Re: Request for Comments on the Draft Guidelines for Accessible Public Rights-of-Way.

The Oklahoma Department of Transportation has reviewed the proposed draft guidelines for accessible public rights of way, and subsequently reviewed the AASHTO recommendations relative to that guidance.

The Department concurs with responses conveyed in the " AASHTO Comments and Recommendations on the Draft Guidelines for Public Access", and fully supports the AASHTO efforts to address safety concerns and eliminate ambiguities within the proposed guideline language.

In addition, the Department would request that the Access Board adopt language that would allow the consideration of off-street parking as an alternative to ADA compliant on-street parallel parking. Proposed Section 1102.14, States;

Where on-street parking is provided, at least one accessible on-street parking space shall be located on each block face and shall comply with 1109.

Further, Section 1109.2, Parallel Parking Spaces, states;

An access aisle at least 60 inches (1525 mm) wide shall be provided at street level the full length of the parking space. The access aisle shall connect to a pedestrian access route serving the space. The access aisle shall not encroach on the vehicular travel lane. EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet (4270 mm). When an access aisle is not provided, the parking space shall be located at the end of the block face.

Flexibility should be afforded the Engineer to allow off-s1Ieet accessible parking, where available, in a reduced vehicular environment common to most minor s1Ieets adjoining heavily traveled throroughfares. The Department would propose that the requirements of Section 1104.12 requiring one compliant parking space per block face, be removed, and Section 1109.2 be revised to read;

An access aisle at least 60 inches (1525 mm) wide shall be provided at street level the full length of the parking space. The access aisle shall connect to a pedestrian access route serving the space. The access aisle shall not encroach on the vehicular travel lane. EXCEPTION: An access aisle is not required where the width of the sidewalk between the extension of the normal curb and boundary of the public right-of-way is less than 14 feet (4270 mm). When an access aisle is not provided, the parking space shall be located at the end of the block face or on adjacent connecting streets.

The Department appreciates the opportunity to comment on the Draft Guidelines for Public Access. Should you have questions or comments, please advise.

Sincerely,

Bruce E. Taylor, P .E.
Chief Engineer
Oklahoma Department of Transportation