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I am writing to provide some personal comments on the Draft Guidelines for Accessible Public Rights-Of-Way, which were issued on June 17, 2002. Thought these are primarily my personal comments, I am also President of the American Council of the Blind, the nation's premiere organization of blind and visually impaired people. On behalf of ACB's Board of Directors and membership, I wish to reiterate the comments so ably prepared and submitted on behalf of our organization by Melanie Brunson, our Director of Governmental Affairs. It is my hope and intention that the following personal observations will act as backup to the formal presentation of points made by her on behalf of ACB and blind citizens of the United States.

I write to add my voice in support of these Access Board guidelines. The ability to detect curbs that lead into traffic ways is extremely important, and becoming more and more difficult. For example, I lived for many years in the city of San JOse, California. The entire downtown area of San Jose has blended curbs and a completely flat transition from sidewalk to street. This makes for great aesthetics, but poor personal safety and the confidence to travel freely that accompanies such safety. Many cities use such blended curbs as a modernizing feature of downtown areas as you are probably already fully aware.

I am also very pleased to see the discussions in your guidelines regarding audible signals and the buttons that operate them. Isn't it odd that in a small country like the Czech Republic, one could find these noise-making buttons 8 years ago, but they are virtually nonexistent in our country today. As a totally blind person, let me assure you that finding these elusive little buttons can be an extremely difficult proposition, especially when they are located some distance from the cross-walk they serve.

I'm sure that many arguments can and have been made in opposition to the beeping and chirping audible signals. There can be little doubt that the technologies that drive these devices has improved and will continue to improve. Similarly, periodic changes are made in the mechanisms and production technology used in traffic lights themselves. Before and after such changes, we have traffic lights. Before and after they may improve, we need to have audible signals as well. Audible signals provide the mechanism by which the information from these lights can most readily be made available to the blind community.

In conclusion, let me thank you for providing the opportunity for comments on these excellent guidelines. It is my fervent hope that the Access Board will adopt them in the near future in order to help provide a safer environment for visually impaired and blind pedestrians to travel, and for pedestrians generally as well..

Sincerely,

Chris Gray, President
American Council of the Blind