Juan Montelongo

October 28, 2002

To the Access Board-

I am writing to express my displeasure with the draft guidelines as issued on June 17, 2002, and to submit my recommendations for changes to the guidelines. The draft guidelines include language that would require modifications to be made to the environment in order to facilitate safe travel by blind people throughout the country. While this is a worthwhile objective, blind people do not need environmental modifications to be able to travel safely, as evidenced by the tens of thousands of blind people that travel safely everyday using the environmental cues currently available.

More specifically, the draft guidelines call for installation of tactile warnings and audible traffic signals at almost every intersection in the United States. These kinds of modifications are not necessary, and may result in making travel for the blind more difficult by masking the environmental cues, such as traffic noise and curb cuts, with artificial cues.

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.

Most intersections do not require an ATS for the accessibility and safety of blind pedestrians. Only those intersections with complex geometry, complex signalization, or varied signalization for each lane may be appropriate for an ATS. Vibrotactile indicators should be used in preference to audible signals in order to minimize noise distractions and promote safety. Locator tones should not be included in the final guidelines and may be subject to further research.

At most intersections the built environment provides ample accessible cues to determine the difference between the sidewalk and the street. A slope of less than 1:15 in crossing from the sidewalk to the street (including medians and islands) may not be detectable and should be identified with a detectable warning.

I appreciate your attention to this matter, and I further urge you to modify the guidelines in such a way that the concerns I mentioned above are addressed.