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Please consider this to be my comment regarding the proposed rules by the Access Board. I oppose the proposed rules for audible traffic signals and detectable warnings as they are written.

My name is Jim Marks. I reside at [ ... ]. I am blind and have been a user of the long, white cane for about twenty years. My opposition to the proposed rules stem from my personal and professional experience, which includes participation in local, state, and national activities of the National Federation of the Blind and employment as the Director of Disability Services for Students at the University of Montana-Missoula. In addition, I serve as the Chairman of the Special Interest Group on Blindness and Visual Impairments, a committee of the Association on Higher Education And Disability. I am very familiar with the Access Board and it excellent work in establishing guidelines for accessibility by people with disabilities.

I oppose the proposed rule for audible traffic signals and for detectable warnings because the rules require their installation at every traffic light and curb ramp. While there may be cases when the audible traffic signals and detectable warnings are useful, they are not necessary for me to travel independently and safely at the majority of places where these features will be installed should the proposed rules be adopted as written.

I believe that most audible traffic signals do more harm than good because they clutter the environment with distracting and unwanted sounds. Many assert that the audible signals enhance safety, but my experience is that they create safety problems. In fact, the Missoula Chapter of the Montana Association of the Blind asked that an audible signal that was improperly installed be turned off. We did get the audible signal turned off, but it took a lot since traffic signals in my city of about 100,000 people fall under the jurisdiction of the state Department of Transportation rather than city or county governments. The audible signal in question is the only such audible signal in town, and is located near the state agency for the blind office. The signal was malfunctioning in that it told pedestrians to proceed at the same time it told vehicles to turn right without stopping. Several of us experienced near misses because it is easy to be lulled into the notion that the chirps and beeps indicate when it's safe to cross. Nothing replaces paying close and intelligent attention to the traffic noise and other non-visual indicators in the environment. The audible tones actually interfere with what one must pay attention to to cross the street safely. If the Access Board insists on putting in non-visual indicators, then let them be of the vibro-tactile type. These accomplish the same ends and even assist those who are hard of hearing as well. However, I feel strongly that the installation of any such device be rooted in verifiable and objective evidence that the device does what it is intended to do. For the most part, I believe that audible traffic signals are an answer in search of a question. Where is the evidence that they provide any margin of safety and access? And speaking of access, I've often heard the fallacious argument that blind people should have access to what the sighted have. This oversimplifies what's at stake. Blind people do things in blind ways. We are blind, not sighted people who can't see. Instead of relying on visual cues, we rely on alternative techniques to do what the sighted do. Chirps and beeps in the environment don't improve access for us while good training rooted in can-do attitudes really does improve access.

Detectable warnings are not quite the danger to me that audible signals are, but I do oppose them because I don't see any evidence they are necessary. Perhaps in some instances, when the transition from the sidewalk to the street is so flat that I cannot detect the change, then the detectable warnings should be installed. Normally, there are plenty of cues that tell me where the sidewalk ends and street begins. So it seems silly to require their installation at every curb ramp. In addition, I live in snow country. It is likely that the detectable warnings will interfere with the effective removal of snow, thus creating a problem of safety for everyone.

Thank you very much for taking my comments.

Jim Marks