Michael T. Stanley, P.E.

October 22, 2002

Please see below comments on the new ADA guidelines, submitted by the North Carolina Department of Transportation's Traffic Engineering and Safety Systems Branch. For further information, you may contact Mr. Spencer Franklin at the number listed following the comments. Thank you for the opportunity to respond.

Spencer Franklin wrote:

We have reviewed the subject document as well as the draft AASHTO
comments and recommendations. While we applaud efforts to provide a
user friendly transportation facility for pedestrians and disabled
individuals, of a primary concern to us is that the subject document
does not appear to balance the needs of other members of the traveling
public. The guidelines present significantly stringent and costly
proposals which may have limited benefit.

We fully support AASHTO's comments and recommendations on these
guidelines.

Significant issues to us are the following:

AASHTO made comments regarding the implied elimination of diagonal
crosswalks (p. 12 of AASHTO response). As you are aware, we already
have difficulty placing our stop bars such that the wheel chair ramps
are in front of the stop bar. Pushing our stop bars further back, as
eliminating diagonal crosswalks would require, would lead to other
safety concerns including increased motorists' disrespect for the stop
bar (and thus increased hazards to pedestrians and the disabled).

In addition, decreasing walking speeds to 3.0 feet/sec and lengthening
the required clearance distances would lead to other safety and
operational concerns. For instances, if a particular corridor must
operate less efficiently due to the proposed requirements on walking
speeds, you may increase stop-and-go conditions such that rear-end
accidents increase and you may introduce an increase in motorists'
violations of our clearance intervals (once again increasing
pedestrian and disabled exposure to moving vehicles).

Regarding page 12 of the draft report, and I don't think AASHTO
mentioned this, but there is a difference of opinion from the two
major blind coalition agencies in the USA over the use of audible
pedestrian signals (I don't know their position on vibrating signals)

Regarding increasing crosswalk widths, from a risk management
standpoint, the chances of two wheel chairs approaching in opposing
directions is probably very low in the vast majority of cases. We
don't think these wider crosswalks should be made mandatory.

Please contact me if you require any further information.

Spencer
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Spencer Franklin
North Carolina Department of Transportation
Traffic Management & Signal Systems Unit


Michael T. Stanley, P.E.
Transportation Staff Engineer
NCDOT Program Development Branch