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I am writing this letter in support of the Draft Guidelines for Accessible Public Rights-of-Way. As a Certified Orientation and Mobility Specialist (COMS), I teach individuals who are blind and visually impaired to travel independently. The instruction I provide necessarily includes using sidewalks, street crossings, and other pedestrian rights-of-way.

At this time, many street crossings are not fully accessible to people who are visually impaired. Traditionally, people who are not able to see a traffic signal time their crossing by listening for the parallel traffic to surge forward. This is considered to be a good indicator that the light has changed and it is time to cross. Such methods have been used for over fifty years, but they are not as reliable as they were in the 1950s. Over the years, street crossings have been complicated by a number of factors including actuated signals, all-ped phases, irregularly shaped intersections, and unbalanced traffic patterns. Moreover, the increase in ambient noise pollution and the quieter vehicles (particularly the new gas-electric hybrids) make it more difficult to use this method.

The accessible pedestrian signals (APS) identified in the Guidelines would alleviate many of these problems. At many such crossings, pedestrian signals exist alongside traffic signals to give pedestrians guidance about when to cross. If this information is only provided visually then it is not available to someone who is visually impaired and is therefore useless. If there is a need to provide such information to sighted pedestrians, then it should be provided to all pedestrians. For this reason, I strongly support the use of APS, particularly at intersections with the characteristics described above. The Guidelines are a good start in making this a reality.

It is my understanding that some in the traffic engineering community believe that such accommodations should only be made in areas where someone who is visually impaired lives. I would add to that requirement that APS should be installed anywhere people who are visually impaired work, shop, or visit. In other words, any pedestrian right-of-way that is accessible to the general public should be accessible to all.

I am also aware that there are those who are concerned that APS would generate noise pollution and draw negative attention to blind people. This is based on the misconception that all APS have to be loud enough to be heard from across the street. An APS that adjusts its sound to be just slightly higher than the level of ambient noise so that it may be heard only from the corner of departure (which is the only place an individual needs to be alerted that it is time to begin crossing) would not pose this problem. Moreover, it is important that APS include a vibro-tactile component for individuals who are also hearing impaired.

I am pleased that the Access Board has drafted these guidelines and is giving them serious consideration. It is my hope that they will be implemented so as to assure continued and improved accessibility in an ever changing world.

Sincerely,
John S. Ford, COMS, CLVT
Member, Association for Education and Rehabilitation of the Blind and Visually Impaired