Richard J. Bacigalupo
|
October 10, 2002 |
Richard J. Bacigalupo, Executive Director
RE: Draft Guidelines for Accessible Public Rights-of-Way
Dear Mr. Windley:
The Regional Transportation Authority (RTA) is pleased to respond to the
Architectural and Transportation Barriers Compliance Board's (Access Board)
draft guidelines addressing accessibility in the public right-of-way.
About RTA
The Illinois State Legislature created the Regional Transportation Authority (RTA)
in 1974 to provide public transportation in the six county area surrounding
Chicago in northeastern Illinois. These counties are Cook, DuPage, Kane, Lake,
McHenry and Will, covering about 3,700 square miles.
As a result of a 1983 legislative reorganization, the RTA is exclusively
responsible for fiscal planning and policy oversight of public transportation in
northeastern Illinois. The actual operation of transit services is the
responsibility of the RTA's Service Boards -- the Chicago Transit Authority (CTA),
the Commuter Rail Division (Metra), and the Suburban Bus Division (Pace).
Comments
In reviewing the suggested ADA guidelines for public right of way, it was
determined that the following may be negatively affected should these
recommendations be adopted:
Sidewalk improvements
Informational signage
ADA Paratransit ridership
Sidewalk Improvements
With regard to sidewalk improvements, section 1102.3 recommends that " ... if a
path of travel is under construction, the entity must provide an alternate
circulation path on the same side of the street parallel to the disrupted
pedestrian access route." This often is not feasible due to the terrain and/or
safety issues related to surrounding traffic.
Local entities may be dissuaded when it comes to making improvements to
sidewalks due to such stringent guidelines. This would be a hindrance to the
disability community if municipalities steered away from making sidewalk/curb
improvements because they are not sure as to how to cr3eate a safe alternate
path.
Likewise, it would pose problems for transit. If sidewalks were not repaired as
readily, people with disabilities would experience problems with path of travel
and would be forced to rely on ADA Paratransit. ADA Paratransit would increase
and funds spent on making bus fleets accessible would go unused. It is our
recommendation that some flexibility be allowed with this section. Specifically,
if the terrain of a sidewalk construction site poses significant problems or
safety issues with an alternate accessible path of travel parallel to the site,
the entity could place blockades and signage stating the sidewalk is out well in
advance of a construction site. This signage would direct pedestrians to a
different accessible, yet direct, safe route. Of course, other options or
technologies, e.g., an auditory announcement system, would need to be explored
in order that people with visual disabilities be notified of the route
deviation.
Street Crossing Allowances
Increasing street crossing allowances, i.e. the amount of time needing to cross
an intersection with a traffic light, are also recommended. This definitely
would be helpful to individuals with disabilities. But, until these times are
adjusted at each street crossing that has a traffic light, transit entities will
have to accommodate those individuals on ADA Paratransit who cannot cross in a
timely fashion.
Detectable Warning Surfaces
Sections 1104.3.2, 1108.1 and 1108.1.4 lay out recommendations for detectable
warning surfaces. Specifically, the recommendations require truncated domes at
all street crossings. The majority of individuals with visual disabilities have
expressed opposition towards this recommendation, saying that the truncated
domes, if not installed properly, can cause them to trip. People who use
mobility devices also have concerns regarding truncated domes. Concerns center
on the domes being a barrier to wheels. We recommend that truncated domes not be
a requirement at all street crossings.
Informational Signage
Section 1102.7.1 recommends that all bus route identification signs incorporate
raised and Braille lettering and rounded corners. Both the Chicago Transit
Authority (CTA) and Pace Suburban Bus change routes on a frequent basis. Having
to incorporate the raised and Braille lettering every time a route was changed
would become costly and difficult to fund.
This would also raise issues of confusing people who are blind if a change
occurs and the signs have not been updated. A better solution would be the
announcement systems which inform a waiting passenger of the route being served
by a stopped bus and allow the passenger and bus driver to further communicate
as to bus route information.
Conclusion
The chief concern of transit with respect to these draft recommendations is that
if these regulations are adopted, we expect ADA Paratransit ridership to
increase. Having higher expectations for accessibility is a good thing. However,
until they are implemented, more barriers will be created to using fixed route
transportation. This would be unfortunate, as billions of dollars have been
spent to make transit systems accessible and allow people with disabilities a
greater amount of freedom and independence.
We appreciate the opportunity to comment on this proposal and look forward to an
NPRM that accommodates the comments of all affected parties. Should you require
additional information, please contact Phillip G. Shayne via telephone at [ ...]
.
Sincerely,
Richard J. Bacigalupo
Executive Director
cc: Phillip G. Shayne, Manager of Regional Services
Kimberly A. Robb, Accessibility Specialist
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