Issues Identified Among Comments on Rights-of-Way Guidelines (4/22/03)   Previous Articles:
Board Releases Draft Guidelines
(6/14/02)
Board Receives Over 1400 Comments
(12/18/02)

Last year, the Board released a draft of guidelines for accessible public rights-of-way which it made available for public comment. The guidelines address access to public streets and sidewalks, including crosswalks, curb ramps, street furnishings, parking, and other components of public rights-of-way. By the close of the comment period in late October, the Board had received over 1,400 comments from persons with disabilities, disability groups, leading industry associations, civil engineers, transportation specialists, public works departments, and others. The Board has completed its review of the comments, which are posted on its website, and has identified key issues raised by commenters. These include:

Alterations.
The guidelines address access to newly built and altered public rights-of-way. Many comments expressed concern or confusion over how the guidelines would be applied in the context of “alterations,” as defined in the guidelines. A reason for these concerns is that the intended application of the guidelines in public improvement projects and roadway work does not fully correspond to industry norms and conventions. (The Board has been aware of the need for additional guidance in this area and is working with former members of the Public Rights-of-Way Access Advisory Committee to develop a comprehensive design guide on achieving access in alterations which is due to be completed this year.)

Access for Persons with Vision Impairments.
Access features at street crossings for people with vision impairments, namely detectable warnings and audible pedestrian signals, were addressed by the majority of comments. The guidelines included revised specifications for detectable warnings, a distinctive surface pattern of domes that are intended to provide a tactile warning of entry into streets where curb faces are absent, such as at curb ramps and blended transitions. The guidelines also included requirements for audible and tactile indicators where walk signals are provided at intersections. Comments, particularly those submitted by persons with vision impairments and advocacy groups, were strongly divided over requiring these features at all intersections. However, most commenters who identified themselves as visually impaired supported detectable warnings at certain locations, such as low-slope curb ramps and pedestrian islands, and backed requirements for audible pedestrian signals at complex intersections.

Traffic Roundabouts.
Continuous-flow roundabouts, an increasingly popular alternative to signalized intersections, present unique challenges to access, particularly for people with vision impairments. The draft guidelines included a requirement for crossing signals at roundabout crosswalks to provide safer crossing. Comments from traffic engineers and others expressed concern about the impact since a key advantage of roundabouts is the absence of traffic signals.

On-street Parking.
The guidelines included a requirement for accessible on-street parking (at least one space per block face). Comments advocated a scoping level that was more consistent with existing requirements for parking lots.

Crosswalks and Walk Signals.
Comments expressed concern about impacts on street traffic flow of certain specifications that depart from industry practice, such as those for crosswalk width (8 feet instead 6 feet) and walk cycle timing (based on a speed of 3 feet per second instead of 4 feet).

Pedestrian Overpasses.
The guidelines included a requirement for elevators at overpasses and underpasses with elevation changes over 5 feet. Questions were raised about such a provision discouraging the installation of overpasses and underpasses.

The Board is deliberating on these and other issues raised in the comments and how they can be addressed through revisions to the draft. Once this work is complete, the Board will release a revised set of guidelines and provide another opportunity for public comment.

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