|October 27, 2002|
To Members of the Access Board:
I am writing in opposition to the proposed mandated installation of
accessible pedestrian signals (APS's) and detectable warnings at every
intersection and street crossing. As a blind person and employee of a
private, not-for-profit training center for the blind, Blindness: Learning
in New Dimensions (BLIND), Inc., I have first-hand experience with
traveling and crossing streets on a daily basis.
Safety is cited as the primary reason for installing APS's. The sound
emitted from APS's has exactly the opposite effect on safetythe beeps from
APS's covers the sound of traffic. In order for me to cross the street
safely, I must listen to the traffic flow. When I come to an intersection,
I listen to the traffic, one can tell if the traffic is moving and in which
direction. It is also critical for me to hear cars that are stopped, but
can make a right turn on red. Some of these signals even get louder as the
traffic is louder. Interfering with the sound from traffic puts my, and
other blind persons, safety at risk. In addition, the locator tones further
create extraneous, unwanted, and dangerous noise.
The APS's are also confusing. When the tone is emitted signaling it is
presumably safe to cross, one cannot be
certain for which street it is "okay" to cross. Once again, I and other
blind people must listen to the flow of traffic.
In addition, APS's give blind people a false sense of security. Just
because the APS is triggered, does not mean it is safe to cross, cars may
turn or run a red light. Once again, traffic cues cannot and should not be
interfered with by adding extraneous and dangerous noise.
Similarly, detectable warnings are dangerous. I have experienced detectable
warnings in other areas and have had my dress shoes get caught on them;
thus, causing me to trip. The detectable warnings also get very slippery
and dangerous when wet or icy. When I come to a street corner, I do not
want to risk my life falling or sliding into traffic.
Installing APS's and detectable warnings at every intersection and street
crossing is extremely expensive and will put a burden on many cities,
towns, and states and our federal government. This money could best be
spent on getting blind people proper training. Our canes will drop when we
come to a curb and you can feel the slope when at a corner with a
wheelchair cut-out. For years, I and other blind people have been crossing
streets independently and safely by using our canes and listening to
traffic. There are training centers for the blind, such as BLIND, Inc. in
Minneapolis, the Colorado Center for the Blind in Denver, and the Louisiana
Center for the Blind in Ruston, and others including other competent blind
people, that train blind people how to cross streets safely and
independently without any alterations to the intersections or street
I am against the wholesale installment of ATS, as they are not necessary at
every intersection, and modifications should be considered only when
sufficient nonvisual cues are not otherwise available. In the rare
situation where an APS's may be necessary, it should be when the
signalization is variable or complex, and the National Federation of the
Blind has been consulted. Furthermore, when such APS's are installed, they
should not be automatically activated and have locator signals, but rather,
be tactile. When detectable warnings are installed, they should only
be considered if the slope of the curb ramp is 1-15 .
Thank you for your time and consideration to deny installation of APS's and
detectable warnings at every corner and street crossing.
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