Comment to: Bridge of Lions Rehabilitation Project Subject: Pedestrian Safety Railings From: T. J. Tremmel There are two consulting parties to the Memorandum of Agreement (MOA). The other consulting party is Save Our Bridge, Inc. In relation to the MOA, the consulting parties will be afforded the opportunity to review and comment on the design plans (MOA 4.c.). The Federal Highway Administration will take into account all comments provided by the consulting parties and notify the consulting parties of the decisions resulting from them (MOA 4.d.). Design Plan Change Documents obtained from Reynolds, Smith and Hills, Inc., representing the project contractors, reveal that a significant historic feature of the rehabilitation project was changed because of the safety concerns of the contractors. The height of the pedestrian sidewalk railings were raised from 42 inches to 54 inches to protect from the possible scenario of a bicyclist falling off a bicycle, and then falling over the railing and into river. It is recognized by the contractors that this scenario could only occur if the bicyclist was riding illegally on the pedestrian sidewalks. Background The consulting parties were not afforded the opportunity to review and comment on the recommended design change. The consulting parties, Save Our Bridge, Inc. and T.J. Tremmel, became aware of the design change after-the-fact in a letter from Florida Department of Transportation (FDOT) in September 2003. As a response to this subject and other MOA subjects discussed in the letter, Save Our Bridge, Inc. requested a meeting with FDOT. At that meeting in November 2003, the FDOT Public Information Officer did not satisfy how the railing decision had been made or why the consulting parties were not allowed to participate in the process as mandated in the MOA. In February 2004, Save Our Bridge, Inc., sent a letter/comment to FDOT addressing the design change and its rationale. That comment has been acknowledged but not responded to by the FDOT officials at the date of this comment. Basis of Design Change The contractors cite AASHTO LRFD Bridge Design Specifications 13.9.1 Bicycle Railings General: ôBicycle railings shall be used on bridges specifically designed to carry bicycle traffic and on bridges where specific protection of bicyclists is deemed necessaryö as the basis and beginning point of recommending this design change. The contractors state in their ôrecommendationö that: ôFrom a safety perspective, potential users of the sidewalk on the rehabilitated bridge include both pedestrians and bicyclists. While signage and law enforcement could potentially reduce bicycle usage on the bridge sidewalks, protection of bicyclists who disregard this guidance is warranted.ö The contractors state in the same recommendation: ôFrom the preservation perspective, the sidewalk railings should be set at the pedestrian height of 3Æ6ö and the ôoriginal 5Æ sidewalks were built and detailed for pedestrians, not bicyclists. The original railings meet current AASHTO guidelines for pedestrian railings.ö The railings in use on the Bridge of Lion at present meet AASHTO guidelines at 42 inches. There is no AASHTO guideline violation. There is no legal or regulatory requirement for the railings to be raised. There has been no history of a problem with bicyclists falling over the railing in seventy-eight years at the current height. The contractors recommendation/determination was to raise the railing height to protect lawbreaking bicyclists from the improbable possibility of falling over the bridge railings based on that it is ôdeemed necessary and warranted.ö The contractors indicate that this safety protection is more important than maintaining the historical integrity and human scale of the pedestrian railings. Challenge to the Basis As a consulting party to the MOA, and as an American taxpayer, I disagree with the both the rationale and expense of this unnecessary design safety element. Furthermore, I donÆt believe that the contractors have the authority in this decision. There are both bicycle and pedestrian facilities on this
bridge. They must be considered in the context that they are separate
facilities, not shared. The contractors ôdeemed necessaryö and ôwarrantedö the protection of bicyclists on the pedestrian sidewalks of the Bridge of Lions citing FDOT Standard Index 850. The contractors determined that raising the height of the railings for bicyclists on a pedestrian sidewalk is a ôrequirementö based on precedent for FDOT bridges in general. The contractors offer additional analysis to the basis of the design change: ôAlthough these standard indexes do not directly apply to this project, they do demonstrate FDOTÆs precedent for complying with the 54 inch height on bicycle facilities.ö This same document cited by the contractors, Standard Index 850, directly states that the standard guideline for complying with pedestrian sidewalk railings on bridges is 42 inches. In the same document the contractors state that ôpotential users of the sidewalk on the rehabilitated bridge includes both pedestrians and bicyclists.ö The rehabilitation plan sidewalks finish out at 4Æ8ö. AASHTO standards for shared use pedestrian/bicycle facilities is 10Æ wide. According to the project plans, a rehabilitated Bridge of Lions has no basis of potential legal use of operating bicycles on the bridge sidewalks. Bicycles on the Bridge I know the Bridge of Lions well as a bicyclist. I have personally ridden bicycles over the Bridge of Lions more than a thousand times. Experienced bicyclists use the traffic lanes as a matter of traffic law and safety. The typical bicyclist that rides on the bridge pedestrian sidewalks is inexperienced in the travel lane and does not know the applicable traffic safety laws related to the bridge. At this time, there is no signage at the Bridge of Lions to inform the public that bicycles are not allowed to be ridden on the pedestrian sidewalks of the bridge. Bicyclists who choose to cross the bridge via the sidewalks need to be told by explicit signage to dismount and walk their bicycle across the bridge under penalty of law. When mandated, this type of bicyclist will likely comply with dismount signage in the interest of both law and safety. Conclusion Documentation indicates that the contractors deemed the design change necessary and warranted, and then presented it as regulatory requirement to the Florida State Historic Preservation Officer. There is no documentation as to whom in authority from FHWA or FDOT ôdeemed necessaryö and ôwarrantedö special protection of bicyclists operating illegally on the pedestrian sidewalks of the Bridge of Lions. In addition, no ôrequirementö is evidenced in the Standard Indexes cited by the contractors. The contractors, acting as regulators, have misapplied the AASHTO standards to increase the capacity and function to the pedestrian railings. This action sends the message to the public that the pedestrian sidewalks of the bridge are bicycle facilities and encourages bicyclists to break the traffic laws by government sanction. This introduces a greater safety threat to the pedestrians using the sidewalks than the perceived threat of bicyclists falling over the railing that the contractors seek to protect. In the context of ôthe best balance between preservation and safety,ö AASHTO guidelines for the development of bicycle facilities require that historic preservation projects be given special consideration where practical and feasible in relation to preservation of historical design elements. As articulated by the contractors: ôFrom the preservation perspective, the sidewalk railings should be set at the pedestrian height of 3Æ6ö...the original 5Æ sidewalks were built and detailed for pedestrians, not bicyclists. The original railings meet current AASHTO guidelines for pedestrian railings. This means that the original railings could be reproduced with no modifications.ö The railings on the Bridge of Lions have been at the 42 inches or less throughout its rich history. A bicyclist falling over the pedestrian height railings has yet to be documented in the seventy-eight years the bridge has been in service. As for those bicyclists that may disregard the law in the future, a compelling case for the government to raise the railings to protect bicyclists while breaking the traffic laws has not been established. There is no context to raise the railings from the standpoint of historic preservation or AASHTO safety requirements and guidelines. In its entirety, the contractors basis for this design change is convoluted and without merit, and it has been misrepresented as a safety requirement which it is not. From both the historical guidelines and the safety guidelines, it is feasible and practical to retain this important historic element of the Bridge of Lions at 42 inches as planned for the rehabilitation project, and as the railing height exists now. The design change does not serve the public well. As a consulting party to the MOA, I strongly disagree with this design change and its stated basis as the best balance of between preservation and safety. I respectfully request that this historic bridge element design change should be reconsidered and returned to the correct height of 42 inches based on the safety and historic guidelines applicable to the Bridge of Lions rehabilitation project.
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