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Michael M. Ryan, P.E.
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October 28, 2002 |
Review Comments on the Draft Guidelines for
Accessible Public Rights-of-Way
Submitted to:
U.S. Architectural and Transportation Barriers
Compliance Board
By:
Pennsylvania Department of Transportation
Michael M. Ryan, P.E.
Deputy Secretary for Highway Administration
400 North Street - 8th Floor
Harrisburg PA 17120-0094
October 25, 2002
Introduction
We certainly appreciate the development of these guidelines since they help to
better define accessibility features that were not addressed or had limited
application to public rights-of-way issues in the original ADAAG.
We have been asked by FHWA and the American Association of State Highway and
Transportation Officials (AASHTO) to forward any of our review comments and
concerns to the Board. PENNDOT is a major transportation design/build state
agency for highway construction. As a separate state entity concerned with
providing accessibility to our highway customers, we are interested in the
development of these guidelines.
We are also a major partner in the AASHTO organization and use their design
guidelines in many applications. We do agree with a majority of the AASHTO
comments and recommendations that have been
forwarded to you separately and we are also including our concerns as listed
below:
Broad Issues / Concern
1. Our major concerns is the 1106 Section dealing with Accessible Pedestrian
Signal Systems. This Section is also of prime concern to AASHTO. The
Introduction / Background and Discussion of Provisions of the Draft Guidelines
downloaded from the www.access-board.gov internet site certainly helps to
provide some guidance on interpreting the various sections. However, these
discussions are not part of the guideline requirements and therefore can cause
confusion in determining when and to what extent items need to be updated to the
new standards especially for locations where existing ADA features are present.
We do not interpret the Guidelines to require a complete new statewide
installation program of the new features for all locations. New construction
installation of the approved ADA features are generally not a problem.
2. We believe that a majority of the new requirements, especially for pedestrian
crosswalk signage and signaling systems cannot be readily achieved with our
normal alteration programs of Resurfacing, Restoration and Rehabilitation (3R)
at existing intersections since any new signing and signaling systems provided
can lead to non-consistent levels of accessibility systems operating at one
time, at various intersections within the same municipality. This piecemeal
arrangement of systems can cause undue confusion to the pedestrian using the
signing / signaling systems. We interpret the Guidelines for compliance at
existing intersections to be ‘pro-rated’ based on the extent of alteration work
planned as described under “General Scoping’. The Board’s belief that access
should be required at all crossings equipped with pedestrian signals to ensure a
consistent level of accessibility within a pedestrian network is not consistent
with the ‘pro-rated’ concept of alteration work.
3. Statewide Cost Implications. We realize that cost concerns are not a
justification for non-compliance with ADA features but the extent of items
covered in these Guidelines can have far-reaching financial implications to all
local municipalities and especially to state transportation agencies charged
with statewide programs. Since most municipalities will not be able fund this
type of work in a timely fashion, the installation of many new accessibility
features can fall to the state level especially where state and local roadways
merge. This scenario occurred when the original ADAAG curb ramp requirements
were enacted and PENNDOT helped to alleviate the financial strain on local
municipality budgets. Other state related highway construction and maintenance
3R projects were cancelled or delayed for several years to concentrate on the
curb ramp installations. Unfunded federal mandate programs are not good programs
for the organizations charged with compliance of the Guidelines.
4. Proprietary Issues. We are concerned that the pedestrian signal industry is
not sufficiently developed with the new systems indicated in the Guidelines to
allow the use of competitive bidding for all the systems identified in the
Guidelines. Both state and federal laws prevent or discourage the use of sole
source or proprietary manufacturers for federal or state funded construction
projects.
5. We agree with AASHTO’s concerns on the use and definition of highway terms
provided in the Guidelines and desire that the terminology be consistent with
normal highway usage.
The use of AASHTO manuals and the Manual of Uniform Traffic Control Devices (MUTCD,
2000) should be consulted for consistency in terminology definitions and usage.
Exception: We do not agree with AASHTO’s desire to eliminate the terms
‘technically infeasible’ and ‘maximum extent feasible’ from the Guidelines. We
believe that these are helpful terms in utilizing the guidelines in difficult
design/construction locations.
Technical Concerns:
1102.10 Stairs –
Stair treads to have a 2-inch strip of color contrasting with the tread and
riser, the full width of the front edge of each tread.
Concern – The length of the tread can greatly affect whether the 2-inch color
strip is visually discernable for each step. We have experienced problems where
narrow step treads with a colored edge strip cannot be visually discerned when
walking down the steps, since the colored edge visually blends together causing
confusion and uncertain foot placement.
1103.3 Minimum Clear Width –
The minimum clear width of a pedestrian access route shall be 48 inches,
exclusive of the width of the curb.
Concern – Using the wider accessible route dimensions for alteration projects
can create an extensive sidewalk patchwork of various width PAR’s within a given
community.
1103.4 Grade –
The grade of the pedestrian access route within a sidewalk shall not exceed the
grade established for the adjacent roadway …
Concern – Sidewalks paralleling roadways in hilly terrain may not meet the
desired grade guidelines therefore making them ramps. Making the sidewalk a ramp
and requiring ramp provisions of handrail on each side, edge protection and
intermediate level landings are often impossible to construct along steep
roadways if the sidewalk is adjacent to the curb and especially within limited
R/W widths. This is even difficult to design for new construction projects. The
less than 1:20 route slope limit for a parallel sidewalk is unrealistic in many
hilly terrain locations. The handrail requirement for a ramp brings an unsafe
element to vehicles if a car leaves the roadway and jumps the curb.
1103.8 Changes in Level –
Changes in level shall comply with 303.
Concern – We agree with AASHTO’s comment that the ¼-inch change in level is very
unrealistic to maintain especially in older existing sidewalks.
1105.2.1 Crosswalks – Width –
Marked crosswalks shall be 96 inches wide minimum.
Concern – We agree with AASHTO’s comment that the extra 24 inch width
requirement beyond the MUTCD standard of 72 inches is not necessary and
excessive in most locations.
Recommendation - This guideline could be adjusted so that different widths are
available to accommodate projected increased pedestrian usage in larger cities.
1105.2.2 Crosswalks – Cross Slope -
The cross slope shall be 1:48 maximum measured perpendicular to the direction of
pedestrian travel.
Concern – Reducing the street profile grades to 1:48 at intersection crosswalks
will lead to ‘tabled areas’ being created that are very difficult to form in
steep or uneven terrain especially at existing intersections. We agree with
AASHTO’s concerns for this guideline.
1105.2.3 Crosswalk Running Slope –
The running slope shall be 1:20 maximum measured parallel to the direction of
pedestrian travel in the crosswalk.
Concern – We agree with AASHTO’s comment that this guideline cannot be achieved
in some super-elevated sections of roadway.
1105.3 Pedestrian Signal Phase Timing -
All pedestrian signal phase timing shall be calculated using a pedestrian walk
speed of 3.0 ft/sec maximum.
Concern – This guideline indicates all signals shall be… If these guidelines are
to include alteration projects, there will be various timed sequences in place
statewide that can create pedestrian confusion to intersections with one time
sequence in one location and have a different time sequence further down the
block. We also agree with AASHTO’s assessment of this guideline.
1105.5 Pedestrian Overpasses and Underpasses -
1105.5.2 The running slope shall not exceed 1:20 maximum.
Concern –The PAR’s can become excessively long at approaches and require extra
physical effort to negotiate the longer distances. The 1:20 exception is too
flat to effectively use in these locations for the heights to be overcome,
especially at existing locations.
1105.5.3 Approach
… where the rise of a ramped approach exceeds 60 inches, an elevator … shall be
provided.
Concern – Elevator usage at these areas is generally infeasible to provide
especially in suburban or rural locations. Their initial installation cost and
long term maintenance cost cannot be justified in most places. We also agree
with AASHTO’s assessment of this guideline.
1105.6 Roundabouts -
Concern - We agree with AASHTO’s assessment of this guideline.
1105.7 Turn Lanes at Intersections –
… crosswalks are provided at right and left turn slip lanes, pedestrian
activated traffic signal … shall be provided.
Concern – This provision can lead to various levels of signal systems being
provided state wide. We also agree with AASHTO’s assessment of this guideline.
1106 Accessible Pedestrian Signal Systems –
Concern – We agree with AASHTO’s assessment of these guidelines for the entire
Section.
1111.3 Location of Alternate Circulation Path –
Concern – We agree with AASHTO’s assessment of this guideline.