November 23, 2011Eileen FeldmanDirector, Community Access ProjectP.O. Box 434Somerville, MA 02143U.S. Access Board1331 F Street, NW, Suite 1000Washington D.C. 20004-1111Dear U.S. Access Board,I respectfully submit these comments on the Proposed Acessibility Guidelines forPedestrian Facilities in the Public Right-of-Way (Guidelines). Thank you for youexpertise and hard work to benefit persons with disabilities and also the public atlarge. These standards are vitally important to all people.At the present time, local and state governments, Traffic Engineers, Public WorksDepartments, and other entities that construct and alter streetscapes are not fullyaware of how to correctly construct pedestrian amenitites so that they facilitate thebroadest inclusion of all people. This is enormously wasteful of time, money andother resources; and creates impediments and lack of the most rudimentaryaccessibility necessities both now and in the future. Your work is vitally importantto the mission and values of safe, inclusive and sustainable communities.I hope these notes are helpful. I am ready to assist in whatever way may be useful.CHart was instrumental in assisting me in this effort.Eileen Feldman COMMENTS ON THE JULY 2011 PROPOSED RIGHT-OF-WAY GUIDELINES• For ease of use by non engineers, the guidelines should incorporate all relavant sections of AASHTO, MUTCD & ADAAG even if the document becomes much longer. Individual advocates, CILs and ped/bike organizations rarely have all these easily available.• In definition sections: please include pertinent MUTCD & AASHTO definitions for: full depth reconstruction, resurfacing, crosswalk, shoulder, etc.. In addition,
please clearly define elements such as plazas or other paved areas that may not fit fully within a common understanding of sidewalks.• Conventions and measurements should be expressed in inches, then engineering scale: 2.1 feet and finally in metric. The lack of inches makes the effective use of the document much harder.• The document treats existing street grades as unchangeable; whereas, during full depth reconstruction, grades and elevations can be changed- and often are. As such, language is needed to encourage creative designs whereby sidewalk slopes might become somewhat steeper along a certain distance to then provide a level landing for resting OR to provide improved access into a building. Stronger language relative to cross slope in R302.6, 304.5.3, R404.2, etc.is also necessary. If sidewalks are rebuilt, then the cross slopes should be minimized. The draft guidelines need to be strengthened in this area.• R201.1 Scope should include: shoulders along more rural roads; as well as privately owned roads that are common to large retail developments, colleges or retirement communities. By not covering these, there can be continued ambiguity for designers and pedestrians. Example: we get off the bus on a public road, then walk into a mixed-use mall site that has sidewalks that don’t conform to these guidelines-- or even have detectable warnings on curb ramps.• R202.3.1 Existing Physical Constraints seems exceptionally broad in its wording and invites continued poor behavior by DPWs nationwide.• R206 Street Crossings is missing language for audible warnings.• R212 Benches needs criteria requiring percentages of benches with arms and backs.
• R302.7.2. Surface Discontinuities needs language discouraging underground structures and bricks within the pedestrian access path.• In R304.5 language is needed to address the common issue of: poor design of roadway gutters and curb ramps transitions, both in terms of 8% ramps meeting roadway parabolas of 5%+- This is a common problems that makes it quite easy to tip forward out of a manual chair. Furthermore, the language should require curb ramp landings & footings to not pool water AND manholes, grates, etc should be prohibited from these surfaces as well as the ramp itself.• Signal timing wording of 3.5 ft/sec is a decent start ; however, this is only marginally helpful for older adults. Timing should be dropped to 3 ft/sec. The Traffic Engineering Handbook recommends 3 to 3.25 ft/sec. States such as Florida have recommended 2.5 ft/sec. The Access Board needs to take the lead here.• Accessible Pedestrian Signal- Technical criteria should refer to previous Access Board drafts rather than the vague wording of MUTC. Consistency is critical for best construction management practices..• R308 Transit Shelters - needs language added to discourage placement of shelters in the middle of sidewalks, thereby requiring peds to detour around the shelters. Language is needed to require perch/leaning rails and define benches in shelters. Language should also clearly state that when shelters and stops provide real time arrival information, the equipment must provide both audio and visual communication.• R308.1 Platforms & Vehicles: Please provide the appropriate 49 CFR text here instead of just referencing part 37 and 38.• R402 Protruding Objects needs to be revised to an 8 ft minimum height clearance to account for sagging of wet branches, awnings and wires.
• R408 Stairs: Is one riser a stair and if not, when are handrails required? Why is there no requirement for visual and cane detectable surface changes on stairs? The lack of these requirments has safety implications.