October 28, 2002
The following comments are from Montgomery County, Maryland's Department of
Public Works and Transportation
While we agree with the need to make the pedestrian environment within the
public right-of-way more accessible, there may be significant unintended
consequences with many of the suggestions coming from the draft guidelines
proposed by the Access Board. We believe some of the requirements are so
restrictive and costly that many potential pedestrian improvements will be
passed over rather than attempting to comply with the draft guidelines.
Many of the potential concerns and comments are listed below:
1101.3 Defined terms-The definition of "blended transitions" should be included.
The proposed definition of "street furniture" is overly broad.
1102 Scoping Requirements-There appears to be areas of easy misinterpretation
that would require compliance on what may be ordinarily considered maintenance
projects. The requirement to acquire right-of-way where "practical" may force an
otherwise beneficial but small project to be postponed indefinitely.
In 1102.6-There is a conflict in the requirement to have the ramp located within
the width of each crosswalk and the desire of the advisory committee to
discourage single ramp installations when there are not marked crosswalks and
48" sidewalks are attached to the back of the curb head. The "unmarked
crosswalk" definition, clarifying that a crosswalk is the extension of the
sidewalk lines, means that only a single combined ramp could be constructed for
the ramps to be located within the unmarked crosswalks.
1103 Pedestrian Access Route-It is unclear how to interpret the meaning of
"changes in level shall be separated by 30 inches minimum"
1104 Curb Ramps and Blended Transitions-The wording seems to imply that ramps
can only be parallel or perpendicular. Many times crosswalks are skewed and the
allowance of a ramp parallel to the crosswalk (but not perpendicular to the
road) might provide better direction.
1188.8.131.52-It is unclear what a "barrier" entails.
1105.2.1 There is no justification as to why the 6 ft width crosswalks allowed
by the MUTCD should be eliminated. While this is not commonly used, a 6 ft width
does not decrease any benefit to any class of pedestrian.
1105.3 Pedestrian signal phase-The requirement of 3 feet per second as the
maximum walking time and increasing the distance to include ramp lengths are
both ill conceived and have the potential for unintended consequences. Most
jurisdictions are now timing pedestrian clearance intervals based on the
character of the intersection. Usually, if there is a demonstrated need for
longer clearance times, the jurisdiction will accommodate that need. To
compensate for the inefficiencies and resulting congestion potential, it will
force the use of longer cycle lengths and delays to pedestrians wishing to also
use the intersection. This will encourage pedestrians to ignore the pedestrian
signals, cross at unsafe times and result in more pedestrian/vehicle conflicts.
This phenomenon would be especially true during the off-peak hours when it is
more common to use shorter cycle lengths.
1105.6 Roundabouts-The requirements proposed in this section are ill conceived.
There will be unintended consequences associated with these requirements if
implemented. This section would eliminate a roundabout from consideration in
favor of a full traffic signal even if the roundabout would reduce accidents.
All benefits of a roundabout, including traffic calming, would be negated
because of the potential for increased rear end accidents. It seems unwise that
the Access Board would choose to retain higher speeds rather than a reasonable
consideration of the proven benefits of roundabouts.
In 1105.6.1 the requirement to install a continuous barrier is not consistent
with other applications where pedestrians are prohibited, yet barriers are not
1105.7 Turn Lanes at intersections-This requirement would result in the
elimination of most slip ramps and channelizing islands. Increased congestion
and accidents would occur and the distance and number of lanes that a pedestrian
must cross in a single pass would increase. This is a poorly conceived idea.
1111 Alternate circulation path-There are situations where pedestrians cannot or
should not be accommodated and must be moved to the opposite side of the street
or, in the case of total street closures, moved around an entire block.
Thank you for the opportunity to comment. Comments on the draft guidelines for
on street parking are being sent under separate cover.