Len A. Sanderson, P.E.

October 28, 2002

STATE OF NORTH CAROLINA
DEPARTMENT OF TRANSPORTATION

MICHAEL F. EASLEY
GOVERNOR

LYNDO TIPPETT
SECRETARY


The North Carolina Department of Transportation embraces the concept of improving the accessibility on our transportation system for disabled persons throughout North Carolina and the country. Through the proposed guidelines, we will continue to provide the citizens the mobility to enjoy the privilege and right to an active role in society.

After our review of the Draft Guidelines for Accessible Public Rights-of-Way, we support the issues and concerns raised by AASHTO in their October 2002 resolution. We have noted in the past and during this phase of development that extremely specific requirements have been set forth that provide no allowance for engineering judgment to be exercised in the design and construction of these facilities. There appears to be very little room for developing alternate engineering solutions to ensure the safety and welfare of the public for specific situations.

We, along with many other states, are experiencing a shortfall in funds. Many of the proposed accessibility guidelines, if implemented, could have major impacts on the state and local jurisdictions to meet the proposed mandates. Locating additional funding sources for these projects, as opposed to using existing highway funding, would help in getting the accessible features on our highway system.

The North Carolina Department of Transportation recommends that the above issues need to be appropriately addressed before the release of a proposed rule.



Len A. Sanderson, P.E.
State Highway Administrator