36 CFR Part 1190, Proposed Accessibility Guidelines for Pedestrian Facilities in the Public Right-of-Way: Notice of Proposed Rulemaking (NPRM)

R211 Signs (Section-by-Section Analysis)

Signs that provide directions, warnings, or other information for pedestrians only and signs that identify routes served by transit stops must comply with the technical requirements for visual characters in Chapter R4. An advisory section provides examples of signs that are required and are not required to comply with the technical requirements for visual characters in Chapter R4. Signs displaying the International Symbol of Accessibility must be provided at accessible parking spaces and accessible passenger loading zones.

The 2004 ADA and ABA Accessibility Guidelines contain similar requirements for transit signs (see 810.4 and 810.6). In the 2004 ADA and ABA Accessibility Guidelines, characters on bus route signs must comply with the technical requirements for character height “to the maximum extent practicable."³⁷  The phrase “to the maximum extent practicable” was intended to provide flexibility where there are restrictions on the size of signs. A similar provision is not included in the proposed guidelines because it is almost always practicable to comply with the technical requirements for character height. Audible sign systems and other technologies are widely used today to transmit information and are more usable by pedestrians who are blind or have low vision.³⁸  Where audible sign systems and other technologies are used to transmit information equivalent to the information contained on signs, the signs are not required to comply with the technical requirements for visual characters in Chapter R4.

Question 12. The Access Board seeks information on technologies that are currently used or are under development to transmit information that is equivalent to the information contained on pedestrian signs and transit signs provided in the public right-of-way.

³⁷The 2004 ADA and ABA Accessibility Guidelines also do not require bus route signs to comply with the technical requirements for minimum height above the ground and line spacing (see 703.5.6, 703.5.9, and 810.4).

³⁸The ANSI approved standard “ICC A117.1‒2009: Accessible and Usable Buildings and Facilities” includes technical requirements for remote infrared audible sign systems (see 703.8).