National Federal of the Blind of New Jersey

Re:  Comments regarding Regulations for Accessible Pedestrian Signals (Audible Pedestrian Signals)

Dear Access Board:

The Accessible Pedestrian Signal Regulations which are scheduled to be put in affect, are worthy of the following

Comments:

1)       The National Federation of the Blind of New Jersey has been aware of the audible pedestrian signal for over thirteen years.  These signals, though thought to assist the blind, are an obstruction to the alternative technique used by blind people in crossing streets. 

When a blind person arrives at an intersection, he listens to the flow of traffic entering and leaving the intersection.  When the traffic in front of him stops, and the traffic which is parallel to him starts, the blind person can be certain that the street in front of him is safe for him to cross.

The Accessible Pedestrian Signals pose additional safety issues.  These include the increase in noise generated by each of the eight signals at a traditional four-way intersection.  This increased noise detracts from the traditional sounds on which a blind person relies to cross a street.

This increased noise is also a distraction to residents and other persons who live / work nearby.  In situations where Accessible Pedestrian Signals have been installed, workers can not open windows during warm days, and residents who live in the area where the signals are installed, complain about the noise during the night.

Installation of Accessible Pedestrian Signals forces a blind person to rely on that device in order to cross a street.  What would happen if the Accessible Pedestrian Signal malfunctioned?, or if the blind person located to an area which was not equipped with Accessible Pedestrian Signals?  Our methods of determining clear right-of-ways are less costly and more versatile. 

The National Federation of the Blind does acknowledge that in certain situations, where a group of blind people agree, an Accessible Pedestrian Signal can be installed.

I also understand that the Access Board is accepting Comments regarding detectable warnings at intersections.  The opinion of the NFBNJ is that these proposed regulations and warnings are unnecessary, because blind pedestrians have functioned without such warnings, by relying upon the sound of traffic, the slope of the ramps built for pedestrians in wheelchairs, and through the use of a guide dog or long white cane.

On a personal note, I traveled Washington, D.C. during the Summer of my Junior Year of college when I interned with the Federal Communications Commission.  If I was unable to independently judge the traffic flow and time to cross, someone who was crossing the street with me indicated when to cross the street by crossing themselves.

The proposed rules and large support for installation of such devices are only the efforts of the manufacturer of the Accessible Pedestrian Signal and ill-informed professionals to undermine and increase the dependence of blind people on another unnecessary device.

If you have any questions, please contact James McCarthy, Assistant Director, Governmental Affairs at [....]. 

Sincerely,
David Mostello
Legislative Coordinator & Board Member
NFBNJ, Inc.