Lloyd E. Neal, P.E.
October 17, 2002
RE: Draft Public Rights-of-Way Accessibility Guidelines
Dear Mr. Windley:
The City of Plano has assembled a group of city planners, traffic engineers,
civil engineers and public works officials to review the Draft Public
Right-of-Way Guidelines proposed by the Access Board. The City fully supports
the goal of increased accessibility and has spent many capital improvement
dollars retrofitting curb ramps and sidewalks to make the city streets as
accessible as possible. However, we do have concerns about the application and
practicality of some of the proposed standards, and offer the following comments
and suggestions for consideration:
1101 Application and Administration
1101.3 Defined Terms
Curb Line – this definition assumes that the sidewalk, if there is a sidewalk,
is always adjacent to the curb. This is not the case in most suburban and
Element & Facility – The definition of “element” includes the term “facility”
and the definition of “facility” includes the term “element.” Therefore, these
appear to be circular references with no clear definition. Traffic control signs
(and their supports) and traffic signals (and their supports) are located in
public right-of-way. Is it intended that they be included in the definition of
element, facility, or both?
Sidewalk – In some cases, sidewalks may be in easements on private property
instead of in public right-of-way or they may meander between easements on
private property and the adjacent public right-of-way.
Street Furniture – the “elements in the public right-of-way that are intended
for use by pedestrians” definition is too general. The sidewalk is in the public
right-of-way and is intended for use by pedestrians, but it should not be
considered street furniture. Street name signs and traffic signals are located
within the public right-of-way and are intended for use by pedestrians (as well
as drivers). These also should not be considered street furniture. A specific
definition of those things specifically considered street furniture should be
Walk Interval – this definition should be modified to read as follows: “That
phase of a traffic signal cycle during which the pedestrian is to begin
crossing, typically indicated by a WALK message or the walking person symbol
and, where provided, its audible equivalent.
1102 Scoping Requirements
1102.2.1 Additions & 1102.2.2 Alterations
It appears that the proposed wording of these sections would require the
installation of audible pedestrian signals and audible/vibrotactile pedestrian
detector buttons/poles for any new traffic signal installation and for
modifications to existing traffic signals. See later comments for 1106
concerning pedestrian signals.
1102.3 Alternate Circulation Path
Sidewalk repairs often involve numerous locations along a block, but only a few
short sections of walk may be removed and for only a short period of time. This
would result in several separate alternative paths being created and maintained
in the same block, and in many instances, the alternate circulation path would
place pedestrians immediately adjacent to fast-moving traffic lanes on major
arterial streets. We suggest that if sidewalks are available on both sides of
the street, the sidewalk on the opposite side of the street should be permitted
as an alternate circulation path.
1102.5.2 Post Mounted Objects
For right-of-way areas near traffic signal controlled intersections, this
section needs to permit the installation of the traffic signal control cabinet
on a post. Although some controller cabinets are ground mounted, many in a CBD
area are post mounted. These are likely to be mounted with the bottom higher
than 27 inches and the top lower than 80 inches.
1102.14 On-Street Parking
Outside of downtowns or high-density mixed-use districts, individual parking
spaces are not typically marked, especially on residential streets. The proposed
wording does not distinguish between locations where on-street parking is
provided with marked parking spaces versus locations where on-street parking is
provided but there are no marked spaces. It is not clear whether or not this
requirement is intended to apply to blocks with unmarked spaces. This situation
is typical in residential subdivisions where parking is permitted on the street
but no specific parking spaces are marked. Under these conditions, the provision
of a marked on-street accessible parking space should not be required. Cities
should have the option to respond to individual requests for parking, so that
spaces are placed in a location most convenient to disabled residents.
1104 Curb Ramps and Blended Transitions
The prohibition of access covers and other appurtenances on curb ramps,
landings, blended transitions, and gutter areas within the pedestrian access
route may discourage the installation of additional sidewalks in some cases. If
this prohibition includes traffic signal pull boxes and a traffic signal
currently exists at a location proposed for new sidewalk installation,
relocating existing pull boxes out of the prohibited areas can be both costly
and disruptive. Since pull boxes are used to connect conduits, route the control
cables around the intersection, and connect vehicle loops to the detector
cables, the relocation of a pull box also requires modifications to the
underground conduit and either replacing or splicing the cables. During the
cable work, the traffic signal will likely have to be operated in either
flashing mode or turned off depending on the cables involved. Similar extensive
underground work would be required where various access covers exist for other
underground items such a telephone or communications cables, sanitary or storm
sewers, or other utility items.
If the access cover is made flush with the surrounding walkway area, it should
be permitted to be in these areas. When faced with a decision to undertake such
a degree of work on an existing signal or utility facility to accommodate the
installation of a sidewalk, many agencies may choose to not install the
sidewalk. When new traffic signal and utility facilities are being installed,
the design can typically locate the access covers outside the curb ramp,
landing, blended transition, and gutter areas. However, relocating existing
items involves extensive work and expense.
Are traffic signal, utility, street light, and other such poles intended to be
included in this prohibition? The use of the work “appurtenances” in the list of
prohibited items could be interpreted to include these. As with the access
covers, the relocation of these can be both costly and disruptive. Also,
underground and overhead utility lines often influence or control the location
of these poles. Existing poles should be permitted to remain. New poles should
be recommended to be located outside these areas but flexibility needs to exist
for cases where the placement of the pole is controlled by existing underground
and overhead utilities.
1105 Pedestrian Crossings
1105.3 Pedestrian Signal Phase Timing
Jurisdictions should be allowed to determine the necessity for the slower
pedestrian walk speed, based on surrounding land uses and on the needs of
individuals in the area. A requirement to use a maximum of 3.0 feet per second
and include the lengths of the curbs ramps also will have a significant impact
on the traffic signal timing at most intersections. This is a significant change
from the existing Manual on Uniform Traffic Control Devices (MUTCD) guidance of
4.0 feet per second walking speed calculated only from the curb to the middle of
the farthest traveled lane. The 2002 proposed MUTCD changes to the pedestrian
clearance time only changed the calculation to include the entire street width.
No change was included in the assumed walking speed. Traffic engineers are free
to use walking speeds slower than the 4.0 feet per second listed as guidance in
the MUTCD and often do so where conditions warrant. However, making an across
the board change from 4.0 feet per second to 3.0 feet per second in the
calculated walking speed, add the additional length of the ramp on each end of
the crosswalk, and make it a requirement rather than guidance will require
retiming of many traffic signals. This will have a significant impact where
signals are operating in a coordinated system as all signals in a system may
have to be retimed to maintain a common cycle length needed for progressive
traffic flow. Increased vehicle delay and congestion resulting from longer
pedestrian clearance timing and longer overall cycle lengths will have a
negative impact on air quality.
1105.4 Medians and Pedestrian Refuge Islands
The proposed wording “medians and refuge islands in crosswalks” is good in that
this section and its subsections would not be applied to medians that are not in
crosswalks. In order to avoid possible confusion about a minimum 6 foot wide
median requirement, a statement should be added indicating that medians less
than 6 feet wide are acceptable as long as they are not in a crosswalk or used
for pedestrian refuge. Medians adjacent to left turn bays in urban areas are
often as narrow as 4 feet from face-to-face of curb.
The requirement to provide a continuous barrier along the street side of the
sidewalk where pedestrian crossing is prohibited is excessive. This requirement
applies whether or not operational experience indicates a problem with crossings
at inappropriate locations. Crossing at mid-block locations or at intersections
where crossings are prohibited by signs may also be dangerous to pedestrians.
However, physical barriers are not proposed to be required at these locations.
If it is desired to treat prohibited pedestrian crossing areas at roundabouts
differently than at other locations, the proposed wording should be in the form
of guidance or option rather than an across the board requirement.
The proposed wording requires the installation of a traffic signal for each
crosswalk at a roundabout. This requirement is made without the benefit of any
engineering study of traffic operations or level of pedestrian activity at the
location. Visibility of the traffic signal to drivers approaching the roundabout
should be similar to other traffic signals. However, drivers exiting the
roundabout will have greater difficulty in seeing and responding to the traffic
signal since they will be negotiating around the roundabout as they approach.
They will not be able to view the signal indications from as great a distance as
drivers on a straight approach. Additionally, traffic may back up around the
roundabout while stopped for a red signal at the pedestrian crosswalk signal
when departing the roundabout. In the event there is more than one crosswalk at
the roundabout, it may be necessary to limit when the crosswalk signals can
respond to a pedestrian call to avoid congestion if separate crosswalk signals
served pedestrian demand consecutively.
1105.7 Turn Lanes at Intersections
The proposed requirement to provide a pedestrian activated traffic signal where
pedestrian crosswalks are provided at right or left turn slip lanes is
excessive. First, there should not be a requirement to install a traffic signal
at an intersection simply because a crosswalk crosses a left or right turn slip
lane. The proposed wording will require signal installation even if the
intersection is operating well without a traffic signal. As in 1105.6.2, the
signal installation requirement is not based on an engineering study of actual
operating conditions at the location. Second, even if there is a traffic signal
at the intersection, there should not be an automatic requirement to control the
pedestrian crossing movement across a left or right turn slip lane. This
requirement would force the turning movement to be controlled by a signal
indication rather that the Yield or Stop signs that are commonly used in such
cases. During the green signal indication for the adjacent through movement,
using signal control for the turning movement has little or no impact whether a
Stop or Yield sign has previously been used. The replacement of a Stop sign with
a signal indication may lead to a slight operational improvement, at least
during the time the signal is green, as the vehicles would no longer have to
come to a stop before proceeding. However, the replacement of a Yield sign with
a signal indication would have a significant impact. While the signal indication
was red, vehicles would be required to come to a complete stop before making the
permitted turning movement versus simply slowing to yield with the previous
Yield control. The proposed control of turning movements in slip lanes should be
modified to list signal control as an option but not as a requirement.
1106 Accessible Pedestrian Signal Systems
1106.2 Pedestrian Signal Devices
The proposed wording requires that all crosswalks with pedestrian signal
indications have both audible and vibrotactile indications for the WALK
interval. Audible signals at intersections in neighborhood settings, even those
with volumes that respond to ambient noise, may annoy nearby residents at night
when background noise levels are not high enough to dampen the sound. Audible
signals should be activated only on a demand basis. Additionally, the
installation of audible and vibrotactile indications of the WALK interval should
not be required under all conditions. Rather, specific conditions requiring such
devices could be listed but their use at other locations should be optional.
Typically, the standard pedestrian signal devices (pedestrian heads and
pedestrian push buttons) serving both crosswalks will be located on one pole at
that corner. The requirement that accessible pedestrian signal devices be
separated by a minimum of 120 inches will preclude this type of placement and
will result in at least one additional pole being installed on the corner.
Whereas the MUTCD currently recommends that accessible pedestrian detectors and
vibrotactile WALK indications be located at least 10 feet apart, this is not a
requirement. This proposal makes this a requirement and adds the location of the
audible WALK indications to this separation requirement. This section should be
revised to provide recommendations rather than requirements.
1106.3 Pedestrian Pushbuttons
1106.3.2 Locator Tone
The proposed wording requires every pushbutton to be equipped with a locator
tone. Whereas the audible WALK indication tone would only operate during the
WALK periods, the push button locator tone is required to operate during the
DON’T WALK and flashing DON’T WALK intervals. In residential settings or where
the WALK interval is served only upon demand, the continuous operation of the
detector locator tone may lead to complaints.
1106.4 Directional Information Signs
Revised wording is needed for this section. The existing wording of “pedestrian
signal devices shall provide tactile and visual signs on the face of the device
or its housing or mounting indicating crosswalk direction and the name of the
street containing the crosswalk served by the pedestrian signal” implies that
each of the pedestrian signal devices must have these signs. This requirement
should not be applied to typical WALK/DON’T WALK pedestrian signal heads. If
required, the tactile and visual signs should be provided as part of the push
button assembly or adjacent to the pushbutton assembly.
This proposed wording adds a requirement for the street names that is not
otherwise required. There would be no street name information provided at an
intersection that was not controlled by a traffic signal. The requirement to
include the street name means unique signs must be installed for each corner
with pedestrian signal devices. The provision of an arrow indicating the
direction of the controlled crosswalk without the street name included would
permit the use of the same device at multiple locations.
1109 On-Street Parking
It should be specified that this applies to accessible parking spaces and not
all parking spaces. Otherwise, it could be interpreted that an access aisle is
required adjacent to every parking space.
1109.2 Parallel Parking Spaces
The exception for when an access aisle is not required appears to assume there
is a paved sidewalk. In some residential and other areas, paved sidewalks are
not provided. Also, the proposed wording permits the exclusion “where the width
of the sidewalk between the extension of the normal curb and the boundary of the
public right-of-way is less than 14 feet.” This wording seems to apply only to
cases where the entire area from the curb to the right-of-way is a paved
sidewalk. Is this exception actually intended to apply in any case where there
is less than 14 feet from the curb to the right-of-way line?
1109.3 Perpendicular or Angled Parking Spaces
Is a separate access aisle required for each parking space or can a single
access aisle between two spaces serve both spaces? It is noted that there is no
requirement on whether the access aisle is on the right side or left side of the
parking space. It seems that a single aisle between two adjacent spaces would
provide the needed access to the parking spaces.
1111 Alternate Circulation Path
The requirement that the alternate circulation path parallel the disrupted
pedestrian access route and be on the same side of the street is impractical in
many cases. If sidewalks in a residential area are being repaired or if utility
work has caused the sidewalk to be closed, the right-of-way is often too narrow
to provide the required 3-foot wide alternate path on the same side of the
street. An alternate circulation path using the opposite side of the street may
be the only practical choice. If faced with the alternatives of an unpaved path
on the same side of the street or an existing paved sidewalk on the opposite
side of the street, the paved sidewalk provides a superior option even if it is
across the street.
It is noted that there does not seem to be a requirement that the alternate
circulation path be paved. In fact, it would be impractical to include such a
requirement for many cases. Repair of damaged sidewalk sections in residential
areas may be completed in a couple of days. If the construction of a paved
alternative path on the same side of the street were required, both the overall
time and cost would increase.
Although the document title indicates it contains guidelines, the proposed
wording actually establishes requirements rather than guidelines in many cases.
It also includes several items that address the installation and/or operation of
various traffic control devices. Since the MUTCD provides the standards,
guidance, options, and support information for traffic control devices, any
proposed additions or changes to the standards, guidance, options, or support
information should also be reflected in the MUTCD.
Thank you for the opportunity for the city to comment on these proposals. If you
have any questions or need additional information, please feel free to contact
Ronnie Bell, Senior Traffic Engineer at [...].
Lloyd E. Neal, P.E.
Transportation Engineering Manager
City of Plano