Comment from Warren, Christine

Document ID: ATBCB-2011-0004-0013
Document Type: Public Submission
Agency: Architectural And Transportation Barriers Compliance Board
Received Date: August 25 2011, at 12:59 PM Eastern Daylight Time
Date Posted: September 22 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: July 26 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: November 16 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80ef012d
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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.

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