Mark L. Schoeffmann, P.E.

October 23, 2002

Village of Arlington Heights


To Whom It May Concern:

I am writing to express concern about several items in the proposed ADAAG for public right-of-ways. I know the intent is to make public right-of-ways safer for those with disabilities, but the safety of those without disabilities must be considered at the same time. I believe several of the proposals will result in the compromising of safety for the public in general and should only be used when warranted by special conditions.


Comments on Proposed ADAAG for Public Right-of Way

1) Pedestrian Signal Phase Timing

A reduction in the required pedestrian walking speed to 3.0 feet per second will have a significant impact on intersection capacity and safety on heavily traveled roadways. The current practice in our area is to utilize 4.0 feet per second and should only be adjusted when warranted for special circumstances, not at all locations.

2) On-Street Parking

The requirement to provide at least one accessible parking space on each block face is not appropriate to all situations. Why should accessible parking spaces be provided on the street in areas where they are already provided in off-street parking facilities? In densely developed commercial area, every on-street parking space is important to the economic vitality of the area. The availability of parking to the public at large would be impacted if the number of accessible spaces exceed the need for accessible spaces.

In addition, the movement in and out of vehicles is safer in an off-street space away from moving traffic.

3) Pedestrian Overpasses and Underpasses

The requirement to provide an elevator for any location that results in an approach of over 60 inches will significantly increase the initial construction cost, increase maintenance costs and decrease safety for these facilities. The requirement to include two elevators with every pedestrian overpass or underpass proposal will result in the delay or canceling of these types of projects due to the high initial and long term maintenance costs. This will have a negative impact on access and safety for all pedestrians who would benefit from the overpass or underpass.

4) Accessible Pedestrian Signal Systems

The requirement for audible walk indicator tones and locator tones for pedestrian signals will not be acceptable in residential areas. The constant beeping of these devices will be extremely annoying to nearby property owners. This requirement will result in the elimination of pedestrian signals at new traffic signals and will decrease the safety for all pedestrians.

5) Detectable Warning Surfaces

The truncated domes proposed for new curb ramps will be difficult to construct in the field. If these detectable surfaces are precast or available in plastic tiles and must be embedded in fresh concrete, the concrete slab’s integrity will be compromised and this will lead to early deterioration. Snow removal difficulty from the proposed warning surfaces can lead to icing and slippery conditions, increasing the hazard to all pedestrians.

I believe that more research and investigation is necessary before these guidelines are approved to determine under what circumstances they should be implemented.

Sincerely,

Mark L. Schoeffmann, P.E.
Director of Engineering