October 15, 2002
Members of the Access Board:
I am writing to you on behalf of the members of the Greater San Antonio Chapter
of the National Federation of the Blind of Texas.
We are in opposition to the Draft Guidelines proposed by the Architectural and
Transportation Barriers Compliance Board, which would require detectible
warnings at all intersections and audible traffic signals at all intersections
with walk/don't walk pedestrian signals. Audible traffic signals and tactile
warnings should only be considered when factors in the environment, including
complex streets and traffic patterns, make knowing where and when to cross
difficult or impossible.
For years, blind people have traveled safely throughout our country without
modification to street crossings. Normally, non-visual clues are available for
safe travel. These non-visual clues include, but are not limited to, the
parallel and cross movement of traffic -- both vehicular and pedestrian, as well
as curbing and other features of the environment.
The proposed guidelines are not necessary to ensure safe travel for blind
pedestrians. In fact, they have the potential to make street crossings less safe
by masking normal traffic sounds and replacing them with added mechanical noise.
The use of locator tones as well as tones for the walk/don't walk sign has the
potential to cause confusion and throw a blind person off course as an
intersection can have eight or more tones sounding simultaneously. These tones
won't be helpful to blind people and they will be an annoyance to the public and
to the citizens living or working near the crossings.
At crossings where there are insufficient non-visual clues for safe crossing,
vibrotactile signals should be installed. Vibrotactile signals will ensure blind
persons of receiving information necessary for safe crossing without adding
noise to the environment and will allow blind people to continue to hear the
traffic and other sounds currently used for safe crossing. Vibrotactile signals
will augment safety rather than decrease it with the use of auditory signals.
Detectible warnings should only be installed at intersections where the
transition from sidewalk to street is flat. Curbing and the changes in texture
of sidewalks and street paving are usually sufficient enough for blind persons
to safely cross.
The installation of unnecessary detectible and audible signals at all
intersections is a waste of public money. The money saved by the elimination of
unnecessary expense on these frivolous devices could be better spent on the
training of blind persons in mobility skills. This would allow blind persons to
safely travel all the streets and by-ways of our country rather than only those
supposedly protected by audible signals and tactile warnings. Futher, this
training would assure blind people safe independent travel at times when
mechanical devices fail.
The members of the San Antonio Chapter of the National Federation of the Blind
of Texas urge you not to issue final guidelines with provisions as extreme as
the current draft.
Sharon Gold, President
Greater San Antonio Chapter
National Federation of the Blind of Texas