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Don Wesely
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October 24, 2002 |
October 20, 2002
Scott Windley
RE: Draft Guidelines on Accessible Public Rights-of-Way
Dear Mr. Windley:
The City of Lincoln has reviewed the Draft Guidelines for Accessible Public
Rights-of-Way. We realize that Title II of the ADA requires governments to not
discriminate against people with disabilities and we support the efforts to
improve existing conditions. However, the guidelines as proposed would have
serious consequences that would impose significant costs on local governments.
It is also our feeling that these would be overly restrictive and would not
allow sufficient latitude to design on a case by case basis.
Our comments and concerns are as follow:
Curb Ramps and Blended Transitions (1102.6, 1104)
- Also, drivers may not be as alert to persons crossing at the apex of a corner.
It would seem drivers would be much more alert at this point in the roadway than
after driving around a corner and encountering a pedestrian when their vehicle
has attained a higher speed than at the apex of the corner.
Other Requirements for Curb Ramps and Blended Transitions (1104.3.3 - 1104.3.7)
- prohibit the placement of... utility and sewer access covers, and similar
fixtures on ramps, landings, transitions and portions of the gutter within the
pedestrian access route;
If these items meet the criteria set forth for changes in level, why would they
not be allowed?
- prohibit grade breaks on ramp runs, blended transitions, landings, and gutter
areas within the pedestrian access route;
How will the gutter work if it must be at the same grade as the ramp? That will
either force all the water out into the street or funnel it all back onto the
sidewalk.
- prohibit any vertical changes in level on curb ramps, landings and gutter
areas within the pedestrian access route;
Again, if the vertical change is within the requirements for changes in level,
it should be allowed. To keep nuisance water from ponding within a ramp area, a
minimal lip is often maintained to keep the water off the ramp and moving around
the corner.
- require clear space at least 48 by 48 inches, located beyond the curb line and
wholly within crosswalks and out of the parallel traffic travel lane.
This is confusing as to intent.
Crosswalks (1105.2)
- The cross slope is limited to 1:48, except at mid-block crossings. The cross
slope of the crosswalk is the running grade of the roadway. It is not uncommon
for streets to be constructed with constant profile grades up to 9 or 10
percent. This spec would require reduction of these profile grades to 2 percent
at intersection crosswalks, thus forming “tabled areas” at intersections so that
the 1:48 slope is achieved at crosswalks. The specified running slope for
crosswalks is 1:20.
This may be fine for new areas, but it is often not realistic in built
environments. Changing slopes of streets to accommodate this ruling may not be
feasible.
Pedestrian Signal Phase Timing (1105.3)
- The draft guidelines would require pedestrian signal phase timing to be
calculated according to a walking speed of 3.0 feet per second. The Board
believes that a rate of 3.0 feet per second will accommodate a broader range of
pedestrians and offer greater access.
This would have a major negative impact on traffic. Requiring this change would
more than offset the gains our jurisdiction has made through expenditures of
hundreds of thousands of dollars to improve the traffic carrying capabilities of
our streets, which has been a mantra of the FHWA for years. To make this change
system-wide would increase energy consumption, pollution and vehicular costs to
motorists to accommodate a small percentage of the population who might use a
signal. It would seem that if the route is used by handicapped individuals who
cannot cross in the 3.5 ft/sec time, then the change to a 3.0 ft/sec crossing
time COULD be used as needed.
Pedestrian Overpasses and Underpasses (1105.5)
- The draft guidelines address access to pedestrian overpasses and underpasses,
which would be required to provide a pedestrian access route. A ramp would be
required where the running slope exceeds 1:20. ... The advisory committee
recommended that an elevation change of 60 inches be the cut-off. Consistent
with this recommendation, the draft guidelines would require elevator access
where the rise of a ramped approach exceeds 60 inches.
Implementation of this rule would practically kill off the installation of
underpasses and overpasses for pedestrian crossings. Since it is quite rare
where the grade change of such a structure would be less than five feet, nearly
every one constructed would require an elevator. The major reason stated for not
installing these structures is cost. When you add the cost of providing
elevators at each end to the already high price, you have just made these
infeasible except in the most extreme cases. By doing so, this would increase
the hazard to all pedestrians, handicapped and able-bodied alike, forcing them
to cross using at-grade crossings.
Roundabouts (1105.6)
- To provide safer crossing at roundabouts, the draft guidelines would require
pedestrian activated crossing signals at each roundabout crosswalk, including
those at splitter islands.
This requirement sounds as if it was written by a group of people scared of new
ideas and who have absolutely no clue what they are talking about. We have just
completed a roundabout to replace a signal at one of the highest accident
locations in the City. A lot of people opposed to this installation stated it
would be dangerous for pedestrians to cross. Quite the opposite is true.
Pedestrians only have to cross one lane at a time, they are crossing at a point
where traffic is moving slowly entering or leaving the roundabout and the driver
is alert because of the increased requirements placed on them. To now have to
signalize these would completely waste the advantages they naturally provide
pedestrians. In certain areas where high volumes of pedestrians and vehicles
exist, crossing lights may be of use, but a requirement for all or even most
locations can only benefit signal suppliers.
Since vehicles would be moving at higher speeds and pedestrians would have
longer crossing distances, by using the same logic, we should put in crossing
signals at every unsignalized intersection also.
- Barriers or similarly distinct elements are needed to prevent blind persons
from inadvertently crossing a roundabout roadway in unsafe locations. The draft
guidelines would require a continuous barrier along the street side of the
sidewalk where pedestrian crossing is prohibited. If a railing is used, it must
have a bottom rail no higher than 15 inches.
Since vehicles would be moving at higher speeds and peds would have longer
crossing distances, by using the same logic, we should put in barriers at every
unsignalized intersection also. Again, this just doesn’t make sense. By
following the sidewalk, pedestrians are directed to the safest crossing
locations.
Turn Lanes at Intersections (1105.7)
- The draft guidelines also include a requirement for a pedestrian activated
signal at each segment of a crosswalk that crosses right or left turn slip
lanes.
This will likely increase vehicular crashes. In order to place the signals where
turning vehicles can see them an adequate distance in advance of the crossing,
they will also be visible to through vehicles who may become confused by several
conflicting indications. Rear end and side-swipe crashes will likely result.
This should not be mandatory at all locations, but rather should be considered
on a case by case basis. If signals are not needed for non-handicapped persons,
there is a question as to whether or not they would be needed for handicapped
individuals.
Accessible Pedestrian Signal Systems (1102.8, 1106)
1106.2 Pedestrian Signal Devices. Each crosswalk with pedestrian signal
indication shall have a signal device which includes audible and vibrotactile
indications of the WALK interval. Where a pedestrian pushbutton is provided, it
shall be integrated into the signal device and shall comply with 1106.3.
Obviously these add cost to signal installation/maintenance. Where will the
funding for this come from in these tight economic times?
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.
This will require major reconstruction of many traffic signals. In many
locations, it is not possible to comply with this due to existing obstructions
in the way of the signal, including underground utilities.
1106.3.2 Locator Tone. Pedestrian pushbuttons shall incorporate a locator tone
at the pushbutton. Locator tone volume measured at 36 inches (915 mm) from the
pushbutton shall be 2 dB minimum and 5 dB maximum above ambient noise level and
shall be responsive to ambient noise level changes. The duration of the locator
tone shall be 0.15 seconds maximum and shall repeat at intervals of one second.
The locator tone shall operate during the DON’T WALK and flashing DON’T WALK
intervals only and shall be deactivated when the pedestrian signal system is not
operative.
This is another cost concern. It is also sometimes a concern with nearby
residents/businesses as to the addition of noise pollution.
1106.4.2 Street Name. Signs shall include street name information aligned
parallel to the crosswalk direction and complying with 703.2.
Another cost concern.
On-Street Parking (1102.14, 1109)
- The draft guidelines would require access to at least one parking space on
each blockface.
In an area with 150 foot long blocks and parallel parking, you can only provide
4 or 5 spaces per block. This creates a rate of handicap parking in the 20-25%
range, which is ridiculously high unless you are in Florida or Arizona. If the
same block has angle parking, you are looking at approximately 8 spaces,
dropping the rate for handicapped spaces to 12.5%, still considerably higher
than what is required for parking lots. Merchants in particular will have great
problems with creating many unusable parking spaces, which will lead to misuse
of these spaces.
This also does not specify if this would be required city-wide or only in
commercial areas. Providing the required handicapped parking space with signing,
pavement markings and ramps on every block in the city would create an
astronomical cost.
- Requirements address adjoining access aisles at spaces, accessible connecting
routes, signs, and parking meters. An accessible parallel space and access
aisle, which must be flush with the street, can be achieved by indenting the
curb line, similar to a loading zone.
This will create problems during snow events. Plows will come along and push
snow into the indented area, making them useless. These will also create
discontinuities in the sidewalks in downtown areas where sidewalks normally run
from the face of buildings to the edge of the curb. In high ped areas, this will
have a major negative impact. I think the cost of lawsuits related to trips and
falls in these inset areas each year will greatly outweigh any benefits derived
from their installation.
Passenger Loading Zones (1102.15)
- ADAAG requirements for passenger loading zones would be applied to loading
zones in the public right-of-way. Where a long loading zone is provided, at
least one area in every 100 continuous feet must comply with requirements in
ADAAG section 302 and 503 which address the surfacing, the size of vehicle
pull-up spaces (8 by 20 feet minimum), the marking and size of access aisles (at
least 60 inches wide and as long as the pull-up space), and vertical clearance
(114 inches minimum).
These will not work well at schools where it is important to provide curbs to
create barriers to vehicles running onto sidewalks and hitting pedestrians.
- 1111.3 Location. The alternate circulation path shall parallel the disrupted
pedestrian access route, on the same side of the street.
This is a costly unfunded mandate. Providing parallel ped access on the same
side of the Street as the existing path is often not practicable. Based on costs
and usage, it is often impossible to justify not moving pedestrians, both able
bodied and disabled, to an adjacent route.
- 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.
The MUTCD allows secondary signs to have a minimum height of 72”, vs. 80”
required here. This would require major work to change signs throughout the
city.
Again, we support reasonable access for disabled pedestrians and continually
review our standards and processes to assure that what we are doing is
reasonable and safe. We are concerned that these draft guidelines, if adopted,
would create major consequences for communities of all sizes. We would ask that
these consequences be considered more carefully before enacting any changes to
the existing requirements.
Sincerely,
Randy Hoskins, P.E.
City Traffic Engineer
City of Lincoln, Nebraska