October 28, 2002
To Whom it May Concern:
I have reviewed the draft guidelines as well as many of the comments on the
report that are shown on your web site. In general, I would like to note that I
concur with the comments provided by Mr. Daniel Centa from Pueblo Colorado on
August 21, 2002. Beyond this, I offer the following comments as a caution to
help prevent unintended consequences of these new guidelines. Thank you for the
opportunity to provide comments.
1101.3 Defined Terms - Section 1102 of the guidelines requires that additions
and alterations to right-of-way shall comply with the guidelines. However, there
is no definition of an alteration. The comments provided by the Committee
indicates that their intent is for compliance to be "prorated" based on the
extent of the work planned. Perhaps and actual definition of alteration in the
definitions section and some illustrative examples would be helpful in
management/implementation of these guidelines. For instance, if 2 sidewalk slabs
are being replaced on an existing 36" sidewalk to alleviate a trip hazard, will
we be required to pour the new section of sidewalk at 48" or would we only take
this extra measure if we were replacing sidewalk along the entire block? Without
specific guidance I see many communities continuing to defer maintenance of
sidewalk for fear of their limited resources being drawn further away from
roadway, stormsewer and other infrastructure needs.
1102 Scoping Requirements - In its comments on the scoping requirements, the
Committee stated that communities will be required to acquire additional
right-of-way where "practicable" in order to ensure compliance with the
guidelines in alteration projects. Mr. Centa's comments are that this could have
a "chilling" effect on projects because local policymakers are often unwilling
to exercise imminent domain. I concur.
1102.14 & 1109 On Street Parking - The proposed rules states "Where on-street
parking is provided, at least on accessible on-street parking space shall be
located on each block face and shall comply with 1109." I strongly concur with
Mr. Centa's comments that this matter wasn't sufficiently thought out. This
requirement should only be applied to business or commercial areas and there is
no allowance for the fact that the size of block faces can vary significantly
from one community to another. Application of this requirement to existing
residential areas would be very problematic and costly. Application of this
requirement to new residential roadway construction is certainly more feasible
but would reduce the flexibility a community has to changing needs for handicap
parking needs in a neighborhood (i.e., the ability to move a handicap space by
moving signage alone).
1105 Pedestrian Crossings - This section would increase crosswalk width from the
MUTCD minimum of 6' to 8'. Mr. Centa notes that this may not require a major
expenditure of funds to change but that we would be merely increasing the
mythical "magic zone of protection." This will also cause there to be less
visibility for turns at intersections for those drivers who actually do stop at
the stop bar potentially increasing traffic collisions.
1105.6 Roundabouts - Our community hasn't yet followed the trend towards using
roundabouts as a traffic calming method. However, the requirement to install
signals at all crosswalks within a roundabout and the requirement to build
barriers may cause this option to become less attractive to many communities.
1108 Detectable Warning Surfaces - The rule states that there must be a
detectable warning surface on handicap ramps. While this may aid with increasing
safety of visually impaired persons it may cause a significant number of
injuries under ice and snow conditions because snow removal becomes problematic.
Public Works Division Manager
City of O'Fallon, Illinois