John W. Van Winkle, P.E.
|
October 25, 2002 |
To the Access Board of the Office of Technical and Informational Services:
I am writing in regards to the proposed guidelines for accessible rights of way.
I am in full agreement with the comments expressed by the Tennessee Section of
the Institute of Transportation Engineers, which I have attached.
I would also like to add comments regarding the section on roundabouts. The
recommendation to require pedestrian-actuated crossing signals and continuous
barriers at roundabouts seems impractical and inconsistent. In many cases,
roundabouts are built to eliminate the need for signalization. To require
signals at a roundabout is contrary to this intended goal.
If pedestrian signals and barriers are to be required for roundabouts, why would
they not be required for all pedestrian crosswalks? A crosswalk at a roundabout
approach is very similar to a crosswalk at any channelized T-intersection or,
for that matter, any midblock crosswalk. In the case of a midblock crosswalk,
the conditions are actually more hazardous for pedestrians in one respect
because the speeds are higher.
I recommend that this section on roundabouts be deleted from the guidelines
or at least amended to be a recommendation, rather than a requirement.
John W. Van Winkle, P.E.
District 5 President of ITE
City Traffic Engineer
Chattanooga, Tennessee
TENNESSEE SECTION, INSTITUTE OF TRANSPORTATION ENGINEERS
RESOLUTION
POSITION OF THE DRAFT “GUIDELINES FOR ACCESSIBLE RIGHTS-OF-WAY”
WHEREAS, the Tennessee Section of the Institute of Transportation Engineers is a
professional organization of over 250 persons who are actively involved in the
field of transportation and who share a common interest in improving the quality
of the surface transportation system in Tennessee; and
WHEREAS, the mission of the Tennessee Section of the Institute of Transportation
Engineers (TSITE) is the professional development and growth of the traffic and
transportation industry, promoting safe and efficient flow of people, goods and
services; and
WHEREAS, the membership of the Tennessee Section of the Institute of
Transportation Engineers represent the local government agencies who will be
most impacted by the proposed “Guidelines for Accessible Rights-of-Way”
developed by The Access Board; and
WHEREAS, a review of the draft “Guidelines for Accessible Rights-of-Way” was
conducted and the Tennessee Section of the Institute of Transportation Engineers
desired to make its comments and concerns known to The Access Board since its
membership will be directly impacted by the proposed guidelines and responsible
for implementing many of its recommendations; and
WHEREAS, the Tennessee Section of the Institute of Transportation Engineers
shares The Access Board’s desire to ensure that access for persons with
disabilities is provided within the public right-of-way and that the same degree
of convenience, connection, and safety afforded the public generally is
available to pedestrians with disabilities. However, we are concerned that the
proposed guidelines do not take into account the negative impacts and in some
cases extreme impacts to the primary users of the public right-of-way, the
motorist; and
THEREFORE, the Tennessee Section of the Institute of Transportation Engineers
would like to provide the following comments for consideration by The Access
Board when developing the final “Guidelines for Accessible Rights-of-Way”:
1. What types of improvements or maintenance activities will trigger any
requirements for accessibility improvements? Will filling potholes, making spot
drainage improvements, upgrading signal displays, recutting vehicle detector
loops, restriping a roadway require accessibility improvements? The types of
activities need to be clarified.
2. What accessibility improvements should reasonably be expected to be made when
the trigger is activated?” What is meant by the phrases “technically infeasible”
and “maximum extent feasible?” These need to be defined and clarified so that
reasonable requirements are made by the Access Board and not by the Court
system.
3. Alternate Circulation Paths – The guidelines call for an alternate
circulation path parallel to and on the same side of the street as the disrupted
pedestrian access route, however, this is not always possible. This requirement
also gives no guidance as to the amount of time the closure may take place
without requiring an alternate route. Would utility work in a manhole for 1 hour
require the construction of an alternate access route? How can existing
sidewalks be brought up to the proposed standards if they can’t be closed for a
day? The phrase “other temporary conditions” appears to be vague and could mean
just about anything to a potential litigant. Further clarification on these
issues needs to be provided.
4. Cross Slope of Crosswalks – The guidelines call for the cross slope of cross
walks to be 1:48 maximum measured perpendicular to the direction of pedestrian
travel. This would in effect require the “tabling” of the crosswalk or
intersection and could require adjustments in the vertical alignment of the
roadway well beyond the intersection which, depending on the road’s design
speed, may be significant. Street elevations may end up being different from the
adjacent sidewalk elevations, which may make sidewalks between intersections
even steeper. Installing “tables” for emergency vehicles could be a serious
problem. Loss of control of vehicles in urban areas due to these “tables” could
have tremendous safety implications for pedestrians alongside the roadway. This
requirement is unrealistic and will likely lead to decreased safety for the
motorist and pedestrians. We strongly feel that this requirement should be
deleted from the guidelines.
5. Curb Ramps – The guidelines discourage diagonal curb ramps at intersections.
While it may be possible to design new intersections to accommodate single ramps
for each crosswalk, reconfiguring many existing intersections with new ramps
would require complete reconstruction of the roadway including moving
crosswalks, parking, signals, etc. In addition, some intersections may function
better for both pedestrians and motorists by using diagonal ramps. We recommend
including diagonal ramps in the guidelines as an acceptable option for use in
appropriate situations and encouraging the use of single ramps at newly designed
intersections.
6. Pedestrian Signal Phase Timing – The guidelines change the pedestrian signal
timing by using a walking speed of 3.0 feet per second maximum. The total
crosswalk distance used in calculating pedestrian signal phase timing shall
include the entire length of the crosswalk plus the length of the curb ramp.
These requirements seem excessive if they applied to all intersections,
especially those with minimal pedestrian activity. This will present serious
disruptions to motorists at a time when we are trying to reduce congestion
through means other than widening roadways. We recommend maintaining the design
criteria for traffic signals as defined in the MUTCD.
7. Channelized Turn Lanes at Intersections - The guidelines will require a
pedestrian activated traffic signal for each segment of the pedestrian
crosswalk, including across the channelized turn lane. The impact of this
requirement will be devastating to capacity at many intersections. Signalizing
these locations may actually decrease the safety of pedestrians and vehicles
because the signals are likely to be ignored by many drivers. We recommend
deleting this requirement from the proposed guidelines.
8. Accessible Pedestrian Signal Systems – The guidelines will require the
installation of Accessible Pedestrian Signal systems at all existing signalized
intersections with pedestrian indications. The costs of these devices will be a
tremendous burden on already strapped traffic engineering agencies. These
requirements appear to be overkill by providing these expensive and untested
devices at all intersections, regardless of the need. We recommend retaining the
MUTCD requirements until studies prove the safety benefits of these devices.
WHEREAS, the Tennessee Section of the Institute of Transportation Engineers
understands the need for standards related to access for disabled pedestrians,
however, we have serious concerns about the impacts of the proposed guidelines
and believe that some are not realistic or cost effective and that revisions to
the draft guidelines are necessary.
NOW, THEREFORE, BE IT RESOLVED, that the Tennessee Section of the Institute of
Transportation Engineers submits these comments listed above for consideration
and requests that serious consideration be given to the issues raised; and
BE IT FURTHER RESOLVED that the Tennessee Section Institute of Transportation
Engineers Board of Directors directs that these recommendations be submitted to
the US Access Board on or before October 28, 2002.
APPROVED: Cindy Pionke, P.E., President
Anthony Todd, Vice President
Bill Kervin, P.E., Secretary-Treasurer
Craig Hanchey, P.E., PTOE, Immediate Past President
___________________________________ __________________
Craig Hanchey, P.E., PTOE
Date