This will follow up the oral testimony I presented at the Public Hearing, regarding Draft Guidelines on Accessible Rights Of Way, which the Access Board held on Tuesday, October 8, 2002, at the Downtown Hilton, in Portland, Oregon. Over the past thirty years, I have held many positions in the National Federation of the Blind of Illinois and its Chicago Chapter. I now serve as First Vice-president of the Chicago Chapter.

I have been blind all my life. Therefore, as a young blind child, growing up in Chicago, I had many enjoyable, exciting experiences traveling throughout this city. I realized that I could lead an active, productive live, full of self-sufficiency and independence, walking through this city and riding its transit systems. I had cane travel instruction in Chicago during the spring and summer of 1964. Since then, I have traveled extensively throughout, Chicago, Illinois, many other states, as well as several other countries. I use many characteristics of the environment all around me, sounds, textures, smells, as well as a good sense of direction, to travel safely, competently and efficiently. Therefore, it never crossed my mind that blind people would not modifications of the built environment, specifically for our benefit until I heard such discussion as an adult during the 1970s. Thus, I strenuously oppose proposed requirements of the Draft Guidelines on Accessible Rights Of Way, calling for detectable warnings, truncated domes, at all curb ramps and crosswalks, also accessible pedestrian signals at all signalized intersections.

At many intersections, I routinely use the curbs to either side of the ramps as a reference to align myself for a straight and safe street crossing. Further, the contrast between the concrete sidewalk and asphalt street pavements often provides tactile and auditory cues which I feel and hear through my cane tip and shoes. The combination of ramps down and up on both sides of the street and the crown of the roadway, slightly up toward the center for drainage, also tells me that I am crossing the street, when I have no traffic sounds to inform me. Using a long fiberglass cane, I like to walk in a relaxed fashion, with grace and finesse. I tend to walk straighter at a moderate to brisk pace. Unfortunately, I have found that truncated domes, heavily grooved surfaces or other textures, ostensibly to benefit blind people, obstruct my cane, tip to the point where I risk either losing my cane from my hand or having its handle jab me in the stomach. Additionally, I have encountered snow and ice in truncated domes, adjacent to completely dry pavement, on outdoor rail station platforms. Therefore, I support the position of the National Federation of the Blind, calling for truncated domes only on slopes of 1 in 15 or less. Perhaps, as other commenters suggested in oral testimony, other treatments might suffice, however, only on very shallow slopes or completely flat surfaces.

As for accessible pedestrian signals, I have heard several demonstrated in quiet meeting rooms, such as the one where this public hearing took place. Indoors, meeting participants were seated, not traveling through an intersection. Moreover, the presenters of these signals played only one locator tone, not several at a time, which pedestrians would hear at an intersection, corresponding with all its crosswalks. Also, outdoors in vehicular traffic, sounds mix, echo and dissipate more than in a meeting room.

I first heard an accessible pedestrian signal at a real intersection with a mobility instructor in Silver Spring, Maryland a little over a year ago. As I approached, I heard the locator tones, corresponding to the crosswalks.

I told her, "I'm confused."

She replied, "I'm confused about why you're confused."

I replied, "It sounds like a stereo video game."

She asked, "Is it too loud?"

I answered, "That's not the problem. It's not too loud. It's too busy." I need to hear the all-important traffic sounds to cross streets safely and reliably, especially: Vehicles moving parallel to my direction, vehicles stopped perpendicular to my route and none turning in front of me. A few months later, I walked through an intersection with similar signal equipment in downtown Baltimore. At both these locations, I found the process of stepping out of the crosswalk and turning toward the box on the pole to press arrow-shaped button a distracting diversion. As I approach an intersection or wait for the green light, I use the sounds of perpendicular and parallel traffic to orient myself to the direction I wish to cross the street. Thus, I orient myself physically by using my cane and listening to traffic. I do not wish to disrupt this orderly process and risk making mistakes crossing streets because of extraneous and disorienting movements.

Vibro-tactile signals at pedestrian-activated signals, where all pedestrians press a button to get a green light, would confirm the actual change of light to a blind pedestrian.

I am seriously concerned that allocating limited resources to expensive and largely unnecessary modifications, such as truncated domes and accessible pedestrian signals, will divert attention and funding away from the usual sidewalk and street repairs, as well as the purchase and maintenance of transit buses and trains, that benefit all citizens of and visitors to cities. I also fear that these features promote negative attitudes about blindness in the community and that employers would become less likely to regard blind people as able, competent members of the work force. I concur with the positive philosophy of the National Federation of the Blind that, given proper training and opportunity, blind people can compete on terms of equality with their sighted colleagues. Therefore, I strongly urge the Access Board to rescind the proposed requirement, calling for these features at all intersections and instead to adopt a much more reasoned and restrained requirement, calling for them only in very limited circumstances, with the advice and consent of blind people generally, and the National Federation of the Blind in particular, in the affected locales.