Comments on Draft Guidelines for Accessible Public Rights-of-Way (dated June 17, 2002)

Submitted by: Village of Hoffman Estates, Illinois
Michael Hankey
Director of Transportation


Thank you for the opportunity to review and comment on the draft guidelines. I understand there will be another chance for public comment at the time the proposed rule is developed. Please consider these items in the development of the proposed rule.

For local agencies, the cost of implementing changes must be considered. The concern is that there is no increased funding from government programs identified at this time to pay for modifications to pedestrian and roadways featured as proposed in the draft guidelines. Timely implementation of construction changes will dependent upon funding available to assist municipalities.

It is important to consider the needs of potential users when evaluating the planning, design, and operation of transportation facilities. A concern with the draft guidelines is that they apply blanket provisions and requirements throughout the system. A more reasonable approach is to consider accessible measures in specific areas of the community where the benefit and need is expected to be the greatest. Examples include audible / vibratory signals, slower walking speed, on-street accessible spaces, etc. There are locations where these measures should definitely be a part of the design and operation, but they do not need to be applied throughout the system. Traffic signals and other controls are based on need. The application of the accessible guidelines should follow a need-based assessment too.

Perhaps the “guidance material” on how the proposed guidelines apply to projects where alterations are made will be helpful. It sounds like this guide will be available in early 2003. I ask that notification be sent when it is available and that input on that document be considered before developing the proposed rule.

The on-street accessible space section needs significant clarification and revision. Again, a main concern is a blanket application of this item. To require at least one accessible space per block face in all situations is not realistic. Why not allow this determination to be made based on needs of the community? The reduction in general supply due to this requirement is not likely to be viewed by the public as reasonable provision for accessibility. The cost and impact on right-of-way and streetscape are also concerns.

Other areas that need clarification and revision are: the 60 inch cut-off for elevator access at underpasses / overpasses should be evaluated based on something more than cited in the document; review design and performance data for roundabouts before recommending additional pedestrian signals; passenger loading zones.

Please consider these comments in developing the proposed rule for accessibility. These are offered in the spirit of developing guidelines that reflect need for accessibility improvements, the ability to implement, while also balancing the cost and impact to the community.