Below is a letter sent earlier responding to the proposals from the US Access Board.  I have since read the letter from the City of Pueblo Colorado penned by Dan Centa.  It is an excellent response, hitting home on most all issues regarding urban area practicalities.  In our genuine zeal to improve conditions for the disabled, it is important to do so in a way that does not set-back other important national priorities (i.e. air quality, mobility, consumption of fuel, overall traffic safety, and in some cases degradation of service for disabled with other types of disabilities).

Mr. Centa's discussion about "unintended consequences" is very real, and touches on important issues. Mainly it is important that the final product not be so rigid that it REQUIRES actions that will certainly carry with them unintended consequences. Some should remain guidelines rather than mandates, to preclude adverse impacts.  In the cases noted, (and a few others too), the consequences may appear to be  "unintended", but they are readily obvious to those accountable and responsible for overall public safety in urban areas.

One last concern is whatever guidelines come out need to respect past efforts of municipal governments. I am proud of our city's efforts, where we have spent about $1,000,000 per year on rebuilding curb returns citywide for the past few years.  We have now completed virtually all transit related routes, and are expanding elsewhere.  The new proposals are different than the old with regard to ramps, negating all that public investment and conscientious follow-through toward meeting the previous access board desires.  Any changing of design standards needs to NOT negate or penalize those forward thinking cities that have tried in good faith interest to improve the overall environment for the disabled community.

Thank you for listening

James W. Sparks P.E.
Deputy Street Transportation Director
City of Phoenix

Just a short note of concern to the very detailed proposed "accessibility requirements" being advertised in the Federal Register.  Please see to it that these comments get considered prior to going forward with the proposal.

(1) Input regarding accessibility FROM the accessibility community is essential, and it is good that those efforts are underway.

(2) How those concerns are addressed is an engineering issue as well as an accessibility issue, and any final rules regarding attainment of the issues needs to be processed using the very same procedure all engineering features of that control the public rights of way.  While I am sure each proposal is well intended, there are inadvertent SERIOUS consequences that can result from failure to benefit from the years of experience the National Committee on Uniform Traffic Control Devices offers.  I can recall an accessibility proposal years ago that would have enlarged signalized intersections by 30% due to a proposal that would set the crosswalks way back from the intersecting streets.  Doing so would have adversely affected safety for not only the disabled community but the entire public at large. Fortunately this got resolved.

(3) One current proposal falls victim to the myth that traffic signals are in some way safety devices. THEY ARE NOT. The collision rate at signals is double that of similar unsignalized intersections.  Signals are essential (no choice) in some instances, but unless essential are bad medicine and counterproductive to traffic safety.  The proposal to have to signalize crosswalks near roundabouts is unwise and counterproductive.

(4) Similarly, the requirement for signalization of right turn lanes is an emotional proposal rather than one conducive to safety of all concerned.  To ignore that fact puts all users at risk.

(5) Requiring a specific walking speed other than what has been found to be a good compromise considering all aspects of making signals function safely, is WRONG.  There is nothing wrong with making such a proposal, but the final decisions should be made by trained engineers familiar with the upsides and downsides of traffic signals.

Thank you for listening.

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