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OREGON PARALYZED VETERANS OF AMERICA

Dear Sirs:
Concerns and comments regarding the proposed “Assessable Public Right-of-Way.

We feel that there is a need to have consistence with the access rules, one source, not ADAA(I, ANSI, UFAS, UBC, Oregon State Statute, ECT, etc..

1101 Ambient Noise, Does this mean that my local train/jet/emergency vehicle and crosswalk will compete with each other any time of the day or night? (11062.3./1106.3.2)

1102.01 (New Construction) We are concerned that the phrase “The draft guidelines would not require the provision of sidewalks, streets crossings, street furniture, parking, or other pedestrian elements where none are intended.” would lead to a great deal of access being not provided. This is not an issue in Oregon where we have Land Use Planning, but areas that do not it may be major issue.

1102.2 Additions and Alterations. The phrase “prorated” could be thorn in our side in Oregon. We bad to go a great deal of to effort to define 25%; I can’t imagine what we will go thru defining “prorated”

1102.5.2 - Needs a better definition

1102.7 Exception #2 (ANSI) not needed, raised lettering for deaf.

1102.14 Parking, Do not agree with the 4 per block. In high-density city areas parking is already at a premium. We in Oregon have seen a dramatic increase in invalid Parking Placards do to the high expense of parking ($300 to $500 per month). Also the 4 per block could be an excessive number of spaces in these high-density areas.

1102.15 Loading Zones- does not match up with UBC 1105, which one will take president? I am obligated to follow UBC.

1103.3 Size-passing space, UBC 1109.4.2 requires 60 inches of passing space.

1103.8 Refer to ANSI 303, which refers to 405, which states in 405.7 length to 60 inches not 30 inches.

1103.8 Cross slope changed to 1:48 why?

1104.2.1.3 Driveways, loading (48X48), Seems strange that landings are refereed to as
48” and 60”.

1104.2,2.3 Is this to extend into the traffic way? And how do we handle the street crowning angles?

1105.3 3” per second? Was this done in a scientific manner? We question this rate of motion as being to fast for many people with mobility impairments. I rolled at speed that my friend, who had a stroke, walks at and I covered 42 fret in 20 seconds. She lives near a main collector street that is 4 vehicle and 2 bike lanes wide which I know exceeds 42 feet, and there is no room for a safety island.

1105.4 Does this mean that we can enforce Safety islands when existing streets are resurfaces and/or repaired?

1104.2.1.4 Flares. We feel that 1:10 flare could be a tip hazard,

1104.3.7 Over bike lanes? 1:20 back slope??

1105.5 No Ref.

1106.2.3 Signals, See first item.

1108 Truncated domes, We are in favor of adding ANSI 705.3.3 to cover future technology i.e.; “Equivalent Delectability”.

1109 Van size-Oregon law. We feel that some thing like ORS 447.223 (2)(b) “In addition, one in every eight assessable spaces, but not less then one shall be van assessable. A van assessable parking space shall be at least nine feet wide and shall have an adjacent access aisle that is at least eight feet wide”. He name should also be changed to “Side Lift/Ramp Only” similar to Nevada Law.

1109 Angle- The side flare rules reference “1104” and “1104.2.1.4 Flares” 1:10 Max. we feel could be a tip hazard. (See ANSI 405).

1109.7.1 Parking Meters -We are concerned with the “coin” insert requirement that requires “pinching”. We feel there should be caution extended to local jurisdictions on parking meter rules.

1109.6 Placement- We feel that there two problems here, one Oregon Laws states clearly visible” to the Operator of the vehicle, where there is pedestrian hazard the sign should at a high enough not to be head hazard.

Thank you for your consideration;

Kevin O’Reilly, Advocacy Director
Patrick E. Rodgers, Advocate.

cc: Darrell Ackerman, ODC Access Comm. Chair
Maureen McCloskey, PVA Advocacy Director