Association for Education and Rehabilitation of the Blind and Visually Impaired
Orientation and Mobility Division Environmental Access Committee
Revised 5/2017
Suggested Process for Requesting an Accessible Pedestrian Signal (APS) (or other modification)
- Educate yourself about types of APS and the applicable regulations
- U.S. Department of Transportation, Federal Highway Administration, Manual on Uniform Traffic Control Devices (MUTCD), 2009 Edition, Sections 4E.08, Pedestrian Detectors, 4E.09 Accessible Pedestrian Signals and Detectors - General, 4E.10 Accessible Pedestrian Signals and Detectors - Location, 4E.11 Accessible Pedestrian Signals and Detectors - Walk Indications, 4E.12 Accessible Pedestrian Signals and Detectors - Tactile Arrows and Locator Tones, 4E.13 Accessible Pedestrian Signals and Detectors - Extended Pushbutton Press Features)
https://mutcd.fhwa.dot.gov/htm/2009r1r2/html_index.htm
- Access Board, Proposed Accessibility Guidelines for Pedestrian Facilities in the Public Right-of-Way, July 2011 R209 Accessible Pedestrian Signals and Pedestrian Pushbuttons, R307 Accessible Pedestrian Signals and Pedestrian Pushbuttons, R403 Operable Parts
https://www.access-board.gov/guidelines-and-standards/streets-sidewalks/public-rights-of-way/proposed-rights-of-way-guidelines
- Find out who controls the intersection where you're making the request. It can be under the jurisdiction of a city or county or state department of traffic engineering/public works. You can call the number listed in the phone book under city, county, and state government offices for traffic engineering/public works and the state department of transportation, and ask who you need to contact about the traffic signals at that intersection. Get a name, job title, address and phone number. If you get to talk to someone on that phone call, ask that person about their policy for installing accessible pedestrian signals (if that's what you're requesting).
- The request for an APS is strongest when it comes from a pedestrian (e.g., blind, low vision, disabled, senior, etc.) who will personally benefit from the installation of this technology. The pedestrian should make the actual request for the installation of the APS in writing, by sending a letter to the engineer who manages that intersection. Email is also ok. (A sample letter will follow at the end of these bullets.)
- Include wording in the first letter about the need for "access to signal information." Then, if you must, you can refer to the ADA and the requirements to make the rights-of-way accessible if they refuse or delay installation.
- A supporting letter can be sent by certified Orientation and Mobility Specialist (O&M). The letter should be written on professional letterhead, restating the reasons for the need for the APS at that intersection.
- Follow up with a phone call about a week later to the engineer who is responsible for that intersection. Remind him/her of your request letter and see how they respond. If they have no idea about APS and where to get them, tell the person that you have a list of manufacturers and would like to meet with them to discuss solutions.
- It would be ideal to arrange for the engineer to meet with the requestor and the orientation & mobility specialist at the location where the APS was requested. Demonstrate the typical street crossing techniques to the engineer and the difficulties at the intersection and discuss how the APS would resolve your problem.
- If there has been no response within two weeks after they should have gotten your letter, you should send a follow-up letter asking them to contact you.
- If you have to send a third letter, it needs to be copied to the department director, the ADA coordinator, and the elected official (city council member, county supervisor, state assembly member, or state senator, depending on the jurisdiction), whose district includes the street crossing where an intersection modification has been requested.
- If the engineer refuses to meet with you or refuses to consider the APS installation, ask that a letter be sent to you stating why it is not being installed. [Say it nicely and don't let them get away with not replying]. Documentation can come in handy if you file an ADA complaint. Requestor and orientation & mobility specialist need to document any phone conversations [date, who, job title, what they said, etc]. Hopefully, you won't need that information later, but just in case, keep track.
- Keep copies of all letters and file an ADA complaint with the Federal Highway Administration if you don't get a satisfactory response.
Sample letter requesting an APS:
[Date]
[Address to traffic engineer in charge of the intersection]
This letter is to request the installation of an Accessible Pedestrian Signal (APS) at the intersection of [insert street names].
As a pedestrian who is blind, I am unable to use the visual pedestrian signals currently installed at this location and need access to the pedestrian signal information in order to cross the street.
As you may be aware, there is a bus stop at this intersection; I must cross the street daily to reach the bus stop.
[change or add more to fit the specifics of the intersection, particularly if there are some issues that make it particularly hard to cross such as poor traffic sounds, lots of right turning traffic, t-intersection, etc.].
I would like to meet with you or someone from your department at the intersection in question to discuss appropriate modifications.
I would also like for [insert O&M instructor name], an orientation and mobility specialist at [insert agency name] to join us.
You may contact me at [insert phone number, mailing address, or email address] or [insert O&M instructor name] at [insert phone number, mailing address, or email address] to set up an appointment. Thank you for your prompt attention to this matter.
Sincerely,
[signature]
cc: [O&M specialist name, agency affiliation]