I am writing to give my support to each of the Draft Guidelines for Accessible Public Rights-of-Way published by the Access Board for comment.

In particular, APSs and detectable warnings are needed as specified in the draft guidelines. I am an orientation and mobility specialist who has been teaching people who are blind how to travel independently for more than 30 years, and during the last 10-15 years I have increasingly seen the effect of ambiguous or insufficient information for detecting the edge of the street, and for determining when the walk signal is on.

At some intersections, no amount of training or even, in some cases, familiarization will provide blind people with the information they need to negotiate the intersection and cross safely. In other instances, familiarization could enable some blind people to cross certain intersections, but blind people don't always travel at familiar intersections, and some blind people (such as those with additional disabilities or hearing loss) need the additional information that the APS and detectable warnings provide even in familiar areas.

--Dona

Dona Sauerburger, COMS
Orientation and Mobility Specialist

October 12, 2002

I want to support your draft of regulations for the public rights of way, in particular the installation of APS at all signals with WALK signals.

25-30 years ago, when I was first teaching blind people to cross streets, I knew of no intersection where an APSs was needed, because signals were predictable and simple, traffic was easy to hear, and there was no RTOR that required blind people to listen to traffic on the parallel street long enough to be sure that some of them were going straight through. When they heard the surge of traffic moving forward on the street beside them, they knew their signal was green and they had enough time to complete their crossing.

Now, there are crossings which require the push of a button to ensure enough time to cross. I have tried to find a reliable, dependable rule to teach blind people how to know if they should look for a button, but there doesn't seem to be any such rule. When I asked on the pednet, I was told that even some downtown areas are actuated.

It is unreasonable to expect that blind people should have to take the time and lose their alignment to search for a button every time they cross an unfamiliar street because there is no other way to know if they have to find and push the button. Only by having every walk signal accessible will they know for sure when they are at a crossing that doesn't require finding the button.

In addition, I have taught many blind people who have additional disabilities that make it difficult to hear or process the traffic sounds and analyze them to determine with reliability when their walk signal is on. Making the signal accessible would enable them to cross streets independently and safely. Many of them now handle it by crossing with assistance or by avoiding the crossing by taking paratransit or other arrangements.

Lastly, 20-30 years ago, it was easy to know when the signal turned green at most intersections, but during the last 15-20 years I have noticed an increasing number of intersections that are difficult or impossible to know when to cross because:

1) it's getting more and more difficult to hear the traffic accurately;

2) complex traffic movement can be confusing (for example the sound of a left-turning car surging from the middle of the intersection from one street is easily mistaken for the surge of traffic coming from other street on the far side of the intersection, which is a cue to begin crossing);

3) right-turn-on-red laws make it impossible to be sure the light has changed until one hears the traffic on the parallel street surging through the intersection, by which time right-turning cars have gained momentum and are unlikely to yield to pedestrians.

--Dona

Dona Sauerburger, COMS
Orientation and Mobility Specialist
 

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