Richard A. Gaffney

October 4, 2002

Dear Board Members:

I am writing on behalf of the National Federation of the Blind of Rhode Island which is the largest consumer organization of blind people in the state. I am concerned about the placement of audible traffic signals and detectable warnings. I believe the proposal by your Board is excessive and could indeed make traffic crossings more 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.

The draft guidelines call for detectable warnings whenever a sidewalk (including a median or island) joins a crosswalk. However, this is not necessary to provide accessible and safe travel for the blind. There are adequate cues available to detect the transition from sidewalk to street. Therefore, detectable warning should only be installed when the slope is virtually flat, referred to as 1:15 or flatter--one inch downward for every fifteen inches of sidewalk.

With proper training blind people can cross streets by monitoring traffic flow. Unless the Board’s proposal includes every street in our nation, blind people have to still use these techniques. What is most important to remember is that all the ATS will not prevent a blind person to detect a car which did not stop when the light is red.

Sincerely,
Richard A. Gaffney
President NFB of RI