Richard J. Bacigalupo

October 10, 2002

Richard J. Bacigalupo, Executive Director

RE: Draft Guidelines for Accessible Public Rights-of-Way

Dear Mr. Windley:

The Regional Transportation Authority (RTA) is pleased to respond to the Architectural and Transportation Barriers Compliance Board's (Access Board) draft guidelines addressing accessibility in the public right-of-way.

About RTA

The Illinois State Legislature created the Regional Transportation Authority (RTA) in 1974 to provide public transportation in the six county area surrounding Chicago in northeastern Illinois. These counties are Cook, DuPage, Kane, Lake, McHenry and Will, covering about 3,700 square miles.

As a result of a 1983 legislative reorganization, the RTA is exclusively responsible for fiscal planning and policy oversight of public transportation in northeastern Illinois. The actual operation of transit services is the responsibility of the RTA's Service Boards -- the Chicago Transit Authority (CTA), the Commuter Rail Division (Metra), and the Suburban Bus Division (Pace).

Comments

In reviewing the suggested ADA guidelines for public right of way, it was determined that the following may be negatively affected should these recommendations be adopted:

Sidewalk improvements
Informational signage
ADA Paratransit ridership
Sidewalk Improvements

With regard to sidewalk improvements, section 1102.3 recommends that " ... if a path of travel is under construction, the entity must provide an alternate circulation path on the same side of the street parallel to the disrupted pedestrian access route." This often is not feasible due to the terrain and/or safety issues related to surrounding traffic.

Local entities may be dissuaded when it comes to making improvements to sidewalks due to such stringent guidelines. This would be a hindrance to the disability community if municipalities steered away from making sidewalk/curb improvements because they are not sure as to how to cr3eate a safe alternate path.

Likewise, it would pose problems for transit. If sidewalks were not repaired as readily, people with disabilities would experience problems with path of travel and would be forced to rely on ADA Paratransit. ADA Paratransit would increase and funds spent on making bus fleets accessible would go unused. It is our recommendation that some flexibility be allowed with this section. Specifically, if the terrain of a sidewalk construction site poses significant problems or safety issues with an alternate accessible path of travel parallel to the site, the entity could place blockades and signage stating the sidewalk is out well in advance of a construction site. This signage would direct pedestrians to a different accessible, yet direct, safe route. Of course, other options or technologies, e.g., an auditory announcement system, would need to be explored in order that people with visual disabilities be notified of the route deviation.

Street Crossing Allowances

Increasing street crossing allowances, i.e. the amount of time needing to cross an intersection with a traffic light, are also recommended. This definitely would be helpful to individuals with disabilities. But, until these times are adjusted at each street crossing that has a traffic light, transit entities will have to accommodate those individuals on ADA Paratransit who cannot cross in a timely fashion.

Detectable Warning Surfaces

Sections 1104.3.2, 1108.1 and 1108.1.4 lay out recommendations for detectable warning surfaces. Specifically, the recommendations require truncated domes at all street crossings. The majority of individuals with visual disabilities have expressed opposition towards this recommendation, saying that the truncated domes, if not installed properly, can cause them to trip. People who use mobility devices also have concerns regarding truncated domes. Concerns center on the domes being a barrier to wheels. We recommend that truncated domes not be a requirement at all street crossings.

Informational Signage

Section 1102.7.1 recommends that all bus route identification signs incorporate raised and Braille lettering and rounded corners. Both the Chicago Transit Authority (CTA) and Pace Suburban Bus change routes on a frequent basis. Having to incorporate the raised and Braille lettering every time a route was changed would become costly and difficult to fund.

This would also raise issues of confusing people who are blind if a change occurs and the signs have not been updated. A better solution would be the announcement systems which inform a waiting passenger of the route being served by a stopped bus and allow the passenger and bus driver to further communicate as to bus route information.

Conclusion

The chief concern of transit with respect to these draft recommendations is that if these regulations are adopted, we expect ADA Paratransit ridership to increase. Having higher expectations for accessibility is a good thing. However, until they are implemented, more barriers will be created to using fixed route transportation. This would be unfortunate, as billions of dollars have been spent to make transit systems accessible and allow people with disabilities a greater amount of freedom and independence.

We appreciate the opportunity to comment on this proposal and look forward to an NPRM that accommodates the comments of all affected parties. Should you require additional information, please contact Phillip G. Shayne via telephone at [ ...] .

Sincerely,

Richard J. Bacigalupo
Executive Director

cc: Phillip G. Shayne, Manager of Regional Services
Kimberly A. Robb, Accessibility Specialist