Henry Hungerbeeler
|
October 28, 2002 |
Missouri Department of Transportation Comments regarding
The Draft Guidelines for Accessible Rights-of-Way
MoDOT would like to thank the US Access Board for addressing these issues. We
are committed to enhance safety and provide Missourians with a first class
transportation system.
MoDOT is concerned that the US Access Board may be favoring large metropolitan
areas while forcing stringent requirements upon smaller population centers that
would create great budgetary difficulties. Missouri has only two metropolitan
areas with more than 300,000. In these areas, the need exists for some of these
proposed guidelines, yet the funds are available for work deemed necessary. In
the smaller, more rural cities and towns, the funds to accommodate these
requirements are not available. Thus if accessibility is enhanced it will be at
the expense of the adjacent roadway, thus decreasing the roadway’s functionality
and safety for the majority of the traveling public
MoDOT very firmly supports the comments from AASHTO. AASHTO has repeatedly
demonstrated its ability to forecast the national impact a policy can be
expected to have.
General comments submitted by MoDOT:
1102.6 - Curb Ramps and Blended Transitions
Perpendicular Curb Ramps (1104.2.1)
• If the curb is six inches high, the ramp will be six feet long. In many cases,
longer than the sidewalk width. The featured drawing is misleading, as it
portrays at least a 12-foot wide sidewalk, not the minimum width.
Other Requirements for Curb Ramps and Blended Transitions (1104.3.3 – 1104.3.7)
• (2nd bullet)There are a lot of urban situations that when sidewalks and access
are added that the narrow amount of right of way usually is inclusive of a
utility corridor. With this requirement there would be a lot of situations where
it would not be feasible to provide access because of all the costs of moving
utilities and buying additional right of way. We can understand not wanting
grates or anything that presents an obstacle in the path, but most utility and
sewer covers are flush and should not present an obstacle to users. Maybe the
wording of this could be changed to say that any of these type of obstacles that
lie in the path shall have such covers as to not present obstacles, and have
less than a ¼” deviation anywhere in the covers. There are a lot of situations
where our pullboxes for a signalized intersection fall within the sidewalk and
in the ramps, and there is no other place for them, they are however very smooth
and the only difference they present is coloration.
• (6th bullet) This limits the counter slope of the gutter area to1:20. MoDOT’s
current standard curb and gutter section has a 1:13.5 slope. If we flatten the
curb and gutter section and make no other changes, there will be more water
spread into the driving lane, creating a hazard. It seems that this criteria
should be lessened to a 1:12 maximum since this will allow proper drainage
without creating a slope that is too much for handicapped individuals to
maneuver.
• (7th bullet) Should it also be recommended that this should be 60”, since the
sidewalks are recommended to be 60”
1102.8 – Pedestrian Crossings
• Under the topic of Pedestrian Overpasses and Underpasses (1105.5) the Draft
recommends a maximum of a 60-inch elevation change, and calls for elevators
beyond the 60 inches. This requirement is unclear. For example, does the
elevation requirement apply to the total rise or the rise of each part in the
case when a ramp has a landing.
• Roundabouts (1105.6). The Draft recommends ped-activated signals at roundabout
crosswalks and includes a photo of crosswalks at the entrances to the
roundabout. This is a concern since roundabouts are designed to keep traffic
flowing. If ped signals are used and traffic is stopped in the roundabout for
ped access many accidents would occur. Have mid-block crossings, farther away
from the roundabout been considered?
• There is a concern regarding barriers to prevent blind persons from
inadvertently crossing in unsafe locations. Why would this intersection require
different treatment than other intersections? Would not the curbs in these areas
present the needed barrier as it does in all other similar situations?
• In the section regarding turn lanes at intersections (1105.7), regarding the
ped-activated signal at right or left-turn slip ramps, shouldn’t threshold
traffic volume level, above which ped-activated signals are required, be
included in this section?
1101.3 – Defined Terms
• The cross slope definition should be revised to state, “The slope that is
perpendicular to the direction of travel on tangent roadway sections.”