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
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
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
Richard A. Retting, October 25, 2002
Architectural and Transportation Barriers Compliance Board
Draft Guidelines for Accessible Public Rights-of-Way
In response to the Draft Guidelines for Accessible Public Rights-of-Way (June 17, 2002) proposed by the Architectural and Transportation Barriers Compliance Board (Access Board, 2002), the Insurance Institute for Highway Safety opposes the provisions that would mandate installation of traffic signals on pedestrian crosswalks at all roundabouts.
Background
Modern roundabouts are designed to function safely and efficiently without traffic signals and, in most cases, are constructed to replace less safe and less efficient stop sign-controlled intersections. Roundabouts are circular intersections with specific design and traffic control features that eliminate the need for traffic signals. These features include yield control of all entering traffic, channelized approaches with raised splitter islands, and geometric curvature to ensure slow travel speeds for vehicles entering into and within the roundabout.
Roundabouts are relatively new in the United States. Las Vegas, Nevada, built the first modern U.S. roundabout in 1990 (Jacquemart, 1998), and since then only 200-300 roundabouts have been constructed nationwide. In comparison, Australia and many European countries have been installing roundabouts extensively for decades, with, for example, more than 2000 roundabouts built in the Australian state of Victoria alone.
Effects on road safety of converting intersections to roundabouts has been the subject of extensive research in the United States and abroad. Results clearly indicate that roundabouts are an extremely safe form of intersection traffic control. For example, an Institute-supported evaluation of 23 U.S. intersections converted from stop sign or traffic signal control reported large reductions in motor vehicle crashes after roundabouts were installed (Persaud et al., 2001). Overall, crashes were reduced by an estimated 40 percent, injury
crashes declined by 80 percent, and crashes resulting in fatal or
incapacitating injuries were reduced by 90 percent. A recent meta-
analysis of 28 separate roundabout safety evaluations from outside the United States concluded that roundabouts were associated with a 30-50 percent reduction in the number of injury crashes and a 50-70 percent reduction in fatal crashes (Elvik, in press).
Although these studies do not provide conclusive evidence of the safety of pedestrians at roundabouts (primarily because of small samples of pedestrian crashes), available research suggests roundabouts can provide a relatively high degree of safety compared with intersections with stop sign and traffic signal control. For example, in the Persaud et al. (2001) study, four pedestrian crashes were reported during the before period and one was reported during the period after roundabouts were built (this difference was not significant due to the small sample size). Brude and Larsson (2000) analyzed pedestrian crash data at 72 roundabouts in Sweden and concluded that roundabouts pose no problems for pedestrians compared with conventional signal control intersections. For single-lane roundabouts, the observed numbers of pedestrian crashes were 3-4 times lower than for comparable signalized intersections, controlling for pedestrian volumes and traffic flow. Jordan (1985) examined pedestrian crash patterns at roundabouts in Victoria, Australia for the 4-year period 1980-83. A total of 35 pedestrian crashes were reported (average 9 crashes per year) at approximately 800 roundabouts. The author characterized this as an extremely low rate of pedestrian crashes and concluded that "concern for pedestrian safety at roundabouts, while well intentioned, is unfounded." Tumber (1997) conducted a review of pedestrian safety at roundabouts, also in Australia. The study focused on roundabouts constructed on arterial roads within the Melbourne metropolitan area during 1987-94. During this period, 64 pedestrian crashes were reported at approximately 400 roundabouts, for an average crash rate of 0.02 crashes per roundabout per year. The severity of pedestrian crashes (as indicated by the proportion of injuries classified as either serious or fatal) also was lower for roundabouts than for intersections with other forms of traffic control.
The safety of blind pedestrians at roundabouts has been questioned by some advocates of the visually impaired, but direct evaluations of crash data are not available. In an indirect evaluation of the issue, Guth et al. (2002) collected data regarding the ability of blind pedestrians to use their hearing to distinguish "crossable" gaps in traffic at roundabouts from gaps that were considered by the authors too short to afford a safe crossing. This work was supported by the Access Board. Three study sites in Maryland included a low-volume, single-lane roundabout; a large, urban, high-volume, two-lane roundabout; and an urban, intermediate-volume, two-lane roundabout. Six blind and four sighted pedestrians observed traffic at roundabout crosswalks and indicated by pressing a button whenever they believed they could complete a crossing before the arrival of the next vehicle. For the low-volume, single-lane roundabout, gaps between vehicles longer than 10 seconds
2-3 seconds
Despite the finding by Guth et al. (2002) that blind pedestrians can adequately judge gaps at single-lane roundabouts with little difficulty and as well as sighted individuals, the Access Board is proposing guidelines that would require signalization of pedestrian crosswalks at all roundabouts on the basis that the safety of blind pedestrians mandates such devices. This proposed requirement would apply even in rural settings where pedestrian activity is infrequent and where blind pedestrians may be nonexistent. However, traffic signals appear to be unnecessary at single-lane roundabouts and, if mandated, actually could be detrimental to highway safety. It is likely that the arbitrary addition of traffic signals to well designed roundabouts could increase the risk of injury crashes due to disruptions in traffic flow. Also, substantial costs associated with installation and maintenance of traffic signals might discourage some communities from constructing roundabouts. Even for high-volume, two-lane roundabouts, the Guth et al. field study does not make a compelling case for traffic signals because of weaknesses in the research methodology. Blind pedestrians were driven to roundabouts and then observed after minimal exposure to these unfamiliar locations. This is unrealistic because blind pedestrians typically do not wander into such areas without a guide to provide initial orientation. Guth et al. merely provides evidence of the perception of risk, not actual risk. The blind pedestrians may have been more willing to press a button when they believed they could complete a crossing than to begin crossing, thus inflating the numbers of "risky" judgments. Also, comparable data were not collected for intersections controlled by traffic signals or stop signs.
Compared with conventional intersections, roundabouts can provide improved access and safety for blind pedestrians as well as sighted individuals because of specific roundabout design and operational characteristics. First and foremost, traffic speeds within roundabouts are very low -- typically 15-20 mph -- compared with considerably higher traffic speeds at most traffic signal and stop sign-controlled intersections. Pedestrian refuge islands at roundabouts provide for short crossing distances. Also, roundabouts are relatively simple intersections that eliminate left turns, right turns, and the associated turning-vehicle conflicts common at conventional intersections. By comparison, conventional intersections are characterized by higher traffic speeds, longer crossing distances, and are more complex due to two-way traffic flow and frequent vehicle turning movements. Preusser et al. (2002) reported that 25 percent of motor vehicle-pedestrian collisions in Washington D.C. involve turning vehicles.
The combination of low traffic speeds, short crossing distances, and absence of turning vehicles in conjunction with White Cane Laws - laws in 47 states that require drivers to yield the right-of-way to a person carrying a white cane or accompanied by a guide dog --- provide safe crosswalks for blind pedestrian at many roundabouts. Additional measures that could enhance safety include textured pavement in conjunction with ramps to help lead blind pedestrians to crosswalks, raised crosswalks that can further slow entering and exiting traffic, and pedestrian yield signs in both directions of the crossing that require drivers to stop for pedestrians waiting on the crosswalk. Also, specific training can be developed and provided to help the visually impaired perceive gaps in traffic and to give drivers cues to stop.
Signalizing roundabout crossings can be justified when the combined volumes of pedestrians and vehicles are high or at locations with complex geometry such as high-volume school zones. In Australia and Europe, the vast majority of roundabouts are unsignalized, but some roundabouts in urban areas do have pedestrian signals. The recommended threshold for signalizing pedestrian crossings in the United Kingdom is:
PV2 > 1 ? 108,
where
P = Pedestrian volumes per hour (average of peak 4 hours)
V = entering vehicles per hour (average of peak 4 hours)
Rather than adopting the Access Board's recommendation to require signalization on pedestrian crosswalks at all roundabouts, regardless of need or justification, the Institute supports the Australian and European practice of installing pedestrian signals at appropriate locations based on objective criteria.
Opposition to Draft Guidelines
The Access Board indicates that the absence of stopped traffic presents a problem for pedestrians with vision impairments in crossing streets. It is true that traffic signals at conventional intersections establish a stop-and-go pattern that can assist blind and visually impaired pedestrians in crossing busy streets by producing audible cues about vehicle movements. However, a large majority of U.S. intersections are not controlled by traffic signals. Most intersections are governed by one-way or two-way stop sign control, which only require vehicles traveling on minor intersection approaches to stop. At most stop sign-controlled intersections, vehicles traveling on major intersection approaches are not required to stop, and at such locations travel speeds often can exceed 40-50 mph. So clearly, the absence of stopped traffic, while potentially problematic for pedestrians with vision impairments, is a frequently encountered condition. Like countless other crossings where traffic does not stop, blind pedestrians primarily rely on hearing to identify gaps in traffic.
The draft guidelines also suggest that crossing at a roundabout requires a pedestrian to visually select a safe gap between cars that may not stop. This statement is inaccurate as well as insulting to pedestrians who are blind. With proper training, blind pedestrians use their hearing to identify and select gaps in traffic at a wide range of unsignalized crossings where traffic may not stop. Even the Access Board-sponsored research by Guth et al. (2002) reported that blind individuals can cross single-lane roundabouts with relatively little difficulty and with few "risky" judgments (and more than half of U.S. roundabouts are single-lane, as reported by Jacquemart (1998)).
The Access Board claims that people who are blind or visually impaired are unable to make eye contact with drivers making it impossible to "claim the intersection." Blind pedestrians obviously are unable to make eye contact with drivers, regardless of the type of intersection traffic control. However, because roundabouts produce low travel speeds, short crossing distances, and eliminate turning vehicles, pedestrian crossings at roundabouts should be safer for blind pedestrians relative to many other unsignalized crossings. White Cane Laws, which require drivers to yield the right-of-way, further enable blind pedestrians to claim the intersection at roundabout crossings despite the inability to make eye contact.
Summary
The Institute opposes provisions of the draft guidelines that would require installation of traffic signals on pedestrian crosswalks at all roundabouts. The Access Board has provided no scientific evidence in support of this proposed requirement and, furthermore, it is likely that the arbitrary addition of traffic signals to well-designed roundabouts could increase the risk of motor vehicle crashes, in particular rear-end collisions, due to disruptions in traffic flow. Substantial costs associated with installation and maintenance of traffic signals might discourage some communities from constructing roundabouts or installing pedestrian crossings. Compared with conventional intersections, roundabout design and operational characteristics can provide improved access and safety for blind as well as sighted pedestrians, and additional measures can be taken to further improve the safety of blind pedestrians at unsignalized roundabout crossings such as textured pavement, raised crosswalks (speed tables), and increased lighting. Rather than adopting the Access Board's recommendation to mandate signalization on pedestrian crosswalks at all roundabouts -- regardless of need or justification -- the Institute supports the practice of installing pedestrian signals at appropriate locations where needed, based on objective criteria.
Sincerely,
Richard A. Retting
Senior Transportation Engineer
References
Architectural and Transportation Barriers Compliance Board. 2002. Draft guidelines for accessible public rights-of-way. Washington, DC. Available: http://www.access-board.gov/rowdraft.htm#DRAFT.
Brude, U. and Larsson, J. 2000. What roundabout design provides the highest possible safety? Nordic Road & Transport Research 12:17-21
Elvik, R. 2002. Effects on road safety of converting intersections to roundabouts: A review of evidence from non-US studies. Transportation Research Record. Washington, DC: Transportation Research Board, in press.
Guth, D.; Long, R.; Ponchilla, P.; Ashmead, D.; and Wall, R. 2002. Non-visual gap detection at roundabouts by pedestrians who are blind: a summary of the Baltimore roundabouts study. Washington, DC. Available: http://www.access-board.gov/publications/roundabouts/ research-summary.htm.
Jacquemart, G. 1998. Modern roundabout practice in the United States. Synthesis of Highway Practice 264. Washington, DC: Transportation Research Board.
Jordan, P.W. 1985 Pedestrians and cyclists at roundabouts. Proceedings of Local Government Engineers Conference. Perth, Australia.
Persaud, B.N.; Retting, R.A.; Garder, P.E.; and Lord, D. 2001. Safety effects of roundabout conversions in the United States: empirical Bayes observational before-after study. Transportation Research Record 1751, 1-8. Washington, DC: Transportation Research Board
Preusser, D.F.; Wells, J.K.; Williams, A.F.; and Weinstein, H.B. 2002. Pedestrian crashes in Washington, DC and Baltimore. Accident Analysis and Prevention 34:703-10
Tumber, C. 1997. Review of pedestrian safety at roundabouts. Victoria, Australia: VicRoads, Road Safety Department.
Arthur Slabosky, P.E., September 25, 2002
There is no need to put pedestrian actuated signals at all roundabout crosswalks. Both sides on this issue are approaching it mechanistically as only a design issue, with no recognition of a role for education and enforcement. Access for pedestrians with vision impairments should be accomplished at roundabouts by enforcement of the law, with motorist and police education devoted to that purpose.. The anti-signal people seem to think that no education is necessary. The pro-signal people seem to think that no education is enough.
The description of the problem as expressed by the Access Board are misleading because they do not recognize that drivers are required to yield for pedestrians in crosswalk, although admittedly this is not enforced in the U.S.
Let us examine the following excerpt from http://www.access-board.gov/rowdraft.htm in section (1105.6) on Roundabouts: "...Because crossing at a roundabout requires a pedestrian to visually select a safe gap between cars that may not stop, accessibility has been problematic...." A pedestrian is not required to cross between cars that may not stop. A pedestrian that steps into the crosswalk legally mandates cars to stop. That is a legally available option to crossing in a gap in traffic.
A later phrase on the same page mentions that ..., the absence of stopped traffic presents a problem for pedestrians with vision impairments in crossing streets." Out of context this is a true statement. In the context of a roundabout with marked crosswalks it is again not quite on target because of the pedestrian's legal power to stop traffic as mentioned above. Furthermore it is not true that automobile traffic is never stopped in the absence of pedestrian demand. During busy times automobile traffic yields for vehicles inside the circle until there is a gap. This creates a stop-and-go queue in which vehicle drivers are amenable to leave a gap at the crosswalk (because they have to stop anyway).
The major premise of the Access Board's approach is that a red light displayed in front of a driver will cause them to stop, but a human being will not. The law on red lights is no higher a law than the one on pedestrians in a crosswalk. Then we can apply the Access Board's own argument also to a red light, and say that this is traffic that "may not stop." Red light running is a documented phenomenon on our streets.
Even red light compliance depends upon awareness of police enforcement presence. The same traffic police who now monitor red light running and speeding in the vicinity of signalized intersections have a simpler task at roundabouts. Failure-to-yield is almost the only violation that can occur in a roundabout. Unlike stop sign and speed violations, which are symbolic most of the time, failure to yield is never victimless. This means more efficient use of traffic police forces where they count; it also means that there should be plenty of police resources available to enforce respect for crosswalks in roundabouts.
Opening of the first roundabout in a community is already a time of change. Such openings are usually accompanied by scads of publicity on how to use the roundabout. Part of such publicity must include a message that at these facilities crosswalk observance will be enforced. Then the police must follow up with some actual enforcement. A few weeks of pedestrian testers followed and cops lying-in-wait should send the message of behavior that is expected.
A tangible suggestion of what the access board's proposal should be:
The design of every new roundabout in a community shall carry a surcharge a of (fill in number) percent up to (Fill in amount of money) that the road authority must use for publicity, police and testers to train the public to use the roundabout in a safe and legal manner with special attention to yields to pedestrians.
Such publicity and training should include but not be limited to:
1. Explaining to the police chief that replacement of signals with roundabouts relieves police of enforcement of stops and substitutes yield requirements which are just as critical for a roundabout's proper operations as are stops for a signal.
2. Placement of temporary signs that emphasize yielding to pedestrians in crosswalks.
3. Printed brochures in public places and radio and TV ads that describe motorist obligations.
4. Literature aimed at pedestrians that emphasizes the importance of crossing roundabouts at the crosswalk.
5. Deployment of pedestrian testers shadowed by uniformed police. The testers can even be police. This is similar to the method where police in unmarked cars spot violators on the road and notify officers in marked cars who issue the citation.
The Access Board 's recommendation for pervasive roundabout ped signals is justified if we assume the best features of perpendicular intersections and the worst features (including driver behavior) of roundabouts. The above recommendation seeks to effect the best features of roundabouts. The roundabout at its best is safer than a signalized intersection for any kind of pedestrian AND motorist.
There are also some things worth mentioning about the side-effects and extremely small cost-effectiveness of the would-be signals as proposed by the Access Board.
In terms of reasonableness of application, the universe in which the pedestrian signals would provide any benefit are very narrow. It would be under the following circumstances:
1. There is a blind pedestrian at the roundabout.
2. Such blind pedestrian doesn't have a dog.
3. The roundabout is busy enough that gaps are not obvious to his/her ears. (There may be NO cars present).
4.. The roundabout is not busy enough to slow speeds to a point where all drivers will observe the crosswalk.
This is a very tight set of conditions to provide at massive expense solution, and certainly stretches the limits of the meaning of reasonable accommodation. In contrast the pervasive signalization requirement offers the following negative side-effects:
1. More injuries and loss of life at the signals that will continue to be built at locations where roundabouts would have been affordable but for the required ped signals.
2. Rear end crashes at roundabouts where pedestrians unnecessarily activated the signals.
3. Increased delay because of persistence of red display after pedestrian has crossed.
4. Fewer pedestrian facilities, e.i. sidewalks and crosswalks at roundabouts.
5. Decreased safety in general for persons who are blind.
6. The death blow to respect for pedestrians in traffic.
Items number 1 through 3 above are well known already. I explain items 4 and 5 and 6 below.
4. Fewer pedestrian facilities. Proposed item 1105.6 requires the actuated signals only "where pedestrian crosswalks and pedestrian facilities are provided at roundabouts. " If you really want the roundabout but can't afford it with the signals, leave out the sidewalk. Now ALL pedestrians are worse off. There must be a specification somewhere describing where a sidewalk is required, but everybody knows how to play the specs game. The temptation to decide that a sidewalk is not required will be strong if the sidewalk involves $100,000 in
5. Decreased safety in general for persons with visual impairments. . This is not a simple trade-off between people in cars whose overall safety is enhanced vs. blind pedestrians whose safety is decreased. Although the Access Boards proposed measure may increase safety and access for blind pedestrians, these are people who do not spend 24 hours a day as pedestrians without any interest in the survivability of motor vehicle users. . They are also passengers in motor vehicles at times. Also the blind persons' friends, drivers, plumbers, mail carriers and everyone else with whom they interact gains enhanced survivability in motor cars when a roundabout is built instead of a signal. Therefore the blind person has a substantial interest as a member of a whole community not only for their own direct safety but for those in society around them. Everyone who interacts with the blind person, including the blind person themself benefits from the increased safety of the roundabout.
If this proposal is adopted, the blind persons will also benefit from police presence at non-roundabout locations. This notion is expanded in the following section.
6. The death blow to respect for pedestrians in traffic.
Some people will say that these signals are needed because respect for pedestrians is already dead. I submit that these signals will insure that such respect will never return. On the good side of things, emphasis of ped laws at roundabouts as herein proposed can become a beachhead for expanding enforcement to other locations. (Note again the freed-up police time as roundabouts replace signals) No matter what happens at major intersections, the majority of road crossings will remain without signal protection.
Roundabouts contain features (unnecessary to mention here) that are the best achievable for pedestrian consideration. If we can't expect drivers to yield to pedestrians at roundabouts, where will they yield to them? The answer is NOWHERE.
Pedestrian and walkability advocates have complained for a long time that drivers do not show pedestrians respect. This is coupled with the fact that the pedestrian laws are rarely if ever enforced. If the American community throws in the towel now and ASSERTS that a driver has to see a big glowing red ball in order to stop for a pedestrian, we can forget about ever re-asserting pedestrian consideration into our driving behavioral culture.
The blossoming of roundabouts is an opportunity to re-assert a pedestrian-aware culture on Americans, not to throw it away.
Related suggestion: Find ways to equip pedestrians to be more attention-getting to motorists.
There are technical opportunities to improve the signals that pedestrians send. Do blind people still walk streets with a non-illuminated red-tipped cane? Aren't there LED devices that the blind people can carry that will alert cars positively to their presence? There must be economical ways to put the signalizing power in the hands of the people who need it, rather than outfit the intersection at great expense in case a person in need comes along.
In fact, Dan Burden of Walkable Communities present slides of a low-tech device in one city. There are red flags on short sticks in umbrella holders at both ends of a non-signalized urban crosswalk. . The pedestrian uses the flag to signal an intent to cross. The person carries the flag across the street and leaves it in the holder on the other side.
In a few years we may be able to equip cars and blind pedestrians with transmitters to send signals that would replace the absent visual knowledge of car movements. Such as-needed features are by their nature more economical and more reliable than sweeping general "solutions."
The debate over pedestrians and yielding should be part of the bigger issue of where traffic law enforcement has gone. The big enforcement actions now are red-light running, speeding and stop sign violations. Without demeaning the importance of such control devices, enforcement of these laws is usually symbolic, as mentioned earlier. That is, most of the time someone violates a stop or speed limit, there is no potential victim. It is easy for police to go to a place where most people "speed" and hand out tickets. It is easy to sit by a stop sign and find people who only came to a rolling stop even with no opposing traffic in sight. . In absence of a victim at the moment, the safety benefit of these enforcement actions is unknown. That is because we don't really know whether the rolling-stop driver would have yielded to an opposing vehicle or pedestrian. The speeder may be violating a politically low speed limit and might very well slow down when conditions warrant.
Implementation of roundabouts without signals coupled with yield-to-pedestrian enforcement emphasizes driver behavior where it counts. If there is no would-be victim, no the driver may proceed ahead.
A quote that followed a tragedy from Michigan illustrates how far we have gone from a culture of responsible responsive driver behavior. In August 2002 a driver hit a construction sign on the shoulder of an active highway work zone The sign hit two members of a crew, killing one and seriously injuring the other. The Detroit News (Macomb Section, 8-14-2002) quoted the director of safety services for the Michigan Road Builders Association thus: "For some reason, people are not getting the message that these are human beings out there, not just barrels with arms."... Maybe this is because drivers have been trained to consider lights and signs in front of them as more important than people.
Comments of Arthur Slabosky, P.E.
Michigan Department of Transportation
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
Dwight Kingsbury, Ph.D., October 28, 2002
Comment on Draft Guidelines for Accessible Public Rights-of-Way, published in the Federal Register, 17 June 2002.
As a pedestrian safety analyst, I support the goals of this effort, but share the concerns expressed by others (e.g., AASHTO) that in some sections, the draft guidelines propose inflexible, "Gordian knot" criteria to the application of pedestrian crossing features that are more appropriately and effectively evaluated through the application of engineering judgment, in the light of the "Manual on Uniform Traffic Control Devices" and other engineering guidance documents.
Specifically, I am concerned about the following.
S. 1105.3 would require calculation of pedestrian signal phase timing using a pedestrian walking speed of 3.0 ft
S. 1105.5.3 would require installation of elevators where the rise of a ramped approach exceeds 60 inches
S. 1105.6.2 would require provision of a pedestrian activated signal at each segment of a roundabout crosswalk. Although pedestrians often expect they will have difficulty using such crosswalks, prior to construction, I have never heard of any pedestrian request for a signal at a signal-lane roundabout, after it has opened. Adoption of this requirement could result in a reduction of the use of marked crosswalks at roundabouts. I concur with AASHTO that this section should be reserved, pending completion of NCHRP Project 3-65, "Applying Roundabouts in the United States."
S. 1105.7 would required provision of a pedestrian activated signal where crosswalks are provided at right or left turn slip lanes. The problem is that, if the slip lane is designed to facilitate a high speed turn, and the signal is used infrequently, it will be ineffective; many drivers simply fail to heed signal indications they are not used to seeing. The failure of drivers to yield to pedestrians in slip lane crosswalks is better addressed through design, e.g., greater use of high-entry-angle slip lanes such as those used in Australia (cf. the Austroads "Guide to Traffic Engineering Practice," Part 5). Let us hope that NCHRP Project 3-72, "Lane Widths, Channelized Right Turns, and Right Turn Deceleration Lanes in Urban and Suburban Areas," will produce some useful recommendations for the pedestrian crossing problem at slip lanes.
S. 1106 would require all pedestrian signal systems to use audible and vibrotactile indications. In Florida, there have been differences among visually impaired pedestrians as to the usefulness of audible signal systems. Some blind persons believe these features are unnecessary, or create a false sense of security, or make it difficult to hear traffic (at least, if not installed properly). They must also be maintained. It is probably better to continue with the current practice of considering installation of such systems on request.
I also concur with AASHTO that the hard conversion of dimensions stated in US customary units into their SI equivalents lends itself to impractical inferences with respect to tolerances. Metric tolerances need to be clarified.
Dwight Kingsbury, Ph.D.
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.
Jennifer Campos, October 25, 2002
City of Vancouver
Transportation Services
On behalf of the City of Vancouver, Washington, I am submitting comments regarding the recently released Draft Guidelines for Accessible Public Rights-of-Way by the Access Board. The City is very supportive of the Board's decision to create guidelines for the public right-of-way, but we do have some concerns over several of the proposed requirements.
Below I have listed our comments below by section number. Assume that if any part of the guidelines is not mentioned, that we support what you have proposed.
1104.3.2 Detectable Warnings. Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.
We strongly feel that this requirement is unnecessary and over burdensome. Detectable warnings should not be placed at all curb ramps or landings, but only in those cases where it would be difficult for someone to detect where the sidewalk ends and the street begins. This would be at rail crossings, platform edges, blended transitions, or ramps that have a slope of 1:15
1105.2.2 Cross Slope. The cross slope shall be 1:48
EXCEPTION: This requirement shall not apply to mid-block crossings.
1105.2.3 Running Slope. The running slope shall be 1:20
Both of these requirements would place a huge burden on the City in trying to meet the standards since it would apply to all streets regardless of any outside circumstances that we would have no control over. This should be a guideline that jurisdictions should strive for while designing their roadways in order to improve pedestrian safety, but it would be impossible for many if not most areas to meet it in all cases.
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Requiring this change in signal timing would ensure much higher delays for all users. The requirement would be applicable on streets that were not overly wide and had curb returns over 25', but unfortunately this is not how many of our streets are built today. We currently respond to the request for more crossing time on a case by case basis, or any place we feel there are users who will benefit from the change.
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
1105.6.1 Separation. Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
This portion of the proposed guidelines has to be the most excessive and unnecessary part of the entire guidelines. To require signals at all legs of roundabouts completely defeats the purpose of building a roundabout in the first place. The board mentions that roundabouts have become popular in the U.S because they "add vehicle capacity and reduce delay." These are not the only reasons and it would be careless of you to not recognize the most important benefits.
Roundabouts have become so successful because the virtually eliminate all accidents at intersections. This is not just automobile accidents, but pedestrian accidents as well. They do so by reducing the number of conflict points and more importantly reduce the speeds of motorists entering the intersection. When motorists drive slower they are more able to take account of their surroundings, making conditions much safer for pedestrians for crossing. We recognize that blind or visually impaired pedestrians can have difficulties crossing at roundabouts, but to install signals at all legs would make them cost prohibitive compared to a regular signalized intersection.
Because navigating the sidewalks around the edge of a roundabout is not different than navigating any other intersection, the need for barriers is completely unnecessary. Curb ramps are installed at roundabouts to indicate crossing locations just as they are for any other type of intersection.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
Rather than require signals at slip lanes for pedestrians, why not just prohibit their use? This would make much more sense, and would completely eliminate the pedestrian/auto conflict that a signal probably would not prevent.
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
We know that most of the controversy surrounding these guidelines has revolved around the audible signal requirement and we feel that to require an audible signal at every intersection with a WALK interval is cost burdensome and unrealistic. For new signals the installation cost would not be significant, but the impacts to the environment would be enormous. Imagine walking in the downtown of a city with a 200 ft
We work with the local blind community to prioritize needed audible signal locations, and try to install as many devices as we can. We get requests from people who have difficulty reading a certain intersection, and they have made it clear that they do not want audible signals at every intersection.
1109.2 Parallel Parking Spaces. An access aisle at least 60 inches
It would be impossible to install and maintain a disabled parking spot on each block of parallel parking. In areas where the block faces are around 200 feet
If you have any questions regarding our comments please don't hesitate to contact me at [ ... ]
Sincerely,
Jennifer Campos
Associate Transportation Planner
I would like to comment on the proposed signalization rule for roundabouts (1105.6.2). I believe this rule is not sufficiently warranted and should be eliminated. Instead, proposed rule 1106 should be used to ensure that pedestrian signals, if otherwise provided, would be meet the needs of the disabled, and further research should be done to find other ways to improve roundabout safety for disabled pedestrians.
Proposed rule 1105.6.2, if enacted, may well end the use of roundabouts in the U.S. There is little reason to construct a traffic circle if you have to signalize anyway. I am not a professional roundabout advocate, but as a city planner with close to twenty years of working experience I know that there are important benefits to society that roundabouts can provide. Vehicles flow through roundabouts at a measured pace without idling at red lights. As the Board indicates, this reduces congestion, but it also reduces air pollution. Second, the high cost of traffic signal electricity and maintenance is eliminated. Third, roundabouts provide a center pubic space that can serve an aesthetic, historic, and/or civic function. Fourth, my understanding is that roundabouts can improve safety over traffic signals for certain types of traffic movements; certainly they calm traffic and reduce vehicle speeds.
I would note that properly designed roundabout crosswalks are no more inherently dangerous to pedestrians with disabilities than signalized intersections that allow right turns when left turns are also allowed from the other direction. The driver turning right may still be looking left to see if there is another vehicle with which to contend, and the right-turning driver thus may not be sufficiently aware of a pedestrian in the crosswalk of the street onto which s/he is turning. Nevertheless, completely shutting down a signalized intersection for pedestrian movements in many cases is seriously impractical. Therefore, the contention that roundabouts are more dangerous for disabled pedestrians is questionable.
Using the services of a traffic consultant, my community did install a roundabout at an intersection because it is an intersection with 5 legs and a traffic signal would not have made sense. We used the "Australian" treatment for the crosswalks which was to place them one car length behind each entrance to the roundabout so that pedestrians would be visible to drivers before the drivers got to the circle and started looking exclusively to the left for oncoming vehicles. The location of the roundabout is in a mixed-use area with a specific revitalization vision that includes being pedestrian friendly. There are several people who live in the neighborhood who use wheel chairs, and other disabled people also are frequently seen using the roundabout's crosswalks, including folks with vision impairment. There have been no pedestrian accidents in the four years the roundabout has been operating.
I feel proposed rule 1105.6 is very drastic and implore the Board to work with engineers and others in seeking refinements in roundabout designs that can allow this fledgling innovation to continue to be implemented and improved without the completely antithetical resort to signalization.
Sincerely,
Tex Haeuser, Planning Director
Paul Plotas, P.E., PTOE, October 24, 2002
Re: Draft Guidelines for Accessible Public Right-of-Way (June 17, 2002) Roundabout Alternative Design Strategies
Dear Access Board:
Although I certainly would not classify myself as a roundabout expert, I am a practitioner of traffic engineering with 16 years of experience. During my review of the "Draft Guidelines for Accessible Public Rights-of Way (June 17, 2002)", the following passage in particular caught my attention:
To provide safer crossing at roundabouts, the draft guidelines would require pedestrian activated crossing signals at each roundabout crosswalk, including those at splitter islands. (The draft guidelines would ensure that such signals are usable b with vision impairments under requirements in section 1106 discussed below.) Although roundabouts are typically used to avoid signalization, the Board is not aware of alternatives that would allow safe passage for pedestrians with disabilities. Aside from accessibility, the use of roundabouts in areas of high pedestrian use has been questioned 4 some in the industry. Requiring the signal to be pedestrian activated may help limit the impact on traffic flow. Signal technologies are available that can further minimized the impact, such as devices that halt traffic only while a pedestrian is in the crosswalk. The Board seeks information on alternative design strategies and available technologies that can improve access at roundabouts for persons with disabilities, particular those with vision impairments.
I developed the attached summary of my thoughts on this subject and respectfully submit it for your review.
Please give me a call at [...] if you would like to discuss my thoughts further.
Very truly yours,
Paul Plotas, PE, PTOE
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Section 1 ? Introduction
Introduction
All at-grade pedestrian crossings of roadways are handled in one of the following two ways:
Vehicular traffic is stopped, allowing the pedestrians to cross ? example: signalized intersections
Pedestrians judgment determines appropriate crossing opportunities ? example: unsignalized intersections
Typically, in both cases vehicles are already expecting to stop at an intersection and pedestrian crossings are accommodated. Roundabouts present a different challenge since vehicular traffic at the egress crosswalks will never be stopping for other vehicles, see Figure 1. Additionally, roundabouts present a particular challenge to visually impaired pedestrians since the geometrics of a roundabout distort audio information from vehicular traffic giving unclear audio clues. To aid pedestrians at roundabouts, one can either attempt to control vehicular traffic or improve the information provided to pedestrians. This report discusses these two alternatives.
Referring to Figure 1, for the purposes of the following discussion, it is assumed that the pedestrian crosswalk is located approximately I to 2 car lengths from the edge of the central circle, which is the typical layout.
Alternatives
In this section various roundabout alternatives for both controlling vehicular traffic and for improving information available to pedestrians will briefly be explored.
Control Vehicular Traffic
There are at least four alternatives available to control vehicular traffic and give pedestrians the right-of-way at a roundabout egress pedestrian crossing.
a. Stop sign
b. Yield sign
c. Traffic signal
d. No control/Understanding that vehicle driver yields right-of-way to pedestrian
a. A stop sign alternative breaks the basic principals of roundabouts: all traffic control of a roundabout is yield controlled. Additionally, with low pedestrian traffic, stop signs will serve no useful purpose the majority of the time, will eventually be ignored by drivers, and will eventually function as a yield sign, and probably as an uncontrolled intersection.
b. As discussed for the sop sign alternative, at low pedestrian volume locations, vehicle drivers will also eventually ignore the yield sign, resulting in an uncontrolled intersection.
c. A third method for controlling vehicles at the egress pedestrian crossing is a traffic signal, however, two issues immediately come to mind. The first is the issue that there is only storage for up to two vehicles before additional vehicles in the queue impede vehicular flow around the roundabout. Even with minimum timings for a signal, a roundabout with relatively low vehicular volumes will experience some blockage.
Having the call for the signal solely dependent on pedestrian demand without regard to vehicular flow in the roundabout could have significant impacts to the capacity of the roundabout. It may be possible to place additional vehicle detectors strategically about the roundabout to delay the pedestrian call to a convenient time for vehicles; however, additional study will be required to determine if a suitable location is actually available.
The second issue that comes to mind with signalized control is driver expectation, especially with low pedestrian volume roundabouts. If a driver continuously meets a green indication at a signal, driver expectation is that a green signal will be met every time. My personal observations are that at low pedestrian volume, mid-block, stand alone pedestrian signals, it is the combination of the physical person and the signal that alert drivers to the signal. My personal observations are that most pedestrians instinctively realize this and will not begin to cross a road, even with the signal giving the right- of-way, until they visually receive confirmation that vehicles are stopping. Sight distance for the mid-block pedestrian signal is very important. Although the same sight distance may be available at a roundabout, the curvature of the intersection at times focuses drivers' attention on negotiating the curves of the road and away from the distant cross walk. The bottom line of this discussion is that due to driver expectations, a signalized crossing could actually give visually impaired pedestrians a false sense of security, and further study is necessary to determine if this is true.
d. Based on the discussion above, the final alternative, No control/Understanding that driver yields right-of-way to pedestrian is the alternative that the unsignalized alternatives default to, particularly at locations with low pedestrian volumes.
Control Pedestrian Traffic
There are at least two alternatives to control pedestrians while maintaining virtually free-flow conditions for vehicular traffic.
a. No control, pedestrian judgment determines acceptable gaps
b. "All Clear" Signal to pedestrians
a. Due to distorted sound the no control alternative is unacceptable.
b. The concept for the "All Clear" alternative is that vehicle detectors can be placed in the pavement upstream of the crosswalk as shown on Figure 2. The upstream detector could be coordinated with a pair of downstream detectors to determine when no vehicles are within the clear zone. When no vehicles are within the clear zone pedestrians would be given an "All Clear" signal.
While it is possible to build such a system, the following issues deserve additional research.
1. Do pedestrians have enough time to cross the egress lane in the scenario where a vehicle is just before the detector just as the pedestrian steps off the curb?
2. Is it prudent to depend on technology to this extent to determine when conditions are all clear?
3. What liability is involved with this alternative? (Is it really any different from a standard signalized intersection?)
Conclusions
The following problem with roundabouts has been identified: the circular portion of the roundabout creates confusing sound patterns. Being able to clearly read these sound patterns is essential for visually impaired pedestrians to safely cross the road. While it is possible to control vehicular traffic to enable pedestrians to cross, it is not obvious, at least to me, that the pedestrians will be safer. Instead of trying to control the vehicular traffic, I propose to improve the information available to pedestrians. It appears that by strategically placing detectors visually impaired pedestrians can have the same information as all other pedestrians to make informed decisions about when to cross.
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
Lawrence T. Hagen, P.E., PTOE, October 22, 2002
As a general comment, too much of the guidelines are attempts to eliminate any engineering judgment in determining what is the appropriate traffic control treatment. This leads to "cookbook engineering" where everyone just blindly implements the cookbook approach. This one-size-fits-all approach is not good engineering, is not good public works, and is usually not serving the overall best interest of the public. Many of the recommended guidelines also seem to have been done with no consideration of the fiscal impact. However, with the ever-increasing demands and less money, operating agencies will have difficulty implementing the proposed guidelines
Alternate Circulation Path - (1102.3, 1111)
I would suggest that an exception for short-duration blockages of pedestrian paths should be included. If construction activities will block the path for a few hours or maybe one day, you could spend more time and disrupt more people by the installation and removal of the accessible and protected alternate path than by the actual construction activity. Short-term closure of a pedestrian path, where the pedestrian could utilize the other side of the road is a reasonable alternative.
Minimum Clear Width (1103.3)
48" width exclusive of curbs will be difficult to obtain in many areas with already-constrained right-of-way. I agree with some of the other posted comments that perhaps we should look to including the curbs.
Pedestrian Crossings (1105.2.1)
I do not support the widening of crosswalks in a sweeping blanket mandate. In many cases at large intersections, traffic engineers struggle to get the signal indications located within the 40 - 150' distance from the stop line as mandated by the MUTCD. Adding a couple of feet doesn't sound like much, but in many instances that could be the difference between four and eight signal structures (mast arms). I would prefer to see the 72 inch
Pedestrian Signal Phase Timing (1105.3)
I am adamantly opposed to mandating a walk speed of 3.0 feet
have crossed.
Pedestrian Crossing Length (1105.4.1)
This requirement would seem to mandate the removal of unsignalized crossings where the median width is less than 72 inches
Pedestrian Overpasses and Underpasses (1105.5)
I believe that requiring elevators where there is a elevation change over 60 inches
Roundabouts (1105.6)
I think mandating signalized pedestrian crossings at all roundabouts is one of the silliest ideas imaginable. Many roundabouts do not warrant signalization, so they would certainly not meet the warrants for the pedestrian crossings on the approaches. There certainly are some roundabouts with poor pedestrian performance, but many of those have design flaws in the roundabout. Many I have seen have the pedestrian crossing at the circulating roadway edge. By properly designing and constructing the pedestrian crossings at roundabouts, I believe that peds can be properly and safely accommodated without signals at most roundabouts. I think "YIELD TO PEDS" signs at the crosswalks should be tried first, and signalized ped crossings should only be a last resort if nothing else seems to work. However, either of these treatments should only be installed after an engineering study determines that they are the most appropriate traffic control device. I am also unsure what type of barrier is needed around roundabouts. Would a small strip of grass or other landscaping (like that shown in the picture) be an appropriate barrier? Guidance on the barrier is needed.
Turn Lanes at Intersections (1105.7)
Among other things, installation of the pedestrian activated signal at each segment of the crosswalk crossing slip lanes creates a maintenance problem. Large trucks routinely hit poles or devices that are out in the refuge island, so the maintaining agency has to repeatedly replace the equipment. Also, with the requirements of 1106.2.1, there is not room on most slip lane channelization islands to accommodate the spacing requirements. Similar to roundabouts above, I believe that if there is a problem, an engineer should study to determine the most appropriate traffic control and be able to choose the best answer for that intersection from the available solutions.
Accessible Pedestrian Signal Systems (1102.8, 1106)
My only comment here is related to the fiscal issue. In large metropolitan areas where there are large numbers of signals, the costs of retrofitting all of the signals with upgraded pedestrian features can be staggering, especially in this day and age when everyone's budget is being cut. Additionally, by replacing a simple pushbutton switch with a more sophisticated device that also vibrates and emits sounds, you will incur more maintenance expense. Please understand, I wholly support having accessible pedestrian devices where they are needed. However, given the additional capital and maintenance costs, is it good public works to install these devices where they may not be needed? Again, my objection is basically the one-size-fits-all approach.
Thank you for the opportunity to comment. Please let me know if you need additional information.
Larry Hagen
Lawrence T. Hagen, P.E., PTOE
Program Director - ITS, Traffic Operations, & Safety
Center for Urban Transportation Research (CUTR)
University of South Florida, College of Engineering
John Jeavons, October 25, 2002
My name is John Jeavons and I have been blind for over twenty years. In that time I have received expert instruction in the use of canes and dog guides for purposes of mobility and orientation and become very competent in their safe and effective use.
I strongly support the Public Rights Of Way Advisory committee's report's recommendations for inclusion of requirements for accessible pedestrian signals at traffic intersections and detectable edge warnings at train and subway platform edges and transitions between curb ramps and vehicular traffic streets.
Accessible pedestrian signals provide useful and meaningful equivalent access to the information provided by visual pedestrian signals at traffic intersections. I find them very useful and would like to see many more of them installed. Indeed, if a visual indication is warranted for sighted pedestrians who can see and evaluate traffic behavior at an intersection, then it is all the more warranted to provide that same information to blind pedestrians like myself at the same intersections, whose traditional reliance on audio cues from traffic is obsoleted to a great extent by intermittent traffic flows and today's much quieter vehicles. Individuals who do not consider these signals useful would be under no compulsion to use them, and therefore unaffected by their presence. I submit that if blind and visually impaired pedestrians do not need accessible pedestrian signals, then sighted pedestrians do not require visual pedestrian signals. I live near several traffic intersections where the flow of traffic is intermittent, making it normally difficult and occasionally impossible to discern what phase the traffic signal cycle is in. Installation of accessible pedestrian signals at these intersections would eliminate any such question, and greatly improve the safety of crossing these intersections for me and my fellow blind pedestrians.
Detectable edge warnings take the place of perpendicular drops at the ends of sidewalks which once made street crossing a routine matter for well-trained blind pedestrians. The present modification of many curbs to include curb ramps has often made it difficult for me and others like me to find the point at which the sidewalk and curb end and the street begins. Truncated dome detectable edge warnings provide a clear, distinct, unmistakable and safe means of notifying a blind pedestrian such as myself of a pending danger, namely the possibility or likelihood of perpendicular vehicular traffic. Correctly configured and installed detectable edge warnings should not impede the safe travel of other pedestrian groups, and can and do provide vital information which was previously readily available to blind pedestrians, and has been compromised by many current curb ramp installations.
The installation of detectable edge warnings at train and subway platform edges similarly provides necessary information to blind mass transit users that is also vital, and they serve an important role in enhancing the safety of blind passengers using these facilities. I have personally fallen from the platform at a local elevated railroad station to the tracks below, which I am certain would not have happened if there had been detectable edge warnings at the platform edges at that time.
Thank you for considering these comments and passing them on to the board. Please contact me via my reply address with any questions you may have concerning these issues.
Sincerely,
John R. Jeavons
Bruce E. Friedman, P.E., PTOE and the NCUTCD Signals Technical Committee, October 23, 2002
The attached are the collective comments of the Signals Technical Committee of the National Committee on Uniform Traffic Control Devices regarding 36 CFR Parts 1190 and 1191 [Docket No. 02-1] as published in the Federal Register on 6/17/02.
Bruce E. Friedman, P.E., PTOE
Vice President
Kimley-Horn and Associates, Inc.
Signals Technical Committee
National Committee on Uniform Traffic Control Devices
Memo to: Mr. Scott Windley, U.S. Access Board
From: Signals Technical Committee, NCUTCD
Date: October 23, 2002
Re: Comments on the portions of the June 17, 2002 " Draft Guidelines for Accessible Public Rights-of-Way" that relate to traffic control signals
The Signals Technical Committee of the National Committee on Uniform Traffic Control Devices has reviewed the above draft guidelines and has the following comments about the portions pertaining to traffic control signals and related items. We compliment the Access Board on tackling a wide array of impediments to the mobility of all citizens, particularly those with disabilities. Our concerns and comments relate to what we believe is a prudent response to these needs.
Section 1105.3 Pedestrian Signal Phase Timing
This section states that all pedestrian phase timing shall be calculated using a maximum pedestrian walking speed of 3.0 feet
We object to this requirement being applied to "all" intersections. Traffic engineers have always used judgment to decide when and where to apply devices, based on an engineering study of need. Where needs are documented, there are many tools available to the traffic engineer to serve populations that require more time to cross the street. If intersections have pedestrian signals that operate pretimed, pushbuttons can be installed to assist those with a need for more time to complete their crossing. If persons who need more time frequent an actuated intersection, longer clearance times can be provided by supplemental actuation, such as pushing and holding the pushbutton to distinguish those calls from ones requiring only routine timing. To require longer pedestrian clearance timing at all traffic control signals (since all signals, even those without pedestrian signals, must provide adequate time for pedestrians to cross a street if pedestrian movements regularly occur) is a total over-reaction to a need that may exist at some locations, but certainly not at all locations. At most locations there will be a price to pay (in the form of a reduced level of service on the arterial, increased congestion, and increased accident rate) with no offsetting benefit.
Likewise, including the curb ramps in the calculation includes the addition of 3 seconds
To universally apply these new guidelines, at 100,000 or more signalized intersections, whether needed or not, is, in our opinion, like providing STOP signs or traffic control signals at all intersections regardless of the need.
It would be interesting to know if the 3.0 feet
Section 1105.6.2 Roundabouts - Signals
This section requires a pedestrian activated signal for each crosswalk at a roundabout. The narrative clearly points out that some believe roundabouts should not be used in areas of high pedestrian activity. This is an accurate conclusion, and these new devices have limited application in urban areas because of that. In areas of heavy pedestrian activity, all pedestrians, not just those with disabilities, will have trouble crossing at roundabouts, especially those with multiple-lane approaches. But to require traffic control signals at these crosswalks would be the same as requiring a pedestrian actuated traffic control signal at every marked crosswalk, regardless of the difficulty of crossing, regardless of the amount of pedestrian traffic, and without any study indicating that they would be justified.
Few roundabouts would ever be built under these circumstances if this requirement stands. To discourage the use of an effective tool that can be used to minimize delay and congestion at locations that would otherwise have a higher crash rate is contrary to all sound traffic engineering principles. European roundabouts built to the new modern standards, with funneling to slow traffic, do not add pedestrian signals automatically. If a roundabout is built in the U.S., and pedestrian traffic experiences difficulties, actuated pedestrian signalization may well be justified, but it should not be required on every roundabout where pedestrian traffic of all abilities may not have any problem. The STC is opposed to this recommendation. Roundabouts should only be signalized where a need is shown. Other solutions, such as wider splitter islands or in-roadway warning lights, might be more helpful than signalization for pedestrians. Language pointing out the incompatibility of roundabouts and heavy pedestrian activity should be included.
Section 1105.7 Turn Lanes at Intersections
This section requires a pedestrian actuated traffic signal at right or left turn slip lanes (bypasses) for the crosswalk across these lanes, including the channelizing island. This again requires all situations be treated the same, regardless of need, and is counter to all traffic engineering principles that required study and justification for the installation of traffic control devices. The fact that these signals would seldom be actuated and drivers would not expect a red light at these locations does not create a safe situation for such crosswalks. Furthermore, these channelized lanes are typically 15 feet
There is an implication in these guidelines that somehow traffic control signals will improve safety and accessibility for all when applied. Traffic engineers know this is not true, and that often the opposite occurs. Proliferation of devices breeds disrespect and wastes resources that could better be used to provide facilities where the need is greater. The STC is opposed to this recommendation, and believes that it is not well-founded.
Section 1106 (and 1102.8) Accessible Pedestrian Signal Systems
The STC has been working with representatives of the blind community and mobility education specialists, as well as representatives of the US Access Board, on this for more than three years. Some language has been put into the MUTCD already. We have standardized certain functions of Accessible Pedestrian Signals (APS) where we know or want to shape good practice. What we do not yet know is how to standardize on these devices. We are aware that the Access Board has pioneered work on a synthesis of current technology. We know some of the current technologies are not effective or lack in certain features that we believe to be important. For that reason the NCUTCD has requested funding for research to answer the questions of effectiveness. We do not want to see a proliferation of such devices until the research is completed. The Transportation Research Board, under its National Cooperative Highway Research Program (NCHRP) has launched a comprehensive study to obtain this information. We are probably about 24 months away from implementing these results. In addition, the National Institute of Health has research underway that will complement that of the NCHRP. Two members of the STC serve on the NCHRP panel to ensure that the research provides the traffic engineering profession with the information we need to adopt standards governing the installation and operation of APS. The two research teams have overlapping membership, so we are confident that we can continue to work with members of the Access Board and the blind community to improve mobility. We have to deal with issues of where and under what conditions they will be installed. Perhaps a way to start is to standardize all pedestrian pushbutton locations for all traffic signals, and our STC task force is working on that. But it is premature and not in the public interest to adopt the guidelines now until such research is completed. Even the standardization of the location of APS is not yet answered, and to spell out exact locations for them as proposed in Section 1106.2.1 is premature, and may not be the correct location for certain complex intersections. The above mentioned research is also addressing that.
Section 1106.3 Pedestrian Pushbuttons
This matter is still being studied by the STC and we request a delay until we can obtain input from the research mentioned above. We agree that there needs to be more standardization of pushbutton locations, recognizing that corner radius geometry sometimes limits the options, and we hope to have all typical conditions covered. Certainly, prescribing the location of pushbuttons needs to take into account the minimum clear width also required, and this may be more important than meeting the exact requirements of the dimensions shown for pushbutton locations. We also need to find out more about locator tones before we can standardize on their sound levels and aiming.
Conclusion
In conclusion, we believe the Access Board is making progress in implementing the requirements of ADA. We are willing to work with all the stakeholders to help, but are concerned with "across-the-board" requirements that are unrealistic to achieve. Specifically, a 3.0 feet
Another important consideration is that the Access Board needs to recognize that agencies responsible for the installation of traffic control devices have limited resources. The requirements for Accessible Pedestrian Signals at all locations should not be applied universally, at the time of reconstruction or alteration, without prioritizing needs. We believe this will not be in the best interests of the very community that is being served by these new guidelines. Traffic engineers can evaluate and prioritize needs, with help from the affected community, as now provided for in the MUTCD. These guidelines ought to support that direction. To do less would not serve the community with disabilities.
Thank you on behalf of all of the members of the STC for your consideration of our collective comments.
Sincerely,
Bruce E. Friedman, P.E., PTOE
Chairman
Signals Technical Committee of the NCUTCD
cc: STC members
Sent in via e-mail by:
Bruce E. Friedman, P.E., PTOE
Kimley-Horn and Associates, Inc.
Deborah Brown, October 22, 2002
Many of the items in the draft guidelines for public rights-of-way are
premature, and many will not help the problem of public access for blind
pedestrians.
I am a member of the National Federation of the Blind living and working in
the Washington area. I have previously lived in south Florida, where there
are no sidewalks. I moved to the Washington area mainly because of improved
pedestrian access.
I appreciate the advocacy for the 3 feet
signals. This is the kind of requirement that would benefit all pedestrians.
No disability accommodations will help pedestrians if there are no signals
or designated pedestrian zones in the first place. Creating expensive
requirements for access may result in a decision not to signalize an
intersection or not to provide sidewalks on the grounds that these
requirements are too expensive. It is also pointless to have a politically
correct ramped, marked, and signalized intersection which is surrounded by
streets that cannot be navigated or crossed.
About intersection design: Poorly designed ramps are a problem for blind
pedestrians. It is better for the ramp to have steeper sides that can be
felt. Also, an ambulatory blind pedestrian is more likely to stay out of a
wheelchair user's way if he does not feel he must stand inside the ramped
area to be assured of crossing the street in the crosswalks.
The issue of raising the street level at intersections is an interesting
one. The main reason we want cars to slow down is to make the roads safe for
pedestrians and other drivers. Raising the street level to the level of the
sidewalk may make it unsafe for blind pedestrians. Why should law-abiding
citizens have to make this accommodation to criminals?
On accessible pedestrian signals: The rule for blind pedestrians is that
when the parallel traffic moves, the blind pedestrian moves. If this rule
can be applied safely, no APS is needed. (Of course this rule cannot be
applied 100% safely because not all drivers are law-abiding. We can never
hope to protect pedestrians or any other group from people who break the
law.)
APSs are complicated to use; therefore, the complexity of the
intersection
must merit the use of a complicated tool like an APS. For example, in
Montgomery County, Maryland, an ordinary four-way intersection, Fenton Street
and Wayne Avenue, has an APS. Anyone wishing to use the APS must find the
button using the locator tone, and then either listen for the signal or feel
the vibrotactile indicator. If the APS is not correctly placed, the
vibrotactile indicator is useless. Any blind pedestrian not using the APS
simply listens to the traffic. Anyone who could not manage to cross the
street without the APS could not cross it with the APS, making the APS
unnecessary.
The design of APSs is made much more complicated than necessary by the
presence of the locator tone. Locator tones are necessary because of
misplacement of the APS. Simply requiring the APS to be located within reach
of the pedestrian waiting to cross the street would make locator tones
unnecessary and APSs much more useful. Poor placement also makes the APS
much less useful because the sound is often coming from behind the person
crossing the street.
APSs should be installed only where the normal rules of street-crossing would
not apply. Examples might be (1) where there is little or no parallel
traffic; (2) where a pedestrian is given a walk signal ahead of the parallel
traffic; (3) where the length of the signal is long enough to cross only
when a pedestrian-activated signal is used. How would a blind pedestrian
know if a pushbutton APS is present without a locator tone? If a pole with a
signal is properly placed, the blind pedestrian would simply look at each new
intersection to find the signal.
Detectable warnings: I am concerned about the use of textures to send
messages. Does the textured surface mean "Walk here," "Don't walk here," or
nothing at all? It is preferable to use grass or sand, or some nonpaved
surface, if a barrier is intended.
Some people have recommended that textured surfaces be used only when a
surface is perceived as flat.
However, it is not the actual slope of the ramp, but the unnatural feel of
it, that tells a blind pedestrian that an area is a street crossing (in
addition to traffic noise). If the surrounding terrain is hilly, a gentle
slope is no different from surrounding areas. If the surrounding terrain
is flat, a gentle slope is quite noticeable. I recommend that other methods,
such as properly designed curb cuts, be used to indicate street crossings.
In Montgomery County wheelchair users are troubled by brick streets in the
downtown Rockville area. I know that many wheelchair users do not complain
about truncated domes, but I believe they are simply being courteous about
what they perceive to be someone else's access need. I fail to see how a
textured surface will be maintained through rain, snow, dirt and traffic.
I believe that many of the accommodations that will help blind pedestrians
are those that will help all pedestrians. These include (1) increasing the
timing on walk signals; (2) taking into account the auditory environment
when determining where to place pedestrian signals; (3) holding drivers
accountable for following the laws of the road; (4) providing public
education to all citizens, including those with disabilities, about
safe travel. Montgomery County, Maryland, where I live, is taking
initiatives in defending the rights of pedestrians. Without the human
interest in the issue, all fancy gadgets will simply cost money and fail to
improve the situation.
the APS is not necessary.
Brian R. Searles, October 25, 2002
STATE OF VERMONT
AGENCY OF TRANSPORTATION
OFFICE OF THE SECRETARY
Brian R. Searles, Secretary
Dear Members of the Access Board:
We have reviewed the Draft Guidelines for Accessible Public Rights-of-Way released on June 17, 2002. We are entirely supportive of the development of guidelines to assist transportation engineers and planners in providing a transportation system that provides access to all users. However, we have some reservations with the draft guidelines as presented. We have been made aware of the comments and recommendations being made by AASHTO on the draft guidelines and, in general, we concur with the proposed changes and concerns adopted by their Board of Directors on October 14, 2002.
In addition, we have the following specific comments:
1. Section 1103.3 - Clear Width - It is unclear how this provision is to be coordinated with existing ADAAG minimum width of 36 inches
2. Section 1105.3 - Pedestrian Signal Phase Timing - The use of the slower walking speed and longer crossing distance in calculating pedestrian signal phases will certainly have an impact on overall operation of traffic signals. The guideline, as written, does not address the situation of an exclusive pedestrian phase, in which all motor vehicle traffic is stopped. If multiple crosswalks exist, which one should be used to calculate the length of the exclusive pedestrian phase? We suggest that using 3.5 feet
3. Section 1105.5.3 - Approach (Pedestrian Overpasses and Underpasses) - The trigger of 60 inches
4. Section 1105.6.1 - Separation (at roundabouts) - As written, it is not clear what portion of the roundabout is considered as having "prohibited" pedestrian crossings. Would this be the area between marked crosswalks? Would any of the approach leading up to a marked crosswalk be included in the "prohibited" area? If visually impaired pedestrians generally use curbs to discern where it is unsafe to cross, why would roundabouts be treated differently than other intersections? Assuming that the circular nature of roundabouts is confusing to those with visual disabilities, maybe other technologies like audible messages could be used to clarify where marked crosswalks are and what type of intersection treatment is present.
5. Section 1105.6.2 - Signals (at roundabouts) - The requirement for signals at roundabout crosswalks will negate many of the traffic flow and traffic calming benefits that roundabouts offer over traditional signalized intersections.
6. Section 1105.7 - Turn Lanes at Intersections - The requirement for signals at all crosswalks that cross slip lanes will have significant impacts on overall traffic flow, in addition to significant cost increases.
7. Section 1106.3.4 - Optional Features (of pedestrian pushbuttons) - It is unclear what additional features could be activated by pedestrian pushbuttons. A listing of these potential features would be helpful.
8. Section 1111.3 - Location (of alternate circulation path) - It is proscriptive to state that the alternate route must be on the same side of the street as the closed sidewalk. It may be more helpful to state that the preferred route is the same side of the street, unless it is unsafe to do so, in which case nearby parallel routes may be provided.
We appreciate the opportunity to comment on the draft guidelines. Please do not hesitate to contact me if you have any questions or require additional information.
Sincerely,
Brian R. Searles
Secretary of Transportation
Melanie Brunson, October 25, 2002
COMMENTS OF THE AMERICAN COUNCIL OF THE BLIND
Regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
Docket Number: 02-1
Submitted: October 24, 2002
Submitted by: Melanie Brunson, Director of Advocacy and Governmental Affairs
The American Council of the Blind (ACB) is pleased to submit the following comments on the Draft Guidelines for Accessible Public Rights-Of-Way, which were issued on June 17, 2002.
The American Council of the Blind (ACB) is a national membership organization of people who are blind and visually impaired. ACB is dedicated to improving the quality of life, equality of opportunity and independence of all people who have visual impairments. Its members and affiliated organizations have a long history of commitment to the advancement of policies and programs which will enhance the safety of pedestrians who are blind and visually impaired. For this reason, the Draft Guidelines for Accessible Public Rights-Of-Way proposed by the Access Board are of great interest to us.
By way of general comment, we want to let the Access Board know that we support the recommendations contained in this draft, and we believe that their implementation would make travel on public ways much safer for people who are blind and visually impaired. In the paragraphs that follow, we will highlight some of the proposals which we believe have the greatest impact on pedestrians who are blind and visually impaired and provide our comments thereon.
Section 1104 Curb Ramps And Blended Transitions
ACB concurs with the Access Board's recommended guidelines with regard to curb ramps and blended transitions. Of particular interest is the requirement in Section 1104.3.2 that detectable warning surfaces be provided wherever a curb ramp, landing, or blended transition connects to a crosswalk. We strongly support this requirement, and would urge the Access Board to retain it without exception. If detectable warning surfaces are to be incorporated into the public right-of-way in an effective manner, their application must be consistent. We believe that their use as a means of indicating to the visually impaired pedestrian that they are approaching an area in which traffic is likely to be moving is reasonable and will enhance the safety of such pedestrians. The suggestion that detectable warnings should only be installed where the slope of a curb ramp is 1:15
Section 1105 Pedestrian Crossings
1105.4 Medians and Pedestrian Refuge Islands: ACB supports the requirement for installation of detectable warnings on medians and pedestrian refuge islands set forth in 1105.4.2. We concur with the Board's conclusion that an exception is appropriate for islands where the crossing is controlled by signals which are timed for full crossing.
1105.6 Roundabouts: ACB supports the recommendations in 1105.6.1 that barriers be provided at roundabouts, along the street side of the sidewalk where pedestrian crossing is prohibited. Further, ACB concurs with the Board's recommendation that pedestrian activated traffic signals complying with 1106 be provided for each segment of the crosswalk, including the splitter island, as indicated in 1105.6.2. This appears to be the only feasible means of giving blind and visually impaired pedestrians safe access to the crosswalks at roundabouts, while causing a minimal interference with the flow of traffic on the roundabout. It is important that at these intersections, as well as at those intersections where a pedestrian crosswalk is provided at a right or left turn slip lane, a pedestrian activated traffic signal that complies with 1106 is provided for each segment of the pedestrian crosswalk, including the island.
Section 1106 Accessible Pedestrian Signal Systems
ACB supports the requirement that each crosswalk with pedestrian signal indication shall have a signal device which gives audible and vibrotactile indications of the walk interval. We agree with the Board that care should be exercised in the location of pedestrian push buttons to insure that, to the maximum extent feasible, push buttons for accessible pedestrian signals will be positioned where they can be located and activated by the pedestrian while leaving sufficient opportunity for the pedestrian to reach the curb in time to respond to the walk interval indication.
As an aid to this process, the locator tone required by 1106.3.2 is essential. In addition to alerting the visually impaired pedestrian to the presence of the push button, it draws the attention of non-disabled pedestrians to the push button, as well, increasing the likelihood of safer street crossings overall. In addition, as the locator tone becomes consistently incorporated into accessible pedestrian signal systems, the visually impaired pedestrian will have the benefit of knowing that further accessible information is forthcoming as a result of his/her activation of the push button. Since these tones are only audible at close range, if the recommended guidelines are followed correctly, they will not be disruptive to the surrounding community. Therefore, we believe their benefits far outweigh the minimal impact they may have on the environment.
We thank the Access Board for including specifications for pedestrian push buttons in 1106.3.3 regarding size and contrast. These specifications are important to facilitate their use by people who have low vision.
We believe that sections 1106.3.4 through section 1106.4.3 should be incorporated into the Access Board's rule in their entirety. These sections contain well-reasoned guidelines regarding the manner in which visually impaired individuals should be able to effectively access information about signal phases, as well as street identification and intersection design. It is essential that accessible pedestrian signals convey this information in a manner that is unambiguous and we believe these guidelines will accomplish this.
Section 1108 Detectable Warnings
ACB supports the Access Board's guidelines for the location and installation of detectable warning surfaces, as set forth in this section. We believe that the specifications contained herein minimize the accessibility concerns of persons who have mobility impairments, while greatly enhancing the ability of visually impaired people to access the public right-of-way in a safe manner.
As automobiles become quieter and traffic patterns become more complex, it becomes increasingly difficult, and unsafe, to rely upon the traditional sound of the traffic as the only means of determining when and where to cross streets. Pedestrians who do not have visual impairments are aided by signage and other visual cues for which people who are blind must compensate. It is our view that the Americans with Disabilities Act requires communities to take all reasonable steps to insure that people who are blind have access to the same information they provide to the general public. The guidelines recommended here represent a thoughtful and reasonable attempt to assist communities in carrying out that responsibility and we urge the Access Board to incorporate these guidelines into a rule for accessible public rights-of-way.
The members of ACB passed a resolution at their convention in 2002 reiterating their support for these guidelines, and expressing some further views with regard to appropriate features for accessible pedestrian signals. A copy of this resolution appears at the end of this document.
Thank you very much for your consideration.
Sincerely,
Melanie Brunson
Director of Advocacy and Governmental Affairs
AMERICAN COUNCIL OF THE BLIND
RESOLUTION 2002-24
WHEREAS, for many years, the American Council of the Blind (ACB) and its affiliates have advocated strongly for the use of accessible pedestrian signals, and have also been leaders in providing advice on the appropriate standards to govern their use and installation; and
WHEREAS, subsequent to the adoption of accessible pedestrian signals standards in the Federal Highway Administration (FHWA) Manual on Uniform Traffic Control Devices 2000 millennium edition, revised, as well as draft guidelines issued by the U.S. Architectural and Transportation Barriers Compliance Board (U.S. Access Board), many state and local jurisdictions are examining the extent to which changes should be made in the accessible pedestrian signals guidelines and standards contained in their traffic manuals; and
WHEREAS, ACB continues to encourage state and local jurisdictions to provide the highest level of access to the public rights-of-way and to ensure the safety of pedestrians;
NOW, THEREFORE, BE IT RESOLVED by the American Council of the Blind in convention assembled this 5th day of July, 2002, in Houston, Texas, that this organization urges state and local jurisdictions to include all of the following requirements in their traffic manuals:
(1) Consistent with the revised FHWA standards, the state or local jurisdiction shall not require that organizations which represent pedestrians with disabilities be in full agreement that there is a widespread demand for the installation of an accessible pedestrian signal at a specific existing signalized location in order for an accessible pedestrian signal to be installed;
(2) Whenever the state or local jurisdiction is installing a new, or upgrading an existing, signal, the signal shall be equipped with accessible pedestrian features;
(3) All accessible pedestrian signals shall contain the following features;
(a) A push button with a locator tone and a tone indicating when the walk interval is in effect.
(b) A vibrotactile device to indicate both that the walk interval is in effect and the direction to which it applies, through the use of a vibrating directional arrow or some other tactile indicator.
(c) Locator and walk interval tones which automatically adjust in volume in relation to ambient noise;
(4) Activation of the pedestrian traffic signal for a period of three seconds activates the accessible pedestrian signal; and
BE IT FURTHER RESOLVED that these standards shall not prohibit a state or local jurisdiction from providing additional accessible pedestrian signal features if requested; and
BE IT FURTHER RESOLVED that this organization transmit a copy of this resolution to the U.S. Access Board during the public comment period on its draft proposed guidelines on access to public rights-of-way, which ends October 28, 2002.
Adopted.
Donna Seliger, Secretary
Roger Petersen, October 28, 2002
My name is Roger Petersen and I live at [ ... ].
I am totally blind since birth and serve as Chairman of the Information
Access Committee of the American Council of the Blind. I am also
Vice-Chair of the Santa Clara County Commission for People with
Disabilities and the City of Mountain View Bicycle and Pedestrian Advisory
Committee.
I am strongly in favor of accessible intersections as defined by the draft
guidelines. As a blind pedestrian, I have learned the work-arounds that
some people mention as ways of doing without audible ped signals. But I
can tell you that it is much less stressful to cross intersections where
they exist. It has been the practice to provide walk signals for sighted
pedestrians, even though they are better equipped than blind pedestrians to
judge the traffic and watch the traffic signals. It seems only logical
that the same information should be available to blind pedestrians. In
many cases, there is turning traffic that is competing with pedestrians for
the crosswalk. In such situations, it is very helpful to know the exact
moment when the walk interval begins. Otherwise, while I am figuring out
that the ped interval has begun, the traffic will start turning in front of me.
In the area where I live, there are many of the old "cuckoo" type audible
signals. I have heard a lot about how these are not preferred. But I find
even those signals very helpful. Often the one on the corner to which I am
crossing gives some guidance in crossing. After all, the crosswalk lines
are also information that is provided to sighted pedestrians and to which I
believe I have the right. I would encourage the board to continue to
concern itself with best practices wayfinding information in crossing
intersections, such as tactile wayfinding or audible beacons.
I hope you find these observations helpful. I would be glad to answer
further questions you may have.
Sincerely,
Roger D. Petersen
Edmund Waddell, August 14, 2002
Roundabouts have been shown to reduce intersection injury crashes by 76% compared to signals, and to reduce fatalities by 90% (Retting et al, 2001). Results of these American studies, published by the Insurance Institute for Highway Safety, and by the American Journal of Public Health, are identical to findings from decades of overseas research. Put another way, comparable crossroad intersections have FOUR TIMES AS MANY INJURIES - including severe brain and spinal cord injuries - and about TEN TIMES AS MANY FATALITIES as a roundabout. Where roundabouts have replaced signals, repeated studies have shown they reduce pedestrian accidents by 30-50% (Lalani 1975, Daley 1981, O'Brien 1985).
In lay terms, roundabouts can keep people out of hospitals, wheelchairs, and graveyards, and that's a common reason they're built.
Unfortunately, these safety facts were not emphasized in Dr. Richard Long's report to the Access Board: a report which was used to develop the Access Board's current design proposals. The proposed new unfunded federal mandate would require complex signals and barrier systems at every roundabout crosswalk, regardless of how easily the crosswalk operates or whether a blind person ever uses it. At $100,000 or more per intersection, that's an expensive proposal, and since it has serious ramifications on public safety, it bears close examination.
Like more than 90% of US crosswalks, most roundabout crosswalks are not signalized. Because a pedestrian refuge is provided mid-crossing (shortening the crossing distance), and because vehicles operate at unusually low speeds (typically 15-20 MPH), the overwhelming majority of roundabout crosswalks are extremely easy to use, and like the vast majority of all crosswalks in the US, they simply don't need signals. In such locations, even if signals were provided, pedestrians wouldn't use them.
Traffic engineers have known for decades that, if unwarranted and infrequently used, signals can confuse drivers, become ineffective, and INCREASE accidents, causing more injuries to pedestrians and vehicle occupants alike. That's bad for public safety, but too few lay people understand it. People tend to think that signals always improve safety, but signals can increase speeding, distract drivers' eyes away from traffic and pedestrians, and create a false sense of security for pedestrians. Signals do not put a concrete wall between vehicles and pedestrians: pedestrians are struck at traffic signals with sickening regularity.
In locations where pedestrian and traffic volumes warrant them, crosswalks should have signals, and many roundabouts in the United Kingdom and Europe have pedestrian signals. They're common in London, Birmingham, and other cities. Examples of appropriate locations for signalized crosswalks include high-volume urban roundabout crosswalks, and locations where pedestrians (both blind and sighted) are most frequent. These factors are easily quantifiable. At rural intersections or low-volume locations, and locations where pedestrians are infrequent, signals are not used because they confuse drivers and unnecessarily increase highway construction, maintenance, and operating costs.
To assure that traffic signals are only installed where prudent, "warrants" have been developed for traffic signal installation in the United States. In the United Kingdom - a country with decades of experience with roundabouts in a wide variety of locations - the warrant for a signalized pedestrian crosswalk at a roundabout is where PV squared is greater than 1*10^8 (in words, where the number of pedestrians, times the number of vehicles per hour squared, exceeds a value of 100 million). Use of appropriate signal warrants assures that signals are provided only where needed, and not where they are unnecessary and potentially harmful.
The ramifications of an ill-considered intersection design policy can negatively impact the general public in unintended ways. For example, if ALL roundabout crosswalks were required to have signals, about $100,000 would be added to the cost of each roundabout, making them unnecessarily expensive in comparison to other intersection alternatives. As a result, far fewer roundabouts would be built, and many more of the common alternative - a signalized crossroad - would be built instead. As stated previously, studies show these have FOUR TIMES as many injuries, and TEN TIMES as many fatalities as a roundabout. The United States currently has about 15,000 deaths and about 1 million injuries at intersections every year, and installation of well-designed roundabouts might prevent countless human tragedies. Meanwhile, signals at unwarranted locations may help no one at all, and could in fact be harmful.
A single-user approach to traffic engineering would be a mistake. All users of an intersection must be taken into account, and the appropriate solution needs to be provided that will provide the greatest benefit to the public in each specific situation. No one wants more people injured or killed because we impose an ill-considered intersection design policy.
The Access Board proposal to require signals at all roundabout crosswalks needs to be reconsidered. Signals should be installed where they are warranted, and where there is no better alternative. In specific locations where users have special needs, the needs should be evaluated and provisions should be made in the design.
The opinions expressed above are those of the author, and do not represent an official policy statement of the State of Michigan or the Michigan Department of Transportation.
Edmund Waddell, Senior Transportation Planner
MDOT Project Planning Division
Lansing MI
Alonzo Liñán, P.E., November 1, 2002
City of Olathe
Re: Draft guidelines on accessible public right-of-way proposed by the U.S. Access Board.
Dear Mr. Windley:
Since the Rehabilitation Act of 1973, the city of Olathe has endeavored to maximize accessibility of city programs and facilities to all segments of our population. The city of Olathe has also incorporated the additional requirements of the Disability Act of 1990 and it subsequent revisions. All of these actions have been successful in removing barriers for the disabled and has provided access to all parts of the community to public services, programs and facilities. To date, none of these actions have resulted in a decrease of access to other segments of the community nor has it compromised the safety of other customers in our community.
Several of the proposed guidelines require pedestrian activated traffic signals at many locations. This blanket requirement for the placement of traffic signals in contrary to the MUTCD where at least some minimum warrant has to be met. Without at least minimum warrants, traffic signals will soon go the way of "Children At Play" and "Neighborhood Watch" signs. There will be so many traffic signals that when they are actually needed, they will be ignored. This is a very serious safety issue for the entire population.
The proposed draft guidelines will push communities like ours into a position of not providing facilities or services because of the cost of maintenance, rehabilitations and reconstructions as well as its impact on safety. In short, the Access Board's attempt to provide access for all people, at all times, for all programs, at all facilities, may deny access and services to all citizens of the community so that there will not be a "discriminated group". In the end, everyone will be treated equally as communities exercise their discretionary powers to not make improvements beyond a certain level.
Finally, I feel that many of these proposals are premature as statistical information is not available to draw conclusions from nor is there consensus between The National Federation of the Blind or the American Council of the Blind on many of these issues.
I hope the following comments illustrate these views.
Section 1102.2.2; Additions and Alternations - "Compliance in alterations is required except where it is 'technically infeasible.'"
My concern is that, as an engineer, the only thing that makes something "technically infeasible" is money and politics. This needs to be better defined.
"...such work might be technically feasible at other locations where acquiring right-of-way is practicable."
"Practicable" needs to be defined as well. Cities can use imminent domain, but the political ramifications of doing so for a sidewalk may force policy makers to avoid the project.
Section 1102.3; Alternate Circulation Path - "...call[s] for alternate circulation path are where pedestrian access routes are temporarily blocked by construction, alteration, maintenance, or other temporary conditions...(on the same side of the street parallel to the disrupted pedestrian access route)."
The concern is "or other temporary conditions". First, this needs to be more narrow in definition as snow can be considered a temporary condition. I would also suggest that the barrier requirement be changed to allow for barricades with modifications for the disabled.
Second, since an alternate path has to be parallel and on the same side, this may require easements to construct a temporary surface "to the outside". This speaks to a significant cost increase to repair or replace some sidewalk. If the sidewalk is on a 4 lane road and no easements or right-of-way exists "to the outside", then taking the outside lane of traffic may be the only other choice. But then you run into a curb, slope limits, additional traffic control... Regardless, a 30 minute job could now take hours.
In either case, the city will be faced with either increased costs for easements or potential reduced safety on the street by putting peds in the street; both of which may lead a city to determine that sidewalks may not be maintainable and, therefore, either removed or not put in.
Section 1102.4; Pedestrian Access Route - "...refers to the portion of the public right-of-way that serves as an accessible route."
What provision is there for sidewalks that are in easements? Does this proposed document extend into private property for public use but is not right-of-way? Does this unintentionally obviate easements for sidewalks in the future?
Section 1102.5; Protruding Objects - "...limited to a 4 inch
This could lead to a lot of unintended prohibitions. Examples include call boxes, pole mounted controllers, streetlight controllers, directional and informational signs...
Section 1102.12; Vertical Access - "Elevators are not required by these guidelines except at certain pedestrian overpasses and underpasses with elevation changes greater than 60 inches
Aside from the obvious maintenance and security issues, this will clearly prohibit any municipality from seriously considering any pedestrian over/underpasses.
Section 1102.14; On-Street Parking - "[For parallel parking] an access isle at 60 inches
This is too broad of a statement and is unreasonable for every block face. Is this just for downtown blocks or residential blocks as well? What is considered a block? This seems to ignore the curvilinear nature of suburban street design if it includes residential streets. This also assumes that there is a need for this specific number of parking; "blocks" can have more or less need. This also assumes that there are "parking stalls" already marked. This is certainly not the case in residential areas.
Logistically, this will come at a cost of at least three other parking stalls, if not more, and will negatively impact the sidewalk system. If the presumption is that a driver can pull next to the new curb so that the driver can utilize the additional 60 inches
The drainage will be severely affected as well. While the slope can be maintained for street drainage at the original curb line, this introduces ADA slope and transition issues to connect to a relocated sidewalk. The now relocated sidewalk becomes an unexpected variable for the blind and as such becomes a safety issue.
This one just needs to be dropped.
Section 1105.2.1; Pedestrian Crosswalk Width - "...shall be 96 inches
This is in inconsistent with the MUTCD which requires only 72 inches
Section 1105.2.2; Pedestrian Crosswalk Slope - "...slope shall be 1:48
This maximum cross slope will require "tables" at each intersection which will degrade the ride-ability of vehicular traffic and may compound grade problems in mid-block sections of steep roadways.
Section 1105.3; Pedestrian Signal Phase Timing - "All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
This is extremely unreasonable. The MUTCD indicates 4.0 f/s with the freedom to reduce as needed. To require 3 f/s and increasing the distance to include ramp lengths engender disrespect for the pedestrian indications as pedestrians will watch the flashing Don't Walk continue for as much as 15 to 20 seconds
Section 1105.6; Roundabout
This is a principle example of how the proposed accessibility measures will come at the cost of safety on the street. It is my hope that these "proposals" are only published to generate discussion and are not truly seen as reasonable.
Section 1105.6.1; [Roundabout] Separation- "Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited."
This is not consistent with other street designs and conditions. If the attempt is to prohibit the blind pedestrian from inadvertently crossing, then "regular" curves in the road become suspect. I find it difficult to accept that the blind pedestrian would consider "jaywalking"; which is what would be required if they were on any other curved street.
Section 1105.6.2; [Roundabouts] Signals - "A pedestrian activated traffic signal...shall be provided for each segment of the crosswalk, including the splinter island."
It appears form the discussion that there is a view that roundabouts are intrinsically unsafe for pedestrians. There is no documented proof that indicates that roundabouts are unsafe for pedestrians. It seems that this proposal is an attempt to pass judgement on the appropriateness of a traffic control device and recommend remedial actions without the benefit of any statistical data. If this gets adopted as written, it will effectively remove roundabouts as a traffic control and flow option as any traffic benefit will be negated with the presence of traffic signals.
So, again, in an attempt to provide access for all people, at all times, for all programs, at all facilities, cities will be forced to not make these improvements because of the cost, or not make these improvements because of the reduced or no benefit, or live with the more dangerous condition of following these rules and increase rear-end accidents, increase delay, increase air pollution, increase driver frustration...
The bottom line is that every traffic control device can be dangerous if not used properly and roundabouts are no different. The difference with roundabouts is that there are fewer conflict points, slower traffic, and less severe crashes. The addition would again negate all of these benefits and would make the intersection very complex for any pedestrian and driver.
Section 1105.7; Turn Lanes at Intersections - "Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal...shall be provided for each segment of the...crosswalk..."
What's a slip lane? If free-flow turn lanes are at issue, then there are literally thousands of existing "slip" lanes, both at signalized and un-signalized intersections. This is a common design element this requirement would essentially eliminate slip lane design from intersections.
Again, not until now have access accommodations resulted in a decrease of access and safety to other segments of the community.
Sincerely,
Alonzo Liñán, P.E.
Traffic Division Manager
City of Olathe
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
Robert R."Bob" Matti, October 28, 2002
I think it should be mandated that Accessible Pedestrian Signals and Detectable Warnings be present at all intersections with moderate to heavy pedestrian traffic. I urge this as a blind Guide dog user but honestly feel these devices will benefit all pedestrians significantly.
Robert R."Bob" Matti
Kimberly Pawling, COMS & RTC, October 28, 2002
To Whom It May Concern:
My name is Kimberly A. Pawling. I hold a certification in Orientation & Mobility (O&M) and in Rehabilitation Teaching with the Academy for Certification of Vision Rehabilitation & Education Professionals. I am an active member of AERBVI (the Association for Education and Rehabilitation of the Blind and Visually Impaired), and I am currently employed at CITE, Inc. in Orlando, Florida as the O&M Specialist and Rehabilitation Teacher. I have reviewed the following comments written by my colleage Mrs. L. Dianne Ketts, a member of the Environmental Access Committee for AERBVI, and I would like to submit comments on the Draft Public Rights-of-Way Accessibility Guidelines.
Curb Ramps and Blended Transitions (1104)
Detectable Warning (1104.3.2)
I support inclusion of specifications in the draft guidelines for detectable warnings and urge The Board to include requirements for detectable warnings at ALL slopes and curb ramps where a pedestrian way intersects with a vehicular way regardless of grade.
Pedestrian Signal Phase Timing (1105.3)
I support The Board's draft guideline for Pedestrian Signal Phase Timing, stating that "signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Medians and Pedestrian Refuge Islands - Detectable Warnings (1105.4.2)
I do not support the EXCEPTION to this recommended guideline stating that "Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing." It is my recommendation that this EXCEPTION be removed from the proposed guidelines.
Turn Lanes at Intersections (1105.7)
I whole heartedly support the recommendation for pedestrian activated traffic signals at these locations.
Accessible Pedestrian Signals - General (1106.1)
I support the inclusion of specifications for Accessible Pedestrian Signal (APS) systems.
Many intersections in the central Florida area are typical of intersections that can be found throughout the country. Minor, lightly traveled streets often intersect with major arteries. When a visually impaired pedestrian's intention is to cross the major artery, there is often little or no parallel traffic movement on the minor street to indicate that it is the appropriate time for the pedestrian to begin crossing. Accessible Pedestrian Signal technology provides information critical to determining when to begin a crossing in a format that is accessible to the visually impaired pedestrian.
I recommend that The Board use the term "Accessible Pedestrian Signal (APS)" when referring to these types of devices as opposed to "pedestrian signal systems" or "pedestrian signal devices." This terminology would more closely match the language in the MUTCD and current terminology. As a result, engineers and others utilizing the MUTCD when building public rights-of-way will be less likely to encounter conflicting or misguiding terminology.
Once again, thank you for the opportunity to comment.
Kimberly Pawling, COMS & RTC
CITE, Inc.
Mark Richert, October 28, 2002
Attached for the Board's consideration are the comments of the Association for Education and Rehabilitation of the Blind and Visually Impaired (AER). These comments were prepared after long and thoughtful scrutiny by members of AER's Orientation and Mobility Division. Please direct requests for further information to Janet M. Barlow [...]
AER and its members appreciate the opportunity to submit these comments and commend the Access Board for its diligence in addressing these pressing issues.
Sincerely,
Mark Richert
Executive Director
Association for Education and Rehabilitation of the Blind and Visually Impaired
Alexandria, VA
Contact: Janet M. Barlow
SUBJECT: Draft Guidelines for Accessible Public Rights-of-Way (June 17, 2002)
The Association for the Education and Rehabilitation of the Blind and Visually Impaired (AER) is an international membership organization of approximately 4600 professionals. Its mission is "to develop and promote professional excellence through support of those who provide education and rehabilitation services to people with visual impairments". The Orientation and Mobility Division of AER represents over 1000 orientation and mobility specialists, individuals who teach independent travel skills to persons who are blind or visually impaired. Certified Orientation and Mobility Specialists (COMS) are graduates of specialized college degree programs in education and/or rehabilitation. The following information and recommendations have been developed by the members of the Environmental Access Committee of AER's Orientation and Mobility Division.
We are delighted that guidelines for the public rights-of-way are now being developed that will address the needs of pedestrians who are blind or visually impaired. Following these recommendations is a resolution passed at the AER conference this summer in support of these guidelines. The transportation and public works community needs guidelines and specific direction to provide facilities that are accessible to pedestrians who are visually impaired or blind.
We are particularly pleased that specifications for detectable warnings and accessible pedestrian signals have been included. As representatives of a profession that has taught travel skills to individuals who are blind over the past 50 years, we recognize the evolution of intersection design and traffic control that now necessitates some of the modifications and accommodations that these guidelines require. Comparing a photo of an intersection in the 1960's with a photo of a current intersection makes it clear that the tasks and issues have changed. While individuals who are blind do cross streets without accessible pedestrian signals and do manage to locate the street edge without detectable warnings, these two tasks, in particular, have become much more difficult, and sometimes impossible, in the past twenty years due to changes in intersection design and signalization.
We strongly support the draft guidelines. The implementation of the draft recommendations on Accessible Pedestrian Signals (APS) and the resultant improvement in predictability and accessibility will go a long way towards insuring that the pedestrian environment remains accessible into the future. Please note in our comments, however, that we recommend that the Access Board add additional language specifying types of intersections where APS should be installed. In addition, we recommend some wording changes in the section on walk messages and suggest a more precise requirement for pole location than that in the PROWAAC report or the MUTCD. We feel that in new construction a tighter specification is possible, and necessary, to make the interface as unambiguous and quiet as possible.
Many who have provided comments seem to be misinformed regarding the types of APS recommended in these guidelines. Their comments and objections to "screeching signals" and "bird calls" indicate that they are unaware of the new types of signals recommended by PROWAAC and these draft guidelines. While many NFB members are expressing opposition to 'beeping signals' on every corner, the Access Board may wish to review articles by NFB President Mark Mauer in which he discusses signals in Australia and Sweden favorably ("World Blind Union Fifth General Assembly" The Braille Monitor, Vol. 44, No.3, March 2001 and "Blindness, Travel, the Environment, and Technology", The Braille Monitor, Vol. 42, No. 9, November, 1999, posted at www.nfb.org). The signals in Australia and Sweden include locator tones and audible and vibrotactile walk indications, installed close to each crosswalk location. This type of signal is exactly what these draft guidelines are calling for.
We have provided our response to the Board's question regarding detectable warnings in the section of these comments regarding the 'Discussion of Provisions'. We have also provided a response to the questions on roundabouts later in these comments. Many specific wording changes and the rationale for the suggested change are included later in this letter as well.
While the Board did not ask for specific comment on the issue of 'directionality' of curb ramps, we urge consideration of issues expressed in the PROWAAC discussions and research to develop solutions. Pedestrians who are blind or visually impaired try to avoid using the slope of the curb ramp as a cue to the direction of the crossing. However, it is difficult to avoid traveling and aligning in the direction of the slope. The detectable warning, as specified, is not an alignment cue, but a 'stop' indication.
The provision of additional alignment information at some types of curb ramps and blended transitions, particularly where the ramp is not aligned with the crosswalk direction, is needed. In addition, the PROWAAC committee was unable to agree on a specification for a tactile cue in the sidewalk to indicate the location of midblock crossings and roundabout crossing to pedestrians who are blind or visually impaired. Research is needed to identify solutions and address concerns of persons with mobility impairments as well as the needs of individuals who are blind or visually impaired. This research should evaluate the ability of pedestrians who are blind or visually impaired to detect and align with various surfaces, such as the bar tiles used in Europe and Japan, line tiles sold by US manufacturers, and other possible alignment surfaces, as well as the ability of wheelchair users and those with mobility impairments to navigate over and around such surfaces.
The Access Board should move as quickly as possible to implement this draft as a rule. Some in the transportation industry may urge waiting for the completion of additional research. Travelers who are blind or visually impaired are required to use the sidewalks and street crossings in their daily travel, usually in conjunction with the use of public transportation. They are at risk in traveling, due to the lack of consideration in current intersection and sidewalk designs. As additional research is completed, it can be incorporated into designs and provisions. These guidelines need to be completed and published as a final rule.
We encourage your consideration of the following specific comments as rulemaking process continues:
DISCUSSION OF PROVISIONS
Detectable Warning
The Board asks for response on a question regarding installation of detectable warnings only on curb ramps with a slope of 1:15
RESPONSE: We support the requirement for detectable warnings on ALL ramps and sidewalk/street transitions leading to crosswalks, regardless of slope. AER resolutions 98-01 and 94-08, supporting this requirement, follow.
Rationale: Two studies confirmed that removal of the curb was problematic for travelers who are blind. Barlow and Bentzen, found that 39% of blind travelers did not detect the street and stop when they approached the crosswalk on a curb ramp. Repeating their analysis using only the ramps that met ADA requirements at that time, (those that had a slope of 1:12
Roundabouts
We applaud the Board's strong stance on signalization of roundabout crossings. We expect that there are alternative solutions to provide accessibility, however, roundabout proponents have been slow to respond to concerns of pedestrians with disabilities. Proponents of roundabouts often quote the reduction in crashes as support for the safety of the installations. Crash data do not tell the whole story; there is little or no information on pedestrian avoidance of roundabout locations. Anecdotal information from Europe and Australia, as well as from US installations, indicates that pedestrians who are blind or visually impaired avoid crossing at roundabouts.
While there is ongoing research on the challenges for pedestrians who are blind or visually impaired and potential solutions, there is a need to slow the proliferation of inaccessible roundabouts in the United States. We believe that traffic engineers and designers who desire to solve this problem can do so, however, the will did not seem to be present until the draft guideline was published which required their attention to the issue. Many designers and governments who are complaining about the problems of signalization seem unable to consider pedestrian signals that function differently than those that have traditionally been installed in the US, as considered by the PROWAAC and the Access Board. The experience of England and other countries with signalization of pedestrian crossings at roundabouts should be considered.
Designers who develop better solutions can always install solutions that provide better accessibility, in full compliance with guidelines. We urge the Board to continue to require signalization of the pedestrian crossings.
1101.3 DEFINED TERMS
Detectable warning
ADD: standardized
Detectable Warning. A standardized surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path.
Rationale: Those reading the definition need to understand that the surface of the detectable warning is specified in ADAAG and that various textured surfaces may not meet the requirements of a detectable warning.
Locator tone:
CHANGE to: Pushbutton Locator Tone?a repeating sound that informs approaching pedestrians that they are required to push a button to actuate pedestrian timing and that enables pedestrians who have visual disabilities to locate the pushbutton.
Rationale: The above definition is the definition and term used in the MUTCD.
1102. SCOPING
1102.5.2 Protruding objects
1102.5.2 Post-Mounted Objects.
ADD: Where a sign or other obstruction is mounted between posts or pylons and the clear distance between post or pylons is greater than 12 inches
Rationale: We are delighted with the reduction of distance that objects can protrude from posts. This will eliminate many hazards in the sidewalk area. Pedestrians who are blind or visually impaired may travel on any part of the public sidewalk and are not limited to the pedestrian access route, a fact which many designers do not seem to understand.
The sentence regarding posts and pylons seemed to be missing a section regarding the distance between posts and pylons. In addition, we encourage the addition of the requirement for a lower bar on such signs. Signs between poles, and railings with their leading edges higher than 15 inches
The three principal cane techniques are: 1) the touch technique, where the cane is lifted slightly off the ground and moved in an arc from side-to-side and touches the ground at points outside both shoulders; 2) the constant contact technique, where the cane is slid from side-to-side in a path extending just beyond both shoulders; and 3) the diagonal technique, where the cane is held in a stationary position diagonally across the body with the tip just above the ground at a point outside one shoulder and the handle extended to a point outside the other shoulder. When one of these techniques is used and the element is in the detectable range, it gives a person of average adult stature, who uses proficient technique with a long cane, sufficient time to detect the element with the cane before there is body contact. The typical cane techniques do not locate objects extending into the travel path above the hips. For persons of short stature, including children, simple geometry indicates that they will be unlikely to detect objects with a long cane before contacting them with the body when the leading edge is as high as 27 inches
1102.7.1 Bus Route Identification. Exception 2
ADD: If portable receivers are required to access the signs, receivers must be freely distributed persons with disabilities who cannot read print signs.
Rationale: Allowing such an exception does not provide accessible information unless there is a concomitant requirement to distribute the receivers to those who may wish to access the information.
1102.8 Pedestrian crossings
CHANGE TO: Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, where pedestrian signal timing is actuated by pedestrian detectors (pushbuttons) or by passive pedestrian detection, or where leading pedestrian intervals or exclusive pedestrian phasing is used, pedestrian signals shall comply with 1106.
Rationale: The draft language does not require accessible information to be provided at intersections unless pedestrian signals are installed. The Manual on Uniform Traffic Control Devices (MUTCD) only requires (using 'shall' language) the installation of pedestrian signals at limited locations, such as school zones, crossings where a signal is installed due to high pedestrian volumes, and where there is exclusive pedestrian phasing. Other locations are discussed in 'should' language. We are concerned that this rule may encourage traffic engineers to limit the installation of pedestrian signals, in order to avoid installing accessible pedestrian signals. In the MUTCD, pedestrian signals are not required at some locations because the vehicular signal can be considered adequate, under provisions in the MUTCD, to provide information to pedestrians. Under the current draft guidelines, therefore, there would be no imperative to make the "green ball" information accessible. These locations may not provide adequate information for pedestrians who are blind without installation of accessible pedestrian signals.
The locations suggested above and in the PROWAAC report are ones at which the signal features make it hard to detect the pedestrian crossing phase without provision of accessible information. Locations such as those are known to be problematic for pedestrians who are blind or visually impaired. In addition, there may be other locations where the traffic movement does not provide sufficient information for pedestrians who are blind or visually impaired.
We are unable at this time to suggest language that will cover all possible situations in which accessible information may be needed by an individual pedestrian who is blind. Therefore we recommend that at signalized intersections in new construction where pedestrian facilities such as sidewalks are provided but pedestrian signalization is not, that conduit piping be installed in relation to the curb ramps such that a retrofit with APS if required could be easily accomplished.
As we stated previously, many who have provided comments seem to be misinformed regarding the types of APS recommended in these guidelines as well as the types of intersection signalization typically used now. (see our opening comments). Most newly installed intersections will be traffic actuated and will have complex traffic patterns. Pedestrian actuated traffic signals change with each cycle and usually require the pedestrian to push a button to get enough time in the cycle to cross the street. As well, the vehicular patterns and pedestrian timing may vary, depending on the signal timing plan of the intersection. The pedestrian timing may be concurrent with the traffic moving parallel to the pedestrian's path, or at a totally different time in the cycle. Pedestrians who misjudge the starting traffic pattern may find themselves in the street when cars are moving perpendicular to their path with a 'green arrow'. These changes have resulted in our advocacy for Accessible Pedestrian Signals to provide individuals who are blind or visually impaired with the signal information provided to persons who are sighted.
At the public information meeting in Portland, APS device costs of $4000 per device were suggested by some individual commenters. These estimates are incorrect. The cost of a pushbutton integrated APS, such as referred to in the draft guidelines, is currently approximately $400. per device. As with many items, that estimate may be reduced with quantity purchasing.
1102.10 Stairs
We agree with this addition that will make stairs in the public rights-of-way more visible to all pedestrians. We suggest a slight revision in the language.
DELETE: 'of color'
INSERT: "contrasting with the tread and riser, dark on light or light on dark,"
1102.10 Stairs. Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
Rationale: Light/dark contrast is the important feature, not color or hue.
1104 CURB RAMPS AND BLENDED TRANSITIONS
1104.3 Common Elements
MOVE: 1104.3 Common elements to 1104.2 and Types to 1104.3
Rationale: The common elements need to be more clearly described before the details of the various types of ramps. In addition, blended transitions may need additional language to clarify that a raised intersection or raised crosswalk could provide a blended transition.
1104.2.1 Perpendicular curb ramps.
ADD: Where possible, the slope of the curb ramp shall be aligned with the sidewalk and crosswalk direction.
Rationale: The orientation of curb ramps toward the intersection can be disorienting for travelers who are blind or visually impaired. In addition, they require an extra turn for wheelchair users. We believe that the guidelines need to encourage orientation of the ramp in the direction of travel on the crosswalk.
PROWAAC debated at great length on the issue of curb ramp orientation. While travelers who are blind or visually impaired do not use the slope of the ramp to determine their crossing alignment, it is difficult to prevent the slope from influencing travel direction. Advocates for pedestrians with visual impairments recognize the safety issues for wheelchair users of warping at the gutter/ramp intersection, however, whenever possible, the slope of the ramp should be aligned with the crosswalk and the grade break should be aligned perpendicular to the crosswalk alignment. The language of the guidelines needs to state that and encourage two ramps more strongly.
1105 PEDESTRIAN CROSSINGS
1105.4.2 Medians and Pedestrian Refuge Islands - Detectable Warnings
DELETE: Exception
Rationale: Detectable warnings inform the pedestrian who is blind or visually impaired about the presence of a cut-through island or median. They should be required at all medians and islands. Although the pedestrian may not need to stop at that location when the signal timing is adequate for a full crossing, slower pedestrians may prefer to stop and wait, if they know the refuge exists. In the absence of an APS, blind pedestrians frequently begin crossing during the clearance interval because of the difficulty of determining the exact onset of the walk interval, and the resulting inability to "claim" the crosswalk before vehicles turning across the crosswalk. Hence, they may have insufficient time to cross the street. Denying them the information that they have a safe refuge constitutes discrimination and endangers the life safety of pedestrians who are blind in such situations. Even in the presence of APS, because they are unable to make eye contact with drivers, pedestrians with visual impairments have difficulty claiming the crosswalk during the walk interval, and may be delayed in starting crossings relative to sighted pedestrians.
In addition, contacting the side edge unexpectedly when traveling within the cut-through section of the median can be disorienting and confusing if pedestrians do not realize they are within a median area. The detectable warning provides the pedestrian with information about the location of the cut-through refuge area.
1105.6 Roundabouts
1105.6.1 Separation
CHANGE TO: Continuous barriers landscaping separation or railings shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. When railings are used, they shall have a bottom rail 15 inches
Rationale: Use of the word barriers is confusing. Landscaping can be an appropriate guide to guide individuals to the crosswalk location, instead of a barrier or guardrail.
1105.6.2 Signals
We urge the Board to keep this language and requirement for signals at each crossing of roundabouts. See previous comments in answer to the question in the Preamble.
1105.7 Turn lanes at Intersections
We also applaud the inclusion of pedestrian activated signals at these locations, which have been problematic for pedestrians who are blind for years.
1106. ACCESSIBLE PEDESTRIAN SIGNAL SYSTEMS
1106. 1 General.
We recommend the use of the term "Accessible Pedestrian Signal (APS)", rather than Signal Systems or Pedestrian Signal Devices in this text to more closely conform to the MUTCD language and typical current terminology.
Rationale: The Board has introduced new language in these guidelines that does not match with language typically used in either the traffic engineering or the orientation and mobility professions. 'Signal system' is a defined term in the MUTCD ("Signal System - two or more traffic control signals operating in signal coordination"). 'Signal system' is not used with that meaning in these guidelines. It is important that engineers and those who are familiar with the MUTCD understand these guidelines properly.
1106.2 Pedestrian Signals.
CHANGE: Each crosswalk with pedestrian signal indication, or where pedestrian signal timing is actuated by pedestrian detectors (pushbuttons) or by passive pedestrian detection, or where a leading pedestrian interval or exclusive pedestrian phasing is used, shall have a signal device an Accessible Pedestrian Signal which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device Accessible Pedestrian Signal and shall comply with 1106.3.
Rationale: As stated earlier in our discussion of scoping, 1102.8, pedestrian signals are not required at some locations because the vehicular signal can be considered adequate, under provisions in the MUTCD, to provide information to pedestrians. These locations may not provide adequate information for pedestrians who are blind without installation of accessible pedestrian signals.
The term 'signal device' has a different meaning in the traffic engineering profession and may not be understood to mean a device that is commonly known as an Accessible Pedestrian Signal. There's no need to introduce confusion.
1106.3 Location.
CHANGE: Pedestrian signal devices Accessible Pedestrian Signals shall be located 60 inches
Rationale: In new construction, the location for the APS can and should be restrictive and consistent. The 'box' in the MUTCD was developed in consideration of retrofit situations and local practice; it is a large area 10 feet
The requirement of location more than 30 inches
1106.2.3 Audible Walk Indication
CHANGE: The audible indication of the WALK interval shall be by voice speech message or tone.
Rationale: The use of the term 'speech message' is more accurate. We are concerned that use of 'voice' will be considered to require the recording of human voice messages. Some methods of digital speech may provide more consistent messaging than individual recordings. Currently, AT&T provides text to speech messaging capabilities on the web and in commercially available software. (http://www.naturalvoices.att.com/demos/index.html)
1106.2.3.1 Tones.
CHANGE: Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds
Rationale: The current wording of the duration and repetition rate could be understood to indicate a continuous tone. We assume that the Board intended to require a tone such as is used in the Swedish or Australian signals. These repeat at rates of around 7 to 10 repetitions per second with short bursts of sound, with silence between tones of around 50 milliseconds. A repetition rate of 0.15 seconds
1106.2. Speech WALK Messages.
ADD A NEW SECTION
ADD: 1106.2._ Speech WALK Messages.
ADD: 1106.2. WALK signals may be in the form of speech messages.
1106.2._._ Speech WALK messages shall contain the words "WALK SIGN."
1106.2._._ Speech WALK messages shall repeat throughout the WALK interval or be combined with a repeating WALK tone.
Exception: Speech messages may be limited to a maximum of seven seconds in duration where pedestrian signals rest in WALK.
1106.2._._ At intersections having concurrent pedestrian phasing, speech messages shall follow the model: "Howard. Walk sign is on to cross Howard." Designation of "street, "avenue," etc. shall be used whenever its omission could lead to ambiguity.
Rationale: The language of speech walk messages must be consistent and these guidelines should repeat at least the same specifications as in the MUCTD. The MUTCD specifies that speech WALK messages should say 'Walk sign', in order to provide information about the status of the walk indication without providing a command, such as 'walk now'. Accessible Design for the Blind completed a survey of pedestrians who are blind, traffic engineers and orientation and mobility specialists last year and developed recommendations for speech WALK messages, as well as pushbutton informational messages. The recommended wording for WALK messages was "Howard. Walk sign is on to cross Howard."
In the US, speech WALK messages are commonly used in newer accessible pedestrian signal installations. All of the pushbutton-integrated devices on the market in the US are capable of providing speech messages. Speech WALK messages are not necessary to providing unambiguous information regarding which crosswalk has the WALK interval, provided that pushbuttons are installed in the locations specified, and they will be unintelligible to some users in some ambient noise conditions. However, speech walk signals are perceived as being more user-friendly than tonal WALK signals. Good installation has a number of requirements.
Speech WALK messages should continue to repeat throughout the WALK interval, or be combined with a WALK tone for the balance of the WALK interval so that pedestrians with visual impairments will know when the WALK interval ends, they will be aware of its full duration, and be able to initiate street crossings in knowledge of the status of the pedestrian signal. Combination of a speech WALK signal with a tone signal may have some of the advantages of both. It should be clear that this is permitted.
At many intersections of an arterial with a minor street, the pedestrian signal on the minor street "rests in WALK" during the vehicular green of the arterial, until a pedestrian or vehicle actuates the signal to enter or cross the arterial. WALK signals that sound continuously during what is sometimes a walk interval some minutes long will be particularly objectionable in neighborhoods. Most of the pushbutton-integrated APS have means to limit the WALK signal to a certain number of seconds. Pedestrians may be able to actuate the audible WALK signal multiple times during the same (rest-in-)WALK interval.
1106.2.3.2 Volume
ADD: Exception: When special activation is used to provide audible beaconing, the volume may exceed 5dB above ambient noise level.
Rationale: Special activation of louder signals may be useful in some situations to provide beaconing. If it is provided by special activation, such as a long press of the pushbutton, as suggested by PROWAAC and provided by several US manufacturers of APS, the louder signal will only sound when someone requests such a feature. Allowing a volume increase in response to special activation will provide some flexibility as these features develop in response to needs and as research continues on these issues.
Additional speakers mounted at pedhead might be found to provide directional information to pedestrians who are blind or visually impaired; we do not want these guidelines to prevent further evaluation of that option.
1106.2.3.3 Duration
ADD: WALK tones shall repeat throughout the WALK interval.
Exception: WALK tones may be limited to a maximum of seven seconds in duration where pedestrian signals rest in WALK.
Rationale: At many intersections of an arterial with a minor street, the pedestrian signal on the minor street "rests in WALK" during the vehicular green of the arterial, until a pedestrian or vehicle actuates the signal to enter or cross the arterial. WALK signals that sound continuously during a walk interval that is often several minutes long will be particularly objectionable in neighborhoods. Most of the pushbutton-integrated APS have means to limit the WALK signal to a certain number of seconds. Pedestrians can actuate the audible WALK signal multiple times during the same rest-in-WALK interval, if needed.
1106.3.2 Pushbutton Locator Tone.
ADD: Exception: When special activation is used to provide audible beaconing, the volume of the locator tone for the succeeding clearance interval may exceed 5dB above ambient noise level
Rationale: When special actuation of louder signals is used to provide beaconing, having the loudness of the pushbutton locator tone increased for the remainder of the pedestrian phase is essential to enabling those who need this assistance to home in on the opposite corner while they are still in the middle of the crossing.
1107.4 Arrow
ADD: more specific information on contrast
1106.4.Arrow. Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 (0.8 mm) minimum and shall be 1-1/2 inches
Rationale: Contrast in hue may not be perceptible but light/dark will be perceptible for most who use visual information.
1106.4.2 Street name
CHANGE TO READ: Accessible pedestrian signals shall include street name information aligned parallel to the crosswalk direction and complying with 703.3, or shall provide street name information in audible format.
Rationale: Street name information provided in audible format will be usable by more individuals than street name information provided in tactile format.
Providing street name information in tactile characters will result in signs that are very large. Most persons who read by touch read Braille. If there is a requirement for tactile street name information, it is more reasonable to require Braille information than tactile characters. It will serve those who will use it better, and require smaller, less expensive signs.
1108. DETECTABLE WARNINGS
1108.1.2 Size
CHANGE Add a maximum depth:
1108.1.4 Size. Detectable warning surfaces shall extend 24 inches
Rationale: We assume the Board did not establish a maximum depth of detectable warning because there is some research evidence that deeper warnings are more detectable. However, while research by Bentzen and others consistently found that blind persons more reliably detected detectable warnings at 30 inches
Failure to specify a maximum depth could result in continued installation of detectable warnings on the full surface of curb ramps. Installing such large areas of detectable warning surfaces as entire curb ramps provides less precise information to blind pedestrians than installing a smaller amount in a very predictable location. In addition, larger depth may result in increased expense and greater possible adverse impact on persons with mobility impairments.
1108.2.1 Curb Ramps and Blended Transitions
ADD EXCEPTION:
Exception: At cut-through islands and medians, the detectable warning may be located so that the edge nearest the crosswalk is at the curb line.
Rationale: The PROWAAC recommendation that detectable warnings be 6-8 inches
However, requiring that detectable warnings be 6-8 inches
1108.2.2 Rail Crossings
ADD EXCEPTION.
Exception: Where automatic gates across pedestrian ways bar pedestrian access to the crossing when rail vehicles are approaching or at a crossing, the detectable warning surface shall be located to the side of the automatic gate farthest from the crossing.
Rationale: Automatic gates can cause serious head injury to blind pedestrians approaching crossings. There is currently no reliable way for pedestrians who are blind to be notified of the location of automatic gates. Gate support is typically outside the normal pedestrian route and not likely to be encountered by blind pedestrians. Where there is a gate, a blind pedestrian may become trapped between the gate and the crossing, with the gate barring the way for the blind pedestrian to move farther away from the crossing.
Thank you for opportunity to comment. It is important that the needs of pedestrians, including those who are visually impaired or blind, are considered in the ADA guidelines.
Following: AER Resolutions
Resolution 2002 - 05
WHEREAS people with disabilities and in particular those who are blind or visually impaired have difficulties negotiating Public Rights of Way in the United States and in Canada; and
WHEREAS, in the United States, the Architectural and Transportation Barriers Compliance Board (Access Board) has developed draft design guidelines to ensure that access for persons with disabilities is provided wherever a pedestrian way is newly built or altered, and to insure that the same degree of convenience, connection, and safety afforded the public generally is available to pedestrians with disabilities; and
WHEREAS street crossings at signalized intersections are often inaccessible to pedestrians with vision impairments; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for
accessible pedestrian signals at all crosswalks with pedestrian signal
information, and guidelines to make all pedestrian pushbuttons accessible; and
WHEREAS in Canada, recommendations for revised standards for accessible
pedestrian signals and accessible pedestrian pushbuttons are currently being developed by the Canadian National Committee on Accessible Pedestrian Signals; and
WHEREAS where boundaries between pedestrian and vehicular ways are not
reliably detectable to pedestrians with vision impairments, these
pedestrians may be unaware when they move from the pedestrian way into the vehicular way; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for defining the boundary between the pedestrian way and the vehicular way by the use of truncated dome detectable warnings where curb ramps, landings and blended transitions connect to crosswalks, and at cut-through medians and islands, and at level rail crossings in the pedestrian way; and
WHEREAS crossings at roundabouts and slip lanes are often inaccessible to pedestrians with vision impairments because of difficulties inherent in determining safe crossing times based on acoustic information, and because of difficulties in locating crosswalks; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for
accessible pedestrian signals for each segment of each crosswalk, and
barriers where crossing is not permitted; and
WHEREAS pedestrians with vision impairments are at an equally great risk from objects protruding from poles and from walls; and
WHEREAS the U.S. Access Board has therefore proposed guidelines in which the amount by which objects may protrude from both poles and from walls is four inches; and
WHEREAS temporary circulation paths are independently usable by persons with vision impairments only if they know about them, and temporary barriers that are not detectable by the use of a long cane do not adequately protect pedestrians with vision impairments, or channelize them along an alternate route if they are not readily detectable by the use of a long cane; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for signs, and guidelines for barricades that are readily detectable by persons traveling with the aid of a long cane; and
WHEREAS persons with low vision are at particular risk of falling at stairs because of inability to visually determine the depth of tread and height of riser; and
WHEREAS the U.S. Access Board has therefore proposed a guideline for
contrasting color along the nosings of stairs, that will increase the
perceptibility of tread depth and riser height;
Therefore be it resolved that on this 21st day of July, 2002, in the city of Toronto, Ontario, that the Association for Education and Rehabilitation of the Blind and Visually Impaired (AER) commends the Access Board for attending carefully to the unique access needs of persons with vision impairments in the preparation of the Draft Guidelines for Accessible Public Rights-of-Way.
Be it further resolved that AER urges the U.S. Federal Highway Administration to bring the Manual on Uniform Traffic Control Devices into harmony with the Draft Guidelines for Accessible Public Rights-of-Way.
Be it further resolved that the AER urges the Transportation Association of Canada to incorporate the recommendations of the Canadian National Committee on Accessible Pedestrian Signals into the Canadian Manual of Uniform Traffic Control Devices.
Be it further resolved that the AER urges the Canadian Standards Association to consider harmonizing Canadian standards with the recommendations in the U.S. Draft Guidelines for Accessible Public Rights-of-Way concerning detectable warnings, protruding objects, temporary circulation paths, roundabouts and stair nosings.
RESOLUTION 94-08
WHEREAS professionals in Orientation and Mobility have observed that when visually impaired pedestrians approach streets at curb ramps they are at risk of walking unaware into the path of moving traffic, since there is no clearly defined distinction at curb ramps between the roadway and sidewalk; and
WHEREAS research has now been conducted which confirms that for persons who are visually impaired, there is a high level of risk of inadvertent street entry associated with the presence of curb ramps, particularly those having slopes of 1:12
WHEREAS it has been demonstrated that detectable warnings complying with ADAAG 4.29.2 are highly detectable by persons with visual impairments, and can provide an effective stop signal for persons who are blind or visually impaired which can be used to determine the end of the sidewalk and the beginning of the vehicular way; and
WHEREAS research has now been conducted which addresses concerns about safety of detectable warnings, indicating that detectable warnings on slopes have minimal impact on the safety and ease of travel for persons having physical disabilities (Bentzen, et al. 1994); and
WHEREAS research has demonstrated that 24 inches
WHEREAS consistency in dimensions and placement of detectable warnings is of critical importance in successful interpretation by the user in varied settings;
THEREFORE BE IT RESOLVED on this 13th day of July, 1994, in the city of Dallas, Texas, that AER urges the Architectural and Transportation Barriers Compliance Board (Access Board) to issue a rule requiring a 24 inch
BE IT FURTHER RESOLVED that AER urges the Access Board to issue a rule requiring a similar 24 inch
Resolution 98-01
WHEREAS Orientation and Mobility Specialists have observed that when visually impaired pedestrians approach streets at curb ramps they are at risk of walking unaware into the path of moving traffic, since there is no clearly defined distinction at curb ramps between the roadway and sidewalk; and
WHEREAS research has now been conducted which confirms that for persons who are visually impaired there is a high level of risk of inadvertent street entry associated with the presence of curb ramps, particularly those having slopes of 1:12
WHEREAS it has been demonstrated that detectable warnings complying with ADAAG 4.29.2 are highly detectable by persons with visual impairments, and can provide an effective stop signal for persons who are blind or visually impaired which can be used to determine the end of the sidewalk and the beginning of the vehicular way; and
WHEREAS research has now been conducted which addresses concerns about safety of detectable warnings, indicating that detectable warning on slopes have minimal impact on the safety and ease of travel for persons having physical disabilities (Bentzen, B., Nolin, T., Easton, R., Desmaris, P., and Mitchell, P., 1994; Hauger, et al, 1996); and
WHEREAS research has demonstrated that 24 inches
WHEREAS it was the nearly unanimous recommendation of the workshop on curb ramps and detectable warnings sponsored by the U.S. Access Board and Project ACTION in January, 1995, that no additional research was needed on detectable warnings at curb ramps and that a detectable warning should forthwith be required on the full width of curb ramps beginning at the curb line and extending back 24"; and
WHEREAS numerous municipalities in the United States have installed detectable warnings on curb ramps and have reported no instances in which safety has been compromised by the presence of detectable warnings on curb ramps;
THEREFORE BE IT RESOLVED on this 12th day of July, 1998, in Atlanta, Georgia that AER urges the U.S. Access Board to provide specific opportunity for public comment on detectable warnings at curb ramps and hazardous vehicular ways when the notice of proposed rulemaking for the revised ADA Accessibility Guidelines is published.
BE IT FURTHER RESOLVED that AER continues to strongly advocate the provision of a 24" wide detectable warning surface at the bottom of curb ramps and at hazardous vehicular ways, particularly where those hazardous vehicular ways are blended curbs or raised crossings at intersections.(See AER Resolution 94-08).
BE IT FURTHER RESOLVED that AER urges Transport Canada to require a 24" wide detectable warning surface at the bottom of curb ramps and at hazardous vehicular ways, particularly where those hazardous vehicular ways are blended curbs or raised crossings at intersections.
Resolution 98-02
WHEREAS the Americans with Disabilities Act guarantees the right of access to information to persons with disabilities; and
WHEREAS many signalized intersections provide information to pedestrians with sight which is not provided to pedestrians with visual impairments; and
WHEREAS it has been demonstrated ( Crandall, W., Bentzen, B.L., and Myers, L., 1998) that competent, independent, blind pedestrians at unfamiliar signalized intersections may initiate as many or more than 34% of crossings during the clearance or DON'T WALK intervals if those intersections are not equipped with accessible pedestrian signals; and
WHEREAS accessible pedestrian signals have been widely used for more than 10 years in countries including Australia, Japan, Sweden, and the United Kingdom and are considered by traffic engineers to be widely effective not only in providing information to blind pedestrians but also in decreasing general pedestrian delay and facilitating vehicular flow at signalized intersections; and
WHEREAS increasing numbers of quiet vehicles, including electric vehicles and those with quiet internal combustion engines, make acoustic information from vehicles inconsistent, resulting in the inability of pedestrians who are blind to reliably detect the onset of the WALK interval by listening for a surge of vehicles; and
WHEREAS inexpensive technologies exist to make Accessible Pedestrian Signals which are automatically responsive to ambient sound , being very quiet at night and in low traffic situations, while still loud enough to be heard above vehicular sound in high traffic situations; and
WHEREAS accessible vibrotactile and speech transmission signal systems exist which add no noise to the environment; and
WHEREAS the Transportation Equity Act for the 21st Century provides that "Transportation plans and projects . . . shall include the installation, where appropriate, and maintenance of audible traffic signals and audible signs at street crossings;"
THEREFORE BE IT RESOLVED on this 12th day of July, 1998, in Atlanta, Georgia that AER urges the U.S. Federal Highway Administration and Transport Canada to develop recommended practices for installation of pedestrian signals which make information which is regularly provided to other pedestrians, accessible to pedestrians who are visually impaired, including but not limited to: information specifying WALK and DON'T WALK intervals; information indicating the presence and location of push-buttons; and information unambiguously indicating the street to which the signal applies.
Resolution 98-03
WHEREAS traffic engineers are increasingly utilizing signal systems in which the only safe time to cross signalized intersections is provided in response to pedestrian use of a push button; and
WHEREAS persons who are visually impaired consistently identify location of the push button as the major problem they experience at pedestrian actuated intersections (American Council of the Blind survey, 1998; City of San Diego, Department of Transportation, 1994; and Tauchi, M., Sawai, H., Takato, J., Yoshiura, T., and Takaeuchi, K., 1998 ); and
WHEREAS persons who are visually impaired often have insufficient time when pedestrian push buttons are far from associated crosswalks, to actuate push buttons and then prepare to cross before the onset of the WALK interval (American Council of the Blind survey, 1998); and
WHEREAS unobtrusive technologies exist for providing information in accessible format, specifying the presence and location of push buttons;
THEREFORE BE IT RESOLVED that AER urges the U.S. Federal Highway Administration and Transport Canada to develop standards for push button location technology such as quiet audible locator tones, and to require the placement of newly installed pedestrian push buttons in close proximity to the top landing of the curb ramp serving that crossing, within accessible reach range for use from a wheelchair, and near enough to the curb line that persons with visual impairments can actuate the push button and then align and prepare for crossing before the onset of the WALK interval.
RESOLUTION 2000-05
WHEREAS there are roundabouts in many states in the United States, and many more are proposed or under construction; and
WHEREAS roundabouts have been shown to reduce the rate of serious personal injury crashes to drivers and passengers relative to similar signalized intersections, and thus have demonstrated their usefulness as an option for intersection design; and
WHEREAS despite the benefits to motorists, recent research at roundabouts in the U.S. indicates that blind pedestrians have difficulty at some roundabouts in determining appropriate times to begin crossing, and also may have difficulty locating crosswalks, aligning to cross the street, and maintaining their heading while crossing; and
WHEREAS focus groups of blind pedestrians conducted by U.S. researchers in the United Kingdom and France reported that the many roundabouts in those countries caused serious access problems for pedestrians who are blind or visually impaired; and
WHEREAS persons with blindness or visual impairments have the right to full access to public rights of way, including roundabouts;
NOW THEREFORE BE IT RESOLVED, this 19th day of July, 2000 in
BE IT FURTHER RESOLVED that, as research identifies best practices concerning roundabouts and blind pedestrians, these practices be implemented by traffic engineers and planners, and included in all U.S. and Canadian design manuals covering roundabouts.
Unanimously Approved
Patricia M. Beattie, October 28, 2002
COMMENTS OF THE COUNCIL OF CITIZENS WITH LOW VISION INTERNATIONAL
Submitted by:
Patricia M. Beattie, President
Council of Citizens With Low Vision International (CCLVI)
Regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
Docket Number: 02-1
The Council of Citizens With Low Vision International (CCLVI), of which I am the current President, is pleased to advise you and the Access Board of our endorsement of comments submitted by American Council of the Blind (ACB) on the above proposed guidelines concerning access to public rights of way.
CCLVI specifically calls for use of the universal attention and safety color bright yellow for warning surfaces which also should be detectable underfoot and upon sound of cane contact. We believe that the use of the bright yellow color is critical for detection by the growing number of older Americans who are living long enough to experience age-related vision loss, most of which is caused by macular degeneration. Of people who attain the age of 70, one of of ten will experience macular degeneration. This condition also greatly diminishes the ability to see when there is the glare of sunshine or bright lights, or conversely, light limited by night.
CCLVI believes that it is the right of visually impaired pedestrians to have access to the same information available to other citizens--that means conveyance of information normally provided on signs and signal lights iin other ways as well--tactily or audibly.
This includes information about whether an intersection is signaled, how to locate and to activate the pedestrian button and when the walk sign comes on. With the new designs of intersections and ways of controlling traffic flow, we no longer can depend only on usual patterns or sounds of or absence of traffic flow.
CCLVI supports use of an unobtrusive tone to indicate location of a traffic signal control button, typically not to be audible beyond a distance of ten feet.
We believe that the buttons should be located sufficiently close to the crosswalk so that individual pedestrians can return to the crossing in time for change to the walk signal.
We trust that the Access Board will pay attention to the quality and content of comments submitted on these proposed guidelines, not just quantity. If some blind people don't understand the importance of these issues, that is no reason to abridge accessability and safety for the vast majority of pedestrians, including those with visual impairments, sensitivity to light or night blindness.
Thanks you for this opportunity to comment on behalf of myself and the Council of Citizens With Low Vision International.
Sincerely,
Patricia M. Beattie, President
Council of Citizens With Low Vision
Attachments:
Comments of American Council of the Blind, as endorsed by CCLVI
ACB Resolution (attached to ACB comments below)
COMMENTS OF THE AMERICAN COUNCIL OF THE BLIND
Regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
Docket Number: 02-1
Submitted: October 24, 2002
Submitted by: Melanie Brunson, Director of Advocacy and Governmental Affairs
Mr. Scot Windley
Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board
1331 F. Street, N.W., Suite 1000
Washington, D.C. 20004-1111
Dear Mr. Windley,
The American Council of the Blind (ACB) is pleased to submit the following
comments on the Draft Guidelines for Accessible Public Rights-Of-Way, which
were issued on June 17, 2002.
The American Council of the Blind (ACB) is a national membership organization
of people who are blind and visually impaired. ACB is dedicated to improving
the quality of life, equality of opportunity and independence of all people
who
have visual impairments. Its members and affiliated organizations have a long
history of commitment to the advancement of policies and programs which will
enhance the safety of pedestrians who are blind and visually impaired. For
this reason, the Draft Guidelines for Accessible Public Rights-Of-Way proposed
by the Access Board are of great interest to us.
By way of general comment, we want to let the Access Board know that we
support
the recommendations contained in this draft, and we believe that their
implementation would make travel on public ways much safer for people who are
blind and visually impaired. In the paragraphs that follow, we will highlight
some of the proposals which we believe have the greatest impact on pedestrians
who are blind and visually impaired and provide our comments thereon.
Section 1104 Curb Ramps And Blended Transitions
ACB concurs with the Access Board's recommended guidelines with regard to curb
ramps and blended transitions. Of particular interest is the requirement in
Section 1104.3.2 that detectable warning surfaces be provided wherever a curb
ramp, landing, or blended transition connects to a crosswalk. We strongly
support this requirement, and would urge the Access Board to retain it without
exception. If detectable warning surfaces are to be incorporated into the
public right-of-way in an effective manner, their application must be
consistent. We believe that their use as a means of indicating to the
visually
impaired pedestrian that they are approaching an area in which traffic is
likely to be moving is reasonable and will enhance the safety of such
pedestrians. The suggestion that detectable warnings should only be installed
where the slope of a curb ramp is 1:15
adjoining those ramps not covered by detectable warnings will be detectable
without them. We are not aware of any research which supports this argument.
In addition, we would point out that it requires more than a determination of
the slope of a curb ramp to determine whether one is approaching a crosswalk,
or a driveway, or some other type of space. Traffic sounds, as well as other
audible and tactile cues can influence one's decision about the nature of the
space one is about to approach, and the absence of such cues can hinder the
pedestrian's ability to accurately assess the safety of the situation. The
use
of detectable warning surfaces at such locations would provide a safe way of
indicating that the approach to a vehicular way is imminent. It provides a
definite tactile cue to the visually impaired pedestrian without in any way
supplanting his/her judgment or interfering with his/her ability to exercise
good travel skills. Therefore, ACB supports this recommendation.
Section 1105 Pedestrian Crossings
1105.4 Medians and Pedestrian Refuge Islands: ACB supports the requirement for
installation of detectable warnings on medians and pedestrian refuge islands
set forth in 1105.4.2. We concur with the Board's conclusion that an
exception is appropriate for islands where the crossing is controlled by
signals which are timed for full crossing.
1105.6 Roundabouts: ACB supports the recommendations in 1105.6.1 that barriers
be provided at roundabouts, along the street side of the sidewalk where
pedestrian crossing is prohibited. Further, ACB concurs with the Board's
recommendation that pedestrian activated traffic signals complying with
1106 be
provided for each segment of the crosswalk, including the splitter island, as
indicated in 1105.6.2. This appears to be the only feasible means of giving
blind and visually impaired pedestrians safe access to the crosswalks at
roundabouts, while causing a minimal interference with the flow of traffic on
the roundabout. It is important that at these intersections, as well as at
those intersections where a pedestrian crosswalk is provided at a right or
left
turn slip lane, a pedestrian activated traffic signal that complies with 1106
is provided for each segment of the pedestrian crosswalk, including the
island.
Section 1106 Accessible Pedestrian Signal Systems
ACB supports the requirement that each crosswalk with pedestrian signal
indication shall have a signal device which gives audible and vibrotactile
indications of the walk interval. We agree with the Board that care should be
exercised in the location of pedestrian push buttons to insure that, to the
maximum extent feasible, push buttons for accessible pedestrian signals
will be
positioned where they can be located and activated by the pedestrian while
leaving sufficient opportunity for the pedestrian to reach the curb in time to
respond to the walk interval indication.
As an aid to this process, the locator tone required by 1106.3.2 is
essential.
In addition to alerting the visually impaired pedestrian to the presence of
the
push button, it draws the attention of non-disabled pedestrians to the push
button, as well, increasing the likelihood of safer street crossings overall.
In addition, as the locator tone becomes consistently incorporated into
accessible pedestrian signal systems, the visually impaired pedestrian will
have the benefit of knowing that further accessible information is forthcoming
as a result of his/her activation of the push button. Since these tones are
only audible at close range, if the recommended guidelines are followed
correctly, they will not be disruptive to the surrounding community.
Therefore, we believe their benefits far outweigh the minimal impact they may
have on the environment.
We thank the Access Board for including specifications for pedestrian push
buttons in 1106.3.3 regarding size and contrast. These specifications are
important to facilitate their use by people who have low vision.
We believe that sections 1106.3.4 through section 1106.4.3 should be
incorporated into the Access Board's rule in their entirety. These sections
contain well-reasoned guidelines regarding the manner in which visually
impaired individuals should be able to effectively access information about
signal phases, as well as street identification and intersection design.
It is
essential that accessible pedestrian signals convey this information in a
manner that is unambiguous and we believe these guidelines will accomplish
this.
Section 1108 Detectable Warnings
ACB supports the Access Board's guidelines for the location and
installation of
detectable warning surfaces, as set forth in this section. We believe that
the
specifications contained herein minimize the accessibility concerns of persons
who have mobility impairments, while greatly enhancing the ability of visually
impaired people to access the public right-of-way in a safe manner.
As automobiles become quieter and traffic patterns become more complex, it
becomes increasingly difficult, and unsafe, to rely upon the traditional sound
of the traffic as the only means of determining when and where to cross
streets. Pedestrians who do not have visual impairments are aided by signage
and other visual cues for which people who are blind must compensate. It is
our view that the Americans with Disabilities Act requires communities to take
all reasonable steps to insure that people who are blind have access to the
same information they provide to the general public. The guidelines
recommended here represent a thoughtful and reasonable attempt to assist
communities in carrying out that responsibility and we urge the Access
Board to
incorporate these guidelines into a rule for accessible public rights-of-way.
The members of ACB passed a resolution at their convention in 2002 reiterating
their support for these guidelines, and expressing some further views with
regard to appropriate features for accessible pedestrian signals. A copy of
this resolution appears at the end of this document.
Thank you very much for your consideration.
Sincerely,
Melanie Brunson
Director of Advocacy and Governmental Affairs
AMERICAN COUNCIL OF THE BLIND
RESOLUTION 2002-24
WHEREAS, for many years, the American Council of the Blind (ACB) and its
affiliates have advocated strongly for the use of accessible pedestrian
signals, and have also been leaders in providing advice on the appropriate
standards to govern their use and installation; and
WHEREAS, subsequent to the adoption of accessible pedestrian signals standards
in the Federal Highway Administration (FHWA) Manual on Uniform Traffic Control
Devices 2000 millennium edition, revised, as well as draft guidelines
issued by
the U.S. Architectural and Transportation Barriers Compliance Board (U.S.
Access Board), many state and local jurisdictions are examining the extent to
which changes should be made in the accessible pedestrian signals guidelines
and standards contained in their traffic manuals; and
WHEREAS, ACB continues to encourage state and local jurisdictions to provide
the highest level of access to the public rights-of-way and to ensure the
safety of pedestrians;
NOW, THEREFORE, BE IT RESOLVED by the American Council of the Blind in
convention assembled this 5th day of July, 2002, in Houston, Texas, that this
organization urges state and local jurisdictions to include all of the
following requirements in their traffic manuals:
(1) Consistent with the revised FHWA standards, the state or local
jurisdiction
shall not require that organizations which represent pedestrians with
disabilities be in full agreement that there is a widespread demand for the
installation of an accessible pedestrian signal at a specific existing
signalized location in order for an accessible pedestrian signal to be
installed;
(2) Whenever the state or local jurisdiction is installing a new, or upgrading
an existing, signal, the signal shall be equipped with accessible pedestrian
features;
(3) All accessible pedestrian signals shall contain the following features;
(a) A push button with a locator tone and a tone indicating when the walk
interval is in effect.
(b) A vibrotactile device to indicate both that the walk interval is in
effect and the direction to which it applies, through the use of a vibrating
directional arrow or some other tactile indicator.
(c) Locator and walk interval tones which automatically adjust in volume in
relation to ambient noise;
(4) Activation of the pedestrian traffic signal for a period of three seconds
activates the accessible pedestrian signal; and
BE IT FURTHER RESOLVED that these standards shall not prohibit a state or
local
jurisdiction from providing additional accessible pedestrian signal
features if
requested; and
BE IT FURTHER RESOLVED that this organization transmit a copy of this
resolution to the U.S. Access Board during the public comment period on its
draft proposed guidelines on access to public rights-of-way, which ends
October
28, 2002.
Adopted.
Donna Seliger, Secretary
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
Dr. Raymond F. Keith, October 27, 2002
I wish to submit the following comments on the Draft Guidelines for Accessible Public Rights-Of-Way, which were issued on June 17, 2002.
I am totally blind and have travelled with relative independence throughout this country and in many other countries of the world.
I have experienced the benefits of some of the technology referred to in these proposals, and know that they would be of great benefit to thousands of people in this country. My comments echo those of the American Council of the Blind, a national membership organization of people who are blind and visually impaired. By way of general comment, I want to let the Access Board know that I support the recommendations contained in this draft, and I believe that their implementation would make travel on public ways much safer for people who are blind and visually impaired. In the paragraphs that follow, I will highlight some of the proposals which I believe have the greatest impact on pedestrians who are blind and visually impaired and provide comments thereon.
Section 1104 Curb Ramps And Blended Transitions
I concur with the Access Board's recommended guidelines with regard to curb ramps and blended transitions. Of particular interest is the requirement in Section 1104.3.2 that detectable warning surfaces be provided wherever a curb ramp, landing, or blended transition connects to a crosswalk. I strongly support this requirement, and would urge the Access Board to retain it without exception. If detectable warning surfaces are to be incorporated into the public right-of-way in an effective manner, their application must be consistent. I believe that their use as a means of indicating to the visually impaired pedestrian that they are approaching an area in which traffic is likely to be moving is reasonable and will enhance the safety of such pedestrians. The suggestion that detectable warnings should only be installed where the slope of a curb ramp is 1:15
Section 1105 Pedestrian Crossings
1105.4 Medians and Pedestrian Refuge Islands: I support the requirement for installation of detectable warnings on medians
and pedestrian refuge islands set forth in 1105.4.2. I concur
with the Board's conclusion that an exception is appropriate for islands where the crossing is controlled by signals which are timed for full crossing.
1105.6 Roundabouts: I support the recommendations in 1105.6.1 that barriers be provided at roundabouts, along the street side of the sidewalk where pedestrian crossing is prohibited.
Further, I concur with the Board's recommendation that pedestrian activated traffic signals complying with 1106 be provided for each segment of the crosswalk, including the splitter island, as indicated in 1105.6.2. This appears to be the only feasible means of giving blind and visually impaired pedestrians safe access to the crosswalks at roundabouts, while causing a minimal interference with the flow of traffic on the roundabout. It is important that at these intersections, as well as at those intersections where a pedestrian crosswalk is provided at a right or left turn slip lane, a pedestrian activated traffic signal that complies with 1106 is provided for each segment of the pedestrian crosswalk, including the island.
Section 1106 Accessible Pedestrian Signal Systems
I support the requirement that each crosswalk with pedestrian signal indication shall have a signal device which gives audible and vibrotactile indications of the walk interval. I agree with the Board that care should be exercised in the location of pedestrian push buttons to insure that, to the maximum extent feasible, push buttons for accessible pedestrian signals will be positioned where they can be located and activated by the pedestrian while leaving sufficient opportunity for the pedestrian to reach the curb in time to respond to the walk interval indication.
As an aid to this process, the locator tone required by 1106.3.2 is essential. In addition to alerting the visually impaired pedestrian to the presence of the push button, it draws the attention of non-disabled pedestrians to the push button, as well, increasing the likelihood of safer street crossings overall. In addition, as the locator tone becomes consistently incorporated into accessible pedestrian signal systems, the visually impaired pedestrian will have the benefit of knowing that further accessible information is forthcoming as a result of his/her activation of the push button. Since these tones are only audible at close range, if the recommended guidelines are followed correctly, they will not be disruptive to the surrounding community. Therefore, I believe their benefits far outweigh the minimal impact they may have on the environment.
I thank the Access Board for including specifications for pedestrian push buttons in 1106.3.3 regarding size and contrast.
These specifications are important to facilitate their use by people who have low vision.
I believe that sections 1106.3.4 through section 1106.4.3 should be incorporated into the Access Board's rule in their entirety.
These sections contain well-reasoned guidelines regarding the manner in which visually impaired individuals should be able to effectively access information about signal phases, as well as street identification and intersection design. It is essential that accessible pedestrian signals convey this information in a manner that is unambiguous and I believe these guidelines will accomplish this.
Section 1108 Detectable Warnings
I support the Access Board's guidelines for the location and installation of detectable warning surfaces, as set forth in this section. I believe that the specifications contained herein minimize the accessibility concerns of persons who have mobility impairments, while greatly enhancing the ability of visually impaired people to access the public right-of-way in a safe manner.
As automobiles become quieter and traffic patterns become more complex, it becomes increasingly difficult, and unsafe, to rely upon the traditional sound of the traffic as the only means of determining when and where to cross streets. Pedestrians who do not have visual impairments are aided by signage and other visual cues for which people who are blind must compensate. It is my view that the Americans with Disabilities Act requires communities to take all reasonable steps to insure that people who are blind have access to the same information they provide to the general public. The guidelines recommended here represent a thoughtful and reasonable attempt to assist communities in carrying out that responsibility and I urge the Access Board to incorporate these guidelines into a rule for accessible public rights-of-way.
Thank you very much for your consideration.
Sincerely,
Raymond Keith
Walter Siren, October 28, 2002
I am pleased to submit the following comments on the Draft Guidelines for Accessible Public Rights-Of-Way, which were issued on June 17, 2002.
I am blind, and for this reason, the Draft Guidelines for Accessible Public Rights-Of-Way proposed by the Access Board are of great interest to me.
By way of general comment, I want to let the Access Board know that I support the recommendations contained in this draft, and I believe that their implementation would make travel on public ways much safer for people who are blind and visually impaired. In the paragraphs that follow, Iwill state some of the proposals which I believe have the greatest impact on pedestrians who are blind and visually impaired and provide my comments there on.
Section 1104 Curb Ramps And Blended Transitions
I concurs with the Access Board's recommended guidelines with regard to curb ramps and blended transitions. Of particular interest is the requirement in Section 1104.3.2 that detectable warning surfaces be provided wherever a curb ramp, landing, or blended transition connects to a crosswalk. I strongly support this requirement, and would urge the Access Board to retain it without exception. If detectable warning surfaces are to be incorporated into the public right-of-way in an effective manner, their application must be consistent. I believe that their use as a means of indicating to the visually impaired pedestrian that they are approaching an area in which traffic is likely to be moving is reasonable and will enhance the safety of such pedestrians. The suggestion that detectable warnings should only be installed where the slope of a curb ramp is 1:15
Section 1105 Pedestrian Crossings
1105.4 Medians and Pedestrian Refuge Islands: I support the requirement for installation of detectable warnings on medians and pedestrian refuge islands set forth in 1105.4.2. I concur with the Board's conclusion that an exception is appropriate for islands where the crossing is controlled by signals which are timed for full crossing.
1105.6 Roundabouts: I supports the recommendations in 1105.6.1 that barriers be provided at roundabouts, along the street side of the sidewalk where pedestrian crossing is prohibited. Further, ACB concurs with the Board's recommendation that pedestrian activated traffic signals complying with 1106 be provided for each segment of the crosswalk, including the splitter island, as indicated in 1105.6.2. This appears to be the only feasible means of giving blind and visually impaired pedestrians safe access to the crosswalks at roundabouts, while causing a minimal interference with the flow of traffic on the roundabout. It is important that at these intersections, as well as at those intersections where a pedestrian crosswalk is provided at a right or left turn slip lane, a pedestrian activated traffic signal that complies with 1106 is provided for each segment of the pedestrian crosswalk, including the island.
Section 1106 Accessible Pedestrian Signal Systems
I support the requirement that each crosswalk with pedestrian signal indication shall have a signal device which gives audible and vibrotactile indications of the walk interval. I agree with the Board that care should be exercised in the location of pedestrian push buttons to insure that, to the maximum extent feasible, push buttons for accessible pedestrian signals will be positioned where they can be located and activated by the pedestrian while leaving sufficient opportunity for the pedestrian to reach the curb in time to respond to the walk interval indication.
As an aid to this process, the locator tone required by 1106.3.2 is essential. In addition to alerting the visually impaired pedestrian to the presence of the push button, it draws the attention of non-disabled pedestrians to the push button, as well, increasing the likelihood of safer street crossings overall. In addition, as the locator tone becomes consistently incorporated into accessible pedestrian signal systems, the visually impaired pedestrian will have the benefit of knowing that further accessible information is forthcoming as a result of his/her activation of the push button. Since these tones are only audible at close range, if the recommended guidelines are followed correctly, they will not be disruptive to the surrounding community. Therefore, we believe their benefits far outweigh the minimal impact they may have on the environment.
I thank the Access Board for including specifications for pedestrian push buttons in 1106.3.3 regarding size and contrast. These specifications are important to facilitate their use by people who have low vision.
I believe that sections 1106.3.4 through section 1106.4.3 should be incorporated into the Access Board's rule in their entirety. These sections contain well-reasoned guidelines regarding the manner in which visually impaired individuals should be able to effectively access information about signal phases, as well as street identification and intersection design. It is essential that accessible pedestrian signals convey this information in a manner that is unambiguous and we believe these guidelines will accomplish this.
Section 1108 Detectable Warnings
I support the Access Board's guidelines for the location and installation of detectable warning surfaces, as set forth in this section. I believe that the specifications contained herein minimize the accessibility concerns of persons who have mobility impairments, while greatly enhancing the ability of visually impaired people to access the public right-of-way in a safe manner.
As automobiles become quieter and traffic patterns become more complex, it becomes increasingly difficult, and unsafe, to rely upon the traditional sound of the traffic as the only means of determining when and where to cross streets. Pedestrians who do not have visual impairments are aided by signage and other visual cues for which people who are blind must compensate. It is my view that the Americans with Disabilities Act requires communities to take all reasonable steps to insure that people who are blind have access to the same information they provide to the general public. The guidelines recommended here represent a thoughtful and reasonable attempt to assist communities in carrying out that responsibility and I urge the Access Board to incorporate these guidelines into a rule for accessible public rights-of-way.
Thank you very much for your consideration.
Walter
Jeffrey A. Hillegonds, P.E., August 14, 2002
In response to the proposed rule to signalize all cross walks at roundabouts.
Comments:
I am distressed to hear about the proposed rule to signalize all cross walks at roundabouts.
Not only would this be a large financial burden to place at these intersections, it is likely not needed at the vast majority of locations. This type of condition should not be placed as a blanket rule. Signalization, where warranted, can enhance safety for pedestrians and vehicular traffic alike. However, where it is not warranted, it will sometimes increase the risk to pedestrians by confusing drivers or, if the signal is seldom used, creating a dangerous situation because vehicles get used to ignoring unused signals in areas with very few pedestrians.
In addition, the function of the modern roundabout, to promote uninterupted flow through the intersection, particularly at the exits, could be effected, thereby impacting the capacity and safety for pedestrians and motorists alike.
Roundabouts have been constructed, without signalization for pedestrians, in locations like college campuses and other high pedestrian areas with great success.
In my opinion, this rule is not needed at all. A prudent design professional will add signalization where it is warranted. At the very least, the language should be changed significantly, to provide warrants and guidelines for the designer, not a blanket statement that this is required at all locations.
Please consider my comments and re-consider this rule. It is a very bad idea to dictate this type of design at all locations when it really is only needed a very small percentage of the time.
Jeffrey A. Hillegonds, P.E.
Senior Project Manager
Progressive AE
Grand Rapids, MI
Lloyd Rasmussen, October 14, 2002
I am filing my comments with regard to the Draft Guidelines for Accessible Public Rights of Way of June 17, 2002.
I am a member of the National Federation of the Blind, and support most of the recommendations contained in these guidelines. I am an electronics engineer, and have traveled in many places in the United States, using a long white cane, for forty years. This travel has included fair weather as well as foul, broken-down sidewalks, intermittent sidewalks, multi-lane street crossings, non-controlled street crossings, and much more. In 1992 I was one of the instigators of an NFB resolution that expressed some flexibility regarding the need for audible pedestrian signals. In 2001 I had the privilege of serving on a panel of the Maryland State Highway Administration which developed a set of warrants for the installation of "accessible" pedestrian signals.
I support the construction of more and better sidewalks, and a greatly increased understanding of the needs of pedestrians (particularly those who cannot drive) when vehicle ways and mass transit are being planned, re-purposed, reassessed and constructed.
I would not like to see these guidelines increase the cost of pedestrian accommodations so greatly that pedestrian access projects are not carried out or are postponed due to a lack of funds. I have the feeling that, even though thousands of hours have gone into the process of writing these guidelines, there are still too many proposed requirements that are "nice to have's" without properly delineating the "must-have's" of pedestrian access.
Blended transitions, perpendicular and parallel curb ramps: I am concerned that people are going to make blended transitions between sidewalks and streets the norm. Where is water supposed to drain?
Vehicles can tolerate more water on their paths than pedestrians can. I support the deprecation of "split the difference" curb ramps which dump pedestrians into the intersection instead of into the crosswalk.
If a blended transition is built, and detectable warnings are placed around the corner, in front of both crosswalks, how are blind pedestrians expected to know the direction of these crosswalks. This would seem to be problematic at intersections with little traffic, where the intersection is offset or not at right angles. Remember that most intersections will not have pedestrian signals of any kind installed, due to the lack of traffic.
When a parallel curb ramp is built, dividing a sidewalk into a portion sloping downward toward street level and a part which is not, what sort of "barrier is contemplated between the two adjacent sidewalk segments? A raised row of bricks? A guard-rail? I can't really picture this.
"Accessible" Pedestrian Signals: I have major reservations regarding the usefulness, safety, and consistent application of these devices.
I support the NFB's position on APS's whole-heartedly. But many NFB statements have mistakenly said that a pedestrian signal "informs a pedestrian when it is safe to cross." It does no such thing. It only informs pedestrians that they have an enhanced right of way for a specific period of time, which may or may not be noticed by drivers. Blind people must be enabled to engage in "defensive walking" as much as drivers are encouraged to drive defensively. In developing these standards, we must not forget the phenomenon that people (pedestrians and drivers) can only pay attention to a small number of stimuli at any particular moment. The unexpected event is usually the most dangerous one. I would hypothesize that a tactile stimulus does not compete for attention among audible stimuli as strongly as an audible stimulus does. Knowing when the pedestrian "start walking" interval occurs is important and useful. Knowing what vehicles around you are doing, and walking in the proper direction, is critical.
Many of the comments you are receiving on the guidelines are from people who have never experienced what is being proposed. You see far too many references to "chirping birds" and other sounds which are not proposed. Nobody should be told that these signals are good or bad until they know how they are supposed to work, and they have tried them.
In my opinion, the studies which the Access Board has conducted have involved really small numbers of blind people, and in many cases the work was carried out under artificial conditions, or only in good weather. And in some studies, the opinions and performance of sighted orientation and mobility instructors are counted as just as important as those of the people who will use the equipment--blind people. In the Washington, DC area, as of this writing, I don't think there are ANY intersections containing the proposed types of APS's, whose crosswalks, curb ramps and other pedestrian features comply with the proposed guidelines. Why should anyone be expected to endorse a system when it stands on several unstable legs, and has not been tested as a whole? Why should the Access Board mandate the installation of APS when they are poorly understood by the Americans who need to build and use them? I support further research and limited installations, to address problems such as we identified in our Maryland Highway Administration warrants system. But I believe that mandating "accessible" pedestrian signals across the board, in all cases, is premature, expensive, foolish and dangerous.
Locator tones: These ought to be called "locator clicks" because they ought to be short enough not to have a well-defined pitch. If the locations of these new signals can become standardized, no tones should be necessary. A cane or guide dog can find APS pedestals, if they are in predictable locations. Even though the guideline and the studies state that the sound pressure level at a distance of three feet should be "plus 2 to plus 5 dB" above the ambient sound level, there is no mention of the time constant of the gain control circuit which maintains this level, and where the ambient noise level is measured in order to control the APS's audio output. The investigators have forgotten that these signals, especially the locator tones, could be set several dB below the noise level and still be heard, because the human ear and brain can detect weak signals having specific frequencies and amplitude profiles. If the levels were reduced 5 or more DB below what is proposed, and the time constant for gain control shortened, there would be less tendency to hear "ping-ponging" signals from several APS around one intersection. Researchers and blind people must also decide, once and for all, whether they expect to use these signals as beacons while out in the middle of the street, or not. The new signals seem to be designed to "launch" a person into the intersection at the designated time and in a specific direction, and not to provide a beacon as the pedestrian is approaching the opposite side of the street. That's how I think they should work, but I don't know whether that is the expectation of the people who want to use these signals. And I don't know whether enough research has been done to verify that this concept works well for intersections which are extremely wide and/or extremely complex.
I am not yet confident that traffic engineers and their contractors will be able to install and maintain APS devices. Will shortcuts be taken in the interest of not burying cable, such as wirelessly controlled signals which are occasionally mis-activated or blocked by radio interference? Signals whose timing has gotten out of sync with the visual signal timing, but an inspector didn't notice or didn't know how to properly check? Directional arrows not lined up with the crosswalk for which the device is signaling? Devices mounted to the existing pole for the pedestrian activation button, even though the existing pole is several feet away from the "starting line" which the pedestrian should be on? But speaking of starting lines, I'm happy that the guidelines posit a slower walking speed, and therefore a longer pedestrian clearance interval.
It is often asserted that traffic is becoming quieter, especially with the advent of electric cars and better mufflers. It is true that the difference in noise output at idle between the loudest and quietest vehicles is increasing. Many trucks and buses are getting louder without limit. In other locations, the noise of building ventilation systems can mask much of the traffic noise. This situation, particularly electric cars, deserves somewhat more study.
Clearly, electric cars will make tire noise while they are moving. I might support the concept that such cars be required to emit some noise while stopped and ready to accelerate or turn. In other words, rather than create more noise and put new pedestals on the sidewalks, it may make more sense to insure that motor vehicles are audible, and also that the greatest contributors to noise pollution be muffled.
Detectable Warnings: I think there may be some intersections and islands where truncated domes would be useful. But again I would rather see ramps and curved edges for walkways, which can provide as much information as the domes can. The installation of detectable warnings at all covered intersections seems wasteful and unnecessary, unless "flat" or "raised" intersections are to become the norm.
Thank you for your consideration of all of these comments. I hope that sanity will prevail when these guidelines become a proposed rule.
Sincerely,
Lloyd Rasmussen
Susan Grossman, October 28, 2002
I am writing to express my support for the PROWAC's (Public Right of Way Advisory Committee) recommendations on accessible pedestrian signals and detectable warnings. I have visited cities in the United States that are in the vanguard of giving information available to sighted pedestrians to non-sighted pedestrians via audible signals. These signals are distinct and make it very easy for non-sighted pedestrians to cross intersections with much greater safety. I do not find these signals confusing and they do not interfer with traffic noise, which is used by some non-sighted pedestrians
use as an indicator. I also think that these signals are a much more effective means of determining whether it is safe to proceed than traffic noise. In very large and busy intersections it is extremely difficult to discern the difference in direction for traffice. Finally, with the recent introduction of electric and gas and electric cars which make little or noise, it is imperative that another means of notification other than traffic noise be instituted.
Thank you for taking my comments.
Susan Grossman