This letter provides comments on the proposed accessibility guidelines for pedestrian facilities in the public right-of-way. It notes that the guidelines are vitally important for inclusive communities but that local governments are not fully aware of how to correctly construct pedestrian amenities. The comments recommend strengthening the guidelines in several areas, such as requiring clearer language and measurements, addressing slopes and cross slopes during reconstruction, expanding the scope, and improving requirements for issues like curb ramps, signal timing, and protruding objects. The letter offers to provide any further assistance.

1. November 23, 2011
Eileen Feldman
Director, Community Access Project
P.O. Box 434
Somerville, MA 02143
U.S. Access Board
1331 F Street, NW, Suite 1000
Washington D.C. 20004-1111
Dear U.S. Access Board,
I respectfully submit these comments on the Proposed Acessibility Guidelines for
Pedestrian Facilities in the Public Right-of-Way (Guidelines). Thank you for you
expertise and hard work to benefit persons with disabilities and also the public at
large. These standards are vitally important to all people.
At the present time, local and state governments, Traffic Engineers, Public Works
Departments, and other entities that construct and alter streetscapes are not fully
aware of how to correctly construct pedestrian amenitites so that they facilitate the
broadest inclusion of all people. This is enormously wasteful of time, money and
other resources; and creates impediments and lack of the most rudimentary
accessibility necessities both now and in the future. Your work is vitally important
to 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,

2. 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.

3. • 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.

4. • 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.