Dennis E. Royer
|
October 28, 2002 |
Dear Committee Members:
I am writing to provide comments on the draft standards for accessibility. I
have thirty years in dealing with these issues, and although an engineer by
profession, I will address these issues in a less detailed perspective, having
read numerous comments submitted by my engineering brethren.
In 1990, the City and County of Denver received an award as the "Most accessible
City in the United States", an award that we are very proud to have received.
Denver has spent over 50 years developing and implementing similar standards.
When these draft standards were originally introduced in the early 1990's, the
late Frank Nelson, Director of the Mayor's Office for People with Disabilities,
and I worked diligently to create appropriate methodologies to integrate the
requirements of the Americans with Disabilities Act into real life applications.
We did not agree with all the standards proposed, similar to the situation we
find ourselves with the current proposals. I would like to address some of the
issues with the draft standards.
On Street Parking: It is not necessary to present a standard or guideline for on
street parking at a ratio of 1 in 25. Limitations and availability of off street
parking spaces make this an unnecessary mandate.
Pedestrian Signaling Devices: This is an issue that seems minor but has
tremendous ramifications, not only for government but the disabled community as
well. For years I was told by the National Federation of the Blind not to
install audible devices because the visually impaired will become dependent on
these devices rather than their senses. As a result every traffic signal will
have to be retrofitted at significant cost. Unlike the cost estimates provided
by the American Council for the Blind, the actual cost will be several times
higher. Denver presently has approximately 1250 signals which will result in an
immediate cost of over $5 million to convert. If the NFB is correct, then these
changeovers cannot be piecemeal, implemented over 20 years, but must be
implemented over the short term to avoid liability claims for locations that
have yet to be retrofitted. With an annual signal budget for all maintenance and
construction of only $1 million, we would need to commit five years budget
allocations or receive an immediate increase to address this one issue. Having
installed several audible signals as demonstrations while the City Traffic
Engineer, I have heard all the complaints associated with this issue. This is a
policy question that must be addressed by the disabled community as well as the
government representatives before standards are finalized.
Alternate Circulation Paths: Many areas simply do not allow same side paths
without tremendous impact on construction costs or eliminating lanes of travel
in the right of way. We already attempted to meet this standard and have for the
past 30 years; however, practical decision making does not always allow this
option. It should be a recommendation, not a mandatory standard.
Handrails for Grades: We already have numerous street furniture requirements
which impose significant liability exposure. As someone with numerous years
trying to implement streetscape while minimizing liability, I have attempted to
avoid railings, as they pose one of the most difficult problems for
implementation due to exposure to sighted people, let alone visually impaired.
Adding these to grade differentials along paths and sidewalks will not create a
safer environment as intended, but will increase the hazard potential to
everyone. Let's look at this requirement from the perspective of all users in
limited space and see if there are not less restrictive design options.
Roundabouts: Signalizing roundabouts for pedestrian crossings will signal (no
pun intended) the end of this strategy for cost reasons. The intent of this
strategy is to avoid signalization. As such, this requirement will emphasize the
traffic signal as the cost effective solution. Most roundabouts are installed on
local or collector streets that do not typically have signals. This requirement
would introduce signals into residential areas where they are not conducive with
good traffic control.
In our pragmatic world, costs will always drive the alternatives that are
implemented. Many of the requirements of these standards create excessive cost
demands on limited resources. Creating unfunded mandates is an issue that the
media and our elected officials get quite interested in addressing. These
standards need to be reduced in their overall breadth to avoid political
backlash. Many of the standards proposed are good. Therefore, let's discard or
revise the more controversial ones to get as many beneficial ones implemented
and, most importantly, funded. We can more prudently address these issues over
time and may, following adoption of the remaining standards, develop support for
those delayed.
Thank you for the opportunity to respond. If I can assist in any way, please
feel free to contact me.
Sincerely:
Dennis E. Royer
Deputy Manager of Public Works for Program Development
City and County of Denver