My name is L. Dianne Ketts. I hold a certification in Orientation & Mobility
(O&M) and in Low Vision Therapy with the Academy for Certification of Vision
Rehabilitation & Education Professionals. I serve as a member of the
Environmental Access Committee of the Orientation and Mobility Division of
AERBVI (the Association for Education and Rehabilitation of the Blind and
Visually Impaired.) I am currently employed at CITE, Inc. in Orlando, Florida as
the O&M and Low Vision Programs Coordinator. Please accept my comments on the
Draft Public Rights-of-Way Accessibility Guidelines.
Curb Ramps and Blended Transitions (1104)
Detectable Warning (1104.3.2)
I support inclusion of specifications in the draft guidelines for detectable
warnings (1108 Detectable Warning Surfaces) and urge The Board to include
requirements for detectable warnings at ALL slopes and curb ramps where a
pedestrian way intersects with a vehicular way regardless of grade.
Rationale: In my experience as an orientation and mobility instructor of
visually impaired adults, even slopes greater than that of 1:15 can be ambiguous
with regard to whether or not they intersect a vehicular way or not. Detectable
warnings would offer a consistent way for blind pedestrians to know when they
have reached an intersection.
Pedestrian Signal Phase Timing (1105.3)
I support The Board’s draft guideline for Pedestrian Signal Phase Timing
(1105.3) stating that “signal phase timing shall be calculated using a
pedestrian walk speed of 3.0 feet per second maximum.”
Rationale: Because I serve many senior individuals and persons with other
mobility impairments in addition to their vision loss, I often consider the
benefit that a longer walk and pedestrian clearance phase would offer. Many
clients I serve are not able to complete the crossing of multiple lanes of
traffic in the normally allotted time of 4.0 feet per second. The Board’s
recommendation of 3.0 feet per second would improve safety and opportunity for
crossing at numerous intersections.
Medians and Pedestrian Refuge Islands – Detectable Warnings (1105.4.2)
I do not support the EXCEPTION to this recommended guideline stating that
“Detectable warnings shall not be required on cut-through islands where the
crossing is controlled by signals and is timed for full crossing.” It is my
recommendation that this EXCEPTION be removed from the proposed guidelines.
Rationale: Detectable warnings located at a median or refuge island give the
visually impaired or blind pedestrian critical information regarding their
location in relation to the crossing. The presence of detectable warnings may
inform the pedestrian that the island is a place of refuge where they could
possibly stop and rest if it were necessary. This may be especially important
for a pedestrian who moves more slowly or with more difficulty.
Turn Lanes at Intersections (1105.7)
I whole heartedly support the recommendation for pedestrian activated traffic
signals at these locations.
Accessible Pedestrian Signals - General (1106.1)
I support the inclusion of specifications for Accessible Pedestrian Signal (APS)
Rationale: Many intersections in the central Florida area are typical of
intersections that can be found throughout the country. Minor, lightly traveled
streets often intersect with major arteries. When a visually impaired
pedestrian’s intention is to cross the major artery, there is often little or no
parallel traffic movement on the minor street to indicate that it is the
appropriate time for the pedestrian to begin crossing. Accessible Pedestrian
Signal technology provides information critical to determining when to begin a
crossing in a format that is accessible to the visually impaired pedestrian.
I recommend that The Board use the term “Accessible Pedestrian Signal (APS)”
when referring to these types of devices as opposed to “pedestrian signal
systems” or “pedestrian signal devices.”
Rationale: This terminology would more closely match the language in the MUTCD
and current terminology. As a result, engineers and others utilizing the MUTCD
when building public rights-of-way will be less likely to encounter conflicting
or misguiding terminology.
Detectable Warning Surfaces (1108)
As I stated above, I support the inclusion of specifications for detectable
Once again, thank you for the opportunity to comment.
L. Dianne Ketts, COMS, CLVT