Dr. Raymond F. Keith
|
October 27, 2002 |
I wish to submit the following comments on the Draft Guidelines for
Accessible Public Rights-Of-Way, which were issued on June 17, 2002.
I am totally blind and have travelled with relative independence throughout this
country and in many other countries of the world.
I have experienced the benefits of some of the technology referred to in these
proposals, and know that they would be of great benefit to thousands of people
in this country. My comments echo those of the American Council of the Blind, a
national membership organization of people who are blind and visually impaired.
By way of general comment, I want to let the Access Board know that I support
the recommendations contained in this draft, and I 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, I will highlight
some of the proposals which I believe have the greatest impact on pedestrians
who are blind and visually impaired and provide comments thereon.
Section 1104 Curb Ramps And Blended Transitions
I concur 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. I 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. I
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. I am
not aware of any research which supports this argument. In addition, I 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, I
support this recommendation.
Section 1105 Pedestrian Crossings
1105.4 Medians and Pedestrian Refuge Islands: I support the requirement for
installation of detectable warnings on medians
and pedestrian refuge islands set forth in 1105.4.2. I 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: I support 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, I concur 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
I support the requirement that each crosswalk with pedestrian signal indication
shall have a signal device which gives audible and vibrotactile indications of
the walk interval. I 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, I believe
their benefits far outweigh the minimal impact they may have on the environment.
I 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.
I 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 I believe these guidelines will accomplish this.
Section 1108 Detectable Warnings
I support the Access Board's guidelines for the location and installation of
detectable warning surfaces, as set forth in this section. I 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 my 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 I urge the Access Board to incorporate these guidelines into
a rule for accessible public rights-of-way.
Thank you very much for your consideration.
Sincerely,
Raymond Keith