October 28, 2002
Dear Members of the Access Board:
This is regarding my opposition to the June 17th proposed rule by the Access
Board to establish regulations regarding Accessible Pedestrian Signals
and Detectable Warnings. This regulation, if adopted, is to the extreme.
Blind travelers are well trained to travel safely and competently in the
majority of environments. If there is a standard developed across the nation, it
should be used as an exception and not the rule. It should not present a
dangerous distraction to pedestrian travel, and it should certainly be cost
Since the "Truncated Dome" is being considered as the Detectable Warning, as a
blind traveler, I am sincerely opposed.
In my travels to work, shopping and other appointments, these domes have been of
no value. The truncated domes are installed at the transit center, for example,
with the assumption that they will assist the blind in locating the bus, however
one must first locate the dome. The cost, also, is absolutely exorbitant and
prohibative to have these on a consistent basis across the nation. additionally,
people who use wheelchairs and other mobility aids, report the domes to be
Other detectable warning devices exist that are cost effective and safe for the
general pedestrian traveler.
The proposed guidelines require the detectable warnings at every cross-walk.
This is not practical. Any surface with a slope greater
than "1 to 15" (1 inch of rise or fall for every 15 inches of run) or flatter is
readily detectable with or without a cane.
The proposed rule regarding "locator tones" for Accessible Pedestrian Signals
should be considered only under extreme circumstances. Locater tones should only
be used when traffic patterns do not provide the information we need to know it
is safe to walk. Accessible Pedestrian Signals provide no directional
information whatsoever, and the locator tones for such can cause great confusion
and dangerous distractions. Research does not exist regarding the effect of
Accessible Pedestrian Signals with locator tones for blind pedestrians. Training
for blind travelers is not included in the proposed rule, and this component
will contribute more to the cost factor and negatively to the feasibility of
Thank you for your attention to this important matter.
Pamela Roark-Glisson, Director
ADA Action Network of Kentucky