Craig G. Kocian
|
October 25, 2002 |
CITY OF ARVADA
PUBLIC WORKS DEPARTMENT -TRAFFIC ENGINEERING DIVISION
Architectural and Transportation Barriers Compliance Board:
The City of Arvada has reviewed the proposed guidelines offered by the
Architectural and Transportation Barriers Compliance Board (Access Board) for
the Design of Accessible Rights-of-Way. After careful review and discussion by
City staff we offer the following comments and suggestions:
1. Section 1102.2.2 Alterations. We look forward to the future release of
guidelines for alteration projects and would encourage the Access Board to
carefully consider its impacts to items that many municipalities consider
routine maintenance. An example of this would be in the replacement of short
stretches of existing sidewalk (i.e. 5-15 feet) that are not currently 48 inches
wide. Given existing constraints (such as right-of-way limits) it may be best to
continue with existing 36 inch wide sidewalks, but keep them in good repair
through replacement of cracked, broken, and/or raised sections of the pedestrian
route.
2. Section 1102.3 Alternate Circulation Path. The suggested requirement that
alternate circulation paths must be parallel and on the same side of the street
as the disrupted access route will be infeasible for many projects that are
under construction or maintenance. In many cases adequate right-of-way is not
available to build such a path, and in these cases obtaining additional
right-of-way would be cost prohibitive, disruptive to private property owners
and users, and impractical. We would suggest that instead the requirement
include provisions that safe and accessible pedestrian crossings be required for
access to alternate paths, and that these paths may be located on either side of
the street as per the requirements of the MUTCD. The impacts to projects that
require only brief (up to one day) impacts to the pedestrian route also need to
be considered in these requirements.
3. Section 1104.3.2 Detectable Warnings. The City considers these to be a major
concern for maintenance and especially snow and ice removal. These devices will
be impossible to completely remove snow and ice from and will create additional
safety issues with a slippery surface for all users of the pedestrian path. If
it is not possible to remove these requirement then we would urge the Access
Board to consider the suggestion that detectable warnings should not be required
on curb ramps and blended transitions that are detectable by a slope of at least
1:15. This would help to minimize the concerns that we have by limiting their
use and overall numbers.
4. Section 1104.3.4 and 1104.3.5 Grade Breaks and Changes in Level. Grade breaks
or vertical changes between ramps and the gutter I flowline assist in the
drainage of storm water and the prevention of ice build up on ramps. These
breaks also help vehicles to better determine the traveled way versus ramps and
pedestrian routes and helps prevent vehicles from traveling over these areas
when making turns at intersections. The strict language as proposed does not
take these situations into consideration and we believe this will have an
adverse impact on pedestrians of all abilities.
5. Section 1104.3.6 Counter Slopes. Current industry practice and drainage
design assumes a counter slope on gutters to be 1: 12. The requirement of 1 :20
as a maximum will create drainage problems by reducing the capacity of the
gutter. Since the 1: 12 is a current standard and does not appear to present an
undue burden on pedestrians we would recommend that this section be modified to
read as such.
6. Section 1105.2.1 Crosswalk Width. The minimum width of cross walks should be
as stated in the MUTCD (72 inches) except as local conditions may warrant. The
universal requirement for 96 inches is too large for the relative size of many
intersections, as it will require vehicles to stop at a distance farther from
the intersection. This will cause vehicles to commonly encroach into crosswalks
when stopping at intersections so that drivers will have adequate sight distance
at the intersection. Also, in many areas the number of pedestrians using a
crosswalk at one time is small and the need for people of any ability to pass
each other is minimal, thus a universal requirement of 96 inches is not needed.
This would also equate to an unfounded mandate that would increase the cost of
crosswalks by nearly 33% for the additional material, time and maintenance for
the additional width. This additional cost will cause municipalities to
re-consider the placement of marked crosswalks and reduce the number of them.
7. Section 1105.2.2 Crosswalk Cross Slave. The proposal of limiting crosswalk
cross slope to 1 :48 (2%) will be difficult if not impossible to meet at many
locations, particularly those regions like Colorado that present many
topographic challenges (i.e. hills and mountains). The current industry standard
for intersection is up to 6%, which is necessary in area with steep grades. In
order to achieve the 2% it would be necessary to create a steeper grade leading
up to the intersection, and would thus also increase the grade of the sidewalks
adjoining the street leading to the intersection, or may require the acquisition
and expense of additional right-of-way and disruption to private property users.
8. Section 1105.3 Pedestrian Signal Phase Timing. It is our belief that this is
an issue to be addressed at specific locations and signals and should not be a
uniform requirement. The increase in the time required by the change from
current practice of 4 fps to 3 fps will cause many issues with the progression
of traffic signals and will create additional delay to the traveling public, the
consumption of additional fuel, and the creating of additional air pollution
from this increased delay. The additional pedestrian crossing time is not needed
in most cases and will cause additional red signal time that will frustrate
motorists and will led to an increase in the occurrence of red light running,
thus endangering more pedestrians and motorists. This issue should be addressed
as needed and requested in specific areas and/or communities.
9. Section 1105.5 Pedestrian Overpasses and Underpasses. The guidelines
requirement of an elevator for rises over 60 inches is unrealistic and causes
other safety concerns with the use of unsupervised elevators that may be placed
in remote or unmonitored locations. Many times we grade separate pedestrian
paths from roadways to increase t11e safety for the pedestrians by eliminating
the need to cross the path of vehicles. This requirement would make the building
of these separations considerably more expensive and would likely led to many of
them never being constructed. The on-going maintenance of elevators placed in
weather and environmental elements and in remote locations and along busy
corridors will create a large burden for municipalities. We are also concerned
about the safety of people using elevators in unmonitored areas where help would
not be readily available in the event of mechanical malfunction or in the event
of criminal action. We recommend that this requirement be removed and other
options be considered.
10. Section 1105.6 Roundabouts. The requirement to install traffic si~a1s on
each leg of a roundabout eliminates all advantages to this type of intersection.
Placement of traffic signals at each leg would be in violation of the
requirements for signals in the MUTCD and will generate confusion for drivers as
to what actions they should take at a roundabout. The confusion that would be
created by signals placed at roundabouts would cause safety concerns for all
users. Recent studies have indicated that roundabouts provide an overall safer
intersection for a1l users, and when crashes occur they are usually at lower
speeds resulting in less serious injuries and damages. We recommend that this
requirement be removed and additional options researched and considered.
11. Section 1105.7 Turn Lanes at Intersections. The requirement that free right
of left turn lanes be signalized will add confusion to the operations of these
lanes at a signalized intersection, including confusion on who has the right of
way for turns versus the through movements given the different signal
indications that will be present. The additional delay the elimination of these
lanes will cause will generate additional air pollution, burn more fuels, and
decrease the operating efficiency of the road network. This would also defeat
the purpose of these improvements by eliminating much of the additional capacity
this type of lane gives an intersection. The problems and costs generated by
this requirement will probably led to the elimination of the use of these types
of turn lanes and will thus impeded a high number of users. We believe that it
is possible for pedestrians of all abilities to safely cross at these devices
when they are properly engineered. This requirement maybe acceptable at areas of
high pedestrian volume but should not be a blanket requirement.
12. Section 1106.2 Pedestrian Signal Devices. The requirement of audible and
vibrotactile indications of the walk interval should not be required at all
intersections. We currently install audible indications of the walk interval
when requested and have had complaints from other disabled users that this is
not necessary and causes them more difficulty. The volume requirement is also
difficult, as with current equipment the volume would have to be set for the
noisiest time of the day. Even at current settings we receive complaints from
people who live or work near these signals about the noise. Increasing the
volume is likely to increase the complaints and present new problems for all
involved, including visually impaired individuals who have complained that these
devices make it more difficult for them to discern the sounds of vehicular
traffic. The need and use of these devices should be a location specific
determination and upon request of the users.
13. Section 1106.3 Pedestrian Pushbuttons. The requirement of locator tones for
pedestrian pushbuttons will led to additional noise pollution and confusion for
pedestrians given the number of different audible noises mixing with and
changing the background sound. This tone will also mix with the audible walk
indicator for other phases of the signal and will create a mixture of different
sounds. The need and use of these devices should be a location specific
determination and upon request of users of the facility.
14. Section 1102.4 On-Street Parking!. Since block lengths can vary greatly
depending on the layout of the roadway network this requirement is extremely
problematic and may cause more parking areas to be designated than intended. We
suggest that this requirement be eliminated and that guidelines could be offered
for the use of on-street parking and the creation of accessible spaces. The
guidelines should take into consideration the type of area and the size of
blocks that are present.
15. Section 1109.2 Parallel Parking Spaces. The requirement for a 60 inch wide
access aisle will be a problem in winter conditions. These areas will not be
accessible to plows and thus will not be cleared of snow and ice. Drainage
around this spots will also be difficult leading to accumulations of water,
debris and ice. Since most van and car lifts do not need an area that is flush
with the street this requirement may not be necessary .Instead we would suggest
that the requirement be that the sidewalk be of adequate width to allow for the
lift access. It is also unlikely that a driver will be able to pull all the way
into the access aisle since it would be a difficult maneuver for anybody
para11el parking.
As the stewards of public money (taxes ) we are required to consider the costs
and benefits of what we do. Many of the items discussed in this letter would
cause additional cost burdens to the taxpayers, and in some instances would
create hann or lessen the benefits to the general public of facilities in the
right-of-way. These issues must be considered in anything that we endeavor to
complete and should be considered in any final rules that are made. Action on
these guidelines and future proposed rules should be delayed and additional
input from all members of our society and communities should be considered and
used in crafting the final requirements.
The City also voices its support and strong encouragement for the Access Board
to consider the comments and recommendations
adopted on October 14,2002 by the American Association of State Highway and
Transportation Officials (AASHTO). Their review and comments provide a good
summary of concerns from officials throughout t11e transportation profession.
We appreciate the opportunity to offer these comments and trust that they will
be of use
in drafting the final guidelines and ultimately in any rulemaking that may occur
on this issue. If you have additional questions please feel free to contact the
city Public Works Department at [...].
Regards,
Craig G. Kocian
City Manager
Traffic and Transportation City Engineer
Parks and Urban Design City Managers office