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State of New Mexico
GOVERNOR’S COMMITTEE ON CONCERNS OF THE HANDICAPPED

Dear Access Board:

We are writing in response to the Draft Public Rights-of-Way (R-O-W) Accessibility Guidelines published on June 17, 2002. We have the following comments:

1102.2 Existing Public Rights-of-Way. This section is written consistent with the current ADA requirements, however, in the R-O-W these guidelines have been more difficult to apply.
GCCH believes that where one corner is altered to provide a curb ramp with detectable warnings, all curb ramps, at that intersection, need to provide a compliant curb ramp with detectable warning. These are critical safety features and they need to be installed consistently so people find them to be useful cues when navigating the R-OW. The only exception for not providing a curb ramp with detectable warning would be where conditions prevent a safe installation such as, existing structures, drainage, extreme slopes, high traffic volumes, or similar conditions.

We realize breaks in the continuity of the accessible sidewalk will occur, however, we request the Access Board to provide more rigorous direction in establishing a timeline to achieve continuous, accessible sidewalks. Continuous, unobstructed, accessible sidewalks need to be a priority around government buildings.

1105.5 Pedestrian Overpasses and Underpasses. We do not believe all pedestrian crossings over 60 inches high should require an elevator. We believe grade separated crossings are good for all pedestrians.

An elevator installation is not appropriate in medium to low density neighborhood/commercial areas. In Albuquerque, New Mexico we have many pedestrian overpasses and underpasses on both sides of the road which exceed 150 linear feet. These crossings connect neighborhoods with schools, parks, major employment centers, military basis, and similar. Many of our suburban areas are split by a major arterial. Everyone uses these crossings because it is the only safe way to cross for small children, people going to work, those riding their bike, the mother with a baby stroller, the elderly, and the person with disabilities. If these quiet and sometimes remote locations are required to provide elevators, we are afraid no crossings will be provided for any ones safety.

Perhaps the elevator requirement should apply only in urban areas where there are existing structures that could accommodate a public elevator addition? An elevator out in a low density development will not feel safe for any one to use on a regular basis, 24 hours a day. Vandalism would be a constant problem. We believe the safety of these elevators needs to be considered further.

Thank you for consideration of our comments and we look forward to seeing the final guidelines. If you have any further questions please feel free to call me at [...].

Sincerely,

Hope Reed,
Access Specialist