Monty W. Fredrickson
|
October 25, 2002 |
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