October 25, 2002
the comments of the National Federation of the Blind of Minnesota regarding the
draft rule for ATS's and detectable warnings.Joyce Scanlan, President National
Federation of the Blind of Minnesota
NATIONAL FEDERATION OF THE BLIND OF MINNESOTA
Dear Access Board members:
The members of the National Federation of the Blind of Minnesota (NFB of
Minnesota) have carefully reviewed the draft rules on Audible Traffic Signals
and Detectable Warnings issued for comment by the Access Board. We find the
proposed rules to be absolutely unacceptable for the following reasons:
First of all, the members of the Access Board who proposed these rules are
completely off track in their presumption that blind people need or will somehow
be assisted by audible traffic signals at all pedestrian intersections with
ďwalk/donít walkĒ signs and by truncated domes at intersections with a slope
steeper than 1-15 at street intersections and alleys as we go about our daily
activities. I personally know thousands of people who are blind and have
concluded that with proper training, blind people can travel about independently
and safely in their communities and throughout the world. Any blind person who
would claim a need for detectable warnings and audible traffic signals has
obviously not had appropriate training. The millions and millions of dollars
needed for atsís and detectable warnings would more appropriately be designated
for training to avoid the unnecessary expense of these two accessibility
Second, the cost of installing audible traffic signals and truncated domes in
the manner proposed by the Access Board rule is exorbitant and beyond reason.
Any city or municipality would have tremendous problems coming up with the
necessary funds to carry out the responsibilities required in the proposed rule.
With public attitudes toward blindness as negative as they are in our society,
this rule would simply say to all public officials responsible for implementing
the rule that blind people are incompetent, unsafe, and unable to participate in
the community on an equal basis with their sighted peers. This rule would lead
to unemployment and further lack of acceptance for blind people in our society.
The extremely high price for atsís and detectable warnings would cause
resentment and exclusion of blind people from the mainstream of the community.
Third, blind people would become segregated from the sighted. The atsís and
truncated domes would be where blind people would be expected to walk, and other
intersections where there were no atsís or detectable warnings would be for the
sighted citizens. This rule is disrespectful of blind peopleís right to make
their own decisions and choose their travel routes in the community. Blind
people are fully capable of being integrated into the community rather than
ghettoized or isolated from the mainstream.
Fourth, atsís and truncated domes present safety hazards for blind people. We
rely upon our ability to hear clearly the sounds of the traffic in the streets.
Adding eight constantly beeping locator poles and four chirping or loudly
beeping traffic signals in one intersection will confuse the sound pattern and
block out the much-needed sounds of the moving traffic. The blind person is
expected to follow the atsís, which are consistent and loud, while the traffic
sounds are less consistent and greatly drowned out by the atsís. Drivers cannot
be counted on to pay heed to traffic lights. The ambient noise level of the
beeping locators and the atsís make crossing the street a potential danger to a
blind person who may not be able to hear and sort out the actual traffic sounds.
Also, the truncated domes at intersections and alleys will cause potential
danger for many elderly people, as well as for those with other disabilities.
Women wearing shoes with high or large heels, individuals with balance problems,
and people in wheelchairs will find truncated domes to be a veritable safety
hazard. While the claim is that these domes are for the benefit of the blind,
blind people gain nothing from such domes, and many others are seriously harmed
by them. Furthermore, weather will be a major problem in states such as
Minnesota, where fall leaves from trees, snow, and slick ice will cause
pedestrians to trip or fall or sustain serious injury. By their very nature, the
truncated domes become collection areas for street debris. These domes
themselves are not safe, do not promote safety of anyone, and have no value in
helping blind people either gain accessibility on the public streets or earn the
respect of the general public.
The rule as proposed is far out of proportion to the benefit from either atsís
or truncated domes. We do not claim that these devices should never be used at
all. We submit that there may be intersections with inadequate nonvisual clues
to permit a person who is blind to determine by the traffic when it is safe to
cross. In these instances, atsís might be requested, and the local municipality
can make an informed decision based on the specific intersection. The extreme
rigidity of the draft rule as proposed makes the implementation of the entire
Thank you for the opportunity to comment on this draft rule. We sincerely hope
the rule as proposed will not become the rule as implemented. Blind people do
not want or need a costly, unsafe, and unhelpful system causing more segregation
of the blind and more resentment toward blind people than our society already
has. Please give careful thought to what is practical and useful, cost-effective
and reasonable. This rule as proposed has no value whatsoever.
Joyce Scanlan, Executive Director
Blindness: Learning In New Dimensions (BLIND), Inc.