Advocating for Accessible Pedestrian Signals


Janet Dickelman
 

The Environmental Access Committee is working with ACB to draft comments on
the proposed amendments to the Manual on Uniform Traffic Control Devices
(MUTCD). Individuals are certainly welcome to comment so we are offering
some guidelines for you to use if you'd like to speak out. Personalize them
as you like but the summary below my signature represents our concern for
the lack of concern re APS. Comments are due Friday, May 14. The link to
submit is at the end of the comments.
Thanks!
Becky Davidson, Chair, EAC
Comments on the Notice of Proposed Amendments to the Manual on Uniform
Traffic Control Devices for Streets and Highways

Agency/Docket Number:
FHWA Docket No. FHWA-2020-0001
RIN:
2125-AF85
Document Number:
2020-26789

(insert personal comments re experiences crossing streets with or without
Accessible Pedestrian Signals)

MUTCD Provisions Specifically impacting Pedestrians who are blind, Low
Vision or Deaf-Blind.
The Federal Highway Administration (FHWA) Notice of Proposed Amendments
(NPA) to the Manual on Uniform Traffic Control Devices for Streets and
Highways (MUTCD) endangers the safety of pedestrians who are blind, low
vision and deafblind (hereafter "blind pedestrians" or "the blindness
community") by failing and refusing to require that an accessible pedestrian
signal (APS) be installed wherever a visual pedestrian signal currently
exists. The proposed 11th edition completely fails to ensure that blind
pedestrians are offered the same opportunity to cross streets safely as are
sighted persons. If a traffic warrant analysis has determined that a
pedestrian signal is necessary for a sighted pedestrian to safely cross a
street, the same information must be effectively communicated to blind
pedestrians in a way that they can understand and use to promote safety,
avoid collisions and reduce or eliminate the greater risk of pedestrian
injury or death the blindness community faces when crossing a street without
an APS.

What the blindness community needs, and the ADA/Section 504 of the
Rehabilitation Act require the MUTCD to mandate:
Elimination of the requirement that an engineering study or traffic warrant
is a prerequisite to justify installation of an APS.

Creation of a transition plan resulting in the replacement of all
inaccessible pedestrian signals with APSs within a reasonable timeframe.

APSs should always be installed wherever and whenever new pedestrian
signalization is installed in new construction or when a pedestrian signal
is replaced at the end of its life cycle.

An APS should always be installed when an existing pedestrian signal is
being altered in a way that could affect its usability such as by adding a
Leading Pedestrian Interval or an Exclusive Pedestrian Phase.

Because of the unique challenges posed to blind pedestrians, require highest
priority replacement of inaccessible pedestrian signals with APSs whenever a
Leading Pedestrian Interval or an Exclusive Pedestrian Phase is planned for
or in use.

A blind person's request for the installation of an APS should be granted on
a highest priority basis.

Alternative forms of pedestrian signalization such as in-roadway warning
lighting, hybrid pedestrian beacons or a Rectangular Rapid Flashing Beacon
should be used only in conjunction with an APS..

To submit comment go to:

http://www.regulations.gov/#ffdocumentDetail;D=FHWA_FRDOC_0001-1260.