Gregory J. Rosine
October 22, 2002
STATE OF MICHIGAN
DEPARTMENT OF TRANSPORTATION
In response to the U.S. Access Board’s request for public review and comments on
the Draft Guidelines for Accessible Public Rights-of-Way, the Michigan
Department of Transportation (MDOT) asks for consideration of the following
1. What discussion has the board had regarding the issues of disabled persons
with artificial lower limbs? They have difficulties with uneven surfaces. The
truncated domes (Section 1104.3.2) could catch their prosthetic limbs causing
them to trip or become unbalanced.
2. We are concerned that snow and ice build-up between truncated domes will
cause slip and fall accidents. Snow removal by brooming would probably work
best; however, not all local agencies are equipped for it.
3. MDOT supports the suggestion that detectable warnings be required only where
the ramp slope is 1:15 or less. The suggestion should be researched since not
all organizations representing the blind are in agreement that detectable
warnings are needed. It would seem that at some point, the degree of incline
would serve as much a non-visual cue as the presence of truncated domes.
4. Some terms used in the draft, such as, “alteration,” “practicable,” and
“technically feasible,” are left open to a wide range of interpretation.
Application and enforcement will vary from state to state. Definitions need to
be clearer and guidelines provided. Misinterpretations can result in unnecessary
right of way expense. Also, a definition of the term “blended” transition would
5. Americans with Disabilities Act Accessibility Guidelines (ADAAG) (Section
1104.3.6) limit the counter slope of the gutter area or street at the foot of
the curb ramp to 1:20 maximum (5 percent). Standard gutter cross slopes are 5
percent to 8 percent for hydraulic capacity (American Association of State
Highway and Transportation Officials “A Policy on Geometric Design of Highways
and Streets” page 325).
6. Section 1105.6.1 requires continuous barrier along the sidewalk at
roundabouts. This introduces an unwarranted roadside object exposed to traffic,
It could trap a blind pedestrian that may be misdirected within the roundabout.
It also would generate objections from local communities wishing to preserve
some degree of aesthetic value in the roundabout.
7. Section 1105.6.2 requires pedestrian activated signals at roundabouts. This
defeats the purpose of roundabouts which is to provide continuous flow.
8. The increase in crosswalk widths from 72 inches to 96 inches (Section
1105.2.1) could cause hardships, especially for local agencies. The 96 inch
width may be excessive in areas where pedestrian traffic is low. The width
should be determined based on engineering judgment to fit traffic conditions and
the needs of the community.
9. The reduction of walking speed to 3.0 feet per second (Section 1105.03) for
calculating pedestrian signal phase timing could result in the need for more
pedestrian activated signals where longer crossing time is needed. Otherwise,
unnecessary delays can result at intersections.
10. Revision 2 of the 2000 Manual of Uniform Traffic Control Devices (MUTCD)
Millennium Edition dated May 21, 2002, still states in Section 4E.01 that
“Engineering judgment should determine the need for separate pedestrian signal
heads (Section 4D.03) and accessible pedestrian signals (Section 4E.06).” The
draft ADAAG requires use of accessible pedestrian signals without evaluating
site specific needs (Section 1105.3). We feel that it would be a more efficient
use of public funds to provide accessible pedestrian signals where needed. Need
should be based on engineering evaluation and public interest.
11. We object to the advisory committee’s recommendation (Section 1105.5) that a
60 inch elevation change be used as a trigger for the requirement to install
elevators. The construction and maintenance expense could render the option of
pedestrian overpass structures infeasible in many cases.
12. The new cross slope limit of 1:48 (Section 1105.2.2) will be difficult at
best in hilly terrain. This creates “tabled” sections at intersections on an
otherwise uniform grade. Engineering judgment is needed in these situations to
design a roadway profile that is safe for vehicle passengers and pedestrians,
while providing the minimum possible cross slope for wheel chairs to traverse.
13. Section 1111 “Alternate Circulation Path” conflicts with Part 6 of the MUTCD.
We feel that the MUTCD addresses the issue more comprehensively. The draft ADAAG
does not consider the potential safety impacts when the alternate circulation
path is located on the same side as the construction activity. Again, some
judgment is needed in determining feasibility and practicality when locating the
14. Many changes in the draft ADAAG conflict with standards and guidelines
currently provided in the MUTCD. The discussion section indicates that the
Federal Highway Administration is in the process of updating the MUTCD. Like the
draft ADAAG, the MUTCD is part of the Federal Register and includes federally
mandated standards. The transportation community would more likely follow the
MUTCD when a conflict arises.
We support the efforts of the U.S. Access Board and the Federal Highway
Administration in ensuring and regulating reasonable pedestrian access for
disabled Americans. We also appreciate the opportunity to offer input in the
federal rule making process.
Questions regarding these comments can be addressed to Carlos Libiran, Design
Standards Engineer, at[...].
Gregory J. Rosine