I am writing this letter to express my support for the drafted guidelines for Accessible Public Rights-of-Way published by the US Access Board on June 17, 2002. In general, I support modifications for the sidewalk environment. We need guidelines to insure that accessible environments are available to our citizens. We need consistent guidelines to which traffic engineers and employees of Public Works can refer to when designing our streets and sidewalks. I hope that my comments concerning my personal experiences illustrate why having such guidelines, establishing and insuring universal standards, and installations of hardware (tactile warnings, accessible pedestrian signals (APS)) is important.

Our current street and sidewalk environments are increasingly becoming more complicated. For a person who is blind or visually impaired, the complexity has been compounded by the development of crossing islands, actuated signals, turn arrows, illuminated "walk and don't walk signs", wheelchair ramps, noisy environments, and numerous other environmental and structural design strategies. For instance, 20 years ago when I was a blind child learning orientation and mobility skills and how to travel safely and independently using a long white cane in our community, I easily detected curbs indicating a change from the sidewalk to the street when my cane tip dropped off the curb bringing to my attention that I had reached a street. Now the tables have turned. Rarely do I encounter a street crossing that a curb drop-off)step) identifies the change in environment. Lack of access to information like the clear identification of a street has made my travel more treacherous in some cases. Many present wheelchair ramps angle a pedestrian out toward the center of an intersection rather than lining them up with the cross walk. I have been taught and use the proper and necessary skills of traveling with a long white cane and a guide dog, however, with out standardized implementations of specific environmental modifications, I may not be able to function in our society safely and independently. If I am not able to travel safely and independently, this may have an adverse impact on my employment, community participation, access to health care, access to groceries, and the list goes on. More importantly, I am not the only individual who is negatively impacted by environmental barriers.

It is becoming more and more common for the sidewalk to street transition to become so blended that the gradual change is not detectable. Although this may be a giant step forward in accessibility for people who use wheelchairs, we need some type of modification to provide the necessary information. A tactile warning installed at these transitions would provide the necessary information.

During the late '90's I relocated to Sunnyvale, CA and the surrounding area for an internship. This was my first exposure to frustration of not being able to cross a street safely and independently. Despite the fact that I had all of the necessary orientation and mobility skills and was an experienced blind traveler, I encountered intersections that were impossible to identify the traffic patterns and impossible to obtain the visual information provided. I was not able to locate the push buttons (if they did exist) because they were far away from the cross walk and randomly placed. In some cases they were so far from the cross walk, that once I pushed the button (if I found it) I did not have time to make it back to the cross walk to cross the street. The traffic was actuated, so it was impossible to understand when was the appropriate time to cross. I had to cross these streets in order to get to work and to get food. It was a dangerous situation and very unnerving. I was very frustrated because, here I was a competent individual who was contributing to our society by working, but could not do my job because I could not get there or get to food independently. No one should have to gamble with their life in order to cross a street. Everyone deserve equal access to visual information given to cross streets.

I know that many intersections like this are present in our current network of roads. I am always traveling for school and various other life events and I frequently encounter street crossing that are not accessible to me as a blind person because I cannot see the "walk, don't walk" signs, locate the buttons, align myself properly with the cross walks, identify if there is even a crosswalk present, identify when it is appropriate to cross. In most situations, the implementation of an audible Pedestrian signal would provide the necessary information. More importantly it would provide the information that every sighted individual is given. We need to make sure that the visual information presented at each intersection is readily available and accessible in alternative formats for people who cannot access visual information. One way to do this is to install the necessary hardware for Audible Pedestrian Signals. I will provide a list of some of them below.

Installations of Audible Pedestrian Signals should not be limited to areas where there is a significant population of people who would benefit from the information given by the APS. People who are blind travel independently to new places for employment purposes, life events, medical needs, groceries, etc. They should not be limited in where they go because necessary visual information is not available to them so that they can make adequately informed judgements about crossing intersections. APS should be placed at intersections as part of a Universal design. Pedestrians should not have to advocate and convenience someone that APS and detectable warnings are needed.

So many environmental factors can interfere with accessing the necessary information. Some intersections may have more traffic at certain times, and it may be necessary for a louder audible signal. For instance, in Berkeley, California, at the corner of University and San Pablo, there are times when it is extremely difficult to hear the audible signal. There has been more than once when I have waited through a whole light cycle because the loud traffic had drowned out the sound of the audible signal.

The following descriptions of APS are from the report of the Public Rights-of-Way Access Advisory Committee (PROWAAC) which was published in January 2001.

1) a quiet locator tone at the push button if it's necessary to push a push button to get the walk timing,
2) an audible and vibrotactile indication of the walk signal,
3) automatic volume adjustment so the audible signal is louder when the traffic is loud and quiet when there's no traffic,
4) the audible walk is a quiet walk signal, adjusted to be 2 to 5 dB above the ambient sound, unless there is special activation to make it loud enough to hear across the street.

I support the APS described above because they address important factors that are important in conveying appropriate information necessary to make judgements about crossing our intersections: i.e. locating the push buttons, volume of APS, etc.

I would also like to point out that it is not just the intersections that have a high volume of traffic that require APS. I live now in a small midwest town. There are countless times that it is difficult to identify the ideal time to cross due to the sporadic pattern of traffic flow. With out the visual information one must guess at times or may be required to walk blocks out of the way to locate an intersection that will provide enough information. All of this to simply cross the street. I remember the days when my biggest problem in accessing information about an intersection was my inability to read the street signs. I was able to use traffic sounds and patterns of traffic to make judgements about crossing. Now, that type of crossing seems to be phasing out of our traffic network because there are more advanced technologies that make traffic (vehicular and pedestrian) more efficient. In order to keep up with these traffic changes, we must also insure that all pedestrians have access to the essential information. I believe we can do this by establishing and implementing standards to address such issues. Continued research and testing of solutions to resolve such problems is also necessary in order to provide the most accessibility.

I sincerely hope that my comments of support for adopting the drafted guidelines pertaining to Audible signals and detectable tactile warnings are taken seriously. Please let me know if you would like additional comments, experiences, ideas, or if I can be of any further assistance.

Sincerely,
Lori M. Miller