Melanie Brunson
|
October 25, 2002 |
COMMENTS OF THE AMERICAN COUNCIL OF THE BLIND
Regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY
Docket Number: 02-1
Submitted: October 24, 2002
Submitted by: Melanie Brunson, Director of Advocacy and Governmental Affairs
The American Council of the Blind (ACB) is pleased to submit the following
comments on the Draft Guidelines for Accessible Public Rights-Of-Way, which were
issued on June 17, 2002.
The American Council of the Blind (ACB) is a national membership organization of
people who are blind and visually impaired. ACB is dedicated to improving the
quality of life, equality of opportunity and independence of all people who have
visual impairments. Its members and affiliated organizations have a long history
of commitment to the advancement of policies and programs which will enhance the
safety of pedestrians who are blind and visually impaired. For this reason, the
Draft Guidelines for Accessible Public Rights-Of-Way proposed by the Access
Board are of great interest to us.
By way of general comment, we want to let the Access Board know that we support
the recommendations contained in this draft, and we believe that their
implementation would make travel on public ways much safer for people who are
blind and visually impaired. In the paragraphs that follow, we will highlight
some of the proposals which we believe have the greatest impact on pedestrians
who are blind and visually impaired and provide our comments thereon.
Section 1104 Curb Ramps And Blended Transitions
ACB concurs 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. We strongly
support this requirement, and would urge the Access Board to retain it without
exception. If detectable warning surfaces are to be incorporated into the public
right-of-way in an effective manner, their application must be consistent. We
believe that their use as a means of indicating to the visually impaired
pedestrian that they are approaching an area in which traffic is likely to be
moving is reasonable and will enhance the safety of such pedestrians. The
suggestion that detectable warnings should only be installed where the slope of
a curb ramp is 1:15 or less presupposes that the crosswalks adjoining those
ramps not covered by detectable warnings will be detectable without them. We are
not aware of any research which supports this argument. In addition, we would
point out that it requires more than a determination of the slope of a curb ramp
to determine whether one is approaching a crosswalk, or a driveway, or some
other type of space. Traffic sounds, as well as other audible and tactile cues
can influence one's decision about the nature of the space one is about to
approach, and the absence of such cues can hinder the pedestrian's ability to
accurately assess the safety of the situation. The use of detectable warning
surfaces at such locations would provide a safe way of indicating that the
approach to a vehicular way is imminent. It provides a definite tactile cue to
the visually impaired pedestrian without in any way supplanting his/her judgment
or interfering with his/her ability to exercise good travel skills. Therefore,
ACB supports this recommendation.
Section 1105 Pedestrian Crossings
1105.4 Medians and Pedestrian Refuge Islands: ACB 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: ACB 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. Further, ACB concurs with the Board's
recommendation that pedestrian activated traffic signals complying with 1106 be
provided for each segment of the crosswalk, including the splitter island, as
indicated in 1105.6.2. This appears to be the only feasible means of giving
blind and visually impaired pedestrians safe access to the crosswalks at
roundabouts, while causing a minimal interference with the flow of traffic on
the roundabout. It is important that at these intersections, as well as at those
intersections where a pedestrian crosswalk is provided at a right or left turn
slip lane, a pedestrian activated traffic signal that complies with 1106 is
provided for each segment of the pedestrian crosswalk, including the island.
Section 1106 Accessible Pedestrian Signal Systems
ACB supports the requirement that each crosswalk with pedestrian signal
indication shall have a signal device which gives audible and vibrotactile
indications of the walk interval. 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
positioned 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 interval indication.
As an aid to this process, the locator tone required by 1106.3.2 is essential.
In addition to alerting the visually impaired pedestrian to the presence of the
push button, it draws the attention of non-disabled pedestrians to the push
button, as well, increasing the likelihood of safer street crossings overall. In
addition, as the locator tone becomes consistently incorporated into accessible
pedestrian signal systems, the visually impaired pedestrian will have the
benefit of knowing that further accessible information is forthcoming as a
result of his/her activation of the push button. Since these tones are only
audible at close range, if the recommended guidelines are followed correctly,
they will not be disruptive to the surrounding community. Therefore, we believe
their benefits far outweigh the minimal impact they may have on the environment.
We thank the Access Board for including specifications for pedestrian push
buttons in 1106.3.3 regarding size and contrast. These specifications are
important to facilitate their use by people who have low vision.
We believe that sections 1106.3.4 through section 1106.4.3 should be
incorporated into the Access Board's rule in their entirety. These sections
contain well-reasoned guidelines regarding the manner in which visually impaired
individuals should be able to effectively access information about signal
phases, as well as street identification and intersection design. It is
essential that accessible pedestrian signals convey this information in a manner
that is unambiguous and we believe these guidelines will accomplish this.
Section 1108 Detectable Warnings
ACB 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.
As automobiles become quieter and traffic patterns become more complex, it
becomes increasingly difficult, and unsafe, to rely upon the traditional sound
of the traffic as the only means of determining when and where to cross streets.
Pedestrians who do not have visual impairments are aided by signage and other
visual cues for which people who are blind must compensate. It is our view that
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
they provide to the general public. The guidelines recommended here represent a
thoughtful and reasonable attempt to assist communities in carrying out that
responsibility and we urge the Access Board to incorporate these guidelines into
a rule for accessible public rights-of-way.
The members of ACB passed a resolution at their convention in 2002 reiterating
their support for these guidelines, and expressing some further views with
regard to appropriate features for accessible pedestrian signals. A copy of this
resolution appears at the end of this document.
Thank you very much for your consideration.
Sincerely,
Melanie Brunson
Director of Advocacy and Governmental Affairs
AMERICAN COUNCIL OF THE BLIND
RESOLUTION 2002-24
WHEREAS, for many years, the American Council of the Blind (ACB) and its
affiliates have advocated strongly for the use of accessible pedestrian signals,
and have also been leaders in providing advice on the appropriate standards to
govern their use and installation; and
WHEREAS, subsequent to the adoption of accessible pedestrian signals standards
in the Federal Highway Administration (FHWA) Manual on Uniform Traffic Control
Devices 2000 millennium edition, revised, as well as draft guidelines issued by
the U.S. Architectural and Transportation Barriers Compliance Board (U.S. Access
Board), many state and local jurisdictions are examining the extent to which
changes should be made in the accessible pedestrian signals guidelines and
standards contained in their traffic manuals; and
WHEREAS, ACB continues to encourage state and local jurisdictions to provide the
highest level of access to the public rights-of-way and to ensure the safety of
pedestrians;
NOW, THEREFORE, BE IT RESOLVED by the American Council of the Blind in
convention assembled this 5th day of July, 2002, in Houston, Texas, that this
organization urges state and local jurisdictions to include all of the following
requirements in their traffic manuals:
(1) Consistent with the revised FHWA standards, the state or local jurisdiction
shall not require that organizations which represent pedestrians with
disabilities be in full agreement that there is a widespread demand for the
installation of an accessible pedestrian signal at a specific existing
signalized location in order for an accessible pedestrian signal to be
installed;
(2) Whenever the state or local jurisdiction is installing a new, or upgrading
an existing, signal, the signal shall be equipped with accessible pedestrian
features;
(3) All accessible pedestrian signals shall contain the following features;
(a) A push button with a locator tone and a tone indicating when the walk
interval is in effect.
(b) A vibrotactile device to indicate both that the walk interval is in effect
and the direction to which it applies, through the use of a vibrating
directional arrow or some other tactile indicator.
(c) Locator and walk interval tones which automatically adjust in volume in
relation to ambient noise;
(4) Activation of the pedestrian traffic signal for a period of three seconds
activates the accessible pedestrian signal; and
BE IT FURTHER RESOLVED that these standards shall not prohibit a state or local
jurisdiction from providing additional accessible pedestrian signal features if
requested; and
BE IT FURTHER RESOLVED that this organization transmit a copy of this resolution
to the U.S. Access Board during the public comment period on its draft proposed
guidelines on access to public rights-of-way, which ends October 28, 2002.
Adopted.
Donna Seliger, Secretary
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