index
previous comment
next comment
|
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.