Lynn B. Jarman
|
October 24, 2002 |
ACCESSIBILITY IN THE PUBLIC RIGHT-OF-WAY DRAFT GUIDELINES
(Response to the Access Board’s request for review and comment)
Salt Lake City Public Services has reviewed the proposed guidelines and
respectfully submits the following recommended revisions and statements of
concern:
1102.3, 1111.3 Alternate Circulation Path
Location. The alternate circulation path shall parallel the disrupted pedestrian
access route, on the same side of the street.
Recommended Revision: The alternate circulation path shall parallel the
disrupted pedestrian access route, on the same side of the street, unless in the
judgment of the engineer, significant pedestrian safety issues exist, then the
alternate circulation path shall be provided on the opposite side of the street.
1102.14 On Street Parking. Where on-street parking is provided, at least one
accessible on-street parking space shall be located on each block face and shall
comply with 1109.
Concern: Block lengths are not consistent across the country; the ratio of
accessible stalls to non-accessible stalls will vary from city to city based on
the standard block length. The proposed guideline does not clearly define
whether the requirements apply to all block faces within a city, or only those
locations with pavement marked stalls. The cost to identify accessible stalls on
all block faces, including residential areas would be extreme.
1104 Ramps and Blended Transitions
1104.2.2.1 Running Slope
EXCEPTION: A parallel curb ramp shall not be required to exceed 15 feet (4570
mm) in length.
Recommended Revision: A parallel curb ramp shall not be required to exceed 16
feet in length.
(The proposed minimum pedestrian access width is 48 inches; therefore, the
common sidewalk scoring pattern would occur every 48 inches. Based on this
pattern, the logical “not to exceed length” should be a multiple of 4 feet. In
this case, a parallel ramp should not be required to exceed 16 feet.)
1104.3.2 Detectable Warnings (see 1108)
1105 Pedestrian Crossings
1105.2 Crosswalks
1105.2.2 Cross Slope. The cross slope shall be 1:48 maximum measured
perpendicular to the direction of pedestrian travel.
Concern: This requirement will create “tabled areas” in the roadway, potentially
creating vehicular traffic hazards, particularly in areas where roadways have
steep running slopes.
1105.3 Pedestrian Signal Phase Timing. All pedestrian signal phase timing shall
be calculated using a pedestrian walk speed of 3.0 feet per second (0.91 m/s)
maximum. The total crosswalk distance used in calculating pedestrian signal
phase timing shall include the entire length of the crosswalk plus the length of
the curb ramp.
Recommended Revision: All pedestrian signal phase timing shall be calculated
using a pedestrian walk speed of 3.0 feet per second (0.91 m/s) maximum. The
total crosswalk distance used in calculating pedestrian signal phase timing
shall include the entire length of the crosswalk plus the length of the curb
ramp and additional distance, if any, to the pedestrian signal device.
Concern: Some consideration has been given to a walk speed of 2.5 feet per
second. Walk speeds less than 3.0 feet per second would create significant
vehicular traffic delay issues and environmental pollution concerns.
1105.5 Pedestrian Overpasses and Underpasses
1105.5.3 Approach. Where the approach exceeds 1:20, the approach shall be a ramp
48 inches (1220 mm) minimum in width and shall comply with 405. Where the rise
of a ramped approach exceeds 60 inches (1525 mm), an elevator complying with
407, or a limited-use / limited-application elevator complying with 408 shall be
provided.
Concern: Overpasses and underpasses exceeding the maximum stated approach rise
should not require the installation of an elevator. The extreme cost for
installation, maintenance, and security makes this requirement an unjustifiable
burden on municipalities with limited resources. Efforts should be made to meet
ramping requirements, but site conditions may present a situation of
infeasibility.
1105.6 Roundabouts
1105.6.2 Signals. A pedestrian activated traffic signal complying with 1106
shall be provided for each segment of the crosswalk, including the splitter
island. Signals shall clearly identify which crosswalk segment the signal
serves.
Concern: Installation of pedestrian signals at each roundabout crossing negates
the intended benefits of installing a roundabout. Additional signalization does
not always result in greater pedestrian safety. Instead of requiring signals at
all roundabouts, local engineers should evaluate roundabout installations to
determine which locations would logically benefit from the installation of
pedestrian signals.
1105.7 Turn Lanes at Intersections. Where pedestrian crosswalks are provided at
right or left turn slip lanes, a pedestrian activated traffic signal complying
with 1106 shall be provided for each segment of the pedestrian crosswalk,
including at the channelizing island.
Concern: Additional signalization does not directly equate to improved
pedestrian safety. Well-engineered slip lanes (channelized turn lanes) with
properly established pedestrian crossing times will result in improved safety.
The slip lane design may or may not include additional signalization; the
engineer should make this decision.
1108 Detectable Warning Surfaces
Concern: Considerable concern appears to exist from both the professional and
public sectors regarding the installation of truncated domes. The major
organizations representing the blind community cannot come to agreement on this
issue. Initial installation costs and ongoing maintenance costs, especially in
areas experiencing ice and snow, present real concerns regarding this proposed
standard. Further evaluation is needed to ensure implementation of this
guideline will provide the desired benefit.
Salt Lake City Public Services appreciates the opportunity to provide comment on
the proposed guidelines. The Board’s efforts in this matter are admirable.
Hopefully, with feedback from local jurisdictions, guidelines meeting the true
needs of our communities will be developed and adopted by those enforcing
construction standards.
Sincerely,
Lynn B. Jarman
Salt Lake City Public Services
Engineering Division
Planning and Programming Manager