Paul T. Wells, P.E.

October 28, 2002

State of New York
Department of Transportation

The New York State Department of Transportation appreciates the opportunity to offer comments regarding the draft accessibility guidelines for public rights-of-way.

While NYSDOT endorsed AASHTO’s request for consideration of their comments, we are also offering the following additional comments from several of the Department’s program areas:

General Comments:

1. We recommend adoption of guidelines that establish performance standards and provide opportunities for designers to use professional judgement to identify site/circumstance specific means of achieving the standards.

2. Signing and signalization related guidelines should be progressed simultaneously with the National Committee on Uniform Traffic Control Devices in order to assure concurrent publication in the MUTCD and ADAAG. This will assure that the two regulatory publications are in harmony.



Specific Comments:

1. Section 1105.3. We do not believe that use of a uniformly applied pedestrian
walking speed of 3.0 feet per second is a satisfactory solution to the problem of insufficient crossing times. Such a universally applied speed ignores opportunities to utilize technology that can offer extended crossing times to those who need it when they need it without the potential of causing unnecessary vehicle traffic delay when extended pedestrian crossing times are not required.

2. Section 1105.6. NYSDOT believes that the overall benefits of roundabouts outweigh their potential disadvantages. However, we do recognize that disabled pedestrians, especially blind and low vision persons, may experience difficulties associated with way finding, assessing gaps in traffic, etc. We also recognize the potential for vehicle/pedestrian conflicts but there is insufficient roundabout related data to adequately determine the nature of any potential problems or their extent. Therefore, the countermeasures proposed in the draft guidelines may not be the most appropriate solutions for whatever problems may exist. Moreover, the guidelines prescribe specific measures that would be required. As an alternative, we believe the Access Board should establish performance standards that may be achievable by employing a variety of solutions, including new applications of technology. Signals may be an option but should not be required as the only acceptable solution.

We agree with AASHTO’s recommendation for additional research to analyze the needs of visually disabled pedestrians at roundabouts. We also recommend investigation of advanced signal systems, detection devices, way finding aides, communications techniques, etc. that may improve blind and other visually disabled pedestrians abilities to navigate anywhere within public rights-of-way, including at roundabouts.

We anticipate research will eventually identify ways in which the needs of disabled persons and vehicle traffic can be balanced. Therefore, we suggest it may be reasonable to reserve Section 1105.6 until appropriate research has been completed.

3. Section 1105.7. Our comments regarding Section 1105.6 including our preference for performance standards, the desirability of additional research, and investigation of new methods/technologies apply to this proposed section as well.

4. Section 1106.2. While we agree that audible and vibrotactile indications are useful and desirable, we do not agree that they are necessary everywhere that a pedestrian signal is installed. We prefer to work with the affected populations in communities to identify priority locations for devices that are most appropriate to the users’ needs. This approach satisfies needs and reduces installation and maintenance costs.

5. Section 1106.3.4. This is another section that might be improved by use of a performance standard. For example, allowance should be made for remote (detection) Architectural and Transportation Barriers Compliance Board actuated pedestrian signal timing, green time extensions (when needed) for visually and physically disabled pedestrians, elderly persons, children, etc. Vehicle traffic delay can be kept at a minimum with signal progression either being regained or maintained through maximum default “bandwidth” settings.

Sincerely,


PAUL T. WELLS, P.E.
Chief Engineer and
Assistant Commissioner