To whom it may concern:

 I am writing to urge you to reconsider your proposal concerning accessible pedestrian signals and detectable warnings for the blind.  I believe the guidelines set forth in this proposal are extreme and generally unnecessary for the majority of blind travelers.  Many travelers, including myself, are able to navigate intersections safely by listening to the traffic patterns around us.  Audible traffic signals should only be used in those rare cases when the traffic does not provide reliable auditory information that indicates when it is safe to walk.  I further believe that fibrotactile warnings are not necessary at every intersection.  I believe that they are applicable only at intersections where the slope is 1-15 (one inch of rise or fall for every 15 inches of run or flatter.)  Anything with a slope greater than 1-15 of an inch is readily detectable, with or without a cane.  I live in Nebraska where snow and ice are both very prominent during the winter months.  These tactile signals would be rendered useless by such conditions.  I also believe it is a mistake to consider these tactile signals as directional aids.  This could prove dangerous for blind travelers and they should only be used to indicate when it is safe to cross an intersection, if they are used at all.  The guidelines outlined in this proposal will be very expensive and will ultimately prove to be unnecessary and irrelevant for the majority of blind travelers.  Therefore, I strongly urge you to withdraw this proposal.

I am writing to ask you to reconsider your proposal regarding audible traffic signals and vibrotactile warnings.  The guidelines you have set forth would require the implementation of these signals at every intersection.  This is an extreme measure that does not justify the high cost that will be involved.  The Majority of blind pedestrians are competent travelers who are able to safely cross intersections using the traffic patterns as sound cues.  The noise created by these signals would obscure the sounds of the traffic and might prove more dangerous to us.  I also believe that the assertion that audible signals can be used as a directional aid is a false one.  The eight beeping points that would be generated by APS at each intersection would only be confusing and hazardous to our traveling ability.  Furthermore, there is no research currently in existence that demonstrates the effect of audible signals on blind pedestrians.  Your guidelines would require consistent placement of these signals, which should make the locater tones unnecessary.  These tones would also prove to be exceedingly noisy and unpleasant for many pedestrians, whether they are blind or sighted.  For these reasons, I strongly urge you to abandon this proposal.

Sincerely,
Jane Elder

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