June 8, 2007
Mr. Dennis Cannon
Architectural and Transportation Barriers Compliance Board
1331 F Street NW, Suite 1000
Washington, DC 20004-1111
Dear Mr. Cannon:
On behalf of the National Federation of the Blind (NFB), I write to offer comments to the Draft Revisions to the ADA Guidelines for Buses and Vans published on April 11, 2007. The NFB largely supports the provisions suggested in this draft; however, we believe the addition of modest changes would significantly enhance a final rule.
The NFB is this nation’s largest organization of blind people composed of over 50 thousand members in affiliates in the fifty states, the District of Columbia, and Puerto Rico with 700 local chapters in metropolitan areas throughout the nation. Most of our members are blind as are all of our nationally elected leaders making us in fact the Voice of the Nation’s Blind.
The majority of proposed provisions pertain to physical access, which generally does not concern those whose only disability is blindness. There are relevant provisions, however, proposed in Sections 1192.27, 35, 37, and 39, for which I offer comments.
Section 1192.27(a) is proposed to read in part, “Each vehicle shall contain sign(s) which indicate that seats in the front of the vehicle are priority seats for persons with disabilities, and that other passengers should make such seats available to those who wish to use them.” Blindness is not a disability that impacts stamina or an individual’s ability to stand for the duration of a trip. However, when a blind passenger boards, seated passengers are routinely ordered to vacate those seats whether or not the blind passenger expresses a need for them.
Blind passengers often are embarrassed and stigmatized by the experience of individuals being removed from their seats. This embarrassment would be addressed if section 27 put the burden to seek the available disability seats on the individual with a disability. This would permit individuals with disabilities to choose seats further back or even to stand, when that is the only option, rather than use the designated seats for disabled passengers. Under present practice, passengers who actually lack the ability to walk easily or stand for long periods are forced to do so in order for a blind person to have a seat.
Proposed Section 1192.35(a) states, “Vehicles in excess of 22 feet in length, used in multiple-stop, fixed-route service, shall be equipped with an automated stop announcement system.” Though the quoted text marks a positive advance in the ability of blind passengers to know when they reach the stop they seek, there are reports that operators intentionally disable automated stop announcement systems to avoid their noise. Therefore, language should be added stating that making an automated stop announcement system inoperable violates these guidelines.
Section 1192.37(a) refers to stop request capability and further requires, “Such a system shall provide auditory and visual indications that the request has been made.” Though stop request systems historically have provided auditory confirmation by a chime or bell, newer technologies have provided this information by spoken words “stop requested.” Blind persons need auditory confirmation of stop requests to provide confidence that a request was properly made. However, we believe that overly verbose auditory stop requests may contribute to the desire of bus operators to render the automated stop announcement systems inoperable. Therefore, we support the language proposed which requires no more than a bell, chime, or other brief auditory indication of a stop request.
Section 1192.39(a) states that when root and destination information are displayed on a vehicle, the signs should be illuminated. The NFB believes that this section should be amended to add a requirement that comparable information to include root designation and destination should be verbally provided. The capacity to provide this information has been available for well over a decade, but without a requirement, many public transit agencies will elect not to do so. Operator representatives regularly seek to limit the demands on operators, which is often a stated reason that stops are not called for the benefit of blind passengers. Therefore, we should allow technology to augment operator duties whenever feasible.
The National Federation of the Blind appreciates this opportunity to comment. We look forward to participating in the revision of these guidelines. If there is additional information I can provide, I would be most pleased to do so.
James D. McCarthy
Government Programs Specialist
NATIONAL FEDERATION OF THE BLIND