Noel Nightingale

September 28, 2002

I am writing to oppose the aspects of the Access Board's proposed rules regarding pedestrian rights of way that cover audible traffic signals and detectable warnings.

I am a blind person who travels with a long white cane. I live in Seattle, Washington, and travel independently (without sighted assistance) on a daily basis, including in unfamiliar settings.

I do not believe that requiring the installation of audible traffic signals everywhere would be a reasonable use of taxpayers' funds. Instead, municipalities should be given the freedom to install such devices where there is sufficient ambient noise that nonvisual cues are not present or where the traffic patterns involve extraordinarily complex street patterns.

Moreover, detectable warnings in every street corner would be a waste of limited public funds. We do not need them in ordinary circumstances. Only where it is so difficult to ascertain where the sidewalk ends and the street begins, in areas where the sidewalk has been flattened as to be almost uniform with the street, should they be installed.

Finally, if such audible traffic signals are to be required, they must be tactile instead of audible in delivering the information. Tactile signaling would avoid the confusing cacophony of sounds that would be emitted by the audible traffic signals and would allow their use by deaf-blind travelers.

I urge that you do not adopt the proposed rules as written with regard to audible signaling and detectable warnings.

Noel Nightingale