Angela Wolf

October 6, 2002

I am writing in opposition to the draft guidelines proposed by the Architectural and Transportation Barriers Compliance Board. The guidelines in question would require the placement of audible traffic signals at all
intersections with walk/don't walk signs and detectable warnings at all intersections.

With proper training, blind pedestrians travel safely with little or no environmental modification. Suitable alternative information is normally available to allow us full and equal access without modification, and in my
opinion, modifications should only be made at crossings where non-visual cues are either insufficient or unavailable.

The guidelines that the board has drafted are not necessary to insure access for blind pedestrians, and may even make street crossings less safe by adding too much noise to the environment in which we must cross the street. Not only would we have to contend with the signal itself, but locator tones would also be mandated. These tones add too much noise and distraction.

Occasionally, there are crossings that do not provide sufficient non-visual information to allow for a safe crossing, and when this occurs, vibrotactile signals should be installed. These signals would insure that
we receive the information we need without adding to the noise level of busy intersections.

As for the requirement that detectable warnings be installed at all intersections, I believe this is a colossal waste of money, and the tax dollars saved by eliminating this unnecessary requirement would be better spent on rehabilitation training for the blind. These warnings should only be installed when the transition from sidewalk to street is virtually flat.  In other instances, blind pedestrians can obtain sufficient information
about the transition using the alternative techniques taught at rehabilitation centers across the country.

I urge the Access Board to reconsider their current proposal and think about equipping blind people with better rehabilitation training, rather than reinforcing a lack of skills and confidence among the blind in this country.

Sincerely,
Angela Wolf
President, National Association of Blind Students