I wish to express my opposition to the proposed rules regarding audible traffic signals (ATS) and detectable warnings. Philosophically, I believe such adaptations are unnecessary and mandates are wrong. I think they present logistical problems and are financially burdensome.

Most intersections provide adequate information--trafic patterns and change in grade--to allow safe crossing. As written, the guidelines require locator tones for "don't walk" and ATS tones for "walk." This may actually decrease safety because of the constant distractions added to the soundscape. Detectable warnings or ATS may enhance safety when the grade is nearly flat (1:15 or less) or the geometry of the intersection is complex. Current law requires the use of ATS when appropriate for safety but allows municipalities to make that determination.

I see several problems with the universal placement of truncated domes to identify the end of the sidewalk. In northern regions, leaves and snow and ice will become packed into the spaces between the domes. Who will clear them? We have become accustomed to curbcuts for wheelchairs. Will domes not interfere with travel for persons in wheelchairs? They are also a potential safety hazard for those who have difficulty walking. For example, one could twist an ankle stepping on the edge of the dome.

The cost of placing these modifications at each intersection far outweighs the perceived benefits. Many of the current traffic signals in my city need to be replaced because of age but have not been due to cost; the modifications would only add to it. And what about the many intersections not currently equipped with signals? The rule for detectable warnings appears to apply to all intersections--even rural
areas. These communities do not have enough traffic to justify the
cost of warnings and signals.

Please do not impose these extreme provisions on the American people.

Karen J. Clayton