John W. Van Winkle, P.E.
|October 25, 2002|
To the Access Board of the Office of Technical and Informational Services:
I am writing in regards to the proposed guidelines for accessible rights of way. I am in full agreement with the comments expressed by the Tennessee Section of the Institute of Transportation Engineers, which I have attached.
I would also like to add comments regarding the section on roundabouts. The recommendation to require pedestrian-actuated crossing signals and continuous barriers at roundabouts seems impractical and inconsistent. In many cases, roundabouts are built to eliminate the need for signalization. To require signals at a roundabout is contrary to this intended goal.
If pedestrian signals and barriers are to be required for roundabouts, why would they not be required for all pedestrian crosswalks? A crosswalk at a roundabout approach is very similar to a crosswalk at any channelized T-intersection or, for that matter, any midblock crosswalk. In the case of a midblock crosswalk, the conditions are actually more hazardous for pedestrians in one respect because the speeds are higher.
I recommend that this section on roundabouts be deleted from the guidelines
or at least amended to be a recommendation, rather than a requirement.
John W. Van Winkle, P.E.
District 5 President of ITE
City Traffic Engineer
TENNESSEE SECTION, INSTITUTE OF TRANSPORTATION ENGINEERS
POSITION OF THE DRAFT “GUIDELINES FOR ACCESSIBLE RIGHTS-OF-WAY”
WHEREAS, the Tennessee Section of the Institute of Transportation Engineers is a professional organization of over 250 persons who are actively involved in the field of transportation and who share a common interest in improving the quality of the surface transportation system in Tennessee; and
WHEREAS, the mission of the Tennessee Section of the Institute of Transportation Engineers (TSITE) is the professional development and growth of the traffic and transportation industry, promoting safe and efficient flow of people, goods and services; and
WHEREAS, the membership of the Tennessee Section of the Institute of Transportation Engineers represent the local government agencies who will be most impacted by the proposed “Guidelines for Accessible Rights-of-Way” developed by The Access Board; and
WHEREAS, a review of the draft “Guidelines for Accessible Rights-of-Way” was conducted and the Tennessee Section of the Institute of Transportation Engineers desired to make its comments and concerns known to The Access Board since its membership will be directly impacted by the proposed guidelines and responsible for implementing many of its recommendations; and
WHEREAS, the Tennessee Section of the Institute of Transportation Engineers shares The Access Board’s desire to ensure that access for persons with disabilities is provided within the public right-of-way and that the same degree of convenience, connection, and safety afforded the public generally is available to pedestrians with disabilities. However, we are concerned that the proposed guidelines do not take into account the negative impacts and in some cases extreme impacts to the primary users of the public right-of-way, the motorist; and
THEREFORE, the Tennessee Section of the Institute of Transportation Engineers would like to provide the following comments for consideration by The Access Board when developing the final “Guidelines for Accessible Rights-of-Way”:
1. What types of improvements or maintenance activities will trigger any requirements for accessibility improvements? Will filling potholes, making spot drainage improvements, upgrading signal displays, recutting vehicle detector loops, restriping a roadway require accessibility improvements? The types of activities need to be clarified.
2. What accessibility improvements should reasonably be expected to be made when the trigger is activated?” What is meant by the phrases “technically infeasible” and “maximum extent feasible?” These need to be defined and clarified so that reasonable requirements are made by the Access Board and not by the Court system.
3. Alternate Circulation Paths – The guidelines call for an alternate circulation path parallel to and on the same side of the street as the disrupted pedestrian access route, however, this is not always possible. This requirement also gives no guidance as to the amount of time the closure may take place without requiring an alternate route. Would utility work in a manhole for 1 hour require the construction of an alternate access route? How can existing sidewalks be brought up to the proposed standards if they can’t be closed for a day? The phrase “other temporary conditions” appears to be vague and could mean just about anything to a potential litigant. Further clarification on these issues needs to be provided.
4. Cross Slope of Crosswalks – The guidelines call for the cross slope of cross walks to be 1:48 maximum measured perpendicular to the direction of pedestrian travel. This would in effect require the “tabling” of the crosswalk or intersection and could require adjustments in the vertical alignment of the roadway well beyond the intersection which, depending on the road’s design speed, may be significant. Street elevations may end up being different from the adjacent sidewalk elevations, which may make sidewalks between intersections even steeper. Installing “tables” for emergency vehicles could be a serious problem. Loss of control of vehicles in urban areas due to these “tables” could have tremendous safety implications for pedestrians alongside the roadway. This requirement is unrealistic and will likely lead to decreased safety for the motorist and pedestrians. We strongly feel that this requirement should be deleted from the guidelines.
5. Curb Ramps – The guidelines discourage diagonal curb ramps at intersections. While it may be possible to design new intersections to accommodate single ramps for each crosswalk, reconfiguring many existing intersections with new ramps would require complete reconstruction of the roadway including moving crosswalks, parking, signals, etc. In addition, some intersections may function better for both pedestrians and motorists by using diagonal ramps. We recommend including diagonal ramps in the guidelines as an acceptable option for use in appropriate situations and encouraging the use of single ramps at newly designed intersections.
6. Pedestrian Signal Phase Timing – The guidelines change the pedestrian signal timing by using a walking speed of 3.0 feet per second 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. These requirements seem excessive if they applied to all intersections, especially those with minimal pedestrian activity. This will present serious disruptions to motorists at a time when we are trying to reduce congestion through means other than widening roadways. We recommend maintaining the design criteria for traffic signals as defined in the MUTCD.
7. Channelized Turn Lanes at Intersections - The guidelines will require a pedestrian activated traffic signal for each segment of the pedestrian crosswalk, including across the channelized turn lane. The impact of this requirement will be devastating to capacity at many intersections. Signalizing these locations may actually decrease the safety of pedestrians and vehicles because the signals are likely to be ignored by many drivers. We recommend deleting this requirement from the proposed guidelines.
8. Accessible Pedestrian Signal Systems – The guidelines will require the installation of Accessible Pedestrian Signal systems at all existing signalized intersections with pedestrian indications. The costs of these devices will be a tremendous burden on already strapped traffic engineering agencies. These requirements appear to be overkill by providing these expensive and untested devices at all intersections, regardless of the need. We recommend retaining the MUTCD requirements until studies prove the safety benefits of these devices.
WHEREAS, the Tennessee Section of the Institute of Transportation Engineers understands the need for standards related to access for disabled pedestrians, however, we have serious concerns about the impacts of the proposed guidelines and believe that some are not realistic or cost effective and that revisions to the draft guidelines are necessary.
NOW, THEREFORE, BE IT RESOLVED, that the Tennessee Section of the Institute of Transportation Engineers submits these comments listed above for consideration and requests that serious consideration be given to the issues raised; and
BE IT FURTHER RESOLVED that the Tennessee Section Institute of Transportation Engineers Board of Directors directs that these recommendations be submitted to the US Access Board on or before October 28, 2002.
APPROVED: Cindy Pionke, P.E., President
Anthony Todd, Vice President
Bill Kervin, P.E., Secretary-Treasurer
Craig Hanchey, P.E., PTOE, Immediate Past President
Craig Hanchey, P.E., PTOE Date
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