Accessible Pedestrian Signal Systems
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
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
Dear Access Board members and Staff:
I am writing in support of the recommendations outlined in the PROWAC report.
As a pedestrian with a visual impairment, I gladly support any and all efforts to incorporate access into existing pedestrian networks. Accessible Pedestrian Signals (APS), detectable directional guidance systems and detectable warnings must be viewed as fundamental elements of modern pedestrian networks.
I ask that the PROWAC recommendations be adopted so the millions of people with disabilities can enjoy accessible public rights of way, which is long over due.
Don Brown
ADA Compliance Coordinator
Kimberly Pawling, COMS & RTC, October 28, 2002
To Whom It May Concern:
My name is Kimberly A. Pawling. I hold a certification in Orientation & Mobility (O&M) and in Rehabilitation Teaching with the Academy for Certification of Vision Rehabilitation & Education Professionals. I am an active member of AERBVI (the Association for Education and Rehabilitation of the Blind and Visually Impaired), and I am currently employed at CITE, Inc. in Orlando, Florida as the O&M Specialist and Rehabilitation Teacher. I have reviewed the following comments written by my colleage Mrs. L. Dianne Ketts, a member of the Environmental Access Committee for AERBVI, and I would like to submit comments on the Draft Public Rights-of-Way Accessibility Guidelines.
Curb Ramps and Blended Transitions (1104)
Detectable Warning (1104.3.2)
I support inclusion of specifications in the draft guidelines for detectable warnings and urge The Board to include requirements for detectable warnings at ALL slopes and curb ramps where a pedestrian way intersects with a vehicular way regardless of grade.
Pedestrian Signal Phase Timing (1105.3)
I support The Board's draft guideline for Pedestrian Signal Phase Timing, stating that "signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Medians and Pedestrian Refuge Islands - Detectable Warnings (1105.4.2)
I do not support the EXCEPTION to this recommended guideline stating that "Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing." It is my recommendation that this EXCEPTION be removed from the proposed guidelines.
Turn Lanes at Intersections (1105.7)
I whole heartedly support the recommendation for pedestrian activated traffic signals at these locations.
Accessible Pedestrian Signals - General (1106.1)
I support the inclusion of specifications for Accessible Pedestrian Signal (APS) systems.
Many intersections in the central Florida area are typical of intersections that can be found throughout the country. Minor, lightly traveled streets often intersect with major arteries. When a visually impaired pedestrian's intention is to cross the major artery, there is often little or no parallel traffic movement on the minor street to indicate that it is the appropriate time for the pedestrian to begin crossing. Accessible Pedestrian Signal technology provides information critical to determining when to begin a crossing in a format that is accessible to the visually impaired pedestrian.
I recommend that The Board use the term "Accessible Pedestrian Signal (APS)" when referring to these types of devices as opposed to "pedestrian signal systems" or "pedestrian signal devices." This terminology would more closely match the language in the MUTCD and current terminology. As a result, engineers and others utilizing the MUTCD when building public rights-of-way will be less likely to encounter conflicting or misguiding terminology.
Once again, thank you for the opportunity to comment.
Kimberly Pawling, COMS & RTC
CITE, Inc.
Melanie Brunson, October 25, 2002
COMMENTS OF THE AMERICAN COUNCIL OF THE BLIND
Regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
Docket Number: 02-1
Submitted: October 24, 2002
Submitted by: Melanie Brunson, Director of Advocacy and Governmental Affairs
The American Council of the Blind (ACB) is pleased to submit the following comments on the Draft Guidelines for Accessible Public Rights-Of-Way, which were issued on June 17, 2002.
The American Council of the Blind (ACB) is a national membership organization of people who are blind and visually impaired. ACB is dedicated to improving the quality of life, equality of opportunity and independence of all people who have visual impairments. Its members and affiliated organizations have a long history of commitment to the advancement of policies and programs which will enhance the safety of pedestrians who are blind and visually impaired. For this reason, the Draft Guidelines for Accessible Public Rights-Of-Way proposed by the Access Board are of great interest to us.
By way of general comment, we want to let the Access Board know that we support the recommendations contained in this draft, and we believe that their implementation would make travel on public ways much safer for people who are blind and visually impaired. In the paragraphs that follow, we will highlight some of the proposals which we believe have the greatest impact on pedestrians who are blind and visually impaired and provide our comments thereon.
Section 1104 Curb Ramps And Blended Transitions
ACB concurs with the Access Board's recommended guidelines with regard to curb ramps and blended transitions. Of particular interest is the requirement in Section 1104.3.2 that detectable warning surfaces be provided wherever a curb ramp, landing, or blended transition connects to a crosswalk. We strongly support this requirement, and would urge the Access Board to retain it without exception. If detectable warning surfaces are to be incorporated into the public right-of-way in an effective manner, their application must be consistent. We believe that their use as a means of indicating to the visually impaired pedestrian that they are approaching an area in which traffic is likely to be moving is reasonable and will enhance the safety of such pedestrians. The suggestion that detectable warnings should only be installed where the slope of a curb ramp is 1:15
Section 1105 Pedestrian Crossings
1105.4 Medians and Pedestrian Refuge Islands: ACB supports the requirement for installation of detectable warnings on medians and pedestrian refuge islands set forth in 1105.4.2. We concur with the Board's conclusion that an exception is appropriate for islands where the crossing is controlled by signals which are timed for full crossing.
1105.6 Roundabouts: ACB supports the recommendations in 1105.6.1 that barriers be provided at roundabouts, along the street side of the sidewalk where pedestrian crossing is prohibited. Further, ACB concurs with the Board's recommendation that pedestrian activated traffic signals complying with 1106 be provided for each segment of the crosswalk, including the splitter island, as indicated in 1105.6.2. This appears to be the only feasible means of giving blind and visually impaired pedestrians safe access to the crosswalks at roundabouts, while causing a minimal interference with the flow of traffic on the roundabout. It is important that at these intersections, as well as at those intersections where a pedestrian crosswalk is provided at a right or left turn slip lane, a pedestrian activated traffic signal that complies with 1106 is provided for each segment of the pedestrian crosswalk, including the island.
Section 1106 Accessible Pedestrian Signal Systems
ACB supports the requirement that each crosswalk with pedestrian signal indication shall have a signal device which gives audible and vibrotactile indications of the walk interval. We agree with the Board that care should be exercised in the location of pedestrian push buttons to insure that, to the maximum extent feasible, push buttons for accessible pedestrian signals will be positioned where they can be located and activated by the pedestrian while leaving sufficient opportunity for the pedestrian to reach the curb in time to respond to the walk interval indication.
As an aid to this process, the locator tone required by 1106.3.2 is essential. In addition to alerting the visually impaired pedestrian to the presence of the push button, it draws the attention of non-disabled pedestrians to the push button, as well, increasing the likelihood of safer street crossings overall. In addition, as the locator tone becomes consistently incorporated into accessible pedestrian signal systems, the visually impaired pedestrian will have the benefit of knowing that further accessible information is forthcoming as a result of his/her activation of the push button. Since these tones are only audible at close range, if the recommended guidelines are followed correctly, they will not be disruptive to the surrounding community. Therefore, we believe their benefits far outweigh the minimal impact they may have on the environment.
We thank the Access Board for including specifications for pedestrian push buttons in 1106.3.3 regarding size and contrast. These specifications are important to facilitate their use by people who have low vision.
We believe that sections 1106.3.4 through section 1106.4.3 should be incorporated into the Access Board's rule in their entirety. These sections contain well-reasoned guidelines regarding the manner in which visually impaired individuals should be able to effectively access information about signal phases, as well as street identification and intersection design. It is essential that accessible pedestrian signals convey this information in a manner that is unambiguous and we believe these guidelines will accomplish this.
Section 1108 Detectable Warnings
ACB supports the Access Board's guidelines for the location and installation of detectable warning surfaces, as set forth in this section. We believe that the specifications contained herein minimize the accessibility concerns of persons who have mobility impairments, while greatly enhancing the ability of visually impaired people to access the public right-of-way in a safe manner.
As automobiles become quieter and traffic patterns become more complex, it becomes increasingly difficult, and unsafe, to rely upon the traditional sound of the traffic as the only means of determining when and where to cross streets. Pedestrians who do not have visual impairments are aided by signage and other visual cues for which people who are blind must compensate. It is our view that the Americans with Disabilities Act requires communities to take all reasonable steps to insure that people who are blind have access to the same information they provide to the general public. The guidelines recommended here represent a thoughtful and reasonable attempt to assist communities in carrying out that responsibility and we urge the Access Board to incorporate these guidelines into a rule for accessible public rights-of-way.
The members of ACB passed a resolution at their convention in 2002 reiterating their support for these guidelines, and expressing some further views with regard to appropriate features for accessible pedestrian signals. A copy of this resolution appears at the end of this document.
Thank you very much for your consideration.
Sincerely,
Melanie Brunson
Director of Advocacy and Governmental Affairs
AMERICAN COUNCIL OF THE BLIND
RESOLUTION 2002-24
WHEREAS, for many years, the American Council of the Blind (ACB) and its affiliates have advocated strongly for the use of accessible pedestrian signals, and have also been leaders in providing advice on the appropriate standards to govern their use and installation; and
WHEREAS, subsequent to the adoption of accessible pedestrian signals standards in the Federal Highway Administration (FHWA) Manual on Uniform Traffic Control Devices 2000 millennium edition, revised, as well as draft guidelines issued by the U.S. Architectural and Transportation Barriers Compliance Board (U.S. Access Board), many state and local jurisdictions are examining the extent to which changes should be made in the accessible pedestrian signals guidelines and standards contained in their traffic manuals; and
WHEREAS, ACB continues to encourage state and local jurisdictions to provide the highest level of access to the public rights-of-way and to ensure the safety of pedestrians;
NOW, THEREFORE, BE IT RESOLVED by the American Council of the Blind in convention assembled this 5th day of July, 2002, in Houston, Texas, that this organization urges state and local jurisdictions to include all of the following requirements in their traffic manuals:
(1) Consistent with the revised FHWA standards, the state or local jurisdiction shall not require that organizations which represent pedestrians with disabilities be in full agreement that there is a widespread demand for the installation of an accessible pedestrian signal at a specific existing signalized location in order for an accessible pedestrian signal to be installed;
(2) Whenever the state or local jurisdiction is installing a new, or upgrading an existing, signal, the signal shall be equipped with accessible pedestrian features;
(3) All accessible pedestrian signals shall contain the following features;
(a) A push button with a locator tone and a tone indicating when the walk interval is in effect.
(b) A vibrotactile device to indicate both that the walk interval is in effect and the direction to which it applies, through the use of a vibrating directional arrow or some other tactile indicator.
(c) Locator and walk interval tones which automatically adjust in volume in relation to ambient noise;
(4) Activation of the pedestrian traffic signal for a period of three seconds activates the accessible pedestrian signal; and
BE IT FURTHER RESOLVED that these standards shall not prohibit a state or local jurisdiction from providing additional accessible pedestrian signal features if requested; and
BE IT FURTHER RESOLVED that this organization transmit a copy of this resolution to the U.S. Access Board during the public comment period on its draft proposed guidelines on access to public rights-of-way, which ends October 28, 2002.
Adopted.
Donna Seliger, Secretary
David Harrell, P.E., October 25, 2002
Per our conversation, attached are comments from the City of Knoxville's Department of Engineering on the Draft Guidelines on Accessible Public Rights-of-Way. I will follow this up with a hard copy and cover letter via regular mail.
Sincerely,
David Harrell, P.E.
Chief Civil Engineer
City of Knoxville
Dept. of Engineering
CITY OF KNOXVILLE, TENNESSEE
DEPARTMENT OF ENGINEERING
Comments on Draft Guidelines on Public Rights-of-Way
SECTION 1102.2.2 Alterations. It is noted that alterations must not be fully compliant "where compliance is technically infeasible". We find the statement to be too vague and believe it needs further clarification. The examples of technical infeasibility given in the "Discussion of Provisions" are extreme cases. For example, would adding a left turn signal to a signalized intersection that has a pedestrian signal system require making the pedestrian signal system fully accessible? If so, this could potentially turn a $400 upgrade into a $10,000 upgrade. We would consider this just as technically infeasible as "altering a load-bearing member of a structural frame". While technically this could be done, the cost to make the area within the alteration fully compliant compared to the cost of the alteration itself would make the project no longer viable.
SECTION 1104.3.2 Detectable Warnings. We concur with the advisory committee's comments on using detectable warnings on only those ramps that are the least distinguishable. While the revised specifications are an improvement we believe the truncated domes to be hazardous for elderly pedestrians and will still cause difficulties in maneuvering for wheelchairs.
SECTION 1104.3.3 Surfaces. When altering an existing facility such as adding a curb ramp where none exists, it is not always possible to locate the ramp to avoid manhole covers for utilities. While the elevation of these covers can be adjusted to match the slope and elevation of the ramp, it is impractical to have these manholes relocated. We would expect this situation to fall under the "technically infeasible" category.
SECTION 1104.3.6 Counter Slopes. Integral curb and gutter sections are typically slip-formed and typically have a cross-slope of 1:12
SECTION 1105.2.2 Cross Slope. With terrain such that is typical in East Tennessee, profile grades of 9 or 10 percent are very common. This requirement would be extremely difficult, it not impossible, to implement for roads having grades of this magnitude. In order to make an intersection design work for a road of this type, the profile grade must be changed by 7 or 8 percent along a vertical curve that maintains the design speed of the road. Typically, the cross-slope of the intersecting street is often sloped as much as 4 percent to minimize the required change in profile grade of the through street.
SECTION 1105.4 Medians and Pedestrian Refuge Islands. The cut through concept is a good idea to provide access for pedestrian access but the need for pedestrian storage needs to be considered as well, e.g., when crossing pedestrians to the refuge island on one phase and then the remainder of the crossing under another phase. The situation could arise where several pedestrians would be crossing but not enough space is provided in the island crossing area and would leave some of the pedestrians in the roadway until the next pedestrian crossing phase.
SECTION 1105.7 Turn Lanes at Intersections. Most right-turn slip lanes have no signalized control other than a yield sign. It would not be practical to locate a pedestrian signal system at these locations as the slip lanes are not signalized. Signalizing the slip lane to enable the use of a pedestrian signal system would effectively remove the reason for providing the slip lane.
SECTION 1102.8 and 1106 Accessible Pedestrian Signal Systems. Is the requirement to install these devices at all existing signalized intersections that currently provide pedestrian signal systems or at only that intersection that will be constructed and/or upgraded. If the Board is advocating that all the pedestrian signal systems be upgraded then there needs to be some consideration to phasing in a program over time to help defer the cost of these upgrades. The cost could exceed $20,000 per intersection for the accessible pedestrian signal system at complex signalized intersections and could be much higher if the relocation of existing signal poles or the addition of pedestrian signal poles is required. Considerations should take for the cost of initial installation and the need for additional maintenance personnel to maintain this type of facility to insure proper operation.
Patricia M. Beattie, October 28, 2002
COMMENTS OF THE COUNCIL OF CITIZENS WITH LOW VISION INTERNATIONAL
Submitted by:
Patricia M. Beattie, President
Council of Citizens With Low Vision International (CCLVI)
Regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
Docket Number: 02-1
The Council of Citizens With Low Vision International (CCLVI), of which I am the current President, is pleased to advise you and the Access Board of our endorsement of comments submitted by American Council of the Blind (ACB) on the above proposed guidelines concerning access to public rights of way.
CCLVI specifically calls for use of the universal attention and safety color bright yellow for warning surfaces which also should be detectable underfoot and upon sound of cane contact. We believe that the use of the bright yellow color is critical for detection by the growing number of older Americans who are living long enough to experience age-related vision loss, most of which is caused by macular degeneration. Of people who attain the age of 70, one of of ten will experience macular degeneration. This condition also greatly diminishes the ability to see when there is the glare of sunshine or bright lights, or conversely, light limited by night.
CCLVI believes that it is the right of visually impaired pedestrians to have access to the same information available to other citizens--that means conveyance of information normally provided on signs and signal lights iin other ways as well--tactily or audibly.
This includes information about whether an intersection is signaled, how to locate and to activate the pedestrian button and when the walk sign comes on. With the new designs of intersections and ways of controlling traffic flow, we no longer can depend only on usual patterns or sounds of or absence of traffic flow.
CCLVI supports use of an unobtrusive tone to indicate location of a traffic signal control button, typically not to be audible beyond a distance of ten feet.
We believe that the buttons should be located sufficiently close to the crosswalk so that individual pedestrians can return to the crossing in time for change to the walk signal.
We trust that the Access Board will pay attention to the quality and content of comments submitted on these proposed guidelines, not just quantity. If some blind people don't understand the importance of these issues, that is no reason to abridge accessability and safety for the vast majority of pedestrians, including those with visual impairments, sensitivity to light or night blindness.
Thanks you for this opportunity to comment on behalf of myself and the Council of Citizens With Low Vision International.
Sincerely,
Patricia M. Beattie, President
Council of Citizens With Low Vision
Attachments:
Comments of American Council of the Blind, as endorsed by CCLVI
ACB Resolution (attached to ACB comments below)
COMMENTS OF THE AMERICAN COUNCIL OF THE BLIND
Regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
Docket Number: 02-1
Submitted: October 24, 2002
Submitted by: Melanie Brunson, Director of Advocacy and Governmental Affairs
Mr. Scot Windley
Office of Technical and Informational Services
Architectural and Transportation Barriers Compliance Board
1331 F. Street, N.W., Suite 1000
Washington, D.C. 20004-1111
Dear Mr. Windley,
The American Council of the Blind (ACB) is pleased to submit the following
comments on the Draft Guidelines for Accessible Public Rights-Of-Way, which
were issued on June 17, 2002.
The American Council of the Blind (ACB) is a national membership organization
of people who are blind and visually impaired. ACB is dedicated to improving
the quality of life, equality of opportunity and independence of all people
who
have visual impairments. Its members and affiliated organizations have a long
history of commitment to the advancement of policies and programs which will
enhance the safety of pedestrians who are blind and visually impaired. For
this reason, the Draft Guidelines for Accessible Public Rights-Of-Way proposed
by the Access Board are of great interest to us.
By way of general comment, we want to let the Access Board know that we
support
the recommendations contained in this draft, and we believe that their
implementation would make travel on public ways much safer for people who are
blind and visually impaired. In the paragraphs that follow, we will highlight
some of the proposals which we believe have the greatest impact on pedestrians
who are blind and visually impaired and provide our comments thereon.
Section 1104 Curb Ramps And Blended Transitions
ACB concurs with the Access Board's recommended guidelines with regard to curb
ramps and blended transitions. Of particular interest is the requirement in
Section 1104.3.2 that detectable warning surfaces be provided wherever a curb
ramp, landing, or blended transition connects to a crosswalk. We strongly
support this requirement, and would urge the Access Board to retain it without
exception. If detectable warning surfaces are to be incorporated into the
public right-of-way in an effective manner, their application must be
consistent. We believe that their use as a means of indicating to the
visually
impaired pedestrian that they are approaching an area in which traffic is
likely to be moving is reasonable and will enhance the safety of such
pedestrians. The suggestion that detectable warnings should only be installed
where the slope of a curb ramp is 1:15
adjoining those ramps not covered by detectable warnings will be detectable
without them. We are not aware of any research which supports this argument.
In addition, we would point out that it requires more than a determination of
the slope of a curb ramp to determine whether one is approaching a crosswalk,
or a driveway, or some other type of space. Traffic sounds, as well as other
audible and tactile cues can influence one's decision about the nature of the
space one is about to approach, and the absence of such cues can hinder the
pedestrian's ability to accurately assess the safety of the situation. The
use
of detectable warning surfaces at such locations would provide a safe way of
indicating that the approach to a vehicular way is imminent. It provides a
definite tactile cue to the visually impaired pedestrian without in any way
supplanting his/her judgment or interfering with his/her ability to exercise
good travel skills. Therefore, ACB supports this recommendation.
Section 1105 Pedestrian Crossings
1105.4 Medians and Pedestrian Refuge Islands: ACB supports the requirement for
installation of detectable warnings on medians and pedestrian refuge islands
set forth in 1105.4.2. We concur with the Board's conclusion that an
exception is appropriate for islands where the crossing is controlled by
signals which are timed for full crossing.
1105.6 Roundabouts: ACB supports the recommendations in 1105.6.1 that barriers
be provided at roundabouts, along the street side of the sidewalk where
pedestrian crossing is prohibited. Further, ACB concurs with the Board's
recommendation that pedestrian activated traffic signals complying with
1106 be
provided for each segment of the crosswalk, including the splitter island, as
indicated in 1105.6.2. This appears to be the only feasible means of giving
blind and visually impaired pedestrians safe access to the crosswalks at
roundabouts, while causing a minimal interference with the flow of traffic on
the roundabout. It is important that at these intersections, as well as at
those intersections where a pedestrian crosswalk is provided at a right or
left
turn slip lane, a pedestrian activated traffic signal that complies with 1106
is provided for each segment of the pedestrian crosswalk, including the
island.
Section 1106 Accessible Pedestrian Signal Systems
ACB supports the requirement that each crosswalk with pedestrian signal
indication shall have a signal device which gives audible and vibrotactile
indications of the walk interval. We agree with the Board that care should be
exercised in the location of pedestrian push buttons to insure that, to the
maximum extent feasible, push buttons for accessible pedestrian signals
will be
positioned where they can be located and activated by the pedestrian while
leaving sufficient opportunity for the pedestrian to reach the curb in time to
respond to the walk interval indication.
As an aid to this process, the locator tone required by 1106.3.2 is
essential.
In addition to alerting the visually impaired pedestrian to the presence of
the
push button, it draws the attention of non-disabled pedestrians to the push
button, as well, increasing the likelihood of safer street crossings overall.
In addition, as the locator tone becomes consistently incorporated into
accessible pedestrian signal systems, the visually impaired pedestrian will
have the benefit of knowing that further accessible information is forthcoming
as a result of his/her activation of the push button. Since these tones are
only audible at close range, if the recommended guidelines are followed
correctly, they will not be disruptive to the surrounding community.
Therefore, we believe their benefits far outweigh the minimal impact they may
have on the environment.
We thank the Access Board for including specifications for pedestrian push
buttons in 1106.3.3 regarding size and contrast. These specifications are
important to facilitate their use by people who have low vision.
We believe that sections 1106.3.4 through section 1106.4.3 should be
incorporated into the Access Board's rule in their entirety. These sections
contain well-reasoned guidelines regarding the manner in which visually
impaired individuals should be able to effectively access information about
signal phases, as well as street identification and intersection design.
It is
essential that accessible pedestrian signals convey this information in a
manner that is unambiguous and we believe these guidelines will accomplish
this.
Section 1108 Detectable Warnings
ACB supports the Access Board's guidelines for the location and
installation of
detectable warning surfaces, as set forth in this section. We believe that
the
specifications contained herein minimize the accessibility concerns of persons
who have mobility impairments, while greatly enhancing the ability of visually
impaired people to access the public right-of-way in a safe manner.
As automobiles become quieter and traffic patterns become more complex, it
becomes increasingly difficult, and unsafe, to rely upon the traditional sound
of the traffic as the only means of determining when and where to cross
streets. Pedestrians who do not have visual impairments are aided by signage
and other visual cues for which people who are blind must compensate. It is
our view that the Americans with Disabilities Act requires communities to take
all reasonable steps to insure that people who are blind have access to the
same information they provide to the general public. The guidelines
recommended here represent a thoughtful and reasonable attempt to assist
communities in carrying out that responsibility and we urge the Access
Board to
incorporate these guidelines into a rule for accessible public rights-of-way.
The members of ACB passed a resolution at their convention in 2002 reiterating
their support for these guidelines, and expressing some further views with
regard to appropriate features for accessible pedestrian signals. A copy of
this resolution appears at the end of this document.
Thank you very much for your consideration.
Sincerely,
Melanie Brunson
Director of Advocacy and Governmental Affairs
AMERICAN COUNCIL OF THE BLIND
RESOLUTION 2002-24
WHEREAS, for many years, the American Council of the Blind (ACB) and its
affiliates have advocated strongly for the use of accessible pedestrian
signals, and have also been leaders in providing advice on the appropriate
standards to govern their use and installation; and
WHEREAS, subsequent to the adoption of accessible pedestrian signals standards
in the Federal Highway Administration (FHWA) Manual on Uniform Traffic Control
Devices 2000 millennium edition, revised, as well as draft guidelines
issued by
the U.S. Architectural and Transportation Barriers Compliance Board (U.S.
Access Board), many state and local jurisdictions are examining the extent to
which changes should be made in the accessible pedestrian signals guidelines
and standards contained in their traffic manuals; and
WHEREAS, ACB continues to encourage state and local jurisdictions to provide
the highest level of access to the public rights-of-way and to ensure the
safety of pedestrians;
NOW, THEREFORE, BE IT RESOLVED by the American Council of the Blind in
convention assembled this 5th day of July, 2002, in Houston, Texas, that this
organization urges state and local jurisdictions to include all of the
following requirements in their traffic manuals:
(1) Consistent with the revised FHWA standards, the state or local
jurisdiction
shall not require that organizations which represent pedestrians with
disabilities be in full agreement that there is a widespread demand for the
installation of an accessible pedestrian signal at a specific existing
signalized location in order for an accessible pedestrian signal to be
installed;
(2) Whenever the state or local jurisdiction is installing a new, or upgrading
an existing, signal, the signal shall be equipped with accessible pedestrian
features;
(3) All accessible pedestrian signals shall contain the following features;
(a) A push button with a locator tone and a tone indicating when the walk
interval is in effect.
(b) A vibrotactile device to indicate both that the walk interval is in
effect and the direction to which it applies, through the use of a vibrating
directional arrow or some other tactile indicator.
(c) Locator and walk interval tones which automatically adjust in volume in
relation to ambient noise;
(4) Activation of the pedestrian traffic signal for a period of three seconds
activates the accessible pedestrian signal; and
BE IT FURTHER RESOLVED that these standards shall not prohibit a state or
local
jurisdiction from providing additional accessible pedestrian signal
features if
requested; and
BE IT FURTHER RESOLVED that this organization transmit a copy of this
resolution to the U.S. Access Board during the public comment period on its
draft proposed guidelines on access to public rights-of-way, which ends
October
28, 2002.
Adopted.
Donna Seliger, Secretary
George Bansman and Others, October 5, 2002
I am writing in support of the regulations requiring the wider use of the accessible pedestrian signals and detectable warning strips. My home address is [ ... ]
I urge you to consider the fact that accessible pedestrian signals provide blind people access to important safety information which is currently being provided to sighted pedestrians. These regulations will help stop the practice of denying us access to this important information.
Thank you for considering these comments.
Sincerely,
George Bansman
[Identical letter submitted by others listed below - Access Board] Peggy Bansman Glenda Blanchard Phil Cheek Susan H. Crawford Donna Evans Wade W. Garrett Ruth Hairsine Steven Hairsine Patsy Harlan Barbara Heffernan Anetta J. Kasecamp Joann Kuzic Velma A. Love Vanessa Lowery Gary Mesman Shirley Messman Anna C. Meyers Brenda Mueller Frank Pacheco Hope Pietrolongo Bari Powers Bill G. Powers Penny Reeder Robin Rehder August Rothe June Sheehan Patrick Sheehan M. Eugene Spurrier Page Trammell Edward Walker E.G. Yakubowski
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
David Mostello, October 7, 2002
National Federal of the Blind of New Jersey
Re: Comments regarding Regulations for Accessible Pedestrian Signals (Audible Pedestrian Signals)
Dear Access Board:
The Accessible Pedestrian Signal Regulations which are scheduled to be put in affect, are worthy of the following
Comments:
1) The National Federation of the Blind of New Jersey has been aware of the audible pedestrian signal for over thirteen years. These signals, though thought to assist the blind, are an obstruction to the alternative technique used by blind people in crossing streets.
When a blind person arrives at an intersection, he listens to the flow of traffic entering and leaving the intersection. When the traffic in front of him stops, and the traffic which is parallel to him starts, the blind person can be certain that the street in front of him is safe for him to cross.
The Accessible Pedestrian Signals pose additional safety issues. These include the increase in noise generated by each of the eight signals at a traditional four-way intersection. This increased noise detracts from the traditional sounds on which a blind person relies to cross a street.
This increased noise is also a distraction to residents and other persons who live / work nearby. In situations where Accessible Pedestrian Signals have been installed, workers can not open windows during warm days, and residents who live in the area where the signals are installed, complain about the noise during the night.
Installation of Accessible Pedestrian Signals forces a blind person to rely on that device in order to cross a street. What would happen if the Accessible Pedestrian Signal malfunctioned?, or if the blind person located to an area which was not equipped with Accessible Pedestrian Signals? Our methods of determining clear right-of-ways are less costly and more versatile.
The National Federation of the Blind does acknowledge that in certain situations, where a group of blind people agree, an Accessible Pedestrian Signal can be installed.
I also understand that the Access Board is accepting Comments regarding detectable warnings at intersections. The opinion of the NFBNJ is that these proposed regulations and warnings are unnecessary, because blind pedestrians have functioned without such warnings, by relying upon the sound of traffic, the slope of the ramps built for pedestrians in wheelchairs, and through the use of a guide dog or long white cane.
On a personal note, I traveled Washington, D.C. during the Summer of my Junior Year of college when I interned with the Federal Communications Commission. If I was unable to independently judge the traffic flow and time to cross, someone who was crossing the street with me indicated when to cross the street by crossing themselves.
The proposed rules and large support for installation of such devices are only the efforts of the manufacturer of the Accessible Pedestrian Signal and ill-informed professionals to undermine and increase the dependence of blind people on another unnecessary device.
If you have any questions, please contact James McCarthy, Assistant Director, Governmental Affairs at [....].
Sincerely,
David Mostello
Legislative Coordinator & Board Member
NFBNJ, Inc.
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
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
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
Kristyn Leigh, October 27, 2002
I am writing in support of the draft Guidelines on Accessible Public Rights-of-Way published in June, 2002. The guidelines contain provisions which have the potential to improve public access for all pedestrians. As a blind person, I am especially interested in the sections related to accessible pedestrian signals. Such signals can provide the same information which is presented visually for drivers and sighted pedestrians.
I look forward to hearing more about the progress of this project and hopefully discovering proof of its success in my travels.
Kristyn Leigh
Kim Charlson, October 19, 2002
Thank you for receiving my comments regarding the importance of accessible pedestrian signals and detectable warnings for blind and visually impaired individuals. I live in a community, Watertown, Massachusetts, that has been forward-thinking to have installed accessible pedestrian signals on all lighted intersections over 30 years ago. The old system used bells instead of the more contemporary beeps, but the outcome was the same -- the ability to safely cross the street. Now, older units are being replaced with contemporary units and no one has had any problems with the transition.
With the complexities of today's traffic and urban intersections, accessible pedestrian signals, and detectable warnings, make an extremely important contribution to the overall accessibility and independence for pedestrians with visual impairments.
I urge you to continue the excellent work of the Access Board in the direction of accessible pedestrian signals and detectable warnings. Every blind and visually impaired person should have the choice to be safe, and to safely cross an intersection. This should be available to them wherever they live and regardless of whether they use a cane or a guide dog. Philosophical arguments as to the impression such devices make on sighted people shouldn't be the overriding consideration, safety of blind and visually impaired people should be the goal. Sighted people understand the reason for accessible pedestrian signals and why they are necessary, and now through the hard work of the Access Board, governments, states, cities and towns will also know the need for these essential modifications.
Thank you for your consideration.
Kim Charlson
Laura Oftedahl, October 27, 2002
I am a competent blind pedestrian - and strongly support accessible pedestrian signals. It is a very scary world crossing the street. I want to live, but need some help from this new technology. Thank you.
Laura Oftedahl
Lukas Franck, COMS, October 28, 2002
Re: The Draft Guidelines for the Accessible Public Rights-of-Way
As the former chair of the PROWAAC sub-committee on Signals and Wayfinding, I would like to congratulate the U.S. Access Board on these draft guidelines which certainly adhere closely to the intent of the recommendations of the majority of our sub-committee. I would like to offer several additional comments.
Of particular concern is the specification on pedestrian pushbutton pole placement. I would like to take this opportunity to review how this specification came about, as the specification appears to have been adopted from that in the MUTCD.
1106.2.1
In working with the National Committee on Uniform Traffic Control Devices to arrive at the proposed language which was eventually included in the MUTCD Millennium edition, we originally proposed that the pedestrian pushbutton pole be placed within five feet of the crosswalk lines extended and five feet of the curb. Please remember that at the time that we were writing that guidance language, there was no requirement that the notification of the WALK interval would always come from the pushbutton housing itself. When this language went out for comments to the MUTCD sponsors, there were several comments from the various states indicating that the proposed "box" was too tight. Bearing in mind that the proposed guidance language in the MUTCD would apply equally to new construction and retrofits, the National Committee decided upon language that extended one dimension of the "box". This resulted in the guidance that the pedestrian pushbutton poles should be placed within five feet of the crosswalk lines extended and within ten feet of the curb.
In the PROWAAC report, we recommended that a much more precise standard apply in new construction and I believe we could have been tighter still. Last year I had the opportunity to visit Australia where I was able to observe signals as proposed in these draft guidelines in operation, which confirmed the importance of good pole placement for accessible pedestrian signals, as proposed in these draft guidelines, if those signals are to work
efficiently and quietly. I urge The Access Board to include the language
as contained in the original PROWAAC report in the new proposed rules.
I would also like to see language that clarifies for engineers that where underground structures, geometric constraints or other factors prevent perfect pole placement, that there should be a bias to place pedestrian pushbutton poles as close as practically possible to the departure point within the MUTCD five foot by ten foot guidance.
1106.2.3.1
Concerning the tones utilized to notify pedestrians of the onset of the WALK
interval: I applaud your choice. It is very similar to the practice currently utilized in Europe and is similar to that formerly used in Australia. However, in recent years, the Australian system has been modified and now includes a "transition tone" preceding the "rapid tick" WALK notification. This "transition tone" is a sharp sound that moves rapidly through many frequencies. In combination with the "rapid tick" it is an absolutely unique sound. Preliminary results of the survey that I have been conducting in Morristown indicate that the distinctiveness of this sound combination is quite striking to blind pedestrians, who identify it as being unlike anything else they would hear in the American soundscape on the street. This may not be true of the "rapid tick" alone. In one experience I had at a test installation in Austin, Texas some years ago, one participant believed the "rapid tick" to be a distant jackhammer. Further, I believe that the Australians added the "transition tone" for a reason, and I suspect it was that the rapidly increasing and then decreasing change in frequencies made the sound more obvious to those with certain types of hearing loss. I would encourage The Access Board to solicit information from the Australian authorities on this point. I would also note that a few blind pedestrians participating in the Morristown study have indicated that the sound combination used in the Australian system imparts to them too great a sense of urgency to leave the curb, so that some further type of refinement might be required. Nevertheless, at this early juncture of the Morristown study, indications are that the use of sound from the pushbutton housing to give WALK information in close proximity to the departure point is extremely well received by the majority of blind pedestrians.
I would also like to respond to some other comments I have seen, in particular those of AASHTO. AASHTO urged that the draft guidelines on Accessible Pedestrian Signals be held in abeyance, pending further research. The implication of their recommendation is that these guidelines are radical and untested. In fact, nothing could be further from the truth, as standards very similar to those proposed in the draft guidelines are the realities on the ground in Australia, Denmark, Sweden, and many other countries.
It is indeed true that further research to improve and enhance the technology employed and the sounds chosen to inform blind pedestrians is ongoing and of great value; however standardized and rational pedestrian pushbutton pole placement will benefit all pedestrians, including those in wheelchairs and with cognitive disabilities. Including pedestrian pole placement in the eventual guidelines will have the effect of forcing engineers to design intersections as thoroughly for pedestrians as they currently do for vehicles.
Finally, since the MUTCD currently allows Accessible Pedestrian Signals and there is considerable demand for those signals from the blind public, there is a risk that in the absence of standards we will miss the opportunity to create a truly national system of accessibility. In that event the resulting regulatory vacuum will be filled with a hodgepodge that will be
installed on the basis of best price rather than best practice.
Thank you for the opportunity to offer my comments. Thank you also, once again, for giving me the opportunity to participate in PROWAAC, and for the opportunity to present to the Board at the Portland, Oregon public hearing earlier this month.
Lukas Franck, COMS
The Seeing Eye Morristown, NJ
Edward Bell, M.A., NOMC, October 8, 2002
Dear Access Board:
I am writing this letter to voice my opposition to the proposed guidelines for environmental modification. In particular, I am concerned about the mandates for Accessible Pedestrian Signals (APS) and detectable warnings proposed at virtually all street corners. I am a certified orientation and mobility specialist (NOMC), and have had experience teaching students to travel across many different types of intersections. Furthermore, I am a blind person, and therefore have personal knowledge of the dangers, or perceived dangers, inherent in our public rights-of-way. I hope that you will consider my comments in view of my credentials and experience as a professional in the field as well as a consumer.
The vast majority of intersections across this country have remained unchanged for decades, yet thousands of blind pedestrians have safely navigated the streets of America without the assistance of accessible pedestrian signals. Nevertheless, there have recently been built intersections which are large, complex and which may be appropriate for intersection adaptation. These are rare occasions, however, and should not become the rule for the rest of the country. I have traveled in my hometown safely, but I have also traveled in many large metropolitan cities, suburban communities and rural areas without the use of any environmental modification. More importantly, I have taught novice, intermediate and experienced students in similar areas with considerable success. As such, there has not been a place where I was either unable to travel or teach that was unsafe without APS or truncated domes.
accessible pedestrian signals already exist at some intersections, and I have had some experience with them. In addition, I was recently present at an orientation and mobility conference during which the newest models of accessible pedestrian signals were being tested. I can say unequivocally that the demonstrated models presented a greater danger than a solution to blind and visually impaired individuals. The intention of the design is noble, however, the devices fall far short of providing a needed function. Perhaps consultation with consumers during the development stage, rather than during the evaluation phase will assist manufactures in the development of better designs.
Advocates of environmental modification embrace the proposed guidelines as a desirable solution, yet blind consumers regard many types of accessible pedestrian signals as a nuisance and potential danger. The chirping sounds of the walk signal and the buzz of the locater tones can be confusing, and present a sufficient distraction to prevent the blind person from correctly identifying the traffic patterns. While walk/don't walk signals are a good idea, they do not control the traffic. Thus, blind and visually impaired pedestrians must be able to monitor the traffic flow without interference of extraneous sounds. Advocates present APS as a necessary accommodation to actuated traffic lights in which the cycle is controlled by traffic flow. These types of intersections, however, are currently controlled by pedestrian signals already in place. As I have already said, blind pedestrians depend on the movement of traffic, or the absence of traffic, to determine that it is safe to cross a street. Since existing pedestrian signals at actuated traffic signals already control the cycle for pedestrians, making them accessible is unnecessary, a waste of money and a potential danger.
I do trust and believe that the Access Board will come to see that the proposed guidelines on environmental modification are excessive, unnecessary and ill planned. As a mobility professional and as a blind pedestrian I will be more than happy to be a part of any future guidelines for accessibility. Please feel free to contact me at any time if I can be of assistance, and together we can make the public environment a safer place for everyone, without making it a potential danger to anyone in the process.
Sincerely,
Edward Bell, M.A., NOMC
Doctoral Student, University of Arkansas
Fayetteville Arkansas
Willamette Pedestrian Coalition, October 28, 2002
Comments by the Willamette Pedestrian Coalition on the Draft Guidelines for Accessible Public Rights-of-Way
Willamette Pedestrian Coalition
Ellen Vanderslice, President
Doug Klotz, Policy Analyst
We are pleased to support the Draft Guidelines for Accessible Public Rights-of-Way. In general this document represents an advance for accessibility on public streets. Our specific comments follow and are also attached as a Word document for your convenience.
1102.14 On-Street Parking
We support the provision of accessible on-street parking. However, we respectfully disagree with the proposed requirement of one space per block. Blocks vary so greatly in size (including average variation between cities) that this is an inherently inequitable requirement. Perhaps the requirement should be something like one for every six hundred feet of on-street parking provided. Also, there should be a better definition of "where on-street parking is provided," whether this means where it is allowed or where it is marked or signed. The guidelines should clarify whether this requirement applies on every street, even low-volume residential streets where parking is permitted but not designated.
1103.3 Clear Width (of the Pedestrian Access Route)
We support widening the minimum clear width requirement in the public right-of-way, with the understanding that larger scooters may be used in this environment and that there should be room for two wheelchairs to pass. We would support the PROWAAC recommendation for 60 inches
1104.3.2 Detectable Warnings (in Common Elements of Curb Ramps and Blended
Transitions)
We support the requirement for detectable warnings at curb ramps and blended transitions. See additional comments on 1108.
1105.2 Crosswalks
We support all the crosswalk provisions, including the minimum width of 96 inches
intersections) and the maximum running slope of 1:20
1105.2 Pedestrian Signal Phase Timing
While we support reducing the walk speed used to calculate crossing times, as well as the inclusion of one ramp in the value of the length of the crosswalk used in the calculation, we suggest that there might be an exception included for signals that use either passive or active detection to extend the pedestrian clearance interval on demand. If the system can provide the added crossing time only when needed, this will benefit those crossing in the perpendicular direction and reduce overall delay for pedestrians.
1105.4 Medians and Pedestrian Refuge Islands
We support the requirement for alignment of the cut-through with the direction of the crosswalk for a minimum of 24 inches
1105.5 Pedestrian Overpasses and Underpasses
We are supportive of the needs of users who experience fatigue but we are concerned about the effect of the 60 inch
We respectfully suggest that the terms "pedestrian overpass" and "pedestrian underpass" be defined in section 1101.3. Without a definition, it is not clear which facilities require an elevator.
1105.6 Roundabouts
We respectfully suggest a definition in 1101.3 of "barriers" as used in 1105.6.1 Separation. We believe landscaping should be allowed as separation. The extent of the required separation should be specified more clearly.
We support 1105.6.2 Signals (at Roundabouts). As noted in the discussion, there currently is no alternative that allows for safe passage of pedestrians with disabilities.
Although this may not be an accessibility issue, we suggest that adding a new tool to the pedestrian signal arsenal could be helpful in this situation. There is currently no provision for pedestrian signals where "pedestrian yield," rather than "don't walk," is the default state. We believe such a signal would be useful in a situation like a roundabout where most pedestrians will use available gaps rather than request the walk signal.
1105.7 Turn Lanes at Intersections
We support the requirement for pedestrian signals with the same suggestions as we made for signals at roundabouts.
1106.2 Pedestrian Signal Devices
We support the requirement for accessible signal devices at all crosswalks with pedestrian signal indication.
1106.3 Pedestrian Pushbuttons
We would like to note that these draft guidelines do not require the use of pedestrian pushbuttons, and that signals without pedestrian pushbuttons are much better for all pedestrians.
The PROWAAC recommended (in "Building a True Community," section X02.5.1.3) that "the control face of the push button shall be parallel to the direction of the crosswalk controlled by the push button?" We believe this guideline should include a requirement for the directionality of pushbuttons.
1108 Detectable Warnings
We respectfully suggest that the language in this section be strengthened to clarify that the "square" grid pattern must be aligned with the direction of the ramp. We also suggest that, in deference to wheelchair users, the range of permitted center-to-center dome spacing under 1108.1.2 be reduced to the largest end of the range and that the minimum base-to-base spacing be increased to 1 inch
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
Kenneth Rosenthal, October 23, 2002
The Seeing Eye, Inc.
Re: Draft Guidelines for Accessible Public Rights-of-Way (June 17, 2002)
Dear Mr. Windley:
As President of The Seeing Eye I would like to commend the US Access Board for its work on the Draft Guidelines on Accessible Public Rights-of-Way and in particular on the sections on Accessible Pedestrian Signals and Detectable Warnings.
I am aware, through my frequent conversations and correspondence with blind graduates of The Seeing Eye, that the many changes in the pedestrian environment and traffic control systems along with quieter cars have made independent travel more challenging for many of them over the last 20 years or so. In fact we have had to increase the training time required of our dogs from three to four months in order to be sure that they are adequately prepared for this increasingly challenging environment.
As Chairman of the International Federation of Guide Dog Schools for the Blind I have the opportunity to travel abroad to Australia and Britain for meetings and consultations with my colleagues in the profession. I have often noticed, in particular in Australia, that pedestrian facilities such as ramps and pedestrian pushbuttons are much more uniform and accessible to blind pedestrians than those I am familiar with in the United States.
I understand that the solutions proposed in the Draft Guidelines would result in a pedestrian landscape that would resemble, rival and possibly even exceed Australia's. Our commitment to all of our citizens is of paramount importance and should be second to none. Thank you for your work towards this end.
Sincerely,
Kenneth Rosenthal
President
KR/km
cc: Lukas Franck
Prepared by Kenneth Rosenthal, approved and signed in his absence.
This letter conveys my thoughts on the Draft Guidelines for
Accessible Public Rights-of-Way with respect to persons with
vision impairment. The installation of accessible pedestrian
signals (APS) along with detectable warnings at street crossings
will enable me to travel more safely. It is very important for
the APS to have a locator tone to help the visually impaired find
the pushbutton and that it have audible output to signal the onset
of the walk phase. The manner in which the accessible pedestrian
signal communicates to the blind pedestrian is important. The
current MUTCD allows the communication to be either tactile or
auditory. The sound levels produced by newer APS equipment
respond to ambient background level and can only be heard a short
distance from the pushbutton. They should not be audible to
neighboring residences and businesses. If members of the Access
Board receives comments from organizations that these sound levels
are not acceptable on a routine bases, then please consider having
the audible output be produced after continuously pressing the
pushbutton for three seconds. The APS equipment would communicate
that the auditory output has been activated by either briefly
vibrating the pushbutton or by giving a verbal message. Note that
a resolution supporting the three-second activation was ratified
at the July 2002 American Council of the Blind (ACB) national
convention in Houston. The three-second activation would
accomodate the members of the National Federation of the Blind
(NFB) who prefer vibro-tactile output without sound. An
accessible pedestrian signal does not reduce the safety of the
elderly or people with other types of disability. Indeed, if a
three-second activation is needed, they would learn its proper use
after reading the face plate of the pushbutton or after hearing a
public service announcement.
The installation of accessible pedestrian signals should be
routine rather than the exception since it is often necessary to
travel to locations which are scattered across several cities in
the area. City traffic engineers are often not responsive when
requests for accessible pedestrian signals are made by blind
persons from other cities. The routine installation of APS
equipment for new signalized intersections and the upgrading of
old signalized intersections when they finally need repair is very
important for the safety of visually impaired pedestrians. The
cost of implementing this recommendation is spread over a long
period of time since pushbuttons only fail after many years of
service. Although an APS is more expensive than an ordinary
pedestrian pushbutton at this time, its price would be appreciably
lowered when major manufactures compete to meet the demand created
by their routine installation. The Access Board can provide the
impetus to these manufacturers by requiring their routine
installation.
Accessible pedestrian signals now emit a variety of audible output
such as bird-call tones, verbal messages, and buzzing or clicking
sounds. Since the optimum auditory output for APS equipment is an
ongoing subject of research, it would be wise to require this
equipment to have a digital sound chip. When the optimum auditory
output is determined, the digital sound chip can easily be
reprogrammed to produce it. Otherwise, the equipment would have
to be replaced.
The detectable warning is also very helpful for pedestrian safety.
Some of the ramps in Menlo Park are so smooth that I have found
myself in the street without realizing it. A Crosswalk with
complex or unusual geometry often creates difficulties for
visually impaired pedestrians. It would be useful to have a guide
strip within the crosswalk or, alternatively, to have the material
within the crosswalk be easily distinguishable from the rest of
the pavement. The guideline which keeps signs from protruding
more than four inches from the pole from 27 to 80 inches
ground is also very much appreciated.
I hope one day to be able to approach any busy intersection with
the assurance that it is safe for me to cross it. Please retain
detectable warnings and the routine installation of accessible
pedestrian signals with audible output in the guidelines.
Thank you for the opportunity to convey my thoughts to you on this
important issue.
Sincerely,
Ezio Alviti
Thomas Cumings, October 29, 2002
My name is Thomas Cumings, and I am totally blind. I am writing to request that you keep in place and do not overturn the recommendations of the public right of way advisory committee to the U.S. Access Board regarding regarding detectable warnings and accessible pedestrian signals. I live in a large city, and the accessible trafic signals I use help me greatly in my travel. I support the regulations regarding these signals and detectable warnings.
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.
Destene Noller, October 14, 2002
I am writing to express my fervent support of accessible audible pedestrian signals and detectable warnings! Many years ago when most signals were simple two-way signals these things may not have been necessary, but now, in the fast paced world in which we live, where almost any major intersection is extremely complex with many lanes to cross and turners to be aware of; it would seem to me that making traffic signals accessible to all people is of utmost importance! We are not asking for anything more than what sighted people already have available to them all the time. I am horrified to think that there are those who would have you believe that to have the very same information that is already available to sighted people somehow compromises our dignity! I am totally blind, a very good and efficient traveler, and am looking forward with great anticipation to a day when I will not have to be surprised to find audible signals in the places where I travel. Audible and accessible pedestrian signals will become more and more necessary to the safety of all pedestrians as the amount of vehicle traffic continues to spiral higher and higher!
Thank you so much for taking the time to consider my comments!
Very Sincerely Yours,
Destene Noller
Kathryn Moore Ridley, October 21, 2002
I would like to provide my support for the accessible pedestrian signals. I have a sister who is blind and these are extremely useful for her and have helped her tremendously in the areas they exist. I also find them useful. I notice that drivers are more aware of pedestrians because of the noise.
Thank you for your attention to this matter.
Kathryn Moore Ridley
Albert Gayzagian, October 28, 2002
Having lived nearly all of my 76 years in a town which provides audible traffic signals, I know their value in enhancing pedestrian safety. I frankly resent the efforts of some blind people to limit or eliminate their availability, depriving those of us who benefit from these signals for whatever reasons move them to take these actions. Let those who don't want to use these signals ignore them if you like, but let those of us who find them helpful have the option to use them. My basic philosophy on this matter is that wherever sighted pedestrians are provided with information in a form accessible to them enhancing their safety, I should have the same information accessible to me to enhance mine. We ask for no more, no less. I appreciate the serious consideration which the Access Board is giving this matter and strongly urge that the Board approves the provisions which will give us a favorable result.
Albert Gayzagian
Jason Ewell, September 5, 2002
Please exercise restraint when implementing a policy requiring the installation of detectable warnings and so-called accessible pedestrian signals, formerly known as audible traffic lights. The Access Board is at a historical decision point. It can either take a bold stance recognizing that people with disabilities are competent human beings who would benefit most from proper training or it can buy into the generally held view in society that people with disabilities are little more than wards of the state.
The over-all accessibility movement will suffer a significant setback if the Access Board requires the ubiquitous installation of "accessible" pedestrian signals and detectable warnings. These technologies are neither essential for the blind to travel safely and efficiently nor to improve access to public rights of way. We are already crossing streets and negotiating dangerous areas without them. In fact, undue reliance on either technology will pose a definite hazard for blind pedestrians because many will perceive these technologies as diminishing the need for proper travel training and alertness to the immediate environment.
The cost to society of installing detectable warnings and "accessible pedestrian signals at every intersection is simply too high--especially, when one realizes that they do not improve accessibility. Perhaps they may address some issues of safety, but the public rights of way are already accessible to the blind. Please do not mix issues of safety with accessibility. You are an Access Board?not the National Highway Safety Administration, and as such, your attention should be focused solely on accessibility.
Yours sincerely,
Jason Ewell
Comments to: Draft of Recommendations of The Access Board on Pedestrian Crosswalks At Roundabouts
Dear Committee Members:
I am since ten years a professor of transportation engineering in the United States. My training was in Sweden where I in 1982 presented my Ph.D.-thesis on Pedestrian Safety at Signalized Intersections. I have worked on research relating to pedestrian safety for 25+ years and parallel to this on roundabout safety for 20+ years and would like to give some comments to your proposed guidelines.
It seems like you write that wherever marked (and possibly unmarked) pedestrian crosswalks are provided at roundabouts, each shall meet the requirements set forth in this section, including: (C) Signals. A pedestrian actuated traffic signal complying with Section ? shall be provided for each segment of the crosswalk, including at the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.
I will comment on this below, in connection to some direct comments to your discussion section. But first, inhttp://www.access-board.gov/rowdraft.htm#1106 you write, "Requiring the signal to be pedestrian activated may help limit the impact on traffic flow." In reality this may be true, but shouldn't the responsibility of lawmakers include that the code be made to be followed? Through education and/or enforcement activities if necessary? As far as I know, pedestrians, in all U.S. states, have the right-of-way in unsignalized marked crosswalks. In other words, the primary purpose of signalizing marked crosswalks should be to give automobile drivers the right-of-way part of the time so that automobile capacity does not become too low where pedestrian flows are high. In Germany, and some other European countries, this is clearly understood and given as the primary reason for signalizing crosswalks. Still, I acknowledge that we in the U.S. live in a country were many drivers do not stop for pedestrians in crosswalks, even for those carrying white canes, and I understand that we may have to 'accommodate' such illegal behavior, and have designs that make it reasonably safe for all pedestrians, including those in wheelchair or visually impaired, even when divers violate codes.
In Discussion (http://www.access-board.gov/prowac/commrept/part3-02-5.htm) you write:
"Modern roundabouts are ?. While this traffic pattern has been an asset to traffic planners in controlling and slowing the flow of traffic at intersections in lieu of having a signalized intersection, the absence of stopped traffic presents a major problem for blind and visually impaired pedestrians when crossing."
I would like that statement to be backed by facts in the form of crash statistics. If it were (only) a perceived "major problem" rather than an actual problem, then maybe education rather than engineering changes would be motivated. I do know that the 'sole' serious opposition to roundabouts in Sweden today stems from visually impaired people and their advocacy groups, and I do not mean that this is not a very important subgroup of the pedestrian population, but still, sub-optimization of our traffic environment is one of the reasons that the risk of fatality per mile walked is about ten times higher in the United States than in Sweden, where roundabouts are utilized frequently in the urban environment. I also know that signalized crosswalks or grade-separated passages are considered at roundabouts in Sweden, where there is a high demand by visually impaired pedestrians? But, to require signalization of all roundabouts is, in my opinion, definitely unwarranted. At least, it is my opinion, that all crosswalk locations away from roundabouts should be signalized prior to the ones adjacent to single-lane roundabouts getting this type of control.
Rather, you should consider requiring signalization of marked crosswalks (or grade-separated crossings) at multi-lane locations including at multi-lane roundabouts with high pedestrian volumes. I am fairly convinced that there is no crash data from the U.S. supporting the view that pedestrians are vulnerable to crashes at single-lane roundabouts. The only pedestrian crash at a U.S. roundabout was, as far as I know, the elderly person hit in Montpelier, VT, and that did not cause any serious injury. Rather, the roundabout prevented the injury. There is statistics from Sweden, showing that 'all' the country's (»700) single-lane roundabouts had a total of three pedestrian crashes (with not a single serious injury) in the 1994 to 1997 period. (Today there are a lot more roundabouts in Sweden, but I do not have any newer statistics.) If these locations had been signalized, there would have been at least 11 pedestrian crashes according to standard models. However, the two-lane roundabouts studied, had an actual safety very similar to signalized locations (10.4 predicted and 12 occurred at the 14 locations in Sweden that have considerable pedestrian traffic.)
You write: "Barriers or similarly distinct elements are needed to prevent blind persons from inadvertently crossing a roundabout roadway in an unsafe location. ? Because the pedestrian crosswalk is generally placed at least one car length from the entry point, in a location that is not immediately apparent to a blind or visually impaired pedestrian, a cue is needed for crosswalk location."
Again, I have no objection to the idea that pedestrians are guided to safe crossing points, but crossing outside the crosswalk at a roundabout is probably safer than crossing anywhere away from a roundabout, so there should be million of miles of barriers put up prior to the ones at roundabouts.
You write, "Pedestrians report that vehicles at roundabouts, right slip lanes, and other unsignalized pedestrian crosswalks often do not yield for pedestrians. Pedestrians with disabilities are particularly vulnerable in these situations. People who are blind or visually impaired are unable to make eye contact with drivers making it impossible to 'claim the intersection.' The driver's view of people using wheelchairs is often blocked by other vehicles. Pedestrians with slower than normal mobility may hesitate when entering the street. All of these situations may result in drivers misinterpreting the pedestrian's intention to cross."
I agree, but this is even truer away from roundabouts at non-signalized locations.
You write, "It is recognized, however, that the purpose of these types of unsignalized crosswalks is to keep traffic moving as continuously as possible."
That is one reason for constructing roundabouts, but I have for over a decade advocated the use of roundabouts for the primary purpose of improving pedestrian safety. That delays are reduces is a side effect rather than the primary purpose in my way of thinking.
You write, "Traffic flow can be achieved, while still affording pedestrians with disabilities the opportunity to cross safely, with the use of pedestrian actuated technologies that halt traffic only while the pedestrian is in the crosswalk. An advantage of passive detectors is that, when pedestrians cross slowly, more time can be automatically provided. When a pedestrian crosses quickly, the traffic is stopped only during the time the pedestrian is crossing, thereby eliminating the problem of traffic being held up when no pedestrian is in the crosswalk."
I agree fully with this strategy. Wherever it is economically feasible, I support the use of passive or active detection and stoplights. But, again, roundabouts should not be the first place to implement such systems.
I recently studied the safety of pedestrians at over a hundred locations in Maine. I counted pedestrian and vehicle volumes and predicted how many crashes there ought to have been if the layout was 'typical' (according to TRL models from England and VTI models from Sweden, which in parenthesis gave very similar results) and compared these estimates to actual crash experience involving pedestrians. I found that the risk of a pedestrian collision is
- roughly 25 times the 'average' where pedestrians cross multi-lane streets at unmarked locations with 25 mph speed limits but actual speeds around 30 to 40 mph
- roughly 10 times the 'average' where pedestrians cross multi-lane streets in marked crosswalks with 25 mph speed limits but actual speeds around 30 to 40 mph
- roughly 4 times the 'average' where pedestrians cross multi-lane streets at unmarked locations with 25 mph speed limits but actual speeds around 25 mph
- roughly 2.5 times the 'average' where pedestrians cross multi-lane streets in marked crosswalks with 25 mph speed limits but actual speeds around 25 mph
- signalization of the above listed locations reduces the risks by roughly 50%
- roughly half the 'average' where pedestrians cross 2-lane streets as an average for all speeds if the street is posted as 25 mph
- extremely low risk where pedestrians cross 2-lane streets in marked or unmarked crosswalks with 25 mph speed limits but actual speeds around 20 mph
There were no multi-lane streets with actual speeds below 25 mph.
All the figures above include visually impaired people but are not specifically true for that group by itself. In summary, 4- and 6-lane streets are very dangerous where speeds are high. Signalization reduces the risk, but the risk is still much higher than at a narrow low-speed location, especially since many of the crashes still occur at very high speeds (jaywalkers or drivers running red lights account for over 50% of the pedestrian crashes). For example, the risk of a pedestrian collision is about 5 to 12 times higher than 'average' at a signalized 4-lane crosswalk if cars are driven at 30 mph whereas it is maybe 20% of the average in the vicinity of a single-lane roundabout (2-lane street) handling the same traffic volume. That is a difference of roughly 50 times. And that is risk of collision, not risk of serious injury or fatality. The risk of fatality, for Maine streets and roads, vary as seen in the table here. In other words, the roundabout may be more than 50 times safer than the signalization.
Table 1 Speed limit and crash severity, Maine data
In conclusion to my comments. I may be wrong in my assessment that non-signalized crosswalks adjacent to roundabouts are very safe for visually impaired people. And I do not want to advocate accepting collateral damage. But, if the design procedures suggested here means that roundabouts will not be constructed, and this means that we will 'keep' signalization and see 500 additional pedestrian fatalities a year compared to if roundabouts were utilized, which would have led to (annually) one visually impaired person being killed at a roundabout, should we then celebrate the saving of that one life at a cost of 500? Maybe? But, what if I am correct, and there will not be any additional deaths among visually impaired people, and the result of this practice will be 500 more pedestrian fatalities and not a single saved life? Then we should feel bad about our choice, shouldn't we? Especially since some of the 500 will be visually impaired people.
Roundabouts are not the only way of slowing down traffic. There are other traffic-calming methods that can be used. Unfortunately, the experience with signalization as a traffic calmer is not encouraging. Even if the mean speeds are reduced, the top speeds are very high. And some of those top speeds are found just after the perpendicular walk signal indicates a clear crossing. And, what the roundabout has in its favor that most other traffic-calming measures don't have is that it allows for narrow streets, something very important for elderly pedestrians' safety.
Now, as my last words, if the suggested design criteria lead to no reduction in the rate of constructing roundabouts, and the proposed signals are such that pedestrians have the absolute right-of-way both when the signal is activated and deactivated (as is the formal rule today if they go blank) then the signalization should cause no bad safety-effects and we would all be winners. My concern is that the cost for such systems will be prohibitive, and the construction of roundabouts will be delayed.
Thank you for listening to my thoughts,
Per Gårder, Professor
Department of Civil Engineering
University of Maine
Christie Gilson, MSW, September 10, 2002
I would like to register my strong support for both detectable warnings at train platforms and accessible pedestrian signals at busy vehicular intersections. Having already been hit once as a blind pedestrian, I can vouch in a very real and personal way for the fear and, sometimes, panic, that I experience when crossing busy intersections. Thankfully, my town has recently installed accessible pedestrian signals at three local intersections, but many, many more are needed.
It would be a shame, in my opinion, if the Access Board failed to recognize the pivotal role that such technology plays in the lives of blind Americans. Please endorse these options which only increase the safety and independence of blind people. I thank you for your consideration of my request.
Sincerely,
Christie Gilson, MSW
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
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
Walter Siren, October 28, 2002
I am pleased to submit the following comments on the Draft Guidelines for Accessible Public Rights-Of-Way, which were issued on June 17, 2002.
I am blind, and for this reason, the Draft Guidelines for Accessible Public Rights-Of-Way proposed by the Access Board are of great interest to me.
By way of general comment, I want to let the Access Board know that I support the recommendations contained in this draft, and I believe that their implementation would make travel on public ways much safer for people who are blind and visually impaired. In the paragraphs that follow, Iwill state some of the proposals which I believe have the greatest impact on pedestrians who are blind and visually impaired and provide my comments there on.
Section 1104 Curb Ramps And Blended Transitions
I concurs with the Access Board's recommended guidelines with regard to curb ramps and blended transitions. Of particular interest is the requirement in Section 1104.3.2 that detectable warning surfaces be provided wherever a curb ramp, landing, or blended transition connects to a crosswalk. I strongly support this requirement, and would urge the Access Board to retain it without exception. If detectable warning surfaces are to be incorporated into the public right-of-way in an effective manner, their application must be consistent. I believe that their use as a means of indicating to the visually impaired pedestrian that they are approaching an area in which traffic is likely to be moving is reasonable and will enhance the safety of such pedestrians. The suggestion that detectable warnings should only be installed where the slope of a curb ramp is 1:15
Section 1105 Pedestrian Crossings
1105.4 Medians and Pedestrian Refuge Islands: I support the requirement for installation of detectable warnings on medians and pedestrian refuge islands set forth in 1105.4.2. I concur with the Board's conclusion that an exception is appropriate for islands where the crossing is controlled by signals which are timed for full crossing.
1105.6 Roundabouts: I supports the recommendations in 1105.6.1 that barriers be provided at roundabouts, along the street side of the sidewalk where pedestrian crossing is prohibited. Further, ACB concurs with the Board's recommendation that pedestrian activated traffic signals complying with 1106 be provided for each segment of the crosswalk, including the splitter island, as indicated in 1105.6.2. This appears to be the only feasible means of giving blind and visually impaired pedestrians safe access to the crosswalks at roundabouts, while causing a minimal interference with the flow of traffic on the roundabout. It is important that at these intersections, as well as at those intersections where a pedestrian crosswalk is provided at a right or left turn slip lane, a pedestrian activated traffic signal that complies with 1106 is provided for each segment of the pedestrian crosswalk, including the island.
Section 1106 Accessible Pedestrian Signal Systems
I support the requirement that each crosswalk with pedestrian signal indication shall have a signal device which gives audible and vibrotactile indications of the walk interval. I agree with the Board that care should be exercised in the location of pedestrian push buttons to insure that, to the maximum extent feasible, push buttons for accessible pedestrian signals will be positioned where they can be located and activated by the pedestrian while leaving sufficient opportunity for the pedestrian to reach the curb in time to respond to the walk interval indication.
As an aid to this process, the locator tone required by 1106.3.2 is essential. In addition to alerting the visually impaired pedestrian to the presence of the push button, it draws the attention of non-disabled pedestrians to the push button, as well, increasing the likelihood of safer street crossings overall. In addition, as the locator tone becomes consistently incorporated into accessible pedestrian signal systems, the visually impaired pedestrian will have the benefit of knowing that further accessible information is forthcoming as a result of his/her activation of the push button. Since these tones are only audible at close range, if the recommended guidelines are followed correctly, they will not be disruptive to the surrounding community. Therefore, we believe their benefits far outweigh the minimal impact they may have on the environment.
I thank the Access Board for including specifications for pedestrian push buttons in 1106.3.3 regarding size and contrast. These specifications are important to facilitate their use by people who have low vision.
I believe that sections 1106.3.4 through section 1106.4.3 should be incorporated into the Access Board's rule in their entirety. These sections contain well-reasoned guidelines regarding the manner in which visually impaired individuals should be able to effectively access information about signal phases, as well as street identification and intersection design. It is essential that accessible pedestrian signals convey this information in a manner that is unambiguous and we believe these guidelines will accomplish this.
Section 1108 Detectable Warnings
I support the Access Board's guidelines for the location and installation of detectable warning surfaces, as set forth in this section. I believe that the specifications contained herein minimize the accessibility concerns of persons who have mobility impairments, while greatly enhancing the ability of visually impaired people to access the public right-of-way in a safe manner.
As automobiles become quieter and traffic patterns become more complex, it becomes increasingly difficult, and unsafe, to rely upon the traditional sound of the traffic as the only means of determining when and where to cross streets. Pedestrians who do not have visual impairments are aided by signage and other visual cues for which people who are blind must compensate. It is my view that the Americans with Disabilities Act requires communities to take all reasonable steps to insure that people who are blind have access to the same information they provide to the general public. The guidelines recommended here represent a thoughtful and reasonable attempt to assist communities in carrying out that responsibility and I urge the Access Board to incorporate these guidelines into a rule for accessible public rights-of-way.
Thank you very much for your consideration.
Walter
John W. Van Winkle, P.E., October 25, 2002
To the Access Board of the Office of Technical and Informational Services:
I am writing in regards to the proposed guidelines for accessible rights of way. I am in full agreement with the comments expressed by the Tennessee Section of the Institute of Transportation Engineers, which I have attached.
I would also like to add comments regarding the section on roundabouts. The recommendation to require pedestrian-actuated crossing signals and continuous barriers at roundabouts seems impractical and inconsistent. In many cases, roundabouts are built to eliminate the need for signalization. To require signals at a roundabout is contrary to this intended goal.
If pedestrian signals and barriers are to be required for roundabouts, why would they not be required for all pedestrian crosswalks? A crosswalk at a roundabout approach is very similar to a crosswalk at any channelized T-intersection or, for that matter, any midblock crosswalk. In the case of a midblock crosswalk, the conditions are actually more hazardous for pedestrians in one respect because the speeds are higher.
I recommend that this section on roundabouts be deleted from the guidelines
or at least amended to be a recommendation, rather than a requirement.
John W. Van Winkle, P.E.
District 5 President of ITE
City Traffic Engineer
Chattanooga, Tennessee
TENNESSEE SECTION, INSTITUTE OF TRANSPORTATION ENGINEERS
RESOLUTION
POSITION OF THE DRAFT "GUIDELINES FOR ACCESSIBLE RIGHTS-OF-WAY"
WHEREAS, the Tennessee Section of the Institute of Transportation Engineers is a professional organization of over 250 persons who are actively involved in the field of transportation and who share a common interest in improving the quality of the surface transportation system in Tennessee; and
WHEREAS, the mission of the Tennessee Section of the Institute of Transportation Engineers (TSITE) is the professional development and growth of the traffic and transportation industry, promoting safe and efficient flow of people, goods and services; and
WHEREAS, the membership of the Tennessee Section of the Institute of Transportation Engineers represent the local government agencies who will be most impacted by the proposed "Guidelines for Accessible Rights-of-Way" developed by The Access Board; and
WHEREAS, a review of the draft "Guidelines for Accessible Rights-of-Way" was conducted and the Tennessee Section of the Institute of Transportation Engineers desired to make its comments and concerns known to The Access Board since its membership will be directly impacted by the proposed guidelines and responsible for implementing many of its recommendations; and
WHEREAS, the Tennessee Section of the Institute of Transportation Engineers shares The Access Board's desire to ensure that access for persons with disabilities is provided within the public right-of-way and that the same degree of convenience, connection, and safety afforded the public generally is available to pedestrians with disabilities. However, we are concerned that the proposed guidelines do not take into account the negative impacts and in some cases extreme impacts to the primary users of the public right-of-way, the motorist; and
THEREFORE, the Tennessee Section of the Institute of Transportation Engineers would like to provide the following comments for consideration by The Access Board when developing the final "Guidelines for Accessible Rights-of-Way":
1. What types of improvements or maintenance activities will trigger any requirements for accessibility improvements? Will filling potholes, making spot drainage improvements, upgrading signal displays, recutting vehicle detector loops, restriping a roadway require accessibility improvements? The types of activities need to be clarified.
2. What accessibility improvements should reasonably be expected to be made when the trigger is activated?" What is meant by the phrases "technically infeasible" and "maximum extent feasible?" These need to be defined and clarified so that reasonable requirements are made by the Access Board and not by the Court system.
3. Alternate Circulation Paths - The guidelines call for an alternate circulation path parallel to and on the same side of the street as the disrupted pedestrian access route, however, this is not always possible. This requirement also gives no guidance as to the amount of time the closure may take place without requiring an alternate route. Would utility work in a manhole for 1 hour require the construction of an alternate access route? How can existing sidewalks be brought up to the proposed standards if they can't be closed for a day? The phrase "other temporary conditions" appears to be vague and could mean just about anything to a potential litigant. Further clarification on these issues needs to be provided.
4. Cross Slope of Crosswalks - The guidelines call for the cross slope of cross walks to be 1:48
5. Curb Ramps - The guidelines discourage diagonal curb ramps at intersections. While it may be possible to design new intersections to accommodate single ramps for each crosswalk, reconfiguring many existing intersections with new ramps would require complete reconstruction of the roadway including moving crosswalks, parking, signals, etc. In addition, some intersections may function better for both pedestrians and motorists by using diagonal ramps. We recommend including diagonal ramps in the guidelines as an acceptable option for use in appropriate situations and encouraging the use of single ramps at newly designed intersections.
6. Pedestrian Signal Phase Timing - The guidelines change the pedestrian signal timing by using a walking speed of 3.0 feet
7. Channelized Turn Lanes at Intersections - The guidelines will require a pedestrian activated traffic signal for each segment of the pedestrian crosswalk, including across the channelized turn lane. The impact of this requirement will be devastating to capacity at many intersections. Signalizing these locations may actually decrease the safety of pedestrians and vehicles because the signals are likely to be ignored by many drivers. We recommend deleting this requirement from the proposed guidelines.
8. Accessible Pedestrian Signal Systems - The guidelines will require the installation of Accessible Pedestrian Signal systems at all existing signalized intersections with pedestrian indications. The costs of these devices will be a tremendous burden on already strapped traffic engineering agencies. These requirements appear to be overkill by providing these expensive and untested devices at all intersections, regardless of the need. We recommend retaining the MUTCD requirements until studies prove the safety benefits of these devices.
WHEREAS, the Tennessee Section of the Institute of Transportation Engineers understands the need for standards related to access for disabled pedestrians, however, we have serious concerns about the impacts of the proposed guidelines and believe that some are not realistic or cost effective and that revisions to the draft guidelines are necessary.
NOW, THEREFORE, BE IT RESOLVED, that the Tennessee Section of the Institute of Transportation Engineers submits these comments listed above for consideration and requests that serious consideration be given to the issues raised; and
BE IT FURTHER RESOLVED that the Tennessee Section Institute of Transportation Engineers Board of Directors directs that these recommendations be submitted to the US Access Board on or before October 28, 2002.
APPROVED: Cindy Pionke, P.E., President
Anthony Todd, Vice President
Bill Kervin, P.E., Secretary-Treasurer
Craig Hanchey, P.E., PTOE, Immediate Past President
___________________________________ __________________
Craig Hanchey, P.E., PTOE Date
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.
Morgan Henderson, M.Ed., October 26, 2002
Our company, Young Opportunities Ltd., providers of access technology equipment, training, and workplace consulting for those who are low vision or blind, are writing in strong support of accessible pedestrian signals and detectable warnings as recommended by the Public Right of Way Advisory Committee to the U.S. Access Board.
Every two weeks, a blind or low vision pedestrian crossing the street is struck and killed by a motor vehicle. Please install detectable warning signals, as well as overhead pedestrian bridges at intersections.
Thank you,
Morgan Henderson, M.Ed.
President, Young Opportunities Ltd and the
Access Technology Learning Center
Betsy A. Zaborowski, Psy.D., August 26, 2002
I write this letter to urge the Access Board to exercise restraint with respect to detectable warnings and "accessible" pedestrian signals. These technologies are not universally accepted within the blind community. Automated teller machines with voice prompts, raised letters on hotel room doors, and tactile and audible information in elevators enjoy far more unanimous support.
The over-all accessibility movement will suffer a significant setback if the Access Board requires the ubiquitous installation of "accessible" pedestrian signals and detectable warnings. These technologies are neither essential for the blind to travel safely and efficiently nor to improve access to public rights of way. We are already crossing streets and negotiating dangerous areas without them. In fact, we argue that undue reliance on either technology will pose a definite hazard for blind pedestrians because many will perceive these technologies as diminishing the need for proper travel training and alertness to the surrounding environment.
The cost to society of installing detectable warnings and "accessible" pedestrian signals at every intersection is simply too high--especially, when one realizes that they do not improve accessibility. Perhaps they may address some issues of safety, but The public rights of way are already accessible to the blind. Please do not mix issues of safety with accessibility. You are an Access Board--not the National Highway Safety Administration, and as such, your attention should be focused solely on accessibility.
Yours sincerely,
Betsy A. Zaborowski, Psy.D.
Director of Special Programs
National Federation of the Blind
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
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
Rox'E M. Homstad, October 9, 2002
I am writing in support of the guidelines set forth in the PROWAC report. As a deafblind service dog user, I firmly believe that Accessible traffic signals and detectable warnings will help me and others like me navigate much more safely and independently. Sighted drivers have visible traffic signals such as stop lights. We, the blind and deafblind deserve no less.
It has come to my attention that some members of the NFB, National Federation of the blind,have said that to install accessible pedestrian signals would cost tax payers money, and that the tax payers will then come to resent the blind there by resulting in lack of hiring opportunities. This simply isn't true. Most sighted people I have spoken with are in support of accessible pedestrian signals, and they admit that their installation on street corners helps them as well, by making them more aware.
Respectfully,
Rox'E M. Homstad
L. Dianne Ketts, COMS, CLVT, October 28, 2002
My name is L. Dianne Ketts. I hold a certification in Orientation & Mobility (O&M) and in Low Vision Therapy with the Academy for Certification of Vision Rehabilitation & Education Professionals. I serve as a member of the Environmental Access Committee of the Orientation and Mobility Division of AERBVI (the Association for Education and Rehabilitation of the Blind and Visually Impaired.) I am currently employed at CITE, Inc. in Orlando, Florida as the O&M and Low Vision Programs Coordinator. Please accept my comments on the Draft Public Rights-of-Way Accessibility Guidelines.
Curb Ramps and Blended Transitions (1104)
Detectable Warning (1104.3.2)
I support inclusion of specifications in the draft guidelines for detectable warnings (1108 Detectable Warning Surfaces) and urge The Board to include requirements for detectable warnings at ALL slopes and curb ramps where a pedestrian way intersects with a vehicular way regardless of grade.
Rationale: In my experience as an orientation and mobility instructor of visually impaired adults, even slopes greater than that of 1:15
Pedestrian Signal Phase Timing (1105.3)
I support The Board's draft guideline for Pedestrian Signal Phase Timing (1105.3) stating that "signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Rationale: Because I serve many senior individuals and persons with other mobility impairments in addition to their vision loss, I often consider the benefit that a longer walk and pedestrian clearance phase would offer. Many clients I serve are not able to complete the crossing of multiple lanes of traffic in the normally allotted time of 4.0 feet
Medians and Pedestrian Refuge Islands - Detectable Warnings (1105.4.2)
I do not support the EXCEPTION to this recommended guideline stating that "Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing." It is my recommendation that this EXCEPTION be removed from the proposed guidelines.
Rationale: Detectable warnings located at a median or refuge island give the visually impaired or blind pedestrian critical information regarding their location in relation to the crossing. The presence of detectable warnings may inform the pedestrian that the island is a place of refuge where they could possibly stop and rest if it were necessary. This may be especially important for a pedestrian who moves more slowly or with more difficulty.
Turn Lanes at Intersections (1105.7)
I whole heartedly support the recommendation for pedestrian activated traffic signals at these locations.
Accessible Pedestrian Signals - General (1106.1)
I support the inclusion of specifications for Accessible Pedestrian Signal (APS) systems.
Rationale: Many intersections in the central Florida area are typical of intersections that can be found throughout the country. Minor, lightly traveled streets often intersect with major arteries. When a visually impaired pedestrian's intention is to cross the major artery, there is often little or no parallel traffic movement on the minor street to indicate that it is the appropriate time for the pedestrian to begin crossing. Accessible Pedestrian Signal technology provides information critical to determining when to begin a crossing in a format that is accessible to the visually impaired pedestrian.
I recommend that The Board use the term "Accessible Pedestrian Signal (APS)" when referring to these types of devices as opposed to "pedestrian signal systems" or "pedestrian signal devices."
Rationale: This terminology would more closely match the language in the MUTCD and current terminology. As a result, engineers and others utilizing the MUTCD when building public rights-of-way will be less likely to encounter conflicting or misguiding terminology.
Detectable Warning Surfaces (1108)
As I stated above, I support the inclusion of specifications for detectable warning surfaces.
Once again, thank you for the opportunity to comment.
L. Dianne Ketts, COMS, CLVT
CITE, Inc.
Norma A. Boge, October 16, 2002
Dear Sir/Madam:
I am Norma A. Boge, a member of the American Council of the Blind. I am writing in support of accessible pedestrian signals. As a person who is totally blind, such signals offer me an extra level of safety when I am crossing streets. It is true that such signals are not a replacement for good skills of orientation and mobility. However, the traning offered in such skill areas is not consistent across the United States. Thus, not all blind persons have a high level of orientation and mobility. But, despite the level of training, all blind persons have the right to information provided to sighted pedestrians; i.e. Don't Walk, Walk, etc. Each year, there are many injuries and even some deaths resulting from blind pedestrians attempting to perform the simple task of crossing a street. Certainly, accessible pedestrian signals will not prevent all such accidents. But, blind and visually impaired pedestrians should be able to take advantage of such safety features of the built environment, in much the same way drivers use stop lights.
I encourage you and your colleagues to not be swayed by the arguments of some groups which say that blind people do not need accessible pedestrian signals. This is not true!! We do need them, and it is important that the Access Board realize that what the sighted public may think of a blind person using an accessible signal is not important. What is important, however, is to foster the independence and safety of those of us who travel independently.
Thank you.
Norma A. Boge
David Treveno and Members of the Mid-Tennessee Council of the Blind, October 11, 2002
The names and addresses listed in the signature of this letter are the members of the Mid-Tennessee Council of the Blind. Our chapter is located in Nashville, Tennessee, although a couple of our members live outside the immediate area.
We all strongly agree with the report and recommendations of the Public Rights of Way Advisory Committee, particularly where detectable warnings and accessible pedestrian signals are concerned. We feel that they greatly increase both the safety and independence of blind and visually impaired pedestrians.
A DETECTABLE WARNING IS THE TACTILE EQUIVALENT OF A FLASHING SIGN.
It instantly focuses the pedestrian's attention as nothing else can. The warnings can be easily and independently detected by blind pedestrians. We find them particularly helpful at intersections where
street boundaries are unclear. there are intersections in Nashville, like Gallatin Road and East Webster Avenue, where it is difficult to determine where the sidewalk ends and the street begins. In addition, the warnings are essential on approaches to subway entrances. It's a really scary experience when one goes to a city with a subway system and nearly falls into the pit. Unfortunately, a number of blind people have actually fallen in and were killed or seriously injured.
Accessible pedestrian signals produce clear audio tones that sound when the light is in the pedestrian's favor. This information makes it much easier for us to negotiate busy intersections like 5th Avenue and Deadrick Street and move quickly and safely toward our destination. Some signals, like the one at 42nd and Charlotte go a step further. They have a button that the pedestrian can push to change the light.
Installing detectable warnings and accessible pedestrian signals will allow both drivers and pedestrians to use our streets safely and efficiently. We urge you to carefully consider all the comments submitted, and decide in favor of saving lives by adopting the recommendations in the Public Rights of Way Advisory Committee's report. Thank you for your time and attention.
Sincerely,
Nathan Baker
[address]
Sonny Bennett
[address]
Hattie Bond
[address]
Sylvia Bradley
[address]
Stanley Coe
[address]
Bobby Cowan
[address]
Jacqueline Davis
[address]
Tennie Dietsch,
[address]
Brenda Dillon
[address]
Dan Dillon
[address]
Barbara Fitts
[address]
Carolyn Fitts
[address]
Evelyn Flippin
[address]
Carol Francisco
[address]
Orlando Francisco
[address]
Darlene Gann
[address]
Jill Garvey,
[address]
James Hardison
[address]
Phillip Hebert
[address]
Cary Johnson
[address]
Kathy Lamb
[address]
Joan Ledbetter
[address]
Tammy Maynard
[address]
Herbert Mooneyham
[address]
Janie Mooneyham
[address]
Irene Morgan
[address]
Marie Roberts
[address]
Selin Saldona
[address]
Gladys Sharp
[address]
Delois Smith
[address]
Maggie Thomas
[address]
David Treveno
[address]
Mozelle Wakefield
[address]
Jean Ward
[address]
Hulen Walker
[address]
Sherri Williams
[address]
Roslyn Williamson,
[address]
Dr. Raymond F. Keith, October 27, 2002
I wish to submit the following comments on the Draft Guidelines for Accessible Public Rights-Of-Way, which were issued on June 17, 2002.
I am totally blind and have travelled with relative independence throughout this country and in many other countries of the world.
I have experienced the benefits of some of the technology referred to in these proposals, and know that they would be of great benefit to thousands of people in this country. My comments echo those of the American Council of the Blind, a national membership organization of people who are blind and visually impaired. By way of general comment, I want to let the Access Board know that I support the recommendations contained in this draft, and I believe that their implementation would make travel on public ways much safer for people who are blind and visually impaired. In the paragraphs that follow, I will highlight some of the proposals which I believe have the greatest impact on pedestrians who are blind and visually impaired and provide comments thereon.
Section 1104 Curb Ramps And Blended Transitions
I concur with the Access Board's recommended guidelines with regard to curb ramps and blended transitions. Of particular interest is the requirement in Section 1104.3.2 that detectable warning surfaces be provided wherever a curb ramp, landing, or blended transition connects to a crosswalk. I strongly support this requirement, and would urge the Access Board to retain it without exception. If detectable warning surfaces are to be incorporated into the public right-of-way in an effective manner, their application must be consistent. I believe that their use as a means of indicating to the visually impaired pedestrian that they are approaching an area in which traffic is likely to be moving is reasonable and will enhance the safety of such pedestrians. The suggestion that detectable warnings should only be installed where the slope of a curb ramp is 1:15
Section 1105 Pedestrian Crossings
1105.4 Medians and Pedestrian Refuge Islands: I support the requirement for installation of detectable warnings on medians
and pedestrian refuge islands set forth in 1105.4.2. I concur
with the Board's conclusion that an exception is appropriate for islands where the crossing is controlled by signals which are timed for full crossing.
1105.6 Roundabouts: I support the recommendations in 1105.6.1 that barriers be provided at roundabouts, along the street side of the sidewalk where pedestrian crossing is prohibited.
Further, I concur with the Board's recommendation that pedestrian activated traffic signals complying with 1106 be provided for each segment of the crosswalk, including the splitter island, as indicated in 1105.6.2. This appears to be the only feasible means of giving blind and visually impaired pedestrians safe access to the crosswalks at roundabouts, while causing a minimal interference with the flow of traffic on the roundabout. It is important that at these intersections, as well as at those intersections where a pedestrian crosswalk is provided at a right or left turn slip lane, a pedestrian activated traffic signal that complies with 1106 is provided for each segment of the pedestrian crosswalk, including the island.
Section 1106 Accessible Pedestrian Signal Systems
I support the requirement that each crosswalk with pedestrian signal indication shall have a signal device which gives audible and vibrotactile indications of the walk interval. I agree with the Board that care should be exercised in the location of pedestrian push buttons to insure that, to the maximum extent feasible, push buttons for accessible pedestrian signals will be positioned where they can be located and activated by the pedestrian while leaving sufficient opportunity for the pedestrian to reach the curb in time to respond to the walk interval indication.
As an aid to this process, the locator tone required by 1106.3.2 is essential. In addition to alerting the visually impaired pedestrian to the presence of the push button, it draws the attention of non-disabled pedestrians to the push button, as well, increasing the likelihood of safer street crossings overall. In addition, as the locator tone becomes consistently incorporated into accessible pedestrian signal systems, the visually impaired pedestrian will have the benefit of knowing that further accessible information is forthcoming as a result of his/her activation of the push button. Since these tones are only audible at close range, if the recommended guidelines are followed correctly, they will not be disruptive to the surrounding community. Therefore, I believe their benefits far outweigh the minimal impact they may have on the environment.
I thank the Access Board for including specifications for pedestrian push buttons in 1106.3.3 regarding size and contrast.
These specifications are important to facilitate their use by people who have low vision.
I believe that sections 1106.3.4 through section 1106.4.3 should be incorporated into the Access Board's rule in their entirety.
These sections contain well-reasoned guidelines regarding the manner in which visually impaired individuals should be able to effectively access information about signal phases, as well as street identification and intersection design. It is essential that accessible pedestrian signals convey this information in a manner that is unambiguous and I believe these guidelines will accomplish this.
Section 1108 Detectable Warnings
I support the Access Board's guidelines for the location and installation of detectable warning surfaces, as set forth in this section. I believe that the specifications contained herein minimize the accessibility concerns of persons who have mobility impairments, while greatly enhancing the ability of visually impaired people to access the public right-of-way in a safe manner.
As automobiles become quieter and traffic patterns become more complex, it becomes increasingly difficult, and unsafe, to rely upon the traditional sound of the traffic as the only means of determining when and where to cross streets. Pedestrians who do not have visual impairments are aided by signage and other visual cues for which people who are blind must compensate. It is my view that the Americans with Disabilities Act requires communities to take all reasonable steps to insure that people who are blind have access to the same information they provide to the general public. The guidelines recommended here represent a thoughtful and reasonable attempt to assist communities in carrying out that responsibility and I urge the Access Board to incorporate these guidelines into a rule for accessible public rights-of-way.
Thank you very much for your consideration.
Sincerely,
Raymond Keith
Craig Hanchey, P.E., P.T.O.E., October 25, 2002
TENNESSEE SECTION, INSTITUTE OF TRANSPORTATION ENGINEERS
RESOLUTION
POSITION ON THE DRAFT "GUIDELINES FOR ACCESSIBLE RIGHTS-OF-WAY"
WHEREAS, the Tennessee Section of the Institute of Transportation Engineers is a professional organization of over 250 persons who are actively involved in the field of transportation and who share a common interest improving the quality of the surface transportation system in Tennessee; and
WHEREAS, the mission of the Tennessee Section of the Institute of Transportation Engineers (TSITE) is the professional development and growth of the traffic and transportation industry, promoting safe and efficient flow of people, goods and services; and
WHEREAS, the membership of the Tennessee Section of the Institute of Transportation Engineers represent the local government agencies who will be most impacted by the proposed "Guidelines for Accessible Rights-of-Way" developed by the Access Board; and
WHEREAS, a review of the draft "Guidelines for Accessible Rights-of-Way" was conducted and the Tennessee Section of the Institute of Transportation Engineers desired to make its comments and concerns known to the Access Board since its membership will be directly impacted by the proposed guidelines and responsible for implementing many of its recommendations; and
WHEREAS, the Tennessee Section of the Institute of Transportation Engineers shares the Access Board's desire to ensure that access for persons with disabilities is provided within the public right-of-way and that the same degree of convenience, connection, and safety afforded the public generally is available to pedestrians with disabilities; and
WHEREAS, the proposed guidelines do not take into account the negative impacts and in some cases extreme impacts to the primary users of the public right-of-way, the motorist; and
THEREFORE, the Tennessee Section of the Institute of Transportation Engineers would like to provide the following comments for consideration by the Access Board when developing the final "Guidelines for Accessible Rights-of-Way":
1. What types of improvements or maintenance activities will trigger any requirements for accessibility improvements? Will filling potholes, making spot drainage improvements, upgrading signal displays, recutting vehicle detector loops, restriping a roadway require accessibility improvements? The types of activities need to be clarified.
2. What accessibility improvements should reasonably be expected to be made when the trigger is activated?" What is meant by the phrases "technically infeasible" and "maximum extent feasible?" These need to be defined and clarified so that reasonable requirements are made by the Access Board and not by the Court system.
3. Alternate Circulation Paths ? The guidelines call for an alternate circulation path parallel to and on the same side of the street as the disrupted pedestrian access route, however, this is not always possible. This requirement also gives no guidance as to the amount of time the closure may take place without requiring an alternate route. Would utility work in a manhole for 1 hour require the construction of an alternate access route? How can existing sidewalks be brought up to the proposed standards if they can't be closed for a day? The phrase "other temporary conditions" appears to be vague and could mean just about anything to a potential litigant. Further clarification on these issues needs to be provided.
4. Cross Slope of Crosswalks ? The guidelines call for the cross slope of cross walks to be 1:48
5. Curb Ramps ? The guidelines discourage diagonal curb ramps at intersections. While it may be possible to design new intersections to accommodate single ramps for each crosswalk, reconfiguring many existing intersections with new ramps would require complete reconstruction of the roadway including the relocation of crosswalks, parking, signals, etc. In addition, some intersections may function better for both pedestrians and motorists by using diagonal ramps. We recommend including diagonal ramps in the guidelines as an acceptable option for use in appropriate situations and encouraging the use of single ramps at newly designed intersections.
6. Pedestrian Signal Phase Timing ? The guidelines change the pedestrian signal timing by using a walking speed of 3.0 feet
7. Channelized Turn Lanes at Intersections - The guidelines will require a pedestrian-activated traffic signal for each segment of the pedestrian crosswalk, including across the channelized turn lane. The impact of this requirement will be devastating to capacity at many intersections. Signalizing these locations may actually decrease the safety of pedestrians and vehicles because the signals are likely to be ignored by many drivers. We recommend deleting this requirement from the proposed guidelines.
8. Accessible Pedestrian Signal Systems ? The guidelines will require the installation of Accessible Pedestrian Signal systems at all existing signalized intersections with pedestrian indications. The costs of these devices will be a tremendous burden on already overextended traffic engineering agencies. These requirements appear to be overkill by requiring these expensive and untested devices at all intersections, regardless of need. We recommend retaining the MUTCD requirements until studies prove the safety benefits of these devices.
WHEREAS, the Tennessee Section of the Institute of Transportation Engineers understands the need for standards related to access for disabled pedestrians, however, we have serious concerns about the impacts of the proposed guidelines and believe that some are not realistic or cost effective and that revisions to the draft guidelines are necessary.
NOW, THEREFORE, BE IT RESOLVED, that the Tennessee Section of the Institute of Transportation Engineers submits these comments listed above for consideration and strongly requests that serious consideration be given to the issues raised; and
BE IT FURTHER RESOLVED that the Tennessee Section Institute of Transportation Engineers Board of Directors directs that these recommendations be submitted to the US Access Board on or before October 28, 2002.
APPROVED:
Cindy Pionke, P.E., President
Anthony Todd, Vice President
Bill Kervin, P.E., Secretary-Treasurer
Craig Hanchey, P.E., PTOE, Immediate Past President
(signed)
Craig Hanchey, P.E., P.T.O.E.
Dear Access Board Members,
For almost 30 years now I have been a white cane user. I am totally blind. I've traveled independently throughout the Philadelphia metropolitan area to school and to work. I've walked by myself around Manhattan and a number of other major cities. I've even crossed streets in London by myself.
Nonetheless, I am writing to cast my vote for intelligent, discrete and well designed systems that give audible feedback to blind pedestrians. Far too many blind people are injured or killed while trying to cross busy streets. Anything we can do to reduce that number is a good thing! A useful system should be one that allows blind travelers who do not wish to use it to simply ignore it. The system should adjust its own volume based on the level of ambient sound in the vicinity of the intersection. I'm sure there are many good ideas to make the system as useful and flexible as possible. But, above all, any system that can promote increased independence and even save a life is a very good idea.
I urge you to set policies that encourage local authorities to integrate Accessible Pedestrian Signals and Detectable Warnings at intersections into their designs for new systems and for upgrades to existing facilities. I look forward to hearing about your decision in this matter.
Regards,
Bill McCann
Blind pedestrian and
President
Dancing Dots
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
Deborah Brown, October 22, 2002
Many of the items in the draft guidelines for public rights-of-way are
premature, and many will not help the problem of public access for blind
pedestrians.
I am a member of the National Federation of the Blind living and working in
the Washington area. I have previously lived in south Florida, where there
are no sidewalks. I moved to the Washington area mainly because of improved
pedestrian access.
I appreciate the advocacy for the 3 feet
signals. This is the kind of requirement that would benefit all pedestrians.
No disability accommodations will help pedestrians if there are no signals
or designated pedestrian zones in the first place. Creating expensive
requirements for access may result in a decision not to signalize an
intersection or not to provide sidewalks on the grounds that these
requirements are too expensive. It is also pointless to have a politically
correct ramped, marked, and signalized intersection which is surrounded by
streets that cannot be navigated or crossed.
About intersection design: Poorly designed ramps are a problem for blind
pedestrians. It is better for the ramp to have steeper sides that can be
felt. Also, an ambulatory blind pedestrian is more likely to stay out of a
wheelchair user's way if he does not feel he must stand inside the ramped
area to be assured of crossing the street in the crosswalks.
The issue of raising the street level at intersections is an interesting
one. The main reason we want cars to slow down is to make the roads safe for
pedestrians and other drivers. Raising the street level to the level of the
sidewalk may make it unsafe for blind pedestrians. Why should law-abiding
citizens have to make this accommodation to criminals?
On accessible pedestrian signals: The rule for blind pedestrians is that
when the parallel traffic moves, the blind pedestrian moves. If this rule
can be applied safely, no APS is needed. (Of course this rule cannot be
applied 100% safely because not all drivers are law-abiding. We can never
hope to protect pedestrians or any other group from people who break the
law.)
APSs are complicated to use; therefore, the complexity of the
intersection
must merit the use of a complicated tool like an APS. For example, in
Montgomery County, Maryland, an ordinary four-way intersection, Fenton Street
and Wayne Avenue, has an APS. Anyone wishing to use the APS must find the
button using the locator tone, and then either listen for the signal or feel
the vibrotactile indicator. If the APS is not correctly placed, the
vibrotactile indicator is useless. Any blind pedestrian not using the APS
simply listens to the traffic. Anyone who could not manage to cross the
street without the APS could not cross it with the APS, making the APS
unnecessary.
The design of APSs is made much more complicated than necessary by the
presence of the locator tone. Locator tones are necessary because of
misplacement of the APS. Simply requiring the APS to be located within reach
of the pedestrian waiting to cross the street would make locator tones
unnecessary and APSs much more useful. Poor placement also makes the APS
much less useful because the sound is often coming from behind the person
crossing the street.
APSs should be installed only where the normal rules of street-crossing would
not apply. Examples might be (1) where there is little or no parallel
traffic; (2) where a pedestrian is given a walk signal ahead of the parallel
traffic; (3) where the length of the signal is long enough to cross only
when a pedestrian-activated signal is used. How would a blind pedestrian
know if a pushbutton APS is present without a locator tone? If a pole with a
signal is properly placed, the blind pedestrian would simply look at each new
intersection to find the signal.
Detectable warnings: I am concerned about the use of textures to send
messages. Does the textured surface mean "Walk here," "Don't walk here," or
nothing at all? It is preferable to use grass or sand, or some nonpaved
surface, if a barrier is intended.
Some people have recommended that textured surfaces be used only when a
surface is perceived as flat.
However, it is not the actual slope of the ramp, but the unnatural feel of
it, that tells a blind pedestrian that an area is a street crossing (in
addition to traffic noise). If the surrounding terrain is hilly, a gentle
slope is no different from surrounding areas. If the surrounding terrain
is flat, a gentle slope is quite noticeable. I recommend that other methods,
such as properly designed curb cuts, be used to indicate street crossings.
In Montgomery County wheelchair users are troubled by brick streets in the
downtown Rockville area. I know that many wheelchair users do not complain
about truncated domes, but I believe they are simply being courteous about
what they perceive to be someone else's access need. I fail to see how a
textured surface will be maintained through rain, snow, dirt and traffic.
I believe that many of the accommodations that will help blind pedestrians
are those that will help all pedestrians. These include (1) increasing the
timing on walk signals; (2) taking into account the auditory environment
when determining where to place pedestrian signals; (3) holding drivers
accountable for following the laws of the road; (4) providing public
education to all citizens, including those with disabilities, about
safe travel. Montgomery County, Maryland, where I live, is taking
initiatives in defending the rights of pedestrians. Without the human
interest in the issue, all fancy gadgets will simply cost money and fail to
improve the situation.
the APS is not necessary.
Robert R."Bob" Matti, October 28, 2002
I think it should be mandated that Accessible Pedestrian Signals and Detectable Warnings be present at all intersections with moderate to heavy pedestrian traffic. I urge this as a blind Guide dog user but honestly feel these devices will benefit all pedestrians significantly.
Robert R."Bob" Matti
Ray Campbell, September 10, 2002
I am writing to urge you in the strongest terms possible to adopt strong language in the Public Rights of Way Accessibility Guidelines for Detectable Warnings and Accessible Pedestrian Signals. As a person who is blind, I assert that any weakening of the language as studied and adopted by the Public Rights of Way Advisory Committee would jeopardize my safety and the safety of those like me. This cannot be allowed to happen.
For almost 10 years, detectable warnings in the form of truncated domes on railway and subway platform edges have provided full access to the same visual information sighted persons have had all along. I regularly use commuter rail, subway and L trains in the Chicago, Illinois area. I am regarded by many as having excellent travel skills using the white cane. Yet, I find that I move about with more confidence on platforms where detectable warnings are installed than on those where they are not.
Contrary to what some might insinuate, detectable warnings are not a substitute for good training. I still must use my good judgment and sound travel skills even when detectable warnings are present. I must still concentrate and be aware of my surroundings at all times. Just a couple of years ago, I was on a rail platform that had detectable warnings. I had something else on my mind and was not paying attention to my traveling as I should have been. I almost walked right off of the platform edge and into the railroad bed. Had I done this, it would have been my fault.
The detectable warning is simply that, a warning to tell me I'm getting close to the edge. Sighted people have different colored lines on platforms to tell them when they are getting close to the edge. The detectable warning is my "different colored line." If I don't need detectable warnings, then please tell me why people who can see need a different colored line at the platform edge.
Accessible Pedestrian Signals provide me as a person who is blind assurance that it is safe for me to cross a street, particularly at a heavily traveled intersection. With urban sprawl, increased traffic, wide, busy streets and other factors, installing these signals is more important than it has ever been. Again, just because an accessible signal is present DOES NOT mean I can forget about using sound travel skills and judgment; I cannot. If I am at an intersection where an accessible signal is present, and that signal tells me it is safe to cross, but there is a car sitting in front of me in the crosswalk, I most certainly will not cross until that vehicle moves out of my way.
Some say accessible signals cost to much. I say two things. First, how can you put a price on a human life? And second, it costs about $75,000 to provide regular signals at intersections. It only costs about $4,000 or about 5.46% additional to install accessible signals. Furthermore, according to the Transportation Equity Act for the 21st Century, 80% of the cost for accessible pedestrian signal installation near public transit facilities can be paid for with Federal dollars.
Today's accessible signals are not annoying like those of the past. The audible locating tones they emit to help a pedestrian who is blind find the push buttons are only audible from 6 to 12 feet
Some will tell you that we can rely on just the traffic flow to determine when to cross the street. If that's the case, then why do sighted people need walk and don't walk signs? The accessible signal is our walk don't walk sign. Furthermore with increased traffic as I already mentioned, distracted drivers, quieter cars and right turn on red, being able to use an accessible signal to know for sure that it is safe to cross is critical to my safety. In fact, these signals not only benefit people who are blind, but they also are of value to Senior citizens, small children and people with other disabilities. And to those who would say we do not need them, I say fine, you don't have to use them.
There is a major 4 to 6 lane street with a lot of traffic on it that runs through the community where I live. The street is home to many stores, restaurants and other businesses. If I want to patronize many of these businesses, I must be able to cross this major street. An accessible signal would make crossing this street much easier for me as I would have the assurance that I am crossing when I am supposed too.
It's not just nice to have detectable warnings and accessible pedestrian signals. It's a matter of personal safety and equal access to the built environment for people who are blind. Again, I strongly urge that the Public Rights of Way Accessibility Guidelines come out in their final form with very strong requirements for the installation of both detectable warnings and accessible pedestrian signals. The lives of people who are blind depend on it. Thank you very much in advance for your time and for taking my comments.
Sincerely,
Ray Campbell
Russ Reinert, October 27, 2002
I just learned yesterday that I could write you about my support for accessible pedestrian signals and detectable warnings. I've been totally blind for 44 years, and I've had a guide dog for 40 of those years. I've had good mobility and independence. However, I was in a city several years ago with accessible pedestrian signals, and I found it so helpful. I felt safer and more secure about my decisions to cross streets. I'm finding that cars are quieter these days than they used to be, and sometimes intersections aren't the traditional straight corners. So I find myself a bit more timid about crossing streets, so I support accessible pedestrian signals and detectable warnings as a means to improve my safety. I want to encourage you to do whatever you can to help those of us who are sightless. I realize that some blind people don't feel they need them, and perhaps they don't, but I do, and I know that there are others who do. Thank you for considering my thoughts, interests and desires.
Gratefully,
Russ Reinert
Bernie R. Vinther, October 28, 2002
About 20 years ago I was a licensed driver. Now, I am totally blind and a
person who has experianced being hit trying to cross streets with standard but not accessible signals. I was seriously injured, going over the hood of a vehicle traveling at 25 mph. Fortunately, my dog guide received less serious injuries, and we still travel independently about town.
However, even before the accident, I felt the need for accessable pedestrian signals, and I am (fortunately living) proof of that need. I also feel STRONGLY that the Access Board should accept/adopt the proposed regulations from the Public rights of Way Advisory committee involving the use of detectable warnings and accessible pedestrian signals. I have personally experienced the benefits of these devices. They cause no harm or disadvantage to those who don't need or choose not to use them. But, They are reasonable and absolutely necessary by all persons in my situation who desire to cross streets safely at controled intersections.
Sincerely,
Bernie R. Vinther
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
Paul Plotas, P.E., PTOE, October 24, 2002
Re: Draft Guidelines for Accessible Public Right-of-Way (June 17, 2002) Roundabout Alternative Design Strategies
Dear Access Board:
Although I certainly would not classify myself as a roundabout expert, I am a practitioner of traffic engineering with 16 years of experience. During my review of the "Draft Guidelines for Accessible Public Rights-of Way (June 17, 2002)", the following passage in particular caught my attention:
To provide safer crossing at roundabouts, the draft guidelines would require pedestrian activated crossing signals at each roundabout crosswalk, including those at splitter islands. (The draft guidelines would ensure that such signals are usable b with vision impairments under requirements in section 1106 discussed below.) Although roundabouts are typically used to avoid signalization, the Board is not aware of alternatives that would allow safe passage for pedestrians with disabilities. Aside from accessibility, the use of roundabouts in areas of high pedestrian use has been questioned 4 some in the industry. Requiring the signal to be pedestrian activated may help limit the impact on traffic flow. Signal technologies are available that can further minimized the impact, such as devices that halt traffic only while a pedestrian is in the crosswalk. The Board seeks information on alternative design strategies and available technologies that can improve access at roundabouts for persons with disabilities, particular those with vision impairments.
I developed the attached summary of my thoughts on this subject and respectfully submit it for your review.
Please give me a call at [...] if you would like to discuss my thoughts further.
Very truly yours,
Paul Plotas, PE, PTOE
--------------------------------------------------------------------------------
Section 1 ? Introduction
Introduction
All at-grade pedestrian crossings of roadways are handled in one of the following two ways:
Vehicular traffic is stopped, allowing the pedestrians to cross ? example: signalized intersections
Pedestrians judgment determines appropriate crossing opportunities ? example: unsignalized intersections
Typically, in both cases vehicles are already expecting to stop at an intersection and pedestrian crossings are accommodated. Roundabouts present a different challenge since vehicular traffic at the egress crosswalks will never be stopping for other vehicles, see Figure 1. Additionally, roundabouts present a particular challenge to visually impaired pedestrians since the geometrics of a roundabout distort audio information from vehicular traffic giving unclear audio clues. To aid pedestrians at roundabouts, one can either attempt to control vehicular traffic or improve the information provided to pedestrians. This report discusses these two alternatives.
Referring to Figure 1, for the purposes of the following discussion, it is assumed that the pedestrian crosswalk is located approximately I to 2 car lengths from the edge of the central circle, which is the typical layout.
Alternatives
In this section various roundabout alternatives for both controlling vehicular traffic and for improving information available to pedestrians will briefly be explored.
Control Vehicular Traffic
There are at least four alternatives available to control vehicular traffic and give pedestrians the right-of-way at a roundabout egress pedestrian crossing.
a. Stop sign
b. Yield sign
c. Traffic signal
d. No control/Understanding that vehicle driver yields right-of-way to pedestrian
a. A stop sign alternative breaks the basic principals of roundabouts: all traffic control of a roundabout is yield controlled. Additionally, with low pedestrian traffic, stop signs will serve no useful purpose the majority of the time, will eventually be ignored by drivers, and will eventually function as a yield sign, and probably as an uncontrolled intersection.
b. As discussed for the sop sign alternative, at low pedestrian volume locations, vehicle drivers will also eventually ignore the yield sign, resulting in an uncontrolled intersection.
c. A third method for controlling vehicles at the egress pedestrian crossing is a traffic signal, however, two issues immediately come to mind. The first is the issue that there is only storage for up to two vehicles before additional vehicles in the queue impede vehicular flow around the roundabout. Even with minimum timings for a signal, a roundabout with relatively low vehicular volumes will experience some blockage.
Having the call for the signal solely dependent on pedestrian demand without regard to vehicular flow in the roundabout could have significant impacts to the capacity of the roundabout. It may be possible to place additional vehicle detectors strategically about the roundabout to delay the pedestrian call to a convenient time for vehicles; however, additional study will be required to determine if a suitable location is actually available.
The second issue that comes to mind with signalized control is driver expectation, especially with low pedestrian volume roundabouts. If a driver continuously meets a green indication at a signal, driver expectation is that a green signal will be met every time. My personal observations are that at low pedestrian volume, mid-block, stand alone pedestrian signals, it is the combination of the physical person and the signal that alert drivers to the signal. My personal observations are that most pedestrians instinctively realize this and will not begin to cross a road, even with the signal giving the right- of-way, until they visually receive confirmation that vehicles are stopping. Sight distance for the mid-block pedestrian signal is very important. Although the same sight distance may be available at a roundabout, the curvature of the intersection at times focuses drivers' attention on negotiating the curves of the road and away from the distant cross walk. The bottom line of this discussion is that due to driver expectations, a signalized crossing could actually give visually impaired pedestrians a false sense of security, and further study is necessary to determine if this is true.
d. Based on the discussion above, the final alternative, No control/Understanding that driver yields right-of-way to pedestrian is the alternative that the unsignalized alternatives default to, particularly at locations with low pedestrian volumes.
Control Pedestrian Traffic
There are at least two alternatives to control pedestrians while maintaining virtually free-flow conditions for vehicular traffic.
a. No control, pedestrian judgment determines acceptable gaps
b. "All Clear" Signal to pedestrians
a. Due to distorted sound the no control alternative is unacceptable.
b. The concept for the "All Clear" alternative is that vehicle detectors can be placed in the pavement upstream of the crosswalk as shown on Figure 2. The upstream detector could be coordinated with a pair of downstream detectors to determine when no vehicles are within the clear zone. When no vehicles are within the clear zone pedestrians would be given an "All Clear" signal.
While it is possible to build such a system, the following issues deserve additional research.
1. Do pedestrians have enough time to cross the egress lane in the scenario where a vehicle is just before the detector just as the pedestrian steps off the curb?
2. Is it prudent to depend on technology to this extent to determine when conditions are all clear?
3. What liability is involved with this alternative? (Is it really any different from a standard signalized intersection?)
Conclusions
The following problem with roundabouts has been identified: the circular portion of the roundabout creates confusing sound patterns. Being able to clearly read these sound patterns is essential for visually impaired pedestrians to safely cross the road. While it is possible to control vehicular traffic to enable pedestrians to cross, it is not obvious, at least to me, that the pedestrians will be safer. Instead of trying to control the vehicular traffic, I propose to improve the information available to pedestrians. It appears that by strategically placing detectors visually impaired pedestrians can have the same information as all other pedestrians to make informed decisions about when to cross.
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
John R. Tobin, P.E., P.T.O.E., October 28, 2002
U. S. Access Board Comments
These comments pertain to proposed rule making on pedestrian signal phase timing (1105.3).
The proposed walking speed criteria coupled with the proposed crossing distance criteria would nearly double the pedestrian clearance time requirements in many instances (see enclosed calculations for six-lane/six-lane arterial intersections). Such large increases in pedestrian crossing times would increase the minimum signal cycle length to unreasonable levels that would often create excessive delays, excessive queuing, and serious degradation in existing signal coordination plans. Enclosed calculations indicate that existing signal systems incorporating large six-lane/six-lane arterial intersections would likely need to operate on cycle lengths three minutes in length in order to meet the proposed criteria. The excessive queuing and poor signal coordination that would result could also be expected to significantly increase vehicular accident rates. It is likely that pedestrian safety would suffer as well. As noted in the HCM 2000 (page 18-7), pedestrians' propensity for taking "risk taking behavior" increases as delays increase.
In view of the serious adverse impacts (including adverse safety concerns) that the proposed changes would impose on many existing arterials, it is concluded that the proposed changes will often be "technically infeasible" in many existing signal systems incorporating large six-lane/six-lane arterial intersections. Many arterials have simply not been designed and constructed with short enough crossing distances to feasibly accommodate the changes. Other measures such as "count-down" pedestrian signals or passive crosswalk detection (to extend the pedestrian clearance only when needed) may be appropriate for these existing facilities.
Accommodating the proposed changes on new six-lane arterial facilities will require significant changes in design standards and strategies in order to avoid excessively long pedestrian clearance requirements. Use of corner channelizing islands and/or median refuge islands will likely be needed (see enclosed concept drawing). These treatments break pedestrian crossings into shorter components that can be accommodated within a reasonable system cycle length. However, these treatments often require additional right-of-way for the corner channelization and additional roadway width. Implementing these treatments on existing facilities will also be expensive and disruptive in many instances.
John R. Tobin, P.E., P.T.O.E.
1555 So. Rainbow Boulevard
Las Vegas, NV 89146
Minimum Cycle Length Calculations for
Six lane/Six-lane Arterial Intersections
Assumptions: 1) Approaches include dual left-turn lanes (24' median) and an
exclusive right-turn lane.
2) Left-turn phase demands require no more than 40% of the signal
cycle.
Current Criteria:
Xng distance = (10' spandral) +6(12') + (24' median) + ½ (12') = 112'
Mini. ped clearance = 112' ÷ 4 fps = 28 sec
Min. cycle length = [2(28" + 7" Walk)] ÷ 0.60 = 117 sec
Proposed Criteria:
Xng Dist. = 2(10' spandral) + 7(12') + (24' median) + 1(8' ramp) = 136'
Min. ped. clearance = 136' ÷ 3 fps = 46 sec
Min. cycle length = [2(46" + 7" walk)] ÷ 0.60 = 177 sec
Impacts: Pedestrian clearance is increased 64% from 28 sec
Minimum cycle length is increased 51% from 117 sec
Intersection Channelization to Reduce
Pedestrian Signal Clearance Time
Donna Sanchez, September 12, 2002
My name is Donna Sanchez. I am a Legally Blind and a member of the Silicon Valley Council of the Blind which is affiliated with California Council of the Blind which is affiliated with the American Council of the Blind. I would like to let you know that I support the Public Rights of Way Advisory committee regarding detectable warning and accessible pedestrian signals which Charlie Crawford and Melanie Brunson from ACB sat on. Detectable warnings prevent folks from falling into subway pits and alert us to the fact that we have reached an area of potentially hazardous traffic flow. Accessible pedestrian signals help us to cross the street safely.
When I was in my 20's I was hit by a car. There were no Pedestrian signals at that particular time. Had the signals been there I know I wouldn't of been hit. As of today I still have back problems.
Please make sure there are pedestrian signals and especially detectable warnings because Blind people need them a lot in order to lead normal lives and to be able to travel where ever we need to go.
Thanks
Donna Sanchez
Charles S. P. Hodge, October 25, 2002
My name is Charles S. P. Hodge, and I reside at [ ... ]. I happen to be totally blind, and I am an experienced civil rights attorney who works for the U.S. Department of Labor. I am keenly interested in the issues raised by and the recommendations designed to address those issues contained in the report of the Public Rights of Way Advisory Committee (prowac), and the below comments are my personal individual comments as an informed disabled person with respect to Docket Number 02-1.
At the outset, I would like to endorse and associate myself with the public comments submitted in the docket file by Melanie Brunson on behalf of the American Council of the Blind. Through years of experience in traveling as a blind person through the use of both a white cane and a guide dog, I can state unequivocally that the prowac recommendation in favor of detectable warnings at the bottom of curb cuts or sidewalk ramps at intersections is essential for the safety of blind and visually impaired independent travelers. Despite the shrill contentions to the contrary of an organized and vocal minority within the blind community exemplified by members of the National Federation of the Blind, blind travelers cannot tell solely by degree of slope of a curb cut or sidewalk ramp where the sidewalk ends and a vehicular way begins. In addition, with developing technology for electric powered vehicles which are deadly silent, blind pedestrians will become increasingly vulnerable and at risk in future years to serious injury or even death if such a pedestrian should unwittingly wander into traffic on a vehicular way.
I also heartily endorse the prowac report's recommendation favoring installation of accessible audible pedestrian signals at signalized intersections. The sighted public is given "walk" and "don't walk" messages through visual cues and signage at signalized intersections, and the prowac recommended audible pedestrian signals would only replicate or give to blind pedestrians the same or equivalent information provided to sighted pedestrians. While traditional orientation and mobility skills and techniques learned by some blind pedestrians are undoubtedly useful in enabling such pedestrians to safely navigate most simple intersections, as pointed out above, with the increasing advent of silent vehicles, reliance by blind or visually impaired pedestrians upon the traditional traffic sound cues will become in future years increasingly risky and problematic. In addition, as the technology for audible pedestrian signals have advanced in recent years, such accessible pedestrian signals can be programmed to alter sound levels based on ambient noise levels. Thus, the sound levels of accessible pedestrian signals no longer pose a nuisance for neighboring residents and businesses during quiet period such as during the middle of the night.
I also wish to support the prowac recommendation for locator tones for activation buttons or controls on every pole at a signalized intersection with accessible pedestrian signals. Such tones can be programmed to be heard only up to a distance of ten feet, and thus these locator tones need not become a nuisance to local residents or business proprietors. The prowac recommendations with respect to accessible audible pedestrian signals are in my view well tailored and designed to give equivalent information access to blind and visually impaired travelers to that information which is routinely provided by traffic signals to sighted pedestrians. As blind people, we can settle for nothing less as a matter of our civil rights. Accessible audibled pedestrian signals and detectable warnings on curb cuts and sidewalk ramps will also provide blind and visually impaired travelers with a reasonable margin of safety which will not intrude obtrusively on the lives of the general public. In my humble opinion, the Access Board should adopt these recommendations, and reject the illogical arguments being proffered by some in the blind community. Indeed, if some super-achieving and competent blind travelers do not wish to avail themselves of the additional requirements contained in the prowac report, such super blind people are free simply not to utilize accessible audible pedestrian signals and to continue to travel at their own peril in their traditional manner. As one well-informed and thoughtful blind person, I can earnestly and honestly tell the members of the Access Board that despite their contentions that they speak for all of the blind, the National Federation of the Blind does not represent or speak for this blind person with respect to the well-thought-out recommendations of the prowac report. I wish in closing to thank the Access Board for paying attention to and considering my views on these crucial and important--if not life threatening--issues of concern to all blind people.
Respectfully submitted,
Charles S. P. Hodge
David J. Barakian, September 24, 2002
City of Palm Springs
Department of Public Works and Engineering
Palm Springs, CA 92262
Re: Comments Regarding "Draft Guidelines for Accessible Public Rights-of-Way"
Enclosed, please find the comments provided by myself, the Director of Public Works/City Engineer, and Phil Kaplan, the ADA Coordinator for the City of Palm Springs.
Sincerely,
David J. Barakian
Director of Public Works/City Engineer
Comments Regarding "Draft Guidelines for Accessible Public Rights-of-Way"
Additions and Alterations (1102.2), 2
Alternate Circulation Path (1102.3, 1111), 1
Pedestrian Access Route (1102.4), (1103): I recommend that clearer guidance be given with respect to sidewalk cross slope through a drive approach, i.e. does a 48-inch "flat" area need to be provided around the approach in areas with curb adjacent sidewalk to avoid the large cross slopes in approaches? Also, I recommend the issue of sidewalk or pedestrian access adjacent to bay parking areas to be addressed. I feel sidewalks should not be allowed behind vehicles parking in "bays" 90 degrees
Grade (1103.5), 1
Surface Gaps at Rail Crossings (1103.7), 1
Curb Ramps and Blended Transitions (1102.6, 1104), 1
Pedestrian Signal Phase Timing (1105.3), 1
Pedestrian Overpasses and Underpasses (1105.5), 1
Roundabouts (1105.6):
2
3
Accessible Pedestrian Signal Systems (1102.8, 1106), 2
Street Furniture (1102.9, 1107), 1
1102.2.2 Alterations: Impossible to interpret this.
1102.8 Pedestrian Crossings: Is every crosswalk a pedestrian crossing?
1102.9 Street Furniture: Not customers of a restaurant?
1105.3 Pedestrian Signal Phase Timing, 2
1105.6.2 Signals: With audible tone and vibro tactile indications?
1109.2 Parallel Parking Spaces: These need a drawing to explain.
Nancy Johnson, September 9, 2002
I've been blind since birth. I'm an independent traveler in my community as well as an occasional traveler to other parts of the country. My most recent journeys away from home were trips from Topeka, Kansas to
Washington, D.C. and to Houston, Texas. Both of these major cities were totally unfamiliar to me.
I traveled to Washington with a visually impaired friend who has more vision than I and some experience with Washington's Subway system. I experienced subway travel for the first time. Without his assistance, I would have been lost. I cannot read signs, identify vehicles, or locate customer assistance areas. I would have been at the mercy of other travelers. That is as it has been throughout my life. When I go to unfamiliar places, I must ask whomever I can find for instructions. The information I receive is not always reliable.
In Houston, I was able to cross a busy intersection independently because an accessible pedestrian signal had been placed at the corner. This gave me the freedom to come and go between the convention hotel and the overflow hotel at will. Also available at the convention were talking signs that allowed people to locate the vendors' booths of their choice without having to ask each vendor whom they represented.
New traffic plans are making it more and more difficult to navigate busy areas as a pedestrian. The most recent development of which i'm aware are the round-abouts. Traffic travels round and round a circle and cars apparently enter and leave without making the traffic stop. These are extremely difficult for a blind pedestrian. My hearing is good, and I have the intelligence, training and skill to travel independently. Every day someone in our country loses their sight. They must give up their cars, and they are frightened of traveling in busy areas as pedestrians. Blind people can - have - been traveling by attending to the movement of traffic for generations. Unless we know where the pole is to press a pedestrian signal, we can't use it. There are more and more cars on the road, and traffic patterns are changing. The right
turn on red is a hazzard we have had to learn to manage.
The technology now exists to eliminate the dangers and fears involved with being a blind pedestrian. Individuals using wheel chairs have curb cuts to make crossings accessible to them. (These made life more difficult for blind pedestrians.) We need accessible pedestrian signals and detectable
warnings so we can safely cross busy intersections. Why should I be limited in where I can go as a pedestrian simply because I don't have the same safety information that everyone else has? Before the
technology existed, we had no choice. All intersections should be accessible to us. We should know where the edge of the street begins so we don't accidentally walk into traffic. And we should know where the signal post is and when the pedestrian signal is in our favor. We should be able to identify instantly when we are as near as is safe to a subway track. It would be extremely helpful to be able to locate ticket booths and customer service areas. Some have suggested braille signage. Not every blind
person knows braille. Those of us who do can't read the braille sign if we can't locate it.
Admittedly, this kind of accessibility is expensive. (Are curb cuts not expensive?) And can we put a dollar price on any life lost because the victim didn't have the necessary information to keep safe? Without
detectable warnings and accessible pedestrian signals, that's the direction we will go.
Thank you for considering my concerns.
Nancy Johnson
Andrea Giudice, October 27, 2002
My name is Andrea Giudice. I am blind and want to let you know that I give my exuberant and total support to the existence and increase of Accessible
Pedestrian Signals and Detectable Warnings at intersections. I live in
the grater San Francisco Bay area and travel throughout the country. I can give you enumerable examples of how crucial Accessible Pedestrian Signals and Detectable Warnings are at intersections.
I have heard nothing about discontinuing the incorporating of crossing indicators for pedestrians who do not need accommodation in terms of size or contrast of signage or other forms of audible or detectable crossing indicators. Why then is this even being considered for Accessible Pedestrian Signals and Detectable Warnings? It is a crime to deny people with disabilities the same safety at intersections that is granted to our non-disabled partners in pedestriandom.
With Kindest regards,
Andrea Giudice
Alonzo Liñán, P.E., November 1, 2002
City of Olathe
Re: Draft guidelines on accessible public right-of-way proposed by the U.S. Access Board.
Dear Mr. Windley:
Since the Rehabilitation Act of 1973, the city of Olathe has endeavored to maximize accessibility of city programs and facilities to all segments of our population. The city of Olathe has also incorporated the additional requirements of the Disability Act of 1990 and it subsequent revisions. All of these actions have been successful in removing barriers for the disabled and has provided access to all parts of the community to public services, programs and facilities. To date, none of these actions have resulted in a decrease of access to other segments of the community nor has it compromised the safety of other customers in our community.
Several of the proposed guidelines require pedestrian activated traffic signals at many locations. This blanket requirement for the placement of traffic signals in contrary to the MUTCD where at least some minimum warrant has to be met. Without at least minimum warrants, traffic signals will soon go the way of "Children At Play" and "Neighborhood Watch" signs. There will be so many traffic signals that when they are actually needed, they will be ignored. This is a very serious safety issue for the entire population.
The proposed draft guidelines will push communities like ours into a position of not providing facilities or services because of the cost of maintenance, rehabilitations and reconstructions as well as its impact on safety. In short, the Access Board's attempt to provide access for all people, at all times, for all programs, at all facilities, may deny access and services to all citizens of the community so that there will not be a "discriminated group". In the end, everyone will be treated equally as communities exercise their discretionary powers to not make improvements beyond a certain level.
Finally, I feel that many of these proposals are premature as statistical information is not available to draw conclusions from nor is there consensus between The National Federation of the Blind or the American Council of the Blind on many of these issues.
I hope the following comments illustrate these views.
Section 1102.2.2; Additions and Alternations - "Compliance in alterations is required except where it is 'technically infeasible.'"
My concern is that, as an engineer, the only thing that makes something "technically infeasible" is money and politics. This needs to be better defined.
"...such work might be technically feasible at other locations where acquiring right-of-way is practicable."
"Practicable" needs to be defined as well. Cities can use imminent domain, but the political ramifications of doing so for a sidewalk may force policy makers to avoid the project.
Section 1102.3; Alternate Circulation Path - "...call[s] for alternate circulation path are where pedestrian access routes are temporarily blocked by construction, alteration, maintenance, or other temporary conditions...(on the same side of the street parallel to the disrupted pedestrian access route)."
The concern is "or other temporary conditions". First, this needs to be more narrow in definition as snow can be considered a temporary condition. I would also suggest that the barrier requirement be changed to allow for barricades with modifications for the disabled.
Second, since an alternate path has to be parallel and on the same side, this may require easements to construct a temporary surface "to the outside". This speaks to a significant cost increase to repair or replace some sidewalk. If the sidewalk is on a 4 lane road and no easements or right-of-way exists "to the outside", then taking the outside lane of traffic may be the only other choice. But then you run into a curb, slope limits, additional traffic control... Regardless, a 30 minute job could now take hours.
In either case, the city will be faced with either increased costs for easements or potential reduced safety on the street by putting peds in the street; both of which may lead a city to determine that sidewalks may not be maintainable and, therefore, either removed or not put in.
Section 1102.4; Pedestrian Access Route - "...refers to the portion of the public right-of-way that serves as an accessible route."
What provision is there for sidewalks that are in easements? Does this proposed document extend into private property for public use but is not right-of-way? Does this unintentionally obviate easements for sidewalks in the future?
Section 1102.5; Protruding Objects - "...limited to a 4 inch
This could lead to a lot of unintended prohibitions. Examples include call boxes, pole mounted controllers, streetlight controllers, directional and informational signs...
Section 1102.12; Vertical Access - "Elevators are not required by these guidelines except at certain pedestrian overpasses and underpasses with elevation changes greater than 60 inches
Aside from the obvious maintenance and security issues, this will clearly prohibit any municipality from seriously considering any pedestrian over/underpasses.
Section 1102.14; On-Street Parking - "[For parallel parking] an access isle at 60 inches
This is too broad of a statement and is unreasonable for every block face. Is this just for downtown blocks or residential blocks as well? What is considered a block? This seems to ignore the curvilinear nature of suburban street design if it includes residential streets. This also assumes that there is a need for this specific number of parking; "blocks" can have more or less need. This also assumes that there are "parking stalls" already marked. This is certainly not the case in residential areas.
Logistically, this will come at a cost of at least three other parking stalls, if not more, and will negatively impact the sidewalk system. If the presumption is that a driver can pull next to the new curb so that the driver can utilize the additional 60 inches
The drainage will be severely affected as well. While the slope can be maintained for street drainage at the original curb line, this introduces ADA slope and transition issues to connect to a relocated sidewalk. The now relocated sidewalk becomes an unexpected variable for the blind and as such becomes a safety issue.
This one just needs to be dropped.
Section 1105.2.1; Pedestrian Crosswalk Width - "...shall be 96 inches
This is in inconsistent with the MUTCD which requires only 72 inches
Section 1105.2.2; Pedestrian Crosswalk Slope - "...slope shall be 1:48
This maximum cross slope will require "tables" at each intersection which will degrade the ride-ability of vehicular traffic and may compound grade problems in mid-block sections of steep roadways.
Section 1105.3; Pedestrian Signal Phase Timing - "All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
This is extremely unreasonable. The MUTCD indicates 4.0 f/s with the freedom to reduce as needed. To require 3 f/s and increasing the distance to include ramp lengths engender disrespect for the pedestrian indications as pedestrians will watch the flashing Don't Walk continue for as much as 15 to 20 seconds
Section 1105.6; Roundabout
This is a principle example of how the proposed accessibility measures will come at the cost of safety on the street. It is my hope that these "proposals" are only published to generate discussion and are not truly seen as reasonable.
Section 1105.6.1; [Roundabout] Separation- "Continuous barriers shall be provided along the street side of the sidewalk where pedestrian crossing is prohibited."
This is not consistent with other street designs and conditions. If the attempt is to prohibit the blind pedestrian from inadvertently crossing, then "regular" curves in the road become suspect. I find it difficult to accept that the blind pedestrian would consider "jaywalking"; which is what would be required if they were on any other curved street.
Section 1105.6.2; [Roundabouts] Signals - "A pedestrian activated traffic signal...shall be provided for each segment of the crosswalk, including the splinter island."
It appears form the discussion that there is a view that roundabouts are intrinsically unsafe for pedestrians. There is no documented proof that indicates that roundabouts are unsafe for pedestrians. It seems that this proposal is an attempt to pass judgement on the appropriateness of a traffic control device and recommend remedial actions without the benefit of any statistical data. If this gets adopted as written, it will effectively remove roundabouts as a traffic control and flow option as any traffic benefit will be negated with the presence of traffic signals.
So, again, in an attempt to provide access for all people, at all times, for all programs, at all facilities, cities will be forced to not make these improvements because of the cost, or not make these improvements because of the reduced or no benefit, or live with the more dangerous condition of following these rules and increase rear-end accidents, increase delay, increase air pollution, increase driver frustration...
The bottom line is that every traffic control device can be dangerous if not used properly and roundabouts are no different. The difference with roundabouts is that there are fewer conflict points, slower traffic, and less severe crashes. The addition would again negate all of these benefits and would make the intersection very complex for any pedestrian and driver.
Section 1105.7; Turn Lanes at Intersections - "Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal...shall be provided for each segment of the...crosswalk..."
What's a slip lane? If free-flow turn lanes are at issue, then there are literally thousands of existing "slip" lanes, both at signalized and un-signalized intersections. This is a common design element this requirement would essentially eliminate slip lane design from intersections.
Again, not until now have access accommodations resulted in a decrease of access and safety to other segments of the community.
Sincerely,
Alonzo Liñán, P.E.
Traffic Division Manager
City of Olathe
Harindra Vohra, P.E., October 28, 2002
Comments and Recommendations on the Draft Guidelines for Accessible Public Rights-of-Way
October 2002
Traffic Engineering Section of Mass. Highway Department reviewed the proposed ADA guidelines. In general we support the AASHTO comments and recommendations. We would like to high light some of the most important issues covered under these guidelines which will be very troublesome for all DOT's. The following points should be considered seriously:
1. It is unclear how these proposed guidelines will relate to other
regulations that must be met within the transportation field, such as air quality, historical preservation, and environmental protection regulations. Many of the proposed accessibility guidelines, if implemented, could have profound impacts on the ability of State and local jurisdictions to meet these existing federal mandates. These conflicts could result in substantial penalties being levied or the denial of transportation funding if existing regulations are not met.
2. A clarification is needed to the term " alteration", as well as the
requirements that it triggers. Currently, this term is open to a wide range of interpretation, which is likely to expose public agencies to potential lawsuits. Access Board should develop additional guidance related to the definition of "alterations" and accessibility improvements they trigger, using typical engineering terminology to ensure understanding by implementing agencies.
3. The current edition of the MUTCD requires a 72-inch minimum
crosswalk, while the draft guidelines require an extra two feet in all cases. This requirement for a 96-inch crosswalk does not appear to be driven by accessibility needs. Eight-foot wide crosswalks are excessive in many small rural towns where few pedestrians are present.
4. All pedestrian signal phase timing shall be calculated using a
pedestrian walk speed of 3.0 feet
5. Section 1106 will require the installation of Accessible Pedestrian
Signal systems at all existing signalized intersections with pedestrian indications. This will be a major cost item for the State and local municipalities. The added complexity of the systems will increase installation time and cost, as well as maintenance needs.
We strongly urge the Access Board to consider these comments and amend the proposed Draft Guidelines accordingly.
Thank you for the opportunity to comment on these proposed Draft Guidelines. If you have any questions regarding these comments, please contact Mr. Charles F. Sterling, P.E., State Traffic Engineer at [ ... ].
Sincerely,
Harindra Vohra, P.E.
Asst. Traffic Engineer
Mass. Highway Department
Andrew P. Avery, P.E., Sr., August 29, 2002
Thank you for the opportunity to comment on the draft guidelines for accessibility to public right-of-way. The City of Elmira wholeheartedly supports improving accessibility for those with disabilities. To this end, we spend many dollars each year improving our crosswalks and signage. We have also been working with our local disability awareness group, Access to Independence and Mobility (AIM), to improve access throughout the City. We are committed to improving mobility where practical and practicable. On this note, however, we must caution against over-standardizing the industry. There is a danger involved with over-saturating transportation corridors with devices intended to improve safety for pedestrians, without also considering the effect on the motoring public. Unintended consequences can decrease safety for vehicles; this can serve to then decrease safety for pedestrians. Rigid standardization removes the ability of the engineer to apply "engineering criteria and sound engineering judgment" to varying situations.
Some specific concerns:
Section 1105.3 Pedestrian Signal Phase Timing: A mandatory 3.0 fps crossing rate does not take into account the nature of the intersection. Is the intersection near a school or a retirement center, or in an area known to be frequented by individuals with disabilities? If so, then 3.0 fps, or even 2.5 fps, may be a valid number. In any signal timing decision, it is very important to balance the safety of the pedestrians with the safety of the motorists.
1105.6 Roundabouts: The requirements in this section will largely negate the benefits achieved by installing low volume residential roundabouts. These are generally used as traffic calming devices, and help to protect the public. Requiring barriers and signals will raise the cost beyond a feasible and reasonable amount, thereby eliminating a useful tool to combat vehicle speeds (in itself, a major safety issue.) Moreover, is the necessity of selecting a gap in traffic any different than the situation at an unsignalized mid-block crosswalk?
1106 Accessible Pedestrian Signal Systems: The requirements in this section may lead to fewer installations of pedestrian signal systems (due to cost). To avoid this potential pitfall, the section should encourage working with disability groups to determine the best locations and best mix of equipment for accessible pedestrian signals. Our goal is to provide pedestrian signals at all signalized locations with pedestrian facilities. To accomplish this, we intended to look at each intersection on a case by case basis, utilizing inputs from professionals and residents.
1108 Detectable Warning Devices: Section 1108 gives no thought to the differences in maintenance between southern and northern cities. Any design we complete, whether it is for parking, highways, traffic calming, or signals, must consider the complexities of ice and snow removal. A requirement that does not consider this factor may be disregarded, or worse yet, make of itself a safety hazard.
1109 On-Street Parking: The requirement for 1 handicap parking space per block face assumes a problem where none may exist. In many of our residential areas, parking density is not an issue. Requiring an indented curb at one location on a residential block would have several unintended consequences. First, it may serve to DECREASE access by implying (but not
requiring) that a handicap-parking permitted vehicle should park in this spot. Secondly, in a low density area, the driver will want (and be able) to park next to his destination. Third, it will create unreasonable expenses in residential areas. Finally, why create a situation where snow and ice removal will be more difficult, and where extra signage will be required, when a problem does not exist? Again we advocate working with your local disability group to target areas in need. We don't need sign pollution, or unnecessary curb indents. Our downtown area has been targeted, and has received additional handicap parking in the last few years, in areas needed by the disabled community.
These comments are not objections to improving mobility and access. Our City believes in access for all, where a balance is reached in safety for all individuals. All transportation solutions must consider safety and cost, so as to provide an economically feasible project that meets the project goals and objectives. This is best accomplished with guidelines that permit a flexible approach to access, allowing for creative solutions that apply engineering criteria and judgment.
Sincerely,
Andrew P. Avery, P.E., Sr. Engineer
Public Services Department
City of Elmira
Elmira, NY
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
Billie Jean Keith, October 28, 2002
Comments from the Northern Virginia Council of the Blind
Regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY Docket Number: 02-1
Submitted: October 28, 2002
Submitted by Billie Jean Keith, President of the Northern Virginia (NOVA) Council of the Blind
The Northern Virginia Council of the Blind is pleased to provide comments on the Draft Guidelines for Accessible Public Rights-Of-Way, issued on June 17, 2002. We are very concerned that many walkways and intersections are not accessible for a blind person, no matter his/her travel skills. I will mention two in my neighborhood. The most dangerous is the crossing at North Fairfax Drive and Glebe Road in Arlington. I have never been able to cross that street for the 14 years I've lived in this area. Even though it is only five blocks from my home, I must take a cab to get past that intersection. Another is crossing Wilson Blvd. at Glebe Road. However, I wish to provide general comments, not just my problems travelling.
The NOVA Council of the Blind has been in existence for twenty five (25) years and is dedicated to the independence and quality of life for Virginians who are blind and visually impaired. NOVA is also a chapter of the American Council of the Blind.
The Draft Guidelines for Accessible Public Rights-Of-Way proposed by the Access Board are of great interest to our members.
Section 1104 Curb Ramps And Blended Transitions
NOVA agrees with the Access Board's recommended guidelines with regard to curb ramps and blended transitions. Of particular interest is the requirement in Section 1104.3.2 that detectable warning surfaces be provided wherever a curb ramp, landing, or blended transition connects to a crosswalk. The use of detectable warning surfaces at such locations would provide a safe way of indicating that the approach to a vehicular way is near.
Section 1105 Pedestrian Crossings
1105.4 Medians and Pedestrian Refuge Islands: NOVA supports the requirement for installation of detectable warnings on medians and pedestrian refuge islands set forth in 1105.4.2. We concur with the Board's conclusion that an exception is appropriate for islands where the crossing is controlled by signals which are timed for full crossing.
1105.6 Roundabouts: nova supports the recommendations in 1105.6.1 that barriers be provided at roundabouts, along the street side of the sidewalk where pedestrian crossing is prohibited.
Section 1106 Accessible Pedestrian Signal Systems
NOVA strongly supports the requirement that each crosswalk with pedestrian signal indication shall have a signal device which gives audible and vibrotactile indications of the walk signal. We agree with the Board that care should be exercised in the location of pedestrian push buttons to insure that, to the maximum extent feasible, push buttons for accessible pedestrian signals will be placed where they can be located and activated by the pedestrian while leaving sufficient opportunity for the pedestrian to reach the curb in time to respond to the walk signal.
Section 1108 Detectable Warnings
NOVA supports the Access Board's guidelines for the location and installation of detectable warning surfaces, as set forth in this
section. We believe that the specifications contained herein
minimize the accessibility concerns of persons who have mobility impairments, while greatly enhancing the ability of visually impaired people to access the public right-of-way in a safe manner.
The Americans with Disabilities Act requires communities to take all reasonable steps to insure that people who are blind have access to the same information
provided to the general public. The guidelines recommended here represent a thoughtful and reasonable attempt to assist communities in carrying out that responsibility.
Thank you very much for considering these comments from our organization.
Billie Jean Keith
Richard A. Retting, October 25, 2002
Architectural and Transportation Barriers Compliance Board
Draft Guidelines for Accessible Public Rights-of-Way
In response to the Draft Guidelines for Accessible Public Rights-of-Way (June 17, 2002) proposed by the Architectural and Transportation Barriers Compliance Board (Access Board, 2002), the Insurance Institute for Highway Safety opposes the provisions that would mandate installation of traffic signals on pedestrian crosswalks at all roundabouts.
Background
Modern roundabouts are designed to function safely and efficiently without traffic signals and, in most cases, are constructed to replace less safe and less efficient stop sign-controlled intersections. Roundabouts are circular intersections with specific design and traffic control features that eliminate the need for traffic signals. These features include yield control of all entering traffic, channelized approaches with raised splitter islands, and geometric curvature to ensure slow travel speeds for vehicles entering into and within the roundabout.
Roundabouts are relatively new in the United States. Las Vegas, Nevada, built the first modern U.S. roundabout in 1990 (Jacquemart, 1998), and since then only 200-300 roundabouts have been constructed nationwide. In comparison, Australia and many European countries have been installing roundabouts extensively for decades, with, for example, more than 2000 roundabouts built in the Australian state of Victoria alone.
Effects on road safety of converting intersections to roundabouts has been the subject of extensive research in the United States and abroad. Results clearly indicate that roundabouts are an extremely safe form of intersection traffic control. For example, an Institute-supported evaluation of 23 U.S. intersections converted from stop sign or traffic signal control reported large reductions in motor vehicle crashes after roundabouts were installed (Persaud et al., 2001). Overall, crashes were reduced by an estimated 40 percent, injury
crashes declined by 80 percent, and crashes resulting in fatal or
incapacitating injuries were reduced by 90 percent. A recent meta-
analysis of 28 separate roundabout safety evaluations from outside the United States concluded that roundabouts were associated with a 30-50 percent reduction in the number of injury crashes and a 50-70 percent reduction in fatal crashes (Elvik, in press).
Although these studies do not provide conclusive evidence of the safety of pedestrians at roundabouts (primarily because of small samples of pedestrian crashes), available research suggests roundabouts can provide a relatively high degree of safety compared with intersections with stop sign and traffic signal control. For example, in the Persaud et al. (2001) study, four pedestrian crashes were reported during the before period and one was reported during the period after roundabouts were built (this difference was not significant due to the small sample size). Brude and Larsson (2000) analyzed pedestrian crash data at 72 roundabouts in Sweden and concluded that roundabouts pose no problems for pedestrians compared with conventional signal control intersections. For single-lane roundabouts, the observed numbers of pedestrian crashes were 3-4 times lower than for comparable signalized intersections, controlling for pedestrian volumes and traffic flow. Jordan (1985) examined pedestrian crash patterns at roundabouts in Victoria, Australia for the 4-year period 1980-83. A total of 35 pedestrian crashes were reported (average 9 crashes per year) at approximately 800 roundabouts. The author characterized this as an extremely low rate of pedestrian crashes and concluded that "concern for pedestrian safety at roundabouts, while well intentioned, is unfounded." Tumber (1997) conducted a review of pedestrian safety at roundabouts, also in Australia. The study focused on roundabouts constructed on arterial roads within the Melbourne metropolitan area during 1987-94. During this period, 64 pedestrian crashes were reported at approximately 400 roundabouts, for an average crash rate of 0.02 crashes per roundabout per year. The severity of pedestrian crashes (as indicated by the proportion of injuries classified as either serious or fatal) also was lower for roundabouts than for intersections with other forms of traffic control.
The safety of blind pedestrians at roundabouts has been questioned by some advocates of the visually impaired, but direct evaluations of crash data are not available. In an indirect evaluation of the issue, Guth et al. (2002) collected data regarding the ability of blind pedestrians to use their hearing to distinguish "crossable" gaps in traffic at roundabouts from gaps that were considered by the authors too short to afford a safe crossing. This work was supported by the Access Board. Three study sites in Maryland included a low-volume, single-lane roundabout; a large, urban, high-volume, two-lane roundabout; and an urban, intermediate-volume, two-lane roundabout. Six blind and four sighted pedestrians observed traffic at roundabout crosswalks and indicated by pressing a button whenever they believed they could complete a crossing before the arrival of the next vehicle. For the low-volume, single-lane roundabout, gaps between vehicles longer than 10 seconds
2-3 seconds
Despite the finding by Guth et al. (2002) that blind pedestrians can adequately judge gaps at single-lane roundabouts with little difficulty and as well as sighted individuals, the Access Board is proposing guidelines that would require signalization of pedestrian crosswalks at all roundabouts on the basis that the safety of blind pedestrians mandates such devices. This proposed requirement would apply even in rural settings where pedestrian activity is infrequent and where blind pedestrians may be nonexistent. However, traffic signals appear to be unnecessary at single-lane roundabouts and, if mandated, actually could be detrimental to highway safety. It is likely that the arbitrary addition of traffic signals to well designed roundabouts could increase the risk of injury crashes due to disruptions in traffic flow. Also, substantial costs associated with installation and maintenance of traffic signals might discourage some communities from constructing roundabouts. Even for high-volume, two-lane roundabouts, the Guth et al. field study does not make a compelling case for traffic signals because of weaknesses in the research methodology. Blind pedestrians were driven to roundabouts and then observed after minimal exposure to these unfamiliar locations. This is unrealistic because blind pedestrians typically do not wander into such areas without a guide to provide initial orientation. Guth et al. merely provides evidence of the perception of risk, not actual risk. The blind pedestrians may have been more willing to press a button when they believed they could complete a crossing than to begin crossing, thus inflating the numbers of "risky" judgments. Also, comparable data were not collected for intersections controlled by traffic signals or stop signs.
Compared with conventional intersections, roundabouts can provide improved access and safety for blind pedestrians as well as sighted individuals because of specific roundabout design and operational characteristics. First and foremost, traffic speeds within roundabouts are very low -- typically 15-20 mph -- compared with considerably higher traffic speeds at most traffic signal and stop sign-controlled intersections. Pedestrian refuge islands at roundabouts provide for short crossing distances. Also, roundabouts are relatively simple intersections that eliminate left turns, right turns, and the associated turning-vehicle conflicts common at conventional intersections. By comparison, conventional intersections are characterized by higher traffic speeds, longer crossing distances, and are more complex due to two-way traffic flow and frequent vehicle turning movements. Preusser et al. (2002) reported that 25 percent of motor vehicle-pedestrian collisions in Washington D.C. involve turning vehicles.
The combination of low traffic speeds, short crossing distances, and absence of turning vehicles in conjunction with White Cane Laws - laws in 47 states that require drivers to yield the right-of-way to a person carrying a white cane or accompanied by a guide dog --- provide safe crosswalks for blind pedestrian at many roundabouts. Additional measures that could enhance safety include textured pavement in conjunction with ramps to help lead blind pedestrians to crosswalks, raised crosswalks that can further slow entering and exiting traffic, and pedestrian yield signs in both directions of the crossing that require drivers to stop for pedestrians waiting on the crosswalk. Also, specific training can be developed and provided to help the visually impaired perceive gaps in traffic and to give drivers cues to stop.
Signalizing roundabout crossings can be justified when the combined volumes of pedestrians and vehicles are high or at locations with complex geometry such as high-volume school zones. In Australia and Europe, the vast majority of roundabouts are unsignalized, but some roundabouts in urban areas do have pedestrian signals. The recommended threshold for signalizing pedestrian crossings in the United Kingdom is:
PV2 > 1 ? 108,
where
P = Pedestrian volumes per hour (average of peak 4 hours)
V = entering vehicles per hour (average of peak 4 hours)
Rather than adopting the Access Board's recommendation to require signalization on pedestrian crosswalks at all roundabouts, regardless of need or justification, the Institute supports the Australian and European practice of installing pedestrian signals at appropriate locations based on objective criteria.
Opposition to Draft Guidelines
The Access Board indicates that the absence of stopped traffic presents a problem for pedestrians with vision impairments in crossing streets. It is true that traffic signals at conventional intersections establish a stop-and-go pattern that can assist blind and visually impaired pedestrians in crossing busy streets by producing audible cues about vehicle movements. However, a large majority of U.S. intersections are not controlled by traffic signals. Most intersections are governed by one-way or two-way stop sign control, which only require vehicles traveling on minor intersection approaches to stop. At most stop sign-controlled intersections, vehicles traveling on major intersection approaches are not required to stop, and at such locations travel speeds often can exceed 40-50 mph. So clearly, the absence of stopped traffic, while potentially problematic for pedestrians with vision impairments, is a frequently encountered condition. Like countless other crossings where traffic does not stop, blind pedestrians primarily rely on hearing to identify gaps in traffic.
The draft guidelines also suggest that crossing at a roundabout requires a pedestrian to visually select a safe gap between cars that may not stop. This statement is inaccurate as well as insulting to pedestrians who are blind. With proper training, blind pedestrians use their hearing to identify and select gaps in traffic at a wide range of unsignalized crossings where traffic may not stop. Even the Access Board-sponsored research by Guth et al. (2002) reported that blind individuals can cross single-lane roundabouts with relatively little difficulty and with few "risky" judgments (and more than half of U.S. roundabouts are single-lane, as reported by Jacquemart (1998)).
The Access Board claims that people who are blind or visually impaired are unable to make eye contact with drivers making it impossible to "claim the intersection." Blind pedestrians obviously are unable to make eye contact with drivers, regardless of the type of intersection traffic control. However, because roundabouts produce low travel speeds, short crossing distances, and eliminate turning vehicles, pedestrian crossings at roundabouts should be safer for blind pedestrians relative to many other unsignalized crossings. White Cane Laws, which require drivers to yield the right-of-way, further enable blind pedestrians to claim the intersection at roundabout crossings despite the inability to make eye contact.
Summary
The Institute opposes provisions of the draft guidelines that would require installation of traffic signals on pedestrian crosswalks at all roundabouts. The Access Board has provided no scientific evidence in support of this proposed requirement and, furthermore, it is likely that the arbitrary addition of traffic signals to well-designed roundabouts could increase the risk of motor vehicle crashes, in particular rear-end collisions, due to disruptions in traffic flow. Substantial costs associated with installation and maintenance of traffic signals might discourage some communities from constructing roundabouts or installing pedestrian crossings. Compared with conventional intersections, roundabout design and operational characteristics can provide improved access and safety for blind as well as sighted pedestrians, and additional measures can be taken to further improve the safety of blind pedestrians at unsignalized roundabout crossings such as textured pavement, raised crosswalks (speed tables), and increased lighting. Rather than adopting the Access Board's recommendation to mandate signalization on pedestrian crosswalks at all roundabouts -- regardless of need or justification -- the Institute supports the practice of installing pedestrian signals at appropriate locations where needed, based on objective criteria.
Sincerely,
Richard A. Retting
Senior Transportation Engineer
References
Architectural and Transportation Barriers Compliance Board. 2002. Draft guidelines for accessible public rights-of-way. Washington, DC. Available: http://www.access-board.gov/rowdraft.htm#DRAFT.
Brude, U. and Larsson, J. 2000. What roundabout design provides the highest possible safety? Nordic Road & Transport Research 12:17-21
Elvik, R. 2002. Effects on road safety of converting intersections to roundabouts: A review of evidence from non-US studies. Transportation Research Record. Washington, DC: Transportation Research Board, in press.
Guth, D.; Long, R.; Ponchilla, P.; Ashmead, D.; and Wall, R. 2002. Non-visual gap detection at roundabouts by pedestrians who are blind: a summary of the Baltimore roundabouts study. Washington, DC. Available: http://www.access-board.gov/publications/roundabouts/ research-summary.htm.
Jacquemart, G. 1998. Modern roundabout practice in the United States. Synthesis of Highway Practice 264. Washington, DC: Transportation Research Board.
Jordan, P.W. 1985 Pedestrians and cyclists at roundabouts. Proceedings of Local Government Engineers Conference. Perth, Australia.
Persaud, B.N.; Retting, R.A.; Garder, P.E.; and Lord, D. 2001. Safety effects of roundabout conversions in the United States: empirical Bayes observational before-after study. Transportation Research Record 1751, 1-8. Washington, DC: Transportation Research Board
Preusser, D.F.; Wells, J.K.; Williams, A.F.; and Weinstein, H.B. 2002. Pedestrian crashes in Washington, DC and Baltimore. Accident Analysis and Prevention 34:703-10
Tumber, C. 1997. Review of pedestrian safety at roundabouts. Victoria, Australia: VicRoads, Road Safety Department.
Debbie Grubb, October 20, 2002
The Americans with Disabilities Act has broken down many barriers. One barrier that still stands pretty firmly on its foundation is the barrier faced by individuals who are blind and visually impaired, the barrier known as Access to Information.
I am sure that you have received many letters proclaiming the glories of travel with the long white cane and of receiving rehabilitation services in certain enlightened rehabilitation centers that negate the necessity for tactile warnings at street curbs and accessible pedestrian signals at intersections. The issue of tactile warnings at curbs and accessible pedestrian signals at intersections is clearly and simply access to information. Many blind people have no concept of the multitude of signage that sighted people see and use every hour of the day. Now technology exists that grants us the assurance that we are at what well might be an undetectable curb. What is of supreme importance to individuals who use wheelchairs proved to be often frustrating and dangerous to people who are blind and visually impaired. This no longer has to be the case because signage now exists that lets us know that the entrance to the street is dead ahead. Now technology exists to let us know something that sighted people have been told for decades--the walk light is initialized. Crossing busy streets every day of my life and having known the joy and certainty of using accessible pedestrian signals, I can tell you that knowing of a certainty that the walk light is initialized takes a lot of the guess work out of crossing streets with the constant movement of traffic due to right turn on red and green turn arrows. No, these signals do not guarantee a safe crossing; but neither do walk lights guarantee that for sighted people. Accessible pedestrian signals simply give a vitally important piece of information that we are morally entitled to and entitled to by the spirit of the ADA.
Congratulations to the Access Board for your wise and forward thinking recommendations regarding tactile warnings at curbs and accessible pedestrian signals at intersections. You have my support.
Debbie Grubb
CITY OF LINCOLN NE
RE: Draft Guidelines on Accessible Public Rights-of-Way
The City of Lincoln has reviewed the draft Guidelines on Accessible Public Rights-of-Way. While we applaud efforts to improve mobility for all citizens, we are concerned that the draft guidelines currently under consideration will have numerous consequences, many of which are negative.
You will find enclosed a copy of a letter compiled by Randy Hoskins, the City's Traffic Engineer. The letter outlines the concerns the City of Lincoln has with proposed guidelines. These concerns have been raised through Public Works Department and City Council review.
We would encourage you to take another look at the guidelines. Many are excellent and will provide needed improvements. Others may have unintended consequences that will be difficult to enforce, apply and/or fund. Still others may make for less safe conditions for all pedestrians, along with increasing delay, costs and pollution of vehicular traffic.
Sincerely,
Don Wesely
Mayor of Lincoln
October 20, 2002
Scott Windley
RE: Draft Guidelines on Accessible Public Rights-of-Way
Dear Mr. Windley:
The City of Lincoln has reviewed the Draft Guidelines for Accessible Public Rights-of-Way. We realize that Title II of the ADA requires governments to not discriminate against people with disabilities and we support the efforts to improve existing conditions. However, the guidelines as proposed would have serious consequences that would impose significant costs on local governments. It is also our feeling that these would be overly restrictive and would not allow sufficient latitude to design on a case by case basis.
Our comments and concerns are as follow:
Curb Ramps and Blended Transitions (1102.6, 1104)
- Also, drivers may not be as alert to persons crossing at the apex of a corner.
It would seem drivers would be much more alert at this point in the roadway than after driving around a corner and encountering a pedestrian when their vehicle has attained a higher speed than at the apex of the corner.
Other Requirements for Curb Ramps and Blended Transitions (1104.3.3 - 1104.3.7)
- prohibit the placement of... utility and sewer access covers, and similar fixtures on ramps, landings, transitions and portions of the gutter within the pedestrian access route;
If these items meet the criteria set forth for changes in level, why would they not be allowed?
- prohibit grade breaks on ramp runs, blended transitions, landings, and gutter areas within the pedestrian access route;
How will the gutter work if it must be at the same grade as the ramp? That will either force all the water out into the street or funnel it all back onto the sidewalk.
- prohibit any vertical changes in level on curb ramps, landings and gutter areas within the pedestrian access route;
Again, if the vertical change is within the requirements for changes in level, it should be allowed. To keep nuisance water from ponding within a ramp area, a minimal lip is often maintained to keep the water off the ramp and moving around the corner.
- require clear space at least 48 by 48 inches
This is confusing as to intent.
Crosswalks (1105.2)
- The cross slope is limited to 1:48
This may be fine for new areas, but it is often not realistic in built environments. Changing slopes of streets to accommodate this ruling may not be feasible.
Pedestrian Signal Phase Timing (1105.3)
- The draft guidelines would require pedestrian signal phase timing to be calculated according to a walking speed of 3.0 feet
This would have a major negative impact on traffic. Requiring this change would more than offset the gains our jurisdiction has made through expenditures of hundreds of thousands of dollars to improve the traffic carrying capabilities of our streets, which has been a mantra of the FHWA for years. To make this change system-wide would increase energy consumption, pollution and vehicular costs to motorists to accommodate a small percentage of the population who might use a signal. It would seem that if the route is used by handicapped individuals who cannot cross in the 3.5 ft/sec time, then the change to a 3.0 ft/sec crossing time COULD be used as needed.
Pedestrian Overpasses and Underpasses (1105.5)
- The draft guidelines address access to pedestrian overpasses and underpasses, which would be required to provide a pedestrian access route. A ramp would be required where the running slope exceeds 1:20
Implementation of this rule would practically kill off the installation of underpasses and overpasses for pedestrian crossings. Since it is quite rare where the grade change of such a structure would be less than five feet, nearly every one constructed would require an elevator. The major reason stated for not installing these structures is cost. When you add the cost of providing elevators at each end to the already high price, you have just made these infeasible except in the most extreme cases. By doing so, this would increase the hazard to all pedestrians, handicapped and able-bodied alike, forcing them to cross using at-grade crossings.
Roundabouts (1105.6)
- To provide safer crossing at roundabouts, the draft guidelines would require pedestrian activated crossing signals at each roundabout crosswalk, including those at splitter islands.
This requirement sounds as if it was written by a group of people scared of new ideas and who have absolutely no clue what they are talking about. We have just completed a roundabout to replace a signal at one of the highest accident locations in the City. A lot of people opposed to this installation stated it would be dangerous for pedestrians to cross. Quite the opposite is true. Pedestrians only have to cross one lane at a time, they are crossing at a point where traffic is moving slowly entering or leaving the roundabout and the driver is alert because of the increased requirements placed on them. To now have to signalize these would completely waste the advantages they naturally provide pedestrians. In certain areas where high volumes of pedestrians and vehicles exist, crossing lights may be of use, but a requirement for all or even most locations can only benefit signal suppliers.
Since vehicles would be moving at higher speeds and pedestrians would have longer crossing distances, by using the same logic, we should put in crossing signals at every unsignalized intersection also.
- Barriers or similarly distinct elements are needed to prevent blind persons from inadvertently crossing a roundabout roadway in unsafe locations. The draft guidelines would require a continuous barrier along the street side of the sidewalk where pedestrian crossing is prohibited. If a railing is used, it must have a bottom rail no higher than 15 inches
Since vehicles would be moving at higher speeds and peds would have longer crossing distances, by using the same logic, we should put in barriers at every unsignalized intersection also. Again, this just doesn't make sense. By following the sidewalk, pedestrians are directed to the safest crossing locations.
Turn Lanes at Intersections (1105.7)
- The draft guidelines also include a requirement for a pedestrian activated signal at each segment of a crosswalk that crosses right or left turn slip lanes.
This will likely increase vehicular crashes. In order to place the signals where turning vehicles can see them an adequate distance in advance of the crossing, they will also be visible to through vehicles who may become confused by several conflicting indications. Rear end and side-swipe crashes will likely result.
This should not be mandatory at all locations, but rather should be considered on a case by case basis. If signals are not needed for non-handicapped persons, there is a question as to whether or not they would be needed for handicapped individuals.
Accessible Pedestrian Signal Systems (1102.8, 1106)
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal indication shall have a signal device which includes audible and vibrotactile indications of the WALK interval. Where a pedestrian pushbutton is provided, it shall be integrated into the signal device and shall comply with 1106.3.
Obviously these add cost to signal installation/maintenance. Where will the funding for this come from in these tight economic times?
1106.2.1 Location. Pedestrian signal devices shall be located 60 inches
This will require major reconstruction of many traffic signals. In many locations, it is not possible to comply with this due to existing obstructions in the way of the signal, including underground utilities.
1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone at the pushbutton. Locator tone volume measured at 36 inches
This is another cost concern. It is also sometimes a concern with nearby residents/businesses as to the addition of noise pollution.
1106.4.2 Street Name. Signs shall include street name information aligned parallel to the crosswalk direction and complying with 703.2.
Another cost concern.
On-Street Parking (1102.14, 1109)
- The draft guidelines would require access to at least one parking space on each blockface.
In an area with 150 foot
This also does not specify if this would be required city-wide or only in commercial areas. Providing the required handicapped parking space with signing, pavement markings and ramps on every block in the city would create an astronomical cost.
- Requirements address adjoining access aisles at spaces, accessible connecting routes, signs, and parking meters. An accessible parallel space and access aisle, which must be flush with the street, can be achieved by indenting the curb line, similar to a loading zone.
This will create problems during snow events. Plows will come along and push snow into the indented area, making them useless. These will also create discontinuities in the sidewalks in downtown areas where sidewalks normally run from the face of buildings to the edge of the curb. In high ped areas, this will have a major negative impact. I think the cost of lawsuits related to trips and falls in these inset areas each year will greatly outweigh any benefits derived from their installation.
Passenger Loading Zones (1102.15)
- ADAAG requirements for passenger loading zones would be applied to loading zones in the public right-of-way. Where a long loading zone is provided, at least one area in every 100 continuous feet must comply with requirements in ADAAG section 302 and 503 which address the surfacing, the size of vehicle pull-up spaces (8 by 20 feet
These will not work well at schools where it is important to provide curbs to create barriers to vehicles running onto sidewalks and hitting pedestrians.
- 1111.3 Location. The alternate circulation path shall parallel the disrupted pedestrian access route, on the same side of the street.
This is a costly unfunded mandate. Providing parallel ped access on the same side of the Street as the existing path is often not practicable. Based on costs and usage, it is often impossible to justify not moving pedestrians, both able bodied and disabled, to an adjacent route.
- 1102.5.2 Post-Mounted Objects. Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches
The MUTCD allows secondary signs to have a minimum height of 72", vs. 80" required here. This would require major work to change signs throughout the city.
Again, we support reasonable access for disabled pedestrians and continually review our standards and processes to assure that what we are doing is reasonable and safe. We are concerned that these draft guidelines, if adopted, would create major consequences for communities of all sizes. We would ask that these consequences be considered more carefully before enacting any changes to the existing requirements.
Sincerely,
Randy Hoskins, P.E.
City Traffic Engineer
City of Lincoln, Nebraska
Roger Church and the Memphis Council of the Blind, October 28, 2002
The names and addresses listed in the signature of this letter are the members of the Memphis Council of the Blind and other concerned citizens in the Memphis area. We all strongly agree with the report and recommendations of the Public Rights of Way Advisory Committee, particularly where detectable warnings and accessible pedestrian signals are concerned. We believe that they greatly increase both the safety and independence of blind and visually impaired pedestrians.
A DETECTABLE WARNING IS THE TACTILE EQUIVALENT OF A FLASHING SIGN. It instantly focuses the pedestrian's attention as nothing else can. Blind persons can easily and independently detect the warnings. We find them particularly hopeful at intersections where street boundaries are unclear.
Accessible pedestrian signals produce clear audio tones that sound when the light is in the pedestrian's favor. This information would make it much easier for us to negotiate busy intersections like Poplar and Ridgeway and move quickly and safely toward our destination. In addition, the warnings are essential on approaches to subway entrances. It's a really scary experience when one goes to a city with a subway system and nearly falls into the pit. Unfortunately, a number of blind people have actually fallen in and were killed or seriously injured.
Installing detectable warnings and accessible pedestrian signals will allow both drivers and pedestrians to use our streets safely and efficiently. We urge you to carefully consider all the comments submitted, and decide in favor of saving lives by adopting the recommendations in the Public Rights of Way Advisory Committee's report. Thank you for your time and consideration.
Sincerely,
Roger Church
[Attached petition (PDF) includes names of 54 persons]
I write this letter to urge the Access Board to exercise restraint with respect to detectable warnings and "accessible" pedestrian signals. These technologies are not universally accepted within the blind community. As a blind person who has lived in more than three states in this country, I must tell you that I deplore the efforts of those who would require detectable warnings and so-called accessible pedestrian signals at every intersection to foist their paternalistic philosophy of blindness on society.
The over-all accessibility movement will be irreparably damaged if the Access Board requires the ubiquitous installation of "accessible" pedestrian signals and detectable warnings. These devices are merely the euphemistic expressions of those policy makers who do not understand how it is that a blind person can safely negotiate the environment. Blind people like me are already crossing streets and negotiating dangerous areas without these unnecessary and worthless technologies.
The cost to society of installing detectable warnings and "accessible" pedestrian signals at every intersection is simply too high?especially, when one realizes that they do not improve accessibility one little bit. Some might argue (I don't) that they may address some issues of safety, but the public rights of way are already accessible to the blind. Remember that. The public rights of way are already accessible to the blind. Please do not mix issues of safety with accessibility. You are the Access Board--not the National Highway Safety Administration, and as such, your attention should be focused solely on accessibility. 1 simply do not believe the tax dollars that have already been wasted by irresponsible considerations based on false and inaccurate presumptions about the ability of blind people to live and compete in the world.
In summation, I as a taxpaying blind person don't want these devices, I don't need them, and neither do lots of other blind people whom I know!
Yours sincerely,
Brad Hodges
Anthony Todd, October 28, 2002
I will try to be brief.
* Widening crosswalk widths indiscriminately has a real cost. It is
unnecessary in many locations and the requirement should either be recommended or have criteria on the number of pedestrians using the crosswalk. The infrequent occurrence at most locations will probably not be improved by moving a white line over two feet.
* The cross slope requirement is not only very nearly impossible in
many locations in eastern Tennessee (and many other areas across the country), the cost to implement would be well in excess of the community's ability to fund. Johnson City allows subdivision streets to have a maximum grade of 14% and requires sidewalks. New subdivisions would either be virtually eliminated in hilly terrain or sidewalks that lead to street crossings would have to be prohibited in these locations; this seems to be moving backwards (not forward to better accessibility).
* Pedestrian timing is an important issue but a requirement of 3.0
feet per second be used in the calculations without regard to the anticipated users is inappropriate. It increases driver frustration, congestion, potential accidents and is unnecessary in many locations.
* It would seem that at least one study should be conducted before
setting the requirements for the maximum length of ramps for pedestrian overpasses and underpasses.
* A blanket requirement for pedestrian activated signals at roundabouts is more dangerous for the pedestrian and the driver. Infrequently used signals blend into the background and go unnoticed. A pedestrian anticipating a vehicle stopping that does not will be a victim of the requirement and will be the one suffering the consequences. Also for the same reason the driver that does notice the signal and stops will have a great probability of being hit from behind if the following vehicle does not notice that the signal has changed. The is a purpose behind the use of traffic signal warrants. Better guidance to appropriate crossing locations could be a real solution.
* What constitutes a barrier?
* Turn lane signals? See the comment on roundabouts.
* Briefly stated: There needs to be significant studies done on the effectiveness of accessible pedestrian signal systems before many cities spend millions of dollars.
* The location of pedestrian pushbuttons cannot always be positioned where it is desired. We have many locations where trucks make lazy turns where they can get by with it and frequently have knocked down pedestrian signal poles -- forcing us to move the pole (buildings prevent widening of some radii).
* Alternate circulation paths on the same side of the road are often impossible due to the location (sidewalk repair in downtown areas is a good example).
* Signal timing based on a 3 feet
* I fully support the resolution from the Tennessee Section Institute
of Transportation Engineers.
Thank you for your consideration.
Anthony Todd
Traffic Division
City of Johnson City