Randall R. Wooley
|
October 28, 2002 |
Regarding the Draft Guidelines for Accessible Public Rights of Way, 36 CFR,
Docket No. 02-1, RIN 3014-AA26, I strongly support the detailed written comments
submitted by the American Association of State Highway and Transportation
Officials. I have particular concerns about the following sections of the Draft
Guidelines:
1102.14 would require at least one passenger loading zone in each block face. In
my city, the majority of street miles are on local residential streets.
Typically each residence has available off-street parking. There seems to be no
need for creating passenger loading zones on such streets. In the areas with
more dense development, the city's development codes (and state law) already
require the provision of off-street accessible parking located near to each
building entrance. On-street parking would typically be less conveniently
located. I recommend that the proposed requirement for spacing of on-street
accessible parking be deleted or, alternatively, that exceptions be provided
where alternative off-street accessible parking is provided.
1105.2 would require that crosswalks have a maximum cross slope of 1:48 and a
maximum running slope of 1:20. This requirement would create major design
problems on local streets in some portions of my city where slopes are steep and
street grades are often as steep as 15%. While we encourage flatter grades,
especially at intersections, it is not always feasible to do so. Requiring flat
grades at crosswalks would conflict with requirements for sight distance on the
roadway. People who are able to negotiate a sidewalk along a 15% grade street
are typically do not require the flat crossings. I recommend that this
requirement be deleted.
1105.6.2 would require traffic signals at all pedestrian crossings at
roundabouts. Discussion materials suggest ways that signals might be designed to
allow compliance without significantly disrupting vehicle capacity. However,
those designs do not comply with current MUTCD requirements. I recommend that
the signal requirement be delayed until additional research can be completed and
appropriate MUTCD revisions can be adopted. This provision should not be adopted
until there are practical ways available for the local agencies to implement the
requirement. Research should also give consideration to roundabouts at
relatively low-volume intersections that would not would not meet signal
warrants even if they were a standard intersection. My city has at least one
such roundabout that is currently controlled by stop signs on all approaches.
1111.3 would require alternate circulation paths on the same side of the street
in construction zones. In many construction projects, this would put the
circulation path in direct conflict with construction traffic. On projects on
low-volume local streets, the required alternate circulation path might cost
more than the road or utility construction. While same-side paths might be
encouraged, the requirement should be deleted.
We appreciate the opportunity to comment. We share the goal of making public
facilities accessible and we continue to upgrade city facilities as budget
allows.
Sincerely,
Randall R. Wooley
City Transportation Engineer
City of Beaverton
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