National Federation Of the Blind, Denver Chapter
October 6, 2002
National Federation Of the Blind
Jeremiah B. Beasley, President
Architectural Transportation Barriers Compliance Board
I am a blind person now living in Colorado. I write to raise concerns that I
have regarding the Board's draft guidelines which were published in the Federal
Register in June of this year.
First it is my understanding that the Board's proposes a standard which would
require accessible pedestrian signals (aps's) at any intersection with
pedestrian signalization. In my view, this proposed standard is far too broad.
Blind individuals are able to function well and safely in the vast majority of
intersection and need no other assistance, in addition to the non-visual cues
present in the existing surroundings.
I am also very concerned about the fact that each APS will be outfitted with a
locator tone. As long as Aps's, when they are necessary, are placed in or near
to a uniform location, there is no need for this tone. The tone is potentially
dangerous because it will throw extra and unnecessary noise energy into the
intersection and possibly mask the sound of traffic. Listening to traffic is the
most crucial skills the blind use to navigate intersections safely.
The Board also proposes to adopt a standard which would require detectable
warnings at every intersection. Once again, this is an unnecessarily broad
standard. If the slope of the intersection is 1:15 or greater, a blind person
can detect the downward slope as they come to the intersection. Therefore,
detectable warnings should only be placed at intersections that are, in effect,
If the Board's guidelines are adopted as drafted, I am fearful that the ultimate
result would hurt blind and visually impaired people. First, in some cases, it
may create additional hazards like putting too much extra noise into the
intersection. Second, the proposed guidelines would cost billions of dollars to
implement, taking scarce public money away from other projects which are of more
benefit to the blind. In conclusion, I support the positions advanced in the
Minority Report to the report of the Public Rights of Way Access Advisory
Committee filed by the National Federation of the Blind.
Very truly yours,
LINDA C ANDERSON
EDDIE K *ILLEG*
CHARLES C COOK
MARY K LARSON
JOHN C LANG
PAUL P LAWRENSON
DORIS M WILLOUGHBY