James W. Sparks P.E. | September 10, 2002 |
Below is a letter sent earlier responding to the proposals from the US Access
Board. I have since read the letter from the City of Pueblo Colorado penned by
Dan Centa. It is an excellent response, hitting home on most all issues
regarding urban area practicalities. In our genuine zeal to improve conditions
for the disabled, it is important to do so in a way that does not set-back other
important national priorities (i.e. air quality, mobility, consumption of fuel,
overall traffic safety, and in some cases degradation of service for disabled
with other types of disabilities).
Mr. Centa's discussion about "unintended consequences" is very real, and touches
on important issues. Mainly it is important that the final product not be so
rigid that it REQUIRES actions that will certainly carry with them
unintended consequences. Some should remain guidelines rather than mandates, to
preclude adverse impacts. In the cases noted, (and a few others too), the
consequences may appear to be "unintended", but they are readily obvious to
those accountable and responsible for overall public safety in urban areas.
One last concern is whatever guidelines come out need to respect past efforts of
municipal governments. I am proud of our city's efforts, where we have spent
about $1,000,000 per year on rebuilding curb returns citywide for the past few
years. We have now completed virtually all transit related routes, and are
expanding elsewhere. The new proposals are different than the old with regard
to ramps, negating all that public investment and conscientious follow-through
toward meeting the previous access board desires. Any changing of design
standards needs to NOT negate or penalize those forward thinking cities that
have tried in good faith interest to improve the overall environment for the
disabled community.
Thank you for listening
James W. Sparks P.E.
Deputy Street Transportation Director
City of Phoenix
Just a short note of concern to the very detailed proposed
"accessibility requirements" being advertised in the Federal Register. Please
see to it that these comments get considered prior to going forward with the
proposal.
(1) Input regarding accessibility FROM the accessibility community is essential,
and it is good that those efforts are underway.
(2) How those concerns are addressed is an engineering issue as well as an
accessibility issue, and any final rules regarding attainment of the issues
needs to be processed using the very same procedure all engineering features of
that control the public rights of way. While I am sure each proposal is well
intended, there are inadvertent SERIOUS consequences that can result from
failure to benefit from the years of experience the National Committee on
Uniform Traffic Control Devices offers. I can recall an accessibility proposal
years ago that would have enlarged signalized intersections by 30% due to a
proposal that would set the crosswalks way back from the intersecting streets.
Doing so would have adversely affected safety for not only the disabled
community but the entire public at large. Fortunately this got resolved.
(3) One current proposal falls victim to the myth that traffic signals are in
some way safety devices. THEY ARE NOT. The collision rate at signals is double
that of similar unsignalized intersections. Signals are essential (no choice)
in some instances, but unless essential are bad medicine and counterproductive
to traffic safety. The proposal to have to signalize crosswalks near
roundabouts is unwise and counterproductive.
(4) Similarly, the requirement for signalization of right turn lanes is an
emotional proposal rather than one conducive to safety of all concerned. To
ignore that fact puts all users at risk.
(5) Requiring a specific walking speed other than what has been found to be a
good compromise considering all aspects of making signals function safely, is
WRONG. There is nothing wrong with making such a proposal, but the final
decisions should be made by trained engineers familiar with the upsides and
downsides of traffic signals.
Thank you for listening.