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Thank you for the opportunity to comment on the Draft Guidelines for Accessible Public Rights-of-Way. The City of Corvallis has reviewed the draft guidelines and we have the following comments.

* The word "shall" in the draft Guidelines should be replaced with
"should" or "may".
* 1105.3 We support the Board's decision that 3.0 feet per second is a
better choice than the advisory committee's recommendation of 3.5 feet per second, however, the length of the crosswalk for this calculation should not include the length of the curb ramps.
* 1106 Accessible Ped Signals - The City opposes the mandatory
requirements of this section. Corvallis has implemented audible pedestrian signals on actuated traffic signals since 1988. We have also attempted to install APS on fixed time signals and had to remove them due to a large number of complaints from the community. Provision of these systems should be encouraged where appropriate, but mandating their use does not recognize the reality we encountered nor the additional expense that many communities may not be able to afford thus eliminating the opportunity to install a traffic signal where it otherwise is warranted due to vehicle safety reasons.
* 1105.5.5 The City opposes the requirement that an elevator would be
required at pedestrian overpasses and underpasses where the rise of a ramped approach exceeds 60 inches.
* 1105.6.2 We oppose signalizing roundabouts. Signals would defeat
the benefit to the intersection design. We are concerned about the requirement of a "continuous barrier" or railing in 1105.6.1 in all cases. It seems that an appropriate design could be done to provide the barrier controls without them being so visually obtrusive.
* 1105.7 We oppose a requirement for signalizing slip ramps.
* 1102.14, 1109 The requirement for one parallel accessible space per
block is excessive especially where angled parking may cover an entire block, including an accessible angled parking space.
* Detectable Warnings (1108) - Should allow "Blind Signs" as an
acceptable alternative to the truncated domes. Assuming Blind Signs are acceptable, the installation instructions/technical specifications sections need to be modified. We believe that the Blind Signs are a superior detectable warning device since they are not only easily detected, but also informative as to direction of travel, type of conflict, etc.
* 1108.2.2 Rail Crossings - The City opposes the requirement of
placement of the detectable warning surfaces at 6 inches (150 mm) minimum and 8 inches (205 mm) maximum from the nearest rail. The current rail bed at crossings, especially the rubberized ones, would not lend themselves to this requirement.
* Platform Edges (1108.2.3) The requirement of the detectable warning
surfaces extending the full length of the platform is unreasonable in some cases. And if the Blind Signs are accepted, which we strongly support, this requirement makes no sense at all. We would prefer, if we are required to use truncated domes, to place them strategically at the loading and unloading areas and not the entire platform length. The platform is elevated above the travel lane and thus the edge of the platform can easily be detected with a cane.

We also agree with an e-mail we received (presumably you have it as
well) from the Oregon Bike/Ped Program Manager, Michael Ronkin:

5% running slope in xwalks: Okay
2% cross-slope in xwalks: Not on local streets in
hilly terrain
(1105.2.2.)

3 ft/sec: Okay in downtown, not in suburbs (1105.3, although
we take exception to including the length of the ramps as a part of the overall crossing length.)

APS: Generally okay with it (1106, but we take exception
to the mandatory nature of the requirements)

48" Generally okay, can cause problems on narrow
sidewalks (1103.3)

No grates in ramps/xwalks May not always be possible (1104.3.3
- 1104.3.7.)

One acc. parking spot/block No, lose too much parking, access
difficult on narrow sidewalks (1102.14, 1109)

Thank you again for the opportunity to comment on the Draft Guidelines.

Jim Mitchell
Transportation & Buildings Division Manager