Charles S. Brown
October 17, 2002
VIA FAX: 202 272 0081
Re: Comments on proposed guidelines on accessible pedestrian signals and
I am writing to express my strong opposition to the Access Board's proposed
guidelines on so-called "accessible" pedestrian traffic signals (APSs) and
detectable warning strips at intersections.
I have been blind all of my life (almost 58 years) and I know personally
hundreds of other blind people. The proposed guidelines will not help blind
people travel safely and will often hinder safe travel instead.
Adequate nonvisual cues already exist at the vast majority of intersections --
primarily traffic flow. In fact, those who pay careful attention to traffic flow
(blind or sighted) are ordinarily the safest street crossers. I am, of course,
aware of the fact that there are some especially complex intersections that make
standard traffic flow analysis difficult. In such situations, local authorities
and the local blindness community are in the best position to determine when and
how to deploy nonvisual signals -- audible or vibrating, with or without locator
The vast majority of intersections do not require such devices. In fact, the
noises emitted from audible signals are almost always useless at best, annoying
or downright unsafe at worst. This would be especially true with the variety of
clicks, chirps, and hee-haws that would result from the cacophony of locator
tones and traffic tones called for in the proposed guidelines.
As I understand it, local authorities are already supposed to install APSs in
the relatively few instances where they would be appropriate. Why impost such a
sweeping new federal mandate from on high to inappropriate locations?
We all know the costs will be enormous. I am concerned that many localities will
attempt to avoid costly APS installations by simply deciding not to construct
traffic lights at all. They may simply decide to rely on two-way and four-way
stops. While I have no problem with using stop signs to control intersections
for which stop signs are appropriate, using stop signs to control intersections
that really need traffic lights can be dangerous and downright unsafe for blind
and sighed pedestrians alike, not to mention the people in the cars.
For the reasons stated above, I am convinced that the proposed APS guidelines
will cause more safety problems than they will solve.
So-called detectable warnings -- speed bumps for the blind -- are rarely helpful
and therefore rarely necessary. Yet, the proposed guidelines would put these
bumps at almost every intersection. What a massive waste of money! The only time
they are helpful is when the transition from sidewalk to street is flat, or
virtually so. That's the only situation in which the Access Board ought to
consider requiring localities to put in these bumpy surfaces.
I very much appreciate your consideration of my comments.
Charles S. Brown