October 25, 2002
Please consider this to be my comment regarding the proposed rules by the Access
Board. I oppose the proposed rules for audible traffic signals and detectable
warnings as they are written.
My name is Jim Marks. I reside at [ ... ]. I am blind and have been a user of
the long, white cane for about twenty years. My opposition to the proposed rules
stem from my personal and professional experience, which includes participation
in local, state, and national activities of the National Federation of the Blind
and employment as the Director of Disability Services for Students at the
University of Montana-Missoula. In addition, I serve as the Chairman of the
Special Interest Group on Blindness and Visual Impairments, a committee of the
Association on Higher Education And Disability. I am very familiar with the
Access Board and it excellent work in establishing guidelines for accessibility
by people with disabilities.
I oppose the proposed rule for audible traffic signals and for detectable
warnings because the rules require their installation at every traffic light and
curb ramp. While there may be cases when the audible traffic signals and
detectable warnings are useful, they are not necessary for me to travel
independently and safely at the majority of places where these features will be
installed should the proposed rules be adopted as written.
I believe that most audible traffic signals do more harm than good because they
clutter the environment with distracting and unwanted sounds. Many assert that
the audible signals enhance safety, but my experience is that they create safety
problems. In fact, the Missoula Chapter of the Montana Association of the Blind
asked that an audible signal that was improperly installed be turned off. We did
get the audible signal turned off, but it took a lot since traffic signals in my
city of about 100,000 people fall under the jurisdiction of the state Department
of Transportation rather than city or county governments. The audible signal in
question is the only such audible signal in town, and is located near the state
agency for the blind office. The signal was malfunctioning in that it told
pedestrians to proceed at the same time it told vehicles to turn right without
stopping. Several of us experienced near misses because it is easy to be lulled
into the notion that the chirps and beeps indicate when it's safe to cross.
Nothing replaces paying close and intelligent attention to the traffic noise and
other non-visual indicators in the environment. The audible tones actually
interfere with what one must pay attention to to cross the street safely. If the
Access Board insists on putting in non-visual indicators, then let them be of
the vibro-tactile type. These accomplish the same ends and even assist those who
are hard of hearing as well. However, I feel strongly that the installation of
any such device be rooted in verifiable and objective evidence that the device
does what it is intended to do. For the most part, I believe that audible
traffic signals are an answer in search of a question. Where is the evidence
that they provide any margin of safety and access? And speaking of access, I've
often heard the fallacious argument that blind people should have access to what
the sighted have. This oversimplifies what's at stake. Blind people do things in
blind ways. We are blind, not sighted people who can't see. Instead of relying
on visual cues, we rely on alternative techniques to do what the sighted do.
Chirps and beeps in the environment don't improve access for us while good
training rooted in can-do attitudes really does improve access.
Detectable warnings are not quite the danger to me that audible signals are, but
I do oppose them because I don't see any evidence they are necessary. Perhaps in
some instances, when the transition from the sidewalk to the street is so flat
that I cannot detect the change, then the detectable warnings should be
installed. Normally, there are plenty of cues that tell me where the sidewalk
ends and street begins. So it seems silly to require their installation at every
curb ramp. In addition, I live in snow country. It is likely that the detectable
warnings will interfere with the effective removal of snow, thus creating a
problem of safety for everyone.
Thank you very much for taking my comments.