Greetings. I am writing with comments on the Access Board Draft Guidelines, specifically the section covering Accessible Pedestrian Signals.

As an Orientation & Mobility Instructor I work with blind and visually impaired students, and also with municipalities that are considering or already installing APS equipment. I have 12 years of experience, and I am currently working with the City of Richmond, Virginia,  which hopes to install at least one APS in 2003.

In my professional opinion, the guidelines go too far in recommending APS equipment at all new intersections. Many intersections can be crossed safely without such equipment, while some are excellent candidates for these devices - which may call for retrofitting. Applying a blanket requirement to all intersections is unnecessary, and certainly not cost efficient. I suspect that resistance, from those responsible for municipal budgets, will be strong.

Perhaps the Access Board could consider APS guidelines that recommend or require consultation with local O&M Instructors and consumer groups for the blind and visually impaired, to assess whether new intersections, or upgrades of existing intersections, call for the inclusion of APS equipment.

I thank you for your consideration of my comments and suggestions.

Regards,
Alan Kirk, COMS