Cathy M. Nelson
|October 25, 2002|
Oregon Department of Transportation
RE: ADA - ODOT Response to Draft Guidelines
The Oregon Department of Transportation applauds the efforts of the Architectural and Transportation Barriers Compliance Board to make transportation facilities accessible to all members of the public. Attached are the comments and recommendations on the Draft Guidelines for Accessible Public Rights-of-Way.
Cathy M. Nelson, Technical Services Manager/Chief Engineer
Oregon Department of Transportation
cc: Bruce Warner, Director of the Oregon Department of Transportation
Comments and Recommendations on the Draft Guidelines
for Accessible Public Rights-of-Way
United States Access Board
Oregon Department of Transportation
EXISTING PUBLIC RIGHTS-OF-WAY
Section 1102.2: The draft guidelines require the retrofitting and the application of the new guidelines to alterations of exiting facilities.
Comment: ODOT opposes this requirement. There is no clear definition for “alteration” nor is there clarity regarding the degree to which the accessibility guidelines should be applied to these projects. It is also unclear how the requirement would be applied to projects currently in the development process. For projects in the early phase of project development, the new guidelines could be applied. For projects further along in the development process, implementing these new guidelines would be both cost-prohibitive and jeopardize their development schedule. It would be more effective to establish/identify a compliance date to aid in the consistent implementation of these new requirements.
Section 1105.6: The draft guidelines would require pedestrian activated crossing signals at each roundabout crosswalk, including those at splitter islands.
Comment: ODOT opposes this requirement. ODOT has made a conscious decision to ensure pedestrian safety in its roundabout designs by slowing vehicular traffic considerably as it enters, circulates around, and exits the roundabout. The ODOT guideline for roundabouts includes an assessment of pedestrian activity at the proposed site. Generally, pedestrian volumes are low, as are vehicle speeds. ODOT design standards assure well-marked, highly visible pedestrian crossings that assure motorists can yield to, and stop for, pedestrians prior to entering the area where attention to circulating traffic is required. This requirement will increase the time it takes pedestrians to cross the road as they would have to push a button and wait for the “WALK” indication rather than merely cross the roadway in an available gap. There would be unnecessary delay to motorists while a traffic signal times the appropriate “WALK” and pedestrian clearance intervals. This delay would increase the possibility of conflicts upon the circulatory roadway and reduce safety to the motoring public. Signalizing roundabouts would add considerably to their cost and defeat one of the primary purposes of roundabouts, which is to maintain capacity by allowing traffic to slow down, yield, and merge rather than stop completely for circulating vehicular traffic. The several roundabouts that have been built in Oregon testify to the success of this design approach, as motorists yielding to pedestrians compliance is very high. Requiring signalization of roundabouts would severely curtail their construction, which could in turn decrease safety for all users.
Section 1105.6: The draft guidelines would require a continuous barrier along the street side of the sidewalk where pedestrian crossing is prohibited. If a railing is used, it must have a bottom rail no higher than 15 inches. This dimension would allow use of a standard roadside guardrail while providing sufficient cane detectability.
Comment: ODOT opposes this requirement. Oregon’s roundabout design guidelines recommend the separation of sidewalks from the approaches and the circulating roadway. This gives ample tactile cues to the user where the sidewalks and crosswalks are located.
TURN LANES AT INTERSECTIONS
Section 1105.7: The draft guidelines also include a requirement for a pedestrian activated signal at each segment of a crosswalk that crosses right or left turn slip lanes.
Comment: ODOT opposes this requirement. ODOT is trying to achieve better geometry and careful placement on the crosswalk to improve visibility of pedestrians and motorists, increasing yielding behavior. Placement of signals is not always possible due to physical constraints.
Signalized slip lanes would introduce additional poles in what often is a limited space. ODOT experience with traffic signals at “slip lanes” has generally found a high rate of both motorist and pedestrian disregard for the traffic signal. The Department has removed several at the request of local governments. In areas where there are multiple turn lanes and resulting higher volumes and longer pedestrian crossing distances, traffic signal control of the turn movements are a viable consideration. Improved traffic signal controller technology will help make these specific cases more efficient and better able to meet driver and pedestrian expectations. ODOT suggests a term other than “slip lane” be used, as this implies traffic can “slip” by without stopping or yielding. Right-turn or left-turn lanes are usually signal, stop or yield controlled.
Section 1105.5: The draft guidelines would require elevator access where the rise of a ramped approach exceeds 60 inches.
Comment: ODOT opposes this requirement. Providing elevators in the public right-of-way would be costly to build and difficult to maintain. ODOT will strive to ensure that changes in elevation are accessible.
5% RUNNING SLOPE IN CROSSWALKS
Section 1105.2: The specified running slope for crosswalks is 1:20.
Comment: ODOT will try to meet this standard on most projects. It may not be possible on certain preservation projects. ODOT will work to achieve 8% and try for 5% where possible.
2% CROSS SLOPES IN CROSSWALKS
Section 1105.2: The cross slope is limited to 1:48, except at mid-block crossings. This specification would require reduction of profile grades to 2 percent at intersection crosswalks, thus forming “tabled areas” at intersections so that the 1:48 slope is achieved at crosswalks.
Comment: ODOT’s crosswalk standard is 10 feet. Requiring a 2% cross-slope across the entire 10 feet may not be possible in steep terrain. ODOT suggestion: require 2% slope for 48 inches of the crosswalk instead of the entire crosswalk.
PEDESTRIAN SIGNAL PHASE TIMING
Section 1105.3: The draft guidelines would require pedestrian signal phase timing to be calculated according to a walking speed of 3.0 feet per second.
Comment: ODOT opposes this requirement at every signal. ODOT currently uses guidance from the MUTCD, which requires the use of 4.0 feet per second (1.2 m/s). We are not aware of cases where this has been a concern, but have addressed special requests near retirement homes. In order to preserve green band vehicle progression on state highways, ODOT typically uses the minimum traffic signal cycle length that will cover the timing requirements of all crosswalks. This approach has usually resulted in providing the best access with minimum delay for all users – both vehicle and pedestrian. The use of a 25 percent longer pedestrian clearance interval would have negative effects on efficiency and delay in state highway traffic signal systems.
There is technology available to provide additional pedestrian clearance time on demand and it would be worthwhile to explore the possibility of passive pedestrian detection to extend pedestrian clearance when conditions warrant. Merely increasing delay to all users without any documented benefit would undoubtedly lead to increased frustration and disrespect for traffic control devices. Engineering judgment should be used and each crosswalk and situation should be considered.
ACCESSIBLE PEDESTRIAN SIGNAL SYSTEMS
Section 1102.8 & 1106: The draft guidelines would require push buttons to be equipped with a locator tone and an audible indication of the WALK interval.
Comment: ODOT opposes this requirement at every location. Not all visually impaired people want the extra help. ODOT has a current practice of providing audible “WALK” indications by user request and is considering an expansion of this practice. We do, however, feel the exactness of the specification will create problems in obtaining suitable equipment. Currently ODOT uses tones at 2800 Hz with a duration of 0.2 seconds and 1100 Hz with a duration of 0.6 seconds. The tones repeat at intervals of 1.0 and 1.5 seconds respectively. We have also found that systems which respond to variation in ambient noise levels cannot guarantee the specification cited. In informal discussions with users it has generally been agreed that a constant tone volume adjusted to the specific environment provides an adequate, constant signal which fully meet the needs of all pedestrians. Although ODOT has provided audible signals we are concerned of the cost and availability of products providing vibratory signals. Would two pushbuttons, and other required equipment, for two different pedestrian signal phases be allowed on the same pole or would separation be required?
48” MINIMUM CLEAR WIDTH
Section 1103.3: The draft guidelines specify a minimum clear width of 48 inches for the pedestrian access route, excluding the width of curbs.
Comment: ODOT opposes this requirement. The 48 inch width is greater than the 36 inch width specified for accessible routes on sites per Section 1111.2. It could cause problems on narrow sidewalks and require extra right-of-way or moving poles, hydrants etc.
NO GRATES IN RAMPS, LANDINGS ETC
Section 1104.3.3: The draft guidelines state “Surfaces of curb ramps, blended transitions, and landings shall comply with 302. Gratings, access covers, and other appurtenances shall not be located on curb ramps, landings, blended transitions, and gutter areas within the pedestrian access route.”
Comment: ODOT opposes this requirement. In most cases it will be possible to comply, but in retrofits, there will often be situations where existing utility lines, drainage basins etc will be located in area that cannot be moved. Gratings, access covers etc. can be placed in ramps and landings in such a way that the walking surface will still be smooth.
ONE HANDICAP PARKING SPACE PER BLOCK
Section 1102.14: The draft guidelines state “Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face…”
Comment: ODOT opposes this requirement. With tight conditions and competition for available space, this requirement would put an undue burden on cities with short blocks and only a handful of parking spaces per block, therefore limiting the total on-street parking available to all.
Section 1102.5: Protruding objects on sidewalks and other pedestrian circulation paths shall comply with 1102.5 and shall not reduce the clear width required for pedestrian accessible routes.”
Comment: ODOT opposes this requirement. Four-inch or less protrusion on poles between 27 and 80-inches would require new push button mountings, removal of controller cabinets, removal of electrical service cabinets, and removal of meter bases from signal poles. Separate power supply cabinets (referred to as BMS) would be required in lieu of the ODOT standard Remote Power Source.
Section 1102.7.2: The language from Informational Signs and Warning Signs reads: “Specifications for visual legibility would also apply to informational signs and warning signs located in public rights-of-ways, but the draft guidelines would not require the inclusion of raised and Braille characters.” The language from the Scoping Requirements reads: “Informational signs and warning signs shall comply with 703.5.” (Section 703.5 describes the specifications for Braille characters.)
Comment: The draft guidelines for Informational Signs and Warning Signs appear to conflict with the guidelines for Scoping Requirements. One must question if the language in Scoping Requirements is intended to exempt temporary informational and warning signs from consistency with the requirements of Informational Signs and Warning Signs.
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