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My name is Charles S. P. Hodge, and I reside at [ ... ]. I happen to be totally blind, and I am an experienced civil rights attorney who works for the U.S. Department of Labor. I am keenly interested in the issues raised by and the recommendations designed to address those issues contained in the report of the Public Rights of Way Advisory Committee (prowac), and the below comments are my personal individual comments as an informed disabled person with respect to Docket Number 02-1.

At the outset, I would like to endorse and associate myself with the public comments submitted in the docket file by Melanie Brunson on behalf of the American Council of the Blind. Through years of experience in traveling as a blind person through the use of both a white cane and a guide dog, I can state unequivocally that the prowac recommendation in favor of detectable warnings at the bottom of curb cuts or sidewalk ramps at intersections is essential for the safety of blind and visually impaired independent travelers. Despite the shrill contentions to the contrary of an organized and vocal minority within the blind community exemplified by members of the National Federation of the Blind, blind travelers cannot tell solely by degree of slope of a curb cut or sidewalk ramp where the sidewalk ends and a vehicular way begins. In addition, with developing technology for electric powered vehicles which are deadly silent, blind pedestrians will become increasingly vulnerable and at risk in future years to serious injury or even death if such a pedestrian should unwittingly wander into traffic on a vehicular way.

I also heartily endorse the prowac report's recommendation favoring installation of accessible audible pedestrian signals at signalized intersections. The sighted public is given "walk" and "don't walk" messages through visual cues and signage at signalized intersections, and the prowac recommended audible pedestrian signals would only replicate or give to blind pedestrians the same or equivalent information provided to sighted pedestrians. While traditional orientation and mobility skills and techniques learned by some blind pedestrians are undoubtedly useful in enabling such pedestrians to safely navigate most simple intersections, as pointed out above, with the increasing advent of silent vehicles, reliance by blind or visually impaired pedestrians upon the traditional traffic sound cues will become in future years increasingly risky and problematic. In addition, as the technology for audible pedestrian signals have advanced in recent years, such accessible pedestrian signals can be programmed to alter sound levels based on ambient noise levels. Thus, the sound levels of accessible pedestrian signals no longer pose a nuisance for neighboring residents and businesses during quiet period such as during the middle of the night.

I also wish to support the prowac recommendation for locator tones for activation buttons or controls on every pole at a signalized intersection with accessible pedestrian signals. Such tones can be programmed to be heard only up to a distance of ten feet, and thus these locator tones need not become a nuisance to local residents or business proprietors. The prowac recommendations with respect to accessible audible pedestrian signals are in my view well tailored and designed to give equivalent information access to blind and visually impaired travelers to that information which is routinely provided by traffic signals to sighted pedestrians. As blind people, we can settle for nothing less as a matter of our civil rights. Accessible audibled pedestrian signals and detectable warnings on curb cuts and sidewalk ramps will also provide blind and visually impaired travelers with a reasonable margin of safety which will not intrude obtrusively on the lives of the general public. In my humble opinion, the Access Board should adopt these recommendations, and reject the illogical arguments being proffered by some in the blind community. Indeed, if some super-achieving and competent blind travelers do not wish to avail themselves of the additional requirements contained in the prowac report, such super blind people are free simply not to utilize accessible audible pedestrian signals and to continue to travel at their own peril in their traditional manner. As one well-informed and thoughtful blind person, I can earnestly and honestly tell the members of the Access Board that despite their contentions that they speak for all of the blind, the National Federation of the Blind does not represent or speak for this blind person with respect to the well-thought-out recommendations of the prowac report. I wish in closing to thank the Access Board for paying attention to and considering my views on these crucial and important--if not life threatening--issues of concern to all blind people.

Respectfully submitted,

Charles S. P. Hodge