Pamela Roark-Glisson

October 28, 2002

Dear Members of the Access Board:

This is regarding my opposition to the June 17th proposed rule by the Access Board to establish regulations regarding Accessible Pedestrian Signals
and Detectable Warnings. This regulation, if adopted, is to the extreme.

Blind travelers are well trained to travel safely and competently in the majority of environments. If there is a standard developed across the nation, it should be used as an exception and not the rule. It should not present a dangerous distraction to pedestrian travel, and it should certainly be cost effective.

Since the "Truncated Dome" is being considered as the Detectable Warning, as a blind traveler, I am sincerely opposed.
In my travels to work, shopping and other appointments, these domes have been of no value. The truncated domes are installed at the transit center, for example, with the assumption that they will assist the blind in locating the bus, however one must first locate the dome. The cost, also, is absolutely exorbitant and prohibative to have these on a consistent basis across the nation. additionally, people who use wheelchairs and other mobility aids, report the domes to be dangerous.

Other detectable warning devices exist that are cost effective and safe for the general pedestrian traveler.
The proposed guidelines require the detectable warnings at every cross-walk. This is not practical. Any surface with a slope greater
than "1 to 15" (1 inch of rise or fall for every 15 inches of run) or flatter is readily detectable with or without a cane.

The proposed rule regarding "locator tones" for Accessible Pedestrian Signals should be considered only under extreme circumstances. Locater tones should only be used when traffic patterns do not provide the information we need to know it is safe to walk. Accessible Pedestrian Signals provide no directional information whatsoever, and the locator tones for such can cause great confusion
and dangerous distractions. Research does not exist regarding the effect of Accessible Pedestrian Signals with locator tones for blind pedestrians. Training for blind travelers is not included in the proposed rule, and this component will contribute more to the cost factor and negatively to the feasibility of functional operation.

Thank you for your attention to this important matter.

Sincerely,

Pamela Roark-Glisson, Director
ADA Action Network of Kentucky