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.”