John Glisson

October 7, 2002

I am writing this to express my opposition to the current proposal by the Access Board to establish regulations regarding Accessible Pedestrian Signals and Detectable Warnings. I believe the current proposal is to the extreme and for the most part unnecessary. Blind White Cane travelers are well trained to travel safely and competently in the majority of environments without such. If there is a standard developed across the nation, it should be used as an exception and not the rule. It should not present a dangerous distraction to pedestrian travel, and it should certainly be cost effective.

Firstly, I understand that the "Truncated Dome" is being considered as the Detectable Warning. I am a totally blind White Cane traveler, and I have found these domes of absolutely no value. I have not been able to discover its whereabouts in order for me to locate the danger. The cost, also, is absolutely outlandish and unthinkable to have these on a consistent basis across the nation. In addition, as I have studied this very subject, I find individuals who use wheelchairs and other mobility aids to consider the dome itself an item of danger.
Other detectable warning devices exist that are cost effective and safe for the general pedestrian traveler.

I believe the proposed guidelines require the detectable warnings at every cross-walk. I don't believe that is practical. Any surface with a slope greater than "1 to 15" (1 inch of rise or fall for every 15 inches of run) or flatter is readily detectable with or without a cane.

Secondly, the issue regarding "locator tones" for Accessible Pedestrian Signals seems to me to be extremely impractical. Only under extreme circumstances concerning intersections should a signal tone be installed. They should only be used when traffic patterns do not provide the information we need to know it is safe to walk. Accessible Pedestrian Signals provide no directional information whatsoever, and the locator tones for such can cause great confusion and dangerous distractions.

I can't imagine approaching an intersection with a minimum of 8 tones beeping at the same time, me attempting to read the traffic for my safety, along with other tones that could be present radiating from a variety of types of vehicles. It seems to be simply more dangerous and impractical for certain if any type of standardization for consistency is developed. To my knowledge, research does not even exist regarding the effect of Accessible Pedestrian Signals with locator tones for blind pedestrians.

Thank you for reviewing my remarks.

Sincerely,
John Glisson, Vice-president: Lexington Chapter
Kentuckiana Regional Group of the Blinded Veterans Association