Thank you for the opportunity to provide comments on the Draft Guidelines on Accessible Public Rights of Way. I requested that the Hawaii Department of Transportation's divisions (Airport, Harbors and Highways) provide comments. Our Harbors Division elected not to comment. Our Highways division response was dated October 4, 2002 from Vincent Llorin, our Highways Division ADA Coordinator. The following are comments from our Airports Divisions.

1) Pedestrian Access Route. Minimum Clear Width (1103.3). As stated, the 48 inch width is greater that the 36 inch width, as specified in the ADAAG. The 36 inch width was determined to allow sufficient space for wheelchairs. It is recommend the width remain at 36 inches to be consistent w ADAAG.

2) Street Furniture. Public Telephones (1107.4) The draft guide lines would require public telephones to provide wheelchair access and TTY access even if only one phone is installed. This requirement would definitely reduce the number of public telephones, due to costs and vandalism, which would be detrimental to the majority population.

3) Passenger Loading Zones (1102.15). The draft quidelines propose that where loading zones are provided, at least one area in every 100 continuous feet must have an accessible loading zone. It is recommended that the guidelines take into consideration the accessible path leading to an accessible entryway or exit, rather than a specified distance.

Estra Quilausing
State of Hawaii
Department of Transportation
Office of Civil Rights