Below, please find my comments in support of the Prowac Report and useage of vehicular traffic warnings and audible pedestrian signals. For purposes of exposition, please allow me to interspurse my comments with those from an e-mail forwarded to various blindness-related lists by employees or members of NFB (National Federation of the Blind). The entire NFB e-mail may be found at the end of my comments.

In 1995, my organizational affiliations changed to membership in the American Council of the Blind after twenty years of active participation with NFB.  The NFB expresses a documented pattern of rabid hostility toward dog guide owners and dog guide issues. The reference to "those who use dogs" needing the audible locater tones to find walk buttons in the NFB post seems devisive and misleading. Some dog guides already locate these walk buttons via instructions from their blind owners. For those dog guide providers who don't educate blind owners in how to teach their dogs to find walk buttons, locater tones would be for the benefit of the blind people in differentiating a walk button from, say a light pole near-by.

My experience of long, white canes shows that the cane does not detect the walk button; it locates an object which the blind user reaches out to touch and identify as the walk button pole, just as a dog guide owner would do. The non-standard placement of walk buttons combined with programming of light sequences which only cycle to 'walk' if a button is pressed makes locating the buttons more valid.

From NFB:

>No research exists regarding the effect of locator tones for every APS on blind pedestrians. Those who use dogs want an easy way to locate the APS, but the effect all this extra noise will have on the ability of all of us to travel safely has never been considered.

No doubt, Access Board guidelines take sound levels into consideration regarding audible signals. Original audible signals used buzzers set quite loudly. These original loud buzzers could act to limit a blind pedestrian's hearing of quiet vehicular traffic. Current audible signals I've heard signal without this disruption. I am not clear what is meant by "eight beeping points" when there is usually four corners to a standard intersection.

From NFB:

> For the average intersection, there will be 8 beeping points of sound over the general traffic noise making it exceedingly difficult to judge traffic. In addition, the draft guidelines require consistent placement, which should make locator tones unnecessary. Not only are the tones unnecessary, they may well prove to be exceedingly unpleasant for many.

Because I travel extremely competently with either a long, white cane or a dog guide, I used to hold with NFB rhetoric about audible pedestrian signals being superfluous, nay, harmful and detrimental to how the sighted community views blind pedestrians. In the 1970's, NFB stood for no audible signalling. Then, after increasing numbers of blind people, including NFB members using white canes and dog guides were killed, maimed and hurt in traffic incidents or subway platform accidents, NFB stance graduated to allowing for audible signals in extreme cases. Direct experience shows me that audible signals, like visual signals for sighted drivers reduce guess work and improve timing and access, especially at odd or noisy intersections or where auto traffic doesn't expect to see pedestrians.

As our population ages I've observed senior citizens and occasionally, inattentive motorists benefitting from the additional audible cues of a crossing signal.

From NFB:

> We have some serious catching up to do. If we do not express our views now, we will have accessible pedestrian signals (APS's) and detectible warnings everywhere.  In our letters, we need to clearly tell the Board that their proposal regarding APS's and detectible warnings are extreme and generally unnecessary. In the vast majority of situations we are able to travel competently without such costly modifications to our environment.  Many of us believe there is no situation that calls for an accessible pedestrian signal, and our resolutions contemplate their use only in limited situations.

Regarding the portion of the NFB post below, how is the level of awareness for traffic determined? Does awareness vary from person to person and even during various types of conditions? A street perfectly navigable by blind pedestrians on a clear fall day may represent different challenges during high wind, a thunder storm or after a significant snow fall.

From NFB:

>It is critical that each and every one of us write the Access Board.  Our letters must press the case for putting real limits on the use of these devices. They should only be used when traffic patterns do not provide the clues we rely upon to know it is safe to walk.  Accessible pedestrian signals should never be used to provide directional guidance. Many proponents of these devices argue to the contrary. However, there is no support for this assertion, and those who seek to rely upon APS's for directional guidance are risking their safety. This is why NFB resolutions only permit vibrotactile APS's in those situations where one is appropriate. Such devices inform the blind pedestrian that it is safe to walk and nothing more than that.

Could this poster's slant below be splitting hairs?

From NFB:

>These guidelines also require detectable warnings at every crosswalk.  Our resolutions state that detectible warnings should only be considered if the slope of the curb ramp is 1-15 (1 inch of rise or fall for every 15 inches of run) or flatter. Anything with a slope greater than 1-15 is readily detectable with or without a cane.  It is imperative that we provide comments to the Access Board now.  Time is running out. If we want our views to be considered we have only until October 28 to comment. .... This may be our last good opportunity to affect the development of these rules, so I urge each of you to do so now. 

In summary, the time may be overdue for blind pedestrians to gain equal signage access as do sighted pedestrians and motorists. My comments support the Prowac Report re vehicular traffic warnings and audible pedestrian signage.

Thank you for this opportunity to comment.

Sincerely,

Cheree Heppe

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Text of quoted e-mail follows:

Hello Federationists,

It is critical that each and every one of us write the Access Board.  We have some serious catching up to do. If we do not express our views now, we will have accessible pedestrian signals (APS's) and detectible warnings everywhere. In our letters, we need to clearly tell the Board that their proposal regarding APS's and detectible warnings are extreme and generally unnecessary. In the vast majority of situations we are able to travel competently without such costly modifications to our environment.

Many of us believe there is no situation that calls for an accessible pedestrian signal, and our resolutions contemplate their use only in limited situations.  Our letters must press the case for putting real limits on the use of these devices. They should only be used when traffic patterns do not provide the clues we rely upon to know it is safe to walk.

Accessible pedestrian signals should never be used to provide directional guidance. Many proponents of these devices argue to the contrary. However, there is no support for this assertion, and those who seek to rely upon APS's for directional guidance are risking their safety. This is why NFB resolutions only permit vibrotactile APS's in those situations where one is appropriate. Such devices inform the blind pedestrian that it is safe to walk and nothing more than that.

No research exists regarding the effect of locator tones for every APS on blind pedestrians. Those who use dogs want an easy way to locate the APS, but the effect all this extra noise will have on the ability of all of us to travel safely has never been considered. For the average intersection, there will be 8 beeping points of sound over the general traffic noise making it exceedingly difficult to judge traffic. In addition, the draft guidelines require consistent placement, which should make locator tones unnecessary. Not only are the tones unnecessary, they may well prove to be exceedingly unpleasant for many.

These guidelines also require detectable warnings at every crosswalk. Our resolutions state that detectible warnings should only be considered if the slope of the curb ramp is 1-15 (1 inch of rise or fall for every 15 inches of run) or flatter. Anything with a slope greater than 1-15 is readily detectable with or without a cane.

It is imperative that we provide comments to the Access Board now.  Time is running out. If we want our views to be considered we have only until October 28 to comment. Comments should be provided by e-mail to windley@access-board.gov, or faxed to (202) 272-0081, or sent by mail to Office of Technical and Information Services, U.S. Access Board, 1331 F. Street NW Suite 1000, Washington, DC 20004-1111.

This may be our last good opportunity to affect the development of these rules, so I urge each of you to do so now.

Best Regards,
Jim McCarthy

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