|October 25, 2002|
1105.3 Pedestrian Signal Phase Timing
The requirements of 3 feet per second as the maximum walking time and increasing the distance to include ramp lengths have the potential for significant 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. However, to mandate increased crossing time when there is not a demonstrated need will cause unnecessary vehicle delay, which can be directly related to increased accidents at intersections as well as amplified driver frustration. This mandate clearly needs to be linked to a demonstrated need for each individual intersection. Our recommendation would be to require jurisdictions to develop pedestrian clearance timing in concert with the disabled community, based on the specific requirements of the specific location.
In 1105.4 the width of the median island is not specified. We would assume it to be 48", however, the discussion contained in the crosswalk width section could lead one to assume the minimum width should be 96". This should be clarified.
1105.5 Pedestrian Overpasses and Underpasses
The requirement to install an elevator or limited-use elevator for applications where the rise of a ramped approach exceeds 60 inches, will also have unintended consequences. Since this is a discretionary structure and there are very few areas that will have a ramped approach of less than 60" a jurisdiction will, in many cases, forgo the installation of the overpass rather than come up with the significant additional funds to construct and maintain an elevator. Also, this requirement is not practical and can be dangerous for the public. An unsupervised elevator if they become disabled would be a dangerous situation for the passengers. This does not address the construction or maintenance costs of those elevators, along with the public liability of crimes against the public in an unsupervised enclosed area. The homeless population will use the elevators at night and possibly during the day. Some overpasses are located away from populated areas, and bringing electric power to those locations would be an unreasonable cost. This would be a bad regulation and violation of the public trust. Our recommendation would be to have "resting platforms" at appropriate intervals, like other ramps.
The requirements proposed in this section are not consistent with accessible pedestrian considerations in other areas. There will also be unintended consequences associated with these requirements if implemented.
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 required. The positive guidance approach is the best way to handle the concern of pedestrians wandering through the center of the roundabout. As shown in the discussion page picture, sidewalks and ramp locations can better address pedestrian channelization than ugly, hard to maintain, hazardous barriers. Also, as a matter of consistency, if barriers are required here they should also be required at all "high-design" intersections and even in mid-block locations to prohibit pedestrian crossings.
In 1105.6.2 the requirement for signalization on every leg of a roundabout defeats the original purpose of the roundabout concept. Thousands of low-volume, neighborhood roundabouts are being built, many as traffic calming devices. To require signals on every leg is tremendously cost prohibitive and does not ensure additional safety benefits. An unintended consequence may be an explosion of drivers pushing the red light and disrespect for these signals specifically and all signals generally if numerous unwarranted signals are installed where drivers perceive they are being stopped unnecessarily. A fundamental concept for roundabout crosswalks is the designer must treat each crossing as a mid-block crosswalk, both in theory and in design. The access board discussion states, "Because crossing at a roundabout requires a pedestrian to visually select a safe gap between cars that may not stop, accessibility has been problematic." However, this same problem exists at every mid-block crosswalk! If there is a mandate to require signals here then the argument could be made that every crosswalk everywhere should be signalized. Obviously, this is a preposterous argument, but that is why we use engineering criteria and judgment – so that a rational balance of perspectives is maintained. Again, the user community has the ear of jurisdictions and specific needs for each crossing can easily be accommodated without the imposition of a far-reaching, harsh standard.
1105.7 Turn Lanes at Intersections
There are literally thousands of existing "slip" lanes at non-signalized intersections and this design is continuing to be built. The imposition of this requirement would essentially eliminate slip lane design for non-signalized intersections. This would have the unintended consequence of increased congestion, which would also increase intersection accidents. We believe a better solution would be to require jurisdictions, in consultation with the disabled community, to evaluate the signalization of slip lanes at signalized intersections.
1106 Accessible Pedestrian Signal Systems
We generally agree with the proposal to require pedestrian signal devices that provide better information and guidance for the pedestrian, even though there will be a slight increase in installation costs. However, there is a precision to the location dimensions that many times simply cannot be met. The "location" wording should be changed to communicate the concept as a guidance statement without making it a mandate.
In 1106.4 the one area we would object to is the requirement "…of tactile and visual signs on the face of the device or its housing or mounting indicating crosswalk direction and the name of the street…". Tactile street name signs are not required at any other location and to require them on pedestrian crossing hardware changes these devices from "off the shelf" equipment to custom devices. This makes them almost impossible to effectively maintain.
1109 On-Street Parking
The majority of streets being built in the County of San Diego each year are in typical residential neighborhoods. To require an indented, signed, handicap space on every residential block is surely not what the committee intended. We would suspect the concern is associated only with areas where there are parking meters or time limited parking, such as in business areas. Our recommendation would be to require such handicap spaces only in business or commercial areas.
In 1109.2 Parallel Parking Spaces – the requirement to provide a 60" access aisle is extremely burdensome and will have significant unintended consequences that will restrict our ability to help the disabled community. Currently we install handicap signs in both residential and business areas quickly and easily to accommodate individual and varying requests. The five-foot indent is simply out of character in residential neighborhoods. With this requirement we will be unable to continue our policy of "immediately taking care of the disabled community." In the future in order to install a handicap space we will have to propose a capital project to construct a five ft. indent aisle. This means projects will have to compete with other county projects for very limited funds and, even if funded, would have large time delays before completion. It also means we would be unable to respond to changing needs by moving a handicap space slightly. It is amazing how many times we change sign locations. Our recommendation would be to eliminate this requirement. It does not serve the best long-term interests of the disabled community. In addition, the 5’ minimum height of handicap signs is in violation of the minimum requirements of the MUTCD.
Passenger Loading Zones
The discussion text states a 5’ access aisle is required for each passenger loading zone (PLZ). Again, as stated above in the handicap signing discussion, this has the effect of limiting our ability to quickly install PLZ signing and if these requirements are adopted we will not be able to install PLZ signs in the accommodating manner that we have historically done. Access aisles adjacent to PLZ zones should be eliminated as a mandated construction requirement.
1110 Call Boxes
The requirement to provide a motor vehicle turnout with a minimum paved area 16 feet wide by 23 feet long, connecting to a turning space at each call box, is not feasible. The requirement to provide teletypewriters (TYYs) at each call box for the deaf is also not feasible.
1111 Alternate Circulation Path
The requirement to provide an alternate path is generally correct. However, the requirement of a path only on the same side of the street, with no provision for "reasonableness", is not feasible in many instances. Many times the scope of construction is such that no pedestrians can be accommodated and, in fact, the forcing of pedestrians into this type of area may create an intolerable safety hazard. Simply put, 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. The guideline for requiring alternate circulation paths should be a recommendation and not a requirement.
In 1111.6 the requirement of a lower rail within 1 ˝" of the surface does not make sense since railings only require a rail at 27" for detectability. The restriction of non-flexible fencing material would appear to be an unnecessary restriction. Plastic fencing products are now extremely strong, durable and easy to install and would appear to accommodate the need to provide pedestrian channelization and protection in a reasonable manner. The allowance of this material would make it much easier for jurisdictions to require protection in very short-term construction areas.
The above comments and suggestions should not be viewed as objections to the concept of providing reasonable access for the disabled community. We, in the County of San Diego, have historically been and continue to be in support of reasonable accommodations within the right-of-way. We have been seeking direction for uniformity of devices and installation practices for years. Our desire is to communicate potential pit-falls and unintended consequences associated with several of the proposed standards and our plea is for balance in the regulations. Should you have any questions or need further clarification on any of our comments, please contact Julie Davis, County of San Diego, Department of Public Works, ADA Coordinator, at [...].
DOUGLAS ISBELL, Deputy Director
Department of Public Works
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