MELANIE BRUNSON: THANK YOU VERY MUCH. GOOD AFTERNOON. I AM MELANIE BRUNSON. I'M THE EXECUTIVE DIRECTOR OF THE AMERICAN COUNCIL OF THE BLIND, OUR ORGANIZATION REPRESENTS THOUSANDS OF PEOPLE FROM ALL OVER THE COUNTRY WHO ARE BLIND AND VISUALLY IMPAIRED. AND WE HAVE BEEN VERY EXCITED ABOUT THIS RULEMAKING AND I TOO ECHO THE COMMENTS OF OTHERS. I'M SORRY THAT I HAVEN'T BEEN HERE TO HEAR MORE OF WHAT HAS BEEN SAID, I HAVE ALSO BEEN TRYING TO COVER THE TELECOM ADVISORY COMMITTEE TODAY AS WELL.
BEFORE I KNEW THAT I WAS GOING TO HAVE TO DO THAT I ACTUALLY LOBBIED TO GET THE OPPORTUNITY TO COME HERE BECAUSE I HAVE A PERSONAL INTEREST IN THIS ISSUE AS WELL AS A PROFESSIONAL INTEREST. I AM TOTALLY BLIND AND I AM -- MY HUSBAND AND I ARE AVID CAMPERS SO WE HAVE HAD QUITE A BIT OF EXPERIENCE DEALING WITH BOTH PUBLICLY RUN AND PRIVATELY RUN CAMP GROUNDS, AS WELL AS PICNIC AREAS AND A LOT OF HIKING TRAILS AND OTHER KINDS OF OUTDOOR PLACES. SO I WAS PLEASED TO SEE THIS RULEMAKING AND I WANT TO THANK THE ACCESS BOARD FOR A VERY COMPREHENSIVE PROPOSAL. IT ADDRESSES MANY OF THE CONCERNS THAT BOTH I HAVE EXPERIENCED AND THAT OTHER MEMBERS OF MY ORGANIZATION HAVE EXPERIENCED OVER THE YEARS. BUT THERE ARE SOME COMMENTS I WANT TO MAKE TODAY. AND I WILL MAKE SOME OF THEM TODAY AND I WILL ALSO LET YOU KNOW THAT WE WILL BE SUBMITTING MORE DETAILED COMMENTS BECAUSE UNFORTUNATELY, BECAUSE OF MY DUAL RESPONSIBILITIES, I WASN'T ABLE TO GO INTO AS THOROUGH A REVIEW OF THE NPRM AS I WOULD HAVE LIKED TO. BUT WE WILL DO THAT BY THE DEADLINE AND PROVIDE YOU WITH FURTHER COMMENT.
AS I SAID TO YOU, I HAVE PERSONAL EXPERIENCE AND I WANT TO TALK TO YOU ABOUT THE IMPACT OF SOME OF THAT AS WELL AS THE IMPACT OF SOME OF THE THINGS THAT I HAVE OBSERVED IN TALKING WITH OTHER OF OUR MEMBERS. WE DO HAVE SOME SUGGESTIONS TO POINT OUT WITH REGARD TO THE RULE, AND TO SUGGEST TO YOU FOR CONSIDERATION IN THE FINAL RULE. MANY OF THESE RELATE TO SIGNAGE. THIS IS PROBABLY FOR FOLKS WITH VISUAL IMPAIRMENTS THE BIGGEST CONCERN THAT WE HAVE. I APPRECIATED THE WAY THE EDGE PROTECTION PROVISIONS, SOME OF THE OTHER KINDS OF PHYSICAL FEATURES THAT WERE INCLUDED IN ORDER TO ACCOMMODATE THE NEEDS OF FOLKS WHO USE WHITE CANES.
AND ALSO SOME OF THE EFFORTS TO PROVIDE COLOR CONTRAST IN A NUMBER OF SITUATIONS. WITH REGARD TO SIGNAGE, WELL WE RECOGNIZE THAT THERE IS A WIDE VARIATION IN THE KINDS OF TERRAIN, AND OTHER TOPOGRAPHIC FEATURES THAT ARE -- THAT MAKE UP DIFFERENT OUTDOOR FACILITIES. AND THAT SOME OF THOSE VARIATIONS MAKE IT DIFFICULT TO DETERMINE HOW TO ADDRESS SIGNAGE ISSUES. I THINK THERE ARE SOME THAT I WOULD REALLY LIKE TO ENCOURAGE THE BOARD TO CONSIDER. FOR INSTANCE, TRAIL HEADS. SOME OF THESE HAVE ALREADY BEEN MENTIONED. AND WHILE THERE IS AN EFFORT -- THERE IS A MENTION OF CONTRAST FOR THE SIGNAGE ON TRAILS, AND PARTICULARLY AT TRAIL HEADS, I WOULD LIKE TO SUGGEST THAT THE BOARD LOOK AT THE POSSIBILITY OF ALSO PROVIDING LARGE PRINT SCOPING REQUIREMENTS BECAUSE IT IS NOT ALWAYS JUST THE CONTRAST THAT MAKES THE SIGNAGE ACCESSIBLE TO FOLKS WITH VISUAL IMPAIRMENTS. IT IS THE SIZE OF THE LETTERS. AND THAT IS A CONCERN THAT A NUMBER OF PEOPLE EXPRESSED TO ME. THERE IS A REFERENCE SPECIFICALLY, TO MAKING MAPS AVAILABLE IN A FORMAT THAT WOULD BE CONDUCIVE TO FOR INSTANCE, A POCKET GUIDE, WHERE INFORMATION IS FAIRLY DETAILED AND IT IS PROVIDED IN A LARGE MAP.
I WOULD ALSO LIKE TO SUGGEST THAT IN ADDITION TO A POCKET GUIDE, THAT LARGE PRINT MATERIAL WOULD BE USEFUL, AND IN SOME INSTANCES, ALTHOUGH BRAILLE IS CONTROVERSIAL FOR MAPS, IT IS A VERY READILY AVAILABLE MEDIUM FOR CONVEYING A LOT OF THE KINDS OF INFORMATION THAT PEOPLE WOULD BENEFIT FROM THINGS LIKE WHAT YOU WOULD -- THE TEXT THAT WAS ON MANY OF THE SIGNS THAT WERE AVAILABLE, OR WERE DEPICTED IN THE NPRM AND IT WOULD SEEM TO ME NOT UNREASONABLE TO HAVE INFORMATION AVAILABLE AT LIKE RANGER STATIONS IN ALTERNATE FORMATS. THERE ARE MANY PLACES OF INTEREST, OTHER THAN TRAILS AT WHICH INFORMATION COULD BE PROVIDED IN ALTERNATE FORMATS. EVEN IF IT IS ONLY DONE ON AN AS REQUESTED BASIS. SPEAKING OF BRAILLE AND LARGE PRINT, I WOULD LIKE TO TAKE JUST A MINUTE TO RELATE TO YOU A RECENT PERSONAL EXPERIENCE. AS I SAID TO YOU, I AM AN AVID CAMPER, AND WE JUST GOT BACK FROM A WEEK IN SHENANDOAH NATIONAL PARK. I KNEW I WAS COMING HERE, SO I DELIBERATELY TRIED TO PAY ATTENTION TO ACCESSIBILITY FEATURES. AND ONE OF THE FIRST THINGS THAT CAME TO MY ATTENTION WAS THAT THERE WAS NO SIGNAGE THAT WAS ACCESSIBLE TO ME ON ANY OF THE BUILDINGS. INCLUDING THE RESTROOMS. NOW, IF YOU ARE A TENT CAMPER, RESTROOMS ARE KIND OF IMPORTANT. AND YOU KNOW, IT WAS AN INTERESTING EXPERIENCE FOR ME BECAUSE ONE COULD ARGUE AND SAY WELL, OKAY, THE MEN'S ROOM IS THE LEFT ONE, AND THE WOMEN'S ROOM IS THE RIGHT ONE EXCEPT THAT IT WAS THAT WAY ON SOME LOCATIONS BUT THE OPPOSITE ON OTHERS.
SO AS A PERSON WHO LIKES TO TRAVEL WITH A FAIR AMOUNT OF INDEPENDENCE, IT WAS A LITTLE BIT INTERESTING TO ALWAYS HAVE TO ASK MY HUSBAND TO ESCORT ME TO THE FACILITIES. SO I GUESS THE BOTTOM LINE THERE, IS THAT IT WOULD BE -- I DID NOT SEE REFERENCES TO PROVIDING THE SAME SORTS OF SIGNAGE ON BUILDINGS THAT MIGHT BE AKIN TO THE KINDS OF SIGNAGE THAT ONE WOULD EXPECT TO FIND IN OTHER SITUATIONS SUCH AS RESTROOMS IN INDOOR FACILITIES. SO IT WOULD BE MY SUGGESTION THAT THE BOARD LOOK AT MAKING CLEARER SOME MORE DETAILED REQUIREMENTS WITH REGARD TO PROVIDING SIGNAGE THAT IS ONE, RAISED LETTERS AND BRAILLE SUCH AS WHAT IS REQUIRED IN OTHER BUILDINGS, AND 2, MAKING IT AVAILABLE WITHIN A REACH RANGE THAT WOULD ENABLE A PERSON TO ACTUALLY TOUCH THE BRAILLE OR RAISED LETTER SIGNAGE ON BUILDINGS IN OUTDOOR FACILITIES.
WHEN SIGNAGE GIVES DIRECTIONS TO A PARTICULAR PLACE, OR SERVICE, IT IS A FASCINATING EXPERIENCE TO HAVE IT SAY IN A STRAIGHT AHEAD IN -- IT IS STRAIGHT AHEAD IN FRONT OF YOU, OR STRAIGHT AHEAD WOULD BE THE CAMP STORE. IT HAS BEEN SUGGESTED THAT FOLKS, PARTICULARLY WHO HAVE VISUAL IMPAIRMENTS, AND I WOULD IMAGINE OTHER PEOPLE AS WELL WOULD BENEFIT FROM FURTHER DETAILS SUCH AS APPROXIMATE DISTANCE, STRAIGHT AHEAD, FOR INSTANCE, IN HALF A MILE, OR IN 500 FEET.
PHILIP PEARCE [BOARD MEMBER]: MISS BRUNSON YOUR TIME IS ABOUT UP.
MELANIE BRUNSON: THANK YOU, THE OTHER THING THAT I WOULD LIKE TO SAY IS THAT I DID APPRECIATE THE COMMENTS, THE PROVISIONS WITH REGARD TO UNRESTRICTED ACCESS TO SCENIC OVERLOOKS, AND TO PLACES OF SIGNAGE REGARDING POINTS OF INTEREST. AND I AGAIN WANT TO THANK THE BOARD FOR AN EXCELLENT JOB OF ADDRESSING MANY VERY COMPLICATED AND VARIED ISSUES. SO I LOOK FORWARD TO FURTHER COMMENTS INTO THE RULE, THANK YOU VERY MUCH.
PHILIP PEARCE: GREAT AND WE LOOK FORWARD TO YOUR FURTHER COMMENTS AS WELL. IS THERE ANYONE WHO HAS A COMMENT OR A QUESTION FOR MISS BRUNSON? JIM.
JIM ELEKES [BOARD MEMBER]: THANK YOU, MR. CHAIRMAN, JIM ELEKES, PUBLIC MEMBER. MELANIE, JUST A QUESTION, BECAUSE IT HAS BEEN ONLY ABOUT TWO OR THREE WEEKS SINCE THE AMERICAN COLLEGE OF OPHTHALMOLOGY HAS STARTED PRODUCING WHAT THEY BELIEVE TO BE A MORE FUNCTIONAL DEFINITION FOR OUTDOOR SIGNAGE AND LARGE PRINT AND RIGHT NOW IT IS ONLY IN THE DRAFT FORM, BUT HAS THE AMERICAN COUNCIL OF THE BLIND IN RELATION TO OUTDOOR SIGNAGE, HAVE THEY COME UP WITH ANY IDEA WHETHER THEY ARE GOING TO BE IN FAVOR OF THE DEFINITION OF VISUAL IMPAIRMENT AS 20 OVER 70, VERSUS THE DEFINITION FOR SIGNAGE A FUNCTIONAL DEFINITION BY THE OPHTHALMOLOGISTS TO BE APPROXIMATELY 20 OVER 100 OR 20 OVER 120, WHICH WOULD BRING THE POINT SIZE FROM ABOUT 14, 16, TO ABOUT 20 TO 22.
MELANIE BRUNSON: I DON'T -- WE HAVEN'T OFFICIALLY COME TO CONSENSUS ON THAT AT THIS POINT. IT IS STILL BEING LOOKED AT BY BOTH US, AND THE COUNCIL OF CITIZENS WITH LOW VISION. BUT I THINK WHAT IT IS PROBABLY GOING TO COME DOWN TO IS THAT THERE IS A LOT OF THINKING WITHIN OUR ORGANIZATION THAT MORE PEOPLE BENEFIT FROM LARGER THAT THE 14 POINTS THAT WERE INITIALLY INCLUDED IN THE ADA, THERE ARE AN AWFUL LOT OF INSTANCES WHERE IT IS JUST NOT ENOUGH. SO I THINK WE ARE PROBABLY GOING TO COME DOWN ON THE SIDE OF THE LARGER. -- LARGER PRINT SIZE. WE HAVEN'T MADE AN OFFICIAL STATEMENT AS OF YET.
JIM ELEKES: OKAY, GREAT, THANK YOU, THAT IS ALL I HAVE MR. CHAIRMAN.
PHILIP PEARCE: ANYONE ELSE? I DO HAVE ONE QUICK QUESTION FOR YOU RELATED TO WHAT I WOULD CALL NONPHYSICAL SIGNS OR NOT WHAT WE WOULD TRADITIONALLY CONSIDER TO BE PHYSICAL SIGNS. THE INFRARED NOTIFICATION AND THAT SORT OF THING. WHAT ARE YOUR THOUGHTS ABOUT THAT SORT OF DIRECTIONAL ASSISTANCE AS OPPOSED TO A PHYSICAL SIGN?
MELANIE BRUNSON: THERE ARE A LOT OF INSTANCES WHERE IT WORKS PRETTY WELL. THE BIG ISSUE THAT COMES UP IN REGARD TO INFRARED SIGNAGE IS HOW TO GET ACCESS TO THE RECEIVERS. AND SO IF YOU CAN DEAL WITH THAT ISSUE, THERE ARE A NUMBER OF LOCATIONS WHERE IT IS BEING USED QUITE EFFECTIVELY IN OTHER TYPES OF SITUATIONS, AND I KNOW THAT IN A NUMBER OF MUSEUMS, FOR INSTANCE, IT IS BEING INCORPORATED INTO THEIR ACCESSIBILITY FEATURES AND IT IS VERY WELL RECEIVED. THE PROBLEM THAT YOU HAVE OF COURSE, IS THAT THEN ONLY THE PEOPLE WHO HAVE A RECEIVER CAN USE IT UNLESS YOU MAKE PROVISION FOR SOMEONE TO GET A RECEIVER. I COULD SEE, FOR INSTANCE, HAVING SOMEONE BE ABLE TO PICK UP A RECEIVER WHEN THEY ENTERED A FACILITY. AND USE IT WHILE THEY WERE THERE AND THEN TURN IT BACK IN WHEN THEY LEFT IF THAT WAS A SETUP, I THINK IT COULD BE QUITE EFFECTIVE.
PHILIP PEARCE: THANK YOU.
MELANIE BRUNSON: THANK YOU VERY MUCH.