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Attached are my comments on the Draft Guidelines for Accessible Public Rights-of-Way. Overall, I think this is an excellent and long overdue document. However, I do have a few very specific comments and recommendations that I urge be given careful consideration.

Please contact me at this e-mail address or you can call me at 773-792-9000 if you have any difficulty in opening this document or if you have any questions. Thank you this opportunity to comment on this important and valuable document.

John N. LaPlante, P.E., P.T.O.E.
Chief Traffic Engineer
TY Lin International, Inc.

1102.2.1 Additions.

Each addition to an existing public right-of-way shall comply with the applicable provisions of Chapter 11. Where the addition connects with existing construction, the connection shall comply with 1102.2.2.

Need clarification regarding how accessible facilities "connect" to existing construction. Does the "connection" refer only to the sidewalk, or does it include the pedestrian signals and/or other features?

Recommend clarification of the types pf treatments necessary when "connecting" with existing construction.

1102.5.1 Protrusion Limits.

Objects with leading edges more than 27 inches (685 mm) and not more than 80 inches (2030 mm) above the finish floor or ground shall protrude 4 inches (100 mm) maximum horizontally into the circulation path. EXCEPTION: Handrails shall be permitted to protrude 4-1/2 inches (115 mm) maximum.

Some safety features within the right-of-way, such as fire hydrants, may not adhere to the protrusion requirements

1102.5.2 Post-Mounted Objects.

Free-standing objects mounted on posts or pylons shall overhang circulation paths 4 inches (100 mm) maximum when located 27 inches (685 mm) minimum and 80 inches (2030 mm) maximum above the finish floor or ground. Where a sign or other obstruction is mounted between posts or pylons is greater than 12 inches (305 mm), the lowest edge of such sign or obstruction shall be 27 inches (685 mm) maximum or 80 inches (2030 mm) minimum above the finish floor or ground. EXCEPTION: This requirement shall not apply to sloping portions of handrails serving stairs and ramps.

1.) The existing ADAAG (Section 307.3) allows a 12-inch maximum overhang of post-mounted objects into the circulation path; thus, the 4-inch requirement in the draft guidelines is a significant restriction. 2.) Some features required in other sections of the guidelines, such as the street name requirement on Accessible Pedestrian Signal poles, may not meet these protrusion requirements.

1102.7.1 Bus Route Identification

Bus route identification signs shall comply with 703.5.1 through 703.5.4, and 703.5.7 and 703.5.8. In addition, to the maximum extent practicable, bus route identification signs shall comply with 703.5.5. Bus route identification signs located at bus shelters shall provide raised and Braille characters complying with 703.2, and shall have rounded corners. EXCEPTIONS 1: Bus schedules, timetables and maps that are posted at the bus stop or bus shelter shall not be required to comply with 1102.7. 2: Signs shall not be required to comply with 703.2 where audible signs are user- or proximity-actuated or are remotely transmitted to a portable receiver carried by an individual.

Consideration needs to be given as to when and how this will be implemented. Bus route identification signing is normally done by transit agencies and is completely independent of any other roadway or sidewalk improvements at a given location or along a route.

Recommend that consideration be given as to how this can be implemented separate from a sidewalk or roadway improvement.

1102.7.2 Informational Signs and Warning Signs.

Informational signs and warning signs shall comply with 703.5.

Signs at signal pushbuttons should also include Braille messages. Should not this note also be included here?

Recommend the following change: Informational signs and warning signs shall comply with 703.5. Signs located at accessible pushbuttons shall comply with 703.2.

1102.15 Passenger Loading Zones.

Where passenger loading zones are provided, they shall connect to a pedestrian access route and shall provide a minimum of one passenger loading zone in every continuous 100 linear feet (30 m) of loading zone space, or fraction thereof, complying with 302, 503.2, 503.3, and 503.5.

Providing 20 feet out of every 100 feet is 20%. Is this what is intended? Just asking.

1102.15 Passenger Loading Zones.

Providing 20 feet out of every 100 feet is 20%. Is this what is intended? Just asking.

1103.3 Clear Width.

The minimum clear width of a pedestrian access route shall be 48 inches (1220 mm), exclusive of the width of the curb.

I would prefer a desirable minimum clear width of 60 inches, with 48 inches OK for segments less than 30 feet in length and permission to go to a minimum width of 36 inches at a point.

Revise wording to say: The minimum clear width shall be 60 inches (1500 mm), exclusive of the width of the curb, for any distance over 30 feet (9 m).Pedestrian access routes less than or equal to 30 feet (9 m) shall be at least 48 inches (1220 mm) in width. This width may be reduced to a minimum of 36 inches (900 mm) at a single-point obstacle, if necessary.

1104.2.1.1 Running Slope.

The running slope shall be 1:48 minimum and 1:12 maximum.

In hilly terrain, due to the slope of the sidewalk and/or the roadway, it may not be possible to provide a perpendicular curb ramp with a running slope between 1V:48H and 1V:12H.

Recommend adding the following text to Section 1104.2.2.1: “EXCEPTION: A perpendicular curb ramp shall not be required to exceed 15 feet (4570 mm) in length.”

1104.2.1.2 Cross Slope.

The cross slope shall be 1:48 maximum. EXCEPTION: This requirement shall not apply to mid-block crossings.

Constructing maximum 1V:48H cross slopes on perpendicular curb ramps will be very costly in areas of hilly terrain.

1104.3.2 Detectable Warnings.

Detectable warning surfaces complying with 1108 shall be provided, where a curb ramp, landing, or blended transition connects to a crosswalk.

I disagree with the suggestion to permit the use of a 1:15 slope as an excuse to eliminate detectable warnings. These warning strips should be required at all locations. There is no other way to practically enforce the 1:15 slope provision.

Recommend no change to this section..

1104.3.7 Clear Space.

Beyond the curb line, a clear space of 48 inches (1220 mm) minimum by 48 inches (1220 mm) minimum shall be provided within the width of the crosswalk and wholly outside the parallel vehicle travel lane.

1.) Is this clear space required for a parallel curb ramp or is it redundant? 2.) From where is 'beyond the curb line' measured? Front or back of curb or other? In addition, in which direction from the curb line is it measured for each type of ramp -- toward the street or toward the sidewalk?

1.) Recommend that this clear space "beyond the curb line" not be required for parallel curb ramps as it would be a duplication of the landing space. 2.) Recommend clarification of where to measure clear space from for perpendicular curb ramps (assumed to be face of curb).

1105.2.1 Width.

Marked crosswalks shall be 96 inches (2440 mm) wide minimum.

Why not use 8 feet instead of 96 inches? Using inches here implies a level of accuracy that is neither necessary nor practical. And why would we want a crosswalk that is wider than most sidewalks? Since this width is usually designated by paint, which is not a barrier to anyone, 8 feet seems excessive.

Recommend the following change: Marked crosswalks shall be 6 feet (1.8 m) wide minimum.

1105.2.2 Cross Slope.

The cross slope shall be 1:48 maximum measured perpendicular to the direction of pedestrian travel. EXCEPTION: This requirement shall not apply to mid-block crossings.

Including every intersection along a constant grade street would result in extremely unsafe vehicular movements where there is no signal or when a traffic signal is green. This will likely lead to cars going out of control, and an out of control car is a risk to everyone, especially pedestrians both in the street and on adjacent sidewalks. I am absolutely opposed to this suggestion!

Recommend dropping this provision.

1105.3 Pedestrian Signal Phase Timing.

All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet per second (0.91 m/s) maximum. The total crosswalk distance used in calculating pedestrian signal phase timing shall include the entire length of the crosswalk plus the length of the curb ramp.

While I agree that 4.0 ft/sec is too fast a walking speed, I cannot agree with lowering the speed to 3.0 ft/sec. This will result in 25% added delay to any signalized intersection where pedestrian crossing time governs. This delay would also apply to pedestrians wishing to cross the street, leading to the likelihood of pedestrians disobeying the ped signal. I suggest as a compromise solution, requiring a minimum total ped crossing time (Walk and Flashing Don’t Walk) be based on 3.0 ft/sec and the Flashing Don’t Walk be based on 3.5 ft/sec.

In addition, including the length of the ramp in the crossing distance can increase the crossing distance by as much as 12 feet, adding even more delay for both peds and cars. There seems to be no justification for adding this distance.

Recommend the following change: All pedestrian signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet per second (0.91 m/sec) maximum for the complete pedestrian Walk/Flashing Don’t Walk phase, and 3.5 ft/sec (1.06 m/sec) maximum for the Flashing Don’t Walk phase alone. The total crosswalk distance used in calculating pedestrian signal phase timing shall include the entire length of the crosswalk from curb to curb.

1105.5.3 Approach.

Where the approach exceeds 1:20, the approach shall be a ramp 48 inches (1220 mm) minimum in width and shall comply with 405. Where the rise of a ramped approach exceeds 60 inches (1525 mm), an elevator complying with 407, or a limited- use/limited-application elevator complying with 408 shall be provided.

Given the high cost of installing and maintaining elevators, particularly in outdoor locations and often not near a likely power source, the 60-inch rise seems unworkable.

Recommend some further research as to a more workable rise differential or some more reasonable exception included in this section.

1105.6.2 Signals.

A pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the crosswalk, including the splitter island. Signals shall clearly identify which crosswalk segment the signal serves.

Traffic signals at roundabouts would completely eliminate both the traffic flow and traffic safety benefits of roundabouts, thus effectively precluding their use in any urbanized areas. Since they usually eliminate so many vehicular crashes, eliminating roundabouts does not seem to be a viable solution. However, I recognize that roundabouts are a very real problem for the visually impaired, as well as other less mobile pedestrians. This is particularly true at multi-lane roundabouts. We quickly need further research on how to enforce vehicular yielding at pedestrian crosswalks.

Recommend the following change for the time being: 1105.6.2 Signing. “Yield to Pedestrians” signs and visible pavement markings shall be provided for each segment of the crosswalk, including the splitter island.

1105.7 Turn Lanes at Intersections.

Where pedestrian crosswalks are provided at right or left turn slip lanes, a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.

Similar to the roundabout discussion above, there are many locations where signalizing a separate turn lane is neither feasible nor safe. However, there are probably too many free flow turn lanes in urban areas that could and should be signalized. This is currently the subject of a new NCHRP study (Project 3-72) and the signalization recommendation should be deferred until that study is complete.

Recommend the following change for the time being: Where pedestrian crosswalks are provided at right or left turn slip lanes a “Yield to Pedestrians” sign or a pedestrian activated traffic signal complying with 1106 shall be provided for each segment of the pedestrian crosswalk, including at the channelizing island.

1106.2.1 Location.

Pedestrian signal devices shall be located 60 inches (1525 mm) maximum from the crosswalk line extended, 120 inches (3050 mm) maximum and 30 inches (760 mm) minimum from the curb line, and 120 inches (3050 mm) minimum from other pedestrian signal devices at a crossing. The control face of the signal device shall be installed to face the intersection and be parallel to the direction of the crosswalk it serves. EXCEPTION: The minimum distance from other signal devices shall not apply to signal devices located in medians and islands.

1.) Space limitations may make it difficult to place separate signal components at the required spacing. 2.) Clarify what is meant by "pedestrian signal device" -- Is this just the push-button, or does it include other items such as the auditory tone, pole, walk/don't walk signs, etc.? 3.) Is "control face" a recognized term for pedestrian signals? It appears to refer to the "walk/don't walk" panel. This section could be reworded for clarity.

1.) Recommend developing illustrative standard drawings for intersections using required spacings to determine feasibility and reasonability of spacing. 2.) Recommend defining "pedestrian control device" or rewording first sentence. 3.) Recommend rewording second sentence to state: "The face of the pedestrian signal should face the crosswalk it serves."

1109.2 Parallel Parking Spaces.

An access aisle at least 60 inches (1525 mm) wide shall be provided at street level the full length of the parking space. The access aisle shall connect to a pedestrian access route serving the space. The access aisle shall not encroach on the vehicular travel lane. EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet (4270 mm). When an access aisle is not provided, the parking space shall be located at the end of the block face.

Bike lanes should not be considered travel lanes with regard to the restriction that "the access aisle shall not encroach on the vehicular travel lane”. And the use of inches to define street space implies a level of accuracy that is neither needed nor practical to achieve.

Recommend the following change: An access aisle at least 5 feet (1.5 m) shall be provided at street level the full length of the parking space. The access aisle shall connect to a pedestrian access route serving the space. The access aisle shall not encroach on the vehicular travel lane. For the purposes of this requirement, a bicycle lane shall not be considered as a vehicular travel lane. EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet (4.2 m). When an access aisle is not provided, the parking space shall be located at the end of the block face.

1109.3 Perpendicular or Angled Parking Spaces.

Where perpendicular or angled parking is provided, an access aisle 96 inches (2440 mm) wide minimum shall be provided at street level the full length of the parking space and shall connect to a pedestrian access route serving the space. Access aisles shall be marked so as to discourage parking in them.

It appears that these requirements apply to all parking spaces, instead of only to the accessible spaces.

Recommend rewording beginning of section to state, "Where accessible perpendicular or angled parking is provided,…"

1109.5 Obstructions.

There shall be no obstructions on the sidewalk adjacent to and for the full length of the space. EXCEPTION: This provision shall not apply to parking signs complying with 1109.6 and parking meters complying with 1109.7.2.

It is unclear how far back on the sidewalk from the accessible parking space this restriction applies, i.e., how far back is "adjacent to...the space"?

Recommend clarifying verbiage.