Following are my comments on the Draft Guidelines for Public Rights of Way, June 17, 2002 Thomas Bickford Draft Guidelines for Accessible Public Rights of way June 17, 2002

1103.6 Surfaces

Even though recommendations are not yet formalized, the concerns of people in wheeled mobility aids should not be “Overtaken By Events.” I refer to the desire of some blind people, to place truncated domes everywhere possible. I am blind, but I do not share that desire. The domes I have observed at transit and rail station platforms have more than ½-inch gaps, cause a bumpy ride under wheels, and are a hazard for people with medical conditions causing balance problems. My experience as an assistant to a wheelchair-bound person demonstrated to me that the wheels can not be guided through the gaps between domes. The bumps simply cannot be avoided. People will always be coming at angles and need to be dodging other pedestrians. The board should not rush ahead with “speed bumps for the blind” only to find that they should be filled in and smoothed out for the needs of other disability groups. We blind people need to learn to use our canes, our brains, and our dogs.

For the most part we blind people need to learn to take responsibility for ourselves to learn to live in the built environment. Sighted pedestrians and drivers learn to live in the built environment and do so.

Roundabouts 1105.6

“Because crossing at a roundabout requires a pedestrian to visually select a safe gap between cars that may not stop, accessibility has been problematic.”

AS a blind person I do nothing “visually” and yet I travel successfully.

Drivers know the rules even though they may not follow or want to follow the rules that they should yield to pedestrians at roundabouts. A blind pedestrian must use senses other than sight to judge whether and when it is safe to cross a street or a roundabout. The sense of hearing and general familiarity with the way traffic moves are the first two senses to use. There are, of course, times and places where it is not ]]]]]]safe for any pedestrian which may be at roundabouts or other places. a roundabout is no place for a beginner or the faint of heart. Those people must find another way to go. There have been times and places that I had to do so myself. I, as an experienced traveler, tried the roundabout in Towson, Maryland, just as a test. I found it necessary to be careful and attentive, and I circled the whole thing safely. Sighted observers with me noticed a blind woman using a dog guide who was crossing by herself and on her own business. She managed the roundabout safely, too.

Turning Lanes at Intersections 1105.7

As a blind cane traveler of many years I have had to learn about turning lanes at intersections. Pedestrians must learn that vehicles can and do come from all directions, so the pedestrian must allow for the possibility. Careful attention simply must be maintained. Regular turning lanes are no great problem.

Slip lanes are another issue. It is my experience that drivers using slip lanes at intersections proceed at as high a speed as possible. The blind pedestrian who is crossing a slip lane to a traffic island is at greater danger than when crossing the main part of the intersection which is signalized. Slip lanes are usually installed at major intersections where traffic noise is sufficient to mask the sound of vehicles approaching from behind fast-moving perpendicular traffic and waiting parallel traffic. A steady stream of traffic would not be a problem. The problem comes from irregular and, therefore, unpredictable traffic. A demand light at a slip lane would be a definite safetyadvantage.

1106

As a blind pedestrian using along white cane It has been my experience that pedestrian activated signals have been a help, not a hinderance, for crossing streets.

As a blind pedestrian I am in agreement with the Advisory Committee that installation of audible signals be limited to certain types of intersections. Locations where vehicles come at high speed, around curves, over hills, and, especially, at irregular intervals near the signalized intersection, are those where audible signals would be appropriate. There is only a small minority of intersections where these conditions are met. If a talking or vibrating signal box is properly placed, there is no need for it to have a constantly beeping locator tone to add to the noise polution of the neighborhood.

It is very easy to say “Just put them in everywhere.” Such a commitment is hugely expensive and, as a practical matter, unnecessary. A flat rectangular intersection with moderate or even heavy traffic is the kind of location where audible signals are superfluous. Sighted as well as blind pedestrians can be frightened by heavy traffic, but the brain, the cane, and the dog guide are what will make the difference, not a machine that tells them when the light changes. Traffic, itself, tells what is necessary.

Location 1106.2.1

As a blind cane traveler I am opposed to constantly beeping traffic signals. The locator tone is a distraction from traffic sounds which are far more important as a crossing guide. With standardized locations, adjacent to the curb and the line of the crosswalk away from the intersection, there is no need for the noise pollution caused by constantly beeping locator tones. Allowing push buttons to be placed as much as 120 inches away from the curb is a convenience to builders, not blind pedestrians. For who’s benefit are these signals designed, anyway? I already have enough trouble finding pedestrian activated signals that are ten feet or more back from the curb and hidden in bushes. No, the solution is not to install locator tones on posts which are still too far from the curb. The solution is to put the button on a post where it will do the most good for the people for whom it is designed, pedestrians. With a properly placed talking and vibrating sign I can start walking as soon as the light changes in my favor. There is still no need for the locator tone. There is also only a small minority of locations where such signals are necessary at all.

Proper curbside and crosswalkside placement of signal boxes would also reduce the time needed for crossing the street since the walker could start five to ten feet closer to the crosswalk.