Brian K. Copeland, P.E.

October 25, 2002

 
I commend your efforts on the development of the new accessibility guidelines. However, there are a few instances where implementation of these guidelines would be cost prohibitive or may not be feasible from an engineering standpoint. The needs of public agencies and designers need to be balanced with needs of disabled persons. My comments are as follows:

1. Protruding Objects (1102.5). Traffic signal controller cabinets are frequently mounted on signal poles, especially in downtown areas where space is constrained. These cabinets would violate your proposed 4" guideline. I agree that these cabinets and other attachment to poles should be kept outside of the pedestrian circulation path, but there need to be provisions for allowing cabinets to be mounted on poles if they are outside the main pedestrian path. For example, the City of Portland has hundreds of these types of controllers mounted on poles. As written, this guideline would severely cramp design efforts and would be very costly to agencies.

2. Detectable Warnings (1104.3). Truncated domes are used in the Portland area for pedestrian/at-grade LRT crossings. When a blind pedestrian experiences truncated dome treatments in the Portland area, they know they are about to cross a rail alignment. Other options should be evaluated for curb ramps outside of at-grade rail crossings (I have seen horizontal raised strips in some areas that seem to be effective). There needs to be distinction between crossing a road and crossing an LRT/heavy rail trackway.

3. Pedestrian Signal Phase Timing (1105.3). Changing the pedestrian walk time from 4.0 ft/sec to 3.0 ft/sec will have significant, far-reaching impacts on our nation's transportation system. By reducing the walk speed, green time will be taken away from vehicle movements and the capacity of many intersections will be reduced. This would lead to the need for costly capacity improvements at intersections which most agencies cannot afford. Where did the 3.0 ft/sec come from? How much has this been studied? We need data/proof that lives will be saved if we do this...

4. Roundabouts (1105.6). What type of signals are we talking about? Requiring all pedestrian crossings at roundabouts to include standard pedestrian signals would be a mistake and would defeat the purpose of the roundabout altogether. There are other ways (pedestrian activated warning flashers or signage, for example) to help create a safe pedestrian crossing. However, there needs to be flexibility to address this on a case by case basis. A signal of some type may be desired on a multilane roundabout, whereas a low-speed, single lane roundabout may only call for signage.

I have worked as an transportation engineering/planning consultant in the Portland, OR area for the past 10 years and have broad experience in transportation design. Please consider the above input as you
finalize the guidelines. Thank you.

Brian K. Copeland, P.E.
DKS Associates