Dear Members of the Access Board:

I am writing to you regarding the regulations currently being considered regarding accessible pedestrian signals (APS) and detectable warning strips on curbs for blind pedestrians. I am thirty-one years old and have negotiated intersections safely with a white cane and using skills I have learned to listen for traffic patterns and determine when it is safe to cross, and as a general rule I am opposed to the use of APS devices because most blind people have been trained in such skills and can travel safely without them.

About twelve years ago I had the opportunity to visit Helsinki, Finland, which has audible traffic signals at every intersection. I found walking through the city extremely annoying because of the constant beeping coming from every corner. The signals were apparently intended to make different sounds for when it was safe to walk and when it was not, but it was impossible to determine which sound was supposed to indicate which condition without listening to the traffic patterns, which in turn could not be heard over the noise of the signals. In addition, because the signals were on every pole at a given intersection and every controlled intersection in town, it was virtually impossible to hear where a given signal was coming from let alone determine its meaning. I shudder to think what might have happened to me had I needed to rely on all the beeping to negotiate traffic safely. As it was I had sighted colleagues with me and took their cues on when it was safe to cross.

Since the regulations currently proposed contemplate audible traffic signals at every major intersection, I urge you to reconsider the effect this will have, not only in terms of expense but as a matter of the safety of blind pedestrians, whose best interests the regulations are intended to serve. As a general rule, a blind person who has been properly trained can identify when it is safe to cross at an intersection by listening to the sounds of traffic. The rehabilitation system is in place to provide such training, so it is available to all blind persons. As cities continue to grow and some intersections become more complex, there may be situations where a pedestrian signal is warranted. If this is the case, the signal should vibrate instead of beeping. if such signals are placed in a consistent location at every intersection where they are deployed, there should be no need for a "locator tone" in order for a blind pedestrian to find and operate them.

I am also opposed to the use of detectable warning strips to indicate curbs, the edges of subway platforms, and the like. Even at intersections with curb cuts, the slope leading to the street is readily detectable with a white cane, and detectable warning strips should only be used where this is not the case. The National Federation of the Blind has proposed language regarding when the slope may not be detectable and some warning may be required, and this language should be used in regulations and detectable strips should only be used where the recommended slope applies. This will save a great deal of public money while still insuring the safety of blind pedestrians.

Please consider all of the above carefully as you consider the proposed regulations. the proposal as currently drafted is not only unnecessary, but may actually prove detrimental to the health and safety of blind pedestrians throughout the nation. Thank you for your attention, and do not hesitate to contact me if you have questions.

Sincerely:

Christopher Stephen Danielsen