Comment NumberOL-100760
Organization
Received06/20/2005 08:02:11 PM
Commenter
First NameLast NameState/Province
SaraBoesserAK
AgencyU. S. Department of Justice
Docket IDCRT Docket No. 2004-DRS01
RuleNondiscrimination on the Basis of Disability in State and Local Government Services; Nondiscrimination on the Basis of Disability by Public Accommodations and in Commercial Facilities
Attachments
AttachmentPlug-in
OL-100760.pdf Adobe Acrobat Reader

CommentsAnswers to Specific Questions

General Comments
Into Proposed Section 15.2, Boating Facilities, I strongly recommend a reminder be placed to remind Title II entities that they must go beyond the 80’ maximum gangway and provide “Program Access” when an 80’ gangway does not provide 1:12 slopes. For the City and Borough of Juneau, Alaska, in particular, I need a letter from DOJ clearly reminding Juneau that Title II entities must go beyond the 80' gangway minimum for disabled access to our city-owned harbors. Program access is not hard to provide here -- it's already been done at the “Wayside Park” fishing facility: via a drive-down gangway with accessible parking provided on the fishing float at the base of the drive-down gangway. The only adjustment for a small boat harbor would be to attach such a down/parking float to a harbor's boat floats. Juneau therefore already has that site’s Program Access for salt water shore-side fishers; and Juneau is in the process of installing a drive-down gangway with parking and working space at its base float for commercial fishers. What's missing is drive-down access with accessible parking on the base float for all other City Harbors services and activities: recreational boaters and boat fishers, commercial and recreational boat tie-ups, commercial small boating tours, and live- aboards. Our Harbors Department has recently purchased and soon will be remodeling an existing harbor, and now is the time to include a drive-down float with parking at its base in the design of that to-be-remodeled harbor. But without a very clear statement from DOJ that such Program Access is required, I know it will not be done because "program access" is not something most people are aware or, and/or are not responsive to without clear direction. So, can you help us out here? Can you provide a letter saying that equal access must go beyond the 80' gangway configuration here in Juneau for Title II, in our 25' tidal range area, in order to accomplish unassisted equal access (program access) for everyone in harbors? Otherwise, entire days will continue to go by with no 1:12 gangway slopes; and even for the very short periods of time in a day when an extra long gangway might achieve 1:12, there are no resting landings for that 80', so true ADA-equivalent access is not possible even momentarily. The drive-down gangway with accessible parking below is the tried and true method of getting program access here in Juneau, every day, at every tidal elevation. To offer staffing assistance as an option would not do in Juneau, in my opinion, because in Juneau the standard of equal access has already been set with the Wayside Park (and upcoming commercial facility) drive-down with parking option. To do less for a harbor would not be viewed as equal access, here, in my view. So -- can you help us out? A letter would be great (a letter attachment to an email would be fine). My hope is it would inspire our Harbors to get the design of the to-be-remodeled harbor to include the accessible parking float now, early on. Thank you very much, Sara Boesser 907-586-0769 (w)