Arthur W. Gruhn
October 25, 2002
Thank you for the opportunity to participate in this important effort of
improving accessibility for disabled persons on the nation's transportation
Various members of the Connecticut Department of Transportation's Bureau of
Engineering and Highway Operations have reviewed the draft Guidelines for
Accessible Public Rights-of-Way that have been proposed by the US Access Board,
as well as the American Association of State Highway and Transportation
Officials (AASHTO) comments and recommendations of such.
ConnDOT strongly supports AASHTO's comments and recommendations. We feel that
the technical issues and cost implications encompassed in AASHTO's October 14,
2002 submittal represent realistic concerns if the guidelines are released "as
is" and that these need to be addressed at this stage rather than during
In addition to AASHTO's comments, we offer the following:
* Curb Ramps and Blended Transitions (1102.6, 1104)
Due to existing street hardware, available Rights-of-Way, and/or roadway
geometry, it is not always practical to provide two separate curb ramps at a
corner. Contrary to the two-ramp requirement, there are instances in which a
single ramp that opens diagonally onto an intersection would be the preferable
treatment. It is recommended that State and local jurisdictions be given the
latitude of choice on this issue.
* Accessible Pedestrian Signal Systems (1102.8, 1106)
In Connecticut there have been cases where complaints have been received
regarding the use of audio devices which operate in conjunction with our "Walk"
signals. Adjacent residential and/or commercial property occupants have had
concerns about noise made by the devices in areas of frequent crossing activity.
In addition, several blind pedestrians have mentioned that the audio devices
interfere with their need to hear the sound of traffic to distinguish
conflicting vehicular movements.
* Detectable Warning Surfaces (1108)
Investigation with cold weather States and Canada, who have used truncated domes
in streetscapes, have revealed maintenance problems with the life expectancy of
the domes when faced with snow removal. Often snowplows are used to remove snow
from walks resulting in damage to the domes and the peeling of tiles where tiled
domes are used.
If you have any questions or need additional information, please contact me at [
Arthur W. Gruhn