Dan Gentry

October 28, 2002

To Whom it May Concern:

I have reviewed the draft guidelines as well as many of the comments on the report that are shown on your web site. In general, I would like to note that I concur with the comments provided by Mr. Daniel Centa from Pueblo Colorado on August 21, 2002. Beyond this, I offer the following comments as a caution to help prevent unintended consequences of these new guidelines. Thank you for the opportunity to provide comments.

1101.3 Defined Terms - Section 1102 of the guidelines requires that additions and alterations to right-of-way shall comply with the guidelines. However, there is no definition of an alteration. The comments provided by the Committee indicates that their intent is for compliance to be "prorated" based on the extent of the work planned. Perhaps and actual definition of alteration in the definitions section and some illustrative examples would be helpful in management/implementation of these guidelines. For instance, if 2 sidewalk slabs are being replaced on an existing 36" sidewalk to alleviate a trip hazard, will we be required to pour the new section of sidewalk at 48" or would we only take this extra measure if we were replacing sidewalk along the entire block? Without specific guidance I see many communities continuing to defer maintenance of sidewalk for fear of their limited resources being drawn further away from roadway, stormsewer and other infrastructure needs.

1102 Scoping Requirements - In its comments on the scoping requirements, the Committee stated that communities will be required to acquire additional right-of-way where "practicable" in order to ensure compliance with the guidelines in alteration projects. Mr. Centa's comments are that this could have a "chilling" effect on projects because local policymakers are often unwilling to exercise imminent domain. I concur.

1102.14 & 1109 On Street Parking - The proposed rules states "Where on-street parking is provided, at least on accessible on-street parking space shall be located on each block face and shall comply with 1109." I strongly concur with Mr. Centa's comments that this matter wasn't sufficiently thought out. This requirement should only be applied to business or commercial areas and there is no allowance for the fact that the size of block faces can vary significantly from one community to another. Application of this requirement to existing residential areas would be very problematic and costly. Application of this requirement to new residential roadway construction is certainly more feasible but would reduce the flexibility a community has to changing needs for handicap parking needs in a neighborhood (i.e., the ability to move a handicap space by moving signage alone).

1105 Pedestrian Crossings - This section would increase crosswalk width from the MUTCD minimum of 6' to 8'. Mr. Centa notes that this may not require a major expenditure of funds to change but that we would be merely increasing the mythical "magic zone of protection." This will also cause there to be less visibility for turns at intersections for those drivers who actually do stop at the stop bar potentially increasing traffic collisions.

1105.6 Roundabouts - Our community hasn't yet followed the trend towards using roundabouts as a traffic calming method. However, the requirement to install signals at all crosswalks within a roundabout and the requirement to build barriers may cause this option to become less attractive to many communities.

1108 Detectable Warning Surfaces - The rule states that there must be a detectable warning surface on handicap ramps. While this may aid with increasing safety of visually impaired persons it may cause a significant number of injuries under ice and snow conditions because snow removal becomes problematic.

Dan Gentry
Public Works Division Manager
City of O'Fallon, Illinois