Bolduc, Smiley & Associates, Inc. is responding to
the request for comments about the referenced guidelines that were published
in the Federal Register on Monday, June 17, 2002. We are a
professional transportation engineering firm in Phoenix, AZ.
In general, we are respectfully recommending that
the Access Board not adopt the proposed requirements for the
following subjects. Further research and joint discussions with the
professionals who deal with pedestrian, bicycle and vehicular movements on
public rights-of-way are highly recommended, as well discussions with
representatives of the National Federation of the Blind.
The subjects, along with brief comments are shown
Pedestrian Signal Phase Timing
A walking speed of 3.0 feet per second is not safe
and is not reasonable everywhere. Currently professional transportation
engineers adjust walking speeds based upon users requirements.
Pedestrian Activated Crossing Signals
at each Roundabout Crosswalk and Right or Left Turn Slip Lanes
This requirement, while undoubtedly well
intentioned, unfortunately has the very real potential to be a primary cause
of thousands of rear-end crashes and substantially increase congestion and
delay. It is my understanding that the National Federation of the Blind (NFB)
and the Rehabilitation Services Administration (RSA) of the U.S. Department of
Education both strongly support proper orientation and mobility training over
this sort of unnecessary assistive device.
Accessible Pedestrian Signal Systems
It is not justified everywhere that “push buttons
be equipped with a locator tone integrated into the signaling device to
indicate that pedestrian activation is necessary and to identify the location
of the push button”. The professional transportation engineers currently
cooperate with the crossing needs for vision impaired pedestrians when they
are made aware of specific locations needing special attention.
The draft guidelines would require a continuous
barrier along the street side of the sidewalk where pedestrian crossing is
prohibited. This requirement is unsafe, unreasonable, not justified and
unsupported by either research or the NFB or RSA.
Please consider these comments before moving
forward with the proposed requirements.
Stephen L. Bolduc, P.E.
Bolduc, Smiley & Associates, Inc.