Lukas Franck, COMS

October 28, 2002

Re: The Draft Guidelines for the Accessible Public Rights-of-Way

As the former chair of the PROWAAC sub-committee on Signals and Wayfinding, I would like to congratulate the U.S. Access Board on these draft guidelines which certainly adhere closely to the intent of the recommendations of the majority of our sub-committee. I would like to offer several additional comments.

Of particular concern is the specification on pedestrian pushbutton pole placement. I would like to take this opportunity to review how this specification came about, as the specification appears to have been adopted from that in the MUTCD.

1106.2.1
In working with the National Committee on Uniform Traffic Control Devices to arrive at the proposed language which was eventually included in the MUTCD Millennium edition, we originally proposed that the pedestrian pushbutton pole be placed within five feet of the crosswalk lines extended and five feet of the curb. Please remember that at the time that we were writing that guidance language, there was no requirement that the notification of the WALK interval would always come from the pushbutton housing itself. When this language went out for comments to the MUTCD sponsors, there were several comments from the various states indicating that the proposed "box" was too tight. Bearing in mind that the proposed guidance language in the MUTCD would apply equally to new construction and retrofits, the National Committee decided upon language that extended one dimension of the "box". This resulted in the guidance that the pedestrian pushbutton poles should be placed within five feet of the crosswalk lines extended and within ten feet of the curb.

In the PROWAAC report, we recommended that a much more precise standard apply in new construction and I believe we could have been tighter still. Last year I had the opportunity to visit Australia where I was able to observe signals as proposed in these draft guidelines in operation, which confirmed the importance of good pole placement for accessible pedestrian signals, as proposed in these draft guidelines, if those signals are to work
efficiently and quietly. I urge The Access Board to include the language
as contained in the original PROWAAC report in the new proposed rules.

I would also like to see language that clarifies for engineers that where underground structures, geometric constraints or other factors prevent perfect pole placement, that there should be a bias to place pedestrian pushbutton poles as close as practically possible to the departure point within the MUTCD five foot by ten foot guidance.

1106.2.3.1
Concerning the tones utilized to notify pedestrians of the onset of the WALK
interval: I applaud your choice. It is very similar to the practice currently utilized in Europe and is similar to that formerly used in Australia. However, in recent years, the Australian system has been modified and now includes a "transition tone" preceding the "rapid tick" WALK notification. This "transition tone" is a sharp sound that moves rapidly through many frequencies. In combination with the "rapid tick" it is an absolutely unique sound. Preliminary results of the survey that I have been conducting in Morristown indicate that the distinctiveness of this sound combination is quite striking to blind pedestrians, who identify it as being unlike anything else they would hear in the American soundscape on the street. This may not be true of the "rapid tick" alone. In one experience I had at a test installation in Austin, Texas some years ago, one participant believed the "rapid tick" to be a distant jackhammer. Further, I believe that the Australians added the "transition tone" for a reason, and I suspect it was that the rapidly increasing and then decreasing change in frequencies made the sound more obvious to those with certain types of hearing loss. I would encourage The Access Board to solicit information from the Australian authorities on this point. I would also note that a few blind pedestrians participating in the Morristown study have indicated that the sound combination used in the Australian system imparts to them too great a sense of urgency to leave the curb, so that some further type of refinement might be required. Nevertheless, at this early juncture of the Morristown study, indications are that the use of sound from the pushbutton housing to give WALK information in close proximity to the departure point is extremely well received by the majority of blind pedestrians.

I would also like to respond to some other comments I have seen, in particular those of AASHTO. AASHTO urged that the draft guidelines on Accessible Pedestrian Signals be held in abeyance, pending further research. The implication of their recommendation is that these guidelines are radical and untested. In fact, nothing could be further from the truth, as standards very similar to those proposed in the draft guidelines are the realities on the ground in Australia, Denmark, Sweden, and many other countries.

It is indeed true that further research to improve and enhance the technology employed and the sounds chosen to inform blind pedestrians is ongoing and of great value; however standardized and rational pedestrian pushbutton pole placement will benefit all pedestrians, including those in wheelchairs and with cognitive disabilities. Including pedestrian pole placement in the eventual guidelines will have the effect of forcing engineers to design intersections as thoroughly for pedestrians as they currently do for vehicles.

Finally, since the MUTCD currently allows Accessible Pedestrian Signals and there is considerable demand for those signals from the blind public, there is a risk that in the absence of standards we will miss the opportunity to create a truly national system of accessibility. In that event the resulting regulatory vacuum will be filled with a hodgepodge that will be
installed on the basis of best price rather than best practice.

Thank you for the opportunity to offer my comments. Thank you also, once again, for giving me the opportunity to participate in PROWAAC, and for the opportunity to present to the Board at the Portland, Oregon public hearing earlier this month.

Lukas Franck, COMS
The Seeing Eye Morristown, NJ