Mark L. Schoeffmann, P.E.
October 23, 2002
Village of Arlington Heights
To Whom It May Concern:
I am writing to express concern about several items in the proposed ADAAG for
public right-of-ways. I know the intent is to make public right-of-ways safer
for those with disabilities, but the safety of those without disabilities must
be considered at the same time. I believe several of the proposals will result
in the compromising of safety for the public in general and should only be used
when warranted by special conditions.
Comments on Proposed ADAAG for Public Right-of Way
1) Pedestrian Signal Phase Timing
A reduction in the required pedestrian walking speed to 3.0 feet per second will
have a significant impact on intersection capacity and safety on heavily
traveled roadways. The current practice in our area is to utilize 4.0 feet per
second and should only be adjusted when warranted for special circumstances, not
at all locations.
2) On-Street Parking
The requirement to provide at least one accessible parking space on each block
face is not appropriate to all situations. Why should accessible parking spaces
be provided on the street in areas where they are already provided in off-street
parking facilities? In densely developed commercial area, every on-street
parking space is important to the economic vitality of the area. The
availability of parking to the public at large would be impacted if the number
of accessible spaces exceed the need for accessible spaces.
In addition, the movement in and out of vehicles is safer in an off-street space
away from moving traffic.
3) Pedestrian Overpasses and Underpasses
The requirement to provide an elevator for any location that results in an
approach of over 60 inches will significantly increase the initial construction
cost, increase maintenance costs and decrease safety for these facilities. The
requirement to include two elevators with every pedestrian overpass or underpass
proposal will result in the delay or canceling of these types of projects due to
the high initial and long term maintenance costs. This will have a negative
impact on access and safety for all pedestrians who would benefit from the
overpass or underpass.
4) Accessible Pedestrian Signal Systems
The requirement for audible walk indicator tones and locator tones for
pedestrian signals will not be acceptable in residential areas. The constant
beeping of these devices will be extremely annoying to nearby property owners.
This requirement will result in the elimination of pedestrian signals at new
traffic signals and will decrease the safety for all pedestrians.
5) Detectable Warning Surfaces
The truncated domes proposed for new curb ramps will be difficult to construct
in the field. If these detectable surfaces are precast or available in plastic
tiles and must be embedded in fresh concrete, the concrete slabís integrity will
be compromised and this will lead to early deterioration. Snow removal
difficulty from the proposed warning surfaces can lead to icing and slippery
conditions, increasing the hazard to all pedestrians.
I believe that more research and investigation is necessary before these
guidelines are approved to determine under what circumstances they should be
Mark L. Schoeffmann, P.E.
Director of Engineering