Andrew M. Mudryk
October 25, 2002
I am submitting these comments
on behalf of the Arizona Center for Disability Law (ACDL) in response to an
Access Board request for comments regarding its draft guidelines addressing
accessibility in the public right-of-way. ACDL fully supports the Board’s
guidelines and encourages the Board to proceed quickly to issue a notice of
ACDL is the designated protection and advocacy system for persons with
disabilities in the State of Arizona. The following comments will proceed in
order by section number.
Section 1101.3 defines Public Right-of-Way as “land or property . . . that is
acquired for or devoted to transportation purposes.” This definition should be
clarified to make clear that it applies not only in the strict vehicular sense
but also includes all pedestrian facilities appurtenant to them.
Sections 1104.2.3 and 1104.3 set forth the technical standard for blended
transitions. A blended transition is one design option for connecting pedestrian
access routes with crosswalks. The Access Board should clarify that blended
transitions, as it envisions them, are different from and much safer than a
similar design currently in widespread use. In the latter design, the sidewalk
gradually flares down to the street on the radius corner but is not connected to
a landing space at the bottom that is wholly within a marked crossing. Blended
transitions as portrayed in the graphic included in the draft guidelines are
required to have a bottom landing that keeps wheelchair users from having to
wait in the street for a traffic-crossing signal.
Section 1105.3 requires pedestrian signal phase timing to be calculated
according to a walking speed of three feet per second. ACDL has concerns about
the appropriateness of using three feet per second as a benchmark for measuring
the safe crossing speed of manual wheelchair users and other people with
mobility impairments and would be interested in any clarification the Access
Board might offer as to the benchmark’s derivation.
Section 1105.5 would require elevator access where the rise of a ramped approach
to a pedestrian overpass exceeds 60 inches. ACDL does not object to the use of
60 inches of elevation change as an appropriate cut-off for requiring an
elevator but does urge the Access Board to clarify that the use of an elevator
after the cut-off point is in addition to, and not in lieu of, a ramp. ACDL does
not support the use of an elevator instead of a ramp to reach an overpass. The
Board should also clarify that elevators to pedestrian overpasses shall be
independently operable at all times.
Andrew M. Mudryk
Arizona Center for Disability Law