I was a member of a committee composed of representatives from various City departments that reviewed the Draft Public Rights-of-Way Accessibility Guidelines. Comments from the City of Plano, Texas are included in the attached file. We appreciate the opportunity to participate in this important process. Please feel free to contact me if you have any questions or need any additional information.

Ronnie Bell, P.E.
Senior Traffic Engineer
City of Plano
 

October 17, 2002


Mr. Scott Windley, Office of Technical and Information Services
Architectural and Transportation Barriers Compliance Board
1331 F Street, NW, Suite 1000
Washington DC 20004-1111

RE: Draft Public Rights-of-Way Accessibility Guidelines

Dear Mr. Windley:

The City of Plano has assembled a group of city planners, traffic engineers, civil engineers and public works officials to review the Draft Public Right-of-Way Guidelines proposed by the Access Board. The City fully supports the goal of increased accessibility and has spent many capital improvement dollars retrofitting curb ramps and sidewalks to make the city streets as accessible as possible. However, we do have concerns about the application and practicality of some of the proposed standards, and offer the following comments and suggestions for consideration:

1101 Application and Administration

1101.3 Defined Terms

Curb Line – this definition assumes that the sidewalk, if there is a sidewalk, is always adjacent to the curb. This is not the case in most suburban and residential areas.

Element & Facility – The definition of “element” includes the term “facility” and the definition of “facility” includes the term “element.” Therefore, these appear to be circular references with no clear definition. Traffic control signs (and their supports) and traffic signals (and their supports) are located in public right-of-way. Is it intended that they be included in the definition of element, facility, or both?

Sidewalk – In some cases, sidewalks may be in easements on private property instead of in public right-of-way or they may meander between easements on private property and the adjacent public right-of-way.

Street Furniture – the “elements in the public right-of-way that are intended for use by pedestrians” definition is too general. The sidewalk is in the public right-of-way and is intended for use by pedestrians, but it should not be considered street furniture. Street name signs and traffic signals are located within the public right-of-way and are intended for use by pedestrians (as well as drivers). These also should not be considered street furniture. A specific definition of those things specifically considered street furniture should be prepared.

Walk Interval – this definition should be modified to read as follows: “That phase of a traffic signal cycle during which the pedestrian is to begin crossing, typically indicated by a WALK message or the walking person symbol and, where provided, its audible equivalent.

1102 Scoping Requirements

1102.2.1 Additions & 1102.2.2 Alterations
It appears that the proposed wording of these sections would require the installation of audible pedestrian signals and audible/vibrotactile pedestrian detector buttons/poles for any new traffic signal installation and for modifications to existing traffic signals. See later comments for 1106 concerning pedestrian signals.

1102.3 Alternate Circulation Path
Sidewalk repairs often involve numerous locations along a block, but only a few short sections of walk may be removed and for only a short period of time. This would result in several separate alternative paths being created and maintained in the same block, and in many instances, the alternate circulation path would place pedestrians immediately adjacent to fast-moving traffic lanes on major arterial streets. We suggest that if sidewalks are available on both sides of the street, the sidewalk on the opposite side of the street should be permitted as an alternate circulation path.

1102.5.2 Post Mounted Objects
For right-of-way areas near traffic signal controlled intersections, this section needs to permit the installation of the traffic signal control cabinet on a post. Although some controller cabinets are ground mounted, many in a CBD area are post mounted. These are likely to be mounted with the bottom higher than 27 inches and the top lower than 80 inches.

1102.14 On-Street Parking
Outside of downtowns or high-density mixed-use districts, individual parking spaces are not typically marked, especially on residential streets. The proposed wording does not distinguish between locations where on-street parking is provided with marked parking spaces versus locations where on-street parking is provided but there are no marked spaces. It is not clear whether or not this requirement is intended to apply to blocks with unmarked spaces. This situation is typical in residential subdivisions where parking is permitted on the street but no specific parking spaces are marked. Under these conditions, the provision of a marked on-street accessible parking space should not be required. Cities should have the option to respond to individual requests for parking, so that spaces are placed in a location most convenient to disabled residents.

1104 Curb Ramps and Blended Transitions

1104.3.3 Surfaces
The prohibition of access covers and other appurtenances on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route may discourage the installation of additional sidewalks in some cases. If this prohibition includes traffic signal pull boxes and a traffic signal currently exists at a location proposed for new sidewalk installation, relocating existing pull boxes out of the prohibited areas can be both costly and disruptive. Since pull boxes are used to connect conduits, route the control cables around the intersection, and connect vehicle loops to the detector cables, the relocation of a pull box also requires modifications to the underground conduit and either replacing or splicing the cables. During the cable work, the traffic signal will likely have to be operated in either flashing mode or turned off depending on the cables involved. Similar extensive underground work would be required where various access covers exist for other underground items such a telephone or communications cables, sanitary or storm sewers, or other utility items.

If the access cover is made flush with the surrounding walkway area, it should be permitted to be in these areas. When faced with a decision to undertake such a degree of work on an existing signal or utility facility to accommodate the installation of a sidewalk, many agencies may choose to not install the sidewalk. When new traffic signal and utility facilities are being installed, the design can typically locate the access covers outside the curb ramp, landing, blended transition, and gutter areas. However, relocating existing items involves extensive work and expense.

Are traffic signal, utility, street light, and other such poles intended to be included in this prohibition? The use of the work “appurtenances” in the list of prohibited items could be interpreted to include these. As with the access covers, the relocation of these can be both costly and disruptive. Also, underground and overhead utility lines often influence or control the location of these poles. Existing poles should be permitted to remain. New poles should be recommended to be located outside these areas but flexibility needs to exist for cases where the placement of the pole is controlled by existing underground and overhead utilities.

1105 Pedestrian Crossings

1105.3 Pedestrian Signal Phase Timing
Jurisdictions should be allowed to determine the necessity for the slower pedestrian walk speed, based on surrounding land uses and on the needs of individuals in the area. A requirement to use a maximum of 3.0 feet per second and include the lengths of the curbs ramps also will have a significant impact on the traffic signal timing at most intersections. This is a significant change from the existing Manual on Uniform Traffic Control Devices (MUTCD) guidance of 4.0 feet per second walking speed calculated only from the curb to the middle of the farthest traveled lane. The 2002 proposed MUTCD changes to the pedestrian clearance time only changed the calculation to include the entire street width. No change was included in the assumed walking speed. Traffic engineers are free to use walking speeds slower than the 4.0 feet per second listed as guidance in the MUTCD and often do so where conditions warrant. However, making an across the board change from 4.0 feet per second to 3.0 feet per second in the calculated walking speed, add the additional length of the ramp on each end of the crosswalk, and make it a requirement rather than guidance will require retiming of many traffic signals. This will have a significant impact where signals are operating in a coordinated system as all signals in a system may have to be retimed to maintain a common cycle length needed for progressive traffic flow. Increased vehicle delay and congestion resulting from longer pedestrian clearance timing and longer overall cycle lengths will have a negative impact on air quality.

1105.4 Medians and Pedestrian Refuge Islands
The proposed wording “medians and refuge islands in crosswalks” is good in that this section and its subsections would not be applied to medians that are not in crosswalks. In order to avoid possible confusion about a minimum 6 foot wide median requirement, a statement should be added indicating that medians less than 6 feet wide are acceptable as long as they are not in a crosswalk or used for pedestrian refuge. Medians adjacent to left turn bays in urban areas are often as narrow as 4 feet from face-to-face of curb.

1105.6 Roundabouts
1105.6.1 Separation
The requirement to provide a continuous barrier along the street side of the sidewalk where pedestrian crossing is prohibited is excessive. This requirement applies whether or not operational experience indicates a problem with crossings at inappropriate locations. Crossing at mid-block locations or at intersections where crossings are prohibited by signs may also be dangerous to pedestrians. However, physical barriers are not proposed to be required at these locations. If it is desired to treat prohibited pedestrian crossing areas at roundabouts differently than at other locations, the proposed wording should be in the form of guidance or option rather than an across the board requirement.

1105.6.2 Signals
The proposed wording requires the installation of a traffic signal for each crosswalk at a roundabout. This requirement is made without the benefit of any engineering study of traffic operations or level of pedestrian activity at the location. Visibility of the traffic signal to drivers approaching the roundabout should be similar to other traffic signals. However, drivers exiting the roundabout will have greater difficulty in seeing and responding to the traffic signal since they will be negotiating around the roundabout as they approach. They will not be able to view the signal indications from as great a distance as drivers on a straight approach. Additionally, traffic may back up around the roundabout while stopped for a red signal at the pedestrian crosswalk signal when departing the roundabout. In the event there is more than one crosswalk at the roundabout, it may be necessary to limit when the crosswalk signals can respond to a pedestrian call to avoid congestion if separate crosswalk signals served pedestrian demand consecutively.

1105.7 Turn Lanes at Intersections
The proposed requirement to provide a pedestrian activated traffic signal where pedestrian crosswalks are provided at right or left turn slip lanes is excessive. First, there should not be a requirement to install a traffic signal at an intersection simply because a crosswalk crosses a left or right turn slip lane. The proposed wording will require signal installation even if the intersection is operating well without a traffic signal. As in 1105.6.2, the signal installation requirement is not based on an engineering study of actual operating conditions at the location. Second, even if there is a traffic signal at the intersection, there should not be an automatic requirement to control the pedestrian crossing movement across a left or right turn slip lane. This requirement would force the turning movement to be controlled by a signal indication rather that the Yield or Stop signs that are commonly used in such cases. During the green signal indication for the adjacent through movement, using signal control for the turning movement has little or no impact whether a Stop or Yield sign has previously been used. The replacement of a Stop sign with a signal indication may lead to a slight operational improvement, at least during the time the signal is green, as the vehicles would no longer have to come to a stop before proceeding. However, the replacement of a Yield sign with a signal indication would have a significant impact. While the signal indication was red, vehicles would be required to come to a complete stop before making the permitted turning movement versus simply slowing to yield with the previous Yield control. The proposed control of turning movements in slip lanes should be modified to list signal control as an option but not as a requirement.

1106 Accessible Pedestrian Signal Systems

1106.2 Pedestrian Signal Devices
The proposed wording requires that all crosswalks with pedestrian signal indications have both audible and vibrotactile indications for the WALK interval. Audible signals at intersections in neighborhood settings, even those with volumes that respond to ambient noise, may annoy nearby residents at night when background noise levels are not high enough to dampen the sound. Audible signals should be activated only on a demand basis. Additionally, the installation of audible and vibrotactile indications of the WALK interval should not be required under all conditions. Rather, specific conditions requiring such devices could be listed but their use at other locations should be optional.

1106.2.1 Location
Typically, the standard pedestrian signal devices (pedestrian heads and pedestrian push buttons) serving both crosswalks will be located on one pole at that corner. The requirement that accessible pedestrian signal devices be separated by a minimum of 120 inches will preclude this type of placement and will result in at least one additional pole being installed on the corner. Whereas the MUTCD currently recommends that accessible pedestrian detectors and vibrotactile WALK indications be located at least 10 feet apart, this is not a requirement. This proposal makes this a requirement and adds the location of the audible WALK indications to this separation requirement. This section should be revised to provide recommendations rather than requirements.

1106.3 Pedestrian Pushbuttons
1106.3.2 Locator Tone
The proposed wording requires every pushbutton to be equipped with a locator tone. Whereas the audible WALK indication tone would only operate during the WALK periods, the push button locator tone is required to operate during the DON’T WALK and flashing DON’T WALK intervals. In residential settings or where the WALK interval is served only upon demand, the continuous operation of the detector locator tone may lead to complaints.

1106.4 Directional Information Signs
Revised wording is needed for this section. The existing wording of “pedestrian signal devices shall provide tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street containing the crosswalk served by the pedestrian signal” implies that each of the pedestrian signal devices must have these signs. This requirement should not be applied to typical WALK/DON’T WALK pedestrian signal heads. If required, the tactile and visual signs should be provided as part of the push button assembly or adjacent to the pushbutton assembly.

This proposed wording adds a requirement for the street names that is not otherwise required. There would be no street name information provided at an intersection that was not controlled by a traffic signal. The requirement to include the street name means unique signs must be installed for each corner with pedestrian signal devices. The provision of an arrow indicating the direction of the controlled crosswalk without the street name included would permit the use of the same device at multiple locations.

1109 On-Street Parking
It should be specified that this applies to accessible parking spaces and not all parking spaces. Otherwise, it could be interpreted that an access aisle is required adjacent to every parking space.

1109.2 Parallel Parking Spaces
The exception for when an access aisle is not required appears to assume there is a paved sidewalk. In some residential and other areas, paved sidewalks are not provided. Also, the proposed wording permits the exclusion “where the width of the sidewalk between the extension of the normal curb and the boundary of the public right-of-way is less than 14 feet.” This wording seems to apply only to cases where the entire area from the curb to the right-of-way is a paved sidewalk. Is this exception actually intended to apply in any case where there is less than 14 feet from the curb to the right-of-way line?

1109.3 Perpendicular or Angled Parking Spaces
Is a separate access aisle required for each parking space or can a single access aisle between two spaces serve both spaces? It is noted that there is no requirement on whether the access aisle is on the right side or left side of the parking space. It seems that a single aisle between two adjacent spaces would provide the needed access to the parking spaces.

1111 Alternate Circulation Path

1111.3 Location
The requirement that the alternate circulation path parallel the disrupted pedestrian access route and be on the same side of the street is impractical in many cases. If sidewalks in a residential area are being repaired or if utility work has caused the sidewalk to be closed, the right-of-way is often too narrow to provide the required 3-foot wide alternate path on the same side of the street. An alternate circulation path using the opposite side of the street may be the only practical choice. If faced with the alternatives of an unpaved path on the same side of the street or an existing paved sidewalk on the opposite side of the street, the paved sidewalk provides a superior option even if it is across the street.

It is noted that there does not seem to be a requirement that the alternate circulation path be paved. In fact, it would be impractical to include such a requirement for many cases. Repair of damaged sidewalk sections in residential areas may be completed in a couple of days. If the construction of a paved alternative path on the same side of the street were required, both the overall time and cost would increase.


Although the document title indicates it contains guidelines, the proposed wording actually establishes requirements rather than guidelines in many cases. It also includes several items that address the installation and/or operation of various traffic control devices. Since the MUTCD provides the standards, guidance, options, and support information for traffic control devices, any proposed additions or changes to the standards, guidance, options, or support information should also be reflected in the MUTCD.

Thank you for the opportunity for the city to comment on these proposals. If you have any questions or need additional information, please feel free to contact Ronnie Bell, Senior Traffic Engineer at (972) 941-7151.

Sincerely,


Lloyd E. Neal, P.E.
Transportation Engineering Manager
City of Plano