Rodney T. Andrade
|August 14, 2002|
By way of introduction, MacKay & Somps is company that has specialized in providing private and public clients with planning, engineering and surveying services for land development and public works projects for about 50 years. We are consistently ranked in the 200’s of the Engineering News Record’s top 500 design firms in the country.
The following constitutes our company’s comments on the above referenced Draft
1. It is presumed that not all public street systems must comply with the criteria proposed, rather compliance is required for designated “Pedestrian Access Routes” only. Clarification of when “Pedestrian Access Routes” are required is very important since the design criteria proposed will be very difficult to achieve on many projects. Requiring local agencies to officially determine those routes that qualify as “Pedestrian Access Routes” should be considered. Specific guidelines (with examples) as to how Pedestrian Access Routes are identified is a significant issue. For instance, would a Pedestrian Access Route be required to connect a bus stop to a private (HOA owned) swimming pool complex? If so, what if the complex is some distance from the bus stop? If so, must the Pedestrian Access Route connect the pool facility to all bus stops or just one? What about a small park site in hillside areas where compliance is impossible? We fear that lack of detailed guidance in this regard will lead to local agencies requiring that all public streets comply with these standards which will be an impossible situation.
2. Private land development projects typically involve the construction of public streets and often have a quite extensive and time-consuming approval process with which to comply. Often project planning and design is underway for many years before construction is allowed to proceed. Will the Board allow projects involved in the midst of these planning and design efforts to avoid having to comply with the design criteria proposed? Some “grandfathering” of projects must be considered.
3. For many years local agency public works standards have required that “accessibility” be incorporated in all public street construction. This effort is most evident by the installation of accessible ramps at every new curb return constructed. Assuming that the proposed standards apply to “Pedestrian Access Routes” only, should current standards continue to apply to other public streets? This will introduce a situation where different standards apply to different streets, potentially a confusing (for the public) situation. How will a “user” identify in the field which route complies with the new standards?
4. Should horizontal alignment standards be included in the document (consider meandering sidewalks or walks that jog 90% around driveways)?
5. Public works standard sidewalk cross slopes (as well as other infrastructure elements like cross slopes) are typically 2%. We suggest the 1:48 slope specification be changed to 1:50 (2%) so as to avoid wholesale revisions to public works standards. Also, it should be made clear that local agency public works construction tolerances will be allowed.
6. The requirement for no more than a 1:48 cross slope in a crosswalk is often problematic. Typical public works standards allow 6% through intersections. If this 1:48 (2%) slope proposal is upheld, it will have the result of steepening those portions of the street between intersections often above the 5% desirable for a Pedestrian Access Route. It is suggested that additional cross slope at crosswalks be allowed, especially when the longitudinal (running slope) for a crosswalk can be set at a slope less than the 5% allowed in the draft standards. For instance, when the running slope is 2% the cross slope should be able to be increased to 5%.
7. The proposed standards do not allow grade breaks “at gutter areas within the Pedestrian Access Route”. We assume that this precludes grade breaks in the gutter where the Pedestrian Access Route crosses the gutter at a curb ramp. It is not reasonable that no grade breaks be allowed. Rather, how much of a grade break can be tolerated (1%?) should be evaluated.
8. We do not understand how crosswalk requirements would apply to unmarked crossing wherever pedestrian travel across the roadway is not prohibited.
9. We do not think limiting the ramp height at over-crossings or under-crossings to 60 inches (without an elevator) is logical in consideration of the fact that Pedestrian Access Routes in other areas would be allowed to follow the slope of an adjacent street which might have many times exceeded the 60” ramp height and the 5% ramp grade criteria.
10. Please clarify the requirement for signals at “right or left turn slip lanes”. We assume this criteria applies where free right or left turns are allowed without stopping at an intersection and not where standard deceleration lanes are constructed.
11. Parking is required at the rate of one space per “block face”. Blocks (space between intersections) vary substantially so we suggest a maximum spacing be defined. Also, we assume that this parking is required along a Pedestrian Access Routes only. Please clarify.
12. Current ADA standards allow private development in hillside areas to be exempted from requirements. It is suggested that, since land development projects in hillside areas normally include public streets, this type of an exemption from public right of way accessibility standards be established.
13. The draft includes various graphics which would be much more helpful if dimensional requirements and maximum slopes were shown on the graphics.
14. We suggest that traffic signal timing requirements be reviewed by professional traffic engineers as to it’s impact on municipal traffic systems.
Thank you in advance for your thoughtful consideration of our comments.
Rodney T. Andrade
Mackay & Somps
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