Willamette Pedestrian Coalition
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October 28, 2002 |
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 buttonÅ " 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.