Lawrence T. Hagen, P.E., PTOE

October 22, 2002

As a general comment, too much of the guidelines are attempts to eliminate any engineering judgment in determining what is the appropriate traffic control treatment. This leads to "cookbook engineering" where everyone just blindly implements the cookbook approach. This one-size-fits-all approach is not good engineering, is not good public works, and is usually not serving the overall best interest of the public. Many of the recommended guidelines also seem to have been done with no consideration of the fiscal impact. However, with the ever-increasing demands and less money, operating agencies will have difficulty implementing the proposed guidelines

Alternate Circulation Path - (1102.3, 1111)

I would suggest that an exception for short-duration blockages of pedestrian paths should be included. If construction activities will block the path for a few hours or maybe one day, you could spend more time and disrupt more people by the installation and removal of the accessible and protected alternate path than by the actual construction activity. Short-term closure of a pedestrian path, where the pedestrian could utilize the other side of the road is a reasonable alternative.

Minimum Clear Width (1103.3)

48" width exclusive of curbs will be difficult to obtain in many areas with already-constrained right-of-way. I agree with some of the other posted comments that perhaps we should look to including the curbs.

Pedestrian Crossings (1105.2.1)

I do not support the widening of crosswalks in a sweeping blanket mandate. In many cases at large intersections, traffic engineers struggle to get the signal indications located within the 40 - 150' distance from the stop line as mandated by the MUTCD. Adding a couple of feet doesn't sound like much, but in many instances that could be the difference between four and eight signal structures (mast arms). I would prefer to see the 72 inch minimum remain, with guidance to use the 96 inch width where there were higher numbers of pedestrians.

Pedestrian Signal Phase Timing (1105.3)

I am adamantly opposed to mandating a walk speed of 3.0 feet per second and including the length of the curb ramps in the crossing time calculations. I think that the local traffic engineer should have some discretionary authority in these decisions. As a former municipal signal system engineer responsible for the operation of over 1300 signals, I know that this would greatly decrease the capacity of many intersections and increase driver frustration and road rage. The signal maintaining agencies would receive numerous complaints from people who have to sit and wait while the flashing don't walk interval continues to time out, long after all of the pedestrians
have crossed.

Pedestrian Crossing Length (1105.4.1)

This requirement would seem to mandate the removal of unsignalized crossings where the median width is less than 72 inches.

Pedestrian Overpasses and Underpasses (1105.5)

I believe that requiring elevators where there is a elevation change over 60 inches will make pedestrian overpasses too expensive to build and maintain. This will significantly reduce the number of pedestrian overpasses built.

Roundabouts (1105.6)

I think mandating signalized pedestrian crossings at all roundabouts is one of the silliest ideas imaginable. Many roundabouts do not warrant signalization, so they would certainly not meet the warrants for the pedestrian crossings on the approaches. There certainly are some roundabouts with poor pedestrian performance, but many of those have design flaws in the roundabout. Many I have seen have the pedestrian crossing at the circulating roadway edge. By properly designing and constructing the pedestrian crossings at roundabouts, I believe that peds can be properly and safely accommodated without signals at most roundabouts. I think "YIELD TO PEDS" signs at the crosswalks should be tried first, and signalized ped crossings should only be a last resort if nothing else seems to work. However, either of these treatments should only be installed after an engineering study determines that they are the most appropriate traffic control device. I am also unsure what type of barrier is needed around roundabouts. Would a small strip of grass or other landscaping (like that shown in the picture) be an appropriate barrier? Guidance on the barrier is needed.

Turn Lanes at Intersections (1105.7)

Among other things, installation of the pedestrian activated signal at each segment of the crosswalk crossing slip lanes creates a maintenance problem. Large trucks routinely hit poles or devices that are out in the refuge island, so the maintaining agency has to repeatedly replace the equipment. Also, with the requirements of 1106.2.1, there is not room on most slip lane channelization islands to accommodate the spacing requirements. Similar to roundabouts above, I believe that if there is a problem, an engineer should study to determine the most appropriate traffic control and be able to choose the best answer for that intersection from the available solutions.

Accessible Pedestrian Signal Systems (1102.8, 1106)

My only comment here is related to the fiscal issue. In large metropolitan areas where there are large numbers of signals, the costs of retrofitting all of the signals with upgraded pedestrian features can be staggering, especially in this day and age when everyone's budget is being cut. Additionally, by replacing a simple pushbutton switch with a more sophisticated device that also vibrates and emits sounds, you will incur more maintenance expense. Please understand, I wholly support having accessible pedestrian devices where they are needed. However, given the additional capital and maintenance costs, is it good public works to install these devices where they may not be needed? Again, my objection is basically the one-size-fits-all approach.


Thank you for the opportunity to comment. Please let me know if you need additional information.

Larry Hagen

Lawrence T. Hagen, P.E., PTOE
Program Director - ITS, Traffic Operations, & Safety
Center for Urban Transportation Research (CUTR)
University of South Florida, College of Engineering