Dear Access Board Committee:

Blind folks do not need detectible bumps and beeping poles at every intersection. There may be instances where audible traffic signals could be helpful. However, they should only be considered when traffic cues cannot be determined by blind pedestrians. We acknowledge that there are some situations where detectible warnings should be installed. When we are unable to tell the difference between sidewalks (including medians and islands) and the street, detectible warnings are appropriate. However, most situations do not require audible signals or detectible warnings.

We are the blind and we know what we need. There is a true risk that our pedestrian ways will become less safe with the installation of audible traffic signals and detectible warnings.

Blind people travel safely every day without adaptations to the built environment. Moreover, suitable and sufficient alternative methods and information are normally available to provide us full and equal access without modification. Modifications should be considered only when sufficient nonvisual cues are not otherwise available.

The current draft guidelines are unnecessary to make travel safe for blind people. They would not improve access and may actually decrease safety due to distractions created by the variety of tones added to the soundscape. For example, adoption of the guidelines as written would result in having a locator tone constantly beeping from each pole with a pedestrian activated push button for the "walk/don't walk" sign. This means that mixed with all the traffic sounds there may be as many as 8 or more separate tones all going off simultaneously, some of which are locator tones (beeping every second when the "don't walk" sign is on), and others which are ATS tones (beeping more rapidly when the "walk" sign is on). This confusing array of tones would be presented at virtually every intersection. Most intersections do not require an ATS for the accessibility and safety of blind pedestrians. Only those intersections with complex geometry, complex signalization, or varied signalization for each lane may be appropriate for an ATS. Vibrotactile indicators should be used in preference to audible signals in order to minimize noise distractions and better promote safety. Locator tones should not be included in the final guidelines and may be subject to further research. At most intersections the built environment provides ample accessible cues to determine the difference between the sidewalk and the street. A slope of less than 1:15 in crossing from the sidewalk to the street (including medians and islands) may not be detectable and should be identified with a detectable warning.

Sincerely
Thomas P. Duffy, Jr.
Editor, Newsletter NFBM