Billie Jean Keith
October 28, 2002
Comments from the Northern Virginia Council of the Blind
Regarding: DRAFT GUIDELINES FOR ACCESSIBLE PUBLIC RIGHTS-OF-WAY Docket Number:
Submitted: October 28, 2002
Submitted by Billie Jean Keith, President of the Northern Virginia (NOVA)
Council of the Blind
The Northern Virginia Council of the Blind is pleased to provide comments on the
Draft Guidelines for Accessible Public Rights-Of-Way, issued on June 17, 2002.
We are very concerned that many walkways and intersections are not accessible
for a blind person, no matter his/her travel skills. I will mention two in my
neighborhood. The most dangerous is the crossing at North Fairfax Drive and
Glebe Road in Arlington. I have never been able to cross that street for the 14
years I've lived in this area. Even though it is only five blocks from my home,
I must take a cab to get past that intersection. Another is crossing Wilson
Blvd. at Glebe Road. However, I wish to provide general comments, not just my
The NOVA Council of the Blind has been in existence for twenty five (25) years
and is dedicated to the independence and quality of life for Virginians who are
blind and visually impaired. NOVA is also a chapter of the American Council of
The Draft Guidelines for Accessible Public Rights-Of-Way proposed by the Access
Board are of great interest to our members.
Section 1104 Curb Ramps And Blended Transitions
NOVA agrees 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. The use of
detectable warning surfaces at such locations would provide a safe way of
indicating that the approach to a vehicular way is near.
Section 1105 Pedestrian Crossings
1105.4 Medians and Pedestrian Refuge Islands: NOVA supports the requirement for
installation of detectable warnings on medians and pedestrian refuge islands set
forth in 1105.4.2. We 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: nova supports the recommendations in 1105.6.1 that barriers
be provided at roundabouts, along the street side of the sidewalk where
pedestrian crossing is prohibited.
Section 1106 Accessible Pedestrian Signal Systems
NOVA strongly supports the requirement that each crosswalk with pedestrian
signal indication shall have a signal device which gives audible and
vibrotactile indications of the walk signal. We 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 placed 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 signal.
Section 1108 Detectable Warnings
NOVA supports the Access Board's guidelines for the location and installation of
detectable warning surfaces, as set forth in this
section. We 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.
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
provided to the general public. The guidelines recommended here represent a
thoughtful and reasonable attempt to assist communities in carrying out that
Thank you very much for considering these comments from our organization.
Billie Jean Keith