City of Bellevue
Bellevue, WA  98009-9012 

Please find attached the City of Bellevue's comments on the draft guidelines for accessible public rights-of-way. 

We appreciate the effort to establish and clarify accessibility requirements for our citizens.  Bellevue is committed to providing accessible streets and walkways, but we caution that mandates be established within reason, and with consideration to the constraints presented both financially and physically.  In addition, we do not believe that mandates should replace the practice of sound engineering and decision-making that considers the specifics of each situation. 

We appreciate your consideration of our comments, and look forward to final guidelines that meet the needs of all involved. 

Sincerely,

Goran Sparrman
Director of Transportation
City of Bellevue

Draft Guidelines for Accessible Public Rights-of-Way

Comments by City of Bellevue, Washington

Additions and Alterations – Guidance for additions and alterations is the scope of the project would determine the extent to which the guidelines apply.  Also, compliance would be required except where “technically infeasible”.  Practically anything is “technically feasible”, as long as sufficient resources are committed.  The example of a bridge column could be solved by rebuilding the bridge, which is “technically” but perhaps not “fiscally” feasible.  Perhaps this guideline should be given in terms of fiscal impact.  As currently written, these statements are somewhat vague and could lead to broadly different interpretations. 

Alternate Circulation Route – We agree that it is desirable to provide alternate pedestrian routes during construction.  However, it is not always practical or financially feasible.  Guidance regarding exceptions should be included, particularly when providing an alternate route results in a cost that would prevent the project from occurring at all, or where the construction duration is extended such that this extension has more disbenefit than not having an alternate route. 

Diagonal Curb Ramps – We have used diagonal curb ramps with apparent success and no complaints from the public.  They have advantages in some cases, such as lower turn speed across the crosswalk, better sight distance to the pedestrian, more full height curb around the corner radius, ease of crosswalk layout, and better ability to incorporate junction boxes, storm drains, etc.  Detectable warnings help address the concerns of the committee.  The advantages of this type of ramp should be acknowledged.  The strong statements against their use could be used against an agency when this treatment is selected for use, whatever the reason. 

Perpendicular Curb Ramps – The same exception for slopes at mid-block crossings should be given at intersections.  The curb ramp slopes for the side flares (1:10) and cross slope (1:48) should be measured relative to the running slope of the sidewalk, not level.  Leveling entire intersection areas is not reasonable or practical in most cases. 

Parallel Curb Ramps – Again, the same exception for slopes given at mid-block crossings should be given at intersections.  Running parallel ramps out 15 feet may not be desirable or reasonably feasible, and could have unintended concerns. 

Detectable Warnings – The ramp between sidewalk and crosswalk should provide adequate notification of the blend of a pedestrian way with a vehicular way.  Truncated domes should only be required where ramp slopes are very gradual; 1:15 or less as suggested by Pueblo seems reasonable. 

Other Curb Ramp Requirements – It is often very difficult, especially in developed urban areas, to avoid conflicts between curb ramps and utility fixtures. Relocating utility fixtures is not always a reasonable option.  Recognition of this including some allowance and guidelines for integrating the two should be considered.  For instance, placing junction boxes wholly within the ramp (instead of the side flares) when necessary. 

Crosswalks – Limiting cross slope to 2% will require “tabletop” intersections, which may not be reasonable to construction, particularly in areas with challenging topography and/or limited rights of way.

Pedestrian Refuge Islands – Although the 6 foot minimum length is desirable, it could prevent the installation of a refuge island altogether where space or right of way limits the refuge to less than 6 feet.  Engineering and site specific conditions should determine if a refuge island less than 6 feet long should be installed. 

Pedestrian Signs – There could be conflicts between the minimum and maximum mounting heights specified in 703 and the minimum mounting height of signs specified in the MUTCD, particularly for stand alone signs.  Availability of space and location for all the required pedestrian signs is also a concern.

Pedestrian Overpasses and Underpasses – The construction and maintenance cost of elevators will significantly reduce the actual installation of overpasses/underpasses when this type of structure is the best solution.  The installation of resting platforms, where reasonable, is a better approach. 

Roundabouts – The requirement to signalize the pedestrian crossings at the splitter islands is not sound, reasonable or consistent.  These crossings are essentially mid-block crossings; however, signalization is not required at other mid-block crossings.  The requirements to signalize roundabout pedestrian crossings will limit the use of what is proving to be an intersection control strategy that works well for a number of situations.  The decision whether or not to signalize roundabout pedestrian crossings should be determined during project engineering based on all the conditions associated with the intersection.

Further, a continuous barrier should not be required.  Accessibility requirements are moving toward ramps or detectable warnings at crossing locations.  The outside of the circulating roadway is typically curbed with sidewalk behind.  The curb drop off is reasonable notification to the pedestrian of where the sidewalk ends and the circulating roadway begins. 

Turn Lanes at Intersections – Slip right or left turn lanes have proven to be useful features in intersection design.  They can provide shorter pedestrian crossings, better channelization at skewed intersections, reduced open pavement space, and stopped vehicle refuge at intersections.  They can also increase intersection capacity.  The requirement to signalize pedestrian crossings across these types of lanes is not sound or reasonable.  These types of lanes are often found at unsignalized intersections; a requirement to signalize just the pedestrian crossing portion of the otherwise unsignalized intersection is not reasonable and eliminates engineering from the design process.  The only time signalization of the pedestrian crossing across a slip lane should be required to be considered is at an already signalized intersection, with final determination during design engineering of the intersection. 

Stairs – This section should be clarified to exclude existing, limited use stairways.  A common example is a stairway from an existing house to a street.  Often these types of stairways must be modified to match a new sidewalk installation along the street.  It is not reasonable or necessary to meet the requirements of 504, particularly when the residence does not have special accessibility needs. 

Handrails – This section should be clarified to not include pedestrian railings intended to protect pedestrians and cyclists from drop-offs at the back of sidewalks. 

On Street Parking --  Handicap spaces should not be required in residential areas.  Parking is typically widely available in these areas, and parking areas are generally unmarked.  Handicap spaces should be marked by the jurisdiction only upon the request of  a resident, and only when parking is not widely available.  Further, the requirement of a 5’ indent on new residential developments would not necessarily be in character with the goals of the developer, residents, or jurisdiction.  This is especially true when the location of these indents would be random and not necessarily adjacent to any handicap residents that might happen to move into the development. Also, it would be reasonable to assume the parking needs of these residents could be met in their own driveway. 

In commercial areas, handicap stalls are required on the business site, and should not be necessarily be required on street.  Installation of handicap stalls on street would be better handled on a flexible, case by case basis.  The requirement of an access aisle for parallel spaces is very problematic, particularly in areas of “zero setback” buildings.  Taking from the sidewalk space, when the sidewalk width has been established based on forecasted pedestrian demand, is not reasonable.

Other concerns include on-street parking spaces that are time of day (sometimes parking allowed, other times the lane is used for traffic).  Individual stalls can not be marked in these types of lanes. 

Parking Loading Zones – The aisle width requirement is again problematic per discussion above. 

Pedestrian signal Phase Timing – the use of 3.0 ft/sec may have many consequences for overall intersection capacity/safety that are not necessary or good engineering. The State of Washington is a permissive state.  A pedestrian entering the intersection legally has the right of way and other vehicles must yield until they clear the intersection.  Bellevue currently uses the 4 ft/sec national standard, but uses the full roadway width (typically) for determining phase clearance timing.  If we use an 84’ crossing, as an example, at 4 ft/sec would require 21 seconds while 3 ft/sec would require 28 seconds.  If the vehicle volumes can justify the extra 7 seconds no problem.  However, in many cases this would require a longer cycle length or unnecessary delay to other users of the system.  If we use the current national standard and only require the pedestrian to reach the middle of the far lane, this drops the required clearance to 26 seconds. If we allow the pedestrian to finish crossing at the same time the vehicles are finishing crossing (4 seconds yellow typical) this drops the required clearance to 22 seconds.  We then have 1 second of All-red to clear the intersection.  This shows we can provide clearance for someone traveling at 3 ft/sec, without taking into account the fact of how many pedestrians start their crossing at the exact time we start the clearance time.  Bellevue typically has 7 seconds or more of walk time and in coordinated directions can have upwards of 40 to 50 seconds of walk time followed by a clearance.  To increase the clearance requirements in light of these facts is not good policy.  Many pedestrians who know they are slow walkers would not continue to cross an intersection that is 84’ wide if within one or two strides it is already flashing for clearance.  We feel we have provided them safe passage (assuming drivers obey the law) even if they do choose to continue. 

We can find no rational explanation for requiring the clearance interval to include another 12’ or 4 seconds so an individual can start/end 6’ behind the curb, especially considering the requirements for maximum curb ramp slopes at all intersections. 

Another consequence that some areas under Air Quality restrictions from the EPA will face is whether to eliminate the crosswalks that vehicle traffic cannot justify the increased clearance time requirements.  Many jurisdictions already have had to remove or choose not to install protected left turn phases, even though left turn delay or accident history warrants have been satisfied.  This would actually decrease the mobility of the pedestrian at the intersection. 

Accessible Pedestrian Signals – The blanket requirement for using an audible walk and vibrotactile device at all crossing is fiscally irresponsible and not supported by current research results from the disabled community.  Bellevue has had an open policy of over 10 years to install the audible walk devices where requested.  Of the current 165 signals under operation, only 14 locations have audible pedestrian devices. 

Electromechanical devices like the vibrotactile device require a much higher level of maintenance and are more likely to be vandalized (similar to push buttons) which further increases the fiscal impact and potential staffing requirements for numerous unnecessary installations.  The current locations mostly agree with the latest research of intersections with complex phasing or high background and/or adjacent traffic noise.  A location that is a simple 2 phase isolated intersection does not warrant the same investment that an 8+ phase intersection with overlaps warrants.  We recommend a graduated requirement depending on the conditions actually present at the location and more dependence on working with the disabled community to determine where the problems are actually being experienced. 

We know of many locations that if required to have the display within 5’ of the crosswalk and 10’ from other displays, would require one of the poles to be placed in the sidewalk and not behind the sidewalk.  This would have the unintended consequence of placing on obstacle within the sidewalk.  This requirement should be revised to guidance where specific conditions allow avoiding less than desirable installations. 

A 2” chrome plunger protruding from a Black and White mounting bracket/Sign seemingly provides adequate contrast, and we are interested in further clarification. 

Why would there be a requirement for tactile/visual street name signs on pedestrian crossing equipment, when it is not required at any other location.  There doesn’t seem to be any uniformity or consistency of when/where many of these requirements are being implemented.