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Here are the comments of the National Federation of the Blind of Minnesota regarding the draft rule for ATS's and detectable warnings.Joyce Scanlan, President National Federation of the Blind of Minnesota

NATIONAL FEDERATION OF THE BLIND OF MINNESOTA

Dear Access Board members:

The members of the National Federation of the Blind of Minnesota (NFB of
Minnesota) have carefully reviewed the draft rules on Audible Traffic Signals and Detectable Warnings issued for comment by the Access Board. We find the proposed rules to be absolutely unacceptable for the following reasons:

First of all, the members of the Access Board who proposed these rules are completely off track in their presumption that blind people need or will somehow be assisted by audible traffic signals at all pedestrian intersections with “walk/don’t walk” signs and by truncated domes at intersections with a slope steeper than 1-15 at street intersections and alleys as we go about our daily activities. I personally know thousands of people who are blind and have concluded that with proper training, blind people can travel about independently and safely in their communities and throughout the world. Any blind person who would claim a need for detectable warnings and audible traffic signals has obviously not had appropriate training. The millions and millions of dollars needed for ats’s and detectable warnings would more appropriately be designated for training to avoid the unnecessary expense of these two accessibility gimmicks.

Second, the cost of installing audible traffic signals and truncated domes in the manner proposed by the Access Board rule is exorbitant and beyond reason. Any city or municipality would have tremendous problems coming up with the necessary funds to carry out the responsibilities required in the proposed rule. With public attitudes toward blindness as negative as they are in our society, this rule would simply say to all public officials responsible for implementing the rule that blind people are incompetent, unsafe, and unable to participate in the community on an equal basis with their sighted peers. This rule would lead to unemployment and further lack of acceptance for blind people in our society. The extremely high price for ats’s and detectable warnings would cause resentment and exclusion of blind people from the mainstream of the community.

Third, blind people would become segregated from the sighted. The ats’s and truncated domes would be where blind people would be expected to walk, and other intersections where there were no ats’s or detectable warnings would be for the sighted citizens. This rule is disrespectful of blind people’s right to make their own decisions and choose their travel routes in the community. Blind people are fully capable of being integrated into the community rather than ghettoized or isolated from the mainstream.

Fourth, ats’s and truncated domes present safety hazards for blind people. We rely upon our ability to hear clearly the sounds of the traffic in the streets. Adding eight constantly beeping locator poles and four chirping or loudly beeping traffic signals in one intersection will confuse the sound pattern and block out the much-needed sounds of the moving traffic. The blind person is expected to follow the ats’s, which are consistent and loud, while the traffic sounds are less consistent and greatly drowned out by the ats’s. Drivers cannot be counted on to pay heed to traffic lights. The ambient noise level of the beeping locators and the ats’s make crossing the street a potential danger to a blind person who may not be able to hear and sort out the actual traffic sounds.

Also, the truncated domes at intersections and alleys will cause potential danger for many elderly people, as well as for those with other disabilities. Women wearing shoes with high or large heels, individuals with balance problems, and people in wheelchairs will find truncated domes to be a veritable safety hazard. While the claim is that these domes are for the benefit of the blind, blind people gain nothing from such domes, and many others are seriously harmed by them. Furthermore, weather will be a major problem in states such as Minnesota, where fall leaves from trees, snow, and slick ice will cause pedestrians to trip or fall or sustain serious injury. By their very nature, the truncated domes become collection areas for street debris. These domes themselves are not safe, do not promote safety of anyone, and have no value in helping blind people either gain accessibility on the public streets or earn the respect of the general public.

The rule as proposed is far out of proportion to the benefit from either ats’s or truncated domes. We do not claim that these devices should never be used at all. We submit that there may be intersections with inadequate nonvisual clues to permit a person who is blind to determine by the traffic when it is safe to cross. In these instances, ats’s might be requested, and the local municipality can make an informed decision based on the specific intersection. The extreme rigidity of the draft rule as proposed makes the implementation of the entire rule unworkable.

Thank you for the opportunity to comment on this draft rule. We sincerely hope the rule as proposed will not become the rule as implemented. Blind people do not want or need a costly, unsafe, and unhelpful system causing more segregation of the blind and more resentment toward blind people than our society already has. Please give careful thought to what is practical and useful, cost-effective and reasonable. This rule as proposed has no value whatsoever.

Joyce Scanlan, Executive Director
Blindness: Learning In New Dimensions (BLIND), Inc.