements exceeds 20% of the cost of the project in the area affected by the improvement, full compliance may be considered "Disproportional" to the cost of constructing that area of the project. In those circumstances where personnel of the public entity believe that the proposed action would fundamentally alter the project, service, program, or activity, or the cost is disproportional or would result in undue financial and administrative burdens, a public entity has the burden of proving that compliance would result in such alteration or burdens. The decision that compliance would result in such alteration or burdens must be made by the head of a public entity or his or her designee after considering all resources available for use in the funding and operation of the service, program, or activity, and must be documented by a written statement of the reasons for reaching that conclusion. If an action would result in such an alteration or such burdens, a public entity shall take any other action that would not result in such an alteration or such burdens but would nevertheless ensure that individuals with disabilities receive the benefits or services provided by the public entity.
1102.2.2.1 Extent of Application. An alteration of an existing element, space, or area of a public right-of-way shall not impose a requirement for accessibility greater than required for new construction.
1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way, below the requirements for new construction at the time of the alteration is prohibited.
GDOT Comment: As worded it appears redundant. The GDOT wording states that regardless of what exceptions may be approved the accessibility cannot be less that before the project was constructed.
GDOT Recommended wording:
1102.2.2.2 Prohibited Reduction in Access. An alteration that decreases or has the effect of decreasing the accessibility of a public right-of-way or site arrival points to buildings or facilities adjacent to the altered portion of the public right-of-way is prohibited.
1102.3 Alternate Circulation Path. An alternate circulation path complying with 1111 shall be provided whenever the existing pedestrian access route is blocked by construction, alteration, maintenance, or other temporary conditions.
GDOT Comment: The amount of time of the closure and the expected pedestrian usage should be a factor. As written this would require a pedestrian bridge to be constructed if the entire bridge had to be closed for just 10 minutes.
See other comments on 1111
1102.4 Sidewalks. Where sidewalks are provided, they shall contain a continuous pedestrian access route complying with 1103. The pedestrian access route shall connect to elements required to comply with Chapter 11.
1102.5 Protruding Objects. Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes.
1102.5.1 Protrusion Limits. Objects with leading edges more than 27 inches
EXCEPTION: Handrails shall be permitted to protrude 4-1/2 inches
1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps.
1102.5.3 Reduced Vertical Clearance. Guardrails or other barriers shall be provided where the vertical clearance is less than 80 inches
EXCEPTION: Door closers and door stops shall be permitted to be 78 inches
1102.6 Curb Ramps and Blended Transitions. A curb ramp or blended transition complying with 1104, or a combination of curb ramps and blended transitions, shall connect the pedestrian access routes to each street crossing within the width of each crosswalk.
1102.7 Pedestrian Signs. Signs for pedestrian use shall comply with 1102.7.
1102.7.1 Bus Route Identification. Bus route identification signs shall comply with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to the maximum extent practicable, bus route identification signs shall comply with 703.5.5. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with 703.2, and shall have rounded corners.
EXCEPTIONS 1: Bus schedules, timetables and maps that are posted at the bus stop or bus shelter shall not be required to comply with 1102.7.
2: Signs shall not be required to comply with 703.2 where audible signs are user- or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual.
1102.7.2 Informational Signs and Warning Signs. Informational signs and warning signs shall comply with 703.5.
1102.8 Pedestrian Crossings. Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, they shall comply with 1106.
1102.9 Street Furniture. Street furniture that is intended for use by pedestrians and installed on or adjacent to a sidewalk shall comply with 309 and 1107.
1102.10 Stairs. Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
1102.11 Handrails. Where provided, handrails shall comply with 505.
1102.12 Vertical Access. Where provided elevators shall comply with 407, limited-use/limited-application elevators shall comply with 408, and platform lifts shall comply with 410. Vertical access shall remain unlocked during the operating hours of the facility served.
1102.13 Bus Stops. Bus boarding and alighting areas shall comply with 810.2. Bus shelters shall comply with 810.3.
GDOT comment: The bus stop locations are determined (and often changed) by the local transit authority. The GDOT does not have control on where these are placed and often the bus stops a several locations along a block. In many areas that have bus service there is not space available to provide these landings at all bus stops without severe disruption of the community. Consider requiring one accessible bus landing per block or every ¼ mile.
1102.14 On-Street Parking. Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.
GDOT Comment: The requirement will generally be achievable. However many of the small towns in Georgia are built with a small square. The blocks are very short and the sidewalks are often elevated. In this situation the addition of the accessible parking space (and an access route to the elevated sidewalk) would eliminate most or all the remaining spaces in the block. This would effectively put the businesses on the Town Square out of business. Often the entrances to the businesses are not accessible from the sidewalk due to steps. This requirement would provide access to the sidewalk in front of the businesses but would not provide access to the business.
This is another example of where "Engineering Judgement" should be used instead of a mandated requirement.
1102.15 Passenger Loading Zones. Where passenger loading zones are provided, they shall connect to a pedestrian access route and shall provide a minimum of one passenger loading zone in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof, complying with 302, 503.2, 503.3, and 503.5.
1102.16 Call Boxes. Where provided, call boxes shall comply with 1110.
1103 Pedestrian Access Route
1103.1 General. Pedestrian access routes shall connect to elements required to be accessible and shall comply with 1103.
1103.2 Components. Pedestrian access routes shall consist of one or more of the following components: walking surfaces, ramps, curb ramps, blended transitions, crosswalks, pedestrian overpasses and underpasses, elevators, and platform lifts. All components of a pedestrian access route shall comply with the applicable portions of this chapter.
1103.3 Clear Width. The minimum clear width of a pedestrian access route shall be 48 inches
1103.4 Cross Slope. The cross slope of the pedestrian access route shall be 1:48
Also, see comments on crosswalks (which are a part of the pedestrian access route).
The requirement for a 1:48
1103.5 Grade. The grade of the pedestrian access route within a sidewalk shall not exceed the grade established for the adjacent roadway.
EXCEPTION: The running slope of a pedestrian access route shall be permitted to be steeper than the grade of the adjacent roadway, provided that the pedestrian access route is less than 1:20
1103.6 Surfaces. The surfaces of the pedestrian access route shall comply with 302.
1103.7 Surface Gaps at Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the horizontal gap at the inner edge of each rail shall be constructed to the minimum dimension necessary to allow passage of railroad car wheel flanges and shall not exceed 2-½ inches (64 mm).
EXCEPTION: On tracks that carry freight, a maximum horizontal gap of 3 inch
1103.7.1 Detectable Warnings. Where rail systems cross pedestrian facilities that are not shared with vehicular ways, a detectable warning shall be provided in compliance with 1108.
1103.8 Changes in Level. Changes in level shall comply with 303. Changes in level shall be separated horizontally 30 inches
GDOT Comment: 303 allows a ¼" max vertical lip, ¼" to ½" beveled on 1:2
EXCEPTION: The horizontal separation requirement shall not apply to detectable warnings.
GDOT Comment: What horizontal separation requirement? It is unclear what this means even if a horizontal separation requirement is specified.
1103.8.1 Rail Crossings. Where the pedestrian access route crosses rail systems at grade, the surface of the pedestrian access route shall be level and flush with the top of the rail at the outer edge and between the rails.
1104 Curb Ramps and Blended Transitions
1104.1 General. Curb ramps and blended transitions shall comply with 1104.
1104.2 Types. Perpendicular curb ramps shall comply with 1104.2.1 and 1104.3; parallel curb ramps shall comply with 1104.2.2 and 1104.3; blended transitions shall comply with 1104.2.3 and 1104.3.
1104.2.1 Perpendicular Curb Ramps. Perpendicular curb ramps shall comply with 1104.2.1, and shall have a running slope that cuts through the curb at right angles or meets the gutter grade break at right angles.
1104.2.1.1 Running Slope. The running slope shall be 1:48
1104.2.1.2 Cross Slope. The cross slope shall be 1:48
EXCEPTION: This requirement shall not apply to mid-block crossings.
1104.2.1.3 Landing. A landing 48 inches
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.
EDITORIAL COMMENT: The cross slope and running grade requirements do not apply at mid-block crossings 1104.2.1.3). If "Engineering Judgement" cannot be used, all pedestrian crossings at intersections can be prohibited and mid-block crossings provided. Is this the intention of these requirements?
1104.2.1.4 Flares. Flared sides with a slope of 1:10
1104.2.2 Parallel Curb Ramps. Parallel curb ramps shall comply with 1104.2.2, and shall have a running slope that is in-line with the direction of sidewalk travel.
1104.2.2.1 Running Slope. The running slope shall be 1:48
EXCEPTION: A parallel curb ramp shall not be required to exceed 15 feet
1104.2.2.2 Cross Slope. The cross slope shall be 1:48
1104.2.2.3 Landing. A landing 48 inches
GDOT Comment: This is a major problem. See comments on crosswalk cross slope 1105.2.2. Since this area at the edge of the curb, this can sometimes be accomplished by increasing the radii at the corners to get this are away form the travel lanes to allow room for warping the slope, but this increases the length of the crosswalk. Consider that this will require tradeoffs for the pedestrian.
EXCEPTION: Running and cross slope requirements shall not apply to mid-block crossings.
1104.2.2.4 Diverging Sidewalks. Where a parallel curb ramp does not occupy the entire width of a sidewalk, drop-offs at diverging segments shall be protected with a barrier.
1104.2.3 Blended Transitions. Blended transitions shall comply with 1104.3, and shall have running and cross slopes of 1:48
1104.3 Common Elements. Curb ramps and blended transitions shall comply with 1104.3.
1104.3.1 Width. The clear width of landings, blended transitions, and curb ramps, excluding flares, shall be 48 inches
1104.3.2 Detectable Warnings. Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.
1104.3.3 Surfaces. Surfaces of curb ramps, blended transitions, and landings shall comply with 302. Gratings, access covers, and other appurtenances shall not be located on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route.
1104.3.4 Grade Breaks. Grade breaks shall not be permitted on curb ramps, blended transitions, landings, and gutter areas within the pedestrian access route. Surface slopes that meet at grade breaks shall be flush.
GDOT comment: Where did this come from? It appears to be impossible to meet this requirement unless the entire intersection is on the same slope (no crown in the roadways). Also, does flush mean less than the 1/4" vertical lip allowed in the pedestrian access route?
1104.3.5 Changes in Level. Vertical changes in level shall not be permitted on curb ramps, blended transitions, landings, or gutter areas within the pedestrian access route.
GDOT comment: If the intent is to require no vertical lips (0" allowable) in these areas it is impossible to meet. If the ¼" allowed in the pedestrian access path it is OK this requirement is redundant.
1104.3.6 Counter Slopes. The counter slope of the gutter area or street at the foot of a curb ramp or blended transition shall be 1:20
GDOT comment: This is OK but it is not what the 2001 report recommended. A definition or picture of "counter slope" would be good.
1104.3.7 Clear Space. Beyond the curb line, a clear space of 48 inches
GDOT comment: The 4x4 clear area is required to begin beyond the curb line. Since the gutter slope only is required to be 5% or less in this area, Can the 4x4 area can include the gutter if the gutter slope is 2.08%? This should be clarified.
1105 Pedestrian Crossings
1105.1 General. Pedestrian crossings shall comply with 1105.
1105.2 Crosswalks. Crosswalks shall comply with 1105.2.
1105.2.1 Width. Marked crosswalks shall be 96 inches
1105.2.2 Cross Slope. The cross slope shall be 1:48
GDOT comment: This is a major problem, especially if reasonable grounds for exceptions are not provided. This requires "tabletopping" the intersection and adjusting the grades on the approaches. If one of the roads is in a curve where the superelevation is greater than 2.08% it requires a change in the horizontal alignment.
GDOT recommendation: Change "The cross slope shall" to "When practical the cross slope should".
EXCEPTION: This requirement shall not apply to mid-block crossings.
1105.2.3 Running Slope. The running slope shall be 1:20
GDOT comment: This is a problem, especially if reasonable grounds for exceptions are not provided and the cross slope requirements are changed. If the cross slope requirements are not change this requirement is meaningless and will not control. This requires changing the grade in the intersection and adjusting the grades on the approaches to less than 5 %. If one of the roads is in a curve where the superelevation is greater than 5% it requires a change in the horizontal alignment.
GDOT recommendation: Change "The running slope shall" to "When practical the cross slope should".
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
GDOT comment: Currently the GDOT normally uses 3.5 fps that was recommended in the Jan. 2001 report. The speed is reviewed on a case by case basis and 3.0 fps or sometime less is used depending on the type of the pedestrians at the intersection. It is possible to set the signal timing for a pedestrian speed of 3 feet
1105.4 Medians and Pedestrian Refuge Islands. Medians and pedestrian refuge islands in crosswalks shall comply with 1105.4 and shall be cut through level with the street or have curb ramps complying with 1104 and shall contain a pedestrian access route complying with 1103. Where the cut-through connects to the street, edges of the cut-through shall be aligned with the direction of the crosswalk for a length of 24 inches
1105.4.1 Length. Where signal timing is inadequate for full crossing of all traffic lanes or where the crossing is not signalized, cut-through medians and pedestrian refuge islands shall be 72 inches
GDOT Comment: The 6 foot
1105.4.2 Detectable Warnings. Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24 inch
EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing.
1105.5 Pedestrian Overpasses and Underpasses. Pedestrian overpasses and underpasses shall comply with 1105.5.
1105.5.1 Pedestrian Access Route. Pedestrian overpasses and underpasses shall contain a pedestrian access route complying with 1103.
1105.5.2 Running Slope. The running slope shall not exceed 1:20
1105.5.3 Approach. Where the approach exceeds 1:20
GDOT Comment: The requirement to require elevators at pedestrian overpasses / underpasses where the total rise / fall of the ramps is over 60 inches
1105.5.4 Stairs. Stairs shall comply with 504.
1105.5.5 Escalators. Escalators shall comply with 810.9.
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
GDOT Comment: The GDOT agrees that it is a challenge for a pedestrian (especially a vision-impaired pedestrian) to cross a roundabout. However adding pedestrian signals to the roundabout not only decreases the capacity of the intersection it violates driver expectations and provides the pedestrians with a false since of security. The GDOT feels that this requirement would increase vehicular accidents (mostly rear-end collisions) and increase pedestrians accidents. The only advantage to it would be that the driver could be charged with running a traffic light in addition to failing to yield to a pedestrian. As an aside, the definition of roundabout states "an intersection that has yield control?". If this requirement is implemented the definition is wrong.
1105.6.1 Separation. Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
If the discussion in the commentary that states crosswalks are wherever pedestrians crossing are not prohibited is true, the requirement for a pedestrian actuated signal at right and left turn slip lanes should be reconsidered. On most multilane roads the GDOT constructs right turn lanes to allow the turning traffic to get out of the through lanes. This is done to reduce accidents by providing a safer right turn. As written, this requires a pedestrian activated signal (even if a pedestrian is at the intersection just once every 6 months). This is not only very costly and provides very little benefit; it violates driver expectations and will result in increased accidents and probably increase pedestrian accidents. (see roundabout discussion)
Another consideration for not providing the pedestrian activated signal at all slip lanes and roundabouts: In some area of the state, persons (and sometimes organized groups of persons) solicit handouts at intersections. These persons benefit from stopped traffic. The pedestrian signal would continually be activated by these persons (resulting in traffic congestion) even if no pedestrian was attempting to use the crosswalk.
1106 Accessible Pedestrian Signal Systems
1106.1 General. Pedestrian signal systems shall comply with 1106.
The signal that re
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
1106.2.1 Location. Pedestrian signal devices shall be located 60 inches
EXCEPTION: The minimum distance from other signal devices shall not apply to signal devices located in medians and islands.
1106.2.2 Reach and Clear Floor or Ground Space. Pedestrian signal devices shall comply with 308. A clear floor or ground space complying with 305 shall be provided at the signal device and shall connect to or overlap the pedestrian access route.
1106.2.3 Audible Walk Indication. The audible indication of the WALK interval shall be by voice or tone.
1106.2.3.1 Tones. Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds
1106.2.3.2 Volume. Tone or voice volume measured at 36 inches
1106.3 Pedestrian Pushbuttons. Pedestrian pushbuttons shall comply with 1106.3.
1106.3.1 Operation. Pedestrian pushbuttons shall comply with 309.4.
1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
1106.3.3 Size and Contrast. Pedestrian pushbuttons shall be a minimum of 2 inches
1106.3.4 Optional Features. An extended button press shall be permitted to activate additional features. Buttons that provide additional features shall be marked with three Braille dots forming an equilateral triangle in the center of the pushbutton.
1106.4 Directional Information and Signs. Pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal.
1106.4.1 Arrow. Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 inch
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.
1106.4.3 Crosswalk Configuration. Where provided, graphic indication of crosswalk configuration shall be tactile and shall comply with 703.5.1.
1107 Street Furniture
1107.1 General. Street furniture shall comply with 1107.
1107.2 Clear Floor or Ground Space. Street furniture shall have clear floor or ground space complying with 305 and shall be connected to the pedestrian access route. The clear floor or ground space shall overlap the pedestrian access route 12 inches
1107.3 Drinking Fountains. Where drinking fountains are provided, they shall comply with 602.
1107.4 Public Telephones. Where public telephones are provided, they shall comply with 1107.4.
1107.4.1 Single Telephone. Where a single public telephone is provided, it shall comply with 704.2 and 704.4
1107.4.2 Multiple Telephones. Where a bank of public telephones is provided, at least one telephone shall comply with 704.2, and at least one additional telephone shall comply with 704.4.
1107.4.3 Volume Controls. All public telephones shall provide volume controls complying with 704.3.
1107.5 Public Toilet Facilities. Permanent or portable public toilet facilities shall comply with 603. At least one fixture of each type provided shall comply with 604 through 610. Operable parts, dispensers, receptacles, or other equipment shall comply with 309.
EXCEPTION: Where multiple single-user toilet facilities are clustered at a single location, at least 5 percent, but no fewer than one single-user toilet at each cluster shall comply with 603 and shall be identified by the International Symbol of Accessibility complying with 703.7.2.1.
1107.6 Tables, Counters, and Benches. Tables, counters, and benches shall comply with 1107.6.
1107.6.1 Tables. Where tables are provided in a single location, at least 5 percent but no fewer than one, shall comply with 902.
1107.6.2 Counters. Where provided, counters shall comply with 904.
1107.6.3 Benches. Where benches without tables are provided at a single location, at least 50 percent, but no fewer than one, shall comply with 903 and shall have an armrest on at least one end.
1108 Detectable Warning Surfaces
1108.1 General. Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.
1108.1.1 Dome Size. Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches
1108.1.2 Dome Spacing. Truncated domes in a detectable warning surface shall have a center-to-center spacing of 1.6 inches
1108.1.3 Contrast. Detectable warning surfaces shall contrast visually with adjacent walking surfaces either light-on-dark, or dark-on-light.
1108.1.4 Size. Detectable warning surfaces shall extend 24 inches
1108.2 Location.
1108.2.1 Curb Ramps and Blended Transitions. The detectable warning surface shall be located so that the edge nearest the curb line is 6 inches
1108.2.2 Rail Crossings. The detectable warning surface shall be located so that the edge nearest the rail crossing is 6 inches
1108.2.3 Platform Edges. Detectable warning surfaces at platform boarding edges shall be 24 inches
1109 On-Street Parking
1109.1 General. Car and van on-street parking spaces shall comply with 1109.
1109.2 Parallel Parking Spaces. An access aisle at least 60 inches
GDOT comment: The vehicular travel lane should not include the bike lane, if present.
EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet
1109.3 Perpendicular or Angled Parking Spaces. Where perpendicular or angled parking is provided, an access aisle 96 inches
1109.4 Curb Ramps or Blended Transition. A curb ramp or blended transition complying with 1104 shall connect the access aisle to the pedestrian access route.
1109.5 Obstructions. There shall be no obstructions on the sidewalk adjacent to and for the full length of the space.
EXCEPTION: This provision shall not apply to parking signs complying with 1109.6 and parking meters complying with 1109.7.2.
1109.6 Signs. Parking spaces shall be designated as reserved by a sign complying with 502.6. Signs shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer.
1109.7 Parking Meters. Where parking meters are provided, they shall comply with 1109.7.
1109.7.1 Operable Parts. Operable parts shall comply with 309.
1109.7.2 Location. A parking meter shall be located at the head or foot of the parking space so as not to interfere with the operation of a side lift or a passenger side transfer.
EXCEPTION: Where parking meters are not provided at the space, but payment for parking in the space is included in a centralized collection box or paying station, the space shall be connected to the centralized collection point with a pedestrian access route.
1109.7.3 Displays and Information. Displays and information shall be visible from a point located 40 inches
1110 Call Boxes
1110.1 General. Call boxes shall comply with 1110.
1110.2 Operable Parts. Operable parts shall comply with 308 and 309.4. Where provided, labeling shall comply with 703.2 and 703.3.
EXCEPTION: Mechanically operated systems in which the signal is initiated by a lever pull shall be permitted to have an activating force of 12 lbf
1110.3 Turning Space. A turning space complying with 304 shall be provided at the controls.
1110.4 Edge Protection. Edge protection complying with 405.9.2 shall be provided where the area at the call box is adjacent to an abrupt level change.
1110.5 Motor Vehicle Turnouts. Where provided, a motor vehicle turnout shall have a minimum paved area of 16 feet
1110.6 Two-Way Communication. Where provided, two-way voice communication shall comply with 1110.6, 708.2 and 708.3.
1110.6.1 Volume Controls. Volume controls complying with 704.3 shall be provided.
1110.6.2 TTY. A TTY complying with 704.4 shall be provided.
1111 Alternate Circulation Path
1111.1 General. Alternate circulation paths shall comply with 1111.
Also see comment in 1102.3
1111.2 Width. The alternate circulation path shall have a width of 36 inches
1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
GDOT comment: This should be a recommendation and subject to Engineering judgement. This will require additional easement and may cause additional displacements. Providing a pedestrian route on the same side of the road for a few hours, weeks or months should be weighed against the community impacts. Especially since many existing sidewalks were built to avoid taking homes and there is limited pedestrian usage.
This requirement may reduce the overall safety to the pedestrians since it will provide path near the construction equipment.
On a project where existing bridges with sidewalk on both sides are being widened, this requirement will require pedestrian accommodations on both sides, which will often require a temporary pedestrian bridge (or 2 temporary bridges).
1111.4 Protection. The alternate circulation path shall comply with 307 and shall be protected with a barricade complying with 1111.6 to separate the pedestrian access route and alternate circulation path from any adjacent construction, drop-offs, openings, or other hazards.
GDOT comment: This needs clarification. In the permanent condition the pedestrian on the sidewalk is only protected from traffic by curb(2 feet
1111.5 Signs. Signs complying with 703.5 shall be provided at both the near side and the far side of the intersection preceding a disrupted pedestrian access route.
1111.6 Barricades. Barricades shall be continuous, stable, and non-flexible and shall consist of a solid wall or fence or a Type II or Type III barricade as specified in MUTCD section 6F-60 with the bottom or lower rail 1-1/2 inches
Richard A. Retting, October 25, 2002
Architectural and Transportation Barriers Compliance Board
Draft Guidelines for Accessible Public Rights-of-Way
In response to the Draft Guidelines for Accessible Public Rights-of-Way (June 17, 2002) proposed by the Architectural and Transportation Barriers Compliance Board (Access Board, 2002), the Insurance Institute for Highway Safety opposes the provisions that would mandate installation of traffic signals on pedestrian crosswalks at all roundabouts.
Background
Modern roundabouts are designed to function safely and efficiently without traffic signals and, in most cases, are constructed to replace less safe and less efficient stop sign-controlled intersections. Roundabouts are circular intersections with specific design and traffic control features that eliminate the need for traffic signals. These features include yield control of all entering traffic, channelized approaches with raised splitter islands, and geometric curvature to ensure slow travel speeds for vehicles entering into and within the roundabout.
Roundabouts are relatively new in the United States. Las Vegas, Nevada, built the first modern U.S. roundabout in 1990 (Jacquemart, 1998), and since then only 200-300 roundabouts have been constructed nationwide. In comparison, Australia and many European countries have been installing roundabouts extensively for decades, with, for example, more than 2000 roundabouts built in the Australian state of Victoria alone.
Effects on road safety of converting intersections to roundabouts has been the subject of extensive research in the United States and abroad. Results clearly indicate that roundabouts are an extremely safe form of intersection traffic control. For example, an Institute-supported evaluation of 23 U.S. intersections converted from stop sign or traffic signal control reported large reductions in motor vehicle crashes after roundabouts were installed (Persaud et al., 2001). Overall, crashes were reduced by an estimated 40 percent, injury
crashes declined by 80 percent, and crashes resulting in fatal or
incapacitating injuries were reduced by 90 percent. A recent meta-
analysis of 28 separate roundabout safety evaluations from outside the United States concluded that roundabouts were associated with a 30-50 percent reduction in the number of injury crashes and a 50-70 percent reduction in fatal crashes (Elvik, in press).
Although these studies do not provide conclusive evidence of the safety of pedestrians at roundabouts (primarily because of small samples of pedestrian crashes), available research suggests roundabouts can provide a relatively high degree of safety compared with intersections with stop sign and traffic signal control. For example, in the Persaud et al. (2001) study, four pedestrian crashes were reported during the before period and one was reported during the period after roundabouts were built (this difference was not significant due to the small sample size). Brude and Larsson (2000) analyzed pedestrian crash data at 72 roundabouts in Sweden and concluded that roundabouts pose no problems for pedestrians compared with conventional signal control intersections. For single-lane roundabouts, the observed numbers of pedestrian crashes were 3-4 times lower than for comparable signalized intersections, controlling for pedestrian volumes and traffic flow. Jordan (1985) examined pedestrian crash patterns at roundabouts in Victoria, Australia for the 4-year period 1980-83. A total of 35 pedestrian crashes were reported (average 9 crashes per year) at approximately 800 roundabouts. The author characterized this as an extremely low rate of pedestrian crashes and concluded that "concern for pedestrian safety at roundabouts, while well intentioned, is unfounded." Tumber (1997) conducted a review of pedestrian safety at roundabouts, also in Australia. The study focused on roundabouts constructed on arterial roads within the Melbourne metropolitan area during 1987-94. During this period, 64 pedestrian crashes were reported at approximately 400 roundabouts, for an average crash rate of 0.02 crashes per roundabout per year. The severity of pedestrian crashes (as indicated by the proportion of injuries classified as either serious or fatal) also was lower for roundabouts than for intersections with other forms of traffic control.
The safety of blind pedestrians at roundabouts has been questioned by some advocates of the visually impaired, but direct evaluations of crash data are not available. In an indirect evaluation of the issue, Guth et al. (2002) collected data regarding the ability of blind pedestrians to use their hearing to distinguish "crossable" gaps in traffic at roundabouts from gaps that were considered by the authors too short to afford a safe crossing. This work was supported by the Access Board. Three study sites in Maryland included a low-volume, single-lane roundabout; a large, urban, high-volume, two-lane roundabout; and an urban, intermediate-volume, two-lane roundabout. Six blind and four sighted pedestrians observed traffic at roundabout crosswalks and indicated by pressing a button whenever they believed they could complete a crossing before the arrival of the next vehicle. For the low-volume, single-lane roundabout, gaps between vehicles longer than 10 seconds
2-3 seconds
Despite the finding by Guth et al. (2002) that blind pedestrians can adequately judge gaps at single-lane roundabouts with little difficulty and as well as sighted individuals, the Access Board is proposing guidelines that would require signalization of pedestrian crosswalks at all roundabouts on the basis that the safety of blind pedestrians mandates such devices. This proposed requirement would apply even in rural settings where pedestrian activity is infrequent and where blind pedestrians may be nonexistent. However, traffic signals appear to be unnecessary at single-lane roundabouts and, if mandated, actually could be detrimental to highway safety. It is likely that the arbitrary addition of traffic signals to well designed roundabouts could increase the risk of injury crashes due to disruptions in traffic flow. Also, substantial costs associated with installation and maintenance of traffic signals might discourage some communities from constructing roundabouts. Even for high-volume, two-lane roundabouts, the Guth et al. field study does not make a compelling case for traffic signals because of weaknesses in the research methodology. Blind pedestrians were driven to roundabouts and then observed after minimal exposure to these unfamiliar locations. This is unrealistic because blind pedestrians typically do not wander into such areas without a guide to provide initial orientation. Guth et al. merely provides evidence of the perception of risk, not actual risk. The blind pedestrians may have been more willing to press a button when they believed they could complete a crossing than to begin crossing, thus inflating the numbers of "risky" judgments. Also, comparable data were not collected for intersections controlled by traffic signals or stop signs.
Compared with conventional intersections, roundabouts can provide improved access and safety for blind pedestrians as well as sighted individuals because of specific roundabout design and operational characteristics. First and foremost, traffic speeds within roundabouts are very low -- typically 15-20 mph -- compared with considerably higher traffic speeds at most traffic signal and stop sign-controlled intersections. Pedestrian refuge islands at roundabouts provide for short crossing distances. Also, roundabouts are relatively simple intersections that eliminate left turns, right turns, and the associated turning-vehicle conflicts common at conventional intersections. By comparison, conventional intersections are characterized by higher traffic speeds, longer crossing distances, and are more complex due to two-way traffic flow and frequent vehicle turning movements. Preusser et al. (2002) reported that 25 percent of motor vehicle-pedestrian collisions in Washington D.C. involve turning vehicles.
The combination of low traffic speeds, short crossing distances, and absence of turning vehicles in conjunction with White Cane Laws - laws in 47 states that require drivers to yield the right-of-way to a person carrying a white cane or accompanied by a guide dog --- provide safe crosswalks for blind pedestrian at many roundabouts. Additional measures that could enhance safety include textured pavement in conjunction with ramps to help lead blind pedestrians to crosswalks, raised crosswalks that can further slow entering and exiting traffic, and pedestrian yield signs in both directions of the crossing that require drivers to stop for pedestrians waiting on the crosswalk. Also, specific training can be developed and provided to help the visually impaired perceive gaps in traffic and to give drivers cues to stop.
Signalizing roundabout crossings can be justified when the combined volumes of pedestrians and vehicles are high or at locations with complex geometry such as high-volume school zones. In Australia and Europe, the vast majority of roundabouts are unsignalized, but some roundabouts in urban areas do have pedestrian signals. The recommended threshold for signalizing pedestrian crossings in the United Kingdom is:
PV2 > 1 ? 108,
where
P = Pedestrian volumes per hour (average of peak 4 hours)
V = entering vehicles per hour (average of peak 4 hours)
Rather than adopting the Access Board's recommendation to require signalization on pedestrian crosswalks at all roundabouts, regardless of need or justification, the Institute supports the Australian and European practice of installing pedestrian signals at appropriate locations based on objective criteria.
Opposition to Draft Guidelines
The Access Board indicates that the absence of stopped traffic presents a problem for pedestrians with vision impairments in crossing streets. It is true that traffic signals at conventional intersections establish a stop-and-go pattern that can assist blind and visually impaired pedestrians in crossing busy streets by producing audible cues about vehicle movements. However, a large majority of U.S. intersections are not controlled by traffic signals. Most intersections are governed by one-way or two-way stop sign control, which only require vehicles traveling on minor intersection approaches to stop. At most stop sign-controlled intersections, vehicles traveling on major intersection approaches are not required to stop, and at such locations travel speeds often can exceed 40-50 mph. So clearly, the absence of stopped traffic, while potentially problematic for pedestrians with vision impairments, is a frequently encountered condition. Like countless other crossings where traffic does not stop, blind pedestrians primarily rely on hearing to identify gaps in traffic.
The draft guidelines also suggest that crossing at a roundabout requires a pedestrian to visually select a safe gap between cars that may not stop. This statement is inaccurate as well as insulting to pedestrians who are blind. With proper training, blind pedestrians use their hearing to identify and select gaps in traffic at a wide range of unsignalized crossings where traffic may not stop. Even the Access Board-sponsored research by Guth et al. (2002) reported that blind individuals can cross single-lane roundabouts with relatively little difficulty and with few "risky" judgments (and more than half of U.S. roundabouts are single-lane, as reported by Jacquemart (1998)).
The Access Board claims that people who are blind or visually impaired are unable to make eye contact with drivers making it impossible to "claim the intersection." Blind pedestrians obviously are unable to make eye contact with drivers, regardless of the type of intersection traffic control. However, because roundabouts produce low travel speeds, short crossing distances, and eliminate turning vehicles, pedestrian crossings at roundabouts should be safer for blind pedestrians relative to many other unsignalized crossings. White Cane Laws, which require drivers to yield the right-of-way, further enable blind pedestrians to claim the intersection at roundabout crossings despite the inability to make eye contact.
Summary
The Institute opposes provisions of the draft guidelines that would require installation of traffic signals on pedestrian crosswalks at all roundabouts. The Access Board has provided no scientific evidence in support of this proposed requirement and, furthermore, it is likely that the arbitrary addition of traffic signals to well-designed roundabouts could increase the risk of motor vehicle crashes, in particular rear-end collisions, due to disruptions in traffic flow. Substantial costs associated with installation and maintenance of traffic signals might discourage some communities from constructing roundabouts or installing pedestrian crossings. Compared with conventional intersections, roundabout design and operational characteristics can provide improved access and safety for blind as well as sighted pedestrians, and additional measures can be taken to further improve the safety of blind pedestrians at unsignalized roundabout crossings such as textured pavement, raised crosswalks (speed tables), and increased lighting. Rather than adopting the Access Board's recommendation to mandate signalization on pedestrian crosswalks at all roundabouts -- regardless of need or justification -- the Institute supports the practice of installing pedestrian signals at appropriate locations where needed, based on objective criteria.
Sincerely,
Richard A. Retting
Senior Transportation Engineer
References
Architectural and Transportation Barriers Compliance Board. 2002. Draft guidelines for accessible public rights-of-way. Washington, DC. Available: http://www.access-board.gov/rowdraft.htm#DRAFT.
Brude, U. and Larsson, J. 2000. What roundabout design provides the highest possible safety? Nordic Road & Transport Research 12:17-21
Elvik, R. 2002. Effects on road safety of converting intersections to roundabouts: A review of evidence from non-US studies. Transportation Research Record. Washington, DC: Transportation Research Board, in press.
Guth, D.; Long, R.; Ponchilla, P.; Ashmead, D.; and Wall, R. 2002. Non-visual gap detection at roundabouts by pedestrians who are blind: a summary of the Baltimore roundabouts study. Washington, DC. Available: http://www.access-board.gov/publications/roundabouts/ research-summary.htm.
Jacquemart, G. 1998. Modern roundabout practice in the United States. Synthesis of Highway Practice 264. Washington, DC: Transportation Research Board.
Jordan, P.W. 1985 Pedestrians and cyclists at roundabouts. Proceedings of Local Government Engineers Conference. Perth, Australia.
Persaud, B.N.; Retting, R.A.; Garder, P.E.; and Lord, D. 2001. Safety effects of roundabout conversions in the United States: empirical Bayes observational before-after study. Transportation Research Record 1751, 1-8. Washington, DC: Transportation Research Board
Preusser, D.F.; Wells, J.K.; Williams, A.F.; and Weinstein, H.B. 2002. Pedestrian crashes in Washington, DC and Baltimore. Accident Analysis and Prevention 34:703-10
Tumber, C. 1997. Review of pedestrian safety at roundabouts. Victoria, Australia: VicRoads, Road Safety Department.