Michael Hankey
|
October 28, 2002 |
Comments on Draft Guidelines for Accessible Public Rights-of-Way (dated
June 17, 2002)
Submitted by: Village of Hoffman Estates, Illinois
Michael Hankey
Director of Transportation
Thank you for the opportunity to review and comment on the draft guidelines. I
understand there will be another chance for public comment at the time the
proposed rule is developed. Please consider these items in the development of
the proposed rule.
For local agencies, the cost of implementing changes must be considered. The
concern is that there is no increased funding from government programs
identified at this time to pay for modifications to pedestrian and roadways
featured as proposed in the draft guidelines. Timely implementation of
construction changes will dependent upon funding available to assist
municipalities.
It is important to consider the needs of potential users when evaluating the
planning, design, and operation of transportation facilities. A concern with the
draft guidelines is that they apply blanket provisions and requirements
throughout the system. A more reasonable approach is to consider accessible
measures in specific areas of the community where the benefit and need is
expected to be the greatest. Examples include audible / vibratory signals,
slower walking speed, on-street accessible spaces, etc. There are locations
where these measures should definitely be a part of the design and operation,
but they do not need to be applied throughout the system. Traffic signals and
other controls are based on need. The application of the accessible guidelines
should follow a need-based assessment too.
Perhaps the “guidance material” on how the proposed guidelines apply to projects
where alterations are made will be helpful. It sounds like this guide will be
available in early 2003. I ask that notification be sent when it is available
and that input on that document be considered before developing the proposed
rule.
The on-street accessible space section needs significant clarification and
revision. Again, a main concern is a blanket application of this item. To
require at least one accessible space per block face in all situations is not
realistic. Why not allow this determination to be made based on needs of the
community? The reduction in general supply due to this requirement is not likely
to be viewed by the public as reasonable provision for accessibility. The cost
and impact on right-of-way and streetscape are also concerns.
Other areas that need clarification and revision are: the 60 inch cut-off for
elevator access at underpasses / overpasses should be evaluated based on
something more than cited in the document; review design and performance data
for roundabouts before recommending additional pedestrian signals; passenger
loading zones.
Please consider these comments in developing the proposed rule for
accessibility. These are offered in the spirit of developing guidelines that
reflect need for accessibility improvements, the ability to implement, while
also balancing the cost and impact to the community.