Comments and Recommendations on the Draft Guidelines for Accessible Public
Rights-of-Way
October 2002
Traffic Engineering Section of Mass. Highway Department reviewed the proposed
ADA guidelines. In general we support the AASHTO comments and recommendations.
We would like to high light some of the most important issues covered under
these guidelines which will be very troublesome for all DOT's. The following
points should be considered seriously:
1. It is unclear how these proposed guidelines will relate to other
regulations that must be met within the transportation field, such as air
quality, historical preservation, and environmental protection regulations. Many
of the proposed accessibility guidelines, if implemented, could have profound
impacts on the ability of State and local jurisdictions to meet these existing
federal mandates. These conflicts could result in substantial penalties being
levied or the denial of transportation funding if existing regulations are not
met.
2. A clarification is needed to the term " alteration", as well as the
requirements that it triggers. Currently, this term is open to a wide range of
interpretation, which is likely to expose public agencies to potential lawsuits.
Access Board should develop additional guidance related to the definition of
"alterations" and accessibility improvements they trigger, using typical
engineering terminology to ensure understanding by implementing agencies.
3. The current edition of the MUTCD requires a 72-inch minimum
crosswalk, while the draft guidelines require an extra two feet in all cases.
This requirement for a 96-inch crosswalk does not appear to be driven by
accessibility needs. Eight-foot wide crosswalks are excessive in many small
rural towns where few pedestrians are present.
4. All pedestrian signal phase timing shall be calculated using a
pedestrian walk 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. We have a
serious concern about this guideline, as the slower crossing speeds and longer
distance for calculating the traffic signal timing will have a significant
effect on traffic flow in major metropolitan areas where congestion is already
heavy.
5. Section 1106 will require the installation of Accessible Pedestrian
Signal systems at all existing signalized intersections with pedestrian
indications. This will be a major cost item for the State and local
municipalities. The added complexity of the systems will increase installation
time and cost, as well as maintenance needs.
We strongly urge the Access Board to consider these comments and amend the
proposed Draft Guidelines accordingly.
Thank you for the opportunity to comment on these proposed Draft Guidelines.
If you have any questions regarding these comments, please contact Mr. Charles
F. Sterling, P.E., State Traffic Engineer at [ ... ].
Sincerely,
Harindra Vohra, P.E.
Asst. Traffic Engineer
Mass. Highway Department
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