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Dear U.S. Access Board

Thank you for the opportunity to comment on the proposed Public Rights of Way Guidelines. The guidelines are vital to insure that persons with disabilities have an equal opportunity to participate in the community. I wish to express my support for the adoption of these guidelines.

In addition, I would like to make special note of the following:

1102.5.2 Post-Mounted Objects.

I support the 4" maximum protrusion from poles and posts. I would suggest that the second sentence is somewhat confusing and could use a rewrite.

1102.14 On-Street Parking.

I support providing accessible parking in public rights-of-way. I would suggest adding language that would permit face clustering – in other words, if one face has a severe running slope and the crossing face does not - it would better to put spaces on the level area rather than forcing locations that may be very difficult to negotiate.

1103.2 Components.

Driveway crossings should be included as part of the pedestrian access route. This will help combat the practice of parking vehicles in the mouth of a driveway thus blocking the access route.

1103.3 Clear Width.

I would prefer a desirable minimum clear width of 60 inches, with 48 inches OK for segments less than 30 feet in length.

1103.6 Surfaces.

It is disappointing that all consideration for surface characteristics was deleted from the recommendations. I know that excessively bumpy surfaces can be exceedingly uncomfortable and difficult to negotiate. If it is not possible to include some description of smoothness, perhaps it is possible to describe the relative flatness or levelness of adjacent unit pavers. I am seeing an increasing tendency for cities to use bricks or concrete pavers set in sand – a surface sure to become uneven quite quickly. Without direction from the Access Board, this style will proliferate.

1104.3.2 Detectable Warnings.

I support the requirement for detectable warnings.

1106.2 Pedestrian Signal Devices.

I support the requirement for accessible pedestrian signals. I would ask that you consider three possible refinements.

One, that fixed time indicators may be accessed with a long button push and that the locator tone may need to be reconsidered at these locations. The locator tone recommended by the committee was specifically intended to indicate the presence of a signal that requires activation by the pedestrian to initiate the walk cycle. Without this indicator, the visually impaired pedestrian will be left without the information that activation is required to affect timing.

Second, that the location for the push button be more clearly defined. It should be clearly stated that the button should be as close as possible to the top lead off point of the departure curb ramp. Buttons should not be 120" away from the crosswalk when a viable location is available at 60" (assuming a 5" curb).

Third, re-inclusion of the concept that locator tones may be initiated by a passive detector as recommended by the Public Rights of Way Access Advisory Committee.

1107.5 Public Toilet Facilities.

The Public Rights of Way Access Advisory Committee recommended to the Board that toilet facilities in the outdoor environment have 48 inches of clear floor space in front of the toilet. This was recommended because the current ADAAG standards do not provide for a toilet stall large enough to accommodate people in larger wheelchairs and scooters. Particularly in the outdoor environment, more people with mobility disabilities use scooters and need to be able to use the public toilet facilities. Please follow the recommendation of the committee and amend the guidelines to require toilet stalls that are usable by persons who use larger wheelchairs and scooters.

1108.1.3 Dome Spacing.

The description of dome spacing should include the phrase in-line grid. Calling for measuring the domes on a square grid could be misinterpreted to allow for a diagonal arrangement.

Thank you again for the opportunity to submit these comments. If you would like additional detail or have questions, please feel free to contact me.

Gina Hilberry

Cohen Hilberry Architects