Richard A. Gaffney
October 4, 2002
Dear Board Members:
I am writing on behalf of the National Federation of the Blind of Rhode Island
which is the largest consumer organization of blind people in the state. I am
concerned about the placement of audible traffic signals and detectable
warnings. I believe the proposal by your Board is excessive and could indeed
make traffic crossings more 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.
The draft guidelines call for detectable warnings whenever a sidewalk (including
a median or island) joins a crosswalk. However, this is not necessary to provide
accessible and safe travel for the blind. There are adequate cues available to
detect the transition from sidewalk to street. Therefore, detectable warning
should only be installed when the slope is virtually flat, referred to as 1:15
or flatter--one inch downward for every fifteen inches of sidewalk.
With proper training blind people can cross streets by monitoring traffic flow.
Unless the Board’s proposal includes every street in our nation, blind people
have to still use these techniques. What is most important to remember is that
all the ATS will not prevent a blind person to detect a car which did not stop
when the light is red.
Richard A. Gaffney
President NFB of RI