Randall R. Wooley

October 28, 2002

Regarding the Draft Guidelines for Accessible Public Rights of Way, 36 CFR, Docket No. 02-1, RIN 3014-AA26, I strongly support the detailed written comments submitted by the American Association of State Highway and Transportation Officials. I have particular concerns about the following sections of the Draft Guidelines:

1102.14 would require at least one passenger loading zone in each block face. In my city, the majority of street miles are on local residential streets. Typically each residence has available off-street parking. There seems to be no need for creating passenger loading zones on such streets. In the areas with more dense development, the city's development codes (and state law) already require the provision of off-street accessible parking located near to each building entrance. On-street parking would typically be less conveniently located. I recommend that the proposed requirement for spacing of on-street accessible parking be deleted or, alternatively, that exceptions be provided where alternative off-street accessible parking is provided.

1105.2 would require that crosswalks have a maximum cross slope of 1:48 and a maximum running slope of 1:20. This requirement would create major design problems on local streets in some portions of my city where slopes are steep and street grades are often as steep as 15%. While we encourage flatter grades, especially at intersections, it is not always feasible to do so. Requiring flat grades at crosswalks would conflict with requirements for sight distance on the roadway. People who are able to negotiate a sidewalk along a 15% grade street are typically do not require the flat crossings. I recommend that this requirement be deleted.

1105.6.2 would require traffic signals at all pedestrian crossings at roundabouts. Discussion materials suggest ways that signals might be designed to allow compliance without significantly disrupting vehicle capacity. However, those designs do not comply with current MUTCD requirements. I recommend that the signal requirement be delayed until additional research can be completed and appropriate MUTCD revisions can be adopted. This provision should not be adopted until there are practical ways available for the local agencies to implement the requirement. Research should also give consideration to roundabouts at relatively low-volume intersections that would not would not meet signal warrants even if they were a standard intersection. My city has at least one such roundabout that is currently controlled by stop signs on all approaches.

1111.3 would require alternate circulation paths on the same side of the street in construction zones. In many construction projects, this would put the circulation path in direct conflict with construction traffic. On projects on low-volume local streets, the required alternate circulation path might cost more than the road or utility construction. While same-side paths might be encouraged, the requirement should be deleted.

We appreciate the opportunity to comment. We share the goal of making public facilities accessible and we continue to upgrade city facilities as budget allows.

Sincerely,


Randall R. Wooley
City Transportation Engineer
City of Beaverton