October 28, 2002
Dear Access Board,
I am writing in regards to the June 17, 2002, United States Architectural and
Transportation Barriers Compliance Board (Access Board) d draft guidelines.
These guidelines would 1. mandate audible traffic signals (ATS) at all
intersections with "walk/don't walk" signs; and 2. require detectable warnings
to be placed at every street crossing without exception. As a blind person with
competent blind traveling skills, I find these guidelines to be unnecessary and
in some cases very dangerous.
Audible traffic signals should only be considered when factors in the
environment (including complex street and traffic patterns) make knowing when to
cross difficult or impossible.
The current draft guidelines are unnecessary to make travel safe for blind
people. They would not improve access and may actually decrease safety due to
distractions created by the variety of tones added to the soundscape. For
example, adoption of the guidelines as written would result in having a locator
tone constantly beeping from each pole with a pedestrian activated push button
for the "walk/don't walk" sign. This means that mixed with all the traffic
sounds there may be as many as 8 or more separate tones all going off
simultaneously, some of which are locator tones (beeping every second when the
"don't walk" sign is on), and others which are ATS tones (beeping more rapidly
when the "walk" sign is on). This confusing array of tones would be presented at
virtually every intersection.
More importantly, this process is very expensive. Tax payer dollars could be
better utilized by equipping blind people with the training necessary for one to
travel safely and independently.
Thank you for your time.