Jeffrey S. Polenske, P.E.
|October 28, 2002|
Comments on the Draft Guidelines for Accessible Public Rights-of-Way
1) In Section 1101.3 Defined Terms the definition for Street Furniture is too broad, "elements.. .that are intended for use by pedestrians" could include handrails, benches, bus shelters, stairs, ramps, sidewalks, etc. The street furniture definition should define the way pedestrians will use these elements versus other elements such as sidewalks or curb ramps.
In addition, please include definitions for Alternate Circulation Path and Blended Transition in this section.
2) In Section 1102.2.2 Alterations, exceptions for compliance in making alterations in the right-of-way are allowed to be below the standard set by these guidelines if it is technically infeasible to fully comply. So, what does "technically infeasible" mean and who decides what is "technically infeasible"? Cost affects many, if not most, decisions made in City of Milwaukee street designs. Will cost be an allowable criterion when considering whether an alteration is "technically infeasible"? Perhaps the Access Board or some other entity should provide a guideline to provide a measure of when an alteration is "technically infeasible" and when partial compliance is allowed? Such a guideline may better help communities in making decisions about alterations.
3) Section 1102.14 On-Street Parking, as written, appears to call for one designated parking space per block face. Currently, the City of Milwaukee will install an accessible loading zone per request. Requiring a designated parking space on every block face will add a significant cost to the City and, in addition, may limit the City’s ability to be flexible in terms of installing accessible loading zones where they are most useful. Further comments on On-Street Parking can be found below.
4) Section 1102.3 Alternate Circulation Path Street construction zones are inherently dangerous even for able-bodied pedestrians. It is not unusual to have to close pedestrian access on one side of the street during construction. In such situations, it may be impossible to provide an Alternate Circulation Path on the same side of the street.
5) In Section 1103.3 Clear Width it is unclear if the clear width is referring to the width between the front of walk and the back of curb or if this is the minimum width of the sidewalk. Does this mean that sidewalk, especially in terms of new construction, can be built without any space between the back of curb and the front of walk?
6) In Section 1103.4 Cross Slope the entire pedestrian access route, including sidewalks, street crossings, and, in addition, other elements would only be allowed to have a cross slope of 1:48. It would be impossible to ensure that the pedestrian access route would meet this requirement as it crosses an intersection. Forcing a cross walk to have a cross slope no greater than 1:48 would, in many cases, create a shelf in an intersection that could be detrimental to vehicular traffic.
Another concern regarding cross slope of the pedestrian access route has to do with the inherent restriction against depressed driveways. The City of Milwaukee uses depressed driveways frequently to prevent damage to vehicles. Many of the suggestions made in the book Designing Sidewalks and Trails for Access, Part 2 for designing without the use of depressed driveways would not be feasible or practical in terms of future maintenance.
7) In Section 1104.2 Types Please define the term blended transition.
8) Section 1104 Curb Ramps and Blended Transitions Two separate curb ramps rather than a single ramp that opens diagonally into the intersection is recommended. However, State of Wisconsin statues dictate the placement of a diagonal ramp as the location of first choice; and the City of Milwaukee completed a costly multiyear initiative to comply with this directive. Without a source of additional funding, the replacement of the diagonal ramp with two parallel ramps would only be accomplished with street paving projects. As such, it could take decades before total conversion is complete.
In terms of semantics, in this section, the terms parallel and perpendicular should be more clearly defined as to the axis used to determine what is parallel or perpendicular.
9) In Section 1105.2.2 Cross Slope it would be impossible to ensure that the pedestrian access route would meet this requirement as it crosses an intersection. Forcing a cross walk to have a cross slope no greater than 1:48 would, in many cases, create a shelf in an intersection that could be detrimental to vehicular traffic.
10) Section 1105.3 Signal Phase Timing. Changing walking speed from the current 4.0 feet per second to 3.0 feet per second can have a significant impact. At intersections with considerable width for both the main and cross streets, it will be necessary to utilize longer cycle lengths in order to accommodate pedestrian clearance intervals. Longer cycle lengths increase delay and result in poor coordination with adjacent signals operating on different cycle lengths.
11) Section 1105.4 Medians and Pedestrian Refuge Islands. Requires median islands to be six feet or larger in width. Milwaukee has roadways with 4-foot wide medians and numerous small refuge islands that will not meet this criterion.
12) Section 1105.5.3 Pedestrian Overpasses and Underpasses The requirement of an elevator where ever the difference in grade between the approach and the overpasses or underpasses exceeds 60 inches could result in a less safe crossing for all pedestrians when jurisdictions elect to remove overpasses and/or underpasses in lieu of providing elevators that are costly to install and maintain.
13) Section 1105.6 Roundabouts. Roundabouts require pedestrians to select a safe gap in the traffic flow and motorists to yield the right of way, which can result in pedestrian accessibility problems. Roundabouts, however, are customarily installed in lieu of the traffic signal. We recommend that further study be undertaken on the safety of pedestrian movements in roundabouts prior to mandating that pedestrian activated signals be provided at each crosswalk in a roundabout and the placement of a continuous barrier along the street side of the sidewalk.
14) Section 1105.7 Turn Lanes at Intersections Right turn by-pass lanes at intersections are often controlled with either stop signs or yield signs. The proposed guidelines would mandate installation of pedestrian activated signals. We are unaware of any studies showing increased pedestrian injuries resulting from vehicle collisions at right turn bypass crossings that would warrant this installation.
15) Section 1106.2 Pedestrian Signal Devices. We have worked with the blind community in Milwaukee to provide audible pedestrian signals at locations adjacent to facilities that serve the blind and have higher numbers of visually impaired pedestrians crossing. The requirement to provide audible signals at every intersection seems excessive.
16) Section 1108.2.1 Curb Ramps and Blended Transitions outlines the requirement for the installation of a detectable warning surface at a curb ramp or a blended transition. Currently, truncated domes are considered to be the preference this type of surface. Truncated domes would pose problems for the City of Milwaukee on several fronts. There are serious concerns regarding increased difficulty in removing snow and ice because of the installation of truncated domes. In addition, maintenance of curb ramps with truncated domes is also of concern in that there is no information on how well the domes survive freeze/thaw cycles, salt from snow clearing operations, and the clearing of snow or ice from the curb ramp surface. Truncated domes would add a significant maintenance cost that the City of Milwaukee may not be able to meet. In addition, curb ramps with truncated domes that have broken or chipped off the sidewalk surface, may pose a safety hazard themselves.
17) Section 1109 On-Street Parking. Wisconsin state statutes permit a vehicle with handicap plates and/or placard to be parked in any legal parking space in excess of the posted time limit and without payment of any meter fee. The draft guidelines would require at least one accessible parking space on each block face. An access aisle at least five feet in width that does not encroach into the vehicular travel lane shall be provided to serve the space. Wherever the sidewalk width is greater than 14 feet, the accessible parking space would be created by indenting the curb line to create a parking stall that is five feet wider. With the exception of government buildings and medical facilities, we have not installed on-street handicapped spaces, access aisles were provided for angle parking but not for parallel parking. Indenting the curb to provide an access aisle will create drainage problems and snowplowing difficulties. Requiring one accessible parking space per block face seems excessive, particularly in residential neighborhoods. In lieu of a handicap parking space, the City of Milwaukee has traditionally provided handicap-loading zones to qualified handicapped individuals in residential areas. This practice has worked well and has avoided the conflict between handicapped and non-handicapped residents seeking scarce on-street parking.
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