Arthur W. Gruhn

October 25, 2002

Thank you for the opportunity to participate in this important effort of improving accessibility for disabled persons on the nation's transportation system.

Various members of the Connecticut Department of Transportation's Bureau of Engineering and Highway Operations have reviewed the draft Guidelines for Accessible Public Rights-of-Way that have been proposed by the US Access Board, as well as the American Association of State Highway and Transportation Officials (AASHTO) comments and recommendations of such.

ConnDOT strongly supports AASHTO's comments and recommendations. We feel that the technical issues and cost implications encompassed in AASHTO's October 14, 2002 submittal represent realistic concerns if the guidelines are released "as is" and that these need to be addressed at this stage rather than during implementation.

In addition to AASHTO's comments, we offer the following:

* Curb Ramps and Blended Transitions (1102.6, 1104)
Due to existing street hardware, available Rights-of-Way, and/or roadway geometry, it is not always practical to provide two separate curb ramps at a corner. Contrary to the two-ramp requirement, there are instances in which a single ramp that opens diagonally onto an intersection would be the preferable treatment. It is recommended that State and local jurisdictions be given the latitude of choice on this issue.

* Accessible Pedestrian Signal Systems (1102.8, 1106)
In Connecticut there have been cases where complaints have been received regarding the use of audio devices which operate in conjunction with our "Walk" signals. Adjacent residential and/or commercial property occupants have had concerns about noise made by the devices in areas of frequent crossing activity. In addition, several blind pedestrians have mentioned that the audio devices interfere with their need to hear the sound of traffic to distinguish conflicting vehicular movements.

* Detectable Warning Surfaces (1108)
Investigation with cold weather States and Canada, who have used truncated domes in streetscapes, have revealed maintenance problems with the life expectancy of the domes when faced with snow removal. Often snowplows are used to remove snow from walks resulting in damage to the domes and the peeling of tiles where tiled domes are used.

If you have any questions or need additional information, please contact me at [ ... ].

Sincerely,
Arthur W. Gruhn