Michele Gittens

October 28, 2002

Dear Access Board,

I am writing in regards to the June 17, 2002, United States Architectural and Transportation Barriers Compliance Board (Access Board) d draft guidelines. These guidelines would 1. mandate audible traffic signals (ATS) at all intersections with "walk/don't walk" signs; and 2. require detectable warnings to be placed at every street crossing without exception. As a blind person with competent blind traveling skills, I find these guidelines to be unnecessary and in some cases very 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.

More importantly, this process is very expensive. Tax payer dollars could be better utilized by equipping blind people with the training necessary for one to travel safely and independently.

Thank you for your time.

Respectfully,

Michele Gittens