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
Jennifer Campos, October 25, 2002
City of Vancouver
Transportation Services
On behalf of the City of Vancouver, Washington, I am submitting comments regarding the recently released Draft Guidelines for Accessible Public Rights-of-Way by the Access Board. The City is very supportive of the Board's decision to create guidelines for the public right-of-way, but we do have some concerns over several of the proposed requirements.
Below I have listed our comments below by section number. Assume that if any part of the guidelines is not mentioned, that we support what you have proposed.
1104.3.2 Detectable Warnings. Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.
We strongly feel that this requirement is unnecessary and over burdensome. Detectable warnings should not be placed at all curb ramps or landings, but only in those cases where it would be difficult for someone to detect where the sidewalk ends and the street begins. This would be at rail crossings, platform edges, blended transitions, or ramps that have a slope of 1:15
1105.2.2 Cross Slope. The cross slope shall be 1:48
EXCEPTION: This requirement shall not apply to mid-block crossings.
1105.2.3 Running Slope. The running slope shall be 1:20
Both of these requirements would place a huge burden on the City in trying to meet the standards since it would apply to all streets regardless of any outside circumstances that we would have no control over. This should be a guideline that jurisdictions should strive for while designing their roadways in order to improve pedestrian safety, but it would be impossible for many if not most areas to meet it in all cases.
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Requiring this change in signal timing would ensure much higher delays for all users. The requirement would be applicable on streets that were not overly wide and had curb returns over 25', but unfortunately this is not how many of our streets are built today. We currently respond to the request for more crossing time on a case by case basis, or any place we feel there are users who will benefit from the change.
1105.6 Roundabouts. Where pedestrian crosswalks and pedestrian facilities are provided at roundabouts, they shall comply with 1105.6.
1105.6.1 Separation. Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. Where railings are used, they shall have a bottom rail 15 inches
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
This portion of the proposed guidelines has to be the most excessive and unnecessary part of the entire guidelines. To require signals at all legs of roundabouts completely defeats the purpose of building a roundabout in the first place. The board mentions that roundabouts have become popular in the U.S because they "add vehicle capacity and reduce delay." These are not the only reasons and it would be careless of you to not recognize the most important benefits.
Roundabouts have become so successful because the virtually eliminate all accidents at intersections. This is not just automobile accidents, but pedestrian accidents as well. They do so by reducing the number of conflict points and more importantly reduce the speeds of motorists entering the intersection. When motorists drive slower they are more able to take account of their surroundings, making conditions much safer for pedestrians for crossing. We recognize that blind or visually impaired pedestrians can have difficulties crossing at roundabouts, but to install signals at all legs would make them cost prohibitive compared to a regular signalized intersection.
Because navigating the sidewalks around the edge of a roundabout is not different than navigating any other intersection, the need for barriers is completely unnecessary. Curb ramps are installed at roundabouts to indicate crossing locations just as they are for any other type of intersection.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
Rather than require signals at slip lanes for pedestrians, why not just prohibit their use? This would make much more sense, and would completely eliminate the pedestrian/auto conflict that a signal probably would not prevent.
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
We know that most of the controversy surrounding these guidelines has revolved around the audible signal requirement and we feel that to require an audible signal at every intersection with a WALK interval is cost burdensome and unrealistic. For new signals the installation cost would not be significant, but the impacts to the environment would be enormous. Imagine walking in the downtown of a city with a 200 ft
We work with the local blind community to prioritize needed audible signal locations, and try to install as many devices as we can. We get requests from people who have difficulty reading a certain intersection, and they have made it clear that they do not want audible signals at every intersection.
1109.2 Parallel Parking Spaces. An access aisle at least 60 inches
It would be impossible to install and maintain a disabled parking spot on each block of parallel parking. In areas where the block faces are around 200 feet
If you have any questions regarding our comments please don't hesitate to contact me at [ ... ]
Sincerely,
Jennifer Campos
Associate Transportation Planner
Frederick M Chambers, October 4, 2002
My name is Fred Chambers. I am blind, and I oppose most installations of audible crosswalk signals. The common cuckoo & chirp audible signals are not as useful as the newer tactile and audible signals. I favor the newer crossing indicators that provide accommodations for deaf and deaf-blind, as well as blind pedestrians. The system I'm most familiar with is made in Orange County. I think it's called the APS, for Accessible Pedestrian Signals. This system doesn't make distracting bird calls. It does identify the intersection verbally, and announces the walk signal with words. In addition to telling us where we are, and which directions are
walkable, it also has a vibrating arrow on the button. Lastly, if the pedestrian wants to mute it to listen to traffic sounds, they can do that too.
Most intersections don't need accommodations, but for those that do, I want the APS. Perhaps the bird call signals work well in dense urban, snowswept permafrost, scortching deserts and underwater environments, but the bird call signals are a very bad idea for San Diego County. We have well over 200 song bird species that live here at least part of the year. Several of them are parrots, mynas, mockingbirds, and others known to mimic birds and environmental sounds. I was almost hit near my home. A mockingbird in a tree near the intersection began making the east-west crossing sound. Several cars had stopped, so it seemed right. As I walked, a big white SUV came blazing through the intersection, huge tires howling, horn honking. It missed me by a few feet. After I was safely across, it was obvious what happened. A driver also got out of his car to explain from his angle. We could both hear the mockingbird mimicking the crossing signal. He asked, "What kind of a moron would install crossing indicators that sound like birds?"
We do not need the audible walk signals at every intersection. Usually, traffic provides plenty of audible indicators about which light is green. A few lonely stretches of road around here have the bird call crossing signals. One of them on Carlsbad Village Drive at Valley is where I was nearly hit.
The extra noise is distracting. That's the main reason why I want talking signals with a vibrating arrow at the few intersections that need anything.
Thanks for your attention,
Frederick M Chambers
Judy Prociuk, September 28, 2002
To Whom it may concern,
Even though I am not a U.S. citizen, I frequently visit the United States and therefore would like to submit my comments on accessible pedestrian signals. I am a blind person living in Canada and very much appreciate the audible component in traffic signals to indicate when the walk light is on and therefore safe to cross the street. I look upon this as an access to information issue. If there is a visual signal to alert sighted pedestrians when to walk or not walk, the same should be true for blind pedestrians. Blind pedestrians should not have to depend on listening for traffic noises or for someone to help them across the street if an accessible signal is not present. In my opinion accessible signals should be at every intersection where a visual signal is present. If blind pedestrians don't need to know when the signal is on, then sighted pedestrians should also be made to rely on other means to determine when to cross a street. I trust my comments will be given some consideration, thank you for your time and attention, respectfully,
Judy Prociuk
Saskatoon, Saskatchewan
Edmund Waddell, August 14, 2002
Roundabouts have been shown to reduce intersection injury crashes by 76% compared to signals, and to reduce fatalities by 90% (Retting et al, 2001). Results of these American studies, published by the Insurance Institute for Highway Safety, and by the American Journal of Public Health, are identical to findings from decades of overseas research. Put another way, comparable crossroad intersections have FOUR TIMES AS MANY INJURIES - including severe brain and spinal cord injuries - and about TEN TIMES AS MANY FATALITIES as a roundabout. Where roundabouts have replaced signals, repeated studies have shown they reduce pedestrian accidents by 30-50% (Lalani 1975, Daley 1981, O'Brien 1985).
In lay terms, roundabouts can keep people out of hospitals, wheelchairs, and graveyards, and that's a common reason they're built.
Unfortunately, these safety facts were not emphasized in Dr. Richard Long's report to the Access Board: a report which was used to develop the Access Board's current design proposals. The proposed new unfunded federal mandate would require complex signals and barrier systems at every roundabout crosswalk, regardless of how easily the crosswalk operates or whether a blind person ever uses it. At $100,000 or more per intersection, that's an expensive proposal, and since it has serious ramifications on public safety, it bears close examination.
Like more than 90% of US crosswalks, most roundabout crosswalks are not signalized. Because a pedestrian refuge is provided mid-crossing (shortening the crossing distance), and because vehicles operate at unusually low speeds (typically 15-20 MPH), the overwhelming majority of roundabout crosswalks are extremely easy to use, and like the vast majority of all crosswalks in the US, they simply don't need signals. In such locations, even if signals were provided, pedestrians wouldn't use them.
Traffic engineers have known for decades that, if unwarranted and infrequently used, signals can confuse drivers, become ineffective, and INCREASE accidents, causing more injuries to pedestrians and vehicle occupants alike. That's bad for public safety, but too few lay people understand it. People tend to think that signals always improve safety, but signals can increase speeding, distract drivers' eyes away from traffic and pedestrians, and create a false sense of security for pedestrians. Signals do not put a concrete wall between vehicles and pedestrians: pedestrians are struck at traffic signals with sickening regularity.
In locations where pedestrian and traffic volumes warrant them, crosswalks should have signals, and many roundabouts in the United Kingdom and Europe have pedestrian signals. They're common in London, Birmingham, and other cities. Examples of appropriate locations for signalized crosswalks include high-volume urban roundabout crosswalks, and locations where pedestrians (both blind and sighted) are most frequent. These factors are easily quantifiable. At rural intersections or low-volume locations, and locations where pedestrians are infrequent, signals are not used because they confuse drivers and unnecessarily increase highway construction, maintenance, and operating costs.
To assure that traffic signals are only installed where prudent, "warrants" have been developed for traffic signal installation in the United States. In the United Kingdom - a country with decades of experience with roundabouts in a wide variety of locations - the warrant for a signalized pedestrian crosswalk at a roundabout is where PV squared is greater than 1*10^8 (in words, where the number of pedestrians, times the number of vehicles per hour squared, exceeds a value of 100 million). Use of appropriate signal warrants assures that signals are provided only where needed, and not where they are unnecessary and potentially harmful.
The ramifications of an ill-considered intersection design policy can negatively impact the general public in unintended ways. For example, if ALL roundabout crosswalks were required to have signals, about $100,000 would be added to the cost of each roundabout, making them unnecessarily expensive in comparison to other intersection alternatives. As a result, far fewer roundabouts would be built, and many more of the common alternative - a signalized crossroad - would be built instead. As stated previously, studies show these have FOUR TIMES as many injuries, and TEN TIMES as many fatalities as a roundabout. The United States currently has about 15,000 deaths and about 1 million injuries at intersections every year, and installation of well-designed roundabouts might prevent countless human tragedies. Meanwhile, signals at unwarranted locations may help no one at all, and could in fact be harmful.
A single-user approach to traffic engineering would be a mistake. All users of an intersection must be taken into account, and the appropriate solution needs to be provided that will provide the greatest benefit to the public in each specific situation. No one wants more people injured or killed because we impose an ill-considered intersection design policy.
The Access Board proposal to require signals at all roundabout crosswalks needs to be reconsidered. Signals should be installed where they are warranted, and where there is no better alternative. In specific locations where users have special needs, the needs should be evaluated and provisions should be made in the design.
The opinions expressed above are those of the author, and do not represent an official policy statement of the State of Michigan or the Michigan Department of Transportation.
Edmund Waddell, Senior Transportation Planner
MDOT Project Planning Division
Lansing MI
LuAnne Bullington, October 21, 2002
I support the PROWAC report. I strongly feel we need to have detectable warnings at places where vehicular traffic is likely to be found and we need accessible pedestrian signals.
I live in Ann Arbor, Michigan. We have a few of the devices and I can't start to tell you how important they have been to my safety and sanity.
Ann Arbor is a college town. Some of our drivers are very distracted. The talking pedestrian signals have made a big difference. That verbal cue seems to sneak through their foggy brains and stop them from turning when they shouldn't and running me down. It has reduced the number of accidents I have encountered at the corner where I use the talking signals the most.
I need to cross very busy intersections where it is difficult to tell if it is safe to walk. The audible signals let me know when I can cross. It has been wonderful and I wish my city would put in many more.
If curb cuts can be made mandatory to help wheel chair users, why can't the blind and visually impaired have these life saving devices?
Please help us stay safe and insist cities put in audible signals just like cities put in curb cuts.
Thank you,
LuAnne Bullington
Laurie Mehta, October 24, 2002
Dear Members of the Access Board,
I am a blind American and I support the recommendations of the PROWAC. I use audible signals
weekly, and would not be able to safely access the bus stop near my computer classes without them.
I have been blind for twenty years or so. I travel very well with either a long cane, or a guide dog.
When I had sight, I did a lot of pedestrian travel, and was immensely benefited by illuminated walk
signals. There are many pedestrian crossings, nowadays, that require more than just the traffic
signal to indicate safe crossing. As a blind taxpayer, I would like my tax dollars to be extended
toward providing this same benefit to me and others. Making walk signals audible will save lives, and each life saved is precious.
Since it is increasingly necessary to employ technology to keep traffic flowing, it is even more
necessary than ever to keep pedestrian signals effective. For those who cannot see, making signals
audible solves this problem. Such audible signals are especially necessary where traffic regulation is complex, at T-intersections, and at pedestrian crossings where traffic is stopped for pedestrians though there is no through cross-traffic.
I am aware that there are some who claim to speak for the blind, and oppose audible signals. I strongly
urge you to employ common-sense, and realize that these individuals can choose to ignore an audible
signal if they wish, but those of us whose lives and independence will be preserved by these signals cannot always avoid the dangerous crossings where audible signals could be placed. I know that audible signals are the singular factor enabling me to cross at certain places. I also know that there are places I must go to which I cannot reach independently, simply because a crossing signal is required but is not currently audible.
Please support the recommendations of the PROWAC, because they will make life more safe and independent for me and thousands of other people who cannot see.
Thank you for your consideration of this matter.
Sincerely,
Laurie Mehta
Jeffrey A. Hillegonds, P.E., August 14, 2002
In response to the proposed rule to signalize all cross walks at roundabouts.
Comments:
I am distressed to hear about the proposed rule to signalize all cross walks at roundabouts.
Not only would this be a large financial burden to place at these intersections, it is likely not needed at the vast majority of locations. This type of condition should not be placed as a blanket rule. Signalization, where warranted, can enhance safety for pedestrians and vehicular traffic alike. However, where it is not warranted, it will sometimes increase the risk to pedestrians by confusing drivers or, if the signal is seldom used, creating a dangerous situation because vehicles get used to ignoring unused signals in areas with very few pedestrians.
In addition, the function of the modern roundabout, to promote uninterupted flow through the intersection, particularly at the exits, could be effected, thereby impacting the capacity and safety for pedestrians and motorists alike.
Roundabouts have been constructed, without signalization for pedestrians, in locations like college campuses and other high pedestrian areas with great success.
In my opinion, this rule is not needed at all. A prudent design professional will add signalization where it is warranted. At the very least, the language should be changed significantly, to provide warrants and guidelines for the designer, not a blanket statement that this is required at all locations.
Please consider my comments and re-consider this rule. It is a very bad idea to dictate this type of design at all locations when it really is only needed a very small percentage of the time.
Jeffrey A. Hillegonds, P.E.
Senior Project Manager
Progressive AE
Grand Rapids, MI
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
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
Bruce E. Friedman, P.E., PTOE and the NCUTCD Signals Technical Committee, October 23, 2002
The attached are the collective comments of the Signals Technical Committee of the National Committee on Uniform Traffic Control Devices regarding 36 CFR Parts 1190 and 1191 [Docket No. 02-1] as published in the Federal Register on 6/17/02.
Bruce E. Friedman, P.E., PTOE
Vice President
Kimley-Horn and Associates, Inc.
Signals Technical Committee
National Committee on Uniform Traffic Control Devices
Memo to: Mr. Scott Windley, U.S. Access Board
From: Signals Technical Committee, NCUTCD
Date: October 23, 2002
Re: Comments on the portions of the June 17, 2002 " Draft Guidelines for Accessible Public Rights-of-Way" that relate to traffic control signals
The Signals Technical Committee of the National Committee on Uniform Traffic Control Devices has reviewed the above draft guidelines and has the following comments about the portions pertaining to traffic control signals and related items. We compliment the Access Board on tackling a wide array of impediments to the mobility of all citizens, particularly those with disabilities. Our concerns and comments relate to what we believe is a prudent response to these needs.
Section 1105.3 Pedestrian Signal Phase Timing
This section states that all pedestrian phase timing shall be calculated using a maximum pedestrian walking speed of 3.0 feet
We object to this requirement being applied to "all" intersections. Traffic engineers have always used judgment to decide when and where to apply devices, based on an engineering study of need. Where needs are documented, there are many tools available to the traffic engineer to serve populations that require more time to cross the street. If intersections have pedestrian signals that operate pretimed, pushbuttons can be installed to assist those with a need for more time to complete their crossing. If persons who need more time frequent an actuated intersection, longer clearance times can be provided by supplemental actuation, such as pushing and holding the pushbutton to distinguish those calls from ones requiring only routine timing. To require longer pedestrian clearance timing at all traffic control signals (since all signals, even those without pedestrian signals, must provide adequate time for pedestrians to cross a street if pedestrian movements regularly occur) is a total over-reaction to a need that may exist at some locations, but certainly not at all locations. At most locations there will be a price to pay (in the form of a reduced level of service on the arterial, increased congestion, and increased accident rate) with no offsetting benefit.
Likewise, including the curb ramps in the calculation includes the addition of 3 seconds
To universally apply these new guidelines, at 100,000 or more signalized intersections, whether needed or not, is, in our opinion, like providing STOP signs or traffic control signals at all intersections regardless of the need.
It would be interesting to know if the 3.0 feet
Section 1105.6.2 Roundabouts - Signals
This section requires a pedestrian activated signal for each crosswalk at a roundabout. The narrative clearly points out that some believe roundabouts should not be used in areas of high pedestrian activity. This is an accurate conclusion, and these new devices have limited application in urban areas because of that. In areas of heavy pedestrian activity, all pedestrians, not just those with disabilities, will have trouble crossing at roundabouts, especially those with multiple-lane approaches. But to require traffic control signals at these crosswalks would be the same as requiring a pedestrian actuated traffic control signal at every marked crosswalk, regardless of the difficulty of crossing, regardless of the amount of pedestrian traffic, and without any study indicating that they would be justified.
Few roundabouts would ever be built under these circumstances if this requirement stands. To discourage the use of an effective tool that can be used to minimize delay and congestion at locations that would otherwise have a higher crash rate is contrary to all sound traffic engineering principles. European roundabouts built to the new modern standards, with funneling to slow traffic, do not add pedestrian signals automatically. If a roundabout is built in the U.S., and pedestrian traffic experiences difficulties, actuated pedestrian signalization may well be justified, but it should not be required on every roundabout where pedestrian traffic of all abilities may not have any problem. The STC is opposed to this recommendation. Roundabouts should only be signalized where a need is shown. Other solutions, such as wider splitter islands or in-roadway warning lights, might be more helpful than signalization for pedestrians. Language pointing out the incompatibility of roundabouts and heavy pedestrian activity should be included.
Section 1105.7 Turn Lanes at Intersections
This section requires a pedestrian actuated traffic signal at right or left turn slip lanes (bypasses) for the crosswalk across these lanes, including the channelizing island. This again requires all situations be treated the same, regardless of need, and is counter to all traffic engineering principles that required study and justification for the installation of traffic control devices. The fact that these signals would seldom be actuated and drivers would not expect a red light at these locations does not create a safe situation for such crosswalks. Furthermore, these channelized lanes are typically 15 feet
There is an implication in these guidelines that somehow traffic control signals will improve safety and accessibility for all when applied. Traffic engineers know this is not true, and that often the opposite occurs. Proliferation of devices breeds disrespect and wastes resources that could better be used to provide facilities where the need is greater. The STC is opposed to this recommendation, and believes that it is not well-founded.
Section 1106 (and 1102.8) Accessible Pedestrian Signal Systems
The STC has been working with representatives of the blind community and mobility education specialists, as well as representatives of the US Access Board, on this for more than three years. Some language has been put into the MUTCD already. We have standardized certain functions of Accessible Pedestrian Signals (APS) where we know or want to shape good practice. What we do not yet know is how to standardize on these devices. We are aware that the Access Board has pioneered work on a synthesis of current technology. We know some of the current technologies are not effective or lack in certain features that we believe to be important. For that reason the NCUTCD has requested funding for research to answer the questions of effectiveness. We do not want to see a proliferation of such devices until the research is completed. The Transportation Research Board, under its National Cooperative Highway Research Program (NCHRP) has launched a comprehensive study to obtain this information. We are probably about 24 months away from implementing these results. In addition, the National Institute of Health has research underway that will complement that of the NCHRP. Two members of the STC serve on the NCHRP panel to ensure that the research provides the traffic engineering profession with the information we need to adopt standards governing the installation and operation of APS. The two research teams have overlapping membership, so we are confident that we can continue to work with members of the Access Board and the blind community to improve mobility. We have to deal with issues of where and under what conditions they will be installed. Perhaps a way to start is to standardize all pedestrian pushbutton locations for all traffic signals, and our STC task force is working on that. But it is premature and not in the public interest to adopt the guidelines now until such research is completed. Even the standardization of the location of APS is not yet answered, and to spell out exact locations for them as proposed in Section 1106.2.1 is premature, and may not be the correct location for certain complex intersections. The above mentioned research is also addressing that.
Section 1106.3 Pedestrian Pushbuttons
This matter is still being studied by the STC and we request a delay until we can obtain input from the research mentioned above. We agree that there needs to be more standardization of pushbutton locations, recognizing that corner radius geometry sometimes limits the options, and we hope to have all typical conditions covered. Certainly, prescribing the location of pushbuttons needs to take into account the minimum clear width also required, and this may be more important than meeting the exact requirements of the dimensions shown for pushbutton locations. We also need to find out more about locator tones before we can standardize on their sound levels and aiming.
Conclusion
In conclusion, we believe the Access Board is making progress in implementing the requirements of ADA. We are willing to work with all the stakeholders to help, but are concerned with "across-the-board" requirements that are unrealistic to achieve. Specifically, a 3.0 feet
Another important consideration is that the Access Board needs to recognize that agencies responsible for the installation of traffic control devices have limited resources. The requirements for Accessible Pedestrian Signals at all locations should not be applied universally, at the time of reconstruction or alteration, without prioritizing needs. We believe this will not be in the best interests of the very community that is being served by these new guidelines. Traffic engineers can evaluate and prioritize needs, with help from the affected community, as now provided for in the MUTCD. These guidelines ought to support that direction. To do less would not serve the community with disabilities.
Thank you on behalf of all of the members of the STC for your consideration of our collective comments.
Sincerely,
Bruce E. Friedman, P.E., PTOE
Chairman
Signals Technical Committee of the NCUTCD
cc: STC members
Sent in via e-mail by:
Bruce E. Friedman, P.E., PTOE
Kimley-Horn and Associates, Inc.
Lloyd E. Neal, P.E., October 17, 2002
RE: Draft Public Rights-of-Way Accessibility Guidelines
Dear Mr. Windley:
The City of Plano has assembled a group of city planners, traffic engineers, civil engineers and public works officials to review the Draft Public Right-of-Way Guidelines proposed by the Access Board. The City fully supports the goal of increased accessibility and has spent many capital improvement dollars retrofitting curb ramps and sidewalks to make the city streets as accessible as possible. However, we do have concerns about the application and practicality of some of the proposed standards, and offer the following comments and suggestions for consideration:
1101 Application and Administration
1101.3 Defined Terms
Curb Line - this definition assumes that the sidewalk, if there is a sidewalk, is always adjacent to the curb. This is not the case in most suburban and residential areas.
Element & Facility - The definition of "element" includes the term "facility" and the definition of "facility" includes the term "element." Therefore, these appear to be circular references with no clear definition. Traffic control signs (and their supports) and traffic signals (and their supports) are located in public right-of-way. Is it intended that they be included in the definition of element, facility, or both?
Sidewalk - In
Street Furniture - the "elements in the public right-of-way that are intended for use by pedestrians" definition is too general. The sidewalk is in the public right-of-way and is intended for use by pedestrians, but it should not be considered street furniture. Street name signs and traffic signals are located within the public right-of-way and are intended for use by pedestrians (as well as drivers). These also should not be considered street furniture. A specific definition of those things specifically considered street furniture should be prepared.
Walk Interval - this definition should be modified to read as follows: "That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and, where provided, its audible equivalent.
1102 Scoping Requirements
1102.2.1 Additions & 1102.2.2 Alterations
It appears that the proposed wording of these sections would require the installation of audible pedestrian signals and audible/vibrotactile pedestrian detector buttons/poles for any new traffic signal installation and for modifications to existing traffic signals. See later comments for 1106 concerning pedestrian signals.
1102.3 Alternate Circulation Path
Sidewalk repairs often involve numerous locations along a block, but only a few short sections of walk may be removed and for only a short period of time. This would result in several separate alternative paths being created and maintained in the same block, and in many instances, the alternate circulation path would place pedestrians immediately adjacent to fast-moving traffic lanes on major arterial streets. We suggest that if sidewalks are available on both sides of the street, the sidewalk on the opposite side of the street should be permitted as an alternate circulation path.
1102.5.2 Post Mounted Objects
For right-of-way areas near traffic signal controlled intersections, this section needs to permit the installation of the traffic signal control cabinet on a post. Although some controller cabinets are ground mounted, many in a CBD area are post mounted. These are likely to be mounted with the bottom higher than 27 inches
1102.14 On-Street Parking
Outside of downtowns or high-density mixed-use districts, individual parking spaces are not typically marked, especially on residential streets. The proposed wording does not distinguish between locations where on-street parking is provided with marked parking spaces versus locations where on-street parking is provided but there are no marked spaces. It is not clear whether or not this requirement is intended to apply to blocks with unmarked spaces. This situation is typical in residential subdivisions where parking is permitted on the street but no specific parking spaces are marked. Under these conditions, the provision of a marked on-street accessible parking space should not be required. Cities should have the option to respond to individual requests for parking, so that spaces are placed in a location most convenient to disabled residents.
1104 Curb Ramps and Blended Transitions
1104.3.3 Surfaces
The prohibition of access covers and other appurtenances on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route may discourage the installation of additional sidewalks in some cases. If this prohibition includes traffic signal pull boxes and a traffic signal currently exists at a location proposed for new sidewalk installation, relocating existing pull boxes out of the prohibited areas can be both costly and disruptive. Since pull boxes are used to connect conduits, route the control cables around the intersection, and connect vehicle loops to the detector cables, the relocation of a pull box also requires modifications to the underground conduit and either replacing or splicing the cables. During the cable work, the traffic signal will likely have to be operated in either flashing mode or turned off depending on the cables involved. Similar extensive underground work would be required where various access covers exist for other underground items such a telephone or communications cables, sanitary or storm sewers, or other utility items.
If the access cover is made flush with the surrounding walkway area, it should be permitted to be in these areas. When faced with a decision to undertake such a degree of work on an existing signal or utility facility to accommodate the installation of a sidewalk, many agencies may choose to not install the sidewalk. When new traffic signal and utility facilities are being installed, the design can typically locate the access covers outside the curb ramp, landing, blended transition, and gutter areas. However, relocating existing items involves extensive work and expense.
Are traffic signal, utility, street light, and other such poles intended to be included in this prohibition? The use of the work "appurtenances" in the list of prohibited items could be interpreted to include these. As with the access covers, the relocation of these can be both costly and disruptive. Also, underground and overhead utility lines often influence or control the location of these poles. Existing poles should be permitted to remain. New poles should be recommended to be located outside these areas but flexibility needs to exist for cases where the placement of the pole is controlled by existing underground and overhead utilities.
1105 Pedestrian Crossings
1105.3 Pedestrian Signal Phase Timing
Jurisdictions should be allowed to determine the necessity for the slower pedestrian walk speed, based on surrounding land uses and on the needs of individuals in the area. A requirement to use a maximum of 3.0 feet
1105.4 Medians and Pedestrian Refuge Islands
The proposed wording "medians and refuge islands in crosswalks" is good in that this section and its subsections would not be applied to medians that are not in crosswalks. In order to avoid possible confusion about a minimum 6 foot
1105.6 Roundabouts
1105.6.1 Separation
The requirement to provide a continuous barrier along the street side of the sidewalk where pedestrian crossing is prohibited is excessive. This requirement applies whether or not operational experience indicates a problem with crossings at inappropriate locations. Crossing at mid-block locations or at intersections where crossings are prohibited by signs may also be dangerous to pedestrians. However, physical barriers are not proposed to be required at these locations. If it is desired to treat prohibited pedestrian crossing areas at roundabouts differently than at other locations, the proposed wording should be in the form of guidance or option rather than an across the board requirement.
1105.6.2 Signals
The proposed wording requires the installation of a traffic signal for each crosswalk at a roundabout. This requirement is made without the benefit of any engineering study of traffic operations or level of pedestrian activity at the location. Visibility of the traffic signal to drivers approaching the roundabout should be similar to other traffic signals. However, drivers exiting the roundabout will have greater difficulty in seeing and responding to the traffic signal since they will be negotiating around the roundabout as they approach. They will not be able to view the signal indications from as great a distance as drivers on a straight approach. Additionally, traffic may back up around the roundabout while stopped for a red signal at the pedestrian crosswalk signal when departing the roundabout. In the event there is more than one crosswalk at the roundabout, it may be necessary to limit when the crosswalk signals can respond to a pedestrian call to avoid congestion if separate crosswalk signals served pedestrian demand consecutively.
1105.7 Turn Lanes at Intersections
The proposed requirement to provide a pedestrian activated traffic signal where pedestrian crosswalks are provided at right or left turn slip lanes is excessive. First, there should not be a requirement to install a traffic signal at an intersection simply because a crosswalk crosses a left or right turn slip lane. The proposed wording will require signal installation even if the intersection is operating well without a traffic signal. As in 1105.6.2, the signal installation requirement is not based on an engineering study of actual operating conditions at the location. Second, even if there is a traffic signal at the intersection, there should not be an automatic requirement to control the pedestrian crossing movement across a left or right turn slip lane. This requirement would force the turning movement to be controlled by a signal indication rather that the Yield or Stop signs that are commonly used in such cases. During the green signal indication for the adjacent through movement, using signal control for the turning movement has little or no impact whether a Stop or Yield sign has previously been used. The replacement of a Stop sign with a signal indication may lead to a slight operational improvement, at least during the time the signal is green, as the vehicles would no longer have to come to a stop before proceeding. However, the replacement of a Yield sign with a signal indication would have a significant impact. While the signal indication was red, vehicles would be required to come to a complete stop before making the permitted turning movement versus simply slowing to yield with the previous Yield control. The proposed control of turning movements in slip lanes should be modified to list signal control as an option but not as a requirement.
1106 Accessible Pedestrian Signal Systems
1106.2 Pedestrian Signal Devices
The proposed wording requires that all crosswalks with pedestrian signal indications have both audible and vibrotactile indications for the WALK interval. Audible signals at intersections in neighborhood settings, even those with volumes that respond to ambient noise, may annoy nearby residents at night when background noise levels are not high enough to dampen the sound. Audible signals should be activated only on a demand basis. Additionally, the installation of audible and vibrotactile indications of the WALK interval should not be required under all conditions. Rather, specific conditions requiring such devices could be listed but their use at other locations should be optional.
1106.2.1 Location
Typically, the standard pedestrian signal devices (pedestrian heads and pedestrian push buttons) serving both crosswalks will be located on one pole at that corner. The requirement that accessible pedestrian signal devices be separated by a minimum of 120 inches
1106.3 Pedestrian Pushbuttons
1106.3.2 Locator Tone
The proposed wording requires every pushbutton to be equipped with a locator tone. Whereas the audible WALK indication tone would only operate during the WALK periods, the push button locator tone is required to operate during the DON'T WALK and flashing DON'T WALK intervals. In residential settings or where the WALK interval is served only upon demand, the continuous operation of the detector locator tone may lead to complaints.
1106.4 Directional Information Signs
Revised wording is needed for this section. The existing wording of "pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal" implies that each of the pedestrian signal devices must have these signs. This requirement should not be applied to typical WALK/DON'T WALK pedestrian signal heads. If required, the tactile and visual signs should be provided as part of the push button assembly or adjacent to the pushbutton assembly.
This proposed wording adds a requirement for the street names that is not otherwise required. There would be no street name information provided at an intersection that was not controlled by a traffic signal. The requirement to include the street name means unique signs must be installed for each corner with pedestrian signal devices. The provision of an arrow indicating the direction of the controlled crosswalk without the street name included would permit the use of the same device at multiple locations.
1109 On-Street Parking
It should be specified that this applies to accessible parking spaces and not all parking spaces. Otherwise, it could be interpreted that an access aisle is required adjacent to every parking space.
1109.2 Parallel Parking Spaces
The exception for when an access aisle is not required appears to assume there is a paved sidewalk. In some residential and other areas, paved sidewalks are not provided. Also, the proposed wording permits the exclusion "where the width of the sidewalk between the extension of the normal curb and the boundary of the public right-of-way is less than 14 feet
1109.3 Perpendicular or Angled Parking Spaces
Is a separate access aisle required for each parking space or can a single access aisle between two spaces serve both spaces? It is noted that there is no requirement on whether the access aisle is on the right side or left side of the parking space. It seems that a single aisle between two adjacent spaces would provide the needed access to the parking spaces.
1111 Alternate Circulation Path
1111.3 Location
The requirement that the alternate circulation path parallel the disrupted pedestrian access route and be on the same side of the street is impractical in many cases. If sidewalks in a residential area are being repaired or if utility work has caused the sidewalk to be closed, the right-of-way is often too narrow to provide the required 3-foot wide alternate path on the same side of the street. An alternate circulation path using the opposite side of the street may be the only practical choice. If faced with the alternatives of an unpaved path on the same side of the street or an existing paved sidewalk on the opposite side of the street, the paved sidewalk provides a superior option even if it is across the street.
It is noted that there does not seem to be a requirement that the alternate circulation path be paved. In fact, it would be impractical to include such a requirement for many cases. Repair of damaged sidewalk sections in residential areas may be completed in a couple of days. If the construction of a paved alternative path on the same side of the street were required, both the overall time and cost would increase.
Although the document title indicates it contains guidelines, the proposed wording actually establishes requirements rather than guidelines in many cases. It also includes several items that address the installation and/or operation of various traffic control devices. Since the MUTCD provides the standards, guidance, options, and support information for traffic control devices, any proposed additions or changes to the standards, guidance, options, or support information should also be reflected in the MUTCD.
Thank you for the opportunity for the city to comment on these proposals. If you have any questions or need additional information, please feel free to contact Ronnie Bell, Senior Traffic Engineer at [...].
Sincerely,
Lloyd E. Neal, P.E.
Transportation Engineering Manager
City of Plano
Anthony R. Candela, October 28, 2002
To Whom It May Concern:
I am writing to request full and due consideration be given to establishing
regulations and guidelines for audible pedestrian signals at unusual and
dangerous street intersections. This is not a black and white issue and
apparent divisions among the blindness community should not be allowed to
eliminate this issue from the landscape.
Audible pedestrian signals are a form of technology that is evolving. In
unusual or dangerous street intersections -- more numerous as modern
traffic control systems are being designed to move automobile traffic more
quickly -- additional help is needed if the non-visual person is to
navigate safely. Since artificial construction is often at the root of the
problem, artificial construction (e.g., easily visible and tactual
crosswalks, more elaborate and audible pedestrian signals, protective
barriers to shield pedestrians from vehicles, etc.) is required to
compensate for the added complexity.
Arguments in favor of and against audible pedestrian signals often overlook
the real problem -- appropriate and easily interpretable signals are
needed, inappropriate and ambiguous signals are harmful. Instead, the
argument becomes black and white. Regulators must not throw out the baby
with the bathwater. Please move forward to develop appropriate regulations
and guidelines. Don't let the 'with -em' or 'agin' 'em' style of argument
distract you from your duty.
Thank you.
Anthony R. Candela
National Program Associate
AFB West
Christine L. Boone, Esq., September 20, 2002
Please accept these comments in opposition to the Access Board's current proposal regarding audible traffic signals.
The Pennsylvania Bureau of Blindness & Visual Services, Office of Vocational Rehabilitation, Department of Labor & Industry will not take a position in favor of audible traffic signals, for the following reasons:
1. The signals, as proposed by the Access Board, constitute a violation of the Americans With Disabilities Act, as the law requires that an individual may accept or decline any offered accommodation (42 U.S.C. Sec. 12101 et seq.).
2. Audible Pedestrian Signals, as proposed by the Access Board constitute a clear and present danger to blind pedestrians as they mask and/or obscure the traffic sounds and other reliable sound cues which these individuals use in order to travel safely and efficiently through the built environment.
The proposed signals are apparently being recommended under the premise that down town intersections are too dangerous for blind pedestrians. In actuality, the signals make intersections which are otherwise safely negotiable by persons who are blind unsafe, and non-ADA-compliant. Further, municipalities may now be liable for injuries sustained by pedestrians, blind or sighted, while crossing intersections which are equipped with audible signals because the distraction created by the noise emitted from the signals may constitute a contributory factor in such injuries.
The proposed signals sound automatically, making it impossible for any pedestrian to "decline" to use them.
The technology exists to install pedestrian activated audible signals which would only sound if a traveler pressed a button other than the standard "walk" button. These devices would be ADA compliant, as they are a reasonable accommodation which can be accepted or declined by the traveler. They would also eliminate the problem of liability, as individuals would need to choose to use the signals, negating any contributory negligence argument that might attach fault to a municipality.
The audible pedestrian signal which can only be activated intentionally by an individual will enable properly trained persons who are blind and visually impaired to safely negotiate intersections using environmental sound cues which are proven to be safe, effective and reliable. These signals will also offer an alternative crossing cue to those pedestrians who are blind and visually impaired who are uncomfortable or untrained in crossing unmodified intersections.
Thank you for the opportunity to comment on the Access Board's proposal. I would be pleased to provide any additional information upon request.
Christine L. Boone, Esq., Director
Bureau of Blindness & Visual Services
Office of Vocational Rehabilitation
Department of Labor & Industry
Ronnie Bell, P.E., October 17, 2002
I was a member of a committee composed of representatives from various City departments that reviewed the Draft Public Rights-of-Way Accessibility Guidelines. Comments from the City of Plano, Texas are included in the attached file. We appreciate the opportunity to participate in this important process. Please feel free to contact me if you have any questions or need any additional information.
Ronnie Bell, P.E.
Senior Traffic Engineer
City of Plano
October 17, 2002
Mr. Scott Windley, Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, NW, Suite 1000
Washington DC 20004-1111
RE: Draft Public Rights-of-Way Accessibility Guidelines
Dear Mr. Windley:
The City of Plano has assembled a group of city planners, traffic engineers, civil engineers and public works officials to review the Draft Public Right-of-Way Guidelines proposed by the Access Board. The City fully supports the goal of increased accessibility and has spent many capital improvement dollars retrofitting curb ramps and sidewalks to make the city streets as accessible as possible. However, we do have concerns about the application and practicality of some of the proposed standards, and offer the following comments and suggestions for consideration:
1101 Application and Administration
1101.3 Defined Terms
Curb Line - this definition assumes that the sidewalk, if there is a sidewalk, is always adjacent to the curb. This is not the case in most suburban and residential areas.
Element & Facility - The definition of "element" includes the term "facility" and the definition of "facility" includes the term "element." Therefore, these appear to be circular references with no clear definition. Traffic control signs (and their supports) and traffic signals (and their supports) are located in public right-of-way. Is it intended that they be included in the definition of element, facility, or both?
Sidewalk - In
Street Furniture - the "elements in the public right-of-way that are intended for use by pedestrians" definition is too general. The sidewalk is in the public right-of-way and is intended for use by pedestrians, but it should not be considered street furniture. Street name signs and traffic signals are located within the public right-of-way and are intended for use by pedestrians (as well as drivers). These also should not be considered street furniture. A specific definition of those things specifically considered street furniture should be prepared.
Walk Interval - this definition should be modified to read as follows: "That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and, where provided, its audible equivalent.
1102 Scoping Requirements
1102.2.1 Additions & 1102.2.2 Alterations
It appears that the proposed wording of these sections would require the installation of audible pedestrian signals and audible/vibrotactile pedestrian detector buttons/poles for any new traffic signal installation and for modifications to existing traffic signals. See later comments for 1106 concerning pedestrian signals.
1102.3 Alternate Circulation Path
Sidewalk repairs often involve numerous locations along a block, but only a few short sections of walk may be removed and for only a short period of time. This would result in several separate alternative paths being created and maintained in the same block, and in many instances, the alternate circulation path would place pedestrians immediately adjacent to fast-moving traffic lanes on major arterial streets. We suggest that if sidewalks are available on both sides of the street, the sidewalk on the opposite side of the street should be permitted as an alternate circulation path.
1102.5.2 Post Mounted Objects
For right-of-way areas near traffic signal controlled intersections, this section needs to permit the installation of the traffic signal control cabinet on a post. Although some controller cabinets are ground mounted, many in a CBD area are post mounted. These are likely to be mounted with the bottom higher than 27 inches
1102.14 On-Street Parking
Outside of downtowns or high-density mixed-use districts, individual parking spaces are not typically marked, especially on residential streets. The proposed wording does not distinguish between locations where on-street parking is provided with marked parking spaces versus locations where on-street parking is provided but there are no marked spaces. It is not clear whether or not this requirement is intended to apply to blocks with unmarked spaces. This situation is typical in residential subdivisions where parking is permitted on the street but no specific parking spaces are marked. Under these conditions, the provision of a marked on-street accessible parking space should not be required. Cities should have the option to respond to individual requests for parking, so that spaces are placed in a location most convenient to disabled residents.
1104 Curb Ramps and Blended Transitions
1104.3.3 Surfaces
The prohibition of access covers and other appurtenances on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route may discourage the installation of additional sidewalks in some cases. If this prohibition includes traffic signal pull boxes and a traffic signal currently exists at a location proposed for new sidewalk installation, relocating existing pull boxes out of the prohibited areas can be both costly and disruptive. Since pull boxes are used to connect conduits, route the control cables around the intersection, and connect vehicle loops to the detector cables, the relocation of a pull box also requires modifications to the underground conduit and either replacing or splicing the cables. During the cable work, the traffic signal will likely have to be operated in either flashing mode or turned off depending on the cables involved. Similar extensive underground work would be required where various access covers exist for other underground items such a telephone or communications cables, sanitary or storm sewers, or other utility items.
If the access cover is made flush with the surrounding walkway area, it should be permitted to be in these areas. When faced with a decision to undertake such a degree of work on an existing signal or utility facility to accommodate the installation of a sidewalk, many agencies may choose to not install the sidewalk. When new traffic signal and utility facilities are being installed, the design can typically locate the access covers outside the curb ramp, landing, blended transition, and gutter areas. However, relocating existing items involves extensive work and expense.
Are traffic signal, utility, street light, and other such poles intended to be included in this prohibition? The use of the work "appurtenances" in the list of prohibited items could be interpreted to include these. As with the access covers, the relocation of these can be both costly and disruptive. Also, underground and overhead utility lines often influence or control the location of these poles. Existing poles should be permitted to remain. New poles should be recommended to be located outside these areas but flexibility needs to exist for cases where the placement of the pole is controlled by existing underground and overhead utilities.
1105 Pedestrian Crossings
1105.3 Pedestrian Signal Phase Timing
Jurisdictions should be allowed to determine the necessity for the slower pedestrian walk speed, based on surrounding land uses and on the needs of individuals in the area. A requirement to use a maximum of 3.0 feet
1105.4 Medians and Pedestrian Refuge Islands
The proposed wording "medians and refuge islands in crosswalks" is good in that this section and its subsections would not be applied to medians that are not in crosswalks. In order to avoid possible confusion about a minimum 6 foot
1105.6 Roundabouts
1105.6.1 Separation
The requirement to provide a continuous barrier along the street side of the sidewalk where pedestrian crossing is prohibited is excessive. This requirement applies whether or not operational experience indicates a problem with crossings at inappropriate locations. Crossing at mid-block locations or at intersections where crossings are prohibited by signs may also be dangerous to pedestrians. However, physical barriers are not proposed to be required at these locations. If it is desired to treat prohibited pedestrian crossing areas at roundabouts differently than at other locations, the proposed wording should be in the form of guidance or option rather than an across the board requirement.
1105.6.2 Signals
The proposed wording requires the installation of a traffic signal for each crosswalk at a roundabout. This requirement is made without the benefit of any engineering study of traffic operations or level of pedestrian activity at the location. Visibility of the traffic signal to drivers approaching the roundabout should be similar to other traffic signals. However, drivers exiting the roundabout will have greater difficulty in seeing and responding to the traffic signal since they will be negotiating around the roundabout as they approach. They will not be able to view the signal indications from as great a distance as drivers on a straight approach. Additionally, traffic may back up around the roundabout while stopped for a red signal at the pedestrian crosswalk signal when departing the roundabout. In the event there is more than one crosswalk at the roundabout, it may be necessary to limit when the crosswalk signals can respond to a pedestrian call to avoid congestion if separate crosswalk signals served pedestrian demand consecutively.
1105.7 Turn Lanes at Intersections
The proposed requirement to provide a pedestrian activated traffic signal where pedestrian crosswalks are provided at right or left turn slip lanes is excessive. First, there should not be a requirement to install a traffic signal at an intersection simply because a crosswalk crosses a left or right turn slip lane. The proposed wording will require signal installation even if the intersection is operating well without a traffic signal. As in 1105.6.2, the signal installation requirement is not based on an engineering study of actual operating conditions at the location. Second, even if there is a traffic signal at the intersection, there should not be an automatic requirement to control the pedestrian crossing movement across a left or right turn slip lane. This requirement would force the turning movement to be controlled by a signal indication rather that the Yield or Stop signs that are commonly used in such cases. During the green signal indication for the adjacent through movement, using signal control for the turning movement has little or no impact whether a Stop or Yield sign has previously been used. The replacement of a Stop sign with a signal indication may lead to a slight operational improvement, at least during the time the signal is green, as the vehicles would no longer have to come to a stop before proceeding. However, the replacement of a Yield sign with a signal indication would have a significant impact. While the signal indication was red, vehicles would be required to come to a complete stop before making the permitted turning movement versus simply slowing to yield with the previous Yield control. The proposed control of turning movements in slip lanes should be modified to list signal control as an option but not as a requirement.
1106 Accessible Pedestrian Signal Systems
1106.2 Pedestrian Signal Devices
The proposed wording requires that all crosswalks with pedestrian signal indications have both audible and vibrotactile indications for the WALK interval. Audible signals at intersections in neighborhood settings, even those with volumes that respond to ambient noise, may annoy nearby residents at night when background noise levels are not high enough to dampen the sound. Audible signals should be activated only on a demand basis. Additionally, the installation of audible and vibrotactile indications of the WALK interval should not be required under all conditions. Rather, specific conditions requiring such devices could be listed but their use at other locations should be optional.
1106.2.1 Location
Typically, the standard pedestrian signal devices (pedestrian heads and pedestrian push buttons) serving both crosswalks will be located on one pole at that corner. The requirement that accessible pedestrian signal devices be separated by a minimum of 120 inches
1106.3 Pedestrian Pushbuttons
1106.3.2 Locator Tone
The proposed wording requires every pushbutton to be equipped with a locator tone. Whereas the audible WALK indication tone would only operate during the WALK periods, the push button locator tone is required to operate during the DON'T WALK and flashing DON'T WALK intervals. In residential settings or where the WALK interval is served only upon demand, the continuous operation of the detector locator tone may lead to complaints.
1106.4 Directional Information Signs
Revised wording is needed for this section. The existing wording of "pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal" implies that each of the pedestrian signal devices must have these signs. This requirement should not be applied to typical WALK/DON'T WALK pedestrian signal heads. If required, the tactile and visual signs should be provided as part of the push button assembly or adjacent to the pushbutton assembly.
This proposed wording adds a requirement for the street names that is not otherwise required. There would be no street name information provided at an intersection that was not controlled by a traffic signal. The requirement to include the street name means unique signs must be installed for each corner with pedestrian signal devices. The provision of an arrow indicating the direction of the controlled crosswalk without the street name included would permit the use of the same device at multiple locations.
1109 On-Street Parking
It should be specified that this applies to accessible parking spaces and not all parking spaces. Otherwise, it could be interpreted that an access aisle is required adjacent to every parking space.
1109.2 Parallel Parking Spaces
The exception for when an access aisle is not required appears to assume there is a paved sidewalk. In some residential and other areas, paved sidewalks are not provided. Also, the proposed wording permits the exclusion "where the width of the sidewalk between the extension of the normal curb and the boundary of the public right-of-way is less than 14 feet
1109.3 Perpendicular or Angled Parking Spaces
Is a separate access aisle required for each parking space or can a single access aisle between two spaces serve both spaces? It is noted that there is no requirement on whether the access aisle is on the right side or left side of the parking space. It seems that a single aisle between two adjacent spaces would provide the needed access to the parking spaces.
1111 Alternate Circulation Path
1111.3 Location
The requirement that the alternate circulation path parallel the disrupted pedestrian access route and be on the same side of the street is impractical in many cases. If sidewalks in a residential area are being repaired or if utility work has caused the sidewalk to be closed, the right-of-way is often too narrow to provide the required 3-foot wide alternate path on the same side of the street. An alternate circulation path using the opposite side of the street may be the only practical choice. If faced with the alternatives of an unpaved path on the same side of the street or an existing paved sidewalk on the opposite side of the street, the paved sidewalk provides a superior option even if it is across the street.
It is noted that there does not seem to be a requirement that the alternate circulation path be paved. In fact, it would be impractical to include such a requirement for many cases. Repair of damaged sidewalk sections in residential areas may be completed in a couple of days. If the construction of a paved alternative path on the same side of the street were required, both the overall time and cost would increase.
Although the document title indicates it contains guidelines, the proposed wording actually establishes requirements rather than guidelines in many cases. It also includes several items that address the installation and/or operation of various traffic control devices. Since the MUTCD provides the standards, guidance, options, and support information for traffic control devices, any proposed additions or changes to the standards, guidance, options, or support information should also be reflected in the MUTCD.
Thank you for the opportunity for the city to comment on these proposals. If you have any questions or need additional information, please feel free to contact Ronnie Bell, Senior Traffic Engineer at (972) 941-7151.
Sincerely,
Lloyd E. Neal, P.E.
Transportation Engineering Manager
City of Plano
Lloyd Rasmussen, October 14, 2002
I am filing my comments with regard to the Draft Guidelines for Accessible Public Rights of Way of June 17, 2002.
I am a member of the National Federation of the Blind, and support most of the recommendations contained in these guidelines. I am an electronics engineer, and have traveled in many places in the United States, using a long white cane, for forty years. This travel has included fair weather as well as foul, broken-down sidewalks, intermittent sidewalks, multi-lane street crossings, non-controlled street crossings, and much more. In 1992 I was one of the instigators of an NFB resolution that expressed some flexibility regarding the need for audible pedestrian signals. In 2001 I had the privilege of serving on a panel of the Maryland State Highway Administration which developed a set of warrants for the installation of "accessible" pedestrian signals.
I support the construction of more and better sidewalks, and a greatly increased understanding of the needs of pedestrians (particularly those who cannot drive) when vehicle ways and mass transit are being planned, re-purposed, reassessed and constructed.
I would not like to see these guidelines increase the cost of pedestrian accommodations so greatly that pedestrian access projects are not carried out or are postponed due to a lack of funds. I have the feeling that, even though thousands of hours have gone into the process of writing these guidelines, there are still too many proposed requirements that are "nice to have's" without properly delineating the "must-have's" of pedestrian access.
Blended transitions, perpendicular and parallel curb ramps: I am concerned that people are going to make blended transitions between sidewalks and streets the norm. Where is water supposed to drain?
Vehicles can tolerate more water on their paths than pedestrians can. I support the deprecation of "split the difference" curb ramps which dump pedestrians into the intersection instead of into the crosswalk.
If a blended transition is built, and detectable warnings are placed around the corner, in front of both crosswalks, how are blind pedestrians expected to know the direction of these crosswalks. This would seem to be problematic at intersections with little traffic, where the intersection is offset or not at right angles. Remember that most intersections will not have pedestrian signals of any kind installed, due to the lack of traffic.
When a parallel curb ramp is built, dividing a sidewalk into a portion sloping downward toward street level and a part which is not, what sort of "barrier is contemplated between the two adjacent sidewalk segments? A raised row of bricks? A guard-rail? I can't really picture this.
"Accessible" Pedestrian Signals: I have major reservations regarding the usefulness, safety, and consistent application of these devices.
I support the NFB's position on APS's whole-heartedly. But many NFB statements have mistakenly said that a pedestrian signal "informs a pedestrian when it is safe to cross." It does no such thing. It only informs pedestrians that they have an enhanced right of way for a specific period of time, which may or may not be noticed by drivers. Blind people must be enabled to engage in "defensive walking" as much as drivers are encouraged to drive defensively. In developing these standards, we must not forget the phenomenon that people (pedestrians and drivers) can only pay attention to a small number of stimuli at any particular moment. The unexpected event is usually the most dangerous one. I would hypothesize that a tactile stimulus does not compete for attention among audible stimuli as strongly as an audible stimulus does. Knowing when the pedestrian "start walking" interval occurs is important and useful. Knowing what vehicles around you are doing, and walking in the proper direction, is critical.
Many of the comments you are receiving on the guidelines are from people who have never experienced what is being proposed. You see far too many references to "chirping birds" and other sounds which are not proposed. Nobody should be told that these signals are good or bad until they know how they are supposed to work, and they have tried them.
In my opinion, the studies which the Access Board has conducted have involved really small numbers of blind people, and in many cases the work was carried out under artificial conditions, or only in good weather. And in some studies, the opinions and performance of sighted orientation and mobility instructors are counted as just as important as those of the people who will use the equipment--blind people. In the Washington, DC area, as of this writing, I don't think there are ANY intersections containing the proposed types of APS's, whose crosswalks, curb ramps and other pedestrian features comply with the proposed guidelines. Why should anyone be expected to endorse a system when it stands on several unstable legs, and has not been tested as a whole? Why should the Access Board mandate the installation of APS when they are poorly understood by the Americans who need to build and use them? I support further research and limited installations, to address problems such as we identified in our Maryland Highway Administration warrants system. But I believe that mandating "accessible" pedestrian signals across the board, in all cases, is premature, expensive, foolish and dangerous.
Locator tones: These ought to be called "locator clicks" because they ought to be short enough not to have a well-defined pitch. If the locations of these new signals can become standardized, no tones should be necessary. A cane or guide dog can find APS pedestals, if they are in predictable locations. Even though the guideline and the studies state that the sound pressure level at a distance of three feet should be "plus 2 to plus 5 dB" above the ambient sound level, there is no mention of the time constant of the gain control circuit which maintains this level, and where the ambient noise level is measured in order to control the APS's audio output. The investigators have forgotten that these signals, especially the locator tones, could be set several dB below the noise level and still be heard, because the human ear and brain can detect weak signals having specific frequencies and amplitude profiles. If the levels were reduced 5 or more DB below what is proposed, and the time constant for gain control shortened, there would be less tendency to hear "ping-ponging" signals from several APS around one intersection. Researchers and blind people must also decide, once and for all, whether they expect to use these signals as beacons while out in the middle of the street, or not. The new signals seem to be designed to "launch" a person into the intersection at the designated time and in a specific direction, and not to provide a beacon as the pedestrian is approaching the opposite side of the street. That's how I think they should work, but I don't know whether that is the expectation of the people who want to use these signals. And I don't know whether enough research has been done to verify that this concept works well for intersections which are extremely wide and/or extremely complex.
I am not yet confident that traffic engineers and their contractors will be able to install and maintain APS devices. Will shortcuts be taken in the interest of not burying cable, such as wirelessly controlled signals which are occasionally mis-activated or blocked by radio interference? Signals whose timing has gotten out of sync with the visual signal timing, but an inspector didn't notice or didn't know how to properly check? Directional arrows not lined up with the crosswalk for which the device is signaling? Devices mounted to the existing pole for the pedestrian activation button, even though the existing pole is several feet away from the "starting line" which the pedestrian should be on? But speaking of starting lines, I'm happy that the guidelines posit a slower walking speed, and therefore a longer pedestrian clearance interval.
It is often asserted that traffic is becoming quieter, especially with the advent of electric cars and better mufflers. It is true that the difference in noise output at idle between the loudest and quietest vehicles is increasing. Many trucks and buses are getting louder without limit. In other locations, the noise of building ventilation systems can mask much of the traffic noise. This situation, particularly electric cars, deserves somewhat more study.
Clearly, electric cars will make tire noise while they are moving. I might support the concept that such cars be required to emit some noise while stopped and ready to accelerate or turn. In other words, rather than create more noise and put new pedestals on the sidewalks, it may make more sense to insure that motor vehicles are audible, and also that the greatest contributors to noise pollution be muffled.
Detectable Warnings: I think there may be some intersections and islands where truncated domes would be useful. But again I would rather see ramps and curved edges for walkways, which can provide as much information as the domes can. The installation of detectable warnings at all covered intersections seems wasteful and unnecessary, unless "flat" or "raised" intersections are to become the norm.
Thank you for your consideration of all of these comments. I hope that sanity will prevail when these guidelines become a proposed rule.
Sincerely,
Lloyd Rasmussen
Kevin Kraly, September 18, 2002
My name is Kevin Kraly, and I am one of many blind pedestrians whose safety will be affected by your decision whether or not to encourage the installation of audible signals at intersections. I feel that these audible signals are very important to all blind pedestrians! Traffic patterns aren't always the same, and the lack of traffic is just as important. If there is no traffic at all, it is impossible to know whether the light is green or red. If an audible signal is present, it's much easier to determine when it's safe to cross, and the chances of Walking out into an intersection against the light are slim to none. There are also intersections with signals for left turn traffic which can sometimes be mistaken for a green light. This is another situation where an audible signal would be of great help to any blind pedestrian. Intersections involving more than two streets can present mass confusion and great danger to blind pedestrians also. We need all of the help that we can get! Without these devices, it would be impossible to navigate many intersections, much like it is when drivers have to go through a city where all of the traffic signals are broken. We, the blind pedestrians in America, are just asking for a signal of our own!
Kevin Kraly,
Hillsboro, Oregon
Cheryl Fischer, October 16, 2002
Dear Access Board:
I am writing to say that, while there are intersections, especially those with actuated traffic signaling systems, where audible signaling devices are necessary for a blind person to gain the information they need to cross safely, these audible signals are not needed everywhere. I am blind and have worked with a community group in my neighborhood and with the City of Cleveland to promote audible signals being installed at two very treacherous intersections. We considered whether such devices were needed at other intersections, some of which are very busy ones, and determined that special signals were not required as the traffic patterns were predictable. I would hate to see money wasted by putting such signaling systems everywhere!
Cheryl Fischer
Mark Richert, October 28, 2002
Attached for the Board's consideration are the comments of the Association for Education and Rehabilitation of the Blind and Visually Impaired (AER). These comments were prepared after long and thoughtful scrutiny by members of AER's Orientation and Mobility Division. Please direct requests for further information to Janet M. Barlow [...]
AER and its members appreciate the opportunity to submit these comments and commend the Access Board for its diligence in addressing these pressing issues.
Sincerely,
Mark Richert
Executive Director
Association for Education and Rehabilitation of the Blind and Visually Impaired
Alexandria, VA
Contact: Janet M. Barlow
SUBJECT: Draft Guidelines for Accessible Public Rights-of-Way (June 17, 2002)
The Association for the Education and Rehabilitation of the Blind and Visually Impaired (AER) is an international membership organization of approximately 4600 professionals. Its mission is "to develop and promote professional excellence through support of those who provide education and rehabilitation services to people with visual impairments". The Orientation and Mobility Division of AER represents over 1000 orientation and mobility specialists, individuals who teach independent travel skills to persons who are blind or visually impaired. Certified Orientation and Mobility Specialists (COMS) are graduates of specialized college degree programs in education and/or rehabilitation. The following information and recommendations have been developed by the members of the Environmental Access Committee of AER's Orientation and Mobility Division.
We are delighted that guidelines for the public rights-of-way are now being developed that will address the needs of pedestrians who are blind or visually impaired. Following these recommendations is a resolution passed at the AER conference this summer in support of these guidelines. The transportation and public works community needs guidelines and specific direction to provide facilities that are accessible to pedestrians who are visually impaired or blind.
We are particularly pleased that specifications for detectable warnings and accessible pedestrian signals have been included. As representatives of a profession that has taught travel skills to individuals who are blind over the past 50 years, we recognize the evolution of intersection design and traffic control that now necessitates some of the modifications and accommodations that these guidelines require. Comparing a photo of an intersection in the 1960's with a photo of a current intersection makes it clear that the tasks and issues have changed. While individuals who are blind do cross streets without accessible pedestrian signals and do manage to locate the street edge without detectable warnings, these two tasks, in particular, have become much more difficult, and sometimes impossible, in the past twenty years due to changes in intersection design and signalization.
We strongly support the draft guidelines. The implementation of the draft recommendations on Accessible Pedestrian Signals (APS) and the resultant improvement in predictability and accessibility will go a long way towards insuring that the pedestrian environment remains accessible into the future. Please note in our comments, however, that we recommend that the Access Board add additional language specifying types of intersections where APS should be installed. In addition, we recommend some wording changes in the section on walk messages and suggest a more precise requirement for pole location than that in the PROWAAC report or the MUTCD. We feel that in new construction a tighter specification is possible, and necessary, to make the interface as unambiguous and quiet as possible.
Many who have provided comments seem to be misinformed regarding the types of APS recommended in these guidelines. Their comments and objections to "screeching signals" and "bird calls" indicate that they are unaware of the new types of signals recommended by PROWAAC and these draft guidelines. While many NFB members are expressing opposition to 'beeping signals' on every corner, the Access Board may wish to review articles by NFB President Mark Mauer in which he discusses signals in Australia and Sweden favorably ("World Blind Union Fifth General Assembly" The Braille Monitor, Vol. 44, No.3, March 2001 and "Blindness, Travel, the Environment, and Technology", The Braille Monitor, Vol. 42, No. 9, November, 1999, posted at www.nfb.org). The signals in Australia and Sweden include locator tones and audible and vibrotactile walk indications, installed close to each crosswalk location. This type of signal is exactly what these draft guidelines are calling for.
We have provided our response to the Board's question regarding detectable warnings in the section of these comments regarding the 'Discussion of Provisions'. We have also provided a response to the questions on roundabouts later in these comments. Many specific wording changes and the rationale for the suggested change are included later in this letter as well.
While the Board did not ask for specific comment on the issue of 'directionality' of curb ramps, we urge consideration of issues expressed in the PROWAAC discussions and research to develop solutions. Pedestrians who are blind or visually impaired try to avoid using the slope of the curb ramp as a cue to the direction of the crossing. However, it is difficult to avoid traveling and aligning in the direction of the slope. The detectable warning, as specified, is not an alignment cue, but a 'stop' indication.
The provision of additional alignment information at some types of curb ramps and blended transitions, particularly where the ramp is not aligned with the crosswalk direction, is needed. In addition, the PROWAAC committee was unable to agree on a specification for a tactile cue in the sidewalk to indicate the location of midblock crossings and roundabout crossing to pedestrians who are blind or visually impaired. Research is needed to identify solutions and address concerns of persons with mobility impairments as well as the needs of individuals who are blind or visually impaired. This research should evaluate the ability of pedestrians who are blind or visually impaired to detect and align with various surfaces, such as the bar tiles used in Europe and Japan, line tiles sold by US manufacturers, and other possible alignment surfaces, as well as the ability of wheelchair users and those with mobility impairments to navigate over and around such surfaces.
The Access Board should move as quickly as possible to implement this draft as a rule. Some in the transportation industry may urge waiting for the completion of additional research. Travelers who are blind or visually impaired are required to use the sidewalks and street crossings in their daily travel, usually in conjunction with the use of public transportation. They are at risk in traveling, due to the lack of consideration in current intersection and sidewalk designs. As additional research is completed, it can be incorporated into designs and provisions. These guidelines need to be completed and published as a final rule.
We encourage your consideration of the following specific comments as rulemaking process continues:
DISCUSSION OF PROVISIONS
Detectable Warning
The Board asks for response on a question regarding installation of detectable warnings only on curb ramps with a slope of 1:15
RESPONSE: We support the requirement for detectable warnings on ALL ramps and sidewalk/street transitions leading to crosswalks, regardless of slope. AER resolutions 98-01 and 94-08, supporting this requirement, follow.
Rationale: Two studies confirmed that removal of the curb was problematic for travelers who are blind. Barlow and Bentzen, found that 39% of blind travelers did not detect the street and stop when they approached the crosswalk on a curb ramp. Repeating their analysis using only the ramps that met ADA requirements at that time, (those that had a slope of 1:12
Roundabouts
We applaud the Board's strong stance on signalization of roundabout crossings. We expect that there are alternative solutions to provide accessibility, however, roundabout proponents have been slow to respond to concerns of pedestrians with disabilities. Proponents of roundabouts often quote the reduction in crashes as support for the safety of the installations. Crash data do not tell the whole story; there is little or no information on pedestrian avoidance of roundabout locations. Anecdotal information from Europe and Australia, as well as from US installations, indicates that pedestrians who are blind or visually impaired avoid crossing at roundabouts.
While there is ongoing research on the challenges for pedestrians who are blind or visually impaired and potential solutions, there is a need to slow the proliferation of inaccessible roundabouts in the United States. We believe that traffic engineers and designers who desire to solve this problem can do so, however, the will did not seem to be present until the draft guideline was published which required their attention to the issue. Many designers and governments who are complaining about the problems of signalization seem unable to consider pedestrian signals that function differently than those that have traditionally been installed in the US, as considered by the PROWAAC and the Access Board. The experience of England and other countries with signalization of pedestrian crossings at roundabouts should be considered.
Designers who develop better solutions can always install solutions that provide better accessibility, in full compliance with guidelines. We urge the Board to continue to require signalization of the pedestrian crossings.
1101.3 DEFINED TERMS
Detectable warning
ADD: standardized
Detectable Warning. A standardized surface feature built in or applied to walking surfaces or other elements to warn of hazards on a circulation path.
Rationale: Those reading the definition need to understand that the surface of the detectable warning is specified in ADAAG and that various textured surfaces may not meet the requirements of a detectable warning.
Locator tone:
CHANGE to: Pushbutton Locator Tone?a repeating sound that informs approaching pedestrians that they are required to push a button to actuate pedestrian timing and that enables pedestrians who have visual disabilities to locate the pushbutton.
Rationale: The above definition is the definition and term used in the MUTCD.
1102. SCOPING
1102.5.2 Protruding objects
1102.5.2 Post-Mounted Objects.
ADD: Where a sign or other obstruction is mounted between posts or pylons and the clear distance between post or pylons is greater than 12 inches
Rationale: We are delighted with the reduction of distance that objects can protrude from posts. This will eliminate many hazards in the sidewalk area. Pedestrians who are blind or visually impaired may travel on any part of the public sidewalk and are not limited to the pedestrian access route, a fact which many designers do not seem to understand.
The sentence regarding posts and pylons seemed to be missing a section regarding the distance between posts and pylons. In addition, we encourage the addition of the requirement for a lower bar on such signs. Signs between poles, and railings with their leading edges higher than 15 inches
The three principal cane techniques are: 1) the touch technique, where the cane is lifted slightly off the ground and moved in an arc from side-to-side and touches the ground at points outside both shoulders; 2) the constant contact technique, where the cane is slid from side-to-side in a path extending just beyond both shoulders; and 3) the diagonal technique, where the cane is held in a stationary position diagonally across the body with the tip just above the ground at a point outside one shoulder and the handle extended to a point outside the other shoulder. When one of these techniques is used and the element is in the detectable range, it gives a person of average adult stature, who uses proficient technique with a long cane, sufficient time to detect the element with the cane before there is body contact. The typical cane techniques do not locate objects extending into the travel path above the hips. For persons of short stature, including children, simple geometry indicates that they will be unlikely to detect objects with a long cane before contacting them with the body when the leading edge is as high as 27 inches
1102.7.1 Bus Route Identification. Exception 2
ADD: If portable receivers are required to access the signs, receivers must be freely distributed persons with disabilities who cannot read print signs.
Rationale: Allowing such an exception does not provide accessible information unless there is a concomitant requirement to distribute the receivers to those who may wish to access the information.
1102.8 Pedestrian crossings
CHANGE TO: Where a pedestrian crossing is provided, it shall comply with the applicable provisions of 1105. Where pedestrian signals are provided at a pedestrian crossing, where pedestrian signal timing is actuated by pedestrian detectors (pushbuttons) or by passive pedestrian detection, or where leading pedestrian intervals or exclusive pedestrian phasing is used, pedestrian signals shall comply with 1106.
Rationale: The draft language does not require accessible information to be provided at intersections unless pedestrian signals are installed. The Manual on Uniform Traffic Control Devices (MUTCD) only requires (using 'shall' language) the installation of pedestrian signals at limited locations, such as school zones, crossings where a signal is installed due to high pedestrian volumes, and where there is exclusive pedestrian phasing. Other locations are discussed in 'should' language. We are concerned that this rule may encourage traffic engineers to limit the installation of pedestrian signals, in order to avoid installing accessible pedestrian signals. In the MUTCD, pedestrian signals are not required at some locations because the vehicular signal can be considered adequate, under provisions in the MUTCD, to provide information to pedestrians. Under the current draft guidelines, therefore, there would be no imperative to make the "green ball" information accessible. These locations may not provide adequate information for pedestrians who are blind without installation of accessible pedestrian signals.
The locations suggested above and in the PROWAAC report are ones at which the signal features make it hard to detect the pedestrian crossing phase without provision of accessible information. Locations such as those are known to be problematic for pedestrians who are blind or visually impaired. In addition, there may be other locations where the traffic movement does not provide sufficient information for pedestrians who are blind or visually impaired.
We are unable at this time to suggest language that will cover all possible situations in which accessible information may be needed by an individual pedestrian who is blind. Therefore we recommend that at signalized intersections in new construction where pedestrian facilities such as sidewalks are provided but pedestrian signalization is not, that conduit piping be installed in relation to the curb ramps such that a retrofit with APS if required could be easily accomplished.
As we stated previously, many who have provided comments seem to be misinformed regarding the types of APS recommended in these guidelines as well as the types of intersection signalization typically used now. (see our opening comments). Most newly installed intersections will be traffic actuated and will have complex traffic patterns. Pedestrian actuated traffic signals change with each cycle and usually require the pedestrian to push a button to get enough time in the cycle to cross the street. As well, the vehicular patterns and pedestrian timing may vary, depending on the signal timing plan of the intersection. The pedestrian timing may be concurrent with the traffic moving parallel to the pedestrian's path, or at a totally different time in the cycle. Pedestrians who misjudge the starting traffic pattern may find themselves in the street when cars are moving perpendicular to their path with a 'green arrow'. These changes have resulted in our advocacy for Accessible Pedestrian Signals to provide individuals who are blind or visually impaired with the signal information provided to persons who are sighted.
At the public information meeting in Portland, APS device costs of $4000 per device were suggested by some individual commenters. These estimates are incorrect. The cost of a pushbutton integrated APS, such as referred to in the draft guidelines, is currently approximately $400. per device. As with many items, that estimate may be reduced with quantity purchasing.
1102.10 Stairs
We agree with this addition that will make stairs in the public rights-of-way more visible to all pedestrians. We suggest a slight revision in the language.
DELETE: 'of color'
INSERT: "contrasting with the tread and riser, dark on light or light on dark,"
1102.10 Stairs. Where provided, stairs shall comply with 504. Stair treads shall have a 2 inch
Rationale: Light/dark contrast is the important feature, not color or hue.
1104 CURB RAMPS AND BLENDED TRANSITIONS
1104.3 Common Elements
MOVE: 1104.3 Common elements to 1104.2 and Types to 1104.3
Rationale: The common elements need to be more clearly described before the details of the various types of ramps. In addition, blended transitions may need additional language to clarify that a raised intersection or raised crosswalk could provide a blended transition.
1104.2.1 Perpendicular curb ramps.
ADD: Where possible, the slope of the curb ramp shall be aligned with the sidewalk and crosswalk direction.
Rationale: The orientation of curb ramps toward the intersection can be disorienting for travelers who are blind or visually impaired. In addition, they require an extra turn for wheelchair users. We believe that the guidelines need to encourage orientation of the ramp in the direction of travel on the crosswalk.
PROWAAC debated at great length on the issue of curb ramp orientation. While travelers who are blind or visually impaired do not use the slope of the ramp to determine their crossing alignment, it is difficult to prevent the slope from influencing travel direction. Advocates for pedestrians with visual impairments recognize the safety issues for wheelchair users of warping at the gutter/ramp intersection, however, whenever possible, the slope of the ramp should be aligned with the crosswalk and the grade break should be aligned perpendicular to the crosswalk alignment. The language of the guidelines needs to state that and encourage two ramps more strongly.
1105 PEDESTRIAN CROSSINGS
1105.4.2 Medians and Pedestrian Refuge Islands - Detectable Warnings
DELETE: Exception
Rationale: Detectable warnings inform the pedestrian who is blind or visually impaired about the presence of a cut-through island or median. They should be required at all medians and islands. Although the pedestrian may not need to stop at that location when the signal timing is adequate for a full crossing, slower pedestrians may prefer to stop and wait, if they know the refuge exists. In the absence of an APS, blind pedestrians frequently begin crossing during the clearance interval because of the difficulty of determining the exact onset of the walk interval, and the resulting inability to "claim" the crosswalk before vehicles turning across the crosswalk. Hence, they may have insufficient time to cross the street. Denying them the information that they have a safe refuge constitutes discrimination and endangers the life safety of pedestrians who are blind in such situations. Even in the presence of APS, because they are unable to make eye contact with drivers, pedestrians with visual impairments have difficulty claiming the crosswalk during the walk interval, and may be delayed in starting crossings relative to sighted pedestrians.
In addition, contacting the side edge unexpectedly when traveling within the cut-through section of the median can be disorienting and confusing if pedestrians do not realize they are within a median area. The detectable warning provides the pedestrian with information about the location of the cut-through refuge area.
1105.6 Roundabouts
1105.6.1 Separation
CHANGE TO: Continuous barriers landscaping separation or railings shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited. When railings are used, they shall have a bottom rail 15 inches
Rationale: Use of the word barriers is confusing. Landscaping can be an appropriate guide to guide individuals to the crosswalk location, instead of a barrier or guardrail.
1105.6.2 Signals
We urge the Board to keep this language and requirement for signals at each crossing of roundabouts. See previous comments in answer to the question in the Preamble.
1105.7 Turn lanes at Intersections
We also applaud the inclusion of pedestrian activated signals at these locations, which have been problematic for pedestrians who are blind for years.
1106. ACCESSIBLE PEDESTRIAN SIGNAL SYSTEMS
1106. 1 General.
We recommend the use of the term "Accessible Pedestrian Signal (APS)", rather than Signal Systems or Pedestrian Signal Devices in this text to more closely conform to the MUTCD language and typical current terminology.
Rationale: The Board has introduced new language in these guidelines that does not match with language typically used in either the traffic engineering or the orientation and mobility professions. 'Signal system' is a defined term in the MUTCD ("Signal System - two or more traffic control signals operating in signal coordination"). 'Signal system' is not used with that meaning in these guidelines. It is important that engineers and those who are familiar with the MUTCD understand these guidelines properly.
1106.2 Pedestrian Signals.
CHANGE: Each crosswalk with pedestrian signal indication, or where pedestrian signal timing is actuated by pedestrian detectors (pushbuttons) or by passive pedestrian detection, or where a leading pedestrian interval or exclusive pedestrian phasing is used, shall have a signal device an Accessible Pedestrian Signal which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device Accessible Pedestrian Signal and shall comply with 1106.3.
Rationale: As stated earlier in our discussion of scoping, 1102.8, pedestrian signals are not required at some locations because the vehicular signal can be considered adequate, under provisions in the MUTCD, to provide information to pedestrians. These locations may not provide adequate information for pedestrians who are blind without installation of accessible pedestrian signals.
The term 'signal device' has a different meaning in the traffic engineering profession and may not be understood to mean a device that is commonly known as an Accessible Pedestrian Signal. There's no need to introduce confusion.
1106.3 Location.
CHANGE: Pedestrian signal devices Accessible Pedestrian Signals shall be located 60 inches
Rationale: In new construction, the location for the APS can and should be restrictive and consistent. The 'box' in the MUTCD was developed in consideration of retrofit situations and local practice; it is a large area 10 feet
The requirement of location more than 30 inches
1106.2.3 Audible Walk Indication
CHANGE: The audible indication of the WALK interval shall be by voice speech message or tone.
Rationale: The use of the term 'speech message' is more accurate. We are concerned that use of 'voice' will be considered to require the recording of human voice messages. Some methods of digital speech may provide more consistent messaging than individual recordings. Currently, AT&T provides text to speech messaging capabilities on the web and in commercially available software. (http://www.naturalvoices.att.com/demos/index.html)
1106.2.3.1 Tones.
CHANGE: Tones shall consist of multiple frequencies with a dominant component at 880 Hz. The duration of the tone shall be 0.15 seconds
Rationale: The current wording of the duration and repetition rate could be understood to indicate a continuous tone. We assume that the Board intended to require a tone such as is used in the Swedish or Australian signals. These repeat at rates of around 7 to 10 repetitions per second with short bursts of sound, with silence between tones of around 50 milliseconds. A repetition rate of 0.15 seconds
1106.2. Speech WALK Messages.
ADD A NEW SECTION
ADD: 1106.2._ Speech WALK Messages.
ADD: 1106.2. WALK signals may be in the form of speech messages.
1106.2._._ Speech WALK messages shall contain the words "WALK SIGN."
1106.2._._ Speech WALK messages shall repeat throughout the WALK interval or be combined with a repeating WALK tone.
Exception: Speech messages may be limited to a maximum of seven seconds in duration where pedestrian signals rest in WALK.
1106.2._._ At intersections having concurrent pedestrian phasing, speech messages shall follow the model: "Howard. Walk sign is on to cross Howard." Designation of "street, "avenue," etc. shall be used whenever its omission could lead to ambiguity.
Rationale: The language of speech walk messages must be consistent and these guidelines should repeat at least the same specifications as in the MUCTD. The MUTCD specifies that speech WALK messages should say 'Walk sign', in order to provide information about the status of the walk indication without providing a command, such as 'walk now'. Accessible Design for the Blind completed a survey of pedestrians who are blind, traffic engineers and orientation and mobility specialists last year and developed recommendations for speech WALK messages, as well as pushbutton informational messages. The recommended wording for WALK messages was "Howard. Walk sign is on to cross Howard."
In the US, speech WALK messages are commonly used in newer accessible pedestrian signal installations. All of the pushbutton-integrated devices on the market in the US are capable of providing speech messages. Speech WALK messages are not necessary to providing unambiguous information regarding which crosswalk has the WALK interval, provided that pushbuttons are installed in the locations specified, and they will be unintelligible to some users in some ambient noise conditions. However, speech walk signals are perceived as being more user-friendly than tonal WALK signals. Good installation has a number of requirements.
Speech WALK messages should continue to repeat throughout the WALK interval, or be combined with a WALK tone for the balance of the WALK interval so that pedestrians with visual impairments will know when the WALK interval ends, they will be aware of its full duration, and be able to initiate street crossings in knowledge of the status of the pedestrian signal. Combination of a speech WALK signal with a tone signal may have some of the advantages of both. It should be clear that this is permitted.
At many intersections of an arterial with a minor street, the pedestrian signal on the minor street "rests in WALK" during the vehicular green of the arterial, until a pedestrian or vehicle actuates the signal to enter or cross the arterial. WALK signals that sound continuously during what is sometimes a walk interval some minutes long will be particularly objectionable in neighborhoods. Most of the pushbutton-integrated APS have means to limit the WALK signal to a certain number of seconds. Pedestrians may be able to actuate the audible WALK signal multiple times during the same (rest-in-)WALK interval.
1106.2.3.2 Volume
ADD: Exception: When special activation is used to provide audible beaconing, the volume may exceed 5dB above ambient noise level.
Rationale: Special activation of louder signals may be useful in some situations to provide beaconing. If it is provided by special activation, such as a long press of the pushbutton, as suggested by PROWAAC and provided by several US manufacturers of APS, the louder signal will only sound when someone requests such a feature. Allowing a volume increase in response to special activation will provide some flexibility as these features develop in response to needs and as research continues on these issues.
Additional speakers mounted at pedhead might be found to provide directional information to pedestrians who are blind or visually impaired; we do not want these guidelines to prevent further evaluation of that option.
1106.2.3.3 Duration
ADD: WALK tones shall repeat throughout the WALK interval.
Exception: WALK tones may be limited to a maximum of seven seconds in duration where pedestrian signals rest in WALK.
Rationale: At many intersections of an arterial with a minor street, the pedestrian signal on the minor street "rests in WALK" during the vehicular green of the arterial, until a pedestrian or vehicle actuates the signal to enter or cross the arterial. WALK signals that sound continuously during a walk interval that is often several minutes long will be particularly objectionable in neighborhoods. Most of the pushbutton-integrated APS have means to limit the WALK signal to a certain number of seconds. Pedestrians can actuate the audible WALK signal multiple times during the same rest-in-WALK interval, if needed.
1106.3.2 Pushbutton Locator Tone.
ADD: Exception: When special activation is used to provide audible beaconing, the volume of the locator tone for the succeeding clearance interval may exceed 5dB above ambient noise level
Rationale: When special actuation of louder signals is used to provide beaconing, having the loudness of the pushbutton locator tone increased for the remainder of the pedestrian phase is essential to enabling those who need this assistance to home in on the opposite corner while they are still in the middle of the crossing.
1107.4 Arrow
ADD: more specific information on contrast
1106.4.Arrow. Signs shall include a tactile arrow aligned parallel to the crosswalk direction. The arrow shall be raised 1/32 (0.8 mm) minimum and shall be 1-1/2 inches
Rationale: Contrast in hue may not be perceptible but light/dark will be perceptible for most who use visual information.
1106.4.2 Street name
CHANGE TO READ: Accessible pedestrian signals shall include street name information aligned parallel to the crosswalk direction and complying with 703.3, or shall provide street name information in audible format.
Rationale: Street name information provided in audible format will be usable by more individuals than street name information provided in tactile format.
Providing street name information in tactile characters will result in signs that are very large. Most persons who read by touch read Braille. If there is a requirement for tactile street name information, it is more reasonable to require Braille information than tactile characters. It will serve those who will use it better, and require smaller, less expensive signs.
1108. DETECTABLE WARNINGS
1108.1.2 Size
CHANGE Add a maximum depth:
1108.1.4 Size. Detectable warning surfaces shall extend 24 inches
Rationale: We assume the Board did not establish a maximum depth of detectable warning because there is some research evidence that deeper warnings are more detectable. However, while research by Bentzen and others consistently found that blind persons more reliably detected detectable warnings at 30 inches
Failure to specify a maximum depth could result in continued installation of detectable warnings on the full surface of curb ramps. Installing such large areas of detectable warning surfaces as entire curb ramps provides less precise information to blind pedestrians than installing a smaller amount in a very predictable location. In addition, larger depth may result in increased expense and greater possible adverse impact on persons with mobility impairments.
1108.2.1 Curb Ramps and Blended Transitions
ADD EXCEPTION:
Exception: At cut-through islands and medians, the detectable warning may be located so that the edge nearest the crosswalk is at the curb line.
Rationale: The PROWAAC recommendation that detectable warnings be 6-8 inches
However, requiring that detectable warnings be 6-8 inches
1108.2.2 Rail Crossings
ADD EXCEPTION.
Exception: Where automatic gates across pedestrian ways bar pedestrian access to the crossing when rail vehicles are approaching or at a crossing, the detectable warning surface shall be located to the side of the automatic gate farthest from the crossing.
Rationale: Automatic gates can cause serious head injury to blind pedestrians approaching crossings. There is currently no reliable way for pedestrians who are blind to be notified of the location of automatic gates. Gate support is typically outside the normal pedestrian route and not likely to be encountered by blind pedestrians. Where there is a gate, a blind pedestrian may become trapped between the gate and the crossing, with the gate barring the way for the blind pedestrian to move farther away from the crossing.
Thank you for opportunity to comment. It is important that the needs of pedestrians, including those who are visually impaired or blind, are considered in the ADA guidelines.
Following: AER Resolutions
Resolution 2002 - 05
WHEREAS people with disabilities and in particular those who are blind or visually impaired have difficulties negotiating Public Rights of Way in the United States and in Canada; and
WHEREAS, in the United States, the Architectural and Transportation Barriers Compliance Board (Access Board) has developed draft design guidelines to ensure that access for persons with disabilities is provided wherever a pedestrian way is newly built or altered, and to insure that the same degree of convenience, connection, and safety afforded the public generally is available to pedestrians with disabilities; and
WHEREAS street crossings at signalized intersections are often inaccessible to pedestrians with vision impairments; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for
accessible pedestrian signals at all crosswalks with pedestrian signal
information, and guidelines to make all pedestrian pushbuttons accessible; and
WHEREAS in Canada, recommendations for revised standards for accessible
pedestrian signals and accessible pedestrian pushbuttons are currently being developed by the Canadian National Committee on Accessible Pedestrian Signals; and
WHEREAS where boundaries between pedestrian and vehicular ways are not
reliably detectable to pedestrians with vision impairments, these
pedestrians may be unaware when they move from the pedestrian way into the vehicular way; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for defining the boundary between the pedestrian way and the vehicular way by the use of truncated dome detectable warnings where curb ramps, landings and blended transitions connect to crosswalks, and at cut-through medians and islands, and at level rail crossings in the pedestrian way; and
WHEREAS crossings at roundabouts and slip lanes are often inaccessible to pedestrians with vision impairments because of difficulties inherent in determining safe crossing times based on acoustic information, and because of difficulties in locating crosswalks; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for
accessible pedestrian signals for each segment of each crosswalk, and
barriers where crossing is not permitted; and
WHEREAS pedestrians with vision impairments are at an equally great risk from objects protruding from poles and from walls; and
WHEREAS the U.S. Access Board has therefore proposed guidelines in which the amount by which objects may protrude from both poles and from walls is four inches; and
WHEREAS temporary circulation paths are independently usable by persons with vision impairments only if they know about them, and temporary barriers that are not detectable by the use of a long cane do not adequately protect pedestrians with vision impairments, or channelize them along an alternate route if they are not readily detectable by the use of a long cane; and
WHEREAS the U.S. Access Board has therefore proposed guidelines for signs, and guidelines for barricades that are readily detectable by persons traveling with the aid of a long cane; and
WHEREAS persons with low vision are at particular risk of falling at stairs because of inability to visually determine the depth of tread and height of riser; and
WHEREAS the U.S. Access Board has therefore proposed a guideline for
contrasting color along the nosings of stairs, that will increase the
perceptibility of tread depth and riser height;
Therefore be it resolved that on this 21st day of July, 2002, in the city of Toronto, Ontario, that the Association for Education and Rehabilitation of the Blind and Visually Impaired (AER) commends the Access Board for attending carefully to the unique access needs of persons with vision impairments in the preparation of the Draft Guidelines for Accessible Public Rights-of-Way.
Be it further resolved that AER urges the U.S. Federal Highway Administration to bring the Manual on Uniform Traffic Control Devices into harmony with the Draft Guidelines for Accessible Public Rights-of-Way.
Be it further resolved that the AER urges the Transportation Association of Canada to incorporate the recommendations of the Canadian National Committee on Accessible Pedestrian Signals into the Canadian Manual of Uniform Traffic Control Devices.
Be it further resolved that the AER urges the Canadian Standards Association to consider harmonizing Canadian standards with the recommendations in the U.S. Draft Guidelines for Accessible Public Rights-of-Way concerning detectable warnings, protruding objects, temporary circulation paths, roundabouts and stair nosings.
RESOLUTION 94-08
WHEREAS professionals in Orientation and Mobility have observed that when visually impaired pedestrians approach streets at curb ramps they are at risk of walking unaware into the path of moving traffic, since there is no clearly defined distinction at curb ramps between the roadway and sidewalk; and
WHEREAS research has now been conducted which confirms that for persons who are visually impaired, there is a high level of risk of inadvertent street entry associated with the presence of curb ramps, particularly those having slopes of 1:12
WHEREAS it has been demonstrated that detectable warnings complying with ADAAG 4.29.2 are highly detectable by persons with visual impairments, and can provide an effective stop signal for persons who are blind or visually impaired which can be used to determine the end of the sidewalk and the beginning of the vehicular way; and
WHEREAS research has now been conducted which addresses concerns about safety of detectable warnings, indicating that detectable warnings on slopes have minimal impact on the safety and ease of travel for persons having physical disabilities (Bentzen, et al. 1994); and
WHEREAS research has demonstrated that 24 inches
WHEREAS consistency in dimensions and placement of detectable warnings is of critical importance in successful interpretation by the user in varied settings;
THEREFORE BE IT RESOLVED on this 13th day of July, 1994, in the city of Dallas, Texas, that AER urges the Architectural and Transportation Barriers Compliance Board (Access Board) to issue a rule requiring a 24 inch
BE IT FURTHER RESOLVED that AER urges the Access Board to issue a rule requiring a similar 24 inch
Resolution 98-01
WHEREAS Orientation and Mobility Specialists have observed that when visually impaired pedestrians approach streets at curb ramps they are at risk of walking unaware into the path of moving traffic, since there is no clearly defined distinction at curb ramps between the roadway and sidewalk; and
WHEREAS research has now been conducted which confirms that for persons who are visually impaired there is a high level of risk of inadvertent street entry associated with the presence of curb ramps, particularly those having slopes of 1:12
WHEREAS it has been demonstrated that detectable warnings complying with ADAAG 4.29.2 are highly detectable by persons with visual impairments, and can provide an effective stop signal for persons who are blind or visually impaired which can be used to determine the end of the sidewalk and the beginning of the vehicular way; and
WHEREAS research has now been conducted which addresses concerns about safety of detectable warnings, indicating that detectable warning on slopes have minimal impact on the safety and ease of travel for persons having physical disabilities (Bentzen, B., Nolin, T., Easton, R., Desmaris, P., and Mitchell, P., 1994; Hauger, et al, 1996); and
WHEREAS research has demonstrated that 24 inches
WHEREAS it was the nearly unanimous recommendation of the workshop on curb ramps and detectable warnings sponsored by the U.S. Access Board and Project ACTION in January, 1995, that no additional research was needed on detectable warnings at curb ramps and that a detectable warning should forthwith be required on the full width of curb ramps beginning at the curb line and extending back 24"; and
WHEREAS numerous municipalities in the United States have installed detectable warnings on curb ramps and have reported no instances in which safety has been compromised by the presence of detectable warnings on curb ramps;
THEREFORE BE IT RESOLVED on this 12th day of July, 1998, in Atlanta, Georgia that AER urges the U.S. Access Board to provide specific opportunity for public comment on detectable warnings at curb ramps and hazardous vehicular ways when the notice of proposed rulemaking for the revised ADA Accessibility Guidelines is published.
BE IT FURTHER RESOLVED that AER continues to strongly advocate the provision of a 24" wide detectable warning surface at the bottom of curb ramps and at hazardous vehicular ways, particularly where those hazardous vehicular ways are blended curbs or raised crossings at intersections.(See AER Resolution 94-08).
BE IT FURTHER RESOLVED that AER urges Transport Canada to require a 24" wide detectable warning surface at the bottom of curb ramps and at hazardous vehicular ways, particularly where those hazardous vehicular ways are blended curbs or raised crossings at intersections.
Resolution 98-02
WHEREAS the Americans with Disabilities Act guarantees the right of access to information to persons with disabilities; and
WHEREAS many signalized intersections provide information to pedestrians with sight which is not provided to pedestrians with visual impairments; and
WHEREAS it has been demonstrated ( Crandall, W., Bentzen, B.L., and Myers, L., 1998) that competent, independent, blind pedestrians at unfamiliar signalized intersections may initiate as many or more than 34% of crossings during the clearance or DON'T WALK intervals if those intersections are not equipped with accessible pedestrian signals; and
WHEREAS accessible pedestrian signals have been widely used for more than 10 years in countries including Australia, Japan, Sweden, and the United Kingdom and are considered by traffic engineers to be widely effective not only in providing information to blind pedestrians but also in decreasing general pedestrian delay and facilitating vehicular flow at signalized intersections; and
WHEREAS increasing numbers of quiet vehicles, including electric vehicles and those with quiet internal combustion engines, make acoustic information from vehicles inconsistent, resulting in the inability of pedestrians who are blind to reliably detect the onset of the WALK interval by listening for a surge of vehicles; and
WHEREAS inexpensive technologies exist to make Accessible Pedestrian Signals which are automatically responsive to ambient sound , being very quiet at night and in low traffic situations, while still loud enough to be heard above vehicular sound in high traffic situations; and
WHEREAS accessible vibrotactile and speech transmission signal systems exist which add no noise to the environment; and
WHEREAS the Transportation Equity Act for the 21st Century provides that "Transportation plans and projects . . . shall include the installation, where appropriate, and maintenance of audible traffic signals and audible signs at street crossings;"
THEREFORE BE IT RESOLVED on this 12th day of July, 1998, in Atlanta, Georgia that AER urges the U.S. Federal Highway Administration and Transport Canada to develop recommended practices for installation of pedestrian signals which make information which is regularly provided to other pedestrians, accessible to pedestrians who are visually impaired, including but not limited to: information specifying WALK and DON'T WALK intervals; information indicating the presence and location of push-buttons; and information unambiguously indicating the street to which the signal applies.
Resolution 98-03
WHEREAS traffic engineers are increasingly utilizing signal systems in which the only safe time to cross signalized intersections is provided in response to pedestrian use of a push button; and
WHEREAS persons who are visually impaired consistently identify location of the push button as the major problem they experience at pedestrian actuated intersections (American Council of the Blind survey, 1998; City of San Diego, Department of Transportation, 1994; and Tauchi, M., Sawai, H., Takato, J., Yoshiura, T., and Takaeuchi, K., 1998 ); and
WHEREAS persons who are visually impaired often have insufficient time when pedestrian push buttons are far from associated crosswalks, to actuate push buttons and then prepare to cross before the onset of the WALK interval (American Council of the Blind survey, 1998); and
WHEREAS unobtrusive technologies exist for providing information in accessible format, specifying the presence and location of push buttons;
THEREFORE BE IT RESOLVED that AER urges the U.S. Federal Highway Administration and Transport Canada to develop standards for push button location technology such as quiet audible locator tones, and to require the placement of newly installed pedestrian push buttons in close proximity to the top landing of the curb ramp serving that crossing, within accessible reach range for use from a wheelchair, and near enough to the curb line that persons with visual impairments can actuate the push button and then align and prepare for crossing before the onset of the WALK interval.
RESOLUTION 2000-05
WHEREAS there are roundabouts in many states in the United States, and many more are proposed or under construction; and
WHEREAS roundabouts have been shown to reduce the rate of serious personal injury crashes to drivers and passengers relative to similar signalized intersections, and thus have demonstrated their usefulness as an option for intersection design; and
WHEREAS despite the benefits to motorists, recent research at roundabouts in the U.S. indicates that blind pedestrians have difficulty at some roundabouts in determining appropriate times to begin crossing, and also may have difficulty locating crosswalks, aligning to cross the street, and maintaining their heading while crossing; and
WHEREAS focus groups of blind pedestrians conducted by U.S. researchers in the United Kingdom and France reported that the many roundabouts in those countries caused serious access problems for pedestrians who are blind or visually impaired; and
WHEREAS persons with blindness or visual impairments have the right to full access to public rights of way, including roundabouts;
NOW THEREFORE BE IT RESOLVED, this 19th day of July, 2000 in
BE IT FURTHER RESOLVED that, as research identifies best practices concerning roundabouts and blind pedestrians, these practices be implemented by traffic engineers and planners, and included in all U.S. and Canadian design manuals covering roundabouts.
Unanimously Approved
Dwight Kingsbury, Ph.D., October 28, 2002
Comment on Draft Guidelines for Accessible Public Rights-of-Way, published in the Federal Register, 17 June 2002.
As a pedestrian safety analyst, I support the goals of this effort, but share the concerns expressed by others (e.g., AASHTO) that in some sections, the draft guidelines propose inflexible, "Gordian knot" criteria to the application of pedestrian crossing features that are more appropriately and effectively evaluated through the application of engineering judgment, in the light of the "Manual on Uniform Traffic Control Devices" and other engineering guidance documents.
Specifically, I am concerned about the following.
S. 1105.3 would require calculation of pedestrian signal phase timing using a pedestrian walking speed of 3.0 ft
S. 1105.5.3 would require installation of elevators where the rise of a ramped approach exceeds 60 inches
S. 1105.6.2 would require provision of a pedestrian activated signal at each segment of a roundabout crosswalk. Although pedestrians often expect they will have difficulty using such crosswalks, prior to construction, I have never heard of any pedestrian request for a signal at a signal-lane roundabout, after it has opened. Adoption of this requirement could result in a reduction of the use of marked crosswalks at roundabouts. I concur with AASHTO that this section should be reserved, pending completion of NCHRP Project 3-65, "Applying Roundabouts in the United States."
S. 1105.7 would required provision of a pedestrian activated signal where crosswalks are provided at right or left turn slip lanes. The problem is that, if the slip lane is designed to facilitate a high speed turn, and the signal is used infrequently, it will be ineffective; many drivers simply fail to heed signal indications they are not used to seeing. The failure of drivers to yield to pedestrians in slip lane crosswalks is better addressed through design, e.g., greater use of high-entry-angle slip lanes such as those used in Australia (cf. the Austroads "Guide to Traffic Engineering Practice," Part 5). Let us hope that NCHRP Project 3-72, "Lane Widths, Channelized Right Turns, and Right Turn Deceleration Lanes in Urban and Suburban Areas," will produce some useful recommendations for the pedestrian crossing problem at slip lanes.
S. 1106 would require all pedestrian signal systems to use audible and vibrotactile indications. In Florida, there have been differences among visually impaired pedestrians as to the usefulness of audible signal systems. Some blind persons believe these features are unnecessary, or create a false sense of security, or make it difficult to hear traffic (at least, if not installed properly). They must also be maintained. It is probably better to continue with the current practice of considering installation of such systems on request.
I also concur with AASHTO that the hard conversion of dimensions stated in US customary units into their SI equivalents lends itself to impractical inferences with respect to tolerances. Metric tolerances need to be clarified.
Dwight Kingsbury, Ph.D.
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
RoseAnn Faber, October 26, 2002
The purpose of this e-mail is to submit comments regarding proposed guidelines for the use of audible traffic signals and detectable warnings.
In most instances audible traffic signals are not needed.In fact they mayactually be hazardous.Audible traffic signals could produce a false sense of security for the blind pedestrian. The noise of such signals could interfere with the blind pedestrian's ability to hear traffic movement. The bottom line is to know what traffic is doing regardless of the status of the traffic light. Finally, if audible traffic signals were common place there is the potential that drivers would feel that they need to pay less attention to the presence of pedestrians.
Audible traffic signals should be considered for those intersections with complex layouts, complex signalization, or varied signalization for each lane. Vibrotactile indicators should be used in preference to audible signals in order to minimize noise distractions and better promote safety.
Locator tones should not be included in the final guidelines and may be subject to further research.
At most intersections the built environment provides enough accessible cues to determine the difference between the sidewalk and the street.
However, a slope of less than 1:15
warning.
Your consideration of my comments is appreciated.
RoseAnn Faber
Suzanne Westhaver, October 24, 2002
I strongly support audible traffic signals in high traffic crossing areas or in areas where traffic may be difficult to judge due to right turns on red, to-intersections with left turn indicators or right turn indicators, and similar situations, but do not feel that all crossings should be mandated to have these audible signals. The signals should only be added in the above described scenarios, taking into account the volume of traffic, right-of-ways, and the flow of traffic. In addition, the signal should not be obnoxiously loud or interfere with the visually impaired person's ability to hear the traffic. A subtle tone should indicate when it is safe to cross and should only sound when the pedestrian presses for a walk signal. In addition, intersections with audible signals should be clearly marked on the button so that the blind pedestrian knows the audible signal is available.
In addition, the current system of off-setting wheelchair ramps from corner curbs is very effective. Markers should only be necessary in areas with a slope of less than 1/15 in
Sincerely yours,
Suzanne Westhaver
To whom it may concern:
I am writing to ask you to reconsider passing a rule which would place accessible pedestrian signals at every lighted intersection in the country. The cost of such an operation is not only unnecessary, but also demands an exorbitant sum of money.
To date, there has been no research on accessible pedestrian signals which states their benefits. However, many of the negative consequences which will result from mass installation of these signals can be drawn from simple inference.
Accessible pedestrian signals are often equipped with a beeping locator tone so that the blind can find them with greater ease. However, the constant beeping of four separate signals on four separate corners of an intersection can be confusing to a traveler. Furthermore, the repeated tones produced by these devices often serve as a nuisance and an annoyance to the sighted public.
When a blind person crosses the street, he or she must listen to traffic patterns not only to determine when it is safe to cross, but also to determine of vehicles are turning in front of him or her. The chirps and tones produced by accessible pedestrian signals can often occlude the sounds of traffic, especially when large structures in the immediate area amplify the sound by means of echoes.
The truncated domes which are proposed to be placed on every corner in America will not always prove useful. In Nebraska, where I am from, the ground is frequently covered by snow and ice in Winter. When this occurs, the tactile warnings will be absolutely useless.
Again, I urge you to consider the factors which surround this situation, and I strongly urge you to withdraw this upcoming ruling. The blind do not need accessible pedestrian signals; they simply need training.
Cordially Yours,
Ryan Strunk
Joni Colver, September 22, 2002
Hello,
As a blind pedestrian I welcome audible traffic signals wherever I find them. The type I have used most often is the audible signal which is activated when a pedestrian presses a button for a "walk" signal. Having the audible beep gives me the same information audibly that a sighted pedestrian receives visually. A blind or sighted pedestrian still must check the traffic before crossing, but the audible signal is extremely valuable in this evaluation process.
Everyone involved in this issue has a right to his or her opinion. However, there is a core group speaking out against these signals and claiming to speak "for the blind." Believe me, they do not speak for me or most of the blind people I know. They do not have the right, in my opinion, to elevate their view to a higher level of consideration by claiming to speak for all blind people.
If the type of audible signal I mentioned above is used, no one should object to it because a person can choose to use it or not use it. It is an issue of freedom of choice and pedestrian safety. I hope that the board will adopt a reasonable position that enhances both of these areas.
Thank you for your time and consideration.
Sincerely,
Joni Colver
Antioch, Tennessee
I would like to comment on the proposed signalization rule for roundabouts (1105.6.2). I believe this rule is not sufficiently warranted and should be eliminated. Instead, proposed rule 1106 should be used to ensure that pedestrian signals, if otherwise provided, would be meet the needs of the disabled, and further research should be done to find other ways to improve roundabout safety for disabled pedestrians.
Proposed rule 1105.6.2, if enacted, may well end the use of roundabouts in the U.S. There is little reason to construct a traffic circle if you have to signalize anyway. I am not a professional roundabout advocate, but as a city planner with close to twenty years of working experience I know that there are important benefits to society that roundabouts can provide. Vehicles flow through roundabouts at a measured pace without idling at red lights. As the Board indicates, this reduces congestion, but it also reduces air pollution. Second, the high cost of traffic signal electricity and maintenance is eliminated. Third, roundabouts provide a center pubic space that can serve an aesthetic, historic, and/or civic function. Fourth, my understanding is that roundabouts can improve safety over traffic signals for certain types of traffic movements; certainly they calm traffic and reduce vehicle speeds.
I would note that properly designed roundabout crosswalks are no more inherently dangerous to pedestrians with disabilities than signalized intersections that allow right turns when left turns are also allowed from the other direction. The driver turning right may still be looking left to see if there is another vehicle with which to contend, and the right-turning driver thus may not be sufficiently aware of a pedestrian in the crosswalk of the street onto which s/he is turning. Nevertheless, completely shutting down a signalized intersection for pedestrian movements in many cases is seriously impractical. Therefore, the contention that roundabouts are more dangerous for disabled pedestrians is questionable.
Using the services of a traffic consultant, my community did install a roundabout at an intersection because it is an intersection with 5 legs and a traffic signal would not have made sense. We used the "Australian" treatment for the crosswalks which was to place them one car length behind each entrance to the roundabout so that pedestrians would be visible to drivers before the drivers got to the circle and started looking exclusively to the left for oncoming vehicles. The location of the roundabout is in a mixed-use area with a specific revitalization vision that includes being pedestrian friendly. There are several people who live in the neighborhood who use wheel chairs, and other disabled people also are frequently seen using the roundabout's crosswalks, including folks with vision impairment. There have been no pedestrian accidents in the four years the roundabout has been operating.
I feel proposed rule 1105.6 is very drastic and implore the Board to work with engineers and others in seeking refinements in roundabout designs that can allow this fledgling innovation to continue to be implemented and improved without the completely antithetical resort to signalization.
Sincerely,
Tex Haeuser, Planning Director
Lynn B. Jarman, October 24, 2002
ACCESSIBILITY IN THE PUBLIC RIGHT-OF-WAY DRAFT GUIDELINES
(Response to the Access Board's request for review and comment)
Salt Lake City Public Services has reviewed the proposed guidelines and respectfully submits the following recommended revisions and statements of concern:
1102.3, 1111.3 Alternate Circulation Path
Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
Recommended Revision: The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street, unless in the judgment of the engineer, significant pedestrian safety issues exist, then the alternate circulation path shall be provided on the opposite side of the street.
1102.14 On Street Parking. Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.
Concern: Block lengths are not consistent across the country; the ratio of accessible stalls to non-accessible stalls will vary from city to city based on the standard block length. The proposed guideline does not clearly define whether the requirements apply to all block faces within a city, or only those locations with pavement marked stalls. The cost to identify accessible stalls on all block faces, including residential areas would be extreme.
1104 Ramps and Blended Transitions
1104.2.2.1 Running Slope
EXCEPTION: A parallel curb ramp shall not be required to exceed 15 feet
Recommended Revision: A parallel curb ramp shall not be required to exceed 16 feet
(The proposed minimum pedestrian access width is 48 inches; therefore, the common sidewalk scoring pattern would occur every 48 inches
1104.3.2 Detectable Warnings (see 1108)
1105 Pedestrian Crossings
1105.2 Crosswalks
1105.2.2 Cross Slope. The cross slope shall be 1:48
Concern: This requirement will create "tabled areas" in the roadway, potentially creating vehicular traffic hazards, particularly in areas where roadways have steep running slopes.
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Recommended Revision: All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Concern: Some consideration has been given to a walk speed of 2.5 feet
1105.5 Pedestrian Overpasses and Underpasses
1105.5.3 Approach. Where the approach exceeds 1:20
Concern: Overpasses and underpasses exceeding the maximum stated approach rise should not require the installation of an elevator. The extreme cost for installation, maintenance, and security makes this requirement an unjustifiable burden on municipalities with limited resources. Efforts should be made to meet ramping requirements, but site conditions may present a situation of infeasibility.
1105.6 Roundabouts
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
Concern: Installation of pedestrian signals at each roundabout crossing negates the intended benefits of installing a roundabout. Additional signalization does not always result in greater pedestrian safety. Instead of requiring signals at all roundabouts, local engineers should evaluate roundabout installations to determine which locations would logically benefit from the installation of pedestrian signals.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.
Concern: Additional signalization does not directly equate to improved pedestrian safety. Well-engineered slip lanes (channelized turn lanes) with properly established pedestrian crossing times will result in improved safety. The slip lane design may or may not include additional signalization; the engineer should make this decision.
1108 Detectable Warning Surfaces
Concern: Considerable concern appears to exist from both the professional and public sectors regarding the installation of truncated domes. The major organizations representing the blind community cannot come to agreement on this issue. Initial installation costs and ongoing maintenance costs, especially in areas experiencing ice and snow, present real concerns regarding this proposed standard. Further evaluation is needed to ensure implementation of this guideline will provide the desired benefit.
Salt Lake City Public Services appreciates the opportunity to provide comment on the proposed guidelines. The Board's efforts in this matter are admirable. Hopefully, with feedback from local jurisdictions, guidelines meeting the true needs of our communities will be developed and adopted by those enforcing construction standards.
Sincerely,
Lynn B. Jarman
Salt Lake City Public Services
Engineering Division
Planning and Programming Manager
Susan Grossman, October 28, 2002
I am writing to express my support for the PROWAC's (Public Right of Way Advisory Committee) recommendations on accessible pedestrian signals and detectable warnings. I have visited cities in the United States that are in the vanguard of giving information available to sighted pedestrians to non-sighted pedestrians via audible signals. These signals are distinct and make it very easy for non-sighted pedestrians to cross intersections with much greater safety. I do not find these signals confusing and they do not interfer with traffic noise, which is used by some non-sighted pedestrians
use as an indicator. I also think that these signals are a much more effective means of determining whether it is safe to proceed than traffic noise. In very large and busy intersections it is extremely difficult to discern the difference in direction for traffice. Finally, with the recent introduction of electric and gas and electric cars which make little or noise, it is imperative that another means of notification other than traffic noise be instituted.
Thank you for taking my comments.
Susan Grossman