Monty W. Fredrickson

October 25, 2002

State of Nebraska
Department of Roads

The Nebraska Department of Roads supports the October 2002 AASHTO comments on the proposed ADA Guidelines and we would like to add a few comments.

We would like to address the section for Curb Ramps and Blended Transitions
(1102.6, 1104).

The Nebraska Department of Roads does not agree with placing detectable warning buttons on ALL of the curb ramps. The problems we see with these are snow removal, hazardous to elderly who shuffle their feet, people using walkers to slide down the sidewalk, and tripping of smaller wheels used with delivery carts, luggage, and baby strollers. We would support the 15:1 and flatter requiring the detectible warnings.

We would like to address the section 1105.5 Pedestrian Overpasses and Underpasses.

The Nebraska Department of Roads would not support making elevators mandatory at pedestrian overpasses and underpasses. If local agencies feel that an elevator bests meets the needs of its local citizens, then it can be an allowable expense on a federal aid project. However, most situations would not require an elevator, and it should not be forced upon them.

The Nebraska Department of Roads funds viaducts and pedestrian overpasses every year. Requiring elevators would certainly limit the amount of bridges we could build. In fact, our policy actually says, "The use of elevators is not recommended and should be discouraged because of high vandalism and maintenance costs." The burden of maintenance costs to cities should be minimized. As Nebraska has rail lines with 70 trains a day, we would like to eliminate as many of the at-grade crossings as possible. The draft guidelines, as written, would seriously impact what we could do.

Our other comment is on the section of on-street parking. Section 1102.14,1109.

"One parking space on each block face" is what you would require. Some of the blocks in Nebraska are only 300 feet long. Handicap parking on the state highway would probably not be the safest place for handicap parking. We would suggest that the committee look at applying the 1 space for every 25 spaces in a broad sense in a downtown area along with the sliding scale. Using your scale on a project we have in Wayne, Nebraska would require 1 space in 8 a handicap space. This would make it difficult for non-handicapped people to actually find a spot to park. This would include elderly people who are not actually handicapped, but have difficulty walking too far. Most city administrators should be able to sit down with their councils and engineers to determine where would be the safest place to put handicap parking and ensure that their downtown has a proper number of handicap spaces. Making broad statements because "the proposed requirement would be easier to implement and enforce" is NOT in the best interests of all citizens, including those who need to use the parking.

Sincerely,



Monty W. Fredrickson
Deputy Director-Engineering