Gordon Anthony
|
October 25, 2002 |
11.
Section 1105.6.1. Roundabouts Separation. Requiring a continuous barrier along
the street side of sidewalk where people with visual impairments will be
precluded from inadvertently entering the vehicular way in “roundabouts” is
essential for their safety.
12. Section 1106.2. Signals. It is essential for the safety of persons with
visual impairments that this section be adopted. Requiring audible and
vibrotactile indications of the WALK interval at signalized intersections
provides the same opportunities and safety provided for the general public. Lack
of audible and vibrotactile indicators where the general public is provided
signalized intersections is discrimination and precludes people with visual
impairments from the use of the public right of way.
13. Section 1108.1. Detectable Warnings. Requiring truncated domes to be aligned
in a grid pattern is necessary to allow the wheels of wheelchair users to travel
over them without difficulty. I support wide dome spacing, in-line grid pattern
and smaller surface coverage.
14. Sections 1111.4 and 1111.6. Barricades. It is essential for the safety of
persons with disabilities, especially those with visual impairments, that the
proposed guideline require a solid wall or fence for barricades to separate the
sidewalk from adjacent construction sites, drop-offs, openings and other
hazards, as proposed.
II. Comments on Portions of the Guidelines I Feel Should Be Revised
1. Sections 1102.5.1 and 1102.5.2. Protrusion Limits and Post-Mounted Objects.
The proposed guidelines allow objects with leading edges less than 27 inches in
height to project into the circulation path. People with visual impairments who
use canes usually do not swing their canes as high as 27 inches in order to
detect a barrier and can be severely hurt as a result of these proposed
guidelines. The guidelines should be amended to require that only objects with
leading edges more than six inches above the ground can project into the
circulation path.
2. Section 1103.7. Surface Gaps at Rail Crossings. The proposed guideline allows
2.5 to 3 inch wide gaps where a circulation route crossing commuter and train
rails. Such gaps are sure to entrap the wheels of wheelchairs and lives will be
lost. The U.S. Access Board should demand immediate development and use of gap
closures for where circulation routes cross rails.
3. Sections 1104.2.1.3 and1104.2.2.3. Curb Ramp Landings. Curb ramp landings
where a change of direction is required must be 60 by 60, as is required in the
current Americans with Disabilities Act Access Guidelines (ADAAG.). See ADAAG
4.2.3. The proposed public-right-of-way guidelines allow a landing at curb ramps
that is 48 inches by 48 inches, which is too small to allow people in
wheelchairs to change directions as will be required at many curb ramps. The 48
inches by 48 inches for landings is particularly inadequate for the larger
scooters, which are used, in the outdoor environment.
4. Sections 1104.2.2. Parallel Curb Ramps. The guideline indicates that the
running slope shall be 1:48 minimum and 1:12 maximum. This requirement of 1:48
minimum triggers the requirement for detectable warnings on the running slope.
This requirement should be changed to read 1:15 minimum and 1:12 maximum.
5. Section 1104.3.6. Counter Slopes. The slope of gutter at the bottom of a curb
ramp creates a trough which can cause wheelchair mobile people to be thrown from
their wheelchairs. The Public Rights of Way Access Advisory Committee proposed
that the resulting combination of the gutter slope and the curb ramp slope not
equal more than 11 percent. That is, if the gutter is 5 percent slope, then the
curb ramp cannot be more than 6 percent slope. However, the U.S. Access Board
did not follow the recommendation of the committee. I strongly urge you to adopt
the 11 percent maximum sum for the addition of the gutter and curb ramp slopes
in order to insure that not only wheelchair users, but users of the longer
scooters will not be damaged by the trough created by the connecting gutters and
curb ramps.
6. Section 1107.4.2. Multiple Telephones. The proposed guidelines require only
one wheelchair accessible telephone and only one telephone with a TTY at a bank
of telephones. This means that people with disabilities have no other telephones
available when the accessible telephones are out of order. Accessible telephones
are accessible to many users. Providing only one accessible telephone is
inadequate and not equitable. Please amend the guidelines to require that 50
percent of telephones in a bank of telephones be accessible.
7. Section 1107.5 Public Toilet Facilities. The Public Rights of Way Access
Advisory Committee recommended to the Board that toilet facilities in the
outdoor environment have 48 inches of clear floor space in front of the toilet.
This was recommended because the current ADAAG standards do not provide for a
toilet stall large enough to accommodate people in larger wheelchairs and
scooters. Particularly in the outdoor environment, more people with mobility
disabilities use scooters and need to be able to use the public toilet
facilities. Please follow the recommendation of the committee and amend the
guidelines to require toilet stalls that are usable by persons who use larger
wheelchairs and scooters. This will be particularly important for the increasing
aging population.
Thank you for your time and consideration.
Respectfully submitted,
Gordon Anthony
Senior Deputy Compliance Officer
County of Los Angeles
Office of Affirmative Action Compliance, ADA Section