Deborah Brown

October 22, 2002

Many of the items in the draft guidelines for public rights-of-way are
premature, and many will not help the problem of public access for blind
pedestrians.

I am a member of the National Federation of the Blind living and working in
the Washington area. I have previously lived in south Florida, where there
are no sidewalks. I moved to the Washington area mainly because of improved
pedestrian access.

I appreciate the advocacy for the 3 feet per second timing on pedestrian
signals. This is the kind of requirement that would benefit all pedestrians.

No disability accommodations will help pedestrians if there are no signals
or designated pedestrian zones in the first place. Creating expensive
requirements for access may result in a decision not to signalize an
intersection or not to provide sidewalks on the grounds that these
requirements are too expensive. It is also pointless to have a politically
correct ramped, marked, and signalized intersection which is surrounded by
streets that cannot be navigated or crossed.

About intersection design: Poorly designed ramps are a problem for blind
pedestrians. It is better for the ramp to have steeper sides that can be
felt. Also, an ambulatory blind pedestrian is more likely to stay out of a
wheelchair user's way if he does not feel he must stand inside the ramped
area to be assured of crossing the street in the crosswalks.

The issue of raising the street level at intersections is an interesting
one. The main reason we want cars to slow down is to make the roads safe for
pedestrians and other drivers. Raising the street level to the level of the
sidewalk may make it unsafe for blind pedestrians. Why should law-abiding
citizens have to make this accommodation to criminals?

On accessible pedestrian signals: The rule for blind pedestrians is that
when the parallel traffic moves, the blind pedestrian moves. If this rule
can be applied safely, no APS is needed. (Of course this rule cannot be
applied 100% safely because not all drivers are law-abiding. We can never
hope to protect pedestrians or any other group from people who break the
law.)

APSs are complicated to use; therefore, the complexity of the
intersection
must merit the use of a complicated tool like an APS. For example, in
Montgomery County, Maryland, an ordinary four-way intersection, Fenton Street
and Wayne Avenue, has an APS. Anyone wishing to use the APS must find the
button using the locator tone, and then either listen for the signal or feel
the vibrotactile indicator. If the APS is not correctly placed, the
vibrotactile indicator is useless. Any blind pedestrian not using the APS
simply listens to the traffic. Anyone who could not manage to cross the
street without the APS could not cross it with the APS, making the APS
unnecessary.

The design of APSs is made much more complicated than necessary by the
presence of the locator tone. Locator tones are necessary because of
misplacement of the APS. Simply requiring the APS to be located within reach
of the pedestrian waiting to cross the street would make locator tones
unnecessary and APSs much more useful. Poor placement also makes the APS
much less useful because the sound is often coming from behind the person
crossing the street.

APSs should be installed only where the normal rules of street-crossing would
not apply. Examples might be (1) where there is little or no parallel
traffic; (2) where a pedestrian is given a walk signal ahead of the parallel
traffic; (3) where the length of the signal is long enough to cross only
when a pedestrian-activated signal is used. How would a blind pedestrian
know if a pushbutton APS is present without a locator tone? If a pole with a
signal is properly placed, the blind pedestrian would simply look at each new
intersection to find the signal.

Detectable warnings: I am concerned about the use of textures to send
messages. Does the textured surface mean "Walk here," "Don't walk here," or
nothing at all? It is preferable to use grass or sand, or some nonpaved
surface, if a barrier is intended.

Some people have recommended that textured surfaces be used only when a
surface is perceived as flat.

However, it is not the actual slope of the ramp, but the unnatural feel of
it, that tells a blind pedestrian that an area is a street crossing (in
addition to traffic noise). If the surrounding terrain is hilly, a gentle
slope is no different from surrounding areas. If the surrounding terrain
is flat, a gentle slope is quite noticeable. I recommend that other methods,
such as properly designed curb cuts, be used to indicate street crossings.

In Montgomery County wheelchair users are troubled by brick streets in the
downtown Rockville area. I know that many wheelchair users do not complain
about truncated domes, but I believe they are simply being courteous about
what they perceive to be someone else's access need. I fail to see how a
textured surface will be maintained through rain, snow, dirt and traffic.

I believe that many of the accommodations that will help blind pedestrians
are those that will help all pedestrians. These include (1) increasing the
timing on walk signals; (2) taking into account the auditory environment
when determining where to place pedestrian signals; (3) holding drivers
accountable for following the laws of the road; (4) providing public
education to all citizens, including those with disabilities, about
safe travel. Montgomery County, Maryland, where I live, is taking
initiatives in defending the rights of pedestrians. Without the human
interest in the issue, all fancy gadgets will simply cost money and fail to
improve the situation.

the APS is not necessary.