National Federation Of the Blind, Denver Chapter

October 6, 2002

National Federation Of the Blind
Denver Chapter
Jeremiah B. Beasley, President

Architectural Transportation Barriers Compliance Board

Greetings:

I am a blind person now living in Colorado. I write to raise concerns that I have regarding the Board's draft guidelines which were published in the Federal Register in June of this year.

First it is my understanding that the Board's proposes a standard which would require accessible pedestrian signals (aps's) at any intersection with pedestrian signalization. In my view, this proposed standard is far too broad. Blind individuals are able to function well and safely in the vast majority of intersection and need no other assistance, in addition to the non-visual cues present in the existing surroundings.

I am also very concerned about the fact that each APS will be outfitted with a locator tone. As long as Aps's, when they are necessary, are placed in or near to a uniform location, there is no need for this tone. The tone is potentially dangerous because it will throw extra and unnecessary noise energy into the intersection and possibly mask the sound of traffic. Listening to traffic is the most crucial skills the blind use to navigate intersections safely.

The Board also proposes to adopt a standard which would require detectable warnings at every intersection. Once again, this is an unnecessarily broad standard. If the slope of the intersection is 1:15 or greater, a blind person can detect the downward slope as they come to the intersection. Therefore, detectable warnings should only be placed at intersections that are, in effect, flat.

If the Board's guidelines are adopted as drafted, I am fearful that the ultimate result would hurt blind and visually impaired people. First, in some cases, it may create additional hazards like putting too much extra noise into the intersection. Second, the proposed guidelines would cost billions of dollars to implement, taking scarce public money away from other projects which are of more benefit to the blind. In conclusion, I support the positions advanced in the Minority Report to the report of the Public Rights of Way Access Advisory Committee filed by the National Federation of the Blind.

Very truly yours,


LINDA C ANDERSON
TOM ANDERSON
EDDIE K *ILLEG*
ALICE BOYD
MARK CARTER
CHARLES C COOK
MARY CULLUM
CHRISTINE DANIEL
FRED DYER
CHERYL FOGLE
ANGELA FOWLER
JOE GOODE
BETH HATCH
DAVID HYDE
NANCY HYDE
LISA ISON
ARTHUR JACOBS
ELAINE KAYGANICH
MARY K LARSON
CONNIE LABLONDE
ZANE LASLEY
JOHN C LANG
PAUL P LAWRENSON
JOE LENNINGER
GREG MALL
MICHAEL MASSEY
DIANE MCGEORGE
ROY MCGEORGE
BETH MILLER
JIM MISENER
B PHELPS
WILLIAM PRICE
MARTY RAHN
PORTER PHELPS
WILLIAM SAHI
KAREN SAMULSON
ROBERT SANTO
RUTH STEWART
BILL SCOTT
SAMARA SHAKEEL
LORRAINE THOMPSON
TIER WOHLER
CURTIS WILLOUGHBY
DORIS M WILLOUGHBY
THOMAS WOODS
BRIDGET WORLEY
KEVIN WORLEY
ARTHUR ZACHARY