I am writing to urge you in the strongest terms possible to adopt strong language in the Public Rights of Way Accessibility Guidelines for Detectable Warnings and Accessible Pedestrian Signals. As a person who is blind, I assert that any weakening of the language as studied and adopted by the Public Rights of Way Advisory Committee would jeopardize my safety and the safety of those like me. This cannot be allowed to happen.

For almost 10 years, detectable warnings in the form of truncated domes on railway and subway platform edges have provided full access to the same visual information sighted persons have had all along. I regularly use commuter rail, subway and L trains in the Chicago, Illinois area. I am regarded by many as having excellent travel skills using the white cane. Yet, I find that I move about with more confidence on platforms where detectable warnings are installed than on those where they are not.

Contrary to what some might insinuate, detectable warnings are not a substitute for good training. I still must use my good judgment and sound travel skills even when detectable warnings are present. I must still concentrate and be aware of my surroundings at all times. Just a couple of years ago, I was on a rail platform that had detectable warnings. I had something else on my mind and was not paying attention to my traveling as I should have been. I almost walked right off of the platform edge and into the railroad bed. Had I done this, it would have been my fault.

The detectable warning is simply that, a warning to tell me I'm getting close to the edge. Sighted people have different colored lines on platforms to tell them when they are getting close to the edge. The detectable warning is my "different colored line." If I don't need detectable warnings, then please tell me why people who can see need a different colored line at the platform edge.

Accessible Pedestrian Signals provide me as a person who is blind assurance that it is safe for me to cross a street, particularly at a heavily traveled intersection. With urban sprawl, increased traffic, wide, busy streets and other factors, installing these signals is more important than it has ever been. Again, just because an accessible signal is present DOES NOT mean I can forget about using sound travel skills and judgment; I cannot. If I am at an intersection where an accessible signal is present, and that signal tells me it is safe to cross, but there is a car sitting in front of me in the crosswalk, I most certainly will not cross until that vehicle moves out of my way.

Some say accessible signals cost to much. I say two things. First, how can you put a price on a human life? And second, it costs about $75,000 to provide regular signals at intersections. It only costs about $4,000 or about 5.46% additional to install accessible signals. Furthermore, according to the Transportation Equity Act for the 21st Century, 80% of the cost for accessible pedestrian signal installation near public transit facilities can be paid for with Federal dollars.

Today's accessible signals are not annoying like those of the past. The audible locating tones they emit to help a pedestrian who is blind find the push buttons are only audible from 6 to 12 feet away. And, today's signals adjust ambient sounds. So, if there is a lot of traffic which would be just as annoying to surrounding neighbors, the signal's volume increases. When it's quiet, the signals's volume decreases.

Some will tell you that we can rely on just the traffic flow to determine when to cross the street. If that's the case, then why do sighted people need walk and don't walk signs? The accessible signal is our walk don't walk sign. Furthermore with increased traffic as I already mentioned, distracted drivers, quieter cars and right turn on red, being able to use an accessible signal to know for sure that it is safe to cross is critical to my safety. In fact, these signals not only benefit people who are blind, but they also are of value to Senior citizens, small children and people with other disabilities. And to those who would say we do not need them, I say fine, you don't have to use them.

There is a major 4 to 6 lane street with a lot of traffic on it that runs through the community where I live. The street is home to many stores, restaurants and other businesses. If I want to patronize many of these businesses, I must be able to cross this major street. An accessible signal would make crossing this street much easier for me as I would have the assurance that I am crossing when I am supposed too.

It's not just nice to have detectable warnings and accessible pedestrian signals. It's a matter of personal safety and equal access to the built environment for people who are blind. Again, I strongly urge that the Public Rights of Way Accessibility Guidelines come out in their final form with very strong requirements for the installation of both detectable warnings and accessible pedestrian signals. The lives of people who are blind depend on it. Thank you very much in advance for your time and for taking my comments.

Sincerely,

Ray Campbell

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