Reference: Audible Traffic Signals and Detectable Warnings.

COMMENTS:

• Most intersections do not require an ATS for the accessibility and safety of blind pedestrians.

• Only those intersections with complex geometry, complex signalization, or varied signalization for each lane may be appropriate for an ATS.
• Vibrotactile indicators should be used in preference to audible signals in order to minimize noise distractions and better promote safety. 
• Locator tones should not be included in the final guidelines and may be subject to further research. 

• At most intersections the built environment provides ample accessible cues to determine the difference between the sidewalk and the street.
• A slope of less than 1:15 in crossing from the sidewalk to the street (including medians and islands) may not be detectable and should be identified with a detectable warning.   

I urge the Access Board to reconsider the recommendations made in the recent draft guidelines.

Respectfully,
Thomas Ghrigsby