Lee Nasehi

October 28, 2002

RE: Draft Guidelines for Accessible Public Rights-of-Way (June 17, 2002)

CITE: Lighthouse for the Visually Impaired is a not-for-profit agency providing educational and rehabilitation services for blind and visually impaired children and adults in the Central Florida counties of Orange, Osceola, Lake, Sumter and Seminole. It is estimated that there are over 50,000 individuals in CITE’s service area facing severe visual impairments or blindness.

CITE is pleased that the Access Board is now in the process of developing guidelines for construction of public rights-of-way that will address the needs of blind and visually impaired pedestrians. Blind and visually impaired residents in the central Florida area encounter barriers to travel on a regular basis with regard to many inaccessible and dangerous street crossings. The intent of this letter is to show general support for the following aspects of the draft guidelines:

Detectable Warning
CITE supports the inclusion of specifications in the draft guidelines for detectable warnings and urges the Board to include requirements for detectable warnings at ALL slopes and curb ramps where a pedestrian way intersects with a vehicular way regardless of grade.

Accessible Pedestrian Signals
CITE applauds the inclusion of specifications for Accessible Pedestrian Signal (APS) systems. APS systems provide information not otherwise available in the environment and can make a safe and independent street crossing possible for a blind pedestrian where before it was not. When blind pedestrians are given the opportunity to cross independently and safely, this increases the ease and which they can access public transportation, retail establishments, medical services, etc.

Pedestrian Signal Phase Timing
We also support the Board’s draft guideline for Pedestrian Signal Phase Timing (1105.3) stating that “signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet per second maximum.” Many of the visually impaired individuals CITE serves have additional mobility impairments and/or are seniors. This requirement would increase the feasibility of safe and independent street crossings for these individuals.

Thank you for the opportunity to comment and good luck in the continuing rulemaking process.

Sincerely,

Lee Nasehi
Executive Director
CITE: Lighthouse for the Visually Impaired