Billie Jean Keith

October 28, 2002

Comments from the Northern Virginia Council of the Blind
Regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY Docket Number: 02-1
Submitted: October 28, 2002
Submitted by Billie Jean Keith, President of the Northern Virginia (NOVA) Council of the Blind


The Northern Virginia Council of the Blind is pleased to provide comments on the Draft Guidelines for Accessible Public Rights-Of-Way, issued on June 17, 2002. We are very concerned that many walkways and intersections are not accessible for a blind person, no matter his/her travel skills. I will mention two in my neighborhood. The most dangerous is the crossing at North Fairfax Drive and Glebe Road in Arlington. I have never been able to cross that street for the 14 years I've lived in this area. Even though it is only five blocks from my home, I must take a cab to get past that intersection. Another is crossing Wilson Blvd. at Glebe Road. However, I wish to provide general comments, not just my problems travelling.

The NOVA Council of the Blind has been in existence for twenty five (25) years and is dedicated to the independence and quality of life for Virginians who are blind and visually impaired. NOVA is also a chapter of the American Council of the Blind.

The Draft Guidelines for Accessible Public Rights-Of-Way proposed by the Access Board are of great interest to our members.

Section 1104 Curb Ramps And Blended Transitions

NOVA agrees with the Access Board's recommended guidelines with regard to curb ramps and blended transitions. Of particular interest is the requirement in Section 1104.3.2 that detectable warning surfaces be provided wherever a curb ramp, landing, or blended transition connects to a crosswalk. The use of detectable warning surfaces at such locations would provide a safe way of indicating that the approach to a vehicular way is near.

Section 1105 Pedestrian Crossings

1105.4 Medians and Pedestrian Refuge Islands: NOVA supports the requirement for installation of detectable warnings on medians and pedestrian refuge islands set forth in 1105.4.2. We concur with the Board's conclusion that an exception is appropriate for islands where the crossing is controlled by signals which are timed for full crossing.

1105.6 Roundabouts: nova supports the recommendations in 1105.6.1 that barriers be provided at roundabouts, along the street side of the sidewalk where pedestrian crossing is prohibited.

Section 1106 Accessible Pedestrian Signal Systems

NOVA strongly supports the requirement that each crosswalk with pedestrian signal indication shall have a signal device which gives audible and vibrotactile indications of the walk signal. We agree with the Board that care should be exercised in the location of pedestrian push buttons to insure that, to the maximum extent feasible, push buttons for accessible pedestrian signals will be placed where they can be located and activated by the pedestrian while leaving sufficient opportunity for the pedestrian to reach the curb in time to respond to the walk signal.

Section 1108 Detectable Warnings

NOVA supports the Access Board's guidelines for the location and installation of detectable warning surfaces, as set forth in this
section. We believe that the specifications contained herein
minimize the accessibility concerns of persons who have mobility impairments, while greatly enhancing the ability of visually impaired people to access the public right-of-way in a safe manner.

The Americans with Disabilities Act requires communities to take all reasonable steps to insure that people who are blind have access to the same information
provided to the general public. The guidelines recommended here represent a thoughtful and reasonable attempt to assist communities in carrying out that responsibility.

Thank you very much for considering these comments from our organization.

Billie Jean Keith