Dear Members of the Access Board,

I am writing to object strenuously to the rule you are considering concerning accessible pedestrian signals and truncated domes.

I lost my sight in Viet Nam. When I returned to this country, sick and weak, the Army sent me to its rehabilitation facility. I was still in the service at the time. In other words, The Army believed that, before it discharged me, it should teach me how to live competently as a blind person. It did so, whether I wanted to learn or not.

The Army was right. I needed those lessons in doing things without sight that I used to do with sight. I am appalled and aghast at the idea now being put forth by some blind people in this country that there is no need to learn such techniques, that some people will be too shy or scared to learn them, and that the techniques don't work anyway so the world has to be re-built. I went to war for our country and lost my sight for our country and learned to be a capable person at the insistence of our country. Now you're going to require my tax dollars to be spent so that people who have never had the kind of experience I had in Southeast Asia and who just want to complain that it's awful hard to be a blind person these days can feel safe in their homes? Not if I can help it!

You just don't get it, do you? These same people who are telling you how very, very hard it is for blind people are of two kinds: (1) sighted people who have made a career of taking care of the blind and who need new, broader fields for the taking care; and (2) blind people who are playing on your sympathy and who won't be walking out there in the big bad world by themselves anyway because they don't have the training and self-confidence to get to that first corner. My goodness, how credulous can people be? I suppose the basic instinct is kindness, the wish to help one's fellow humans. For that, I suppose I should be grateful since the milk of human kindness seems to have stopped flowing altogether in parts of our world.
But the milk of human kindness that declares me and all blind people helpless without billions spent on re-building the environment is a curdled product indeed.

I have been walking around our country and using a cane or guide dog since 1966, and I have yet to find an intersection that I (1) couldn't find; and
(2) couldn't cross safely. So, why do we need these accessible pedestrian signals and truncated domes?

I understand some people say that it's a matter of civil rights: Sighted people have lighted signs, so blind people must have audible ones. Just a matter of civil rights. Baloney. That cheapens the civil rights my
generation fought hard to achieve in the sense of racial and gender
equality. When a kid can't use a bathroom because of color; when a young adult can't read due to racially segregated education; when a woman can't be promoted due to gender, those are civil rights issues: making distinctions in law or policy based on an irrelevant and immutable characteristic to the detriment of the person with the characteristic.
When a blind person reaches an intersection, there is no civil rights issue. There's a simple informational issue: Can he or she find the edge of the street and know when to cross safely? In the overwhelmingly vast majority of cases, the answer is yes under present conditions. No civil rights; just someone lying to you if they say otherwise.

I am especially offended by the idea that we blind people cannot find corners without truncated domes. Which blind people? Nobody I know. And I know lots and lots of blind people. They don't talk about not finding corners. What they talk about is wanting jobs, wanting promotions, wishing a certain person would marry or divorce them, wishing their children would shape up, rejoicing in their children's successes and offspring, liking or hating the latest movie or TV show, and where the best restaurant can be found. In other words, they talk about what everyone else talks about.
They get to work, get their kids to school, find the restaurants, and pay taxes. Oh, yes, taxes. It is immoral and wrong to propose the spending of my tax dollars and those of my fellow blind persons on truncated domes so we can find intersections we can already find. How dare anyone propose such an unreasonable and wasteful federal requirement? We are a nation at war with a slippery and elusive enemy, and that war may widen. How on earth can anyone seriously propose re-building the world to solve a problem that doesn't exist when we have more pressing national priorities, such as war and poverty and literacy and health care? It's mind-boggling.

Where's your evidence that blind people can't find street corners? What will we as a nation have to give up for this ridiculous requirement? How much will it cost? What will it achieve, given that we blind people are already finding the corners as they are?

When a city chooses to pour an intersection and its surrounding sidewalks flat and all at once, I can recognize that, in that instance, the street-sidewalk interface is not obvious to me and other blind persons.
But only then. And, I'm guessing this trend will pass as I still can't figure out and I bet they haven't either how they're going to guide and capture street run-off water. Crowned streets are crowned for a reason:
to guide water. And they give me information. Gutters exist for a reason: to guide water to its final resting place. And they give me information.
Sidewalks poured flat with the intersection are likely to be ponds during rainstorms. Some separation of street and sidewalk is not only safer for pedestrians but also better for water handling. And, at most intersections, safety and water handling have left easily discernible demarcations for blind people to find an d use. I've done it for over thirty years.

Why on earth require wholesale installation of truncated domes when they're only needed at flat intersections? I suppose because some blind people have told you they can't detect intersections. Well, my question
is: How do they get to the intersections in the first place? Most blind people I've known who didn't get the training I did and who haven't tried to use their God-given brains to achieve independence don't walk alone anyway. They know they're not safe in doing so. Notice: I said "they" are not safe; not that the environment is not safe. I state categorically that the environment is safe and has sufficient cues in it (setting aside flat intersections) for blind people to use it with ease and comfort.
Anyone asserting to the contrary is merely trying to take care of the poor blind or is not using the training and talents he or she has or should have.

I only want to make two comments about accessible pedestrian signals.
One is that the intersection is noisy enough as it is. In most cases, information exists to discern the traffic pattern and to move safely through it. In those rare instances where the information is confused, it is possible that an audible signal would help, but I doubt it. Effort should be spent to figure out what factors indicate true complexity and to install signals only there. The signals should always be pedestrian-activated so that the blind user chooses whether to use them or not, and they should never, never have a constant or repeating sound to add to the noise of an intersection which now contains the information we need
to cross. This saves money, addresses the real problem if there is one,
and leaves the choice up to the blind person without blotting out the sound we do need.

The second comment I want to make about these signals is to insist that the Board insist on facts. I have heard repeated over and over that blind persons are being mowed down at a rate of 3,000 a year. Nonsense. If such carnage was occurring, we would all know about it. It's not occurring.
It's my guess that someone in an excess of zeal took the national pedestrian fatality figures and multiplied them by the percentage of blind persons in the country and then used the resulting figure as a fact. It's not a fact. This is an example of the kind of specious reasoning the Board is in danger of using to support its rule. Please, please demand from such persons the actual facts. Demand the statistics be backed up with facts instead of a mere multiplier. You'll find that the statistic is a construct and that the number of blind pedestrian fatalities is far, far lower than our proportion of the population would suggest. In fact, I have lived in my current state of residence for almost ten years, and I cannot remember a single blind person being fatally injured in a pedestrian accident here. I've casually asked others, and the figures for other states are either zero or very low. Each fatality I hear about trumpeted as yet another example of an accident that could have been prevented by an accessible signal by a small group of blind persons, when reviewed on its facts, turns out to be driver error just as with any other accident. I have yet to hear of an accident that would have been prevented by an accessible signal. They don't prevent idiot drivers, and they can mask the approach of one to the greater risk of the blind person.

My whole point in this letter is that the Access Board has been fed a great big meal of hot air by some zealous blind persons and some zealous sighted caregivers. The blind advocates of re-building the world claim that re-building will make it safe for all blind people. Nonsense. Only training like the Army insisted I take can do so. The sighted persons suggest their greater knowledge of blind persons allows them to tell you how better to take care of the blind. Well, we don't need taking care of, and we do need training.

Please take back this flawed and ludicrously excessive rule and try again. Try with real information to define those few, limited instances where information is weak or messy, and require re-building there. Leave the rest of the world alone. You'll make a much better rule, avoid creating yet more barriers for blind persons, save tax dollars, and do the job for access you're supposed to do: eliminate real barriers, not imaginary ones.

Doug Elliott