John Halverson

October 19, 2002

Dear Access Board:

Thank you for the opportunity to comment on the proposed Right- of -Way guidelines.

As a person who is blind and independently travels throughout the country I have observed increased traffic volume and discourtesy toward pedestrians over the last 30 years. However, I am not convinced that the wholesale installation of audible traffic signals will increase safety for blind pedestrians. Audible signals merely tell us when we may walk across an intersection. They do not indicate when it is necessarily safe to do so. We must still depend on our sense of hearing to listen for turning traffic and automobiles running red lights. In fact I believe in most instances audible traffic signals will decrease safety through increasing noise levels and giving a false sense of security.

However, I believe there are a few instances where modified traffic signals may be of benefit. These include three-way intersections where there is a large volume of turning traffic major intersections with complex turning lanes and possibly other rare instances. In these cases push-button activated signals causing a unit to vibrate represents a safer solution.

Despite increased traffic, Department of Transportation data indicate that over the past quarter century pedestrian deaths have significantly decreased. Prior to continuing this regulatory effort the access board should consider if there is a real increase in danger to blind pedestrians. Some individuals indicate anecdotal evidence of increased deaths and injuries faced by blind pedestrians. I am not aware of any systematic study of the record which demonstrates increased real danger. In fact, it may turn out that increased traffic has led to more care taken by blind pedestrians. Given the massive costs of the Board's proposals, a careful exhaustive study of the costs and benefits for the installation of audible traffic signals is necessary.

The use of detectable warnings at all but the most rare intersections is not necessary. Persons who are blind are able to detect almost all curb slopes and drop-offs with the white cane or through the use of a guide dog. My experience has been that these warnings are slippery when wet or icy. Their deployment should be halted unless it can be demonstrated for different slopes and other conditions that the benefits of reduced pedestrian accidents are less than the increased cost of injury caused by the installation of detectable warnings. The Board needs to remember that the regulatory process requires an impact analysis that takes into account benefits and costs from the point of view of the nation, not necessarily those of a specific class of persons.

Finally, if the Board chooses not to listen to the Nations Blind and continues to include audible traffic signals and detectable warnings in this rule making, it should require that blind persons in each community have a strong voice in selecting where these signals and warnings may be installed.