ADAAG Right-of-way Draft

Pedestrian Crossings

Related Public Comments: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31

1. 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

2. Per Gårder, August 6, 2002

   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

3. 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

4. Bill Baranowski, P.E., August 9, 2002

   I have read the proposed ADA rules for pedestrian crossings at roundabouts. I believe it is in the best interest of the public in the USA to

   The 20 roundabouts that I have designed and that were built in the last 8 years in the USA have not experienced any pedestrian crashes. In special situations where a high number of pedestrians cross I would consider an manually or passively activated signal and I have successfully used raised crosswalks and activated flashing warning LED lights and additional illumination. It was used because of the perceived need and was not dictated to me by the ADA. I would prefer that the access board allow engineers to use the good judgement they are paid to use.

   Will this mandate be applied to all regular traffic signal controlled intersections and any marked crosswalk at intersections or mid-block locations on our road system?

   Roundabouts are accessible to all users, and the solution should not be dictated but considerations open to site conditions, engineering judgement, and further research. Such a ruling at this point in time is premature and may serve to inhibit the use of roundabouts which I believe have great potential to reduce injury crashes to pedestrians and thus save many lives in the USA. An example of crash reductions due to roundabouts is contained in a recent study of two roundabouts located in Howard, Wisconsin. The study may be accessed at the following link: http://www.co.brown.wi.us/Planning/transportation_division.html

   This study shows the successful implementation of two roundabouts directly adjacent to an elementary school, a middle school and a new high school. The roundabouts achieved dramatic crash reductions and the school crossing guard indicated that the intersection is easier to cross since the roundabouts were installed. I would ask the board if it would be difficult to conduct similar trials if the proposed rule was enacted and enforced.

   Bill Baranowski, P.E.

   RoundaboutsUSA

   August 15, 2002

   Please add the following to your public input on the access board review of pedestrian safety at roundabouts. The attached designs for two 180' diameter roundabouts located in Riverdale, Utah are shown to illustrate the use of raised pedestrian tables at the entry and exits to roundabouts. The raised, textured and colored surface provides a tactile surface for pedestrian crossing. The gentle rise of the crossing area provides a decrease in speed to vehicles without reducing intersection capacity while creating a very visible crossing area that vehicles can see better than a painted crosswalk. It is possible that this design is superior to that of a pedestrian signal as well because flashing lights are often ignored by drivers.

   See attached photos from grand opening parade held in July 2002.

   Bill Baranowski

   RoundaboutsUSA

5. Laura Oftedahl, October 27, 2002

   I am a competent blind pedestrian - and strongly support accessible pedestrian signals. It is a very scary world crossing the street. I want to live, but need some help from this new technology. Thank you.

   Laura Oftedahl

6. Brian K. Copeland, P.E., October 25, 2002

   I commend your efforts on the development of the new accessibility guidelines. However, there are a few instances where implementation of these guidelines would be cost prohibitive or may not be feasible from an engineering standpoint. The needs of public agencies and designers need to be balanced with needs of disabled persons. My comments are as follows:

   1. Protruding Objects (1102.5). Traffic signal controller cabinets are frequently mounted on signal poles, especially in downtown areas where space is constrained. These cabinets would violate your proposed 4" guideline. I agree that these cabinets and other attachment to poles should be kept outside of the pedestrian circulation path, but there need to be provisions for allowing cabinets to be mounted on poles if they are outside the main pedestrian path. For example, the City of Portland has hundreds of these types of controllers mounted on poles. As written, this guideline would severely cramp design efforts and would be very costly to agencies.

   2. Detectable Warnings (1104.3). Truncated domes are used in the Portland area for pedestrian/at-grade LRT crossings. When a blind pedestrian experiences truncated dome treatments in the Portland area, they know they are about to cross a rail alignment. Other options should be evaluated for curb ramps outside of at-grade rail crossings (I have seen horizontal raised strips in some areas that seem to be effective). There needs to be distinction between crossing a road and crossing an LRT/heavy rail trackway.

   3. Pedestrian Signal Phase Timing (1105.3). Changing the pedestrian walk time from 4.0 ft/sec to 3.0 ft/sec will have significant, far-reaching impacts on our nation's transportation system. By reducing the walk speed, green time will be taken away from vehicle movements and the capacity of many intersections will be reduced. This would lead to the need for costly capacity improvements at intersections which most agencies cannot afford. Where did the 3.0 ft/sec come from? How much has this been studied? We need data/proof that lives will be saved if we do this...

   4. Roundabouts (1105.6). What type of signals are we talking about? Requiring all pedestrian crossings at roundabouts to include standard pedestrian signals would be a mistake and would defeat the purpose of the roundabout altogether. There are other ways (pedestrian activated warning flashers or signage, for example) to help create a safe pedestrian crossing. However, there needs to be flexibility to address this on a case by case basis. A signal of some type may be desired on a multilane roundabout, whereas a low-speed, single lane roundabout may only call for signage.

   I have worked as an transportation engineering/planning consultant in the Portland, OR area for the past 10 years and have broad experience in transportation design. Please consider the above input as you

   finalize the guidelines. Thank you.

   Brian K. Copeland, P.E.

   DKS Associates

7. 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.

8. Paul Plotas, P.E., PTOE, October 24, 2002

   Re: Draft Guidelines for Accessible Public Right-of-Way (June 17, 2002) Roundabout Alternative Design Strategies

   Dear Access Board:

   Although I certainly would not classify myself as a roundabout expert, I am a practitioner of traffic engineering with 16 years of experience. During my review of the "Draft Guidelines for Accessible Public Rights-of Way (June 17, 2002)", the following passage in particular caught my attention:

   To provide safer crossing at roundabouts, the draft guidelines would require pedestrian activated crossing signals at each roundabout crosswalk, including those at splitter islands. (The draft guidelines would ensure that such signals are usable b with vision impairments under requirements in section 1106 discussed below.) Although roundabouts are typically used to avoid signalization, the Board is not aware of alternatives that would allow safe passage for pedestrians with disabilities. Aside from accessibility, the use of roundabouts in areas of high pedestrian use has been questioned 4 some in the industry. Requiring the signal to be pedestrian activated may help limit the impact on traffic flow. Signal technologies are available that can further minimized the impact, such as devices that halt traffic only while a pedestrian is in the crosswalk. The Board seeks information on alternative design strategies and available technologies that can improve access at roundabouts for persons with disabilities, particular those with vision impairments.

   I developed the attached summary of my thoughts on this subject and respectfully submit it for your review.

   Please give me a call at [...] if you would like to discuss my thoughts further.

   Very truly yours,

   Paul Plotas, PE, PTOE

   --------------------------------------------------------------------------------

   Section 1 ? Introduction

   Introduction

   All at-grade pedestrian crossings of roadways are handled in one of the following two ways:

   Vehicular traffic is stopped, allowing the pedestrians to cross ? example: signalized intersections

   Pedestrians judgment determines appropriate crossing opportunities ? example: unsignalized intersections

   Typically, in both cases vehicles are already expecting to stop at an intersection and pedestrian crossings are accommodated. Roundabouts present a different challenge since vehicular traffic at the egress crosswalks will never be stopping for other vehicles, see Figure 1. Additionally, roundabouts present a particular challenge to visually impaired pedestrians since the geometrics of a roundabout distort audio information from vehicular traffic giving unclear audio clues. To aid pedestrians at roundabouts, one can either attempt to control vehicular traffic or improve the information provided to pedestrians. This report discusses these two alternatives.

   Referring to Figure 1, for the purposes of the following discussion, it is assumed that the pedestrian crosswalk is located approximately I to 2 car lengths from the edge of the central circle, which is the typical layout.

   Alternatives

   In this section various roundabout alternatives for both controlling vehicular traffic and for improving information available to pedestrians will briefly be explored.

   Control Vehicular Traffic

   There are at least four alternatives available to control vehicular traffic and give pedestrians the right-of-way at a roundabout egress pedestrian crossing.

   a. Stop sign

   b. Yield sign

   c. Traffic signal

   d. No control/Understanding that vehicle driver yields right-of-way to pedestrian

   a. A stop sign alternative breaks the basic principals of roundabouts: all traffic control of a roundabout is yield controlled. Additionally, with low pedestrian traffic, stop signs will serve no useful purpose the majority of the time, will eventually be ignored by drivers, and will eventually function as a yield sign, and probably as an uncontrolled intersection.

   b. As discussed for the sop sign alternative, at low pedestrian volume locations, vehicle drivers will also eventually ignore the yield sign, resulting in an uncontrolled intersection.

   c. A third method for controlling vehicles at the egress pedestrian crossing is a traffic signal, however, two issues immediately come to mind. The first is the issue that there is only storage for up to two vehicles before additional vehicles in the queue impede vehicular flow around the roundabout. Even with minimum timings for a signal, a roundabout with relatively low vehicular volumes will experience some blockage.

   Having the call for the signal solely dependent on pedestrian demand without regard to vehicular flow in the roundabout could have significant impacts to the capacity of the roundabout. It may be possible to place additional vehicle detectors strategically about the roundabout to delay the pedestrian call to a convenient time for vehicles; however, additional study will be required to determine if a suitable location is actually available.

   The second issue that comes to mind with signalized control is driver expectation, especially with low pedestrian volume roundabouts. If a driver continuously meets a green indication at a signal, driver expectation is that a green signal will be met every time. My personal observations are that at low pedestrian volume, mid-block, stand alone pedestrian signals, it is the combination of the physical person and the signal that alert drivers to the signal. My personal observations are that most pedestrians instinctively realize this and will not begin to cross a road, even with the signal giving the right- of-way, until they visually receive confirmation that vehicles are stopping. Sight distance for the mid-block pedestrian signal is very important. Although the same sight distance may be available at a roundabout, the curvature of the intersection at times focuses drivers' attention on negotiating the curves of the road and away from the distant cross walk. The bottom line of this discussion is that due to driver expectations, a signalized crossing could actually give visually impaired pedestrians a false sense of security, and further study is necessary to determine if this is true.

   d. Based on the discussion above, the final alternative, No control/Understanding that driver yields right-of-way to pedestrian is the alternative that the unsignalized alternatives default to, particularly at locations with low pedestrian volumes.

   Control Pedestrian Traffic

   There are at least two alternatives to control pedestrians while maintaining virtually free-flow conditions for vehicular traffic.

   a. No control, pedestrian judgment determines acceptable gaps

   b. "All Clear" Signal to pedestrians

   a. Due to distorted sound the no control alternative is unacceptable.

   b. The concept for the "All Clear" alternative is that vehicle detectors can be placed in the pavement upstream of the crosswalk as shown on Figure 2. The upstream detector could be coordinated with a pair of downstream detectors to determine when no vehicles are within the clear zone. When no vehicles are within the clear zone pedestrians would be given an "All Clear" signal.

   While it is possible to build such a system, the following issues deserve additional research.

   1. Do pedestrians have enough time to cross the egress lane in the scenario where a vehicle is just before the detector just as the pedestrian steps off the curb?

   2. Is it prudent to depend on technology to this extent to determine when conditions are all clear?

   3. What liability is involved with this alternative? (Is it really any different from a standard signalized intersection?)

   Conclusions

   The following problem with roundabouts has been identified: the circular portion of the roundabout creates confusing sound patterns. Being able to clearly read these sound patterns is essential for visually impaired pedestrians to safely cross the road. While it is possible to control vehicular traffic to enable pedestrians to cross, it is not obvious, at least to me, that the pedestrians will be safer. Instead of trying to control the vehicular traffic, I propose to improve the information available to pedestrians. It appears that by strategically placing detectors visually impaired pedestrians can have the same information as all other pedestrians to make informed decisions about when to cross.

9. 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.

10. Howard R. Della, September 21, 2002

    I would like to express my support for audible pedestrian signals. I have been fortunate to be able to use one near the Baltimore Inner Harbor. Believe me, it has made the experience of crossing such a very busy intersection much easier and safer for me. I just wish there could be more of them. Personally, I wish every intersection had one.

    Sincerely,

    Howard R. Della

11. 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.

12. Lisa Suarez, October 18, 2002

    I am writing concerning the audible pedestrian buttons. I am legally blind with a progressive eye disease. Where I live, there is an audible pedestrian button that I use often. I am glad it is there because it reassures me when to cross. It also helps me to align to cross properly. When the noise of the traffic is too loud or it is a windy day, It is hard for me to distinguish when it is safe to cross. With the audible pedestrian button there to help, I am able to travel confidently in those conditions. I know it is not necessary to have audible pedestrian buttons at every traffic light, but it is helpful at the extremely busy

    intersections. I know as my vision decreases I will not hesitate to continue to travel knowing that there is adaptive technology to assist me. Thank you for allowing me to express my opinion.

    Lisa

13. 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

14. Jay Grossman P.E., October 11, 2002

    I am concerned about two of the proposed changes, first concerning crosswalks: Limiting the crosswalk cross slope to 2% at intersections, and hence the roadway's profile grade to that same level, will significantly increase the cost of infrastructure improvements. Even here in flat Indiana, it is not unusual to have profile grades over 2% through an intersection. I would suggest that 5% (1:20) is a better number, consistent with current maximum grades on major routes.

    As pedestrian accessible routes at mid-block are apparently all right with a cross slope that matches the road profile grade, whatever it may be, perhaps a more tempered approach to cross slopes at intersections is appropriate.

    The grading required to flatten out an intersection will be extensive as vertical curvature requirements for roads don't allow for abrupt changes. Using Indiana design standards, at a 35 mph design speed typical in urban areas, flattening a 5% slope out to 2% at an intersection will require reconstruction of 180 feet

    My second concern is with roundabouts. First, the requirement for a barrier on the street side of the sidewalk seems unfounded. In lengthy reading on roundabouts in other countries, who have 30 or more years of experience using them, providing a physical barrier for detectability was never mentioned as having been a safety concern. As a detectable pattern at ground level is sufficient at a crosswalk or train station platform, why is the edge of a roundabout any more dangerous? Traffic in a roundabout generally circulates at 15 mph, much less than the 35-40 mph of traffic rushing for a green light at a signalized intersection.

    If a pedestrian steps over a curb into a roundabout, there is a much better chance that motorists will have a chance to stop or swerve than when a pedestrian steps into a crosswalk at a signal just as the light changes and a motorist is speeding to make the light. Furthermore, the accident data I have seen has never shown any instances of accidents involving pedestrians inadvertently straying into the circulatory roadway. Is it prudent to protect against a type of accident that has never occurred?

    Finally, the requirement for pedestrian activated signals at roundabout crossings also seems extreme. As stated before, traffic at roundabouts is going much slower than that at signals on a green phase, and the accident data reflect how these lower speeds affect safety. Watching a video of a roundabout at Michigan State University shows how, with 5000 pedestrian crossings a day, roundabout crosswalks are generally safer than those at signals. When a pedestrian steps into the crosswalk traffic has time, and does, slow to allow them to cross. Observing roundabouts in Colorado showed the same yielding to pedestrians in the crosswalks by traffic.

    A colleague participated in a visual impairment understanding exercise at a roundabout in Wisconsin. Blindfolded and with a cane, after a couple of tries with a guide, he was able to learn to listen for traffic and safely cross the roundabout approaches without aid. If a person blindfolded for less than half an hour can learn to cross safely at roundabouts, is it unreasonable to think those with permanent disabilities can learn to do the same?

    Thank you for the opportunity to comment,

    Jay Grossman P.E.

15. 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

16. David J. Barakian, September 24, 2002

    City of Palm Springs

    Department of Public Works and Engineering

    Palm Springs, CA 92262

    Re: Comments Regarding "Draft Guidelines for Accessible Public Rights-of-Way"

    Enclosed, please find the comments provided by myself, the Director of Public Works/City Engineer, and Phil Kaplan, the ADA Coordinator for the City of Palm Springs.

    Sincerely,

    David J. Barakian

    Director of Public Works/City Engineer

    Comments Regarding "Draft Guidelines for Accessible Public Rights-of-Way"

    Additions and Alterations (1102.2), 2

    Alternate Circulation Path (1102.3, 1111), 1

    Pedestrian Access Route (1102.4), (1103): I recommend that clearer guidance be given with respect to sidewalk cross slope through a drive approach, i.e. does a 48-inch "flat" area need to be provided around the approach in areas with curb adjacent sidewalk to avoid the large cross slopes in approaches? Also, I recommend the issue of sidewalk or pedestrian access adjacent to bay parking areas to be addressed. I feel sidewalks should not be allowed behind vehicles parking in "bays" 90 degrees

    Grade (1103.5), 1

    Surface Gaps at Rail Crossings (1103.7), 1

    Curb Ramps and Blended Transitions (1102.6, 1104), 1

    Pedestrian Signal Phase Timing (1105.3), 1

    Pedestrian Overpasses and Underpasses (1105.5), 1

    Roundabouts (1105.6):

    2

    3

    Accessible Pedestrian Signal Systems (1102.8, 1106), 2

    Street Furniture (1102.9, 1107), 1

    1102.2.2 Alterations: Impossible to interpret this.

    1102.8 Pedestrian Crossings: Is every crosswalk a pedestrian crossing?

    1102.9 Street Furniture: Not customers of a restaurant?

    1105.3 Pedestrian Signal Phase Timing, 2

    1105.6.2 Signals: With audible tone and vibro tactile indications?

    1109.2 Parallel Parking Spaces: These need a drawing to explain.

17. 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

18. Karen Bays, September 17, 2002

    I am writing to ask you to support the PROWAC report on detectable warnings and accessible pedestrian signals. These accommodations are crucial for those of us who are blind.

    As a blind pedestrian I encounter questionable traffic situations on a daily basis. There are a few corners where crossing causes a great deal of uncertainty as the traffic patterns are not regular and the turn lanes are active. It makes crossing dangerous and I have stood through several cycles of a crossing to make sure I can cross with some measure of safety. It also just seems to make sense that if the ""walk" "don't walk" information is important for a sighted person to know, that it would be even more helpful for those of us who are blind.

    I appreciate your support of the committee's report. It will go a long way to insure safer travel for those of us who are blind.

    Sincerely,

    Karen Bays

19. 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

20. Jacque Olsen, September 9, 2002

    I would like to voice my support for detectable warnings and accessible pedestrian signals to help blind and visually impaired people navigate more safely. I am visually impaired and I use a guide dog as my mobility aid, but I live in a large metropolitan area (Phoenix, Arizona) and it is becoming increasingly more difficult for me to determine when it is safe for us to cross when crossing at lighted intersections. This is especially true when we are crossing at an intersection without a large volume of traffic in the direction that we are walking. It is also a problem when crossing busy streets at pedestrian-only crossings.

    This will also become an issue as Phoenix and surrounding cities develop the light rail transportation system that was recently passed by the voters. I would like to think that these types of issues will be

    addressed during the design process.

    Thank you very much for your consideration of my concerns.

    (Mrs.) Jacque Olsen

21. L. Dianne Ketts, COMS, CLVT, October 28, 2002

    My name is L. Dianne Ketts. I hold a certification in Orientation & Mobility (O&M) and in Low Vision Therapy with the Academy for Certification of Vision Rehabilitation & Education Professionals. I serve as a member of the Environmental Access Committee of the Orientation and Mobility Division of AERBVI (the Association for Education and Rehabilitation of the Blind and Visually Impaired.) I am currently employed at CITE, Inc. in Orlando, Florida as the O&M and Low Vision Programs Coordinator. Please accept my comments on the Draft Public Rights-of-Way Accessibility Guidelines.

    Curb Ramps and Blended Transitions (1104)

    Detectable Warning (1104.3.2)

    I support inclusion of specifications in the draft guidelines for detectable warnings (1108 Detectable Warning Surfaces) and urge The Board to include requirements for detectable warnings at ALL slopes and curb ramps where a pedestrian way intersects with a vehicular way regardless of grade.

    Rationale: In my experience as an orientation and mobility instructor of visually impaired adults, even slopes greater than that of 1:15

    Pedestrian Signal Phase Timing (1105.3)

    I support The Board's draft guideline for Pedestrian Signal Phase Timing (1105.3) stating that "signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet

    Rationale: Because I serve many senior individuals and persons with other mobility impairments in addition to their vision loss, I often consider the benefit that a longer walk and pedestrian clearance phase would offer. Many clients I serve are not able to complete the crossing of multiple lanes of traffic in the normally allotted time of 4.0 feet

    Medians and Pedestrian Refuge Islands - Detectable Warnings (1105.4.2)

    I do not support the EXCEPTION to this recommended guideline stating that "Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing." It is my recommendation that this EXCEPTION be removed from the proposed guidelines.

    Rationale: Detectable warnings located at a median or refuge island give the visually impaired or blind pedestrian critical information regarding their location in relation to the crossing. The presence of detectable warnings may inform the pedestrian that the island is a place of refuge where they could possibly stop and rest if it were necessary. This may be especially important for a pedestrian who moves more slowly or with more difficulty.

    Turn Lanes at Intersections (1105.7)

    I whole heartedly support the recommendation for pedestrian activated traffic signals at these locations.

    Accessible Pedestrian Signals - General (1106.1)

    I support the inclusion of specifications for Accessible Pedestrian Signal (APS) systems.

    Rationale: Many intersections in the central Florida area are typical of intersections that can be found throughout the country. Minor, lightly traveled streets often intersect with major arteries. When a visually impaired pedestrian's intention is to cross the major artery, there is often little or no parallel traffic movement on the minor street to indicate that it is the appropriate time for the pedestrian to begin crossing. Accessible Pedestrian Signal technology provides information critical to determining when to begin a crossing in a format that is accessible to the visually impaired pedestrian.

    I recommend that The Board use the term "Accessible Pedestrian Signal (APS)" when referring to these types of devices as opposed to "pedestrian signal systems" or "pedestrian signal devices."

    Rationale: This terminology would more closely match the language in the MUTCD and current terminology. As a result, engineers and others utilizing the MUTCD when building public rights-of-way will be less likely to encounter conflicting or misguiding terminology.

    Detectable Warning Surfaces (1108)

    As I stated above, I support the inclusion of specifications for detectable warning surfaces.

    Once again, thank you for the opportunity to comment.

    L. Dianne Ketts, COMS, CLVT

    CITE, Inc.

22. 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.

23. Charles Carmalt, October 28, 2002

    In a separate e-mail I will be sending a Microsoft Word version of these comments with formatting as an attachment, which you may find more convenient to use. I will also mail that document as a letter to the Access Board.

    My original intent in responding to the draft standards was that I had been informed that the Board would be establishing 60" as the minimum width for sidewalks. I am glad to see that the Board has instead recommended a minimum width of 48". As discussed below, I believe that the wider width would result in fewer sidewalks being constructed, and would be severely counter-productive.

    However, the idea of requiring wider sidewalk widths is consistent with a general fault of many of the proposed guidelines. The guidelines appear to have been drafted to address common problems experienced in cities by different types of persons having disabilities, or at intersections on very heavily traveled arterial highways. However, the regulations of the Access Board will extend throughout the nation and will be applied on streets, roads, highways, lanes and other public rights-of-way in rural, exurban, suburban and neighborhood environments, not just in city centers. In many of these environments, some of the mandatory standards presented would be either inappropriate or, as in the case of 5' sidewalks, counter-productive by discouraging roadway design practices that soften the roadway environment and make roadways more convenient for all non-motorized users.

    I encourage you to critically evaluate the effect and appropriateness of these standards in environments where the frequency and intensity of conflicts between different users can be anticipated to be substantially less than in city centers and similar intensely used areas.

    My comments are as follows:

    Section 1101.3

    Defined Terms

    Cross slope. Cross-slope is not usually called superelevation. Superelevation is a roadway design treatment that adjusts the cross slope to mitigate the impact of curvature. I recommend that the second sentence be deleted.

    Similarly, if you must define superelevation, you should define it using language that in fact is descriptive. I looked for a definition in both AASHTO's Policy on Geometric Design and ITE's Traffic Engineering Handbook but found none. I suggest something like the following:

    Superelevation - an adjustment to the cross slope of a traveled way that is introduced to mitigate the outward centrifugal force created by a horizontal curve. Superelevation is conventionally termed "banking".

    However, I question whether a definition is required. You may wish to conduct a search to determine if it is used in the text of the regulations.

    Note that if you do use the term, you should use an all-inclusive term such as traveled way rather than roadway or highway. Superelevation can be introduced on paths and sidewalks as well as highways. Conversely, reverse superelevation, or banking in the reverse direction of a curve, can pose a special problem for persons in wheelchairs. Unfortunately, it is relatively easy to inadvertently introduce reverse superelevation along a pedestrian access route if the designer is not attentive.

    Section 1102.10

    Stairs. This section should be amended to provide guidance regarding where the use of stairs may be appropriate in public rights-of-ways. The guidance should strongly discourage the use of stairs except in situations where the natural grade clearly necessitates their use of stairs. Thoughtless designers who introduce unnecessary stairs into public the right-of-way are being cruel to all users.

    When stairs are introduced, they should be located out of the preferred pedestrian route so that most users will be attracted to a route without barriers.

    Section 1102.14

    On-street parking. On-street parking requirements should only apply in locations where the parking is used by the general public in a mixed use environment and where the parking supply is constrained.

    On most residential streets in suburbs, and many other streets, parking is permitted but only lightly used. I feel certain that most persons that might seek an accessible space in a confined and shared parking environment would seek to use a parking space most convenient to the specific destination in an unconfined environment. This could include blocking the driveway at the intended destination.

    In areas surrounding Lawrenceville, municipalities use accessible parking regulations to regulate spaces in front of homes or businesses that have individuals who regularly need such a reservation. This more flexible approach helps to protect proximity of parking for persons who need such protection. At locations where the general public is being encouraged to park, such as in a village center, the approach proposed in the draft regulations is currently followed.

    This section should establish conditions under which it should be implemented. This could either be a warrant based system using a variable associated with constrained parking demand, or it could be based on engineering judgment. Note that an approach frequently followed is to supply accessible spaces in convenient segregated off-street locations and allow the on-street supply to be used for persons not requiring accessible design. Where practical, this approach usually results in superior design.

    Proposed 1102.14 is an example of a regulation aimed at a dense urban environment that would be impractical or counter-productive in other environments. It should be more narrowly drafted.

    Section 1103.3

    Clear width.

    I strongly endorse the use of 48 inches

    Some language should be included to provide guidance where such additional width is required - for example surrounding hospitals, in retail centers, near nursing homes or other places that serve persons with disabilities, etc. A methodology should be presented for determining the amount of additional width required and the extent of the surrounding area within which widening should occur.

    Section 1103.3

    The minimum clear width should be enlarged to six feet if the pedestrian access route immediately abuts a curb. (Note: a curb represents a vertical edge that is a hazard not only for persons in wheel chairs and blind persons but for all pedestrians. Slipping off of a curb can cause serious injury. A requirement that sidewalks be widened if they abut a curb is relatively standard.

    Section 1103

    Add a section on edges.

    This section should include specific guidance regarding the treatment of edges adjacent to pedestrian access routes. Routes that abut a vertical surface such as a wall should be widened by at least one foot.

    The surface of a pedestrian access route should not directly abut an edge. Language similar to 405.9.2 should be provided describing edges and design approaches presented to indicated the protection that should be provided.

    I recently was walking along a bridge over a river that was constructed within the past three years. The wooden sidewalk has railings. However, the 5' boards that create the sidewalk terminate with no edge treatment or curb. Instead, a vertical drop to the river is presented at the edge. The user of a wheelchair could readily have a wheel caught in this edge, would be thrown against the railing and would be unable to extricate himself or herself. I will be working to correct this instance, put the regulations should prohibit it from occurring along a pedestrian access route.

    Section 1103.5

    Grade Exception. The proposed regulations allow for the pedestrian access route to be steeper than the grade of the adjacent roadway. I understand that there may be unique conditions in which this may be appropriate, in particular to create level platforms at doorways. However, the blanket exception, as worded, goes to far.

    In our area, and in many other suburban areas, designers of late have become very fond of introducing unnecessary vertical and horizontal curvature into sidewalks to make them more appealing to motorists. The vertical curves especially are an unwarranted and unnecessary burden to all pedestrians, and are a viciously cruel insult to persons in wheelchairs. Your regulations should include language requiring designers to keep pedestrian access routes as flat as possible and permitting exceptions only where other accessibility requirements require an adjustment.

    In addition, designers should be encouraged to introduce modest horizontal diversions, where appropriate, to reduce the grade of a pedestrian access route. Horizontal diversions should also be encouraged along routes that have a grade in excess of 1:20

    Section 1103

    Pedestrian Access Route and stairs. As indicated above, stairs should be kept out of the pedestrian access route. Where stairs may be desirable, the pedestrian access route should be designed in such a fashion that the route that employs stairs can be perceived as a secondary route.

    Where grades make steps unavoidable and an elevator is required, the elevator should be located in a convenient and obvious location requiring little circuitous travel. Standards are needed, appropriate for public environments.

    Section 1104.2.1.2

    Cross slope. The reason for exempting mid-block crossings from the maximum 1:48

    Section 1104.3.1

    Width. I strongly encourage you to require curb ramps or blended transitions to extend for the full width of a crosswalk, if marked, or the full width of the extending sidewalk if no crosswalk is marked.

    A person needing the use of a curb ramp should not have to search for its location but instead assume that a transition free of vertical change in level will be available at the roadway edge. In a city, fighting to move at right angles to the flow of pedestrians to the available curb ramp can be difficult and/or dangerous. In suburban areas, the crosswalk should provide visual guidance regarding the curb ramp location. See below regarding crosswalk width.

    Section 1104.3.4

    Grade breaks. As I understand this section, it applies only to grade breaks in curb ramps and blended transitions. The first sentence indicates that grade breaks are not permitted at curb ramps, blended transitions, etc.; the second sentence says that when they do occur they shall be flush. Either grade breaks are permitted or they are not permitted.

    I obviously don't understand the meaning of flush in the second sentence, and it is not defined. I think that you mean that there shall be no change in level at a grade break.

    From a practical perspective, this will be very difficult to achieve. With differential settling, differences of less than ¼ inch are bound to occur. Furthermore, unintentional grade breaks are likely to evolve. Do these exceptions become instantly in contravention of the regulations?

    Section 1104.3.5

    Changes in level. Similarly, although a project may be initially designed to result in no changes in level, the requirement that different materials be used in the sequence of devices described, curb ramps, landings and gutters, will over time result in some changes in level evolving. What reasonable approach should be permitted to allow minor, unintended changes in level but also require greater changes to be corrected?

    Section 1104.3.7

    Clear space in crosswalk. I and many other designers are working to reduce the length of crosswalks through the introduction of curb extensions and refuge islands. These can be very beneficial to all pedestrians. What we are trying to do is keep as much of the crosswalk as possible out of the roadway by narrowing the roadway as much as possible.

    The clear space within a crosswalk mandated by this section represents unneeded roadway width. This section will prohibit curb extensions. Is that really your intent? I strongly encourage you to revise this section. Please use the regulations to encourage the practice of installing curb extensions at crosswalks, not prevent it.

    Section 1105.2.1

    Width of crosswalks. The requirement that crosswalks have a minimum width of 8' is another example of introducing a regulation aimed at dense urban environments that would be impractical or counter-productive in other environments. It should be more narrowly drafted.

    Crosswalks in outlying areas are lightly used. While a downtown crosswalk may have several hundred persons crossing every hour, even thousands, in suburban areas we usually are talking about less than 100 per day. In this environment, the crosswalk markings are serving a different function, and the potential of conflicting pedestrian movements are very limited and easily overcome.

    A major purpose of the crosswalk lines in these less traveled areas is to direct pedestrians in the most advantageous and hopefully shortest route. The crosswalk lines can be very helpful in guiding persons to the curb ramps on opposite side of the street. They can also encourage pedestrians to cross at locations where motorists will have the best sight vision of the pedestrians.

    The wide width will restrict the utility of crosswalks in guiding pedestrians to the available curb ramps. In my opinion, an 8' width may reduce the visibility of the crosswalk compared to a 6' width, especially if transverse crosswalk lines are used.

    In heavily developed urban areas, on the other hand, crosswalk lines may need to be wider than 8'. A procedure should be provided to guide designers in those situations as well.

    Section 1105.2.2

    Cross slope. I recommend that you amend this language to specify that you are speaking of the cross slope of the roadway, not the cross slope of the crosswalk. I was very confused.

    Section 1105.3

    Pedestrian signal phase timing. As I understand this section, the draft regulations are requiring that a 14% slower walking speed be assumed. In addition, the regulations require that crosswalks be extended by 48" to provide a clear space within the roadway, and this section requires that the pedestrian clearance interval also include the length of the entire curb ramp, which often are 5 to 10 feet

    The net effect of this section will be to create very lengthy pedestrian crossing phases, necessitating longer traffic signal cycles. This in turn will encourage more pedestrians to illegally cross outside of the pedestrian phase, since they will grow impatient.

    I agree with the reduction in assumed walking speed. However, agencies should be allowed to retain other current procedures for timing pedestrian phases.

    Section 1105.6.2

    Signals at roundabouts. I strongly oppose this section. Roundabouts have many features that are beneficial to all pedestrians, including those with pedestrians. Most notably, crossing distances are substantially shorter, and motorists have much better ability to see crossing pedestrians compared to turning motorists.

    Requiring pedestrian signals at all roundabout crosswalks will substantially increase the cost of installing roundabouts. Since most pedestrians will ignore the signals, finding the short crossing distances easy to negotiate, the use of signals at these locations will breed contempt for traffic signals by pedestrians. If pedestrian signals are activated frequently, traffic engineers will develop lengthy signal cycles, frustrating pedestrians.

    Instead, the Board should work with AASHTO and Federal Highway to develop additional design guidance to enhance the visibility of crossing pedestrians and to encourage yielding behavior by motorists. Consideration should be given to using raised crossings or other traffic calming measures to slow drivers at roundabout crosswalks.

    If signals are to be required, there should be a volume warrant. As worded, this section would apply to any roundabout regardless of its environment if pedestrian crosswalks and facilities are provided. A neighborhood traffic circle with less than 1000 vehicles ADT would have to have signal controlled crossings even though no signal would be warranted without the circle and the circle would enhance pedestrian safety and slow vehicle speeds.

    At exurban locations, this requirement will encourage road designers to eliminate crosswalks and sidewalks so as to avoid the requirement to install pedestrian signals.

    I recommend that the Board instead seek to develop a warrant based crosswalk signal that would take into effect the volume of traffic using each roundabout approach and exit, and the volume of pedestrian activity. On roundabouts with high motor vehicle volumes but only limited pedestrian activity, a flasher system should be required to alert motorists to the presence of pedestrians.

    Finally, to the extent feasible, if pedestrian signals are to be introduced in areas with roundabouts, it should be done in conjunction with other pedestrian improvements that would move pedestrian crossing locations to mid-block sites independent of the roundabout. From a land use perspective, this is difficult, since it requires directing transportations away from their travel paths.

    This is an area requiring much more research.

    The proposal as presented is another example of introducing a regulation aimed at a dense urban environment that would be impractical or counter-productive in other environments. It should be more narrowly drafted.

    Section 1105.7

    Turn Lanes at Intersections. This section requires the provision of a pedestrian activated traffic signal at any right or left turn slip lane. My comments regarding roundabouts also apply to this recommendation.

    The proposal as presented is another example of introducing a regulation aimed at dense urban environments or suburban environments with intense vehicular traffic; it would be impractical or counter-productive in other environments. It should be more narrowly drafted.

    Slip lanes are introduced for many reasons. One important one is to accommodate the wide turning requirements of large vehicles with less pavement, especially at intersections with acute angles. This is desirable for all roadway users and can make pedestrian crossings easier to negotiate.

    Slip ramps may be appropriate on low volume roadways if the roadways intersect at a very acute angle or if there are large vehicles that use the intersection. In this situation, a traffic signal could not meet any reasonable warrant; a roadway designer would likely prefer to construct a wide, unchannelized intersection rather than install a traffic activated pedestrian signal.

    Even in urban locations, most pedestrians will ignore the pedestrian crossing device unless turning volumes are both high and continuous.

    Alternative designs for slip ramps are needed that improve a driver's ability to observe pedestrians and yield to crossing pedestrians. These improved designs exist, and also substantially reduce crashes between motor vehicles. By employing detectable warnings at crossing locations in combination with improved slip ramps, the negative impacts currently experienced can be substantially reduced. Use of rumble strips on slip lanes in advance of crosswalks should be tested as a method of alerting persons with visual disabilities of the presence of an approaching vehicle and would also alert motorists of the crosswalk.

    Finally, there is a need to establish a warrant based system to determine when pedestrian activated signals should be installed. I expect that this will usually only be necessary when the volume of turning traffic exceeds 1000 vehicles in the peak design hour.

    Section 1106.2.1

    Location of pedestrian signal devices. I may be misinterpreting this, but I think the last sentence should state that devices should be perpendicular to the direction of the crosswalk it serves. A device parallel to the crosswalk could not be seen. If I am misinterpreting your intent, others also will like do so.

    Charles Carmalt

24. 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

25. Jessie Lorenz, October 28, 2002

    I'd like you to know that as a congenitally, totally blind person I support the use of audible pedestrian crossings. Being a pedestrian has become increasingly more dangerous for all people, including people who are blind. Lets take some of the roulette out of it.

    Jessie Lorenz

26. Randy Hoskins, P.E., October 23, 2002

    Please consider the attached comments regarding the draft guidelines. A hardcopy version will be sent to you in the mail.

    Randy Hoskins, P.E.

    City Traffic Engineer

    Lincoln, NE

    Scott Windley

    Office of Technical and Informational Services

    Architectural and Transportation Barriers Compliance Board

    1331 F St. NW, Suite 1000

    Washington, DC 20004-1111

    RE: Draft Guidelines on Accessible Public Rights-of-Way

    Mr. Windley:

    The City of Lincoln has reviewed the Draft Guidelines for Accessible Public Rights-of-Way. We realize that Title II of the ADA requires governments to not discriminate against people with disabilities and we support the efforts to improve existing conditions. However, the guidelines as proposed would have serious consequences that would impose significant costs on local governments. It is also our feeling that these would be overly restrictive and would not allow sufficient latitude to design on a case by case basis.

    Our comments and concerns are as follow:

    Curb Ramps and Blended Transitions (1102.6, 1104)

    - Also, drivers may not be as alert to persons crossing at the apex of a corner.

    It would seem drivers would be much more alert at this point in the roadway than after driving around a corner and encountering a pedestrian when their vehicle has attained a higher speed than at the apex of the corner.

    Other Requirements for Curb Ramps and Blended Transitions (1104.3.3 - 1104.3.7)

    - prohibit the placement of ...utility and sewer access covers, and similar fixtures on ramps, landings, transitions and portions of the gutter within the pedestrian access route;

    If these items meet the criteria set forth for changes in level, why would they not be allowed?

    - prohibit grade breaks on ramp runs, blended transitions, landings, and gutter areas within the pedestrian access route;

    How will the gutter work if it must be at the same grade as the ramp? That will either force all the water out into the street or funnel it all back onto the sidewalk.

    - prohibit any vertical changes in level on curb ramps, landings and gutter areas within the pedestrian access route;

    Again, if the vertical change is within the requirements for changes in level, it should be allowed. To keep nuisance water from ponding within a ramp area, a minimal lip is often maintained to keep the water off the ramp and moving around the corner.

    - require clear space at least 48 by 48 inches

    This is confusing as to intent.

    Crosswalks (1105.2)

    - The cross slope is limited to 1:48

    This may be fine for new areas, but it is often not realistic in built environments. Changing slopes of streets to accommodate this ruling may not be feasible.

    Pedestrian Signal Phase Timing (1105.3)

    - The draft guidelines would require pedestrian signal phase timing to be calculated according to a walking speed of 3.0 feet

    This would have a major negative impact on traffic. Requiring this change would more than offset the gains our jurisdiction has made through expenditures of hundreds of thousands of dollars to improve the traffic carrying capabilities of our streets, which has been a mantra of the FHWA for years. To make this change system-wide would increase energy consumption, pollution and vehicular costs to motorists to accommodate a small percentage of the population who might use a signal. It would seem that if the route is used by handicapped individuals who cannot cross in the 3.5 ft/sec time, then the change to a 3.0 ft/sec crossing time COULD be used as needed.

    Pedestrian Overpasses and Underpasses (1105.5)

    - The draft guidelines address access to pedestrian overpasses and underpasses, which would be required to provide a pedestrian access route. A ramp would be required where the running slope exceeds 1:20

    Implementation of this rule would practically kill off the installation of underpasses and overpasses for pedestrian crossings. Since it is quite rare where the grade change of such a structure would be less than five feet, nearly every one constructed would require an elevator. The major reason stated for not installing these structures is cost. When you add the cost of providing elevators at each end to the already high price, you have just made these infeasible except in the most extreme cases. By doing so, this would increase the hazard to all pedestrians, handicapped and able-bodied alike, forcing them to cross using at-grade crossings.

    Roundabouts (1105.6)

    - To provide safer crossing at roundabouts, the draft guidelines would require pedestrian activated crossing signals at each roundabout crosswalk, including those at splitter islands.

    This requirement sounds as if it was written by a group of people scared of new ideas and who have absolutely no clue what they are talking about. We have just completed a roundabout to replace a signal at one of the highest accident locations in the City. A lot of people opposed to this installation stated it would be dangerous for pedestrians to cross. Quite the opposite is true. Pedestrians only have to cross one lane at a time, they are crossing at a point where traffic is moving slowly entering or leaving the roundabout and the driver is alert because of the increased requirements placed on them. To now have to signalize these would completely waste the advantages they naturally provide pedestrians. In certain areas where high volumes of pedestrians and vehicles exist, crossing lights may be of use, but a requirement for all or even most locations can only benefit signal suppliers.

    Since vehicles would be moving at higher speeds and pedestrians would have longer crossing distances, by using the same logic, we should put in crossing signals at every unsignalized intersection also.

    - Barriers or similarly distinct elements are needed to prevent blind persons from inadvertently crossing a roundabout roadway in unsafe locations. The draft guidelines would require a continuous barrier along the street side of the sidewalk where pedestrian crossing is prohibited. If a railing is used, it must have a bottom rail no higher than 15 inches

    Since vehicles would be moving at higher speeds and peds would have longer crossing distances, by using the same logic, we should put in barriers at every unsignalized intersection also. Again, this just doesn't make sense. By following the sidewalk, pedestrians are directed to the safest crossing locations.

    Turn Lanes at Intersections (1105.7)

    - The draft guidelines also include a requirement for a pedestrian activated signal at each segment of a crosswalk that crosses right or left turn slip lanes.

    This will likely increase vehicular crashes. In order to place the signals where turning vehicles can see them an adequate distance in advance of the crossing, they will also be visible to through vehicles who may become confused by several conflicting indications. Rear end and side-swipe crashes will likely result.

    This should not be mandatory at all locations, but rather should be considered on a case by case basis. If signals are not needed for non-handicapped persons, there is a question as to whether or not they would be needed for handicapped individuals.

    Accessible Pedestrian Signal Systems (1102.8, 1106)

    1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.

    Obviously these add cost to signal installation/ maintenance. Where will the funding for this come from in these tight economic times?

    1106.2.1 Location. Pedestrian signal devices shall be located 60 inches

    This will require major reconstruction of many traffic signals. In many locations, it is not possible to comply with this due to existing obstructions in the way of the signal, including underground utilities.

    1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches

    This is another cost concern. It is also sometimes a concern with nearby residents/businesses as to the addition of noise pollution.

    1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.

    Another cost concern.

    On-Street Parking (1102.14, 1109)

    - The draft guidelines would require access to at least one parking space on each block face.

    In an area with 150 foot

    This also does not specify if this would be required city-wide or only in commercial areas. Providing the required handicapped parking space with signing, pavement markings and ramps on every block in the city would create an astronomical cost.

    - Requirements address adjoining access aisles at spaces, accessible connecting routes, signs, and parking meters. An accessible parallel space and access aisle, which must be flush with the street, can be achieved by indenting the curb line, similar to a loading zone.

    This will create problems during snow events. Plows will come along and push snow into the indented area, making them useless. These will also create discontinuities in the sidewalks in downtown areas where sidewalks normally run from the face of buildings to the edge of the curb. In high ped areas, this will have a major negative impact. I think the cost of lawsuits related to trips and falls in these inset areas each year will greatly outweigh any benefits derived from their installation.

    Passenger Loading Zones (1102.15)

    - ADAAG requirements for passenger loading zones would be applied to loading zones in the public right-of-way. Where a long loading zone is provided, at least one area in every 100 continuous feet must comply with requirements in ADAAG section 302 and 503 which address the surfacing, the size of vehicle pull-up spaces (8 by 20 feet

    These will not work well at schools where it is important to provide curbs to create barriers to vehicles running onto sidewalks and hitting pedestrians.

    - 1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.

    This is a costly unfunded mandate. Providing parallel ped access on the same side of the street as the existing path is often not practicable. Based on costs and usage, it is often impossible to justify not moving pedestrians, both able bodied and disabled, to an adjacent route.

    - 1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches

    The MUTCD allows secondary signs to have a minimum height of 72", vs. 80" required here. This would require major work to change signs throughout the city.

    Again, we support reasonable access for disabled pedestrians and continually review our standards and processes to assure that what we are doing is reasonable and safe. We are concerned that these draft guidelines, if adopted, would create major consequences for communities of all sizes. We would ask that these consequences be considered more carefully before enacting any changes to the existing requirements.

    Randy Hoskins, P.E.

    City Traffic Engineer

    City of Lincoln, Nebraska

27. Deborah Wood, October 29, 2002

    I am a member of The American Council of the Blind. I am writing to express my desire for the use of audible pedestrian traffic signals to become common practice. Traffic is becoming more and more complex, and many traffic signals are set up for the benefit of drivers rather than of pedestrians. This often means walk lights that are so short in duration that by the time a person who is blind realizes they have the light, the light has changed or is about to change, and they must wait for the next walk light. this situation can repeat itself again and again at such an intersection, which can make crossing such streets difficult, if not impossible. I was recently hit by a car while crossing the street to go home from work. Thankfully, I was not hurt. But I already felt unsafe crossing busy streets, and I now feel even more unsafe. Furthermore, I understand that several people who are blind have been killed while crossing such streets in the last several years. These fatalities might have been prevented had there been audible traffic signals where they crossed. Those who are sighted do not need to use the movement of the traffic to decide when it is safe to cross, they have a signal they can easily use to let them know when it's safe to cross. Pedestrians who are blind do not always travel with others; we often find ourselves traveling alone. Please do all that you can to give us the security and safety that is given to those who do not have visual impairments.

    I am Deborah Wood. My address is 1[...].

    Thank you for your consideration.

    Deborah Wood.

28. Don Wesely, October 24, 2002

    CITY OF LINCOLN NE

    RE: Draft Guidelines on Accessible Public Rights-of-Way

    The City of Lincoln has reviewed the draft Guidelines on Accessible Public Rights-of-Way. While we applaud efforts to improve mobility for all citizens, we are concerned that the draft guidelines currently under consideration will have numerous consequences, many of which are negative.

    You will find enclosed a copy of a letter compiled by Randy Hoskins, the City's Traffic Engineer. The letter outlines the concerns the City of Lincoln has with proposed guidelines. These concerns have been raised through Public Works Department and City Council review.

    We would encourage you to take another look at the guidelines. Many are excellent and will provide needed improvements. Others may have unintended consequences that will be difficult to enforce, apply and/or fund. Still others may make for less safe conditions for all pedestrians, along with increasing delay, costs and pollution of vehicular traffic.

    Sincerely,

    Don Wesely

    Mayor of Lincoln

    October 20, 2002

    Scott Windley

    RE: Draft Guidelines on Accessible Public Rights-of-Way

    Dear Mr. Windley:

    The City of Lincoln has reviewed the Draft Guidelines for Accessible Public Rights-of-Way. We realize that Title II of the ADA requires governments to not discriminate against people with disabilities and we support the efforts to improve existing conditions. However, the guidelines as proposed would have serious consequences that would impose significant costs on local governments. It is also our feeling that these would be overly restrictive and would not allow sufficient latitude to design on a case by case basis.

    Our comments and concerns are as follow:

    Curb Ramps and Blended Transitions (1102.6, 1104)

    - Also, drivers may not be as alert to persons crossing at the apex of a corner.

    It would seem drivers would be much more alert at this point in the roadway than after driving around a corner and encountering a pedestrian when their vehicle has attained a higher speed than at the apex of the corner.

    Other Requirements for Curb Ramps and Blended Transitions (1104.3.3 - 1104.3.7)

    - prohibit the placement of... utility and sewer access covers, and similar fixtures on ramps, landings, transitions and portions of the gutter within the pedestrian access route;

    If these items meet the criteria set forth for changes in level, why would they not be allowed?

    - prohibit grade breaks on ramp runs, blended transitions, landings, and gutter areas within the pedestrian access route;

    How will the gutter work if it must be at the same grade as the ramp? That will either force all the water out into the street or funnel it all back onto the sidewalk.

    - prohibit any vertical changes in level on curb ramps, landings and gutter areas within the pedestrian access route;

    Again, if the vertical change is within the requirements for changes in level, it should be allowed. To keep nuisance water from ponding within a ramp area, a minimal lip is often maintained to keep the water off the ramp and moving around the corner.

    - require clear space at least 48 by 48 inches

    This is confusing as to intent.

    Crosswalks (1105.2)

    - The cross slope is limited to 1:48

    This may be fine for new areas, but it is often not realistic in built environments. Changing slopes of streets to accommodate this ruling may not be feasible.

    Pedestrian Signal Phase Timing (1105.3)

    - The draft guidelines would require pedestrian signal phase timing to be calculated according to a walking speed of 3.0 feet

    This would have a major negative impact on traffic. Requiring this change would more than offset the gains our jurisdiction has made through expenditures of hundreds of thousands of dollars to improve the traffic carrying capabilities of our streets, which has been a mantra of the FHWA for years. To make this change system-wide would increase energy consumption, pollution and vehicular costs to motorists to accommodate a small percentage of the population who might use a signal. It would seem that if the route is used by handicapped individuals who cannot cross in the 3.5 ft/sec time, then the change to a 3.0 ft/sec crossing time COULD be used as needed.

    Pedestrian Overpasses and Underpasses (1105.5)

    - The draft guidelines address access to pedestrian overpasses and underpasses, which would be required to provide a pedestrian access route. A ramp would be required where the running slope exceeds 1:20

    Implementation of this rule would practically kill off the installation of underpasses and overpasses for pedestrian crossings. Since it is quite rare where the grade change of such a structure would be less than five feet, nearly every one constructed would require an elevator. The major reason stated for not installing these structures is cost. When you add the cost of providing elevators at each end to the already high price, you have just made these infeasible except in the most extreme cases. By doing so, this would increase the hazard to all pedestrians, handicapped and able-bodied alike, forcing them to cross using at-grade crossings.

    Roundabouts (1105.6)

    - To provide safer crossing at roundabouts, the draft guidelines would require pedestrian activated crossing signals at each roundabout crosswalk, including those at splitter islands.

    This requirement sounds as if it was written by a group of people scared of new ideas and who have absolutely no clue what they are talking about. We have just completed a roundabout to replace a signal at one of the highest accident locations in the City. A lot of people opposed to this installation stated it would be dangerous for pedestrians to cross. Quite the opposite is true. Pedestrians only have to cross one lane at a time, they are crossing at a point where traffic is moving slowly entering or leaving the roundabout and the driver is alert because of the increased requirements placed on them. To now have to signalize these would completely waste the advantages they naturally provide pedestrians. In certain areas where high volumes of pedestrians and vehicles exist, crossing lights may be of use, but a requirement for all or even most locations can only benefit signal suppliers.

    Since vehicles would be moving at higher speeds and pedestrians would have longer crossing distances, by using the same logic, we should put in crossing signals at every unsignalized intersection also.

    - Barriers or similarly distinct elements are needed to prevent blind persons from inadvertently crossing a roundabout roadway in unsafe locations. The draft guidelines would require a continuous barrier along the street side of the sidewalk where pedestrian crossing is prohibited. If a railing is used, it must have a bottom rail no higher than 15 inches

    Since vehicles would be moving at higher speeds and peds would have longer crossing distances, by using the same logic, we should put in barriers at every unsignalized intersection also. Again, this just doesn't make sense. By following the sidewalk, pedestrians are directed to the safest crossing locations.

    Turn Lanes at Intersections (1105.7)

    - The draft guidelines also include a requirement for a pedestrian activated signal at each segment of a crosswalk that crosses right or left turn slip lanes.

    This will likely increase vehicular crashes. In order to place the signals where turning vehicles can see them an adequate distance in advance of the crossing, they will also be visible to through vehicles who may become confused by several conflicting indications. Rear end and side-swipe crashes will likely result.

    This should not be mandatory at all locations, but rather should be considered on a case by case basis. If signals are not needed for non-handicapped persons, there is a question as to whether or not they would be needed for handicapped individuals.

    Accessible Pedestrian Signal Systems (1102.8, 1106)

    1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.

    Obviously these add cost to signal installation/maintenance. Where will the funding for this come from in these tight economic times?

    1106.2.1 Location. Pedestrian signal devices shall be located 60 inches

    This will require major reconstruction of many traffic signals. In many locations, it is not possible to comply with this due to existing obstructions in the way of the signal, including underground utilities.

    1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches

    This is another cost concern. It is also sometimes a concern with nearby residents/businesses as to the addition of noise pollution.

    1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.

    Another cost concern.

    On-Street Parking (1102.14, 1109)

    - The draft guidelines would require access to at least one parking space on each blockface.

    In an area with 150 foot

    This also does not specify if this would be required city-wide or only in commercial areas. Providing the required handicapped parking space with signing, pavement markings and ramps on every block in the city would create an astronomical cost.

    - Requirements address adjoining access aisles at spaces, accessible connecting routes, signs, and parking meters. An accessible parallel space and access aisle, which must be flush with the street, can be achieved by indenting the curb line, similar to a loading zone.

    This will create problems during snow events. Plows will come along and push snow into the indented area, making them useless. These will also create discontinuities in the sidewalks in downtown areas where sidewalks normally run from the face of buildings to the edge of the curb. In high ped areas, this will have a major negative impact. I think the cost of lawsuits related to trips and falls in these inset areas each year will greatly outweigh any benefits derived from their installation.

    Passenger Loading Zones (1102.15)

    - ADAAG requirements for passenger loading zones would be applied to loading zones in the public right-of-way. Where a long loading zone is provided, at least one area in every 100 continuous feet must comply with requirements in ADAAG section 302 and 503 which address the surfacing, the size of vehicle pull-up spaces (8 by 20 feet

    These will not work well at schools where it is important to provide curbs to create barriers to vehicles running onto sidewalks and hitting pedestrians.

    - 1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.

    This is a costly unfunded mandate. Providing parallel ped access on the same side of the Street as the existing path is often not practicable. Based on costs and usage, it is often impossible to justify not moving pedestrians, both able bodied and disabled, to an adjacent route.

    - 1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches

    The MUTCD allows secondary signs to have a minimum height of 72", vs. 80" required here. This would require major work to change signs throughout the city.

    Again, we support reasonable access for disabled pedestrians and continually review our standards and processes to assure that what we are doing is reasonable and safe. We are concerned that these draft guidelines, if adopted, would create major consequences for communities of all sizes. We would ask that these consequences be considered more carefully before enacting any changes to the existing requirements.

    Sincerely,

    Randy Hoskins, P.E.

    City Traffic Engineer

    City of Lincoln, Nebraska

29. David Harrell, P.E., October 25, 2002

    Per our conversation, attached are comments from the City of Knoxville's Department of Engineering on the Draft Guidelines on Accessible Public Rights-of-Way. I will follow this up with a hard copy and cover letter via regular mail.

    Sincerely,

    David Harrell, P.E.

    Chief Civil Engineer

    City of Knoxville

    Dept. of Engineering

    CITY OF KNOXVILLE, TENNESSEE

    DEPARTMENT OF ENGINEERING

    Comments on Draft Guidelines on Public Rights-of-Way

    SECTION 1102.2.2 Alterations. It is noted that alterations must not be fully compliant "where compliance is technically infeasible". We find the statement to be too vague and believe it needs further clarification. The examples of technical infeasibility given in the "Discussion of Provisions" are extreme cases. For example, would adding a left turn signal to a signalized intersection that has a pedestrian signal system require making the pedestrian signal system fully accessible? If so, this could potentially turn a $400 upgrade into a $10,000 upgrade. We would consider this just as technically infeasible as "altering a load-bearing member of a structural frame". While technically this could be done, the cost to make the area within the alteration fully compliant compared to the cost of the alteration itself would make the project no longer viable.

    SECTION 1104.3.2 Detectable Warnings. We concur with the advisory committee's comments on using detectable warnings on only those ramps that are the least distinguishable. While the revised specifications are an improvement we believe the truncated domes to be hazardous for elderly pedestrians and will still cause difficulties in maneuvering for wheelchairs.

    SECTION 1104.3.3 Surfaces. When altering an existing facility such as adding a curb ramp where none exists, it is not always possible to locate the ramp to avoid manhole covers for utilities. While the elevation of these covers can be adjusted to match the slope and elevation of the ramp, it is impractical to have these manholes relocated. We would expect this situation to fall under the "technically infeasible" category.

    SECTION 1104.3.6 Counter Slopes. Integral curb and gutter sections are typically slip-formed and typically have a cross-slope of 1:12

    SECTION 1105.2.2 Cross Slope. With terrain such that is typical in East Tennessee, profile grades of 9 or 10 percent are very common. This requirement would be extremely difficult, it not impossible, to implement for roads having grades of this magnitude. In order to make an intersection design work for a road of this type, the profile grade must be changed by 7 or 8 percent along a vertical curve that maintains the design speed of the road. Typically, the cross-slope of the intersecting street is often sloped as much as 4 percent to minimize the required change in profile grade of the through street.

    SECTION 1105.4 Medians and Pedestrian Refuge Islands. The cut through concept is a good idea to provide access for pedestrian access but the need for pedestrian storage needs to be considered as well, e.g., when crossing pedestrians to the refuge island on one phase and then the remainder of the crossing under another phase. The situation could arise where several pedestrians would be crossing but not enough space is provided in the island crossing area and would leave some of the pedestrians in the roadway until the next pedestrian crossing phase.

    SECTION 1105.7 Turn Lanes at Intersections. Most right-turn slip lanes have no signalized control other than a yield sign. It would not be practical to locate a pedestrian signal system at these locations as the slip lanes are not signalized. Signalizing the slip lane to enable the use of a pedestrian signal system would effectively remove the reason for providing the slip lane.

    SECTION 1102.8 and 1106 Accessible Pedestrian Signal Systems. Is the requirement to install these devices at all existing signalized intersections that currently provide pedestrian signal systems or at only that intersection that will be constructed and/or upgraded. If the Board is advocating that all the pedestrian signal systems be upgraded then there needs to be some consideration to phasing in a program over time to help defer the cost of these upgrades. The cost could exceed $20,000 per intersection for the accessible pedestrian signal system at complex signalized intersections and could be much higher if the relocation of existing signal poles or the addition of pedestrian signal poles is required. Considerations should take for the cost of initial installation and the need for additional maintenance personnel to maintain this type of facility to insure proper operation.

30. Janet Muldoon- Ellsworth, October 27, 2002

    I am in favor of the Prowac report for accessible pedestrian crossings. As the parent of two adult, blind children I feel this is very important to their safety as independent members of society.

    Janet Muldoon- Ellsworth

31. Toni Eames, October 17, 2002

    As a blind person, I want to endorse The Access Board's proposed guidelines on Accessible Pedestrian Signals.

    When I lived and traveled in New York using a white cane or my guide dog, I felt safe crossing the streets in Manhattan or in QuennsQueens, where I lived. Since moving to California, my sense of safety and security while walking has been severely shaken. With rights on red and left turn signals, which may or may not be activated depending on traffic flow, my ability to perceive when it is safe to cross a street has been diminished.

    In Fresno, as well as many other cities, the length of time provided to cross a street is very short. An APS, such as we now have on the corner of Marks and Valentine, allows me and other blind pedestrians to step off the sidewalk and cross the street as soon as the walk sign if illuminated. This provides me the same information as members of the sighted publicand gives me a better chance of crossing the street before the light changes and car traffic starts coming at me.

    APSs are not the total solution to the problem, but they would go a long way toward making me and other blind pedestrians feel safer.

    Toni Eames