MASS HIGHWAY
Dear Sirs:
We are responding to the proposed rule changes in the Americans with
Disabilities Act (ADA) Accessibility Guidelines for Buildings and Facilities;
Architectural Barriers Act (ABA) Accessibility Guidelines; Public Rights-of-Way,
published in the Federal Register in Monday, June 17, 2002.
We have reviewed the
comments made by the AASHTO
Committee on Highways, which have been submitted to you, and concur with them.
In addition to those comments, we have one major additional concern which we
believe was inadequately addressed by the committee.
Section 1103.3 Clear Width
This section provides for a 48-inch path of travel for sidewalks excluding the
curb.
To obtain a 48-inch path of travel requires a minimum sidewalk width of 54
inches. This provides for a 48- inch path of travel and allows for a 6-inch
curb. The conditions required for an exception to this are to show it is
infeasible. This is an extremely high standard. From a pure perspective of
feasibility, the building at the back of sidewalk can be taken, streets can be
reduced in width with trucks prohibited, or streets made one way. This will
seriously disrupt the surface transportation, particularly in our older city
centers where existing rights of way are extremely confined. In reality a 48
inch path of travel on the sidewalk excluding curb and without constrictions
means a minimum 72 inch sidewalk to accommodate sign poles, street light!
utility poles, fire hydrants, or other obstructions, with a 12 inch offset from
the face of a 6 inch curb and allowing 12 inches for accommodating the width of
the obstruction.
We strongly urge continuation of the 36-inch path of travel and the reduction of
the clear width of the pedestrian route to 32 inches past obstructions as
currently allowed.
Sincerely,
Thomas F. Broderick, P.E.
Chief Engineer
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