Comment from Moore, William

Comments on ATBCB-2011-0004 - Proposed Accessibility Guidelines for Pedestrian Facilities in the Public Right-of-Way MAJOR ISSUES Alterations to Existing Facilities “The draft guidelines required alterations to existing facilities to comply with the requirements for new construction to the maximum extent feasible. Most of the improvements in the public right-of-way involve alterations to existing facilities. Transportation officials noted that the meaning of the term ‘to the maximum extent feasible’ was not clear and wanted additional guidance on how to apply the guidelines when existing facilities are altered. “The proposed guidelines clarify that where elements, spaces, or facilities are altered, each altered element, space, or facility within the scope of the project must comply with the applicable requirements for new construction (see R202.3). The phrase ‘within the scope of the project’ is intended to focus on whether the alteration project presents an opportunity to design the altered element, space, or facility in an accessible manner. It is not intended for additional work to be done outside the scope of the project.” COMMENT: This clarification was essential and, having been included, should be supported. Chapter R3: Technical Requirements Continuous Width (R302.3) In part: “The advisory committee recommended a minimum width of 1.5 meters (5 feet) for pedestrian access routes. The proposed guidelines specify a minimum width of 1.2 meters (4 feet) in order to allow for street furniture and other objects that may be located on sidewalks.” COMMENT: I believe the 4 ft width is an excellent suggestion. Greater than the minimum 3 ft now required - which can be very tight for a person maneuvering, for example, in a wheelchair - this width should provide unencumbered access as contemplated by the legislation. The 5 ft recommended would have been excessive.