Re: Response to Draft Guidelines on Accessible public rights-of-way

Dear Mr. Windley:

I am writing this letter to express the position of the Institute of Transportation Engineers (ITE) Colorado-Wyoming Section regarding the Draft Guidelines on Accessible public rights-of-way proposed by the United States Access Board. Our ITE Section possesses a membership of approximately 400 transportation professionals who practice in both the public and private sectors. In total, more than 15,000 transportation professionals across the world are members of ITE.

As a Section, we wish to express our support for the comments expressed by Daniel E. Centa, P.E. in his letter submitted to the Access Board on behalf of the City of Pueblo, Colorado dated August 20, 2002. The detailed response presented by Mr. Centa, a member of our Section, encapsulates the position of our membership at-large when he writes the following (p.1):

“It is our firm commitment to provide for pedestrian accommodations to the maximum extent possible when building facilities within the right-of-way. We agree with the need to standardize designs and provide for more consistent pedestrian systems. However, our caution is there may be significant unintended consequences with many of the suggestions coming from the access board.”

His letter continues to enumerate specific comments regarding numerous points within the Draft Guidelines.

In addition to the text of Mr. Centa’s letter, we wish to submit the following additional comments for your consideration:

1. The requirements outlined in the Draft Guidelines will have significant financial impacts that may prove unfair to local jurisdictions.
2. Several Guidelines cover areas that are already specified in the Manual on Uniform Traffic Control Devices, creating conflicting standards.
3. Several areas are addressed with broad mandates which could result in counterproductive and ineffective implementations at the community level.

We believe that our members are committed to planning and constructing public access that most effectively meets the needs of the population. Members of our Section have exhibited a consistent commitment to building transportation projects that further the access needs of the entire population. It is with this history and continued interest that we respectfully submit our position on the Draft Guidelines.

This matter was discussed with our membership at our Section meeting on October 25, 2002 attended by 60 of our members. All those present unanimously supported the position included in this letter.

Thank you for the opportunity to comment on the Draft guidelines. We look forward to participating with you in the ongoing endeavor to provide accessible public rights-of-way.

Sincerely,


ITE Colorado / Wyoming Section

Alex Ariniello
President