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Dear Members of the Access Board,

Thank you for your work on these guidelines. As an Orientation and Mobility Specialist for the past 30 years, I have spent many hours on the streets and sidewalks of my community, usually with a pedestrian who is blind or visually impaired. During that time, I’ve seen major changes in the traffic environment, including the advent of right turn on red, curb ramps, blended corners, left and right turn arrows, raised crossings, right turn slip lanes, and actuated traffic signals. None of those intersection features were much of an issue when I began teaching. They are common at intersections now.

I first became aware of actuated traffic signals in 1992 when I got a call from a former client. He said that he kept getting caught in the middle of the street when the light changed and requested that I meet him at the intersection. He was convinced that he was misjudging traffic and that his hearing had gotten worse (he had a hearing loss in addition to vision loss). After spending an hour at the intersection with him, I realized that his hearing wasn’t worse and he wasn’t misjudging the traffic. However, he was doing something wrong. He wasn’t pushing the pushbutton that was located 25 feet from the crosswalk in some bushes. If he didn’t push that button, the light changed to green for the traffic on the five-lane arterial road before he got to the center line of the street. However, if he pushed the pushbutton and there wasn’t a car on the road beside him (which had very little traffic), he couldn’t tell when the walk light came on to start his crossing at the correct time. The timing seemed to vary and the arterial had gaps in traffic, which also that made the perpendicular traffic an unreliable cue to the change in the traffic signal. Sometimes the light was green for the arterial for 20 seconds and sometimes it was green for 60 seconds. The intersection was not predictable. I had met my match; the skills that I had taught for years didn’t work at that intersection. He couldn’t reliably get from his home to the northbound bus he needed to get to work. I had to suggest paratransit as an alternative until we could come up with something else.

That student and that situation began my interaction with traffic engineers and audible traffic signals. I called the traffic engineer in charge of that intersection to find out what the signals were doing. He educated me about actuated signals and I educated him about pedestrians who are blind and travel skills they used. Working with my client, we developed a solution for that street crossing; it was an audible signal to tell my client when the walk phase began. It worked. He still needed to use the travel skills we’d worked on and listen to be certain that traffic on the arterial was stopping; he still needed his orientation skills to walk in a straight line across the street. However, he knew when the light changed and that he did have a predictable amount of time to cross the street. He could again cross the street comfortably, and ride the regular fixed route bus, which he preferred. And we both learned how actuated traffic signals worked.

My discussions with that traffic engineer led to a presentation at the conference of the Institute of Transportation Engineers and continued work with engineers on access issues. That involvement has continued as a member of the Institute of Transportation Engineers (ITE), a member of the executive committee of the Pedestrian and Bicycle Council of ITE, chair of the Environmental Access Committee of the Orientation and Mobility Division of the Association for Education and Rehabilitation of the Blind and Visually Impaired (AER), and as AER’s representative on the PROWAAC committee.

The modifications required by these guidelines are now needed. I urge the Access Board to move forward quickly to implement the requirements for accessible pedestrian signals and detectable warnings in these guidelines.

Those who state that all we need is more training don’t seem to fully understand the environment we’re dealing with. All the training in the world will not provide the skills to cross at the correct time at many actuated intersections or to locate the street at a blended corner. Nor will it equalize the differences that are common among people, including people who are blind or visually impaired. Suggesting that more training will solve the problem and we won’t need accessible pedestrian signals or detectable warnings is like suggesting that wheelchair users who can’t jump curbs just need more training in how to jump curbs so we won’t need to build curb ramps. There are some individuals who could do that all of the time, some who might be able to do that some of the time, but there are many who would be denied access by such a stance. I have the utmost faith and respect in the ability of blind pedestrians to travel independently and safely and I support that strongly. I want to be able to continue to encourage it.

The traffic engineering and transportation community needs clear directives from you about what is needed to make the streets and sidewalks accessible. There are individual engineers and planners who are aware and responsive to the needs of pedestrians with disabilities. However, there are many more who will do nothing more than what is required. Many transportation planning and engineering courses are just beginning to include discussion of the needs of pedestrians. The education of most of the practicing engineers did not include discussion of pedestrians, much less pedestrians with disabilities. While budget is always an issue for any public works department, we need to insist that the needs of pedestrians with disabilities are a higher priority. Right now, there seems to be plenty of money for expensive signs and lights for vehicular traffic and pretty business center redesigns and very little for those who are pedestrians. These priorities need to be reordered by guidelines that spell out what an accessible street crossing looks and sounds like and what an accessible sidewalk looks like.

You have many comments on this draft. You had a very diverse, talented, knowledgeable, and interested group on the PROWAAC committee. You had good guidance going into this phase. Please move quickly to get the NPRM out. These guidelines need to be out there and implemented. We can’t afford to wait much longer.

Sincerely,

Janet M. Barlow, COMS
Certified Orientation and Mobility Specialist