October 28, 2002
To the Access Board-
As a blind person who travels extensively, and I would say safely, throughout my
community. In addition, I am an orientation and mobility instructor working in
the Northwest regional area in Arkansas, and I provide instruction in cane
travel to blind adults in the area. As an instructor, I believe that the
modifications recommended in the draft resolutions will have a detrimental
effect on blind people.
I am writing to express my displeasure with the draft guidelines as issued on
June 17, 2002, and to submit my recommendations for changes to the guidelines.
The draft guidelines include language that would require modifications to be
made to the environment in order to facilitate safe travel by blind people
throughout the country. While this is a worthwhile objective, blind people do
not need environmental modifications to be able to travel safely, as evidenced
by the tens of thousands of blind people that travel safely everyday using the
environmental cues currently available.
More specifically, the draft guidelines call for installation of tactile
warnings and audible traffic signals at almost every intersection in the United
States. These kinds of modifications are not necessary, and may result in making
travel for the blind more difficult by masking the environmental cues, such as
traffic noise and curb cuts, with artificial cues.
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 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
I appreciate your attention to this matter, and I further urge you to modify the
guidelines in such a way that the concerns I mentioned above are addressed.