Robert Brotherton, P.E.
October 28, 2002
RE: Draft Guidelines on Accessible Public Rights-of-Way
As Proposed by the U.S. Access Board ( June 17, 2002 )
It is our understanding that the transportation industry and State and Local
Governments are being afforded the opportunity for comments and suggestions
regarding the referenced draft guidelines before going to rulemaking. The City
of Dunedin is firmly committed to providing for pedestrian accessibility needs
to the maximum extent possible when constructing facilities within the public
rights-of-way. This commitment extends not only to the ADA requirements for
persons with disabilities, but to all pedestrians, including our City’s high
percentage of elderly population. Although we agree with the need for design
standards and applications criteria, many of the issues in the guidelines lend
themselves to potential negative consequences because the mandates do not allow
flexibility based on demonstrated need or more suitable design.
The following is a summary of our comments and concerns:
1104.3.2 / 1105.4.2 / 1108 Detectable Warnings - We do not support the truncated
dome design for standard ramp conditions. Discussion of the guidelines at a
Dunedin ADA Committee meeting revealed support of the design by the visually
impaired representative, but opposition by the wheelchair representative. We
also have concerns about the roughness of the surface as a potential tripping
hazard, as well as concerns about product availability, material specifications,
and maintenance needs. We feel that a more suitable tactile surface should be
specified for standard 1:12 ramps and that the use of truncated domes should be
reserved for severe conditions such as platform edges, as specified in 1108.2.3
1105.2 Crosswalks - Although the MUTCD allows 6 ft. wide crosswalks, the
proposed minimum width of 8 ft. has sound justification.
1105.3 Pedestrian Signal Phase Timing - This item is vaguely written, in that it
refers to “pedestrian signal phase timing”, which could be interpreted to mean
the WALK plus the flashing DON’T WALK intervals. The calculated flashing DON’T
WALK interval should be based on the appropriate walk speed of the location user
needs, and not be mandated as 3 ft. / second maximum, as proposed. Use of a
slower than necessary walk speed and including the ramp length in the crossing
distance have no merit, as both provisions add unnecessary vehicle delay, which
is a known factor in increased accident rates and negative motorist reactions.
1105.6 Roundabouts - Installation of pedestrian signals at crosswalks and
splitter lanes should be based on demonstrated need, not mandated as proposed.
There is no definition of “continuous physical barrier” required along sidewalk
where crossing is prohibited, and the provision would have significant impact on
locations where physical limitations make it advantageous for the sidewalk to
butt up to and follow the curb alignment.
1105.7 Turn Lanes at Intersections - This is a poorly conceived provision
because it does not specify at signalized intersections.
1106.2 Pedestrian Signal Devices - Installation of audible and vibrotactile
indications of the WALK interval should be required only where a demonstrated
need exists, rather than at every crosswalk with pedestrian signal indications,
1109 On-Street Parking - For consistency in the ADA Accessibility Code, the
dimensional requirement for a 96 in. wide access aisle needs to have the
exception provision for use of a 5 ft. wide access aisle if all spaces are a
“Universal Parking Design” specified in appendix A4.6.3 of the Guidelines for
Buildings and Facilities. In Florida, the required 12 ft. wide space and 5 ft.
wide access aisle meets the ADA universal design criteria. Again for
consistency, the required number of accessible on-street parking spaces should
not be mandated as one per block face, but rather be based on the same minimum
requirements as Buildings and Facilities, with additional spaces at locations of
These comments and suggestions should not be viewed as objections to the
concepts of providing reasonable access for persons with disabilities. Our
intent is to merely point out potential negative impact on both the users and
the providers of facilities within the public rights-of-way.
Robert Brotherton, P.E., Director
Public Works and Utilities
City of Dunedin