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