Paul Carver

October 15, 2002

To: The Access Board

I am writing in opposition to portions of the proposed guidelines. Specifically, the proposal to require audible signals and tactile warnings. Such modifications to the environment are unnecessary, expensive and dangerous.

Thousands of blind Americans travel safely every day through large and small cities using a long white cane. Proper training in the use of a correctly fitted white cane is all that is required for a blind person to cross most streets safely. There are a small percentage of intersections that could benefit from an on-demand type of signal. Tactile warnings on zero slope curbs or on islands of very wide streets would be useful. However, signals that provide unsolicited beeps or chirps, and tactile warnings at every corner are simply not needed or wanted.

In these days of tight budgets and over taxed public resources I believe it is unfair and fiscally irresponsible to require blanket installation of expensive modifications that serve very few and are wanted by even fewer. In the city of Sacramento where I live the Public Works department identified over 30,000 locations where signals and ramps would need modification to meet the proposed guidelines. At a cost of $6,000 per location it would cost the taxpayers of Sacramento $180 million to satisfy the requirements of these guidelines. Further, the number of residents of Sacramento who would use such signals is small, fewer than 500 my recent estimates. This means a cost of $360,000 per beneficiary. Proponents would say that's a small price to pay if it saves a life. I would agree if there were evidence that proved that audible signals and tactile warnings would save lives. No such evidence has been provided

As part of any quality cane travel instruction a blind student is taught to listen to traffic sounds and to identify signal patterns and traffic flow based on this information. For busy or complex intersections this requires a fair amount of concentration and the ability to hear the movement of vehicles. Now the guidelines propose to introduce additional noise into this mix. Rather than making it safer to negotiate an intersection I submit that such devices make it less safe. Beepers and buzzers, chirps and clicks would tend to mask the traffic sounds that are so very important to a safe crossing. Furthermore, as with any technology, failure, or worse yet, malfunctioning units that result in out of sync signals, are real a real possibilities. Finally, they tend to lull blind pedestrians, and others I suspect, into a false sense of security. Reliance on a chirping signal rather than ones own faculties is likely to get more people killed, not less.

In most situation audible traffic signals and tactile warnings are unnecessary, unwanted and dangerous. I urge the Access Board to reconsider the proposed guidelines and work with the leadership of the National Federation of the Blind to draft guidelines that better meet the needs of the blind of America.

Paul Carver
Sacramento California