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