Robert N. Herman
|
October 28, 2002 |
COMMENTS OF THE
PARALYZED VETERANS OF AMERICA
These comments are submitted on behalf of the Paralyzed Veterans of America (PVA)
in response to an Access Board request for comments regarding its draft
guidelines addressing accessibility in the public right-of-way. PVA fully
supports the Board’s guidelines and encourages the Board to proceed quickly to
issue a notice of proposed rulemaking.
PVA is a congressionally chartered veterans service organization with over
20,000 members, all of whom are veterans with spinal cord injury or spinal cord
dysfunction and individuals with disabilities under the Americans with
Disabilities Act (ADA). Virtually all PVA members use wheelchairs for mobility
and it is on their behalf that PVA for many years has participated in the
Board’s various rulemakings to improve and enhance accessibility. In PVA’s view,
the Board’s draft guidelines are well written and require only minimal comments.
These comments will proceed in order by section number.
Section 1101.3 defines Public Right-of-Way as “land or property . . . that is
acquired for or devoted to transportation purposes.” This definition should be
clarified to make clear that it applies not only in the strict vehicular sense
but also includes all pedestrian facilities appurtenant thereto.
Section 1104.2.3 and 1104.3 set forth the technical standard for blended
transitions. A blended transition is one design option for connecting pedestrian
access routes with crosswalks. The Access Board should clarify that blended
transitions, as it envisions them, are different from and much safer than a
similar design currently in widespread use. In the latter design, the sidewalk
gradually flares down to the street on the radius corner but is not connected to
a landing space at the bottom that is wholly within a marked crossing. Blended
transitions as portrayed in the graphic included in the draft guidelines, are
required to have a bottom landing that keeps wheelchair users from having to
wait in the street for a traffic-crossing signal.
Section 1105.3 requires pedestrian signal phase timing to be calculated
according to a walking speed of three feet per second. PVA has concerns about
the appropriateness of using three feet per second as a benchmark for measuring
the safe crossing speed of manual wheelchair users and would be interested in
any clarification the Access Board might offer as to the benchmark’s derivation.
Section 1105.5 would require elevator access where the rise of a ramped approach
to a pedestrian overpass exceeds 60 inches. PVA does not object to the use of 60
inches of elevation change as an appropriate cut-off for requiring an elevator
but does urge the Access Board to clarify that the use of an elevator after the
cut-off point is in addition to, and not in lieu of, a ramp. PVA does not
support the use of an elevator instead of a ramp to reach an overpass. The Board
should also clarify that elevators to pedestrian overpasses shall be
independently operable at all times.
Sincerely,
Robert N. Herman
Senior Advocacy Attorney
Paralyzed Veterans of America