Pedestrian signal devices shall be located 60 inches
(1525 mm) maximum from the crosswalk line extended, 120 inches
(3050 mm) maximum and 30 inches
(760 mm) minimum from the curb line, and 120 inches
(3050 mm) minimum from other pedestrian signal devices at a crossing. The control face of the signal device shall be installed to face the intersection and be parallel to the direction of the crosswalk it serves
EXCEPTION: The minimum distance from other signal devices shall not apply to signal devices located in medians and islands.
John N. LaPlante, P.E., P.T.O.E., October 14, 2002
Attached are my comments on the Draft Guidelines for Accessible Public Rights-of-Way. Overall, I think this is an excellent and long overdue document. However, I do have a few very specific comments and recommendations that I urge be given careful consideration.
Please contact me at this e-mail address or you can call me at 773-792-9000 if you have any difficulty in opening this document or if you have any questions. Thank you this opportunity to comment on this important and valuable document.
John N. LaPlante, P.E., P.T.O.E.
Chief Traffic Engineer
TY Lin International, Inc.
1102.2.1 Additions.
Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2.
Need clarification regarding how accessible facilities "connect" to existing construction. Does the "connection" refer only to the sidewalk, or does it include the pedestrian signals and/or other features?
Recommend clarification of the types pf treatments necessary when "connecting" with existing construction.
1102.5.1 Protrusion Limits.
Objects with leading edges more than 27 inches
Some safety features within the right-of-way, such as fire hydrants, may not adhere to the protrusion requirements
1102.5.2 Post-Mounted Objects.
Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
1.) The existing ADAAG (Section 307.3) allows a 12-inch maximum overhang of post-mounted objects into the circulation path; thus, the 4-inch requirement in the draft guidelines is a significant restriction. 2.) Some features required in other sections of the guidelines, such as the street name requirement on Accessible Pedestrian Signal poles, may not meet these protrusion requirements.
1102.7.1 Bus Route Identification
Bus route identification signs shall comply with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to the maximum extent practicable, bus route identification signs shall comply with 703.5.5. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with 703.2, and shall have rounded corners. EXCEPTIONS 1: Bus schedules, timetables and maps that are posted at the bus stop or bus shelter shall not be required to comply with 1102.7. 2: Signs shall not be required to comply with 703.2 where audible signs are user- or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual.
Consideration needs to be given as to when and how this will be implemented. Bus route identification signing is normally done by transit agencies and is completely independent of any other roadway or sidewalk improvements at a given location or along a route.
Recommend that consideration be given as to how this can be implemented separate from a sidewalk or roadway improvement.
1102.7.2 Informational Signs and Warning Signs.
Informational signs and warning signs shall comply with 703.5.
Signs at signal pushbuttons should also include Braille messages. Should not this note also be included here?
Recommend the following change: Informational signs and warning signs shall comply with 703.5. Signs located at accessible pushbuttons shall comply with 703.2.
1102.15 Passenger Loading Zones.
Where passenger loading zones are provided, they shall connect to a pedestrian access route and shall provide a minimum of one passenger loading zone in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof, complying with 302, 503.2, 503.3, and 503.5.
Providing 20 feet
1102.15 Passenger Loading Zones.
Where passenger loading zones are provided, they shall connect to a pedestrian access route and shall provide a minimum of one passenger loading zone in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof, complying with 302, 503.2, 503.3, and 503.5.
Providing 20 feet
1103.3 Clear Width.
The minimum clear width of a pedestrian access route shall be 48 inches
I would prefer a desirable minimum clear width of 60 inches
Revise wording to say: The minimum clear width shall be 60 inches
1104.2.1.1 Running Slope.
The running slope shall be 1:48
In hilly terrain, due to the slope of the sidewalk and/or the roadway, it may not be possible to provide a perpendicular curb ramp with a running slope between 1V:48H and 1V:12H.
Recommend adding the following text to Section 1104.2.2.1: "EXCEPTION: A perpendicular curb ramp shall not be required to exceed 15 feet
1104.2.1.2 Cross Slope.
The cross slope shall be 1:48
Constructing maximum 1V:48H cross slopes on perpendicular curb ramps will be very costly in areas of hilly terrain.
1104.3.2 Detectable Warnings.
Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.
I disagree with the suggestion to permit the use of a 1:15
Recommend no change to this section..
1104.3.7 Clear Space.
Beyond the curb line, a clear space of 48 inches
1.) Is this clear space required for a parallel curb ramp or is it redundant? 2.) From where is 'beyond the curb line' measured? Front or back of curb or other? In addition, in which direction from the curb line is it measured for each type of ramp -- toward the street or toward the sidewalk?
1.) Recommend that this clear space "beyond the curb line" not be required for parallel curb ramps as it would be a duplication of the landing space. 2.) Recommend clarification of where to measure clear space from for perpendicular curb ramps (assumed to be face of curb).
1105.2.1 Width.
Marked crosswalks shall be 96 inches
Why not use 8 feet
Recommend the following change: Marked crosswalks shall be 6 feet
1105.2.2 Cross Slope.
The cross slope shall be 1:48
Including every intersection along a constant grade street would result in extremely unsafe vehicular movements where there is no signal or when a traffic signal is green. This will likely lead to cars going out of control, and an out of control car is a risk to everyone, especially pedestrians both in the street and on adjacent sidewalks. I am absolutely opposed to this suggestion!
Recommend dropping this provision.
1105.3 Pedestrian Signal Phase Timing.
All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
While I agree that 4.0 ft/sec is too fast a walking speed, I cannot agree with lowering the speed to 3.0 ft/sec. This will result in 25% added delay to any signalized intersection where pedestrian crossing time governs. This delay would also apply to pedestrians wishing to cross the street, leading to the likelihood of pedestrians disobeying the ped signal. I suggest as a compromise solution, requiring a minimum total ped crossing time (Walk and Flashing Don't Walk) be based on 3.0 ft/sec and the Flashing Don't Walk be based on 3.5 ft/sec.
In addition, including the length of the ramp in the crossing distance can increase the crossing distance by as much as 12 feet
Recommend the following change: All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
1105.5.3 Approach.
Where the approach exceeds 1:20
Given the high cost of installing and maintaining elevators, particularly in outdoor locations and often not near a likely power source, the 60-inch rise seems unworkable.
Recommend some further research as to a more workable rise differential or some more reasonable exception included in this section.
1105.6.2 Signals.
A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
Traffic signals at roundabouts would completely eliminate both the traffic flow and traffic safety benefits of roundabouts, thus effectively precluding their use in any urbanized areas. Since they usually eliminate so many vehicular crashes, eliminating roundabouts does not seem to be a viable solution. However, I recognize that roundabouts are a very real problem for the visually impaired, as well as other less mobile pedestrians. This is particularly true at multi-lane roundabouts. We quickly need further research on how to enforce vehicular yielding at pedestrian crosswalks.
Recommend the following change for the time being: 1105.6.2 Signing. "Yield to Pedestrians" signs and visible pavement markings shall be provided for each segment of the crosswalk, including the splitter island.
1105.7 Turn Lanes at Intersections.
Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
Similar to the roundabout discussion above, there are many locations where signalizing a separate turn lane is neither feasible nor safe. However, there are probably too many free flow turn lanes in urban areas that could and should be signalized. This is currently the subject of a new NCHRP study (Project 3-72) and the signalization recommendation should be deferred until that study is complete.
Recommend the following change for the time being: Where pedestrian crosswalks are provided at right or left turn slip lanes a "Yield to Pedestrians" sign or a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
1106.2.1 Location.
Pedestrian signal devices shall be located 60 inches
1.) Space limitations may make it difficult to place separate signal components at the required spacing. 2.) Clarify what is meant by "pedestrian signal device" -- Is this just the push-button, or does it include other items such as the auditory tone, pole, walk/don't walk signs, etc.? 3.) Is "control face" a recognized term for pedestrian signals? It appears to refer to the "walk/don't walk" panel. This section could be reworded for clarity.
1.) Recommend developing illustrative standard drawings for intersections using required spacings to determine feasibility and reasonability of spacing. 2.) Recommend defining "pedestrian control device" or rewording first sentence. 3.) Recommend rewording second sentence to state: "The face of the pedestrian signal should face the crosswalk it serves."
1109.2 Parallel Parking Spaces.
An access aisle at least 60 inches
Bike lanes should not be considered travel lanes with regard to the restriction that "the access aisle shall not encroach on the vehicular travel lane". And the use of inches to define street space implies a level of accuracy that is neither needed nor practical to achieve.
Recommend the following change: An access aisle at least 5 feet
1109.3 Perpendicular or Angled Parking Spaces.
Where perpendicular or angled parking is provided, an access aisle 96 inches
It appears that these requirements apply to all parking spaces, instead of only to the accessible spaces.
Recommend rewording beginning of section to state, "Where accessible perpendicular or angled parking is provided,?"
1109.5 Obstructions.
There shall be no obstructions on the sidewalk adjacent to and for the full length of the space. EXCEPTION: This provision shall not apply to parking signs complying with 1109.6 and parking meters complying with 1109.7.2.
It is unclear how far back on the sidewalk from the accessible parking space this restriction applies, i.e., how far back is "adjacent to...the space"?
Recommend clarifying verbiage.
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