Charles S. Brown

October 17, 2002

VIA FAX: 202 272 0081

Re: Comments on proposed guidelines on accessible pedestrian signals and detectable warnings

I am writing to express my strong opposition to the Access Board's proposed guidelines on so-called "accessible" pedestrian traffic signals (APSs) and detectable warning strips at intersections.

I have been blind all of my life (almost 58 years) and I know personally hundreds of other blind people. The proposed guidelines will not help blind people travel safely and will often hinder safe travel instead.

APSs

Adequate nonvisual cues already exist at the vast majority of intersections -- primarily traffic flow. In fact, those who pay careful attention to traffic flow (blind or sighted) are ordinarily the safest street crossers. I am, of course, aware of the fact that there are some especially complex intersections that make standard traffic flow analysis difficult. In such situations, local authorities and the local blindness community are in the best position to determine when and how to deploy nonvisual signals -- audible or vibrating, with or without locator tones.

The vast majority of intersections do not require such devices. In fact, the noises emitted from audible signals are almost always useless at best, annoying or downright unsafe at worst. This would be especially true with the variety of clicks, chirps, and hee-haws that would result from the cacophony of locator tones and traffic tones called for in the proposed guidelines.

As I understand it, local authorities are already supposed to install APSs in the relatively few instances where they would be appropriate. Why impost such a sweeping new federal mandate from on high to inappropriate locations?

We all know the costs will be enormous. I am concerned that many localities will attempt to avoid costly APS installations by simply deciding not to construct traffic lights at all. They may simply decide to rely on two-way and four-way stops. While I have no problem with using stop signs to control intersections for which stop signs are appropriate, using stop signs to control intersections that really need traffic lights can be dangerous and downright unsafe for blind and sighed pedestrians alike, not to mention the people in the cars.

For the reasons stated above, I am convinced that the proposed APS guidelines will cause more safety problems than they will solve.

Detectable warnings

So-called detectable warnings -- speed bumps for the blind -- are rarely helpful and therefore rarely necessary. Yet, the proposed guidelines would put these bumps at almost every intersection. What a massive waste of money! The only time they are helpful is when the transition from sidewalk to street is flat, or virtually so. That's the only situation in which the Access Board ought to consider requiring localities to put in these bumpy surfaces.

I very much appreciate your consideration of my comments.

Sincerely,

Charles S. Brown