Comments by the Willamette Pedestrian Coalition on the Draft Guidelines for Accessible Public Rights-of-Way

Willamette Pedestrian Coalition
Ellen Vanderslice, President
Doug Klotz, Policy Analyst

We are pleased to support the Draft Guidelines for Accessible Public Rights-of-Way. In general this document represents an advance for accessibility on public streets. Our specific comments follow and are also attached as a Word document for your convenience.

1102.14 On-Street Parking

We support the provision of accessible on-street parking. However, we respectfully disagree with the proposed requirement of one space per block. Blocks vary so greatly in size (including average variation between cities) that this is an inherently inequitable requirement. Perhaps the requirement should be something like one for every six hundred feet of on-street parking provided. Also, there should be a better definition of "where on-street parking is provided," whether this means where it is allowed or where it is marked or signed. The guidelines should clarify whether this requirement applies on every street, even low-volume residential streets where parking is permitted but not designated.

1103.3 Clear Width (of the Pedestrian Access Route)

We support widening the minimum clear width requirement in the public right-of-way, with the understanding that larger scooters may be used in this environment and that there should be room for two wheelchairs to pass. We would support the PROWAAC recommendation for 60 inches with 48 inches allowed for short distances.

1104.3.2 Detectable Warnings (in Common Elements of Curb Ramps and Blended
Transitions)

We support the requirement for detectable warnings at curb ramps and blended transitions. See additional comments on 1108.

1105.2 Crosswalks

We support all the crosswalk provisions, including the minimum width of 96 inches, the maximum cross slope of 1:48 (which will require tabling of
intersections) and the maximum running slope of 1:20 (which will require attention to the crowning of streets). Pedestrian crossings are critical to the complete pedestrian network and should be made accessible.

1105.2 Pedestrian Signal Phase Timing

While we support reducing the walk speed used to calculate crossing times, as well as the inclusion of one ramp in the value of the length of the crosswalk used in the calculation, we suggest that there might be an exception included for signals that use either passive or active detection to extend the pedestrian clearance interval on demand. If the system can provide the added crossing time only when needed, this will benefit those crossing in the perpendicular direction and reduce overall delay for pedestrians.

1105.4 Medians and Pedestrian Refuge Islands

We support the requirement for alignment of the cut-through with the direction of the crosswalk for a minimum of 24 inches where the cut-through connects to the street.

1105.5 Pedestrian Overpasses and Underpasses

We are supportive of the needs of users who experience fatigue but we are concerned about the effect of the 60 inch maximum rise on the provision of pedestrian facilities. We would support additional research to establish the maximum rise. We have a concern that, as written, and due to the prohibitive cost of installing and maintaining elevators, this guideline would lead to facilities with very long approaches at 1:20.

We respectfully suggest that the terms "pedestrian overpass" and "pedestrian underpass" be defined in section 1101.3. Without a definition, it is not clear which facilities require an elevator.

1105.6 Roundabouts

We respectfully suggest a definition in 1101.3 of "barriers" as used in 1105.6.1 Separation. We believe landscaping should be allowed as separation. The extent of the required separation should be specified more clearly.

We support 1105.6.2 Signals (at Roundabouts). As noted in the discussion, there currently is no alternative that allows for safe passage of pedestrians with disabilities.

Although this may not be an accessibility issue, we suggest that adding a new tool to the pedestrian signal arsenal could be helpful in this situation. There is currently no provision for pedestrian signals where "pedestrian yield," rather than "don't walk," is the default state. We believe such a signal would be useful in a situation like a roundabout where most pedestrians will use available gaps rather than request the walk signal.

1105.7 Turn Lanes at Intersections

We support the requirement for pedestrian signals with the same suggestions as we made for signals at roundabouts.

1106.2 Pedestrian Signal Devices

We support the requirement for accessible signal devices at all crosswalks with pedestrian signal indication.

1106.3 Pedestrian Pushbuttons

We would like to note that these draft guidelines do not require the use of pedestrian pushbuttons, and that signals without pedestrian pushbuttons are much better for all pedestrians.

The PROWAAC recommended (in "Building a True Community," section X02.5.1.3) that "the control face of the push button shall be parallel to the direction of the crosswalk controlled by the push buttonŠ" We believe this guideline should include a requirement for the directionality of pushbuttons.

1108 Detectable Warnings

We respectfully suggest that the language in this section be strengthened to clarify that the "square" grid pattern must be aligned with the direction of the ramp. We also suggest that, in deference to wheelchair users, the range of permitted center-to-center dome spacing under 1108.1.2 be reduced to the largest end of the range and that the minimum base-to-base spacing be increased to 1 inch or more in order to allow safe passage of the castor wheels of manual wheelchairs.