John Leonard, P.E.
|
October 28, 2002 |
The Utah Department of Transportation would like to
thank the U.S. Access Board for the opportunity to comment on the draft
Guidelines for Accessible Public Rights-of-Way. We believe these guidelines
will be an important step in improving accessibility for disabled persons
throughout the country on our transportation system. The Department also is
appreciative of the effort and work that went into developing the draft
guidelines.
The Department supports the comments adopted
by the AASHTO Board of Directors. In addition to the comments from AASHTO, we
have comments on the draft guideline:
The practice of construction for highways and related facilities is not an exact
science. There are often issues that cloud the ability to provide services and
facilities for all users. These issues include but are not limited to the
physical layout of the terrain, right-of-way constraints, and the financial
ability to complete the actual construction. The purpose of a guideline is to
provide general guidance to a professional about those features that are
desired, and how to construct them. While this document is a guideline, it
appears to be more restrictive in nature. The use of the word ’shall’ is
included in many sections of the guideline, which makes the action a
requirement. The use of this term removes the ability to use engineering
judgment. We need the flexibility to exercise good judgment in designing and
building transportation facilities to best meet the needs of all users,
including persons with disabilities. We strongly recommend that “shall” be
changed to “should” and/or “may” as would best fit the situation.
Section 1104.3.2--Detectable warning surfaces complying with 1108 shall be
provided where a curb ramp landing or blended transition connects to a
crosswalk.
We believe the section should be modified to recommend the slope have detectable
warnings without specifying the type. This would leave it to the judgment of
the engineer to determine what is the most satisfactory detectable surface for
the specific site. Cold weather issues, including snow, ice, and the damage
that occurs during snow and ice removal, must be addressed. We recommend
dropping the specific reference to truncated domes.
Section 1105.3--All pedestrian signal phase timing shall be calculated using a
pedestrian walk speed of 3.0 feet per second maximum. The total distance used
in calculating pedestrian signal phase timing shall include the entire length of
the crosswalk, plus the length of the curb.
We believe that agencies need the ability to be flexible in designing the timing
of signals to accommodate the needs of all the users. The MUTCD gives the
engineer the option to use a slower speed and longer distance when conditions
warrant. Guidance to the designer as to when to use slower speeds or increased
distances would be more appropriate. We agree with the AASHTO recommendation of
using the criteria in the MUTCD for timing pedestrian signals.
Section 1106.1-General (Accessible Pedestrian Signal Systems). Pedestrian signal systems shall comply with (Section) 1106.
We support the AASHTO recommendation of delaying the implementation of
Section 1106 until further research is conducted to ensure a logical and
comprehensive approach to the installation of these devices.
We are also concerned about the thresholds at which different accommodations
kick in. There is the issue of ‘alterations’, and what truly is an alteration
to a facility. Is it when we repaint a highway, rejuvenate the pavement
surface, perform utility work, start a major construction project, or somewhere
in between? Many of the words in the guideline are not defined, and some that
are do not use the commonly accepted engineering terms. The definitions and
understanding of the terms used in the guideline need to reflect those used in
the industry.
Our final comment is about the application of these guidelines to different areas. It appears the guidelines are designed with the urban environment of high traffic and high pedestrian volumes in mind. How will these guidelines be applied to rural facilities that may have very low volumes, no curb, gutter, or sidewalk, and only occasional, if any, pedestrians? The implementation of all of the requirements in the guideline to these situations may not be appropriate: it should be left to the judgment of the engineer based upon an evaluation of the situation.
Again, the Utah Department of Transportation commends the Access Board for their work on the draft guidelines. We look forward to working with all of our partners in the transportation industry to provide access to everyone, including disabled persons. Together we can make a difference.
John Leonard, P.E.
Operations Engineer
Utah Department of Transportation
Division of Traffic and Safety