Douglas C. Boone

October 19, 2002

Please accept the following comments in opposition to the Access Board's proposal regarding audible traffic signals.

1. I am a consultant in blindness rehabilitation and as part of my services I teach O&M to both consumers and staff of rehabilitation agencies serving the blind. I have done so since 1980. Proper training (and there TRULY are differences in instructional approaches) will enable blind persons (yes even M.R. and people with other secondary disabilities excluding deaf blind), to safely cross a lighted intersection.

2. An audible signal is NOT equivalent to a "walk" sign. Having said that, consider that sighted people get hit by believing the indicator and walking, while losing touch with the environment, the key to staying safe if you are blind or sighted.

3. An audible signal can constitute ambient noise in the environment which can mask the sound of automobiles which are deviating from the rules of the road, be it running a light or other illegal activity. A sighted person can, if smart, stay in touch with the environment with vision, which is their primary source of collecting and responding to the environment. A blind person MUST rely on auditory assessment of the environment and can be as accurate as an alert sighted pedestrian. When the audible signal is introduced, it can mask the sound of traffic and render the blind pedestrian at risk of death or injury.

4. If a municipality installs automatic audible signals and a blind person is injured at such a crossing, I believe that the municipality could be held liable.

5. I believe that any audible signal, which activates automatically, is clearly in violation of the Americans with Disabilities Act. The Act clearly states that 'the person with the disability shall make the determination as to the need for a reasonable accommodation and that no accommodation shall be imposed upon a person with a disability.'

6. In addition to the false sense of security that the blind who support this measure would experience, there are broader implications of the implementation of this needless measure, including public perception of the abilities of the blind. A high unemployment rate already exists and this needless expenditure of tax payer monies WILL NOT encourage additional employment but does serve to reinforce the false public perception that the blind can only minimally function and only with extreme supports.

7. The tax dollars which would be spent on this initiative could be better used to change the way blind pedestrians are trained and provide monies to train and hire additional O&M instructors.

8. An appropriate modification of existing traffic control devices (lights) would be the mandatory extension of the time allocated for effecting a safe crossing, when the crossing button is activated. This provision would assist ALL citizen pedestrians. The blind, those in wheel chairs/walkers, the elderly, children and any other person would equally benefit from this change. I have seen many elderly persons struggle to complete a crossing in a timely manner. Just a thought!

Thank you.

Douglas C. Boone, President
D. Boone Consultants