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

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