Regarding R209.2 - Please clarify this section better. What is a controller or software alteration? Is it upgrading to a new controller or software or simply any timing change? The definition of Alteration "A change to a facility in the public ROW that affects or could affect pedestrian access, circulation or use. Alterations include, but are not limited to, resurgacing, rehabilitation, reconstruction, historic resotration, or changes or rearrangement of structural parts or elements of a facility" - does not clarify the description in R209.2. Additionally, it says that an accessible pedestrian signal should be provided when a "signal head is replaced" - is this describing a pedestrian signal head or a standard red, yellow, green signal head? Please clarify. Additionally, if this section truly means that an accessible pedestrian signal should be provided every time a pedestrian head is changed, and in many jurisdictions the pedestrian heads were upgraded at the same time, it is potentially a great financial burden to install accessible pedestrian signals at many locations at one time. The vibrotactile devices are very expensive. I also don't think simply doing preventative maintenace on the pedestrian head is a true alteration to the intersection for the sighted or non-sighted community. It is simply replacing the LED that has burned out.
Comment from Warren, Christine
This is comment on Proposed Rule
Proposed Accessibility Guidelines for Pedestrian Facilities in the Public Right-of-Way
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