Douglas Isbell
|
October 25, 2002 |
1105.3 Pedestrian Signal Phase Timing
The requirements of 3 feet per second as the maximum walking time and increasing
the distance to include ramp lengths have the potential for significant
unintended consequences. Most jurisdictions are now timing pedestrian clearance
intervals based on the character of the intersection. Usually, if there is a
demonstrated need for longer clearance times, the jurisdiction will accommodate
that need. However, to mandate increased crossing time when there is not a
demonstrated need will cause unnecessary vehicle delay, which can be directly
related to increased accidents at intersections as well as amplified driver
frustration. This mandate clearly needs to be linked to a demonstrated need for
each individual intersection. Our recommendation would be to require
jurisdictions to develop pedestrian clearance timing in concert with the
disabled community, based on the specific requirements of the specific location.
In 1105.4 the width of the median island is not specified. We would assume it to
be 48", however, the discussion contained in the crosswalk width section could
lead one to assume the minimum width should be 96". This should be clarified.
1105.5 Pedestrian Overpasses and Underpasses
The requirement to install an elevator or limited-use elevator for applications
where the rise of a ramped approach exceeds 60 inches, will also have unintended
consequences. Since this is a discretionary structure and there are very few
areas that will have a ramped approach of less than 60" a jurisdiction will, in
many cases, forgo the installation of the overpass rather than come up with the
significant additional funds to construct and maintain an elevator. Also, this
requirement is not practical and can be dangerous for the public. An
unsupervised elevator if they become disabled would be a dangerous situation for
the passengers. This does not address the construction or maintenance costs of
those elevators, along with the public liability of crimes against the public in
an unsupervised enclosed area. The homeless population will use the elevators at
night and possibly during the day. Some overpasses are located away from
populated areas, and bringing electric power to those locations would be an
unreasonable cost. This would be a bad regulation and violation of the public
trust. Our recommendation would be to have "resting platforms" at appropriate
intervals, like other ramps.
1105.6 Roundabouts
The requirements proposed in this section are not consistent with accessible
pedestrian considerations in other areas. There will also be unintended
consequences associated with these requirements if implemented.
In 1105.6.1 the requirement to install a continuous barrier is not consistent
with other applications where pedestrians are prohibited, yet barriers are not
required. The positive guidance approach is the best way to handle the concern
of pedestrians wandering through the center of the roundabout. As shown in the
discussion page picture, sidewalks and ramp locations can better address
pedestrian channelization than ugly, hard to maintain, hazardous barriers. Also,
as a matter of consistency, if barriers are required here they should also be
required at all "high-design" intersections and even in mid-block locations to
prohibit pedestrian crossings.
In 1105.6.2 the requirement for signalization on every leg of a roundabout
defeats the original purpose of the roundabout concept. Thousands of low-volume,
neighborhood roundabouts are being built, many as traffic calming devices. To
require signals on every leg is tremendously cost prohibitive and does not
ensure additional safety benefits. An unintended consequence may be an explosion
of drivers pushing the red light and disrespect for these signals specifically
and all signals generally if numerous unwarranted signals are installed where
drivers perceive they are being stopped unnecessarily. A fundamental concept for
roundabout crosswalks is the designer must treat each crossing as a mid-block
crosswalk, both in theory and in design. The access board discussion states,
"Because crossing at a roundabout requires a pedestrian to visually select a
safe gap between cars that may not stop, accessibility has been problematic."
However, this same problem exists at every mid-block crosswalk! If there is a
mandate to require signals here then the argument could be made that every
crosswalk everywhere should be signalized. Obviously, this is a preposterous
argument, but that is why we use engineering criteria and judgment – so that a
rational balance of perspectives is maintained. Again, the user community has
the ear of jurisdictions and specific needs for each crossing can easily be
accommodated without the imposition of a far-reaching, harsh standard.
1105.7 Turn Lanes at Intersections
There are literally thousands of existing "slip" lanes at non-signalized
intersections and this design is continuing to be built. The imposition of this
requirement would essentially eliminate slip lane design for non-signalized
intersections. This would have the unintended consequence of increased
congestion, which would also increase intersection accidents. We believe a
better solution would be to require jurisdictions, in consultation with the
disabled community, to evaluate the signalization of slip lanes at signalized
intersections.
1106 Accessible Pedestrian Signal Systems
We generally agree with the proposal to require pedestrian signal devices that
provide better information and guidance for the pedestrian, even though there
will be a slight increase in installation costs. However, there is a precision
to the location dimensions that many times simply cannot be met. The "location"
wording should be changed to communicate the concept as a guidance statement
without making it a mandate.
In 1106.4 the one area we would object to is the requirement "…of tactile and
visual signs on the face of the device or its housing or mounting indicating
crosswalk direction and the name of the street…". Tactile street name signs are
not required at any other location and to require them on pedestrian crossing
hardware changes these devices from "off the shelf" equipment to custom devices.
This makes them almost impossible to effectively maintain.
1109 On-Street Parking
The majority of streets being built in the County of San Diego each year are in
typical residential neighborhoods. To require an indented, signed, handicap
space on every residential block is surely not what the committee intended. We
would suspect the concern is associated only with areas where there are parking
meters or time limited parking, such as in business areas. Our recommendation
would be to require such handicap spaces only in business or commercial areas.
In 1109.2 Parallel Parking Spaces – the requirement to provide a 60" access
aisle is extremely burdensome and will have significant unintended consequences
that will restrict our ability to help the disabled community. Currently we
install handicap signs in both residential and business areas quickly and easily
to accommodate individual and varying requests. The five-foot indent is simply
out of character in residential neighborhoods. With this requirement we will be
unable to continue our policy of "immediately taking care of the disabled
community." In the future in order to install a handicap space we will have to
propose a capital project to construct a five ft. indent aisle. This means
projects will have to compete with other county projects for very limited funds
and, even if funded, would have large time delays before completion. It also
means we would be unable to respond to changing needs by moving a handicap space
slightly. It is amazing how many times we change sign locations. Our
recommendation would be to eliminate this requirement. It does not serve the
best long-term interests of the disabled community. In addition, the 5’ minimum
height of handicap signs is in violation of the minimum requirements of the
MUTCD.
Passenger Loading Zones
The discussion text states a 5’ access aisle is required for each passenger
loading zone (PLZ). Again, as stated above in the handicap signing discussion,
this has the effect of limiting our ability to quickly install PLZ signing and
if these requirements are adopted we will not be able to install PLZ signs in
the accommodating manner that we have historically done. Access aisles adjacent
to PLZ zones should be eliminated as a mandated construction requirement.
1110 Call Boxes
The requirement to provide a motor vehicle turnout with a minimum paved area 16
feet wide by 23 feet long, connecting to a turning space at each call box, is
not feasible. The requirement to provide teletypewriters (TYYs) at each call box
for the deaf is also not feasible.
1111 Alternate Circulation Path
The requirement to provide an alternate path is generally correct. However, the
requirement of a path only on the same side of the street, with no provision for
"reasonableness", is not feasible in many instances. Many times the scope of
construction is such that no pedestrians can be accommodated and, in fact, the
forcing of pedestrians into this type of area may create an intolerable safety
hazard. Simply put, there are situations where pedestrians cannot or should not
be accommodated and must be moved to the opposite side of the street or in the
case of total street closures moved around an entire block. The guideline for
requiring alternate circulation paths should be a recommendation and not a
requirement.
In 1111.6 the requirement of a lower rail within 1 ½" of the surface does not
make sense since railings only require a rail at 27" for detectability. The
restriction of non-flexible fencing material would appear to be an unnecessary
restriction. Plastic fencing products are now extremely strong, durable and easy
to install and would appear to accommodate the need to provide pedestrian
channelization and protection in a reasonable manner. The allowance of this
material would make it much easier for jurisdictions to require protection in
very short-term construction areas.
The above comments and suggestions should not be viewed as objections to the
concept of providing reasonable access for the disabled community. We, in the
County of San Diego, have historically been and continue to be in support of
reasonable accommodations within the right-of-way. We have been seeking
direction for uniformity of devices and installation practices for years. Our
desire is to communicate potential pit-falls and unintended consequences
associated with several of the proposed standards and our plea is for balance in
the regulations. Should you have any questions or need further clarification on
any of our comments, please contact Julie Davis, County of San Diego, Department
of Public Works, ADA Coordinator, at [...].
Respectfully submitted,
DOUGLAS ISBELL, Deputy Director
Department of Public Works