October 19, 2002
Dear Access Board:
Thank you for the opportunity to comment on the proposed Right- of -Way
As a person who is blind and independently travels throughout the country I have
observed increased traffic volume and discourtesy toward pedestrians over the
last 30 years. However, I am not convinced that the wholesale installation of
audible traffic signals will increase safety for blind pedestrians. Audible
signals merely tell us when we may walk across an intersection. They do not
indicate when it is necessarily safe to do so. We must still depend on our sense
of hearing to listen for turning traffic and automobiles running red lights. In
fact I believe in most instances audible traffic signals will decrease safety
through increasing noise levels and giving a false sense of security.
However, I believe there are a few instances where modified traffic signals may
be of benefit. These include three-way intersections where there is a large
volume of turning traffic major intersections with complex turning lanes and
possibly other rare instances. In these cases push-button activated signals
causing a unit to vibrate represents a safer solution.
Despite increased traffic, Department of Transportation data indicate that over
the past quarter century pedestrian deaths have significantly decreased. Prior
to continuing this regulatory effort the access board should consider if there
is a real increase in danger to blind pedestrians. Some individuals indicate
anecdotal evidence of increased deaths and injuries faced by blind pedestrians.
I am not aware of any systematic study of the record which demonstrates
increased real danger. In fact, it may turn out that increased traffic has led
to more care taken by blind pedestrians. Given the massive costs of the Board's
proposals, a careful exhaustive study of the costs and benefits for the
installation of audible traffic signals is necessary.
The use of detectable warnings at all but the most rare intersections is not
necessary. Persons who are blind are able to detect almost all curb slopes and
drop-offs with the white cane or through the use of a guide dog. My experience
has been that these warnings are slippery when wet or icy. Their deployment
should be halted unless it can be demonstrated for different slopes and other
conditions that the benefits of reduced pedestrian accidents are less than the
increased cost of injury caused by the installation of detectable warnings. The
Board needs to remember that the regulatory process requires an impact analysis
that takes into account benefits and costs from the point of view of the nation,
not necessarily those of a specific class of persons.
Finally, if the Board chooses not to listen to the Nations Blind and continues
to include audible traffic signals and detectable warnings in this rule making,
it should require that blind persons in each community have a strong voice in
selecting where these signals and warnings may be installed.