Dear Access Board members,

I urge you NOT to mandate the use of audible traffic signals and truncated domes. These devices serve no purpose for blind pedestrians in most situations, and their use should be implemented only when the necessary information cannot be obtained by other means. Most importantly, the cost of implementing such a mandate would be an outrageous waste of the taxpayers' money.

I moved here to Portland, Oregon just over a year ago. From Missoula, Montana. My experience with audible traffic signals had been on visits to other cities. I found the signals confusing and distracting; many were so noisy as to make it impossible to hear the traffic sounds well enough to cross the street safely while the signal was sounding. When I encountered the truncated domes, I had no idea what they were other than just one more obstacle cluttering up the sidewalks.

A couple of years ago one audible traffic signal was installed in Missoula, near the rehabilitation agency for the blind. It was at a busy intersection which my blind colleagues and I had never found difficult to navigate. We invited the city street department to send a representative to a meeting of the Montana Association for the Blind. When we explained that the noisy signal was of no help to us and was actually a dangerous distraction, the city engineer surprised us by saying that he understood exactly what we meant. He then told us the story of a town where the highway passed through the center of town but where there had never been painted crosswalks. The town installed the crosswalks at several intersections and put up crosswalk signs. They were shocked to find that in the first year there were MORE pedestrian accidents at these intersections than there had been before the crosswalks were painted. The reason was obvious: people felt a false sense of security in the crosswalks.

No one actually believes that a painted line on the pavement provides any real protection against tons of moving metal; the same can be said for audible traffic signals. But I am reminded of this story every time I hear a blind person with poor mobility skills say, "Oh, I feel so much safer when there is an audible signal." If September 11 has taught us one lesson, it should be this: just FEELING safe is of no value whatsoever!

When I arrived in Portland, I was appalled to find audible traffic signals all over the city, especially at intersections which are very busy and therefore easy to cross just by listening to the traffic. Most offensive was the intersection of S.E. 122nd Avenue and Division, where I have to change busses when I go to visit my mother. It is a very busy intersection, with heavy traffic in all four directions and a most predictable traffic pattern. But just as the light changed in my favor, the signal would emit a piercing "Screeeeeee," drowning out the sound of the traffic and making it especially hard to detect cars preparing to make a right turn on red--the most dangerous factor at such an intersection. My only option was to stay on the curb until the screeching stopped, thereby losing valuable crossing time. Recently lights at this intersection have been re-programmed and the traffic pattern changed. In addition, the audible signal has been turned down so low that it is almost impossible to hear at all. While that makes the crossing much safer for a blind pedestrian, it is still a waste of the city's money!

I discovered the most ridiculous example of an audible signal this past summer when I was leaving on a trip by plane early in the morning. Rather than drive me all the way to the airport, my husband took me to the Lloyd Center, not far from our house, to catch the first MAX (Portland's light rail train) of the morning at 4:15 a.m. At that hour there was no one around except two other people waiting for the train. There certainly were not crowds of pedestrians, blind or sighted, heading for the shopping mall. But at the corner the audible traffic signal blared out, "Cuckoo, cuckoo!" The signal seemed less of a warning about the traffic than about the mental state of the poor people who live in the nearby apartments and have to listen to that awful sound 24-7!

Ironically, I have encountered a couple of intersections in the Portland area where an audible signal would be helpful. The most notable is in Vancouver, near the Fisher's Landing transit center where I take the bus to visit my two daughters. It is a pedestrian crossing across a busy road leading to a freeway ramp, and there is no cross traffic. I have seen other such intersections in Portland, and none of them have audible signals. The traffic engineers are using a very strange set of criteria in judging which intersections need audible signals and which ones do not!

Most disturbing is the publicity campaign launched by the companies which stand to make a great deal of money if these mandates are implemented. They sponsor tables at conventions of blind people and have convinced many rehabilitation professionals to advocate for them. Especially vulnerable to this pressure are newly blind people who do not yet know that they can learn the necessary skills to travel safely without such expensive devices. We all know that high-pressure advertising can convince us that we really need to be drinking soda pop instead of water, popping vitamin pills instead of eating fruits and vegetables, and playing video games instead of reading books. The same kind of advertising can convince unskilled blind people that audible traffic signals and truncated domes will solve their mobility problems.

I am not one of these citizens, so vocal in recent years, who want to cut taxes in whatever way possible. I am happy to pay my fair share, as I agree with Oliver Wendell Holmes that, "Taxes are the price we pay for a civilized society." I would eagerly pay higher taxes to make life better for all of us: better schools, better law enforcement, better roads, better health care, better mass transit, better access for all pedestrians. In particular, I would love to see better mobility training for all blind people so that everyone can travel confidently and safely. If the tax money were spent for this kind of training, audible traffic signals and truncated domes would be necessary in only a few situations. Let's put our efforts where they will do the most good for the most people.

I urge you to reject the proposed mandates.

Carolyn J. Brock