Dear Access Board members,

This concerns accessible pedestrian signals (APS’s) and detectible warnings.  The Access Board proposal regarding APS’s and detectible warnings are extreme and generally unnecessary.  In the vast majority of situations we are able to travel competently without such costly modifications to our environment.

Many of us believe there is no situation that calls for an accessible pedestrian signal, and our resolutions contemplate their use only in limited situations.  We must  putting real limits on the use of these devices.  They should only be used when traffic patterns do not provide the clues we rely upon to know it is safe to walk.

Accessible pedestrian signals should never be used to provide directional guidance.  Many proponents of these devices argue to the contrary.  However, there is no support for this assertion, and those who seek to rely upon APS’s for directional guidance are risking their safety.  This is why NFB resolutions only permit vibrotactile APS’s in those situations where one is appropriate.  Such devices inform the blind pedestrian that it is safe to walk and nothing more than that.

No research exists regarding the effect of locator tones for every APS on blind pedestrians.  Those who use dogs want an easy way to locate the APS, but the effect all this extra noise will have on the ability of all of us to travel safely has never been considered.  For the average intersection, there will be 8 beeping points of sound over the general traffic noise making it exceedingly difficult to judge traffic.  In addition, the draft guidelines require consistent placement, which should make locator tones unnecessary.  Not only are the tones unnecessary, they may well prove to be exceedingly unpleasant for many.

These guidelines also require detectable warnings at every crosswalk.  Our resolutions state that detectible warnings should only be considered if the slope of the curb ramp is 1-15 (1 inch of rise or fall for every 15 inches of run) or flatter.  Anything with a slope greater than 1-15 is readily detectable with or without a cane.

We want our views to be considered.

Best Regards,
Michael Kasey
President
Fredericksburg Area Chapter NFBV
 

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