Sharon Gold

October 15, 2002

Members of the Access Board:

I am writing to you on behalf of the members of the Greater San Antonio Chapter of the National Federation of the Blind of Texas.

We are in opposition to the Draft Guidelines proposed by the Architectural and Transportation Barriers Compliance Board, which would require detectible warnings at all intersections and audible traffic signals at all intersections with walk/don't walk pedestrian signals. Audible traffic signals and tactile warnings should only be considered when factors in the environment, including complex streets and traffic patterns, make knowing where and when to cross difficult or impossible.

For years, blind people have traveled safely throughout our country without modification to street crossings. Normally, non-visual clues are available for safe travel. These non-visual clues include, but are not limited to, the parallel and cross movement of traffic -- both vehicular and pedestrian, as well as curbing and other features of the environment.

The proposed guidelines are not necessary to ensure safe travel for blind pedestrians. In fact, they have the potential to make street crossings less safe by masking normal traffic sounds and replacing them with added mechanical noise.

The use of locator tones as well as tones for the walk/don't walk sign has the potential to cause confusion and throw a blind person off course as an intersection can have eight or more tones sounding simultaneously. These tones won't be helpful to blind people and they will be an annoyance to the public and to the citizens living or working near the crossings.

At crossings where there are insufficient non-visual clues for safe crossing, vibrotactile signals should be installed. Vibrotactile signals will ensure blind persons of receiving information necessary for safe crossing without adding noise to the environment and will allow blind people to continue to hear the traffic and other sounds currently used for safe crossing. Vibrotactile signals will augment safety rather than decrease it with the use of auditory signals.

Detectible warnings should only be installed at intersections where the transition from sidewalk to street is flat. Curbing and the changes in texture of sidewalks and street paving are usually sufficient enough for blind persons to safely cross.

The installation of unnecessary detectible and audible signals at all intersections is a waste of public money. The money saved by the elimination of unnecessary expense on these frivolous devices could be better spent on the training of blind persons in mobility skills. This would allow blind persons to safely travel all the streets and by-ways of our country rather than only those supposedly protected by audible signals and tactile warnings. Futher, this training would assure blind people safe independent travel at times when mechanical devices fail.

The members of the San Antonio Chapter of the National Federation of the Blind of Texas urge you not to issue final guidelines with provisions as extreme as the current draft.

Cordially,

Sharon Gold, President
Greater San Antonio Chapter
National Federation of the Blind of Texas