July 7, 2002
Please accept this email as my comments on the proposed
accessibility guidelines for public rights-of-way.
Section 1103.7 concerning gaps at railroad rails. I do not
disagree with the current proposal of up to 3" for freight trains. I think
this issue and some others such as surface roughness could be better addressed
by changing wheelchair specifications rather than from the facilities
specifications. For instance requiring wheelchairs with front wheels that
can be locked straight when crossing any gap.
Wheel chairs are way behind the times and could be designed
to accommodate for many issues that are now being addressed from the