Dear U.S. Access Board

Thank you for the opportunity to comment on the proposed Public Rights of Way Guidelines. The guidelines are vital to insure that persons with disabilities have an equal opportunity to participate in the community. I wish to express my support for the adoption of these guidelines. Of particular importance are the following proposed guidelines which I strongly supp

5. Section 1103.4. Cross Slope. The proposal to require a maximum cross slope of 1:48 or 2.08 percent is necessary to insure that sidewalks are usable to persons with disabilities. A 3 percent cross slope is twice as hard to use as a 2 percent cross slope. Cross slopes greater than 2 percent cause permanent and debilitating damage to tendons and joints.

4. 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.

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,
 

Earl White ADA Building Inspector