Medians and refuge islands shall have detectable warnings complying with 1108. Detectable warnings at cut-through islands shall be separated by a 24 inch
(610 mm) minimum length of walkway without detectable warnings
EXCEPTION: Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing.
I am strongly in favor of providing detectable warning at all intersections.
Tom Heinl
David Eichenauer, July 1, 2002
Thank you for the opportunity to comment on the above referenced document.
1103.3 Minimum Clear Width - we feel strongly that this should be 60" rather than 48".
110L3.2 Detectable Warnings. There should be detectable warnings at all curb cuts and blended transitions.
Thank you for the opportunity to comment.
Sincerely,
David Eichenauer
Joseph Roeder, September 13, 2002
As a working, tax-paying citizen who is blind, I am writing to express my support for the PROWAC report and the call for detectable warnings. I am a member of the traveling public and my personal sense of safety in enhanced by detectable warning strips and other alerts about hazardous traffic areas.
Some may argue that detectable warnings produce negative stereotypes about people who are blind or that such warnings are not necessary for well-trained cane travelers who pay attention. But people who are blind, like all human beings, can have their attention distracted from time to time.
Once I stepped off an elevator and started walking to the edge of a train platform. I had traveled this route dozens of times and knew the platform was about 10 paces to the right. But that day my attention was distracted by my thoughts and I forgot which side of the platform I was on. The other side is farther from the elevator and I was walking briskly as though I has several more steps to take. My cane encountered the detectable warning strip and I suddenly forgot my thoughts and immediately stopped. With the long strides I was taking I would have gone over the edge in another step or 2. I considered what I was doing, realized my lack of attentiveness and gave heart-felt thanks for that detectable warning strip.
Pedestrian safety should be the primary concern, not worries over the opinions others have about people who are blind. Detectable warnings are no different than the traffic signs that warn motorists about speed bumps, steep grades, railroad crossings or other highway hazards. Would anyone prudently argue that these signs are not needed because the motorist should be paying attention? Of course not!
I urge the Access Board to support detectable warnings and any other appropriate measures that enhance safety for the traveling public.
Sincerely,
Joseph Roeder
Frank Synoground, October 24, 2002
I would like to offer the following comments on the draft regulations and thank the committee for its considerable efforts. I am blind and am particularly interested in tactile warnings.
Detectable Warnings (1104.3.2)
Detectable warnings should only be required where the ramp slope was 1:15
In reference to sections as cited below:
1108.1 General.
Detectable warnings shall consist of a surface of truncated domes aligned in a square grid pattern and shall comply with 1108.
1108.1.1 Dome Size.
Truncated domes in a detectable warning surface shall have a base diameter of 0.9 inches
The above listed specifications would seem to eliminate or at least not acknowledge parallel tactile warnings that would act as wayfinding as well as warning. I am blind and consider wayfinding in some cases an important safety issue as well.
Frank Synoground
Portland, OR
Virginia Parezo, October 20, 2002
I travel greatly, this would be at my advantage to have the pedestrian signals and detectable warnings. Please do what you can to support this forum. Thank-you!
Virginia Parezo
Rob Turner, September 13, 2002
I'm sending you this e-mail in support of detectable warning strips. As a totally blind traveler, I find them to be very helpful and several times their presents have warned me that I was dangerously close to the edge of subway platforms or railroad tracks. we need to have detectable warnings at places where vehicular traffic is likely to be found and we need accessible pedestrian signals.
Thanks for your attention.
sincerely
Rob Turner
Alpidio Rolón, October 22, 2002
Please include the attached letter among the comments on the proposed guidelines about "audible traffic signals" and "detectable warnings".
Alpidio Rolón
President
NFB of Puerto Rico
National Federation of the Blind of Puerto Rico
I write because I wish to express my views about the proposed guidelines regarding "audible traffic signals" and "detectable warnings". Let me first of all state, that I have been totally blind for thirty-two years. I have up to now, thanks to good orientation and mobility training, managed to go anywhere I wish using my other senses. My few encounters with ATS's have been to say the least, disagreeable. Not only have they not helped; they have impeded my ability to concentrate on ambient signals that might better enable me to cross a street safely. Their use could only be contemplated in certain situations, such as crossings that contemplate multiple traffic alternatives. Even then, we would be better off with "vibrotactile signals".
On the other hand, the imposition of "detectable warnings" at all curb ramps greater than 1-15, is unnecessary and costly. Any blind person can easily detect said ramp. It seems to me that you should concentrate more on the inclination of the curb ramp than on requiring "detectable warnings". Better yet, even though it is not your area of concern, more money should be spent on providing more and better training for blind people.
Hoping that you will consider my opinion about "audible traffic signals" and "detectable warnings", I am,
Sincerely,
Alpidio Rolón
President
NFB of Puerto Rico
I strongly believe in detectable warning and accessible pedestrian signs. Any opportunity for safe warning is an opportunity for life itself!!!
Lee Brown
Karyn Campbell, September 18, 2002
I would like to speak in support of the Public Rights of Way Accessibility Committee (PROWAC) report on detectable warnings and accessible pedestrian signals (APS. Both of these devices are important to the safe travel of people who are blind or visually impaired. I will discuss each device separately.
First of all, I would like to give you some background on me. I am blind but have some light perception. I have never had perfect vision and lost a good deal of what I once had later in life. I also have a mild to moderate hearing loss for which I wear hearing aids bilaterally.
Detectable warnings are important because they provide me with clues about my environment. In a railroad station, a detectable warning is my yellow line. I know when I am at the edge and should not go any further. I must still use good mobility skills when I am traveling. People's skill level does vary; but a person must use the skills he has.
I said that these warnings provide me useful clues about my environment. when I am walking on a train platform, I have more confidence if there is a detectable warning than I do if there is not a detectable warning. This is important to me, especially when you consider that train stations are noisy and background moise makes it more difficult for me to know what is going onnn because sounds can and are drowned out by engine noise. Last Saturday Septemmber 14, 2002, I was waiting for a commuter train at the Glen Ellyn station. Afreight train came through just as I was arriving on the platform. I became disoriented and was not sure which way I was facing. After the train left, I used the detectable warning along the track and in front of the station door to determine where I was. As a result of doing this, i regained my orientation and was fine from there.
As for Accessible Pedestrian Signals (APS), they are good at intersections which are extremely dangerous to cross. We have at least one intersection like this in my community. There is a lot of traffic at this intersection. This intersection does need an APS. I have never crossed this intersection on my own and nevner will. APS not only help people who are blind or visually impaired, they help senior citezens, school -age children, and others with disabilities. They give all of these people extra assurance that they will make it across safely when using good sound judgement and proper safety and mobility sills. Vibrotactile technology can hellp some who are deaf-blind make it as well. Please keep in mind that the term "deaf-blind" does not just refer to a complete loss of both senses; but also refers to a combination of a complete loss of vision and partial loss of hearing or vice versa. While I do not know how much these signals will help me due to background noise, I know they will help others stay safe when crossing at dangerous intersections. These intersections must be determined by the community with input from its residents.
It is time for us to have equal access to our environment. We deserve the same information that the sighted world gets. A detectable warning is our yellow line; and an APS gives us information in a nonvisual form which the sighted world receives in a visual form. It is our safety and access to the comunity we are talking about here.
Thank you very much for your time, attention, and strong support for detectable warnings and APS. Our safety does matter. I will be watching this issue very closely to make sure that my safety, as well as the safety of those close to me, is protected.
Sincerely,
Karyn Campbell
Julie K. Blamphin, October 28, 2002
I support audible traffic signals & detectable warnings.
Thank you.
Julie
Julie K. Blamphin
Data Solutions & Technology, Inc.
Christopher Wright, September 8, 2002
I proudly support the Prowac report. We need to have detectable warnings at places where vehicular traffic is likely to be found and we need accessible pedestrian signals. One place where these should be used is at Subway stations. If these detectable warnings are placed near the train tracks, a blind person would know that he or she is approaching the edge of the platform.
Please respond as soon as possible. Thanks.
Christopher Wright
Hello; I am extremely concerned about the proposed guidelines which will, as I understand it, require audible traffic signals and detectable warning bumps at all intersections. These are NOT needed.
While there are a few cases where an audible signal may be helpful - an especially complex intersection, and detectable warning bumps may be useful - where the sidewalk and street are the same level; these situations are few and far between.
The current crop of audible signals are a particularly bad choice since almost all of them beep or whistle rather than providing usable information. Requiring them to talk rather than beep or whistle would be extremely helpful. Hearing "Walk east and west", and "Don't walk north and south", is far more helpful than "beep, beep, beep, beep".
Detectable warning bumps are not needed in most places. The only time they serve any useful purpose is when the street and sidewalk are level with each other. The presence of these bumps does not make it safer for blind people, in fact these bumps give a false sense of security because they don't tell you how far down the street is from the sidewalk, or in my case how far down the track was from the platform.
I saw the warning bumps and said "So, I know that's the edge of the platform." I then stepped down to go to my train which was several tracks over and fell. If I'd been using my white cane I would have known there was a huge drop rather than the small one I thought there was.
Detectable warning bumps give a false sense of security, as for that matter do audible traffic signals; therefore they need to be kept to an absolute minimum.
I encourage you to reconsider the guidelines and not believe the "poor pitiful blind" idea that so many people are using to justify these unnecessary warning systems. Rather than spending millions of dollars on audible signals and detectable warning bumps we would be far better served by spending thousands of dollars on GOOD mobility training for blind pedestrians.
Thank you for your time and for reading my letter.
Eric Foss
Sherry Gomes, October 15, 2002
I am writing to express my opposition to the proposals concerning audible traffic signals and detectable warnings. I am blind, and I am a competent traveler, either with a white cane or with my Guide Dog. I do not believe that every intersection needs to have an audible traffic signal. I am completely able to cross streets, whether they be lightly traveled or extremely busy. I find the added noise caused by the audible signals add confusion in a situation where the traffic is heavy and constant.
I am even more opposed to detectable warnings. I was born with Juvenile Rheumatoid Arthritis. my right knee is fused, and I have joint replacements in my left knee and both hips. Sometimes, the slightest change in the elevation or texture of a sidewalk or road can cause me to stumble or lose my balance and fall. Those who want detectable warnings to help them stop for edges, platforms or to cross a street are not considering the needs of people in wheel chairs or who have difficulty walking. If a blind person uses the white cane or a dog guide properly, there should be no need for these detectable warnings.
Thank you very much.
Sincerely,
Sherry Gomes
Instructor, Seattle Lighthouse Education and Training
Reference: Audible Traffic Signals and Detectable Warnings.
COMMENTS:
· 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 better promote safety.
· Locator tones should not be included in the final guidelines and may be subject to further research.
Detectable Warnings
· 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
I urge the Access Board to reconsider the recommendations made in the recent draft guidelines.
Respectfully,
Mary Cogg
Larry J. Ghrigsby, October 23, 2002
Reference: Audible Traffic Signals and Detectable Warnings.
COMMENTS:
· 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 better promote safety.
· Locator tones should not be included in the final guidelines and may be subject to further research.
Detectable Warnings
· 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
I urge the Access Board to reconsider the recommendations made in the recent draft guidelines.
Respectfully,
Larry J. Ghrigsby
Andrea Giudice, October 27, 2002
My name is Andrea Giudice. I am blind and want to let you know that I give my exuberant and total support to the existence and increase of Accessible
Pedestrian Signals and Detectable Warnings at intersections. I live in
the grater San Francisco Bay area and travel throughout the country. I can give you enumerable examples of how crucial Accessible Pedestrian Signals and Detectable Warnings are at intersections.
I have heard nothing about discontinuing the incorporating of crossing indicators for pedestrians who do not need accommodation in terms of size or contrast of signage or other forms of audible or detectable crossing indicators. Why then is this even being considered for Accessible Pedestrian Signals and Detectable Warnings? It is a crime to deny people with disabilities the same safety at intersections that is granted to our non-disabled partners in pedestriandom.
With Kindest regards,
Andrea Giudice
Thomas Ghrigsby, October 3, 2002
Reference: Audible Traffic Signals and Detectable Warnings.
COMMENTS:
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 better promote safety. Locator tones should not be included in the final guidelines and may be subject to further research. Detectable Warnings 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
I urge the Access Board to reconsider the recommendations made in the recent draft guidelines.
Respectfully,
Thomas Ghrigsby
Judy Manlove, October 28, 2002
The Audible Pedestrian Signal? A national policy mandating installation? Show cause why. Until then, understand that there are those who want to be patronized and those who do not. To patronize costs lots of our money.
I am Judy Manlove, [ ...] and this is forwarded to you with permission.
Sincerely,
Judy Manlove
It is my understanding that detectable warnings are now to be placed in pedestrian crosswalks. In my city? Who says they are needed for the blind or anyone else? Such assertion is a blatant lie. Besides, where is your data showing need?
I am Judy Manlove, [ ... ] giving permission for my comment to be forwarded in this way. Please stop detectable warnings.
Sincerely,
Judy Manlove
Patricia LaFrance Wolf, September 8, 2002
I SUPPORT THE PROWAC REPORT AND SUPPORT THE FACT THAT DETECTIBLE WARNINGS ARE NEEDED AT INTERSECTIONS. THESE WARNING SIGNALS ARE AN ADDITION THAT MAKES SAFE CROSSINGS MORE LIKELY THAN JUST LISTENING TO TRAFFIC AT STREET CORNERS. MANY PEOPLE HAVING HEARING PROBLEMS AS WELL AS VISION PROBLEMS AND WITH THE MANY INTERSECTIONS THAT HAVE VARIABLE LIGHTS AND INTERMETIANTANT CROSSING SIGNALS, THESE DETECTIBLE SIGNALS ARE A GREAT HELP.
L. Dianne Ketts, COMS, CLVT, October 28, 2002
My name is L. Dianne Ketts. I hold a certification in Orientation & Mobility (O&M) and in Low Vision Therapy with the Academy for Certification of Vision Rehabilitation & Education Professionals. I serve as a member of the Environmental Access Committee of the Orientation and Mobility Division of AERBVI (the Association for Education and Rehabilitation of the Blind and Visually Impaired.) I am currently employed at CITE, Inc. in Orlando, Florida as the O&M and Low Vision Programs Coordinator. Please accept my comments on the Draft Public Rights-of-Way Accessibility Guidelines.
Curb Ramps and Blended Transitions (1104)
Detectable Warning (1104.3.2)
I support inclusion of specifications in the draft guidelines for detectable warnings (1108 Detectable Warning Surfaces) and urge The Board to include requirements for detectable warnings at ALL slopes and curb ramps where a pedestrian way intersects with a vehicular way regardless of grade.
Rationale: In my experience as an orientation and mobility instructor of visually impaired adults, even slopes greater than that of 1:15
Pedestrian Signal Phase Timing (1105.3)
I support The Board's draft guideline for Pedestrian Signal Phase Timing (1105.3) stating that "signal phase timing shall be calculated using a pedestrian walk speed of 3.0 feet
Rationale: Because I serve many senior individuals and persons with other mobility impairments in addition to their vision loss, I often consider the benefit that a longer walk and pedestrian clearance phase would offer. Many clients I serve are not able to complete the crossing of multiple lanes of traffic in the normally allotted time of 4.0 feet
Medians and Pedestrian Refuge Islands - Detectable Warnings (1105.4.2)
I do not support the EXCEPTION to this recommended guideline stating that "Detectable warnings shall not be required on cut-through islands where the crossing is controlled by signals and is timed for full crossing." It is my recommendation that this EXCEPTION be removed from the proposed guidelines.
Rationale: Detectable warnings located at a median or refuge island give the visually impaired or blind pedestrian critical information regarding their location in relation to the crossing. The presence of detectable warnings may inform the pedestrian that the island is a place of refuge where they could possibly stop and rest if it were necessary. This may be especially important for a pedestrian who moves more slowly or with more difficulty.
Turn Lanes at Intersections (1105.7)
I whole heartedly support the recommendation for pedestrian activated traffic signals at these locations.
Accessible Pedestrian Signals - General (1106.1)
I support the inclusion of specifications for Accessible Pedestrian Signal (APS) systems.
Rationale: Many intersections in the central Florida area are typical of intersections that can be found throughout the country. Minor, lightly traveled streets often intersect with major arteries. When a visually impaired pedestrian's intention is to cross the major artery, there is often little or no parallel traffic movement on the minor street to indicate that it is the appropriate time for the pedestrian to begin crossing. Accessible Pedestrian Signal technology provides information critical to determining when to begin a crossing in a format that is accessible to the visually impaired pedestrian.
I recommend that The Board use the term "Accessible Pedestrian Signal (APS)" when referring to these types of devices as opposed to "pedestrian signal systems" or "pedestrian signal devices."
Rationale: This terminology would more closely match the language in the MUTCD and current terminology. As a result, engineers and others utilizing the MUTCD when building public rights-of-way will be less likely to encounter conflicting or misguiding terminology.
Detectable Warning Surfaces (1108)
As I stated above, I support the inclusion of specifications for detectable warning surfaces.
Once again, thank you for the opportunity to comment.
L. Dianne Ketts, COMS, CLVT
CITE, Inc.
Christine McGroarty, September 9, 2002
I'm sending a quick note to say how completely puzzled I am at the resistance to detectable warnings. I'm sure you have received much impassioned correspondence on this matter, so I will simply pose the question. Generally aren't there color coded warning signals in the same places where the detectable signals are proposed? If warnings, in the forms of color, are deemed necessary and appropriate why would you not provide tactile warnings as well?
In addition to the logic of the matter, there seems to me to be a significant risk for legal action if visual warnings are present and tactile ones are I remain puzzled by such vehement resistance to such an obvious and harmless requirement.
Christine McGroarty
Senior Budget and Management Analyst
Office of Budget and Management
City and County of Denver
Dotty Huntley, October 13, 2002
I support audible signal crossings, and detectable warnings.. There are too many people that are blind and have no safe way to cross the street.
Dotty Huntley
As a blind person I must oppose audible traffic signals and detectable warnings in cross walks. I find them confusing and they contribute to noise pollution.
Tom O'Brien
Frank Cuta, September 11, 2002
I am a totally blind independent traveler and I feel strongly that the Access Board should accept/adopt the proposed regulations from the Public rights of Way Advisory committee involving the use of detectable warnings and accessible pedestrian signals. I have personally experienced the benefit of detectable warnings and I have close friends here in Washington who have been hit trying to cross streets without accessible signals. I assure you these regulations are reasonable and necessary.
Thank you,
Frank Cuta
I am writing to state my opposition to the draft guidelines concerning detectable warnings and audible traffic signlas issued by the Access Bard on June 17, 2002. Requiring audible traffic signlas at every corner with a Walk/Don't-Walk sign would be highly detrimiental to blind persons and would inhibit rather than promote safe travel for blind people. Requiring detectable warnings at every street crossing is an unnecesary and costly measure; blind travelers do not need detectable warnings at every street crossing, only at crossings where the slope of the ramp leading inot the street is 11 to 15 or more inches. The independence and safety of blind people will be effected in a drastily negative way if these guidelines are adopted.
Tonia Trapp
To whom it may concern,
I am writing to register my comments regarding the Access board's draft guidelines for public rights of way. I am a 39 year old man who lives in Virginia.
I would like to make comments in the following three areas:
1. Audible Pedestrian Signals
I am opposed to the draft guidelines as they are currently written concerning APS, blind persons are capable of crossing streets using traffic noise independently in most situations. However, I can see where APS would be of assistance in complex intersections. I feel that it is unnecessary to install APS at all new and renovated intersections as the proposed guidelines suggest without any consideration as to the level of complexity of that intersection's traffic flow.
I believe that the Access Board's guidelines should require that a panel of persons from blind consumer groups plus mobility instructors in that community should decide if APS and detectable warnings are warranted for a particular intersection.
It has been my experience in crossing streets with my cane is not a problem but the issue is that some drivers don't pay attention to see if anyone is in the cross walk before turning right on red for example. Once trained a blind person can negotiate most intersections with no issues.
2. Detectable warnings on cross walk ramps I feel that detectable warnings are not necessary on most cross walk ramps except when the decline or incline is very slight. Again this would be best determined by a panel of blind persons and mobility instructors in the community where the detectable warnings are to be installed.
3. Detectable warning strips along train platforms I am whole heartily in favor of placing detectable warning strips at the edge of train platforms. Not because of my blindness but because I think it makes sense as a safety issue for all persons and I think it should have been made a requirement from the start. Think of all our children who don't pay attention to there surroundings until it is to late. Think of
all the adults who have something on their hurried minds and don't pay attention to what they are doing eater. See I think the detectable warnings on train platforms is not a blind safety issue but a people safety issue.
Now I could envision a circumstance during rush hour where there would be so many hurried people pushing to get on a train that it would not allow a blind person to correctly use their cane. So the edge of the platform might be difficult to find at that time. But let me make myself perfectly clear that if it was a perfect world where persons respected you and allowed you to use your cane properly it would be no problem to find the edge of the platform.
Sincerely,
Scott White
Paul D'Addario, September 9, 2002
I'm writing you to express my strong support for detectable warnings on subway and train platforms, and for accessible pedestrian signals.
Each working day, I travel to work using 3 Washington Area Metro stations. 2 of the stations have detectable warnings, one does not. I have first-hand experience of how having the warnings makes a significant difference in my ability to navigate through the stations, avoiding people, suitcases, carts and other impediments.
In addition, my walk home requires me to cross an extremely well traveled street during rush hour. At one time there was no audible signal indicating when the traffic signal had changed. Since the time when one was installed, my walk home has become significantly less dangerous.
In addition, there is an audible signal near my office building that makes it possible to cross a busy intersection in Alexandria, VA.
I am fortunate to have these pedestrian signals, and detectable warnings. I've lived with them and with out them. And can testify that they make a life saving difference. I urge you and the U.S. Access board to look at the evidence, such as the the PROWAC report and do what is necessary to ensure that this relative simple, yet life-saving technology is required where appropriate. Lives are lost for so many unpreventable reasons and we should all endeavor to decrease instances where preventable loss of life occurs.
I would be happy to speak with you further about any of the above. Thank you.
Paul D'Addario
Database Manager
American Society for Industrial Security
Maurine E. Barcelo, October 7, 2002
My name is Maurine Barcelo and I reside in the state of California. I understand that there is a draft proposal, which will put audible signals and detectible warnings at new and repaired street corners. As the proposal stands now, I am against the entire draft. I feel, both as a blind person and as a wheelchair user, that this draft will have a direct impact on me; therefore, my comments are as follows. First there is the issue of the audible signals. I personally believe that audible signals are not needed to allow a blind person to cross the street. If there has been proper mobility training, there shouldn't be any problem crossing the street. However, if a particular corner becomes a traffic hazard for the blind of a given community, then that community and its blind citizens can determine if and where audible signals are needed. Secondly, there is the issue of the detectible warnings. Once again, if there has been proper mobility training, finding the street should pose no problems for a blind person traveling. Most importantly is the fact that curb cuts were made for wheelchair users, and I feel that these detectible warnings will become an obstruction for the wheelchair user. What are these warnings going to be made of? How high will they be? Will these warnings also cause problems for walkers and cane users? Will the wheels of my wheelchair get jammed in the detectible warnings and will I tip and fall out into the street? I am totally against these detectible warnings in all cases.
Sincerely,
Maurine E. Barcelo
Nancy Karstens, September 9, 2002
Please push for the legislation making detectible warnings manditory. Audible traffic lights and rough places on subway platforms have protected me many times. We need more of them. Thanks,
Nancy Karstens, Omaha Ne.
Thomas Cumings, October 29, 2002
My name is Thomas Cumings, and I am totally blind. I am writing to request that you keep in place and do not overturn the recommendations of the public right of way advisory committee to the U.S. Access Board regarding regarding detectable warnings and accessible pedestrian signals. I live in a large city, and the accessible trafic signals I use help me greatly in my travel. I support the regulations regarding these signals and detectable warnings.
Dear Access Board,
I am a blind person living in the Capital District area of New York. I think that the audible pedestrian signals, for the most part, are a waste of taxpayer dollars. In order to pay for universal installation of these signals and detectable warnings will probably result in tax increases or cuts in other federal programs.
I think the tax dollars would be better spent on education and mobility lessons for those who are in need of those services.
The benefit of installing APS and detectable warnings is far too expensive.
Carl Gage
Janice L. Squires, October 16, 2002
To Whom It may concern,
I am in total favor of pedestrian safety for the blind. I am totally blind and use a guide dog for mobility. There are many intersections in my home area, of which I would be unable to cross safely without audible signals and detectable warnings. Please consider voting yes to audible signals and detectable warnings for the federal guidelines.
Thank you,
Janice L. Squires
Ray Campbell, September 10, 2002
I am writing to urge you in the strongest terms possible to adopt strong language in the Public Rights of Way Accessibility Guidelines for Detectable Warnings and Accessible Pedestrian Signals. As a person who is blind, I assert that any weakening of the language as studied and adopted by the Public Rights of Way Advisory Committee would jeopardize my safety and the safety of those like me. This cannot be allowed to happen.
For almost 10 years, detectable warnings in the form of truncated domes on railway and subway platform edges have provided full access to the same visual information sighted persons have had all along. I regularly use commuter rail, subway and L trains in the Chicago, Illinois area. I am regarded by many as having excellent travel skills using the white cane. Yet, I find that I move about with more confidence on platforms where detectable warnings are installed than on those where they are not.
Contrary to what some might insinuate, detectable warnings are not a substitute for good training. I still must use my good judgment and sound travel skills even when detectable warnings are present. I must still concentrate and be aware of my surroundings at all times. Just a couple of years ago, I was on a rail platform that had detectable warnings. I had something else on my mind and was not paying attention to my traveling as I should have been. I almost walked right off of the platform edge and into the railroad bed. Had I done this, it would have been my fault.
The detectable warning is simply that, a warning to tell me I'm getting close to the edge. Sighted people have different colored lines on platforms to tell them when they are getting close to the edge. The detectable warning is my "different colored line." If I don't need detectable warnings, then please tell me why people who can see need a different colored line at the platform edge.
Accessible Pedestrian Signals provide me as a person who is blind assurance that it is safe for me to cross a street, particularly at a heavily traveled intersection. With urban sprawl, increased traffic, wide, busy streets and other factors, installing these signals is more important than it has ever been. Again, just because an accessible signal is present DOES NOT mean I can forget about using sound travel skills and judgment; I cannot. If I am at an intersection where an accessible signal is present, and that signal tells me it is safe to cross, but there is a car sitting in front of me in the crosswalk, I most certainly will not cross until that vehicle moves out of my way.
Some say accessible signals cost to much. I say two things. First, how can you put a price on a human life? And second, it costs about $75,000 to provide regular signals at intersections. It only costs about $4,000 or about 5.46% additional to install accessible signals. Furthermore, according to the Transportation Equity Act for the 21st Century, 80% of the cost for accessible pedestrian signal installation near public transit facilities can be paid for with Federal dollars.
Today's accessible signals are not annoying like those of the past. The audible locating tones they emit to help a pedestrian who is blind find the push buttons are only audible from 6 to 12 feet
Some will tell you that we can rely on just the traffic flow to determine when to cross the street. If that's the case, then why do sighted people need walk and don't walk signs? The accessible signal is our walk don't walk sign. Furthermore with increased traffic as I already mentioned, distracted drivers, quieter cars and right turn on red, being able to use an accessible signal to know for sure that it is safe to cross is critical to my safety. In fact, these signals not only benefit people who are blind, but they also are of value to Senior citizens, small children and people with other disabilities. And to those who would say we do not need them, I say fine, you don't have to use them.
There is a major 4 to 6 lane street with a lot of traffic on it that runs through the community where I live. The street is home to many stores, restaurants and other businesses. If I want to patronize many of these businesses, I must be able to cross this major street. An accessible signal would make crossing this street much easier for me as I would have the assurance that I am crossing when I am supposed too.
It's not just nice to have detectable warnings and accessible pedestrian signals. It's a matter of personal safety and equal access to the built environment for people who are blind. Again, I strongly urge that the Public Rights of Way Accessibility Guidelines come out in their final form with very strong requirements for the installation of both detectable warnings and accessible pedestrian signals. The lives of people who are blind depend on it. Thank you very much in advance for your time and for taking my comments.
Sincerely,
Ray Campbell
Claudia Pattison, COMS, October 29, 2002
As a certified mobility instructor for the legally blind, I would like to support the importance of accessible pedestrian signals and detectable warnings. Where they do exist, they have been a big improvement that have allowed the legally blind to remain independent. I can only hope that accessible pedestrian signals will continue to be used at more complicated traffic intersections and that detectable warnings will also be used at transportation buildings and at ramps.
Claudia Pattison, COMS
Louis Maher, September 28, 2002
There is a proposal, before the Access Board, to install accessible pedestrian signals (APS's) and detectable warnings everywhere.
These APS's and detectable warnings are unnecessary and expensive. This money could more profitably be spent on rehabilitation services for the blind.
Accessible pedestrian signals should never be used to provide directional guidance. If APS', with locator tones for each APS, were fully deployed, the standard intersection would have eight beeping APS buttons, adding to the general noise at the intersection. This increased noise background would make it more difficult to hear the flow of traffic.
The guidelines before the Access Board also require detectable warnings at every crosswalk. The National Federation of the Blind (NFB) recommends that detectable warnings should only be considered if the slope of the curb ramp is 1-15 (1 inch
APS'S should only be used when traffic patterns do not provide the clues the blind rely upon to know it is safe to walk. In these cases, the NFB recommends vibrotactile APS's which inform the blind pedestrian that it is safe to walk without increasing the noise in the environment.
Based on my 17 years of total blindness, I know, that with training, the blind are able to travel competently without such costly modifications to our environment.
Regards
Louis Maher
Paul Dressell, October 18, 2002
My wife, Bernadette, and I are totally blind and have been traveling independently wit the use of white canes for over 40 years without detectable warnings. Although we reside in Cincinnati, Ohio, we have traveled in many large cities such as Atlanta, Chicago, Toronto, and New York City. With a 70% unemployment rate, it is important for those who are blind to live in the world as it exists. The instances when detectable warnings would be beneficial are very small. With the state of the economy, I should think that any reason for not spending money would come as welcome news. With adequate mobility training, pedestrians who are blind can navigate most thoroughfares; any installation of detectable warnings should be done in consultation with residents who are blind and live in the areas under consideration for such devices.
Sincerely,
Paul Dressell
Donna Sanchez, September 12, 2002
My name is Donna Sanchez. I am a Legally Blind and a member of the Silicon Valley Council of the Blind which is affiliated with California Council of the Blind which is affiliated with the American Council of the Blind. I would like to let you know that I support the Public Rights of Way Advisory committee regarding detectable warning and accessible pedestrian signals which Charlie Crawford and Melanie Brunson from ACB sat on. Detectable warnings prevent folks from falling into subway pits and alert us to the fact that we have reached an area of potentially hazardous traffic flow. Accessible pedestrian signals help us to cross the street safely.
When I was in my 20's I was hit by a car. There were no Pedestrian signals at that particular time. Had the signals been there I know I wouldn't of been hit. As of today I still have back problems.
Please make sure there are pedestrian signals and especially detectable warnings because Blind people need them a lot in order to lead normal lives and to be able to travel where ever we need to go.
Thanks
Donna Sanchez
Please consider installing detectable warning signals to help protect people who are blind from being hurt. I support the Prowac report and hope that the Federal Government will begin implementing detectable warnings. It is difficult to learn Orientation and Mobility and travel safely around cities where signals are erratic. On noisy streets, it can be very disorienting and one mistake can be fatal. Anyone who does not believe this should try doing it. Walk on a subway platform with your eyes blindfolded--and see how safe you feel doing so. The technology to put warning strips is here and should be used. It not only helps people who are blind, but others such as senior citizens to live safer lives while traveling our neighborhoods.
Please consider this. Thank you for your consideration.
Sincerely,
Cathy Long
Thomas H. Slack, September 14, 2002
MY NAME IS TOM AND I AM VISUALLY IMPAIRED. I URGE YOU TO SUPPORT LEGISLATION THAT WOULD ENACT NATIONAL LAW REQUIRING THE USE OF DETECTABLE WARNING SIGNALS AT PUBLIC LOCATIONS OF DANGER TO VISUALLY IMPAIRED PEDESTRIANS.
I UNDERSTAND THAT THERE ARE THOSE WHO OPPOSE SUCH LEGISLATION AND I DO NOT SEE HOW THERE CAN BE LOGICAL OPPOSITION TO THIS SIMPLE REQUIREMENT. ANY SUCH OBJECTION IS, IN MY OPINION, WITHOUT CONCERN OR COMPASSION
FOR LOW VISION PEOPLE. CAN YOU IMAGINE ANYONE ASKING A LOVED ONE WITH VISION IMPAIRMENT TO WALK IN DANGEROUS AREAS THAT DO NOT HAVE DETECTABLE
WARNING SIGNALS?
AS A PERSONAL EXAMPLE I KNOW A YOUNG BLIND LADY WHO NEVER HAD VISION AND
WHO IS AN EXPERT USER OF A WHITE CANE. SHE WAS USING AN ELEVATED
WALKWAY THAT HAD NO WARNING STRIPS AND SHE FELL SEVERAL FEET, BADLY
INJURING HERSELF. EVEN EXPERTS CAN MAKE MISTAKES AND WHEN THE RESULT IS BODILY INJURY OR EVEN DEATH THERE CAN BE NO EXCUSE FOR LACK OF THE APPROPRIATE WARNING SIGNALS.
I AM INTERESTED IN THE ENACTMENT OF NATIONAL LAWS THAT MANDATE THE USE OF DETECTABLE WARNING SIGNALS IN AREAS OF PUBLIC USE WHERE SEVERE INJURY CAN RESULT TO VISUALLY IMPAIRED PEDESTRIANS.
MAY I SUGGEST A LITTLE EXERCISE THAT WILL MAKE MY POINT. GO WITH A FRIEND TO A RAIL STATION THAT HAS NO WARNING STRIPS ON THE EDGE OF THE TRAIN PLATFORM. BLIND FOLD YOURSELF AND EXPERIENCE FIRST HAND THE HORROR OF NOT BEING ABLE TO SAFELY FIND THE EDGE OF THE PLATFORM WITH THE ATTENDENT DANGER OF FALLING ONTO THE TRACKS. THIS EXPOSURE TO THE EVERY DAY LIFE OF A BLIND PERSON OUGHT TO MAKE A BELIEVER OF ANY SANE INDIVIDUAL WHO MIGHT OTHERWISE BE OPPOSED TO THE USE OF DETECTABLE WARNINGS.
NOT ONLY DO WE NEED TACTILE WARNING STRIPS, STRIPS THAT CAN BE DETECTED BY A CANE OR UNDER FOOT, BUT WE ALSO NEED BRIGHTLY COLORED STRIPS OF
YELLOW OR ORANGE TO PROVIDE VISUAL DANGER SIGNALS TO FOLKS WITH LOW VISION LIKE MYSELF.
I HUMBLY ASK YOU TO EXERT YOUR INFLUENCE WITH THE U.S. ACCESS BOARD ON THIS ISSUE AND TO SUPPORT THE RECOMMENDATIONS OF THE PROWAC
COMMITTEE TO ESTABLISH THE NECESSARY REGULATIONS. THIS IS OF MAJOR
CONCERN TO ME.
IF YOU HAVE ANY QUESTIONS PLEASE CONTACT ME BY RETURN EMAIL.
THOMAS H. SLACK
CONCERNED CITIZEN
Joan Muldoon-Burk, October 28, 2002
To Whom It May Concern:
I'd like to register my support to provide accessible pedestrian signals and detectable warnings at busy intersections. I can be notified for further comment at my home address: Joan Muldoon-Burk [...] This is a serious concern. Please support the PROWAC report.
Thank you,
Joan Muldoon-Burk
Dory Fisher, September 8, 2002
I wish to express my support of the prowac report. It is vitally important that blind persons be provided detectible warnings and audible pedestrian signals to prevent unnecessary deaths.
Dory
To Whom It May Concern:
As the president of the largest consumer organization of the blind in the state of California it is my responsibility to advise this board of the sentiments of the National Federation of the Blind of California.
The majority of our members travel about easily, and have for years, with either their white cane or guide dog. The advent of audible signals and detectable warnings, in most instances, has not been helpful but often disconcerting. We, as blind travelers, use the sounds of the traffic flow to cross intersections. We use our white cane to locate curbs and find the detectable warnings to be hazardous, particularly in rainy or snowy areas.
We further do not feel that it is the taxpayer's responsibility to provide such devices. These guidelines recommending the installation of audible signals and detectable warnings at every intersection in every city are totally unacceptable. There may be instances at particularly difficult crossings where such audible signals could be helpful. On the whole the vibro-tactile warnings are much preferred. In either situation there needs to be standardization of the placement of such devices.
Thank you for your attention to our concerns.
Sincerely,
Nancy Burns, President
National Federation of the Blind of California
Rebecca Kragnes, September 9, 2002
I am writing to support the position of the American Council of the Blind (ACB) concerning the need for accessible pedestrian signals and detectable warnings. Both of these items will make it safe for people who choose to use them. I haven't experienced the benefits of detectable warnings on train platforms, but we are soon to have a light rail system in Minneapolis where I reside. After having the frightening experience of using noisy, crowded subway stations where detectable warning signals were not available, I hope that Minneapolis and the nation will make use of them. I have benefited from an accessible pedestrian signal at a particularly dangerous intersection -- a wide street with lots of fast-moving traffic with very little traffic on the parallel street. It has been one more tool which helped me to travel safely.
I understand that you are receiving arguments from members of the National Federation of the Blind (NFB). They tell you that somehow accessible pedestrian signals and detectable warnings make the general public view blind people negatively. The general public use traffic signals and see warning signs. They understand the value of both of these things, and do not begrudge us having equivalent measures. The reality is that accessible pedestrian signals and detectable warnings save lives, and the lives of blind citizens are worth more than some abstract, ideological principle. If Federation members choose not to use accessible pedestrian signals anddetectable warnings, that's their business. However, I don't want to see NFB's supposed "philosophy of blindness" deny all blind people from having these options available. NFB is also saying that accessible pedestrian signals and detectable warnings aren't necessary if blind people have good travel skills. First, not all blind people have good travel skills. There are those who are denying their blindness, who are elderly, and/or may not be good travelers despite training. Should they be punished by being denied accessible pedestrian signals and detectable warnings and having to risk their lives because of their lack of skills or abilities in the area of travel? Second, blind people who have good travel skills have found these things to be helpful to them. All of the good travel skills in the world won't help in situations blind travelers find themselves in every day. Accessible pedestrian signals and detectable warnings are two more tools which can be used by a good traveler. Thank you for your time effort and consideration of this matter. Sincerely,
Rebecca Kragnes
Gary Fottrell, P.E., August 29, 2002
After reading the proposed guidelines, I would like to offer the following comments:
1. In the "Discussion of Provisions" section, Crosswalks, (1105.2), the proposal is to require the cross slope on crosswalks be limited to 1:48
When designing a major roadway - let's say you're widening an existing 2-lane roadway to a 5-lane roadway with curb & gutter and sidewalks in a suburban area - the first thing the designer does is take the survey and design a profile. This profile is always a smooth profile, and hopefully is in accordance with the guidelines set forth in the AASHTO "Green Book". No designer that I know will interrupt his profile every few hundred feet with the introduction of the adjacent vertical curves required to flatten the grade through intersections. They certainly will not want to create a "table effect", but would, instead, want a smooth, uninterrupted profile, particularly on the primary route. On the side roads, the situation is completely different. Minor side roads are always tied in to the main route, and the result is a table effect. This is an expected condition for a minor side road, and vehicles usually are required to stop on these minor streets anyway, so the effect of a "table" is of no consequence. Cross slopes of crosswalks on side streets are usually acceptable.
I understand what the Board is trying to achieve, and, ideally, it would be great if the crosswalk side slopes could all be no more than 2%. Is this really the maximum slope that is acceptable for these cross slopes?
I believe that the "table" requirement on primary, heavily traveled routes is not feasible, and that the vast majority of crosswalks that cross major routes will continue to have cross slopes that are equivalent to the grade on the main roadway.
2. I am having some confusion concerning 1103.7.1, Detectable Warnings at rail crossings. In the "Discussion of Provisions" section, it is noted that "the draft guidelines would also require detectable warnings at the outside of each group of tracks that cross the pedestrian access route". So every time a railroad track crosses an access route, detectable warnings (i.e., truncated domes) are required to be installed. Then it notes that the warnings "would not be required at tracks sharing vehicular ways, such as street car tracks". This is all clear.
In the Draft Guidelines, Section 1103.7.1, it states "Where rail systems cross pedestrian facilities that are not shared with vehicular ways, a detectable warning shall be provided." This sentence says that when the pedestrian facility is not shared with a vehicular way, i.e., when you do not have a sidewalk with curb & gutter section along a roadway, but when you would have a pedestrian trail of some type separated from the roadway, then you would have a detectable warning. In other words, with a curb & gutter with sidewalk, you don't need the warning because the pedestrian facility is shared with the roadway. If you have a separated pedestrian trail, you do need the warning. I don't think this is what is intended to be said, according to the "Discussion of Provisions".
I could better understand it if it were stated as "Where pedestrian facilities cross rail systems that are not shared with vehicular ways, a detectable warning shall be provided in compliance with 1108." That would more closely parallel the comments made under 1103.7.1 in
3. In the Draft Guidelines, Section 1108.2.2, Rail Crossings, the text discusses the placement of the detectable warning as related to the "vehicle dynamic envelope". I assume this envelope is the edge of a moving train, plus a little extra for safety. Designers will not know what a vehicle dynamic envelope is. I recommend that the research be done that is required to determine a good number to put in place of this term.
Thank you for the opportunity to comment on the guidelines.
Also, do you know of any states that have good, ADA compatible, standard drawings of handicap ramps that I could access on the internet? I would like to try to get the one Tennessee uses redrawn to comply. If you'd like to see it, check out drawing RP-H-1 athttp://www.tdot.state.tn.us/Chief_Engineer/engr_library/design/Std_Drwg_Eng.HTM
Gary Fottrell, P.E.
Area Engineer
Federal Highway Administration
Nashville, TN
Audra Kramer, October 28, 2002
COMMENTS NEEDED ON AUDIBLE TRAFFIC SIGNALS AND DETECTABLE WARNINGS
SUMMARY:
Blind people travel safely every day without adaptations to the built environment. Moreover, suitable and sufficient alternative methods and information are normally available to provide us full and equal access without modification. Modifications should be considered only when sufficient nonvisual cues are not otherwise available.
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.
The draft guidelines call for detectable warnings whenever a sidewalk (including a median or island) joins a crosswalk. However, this is not necessary to provide accessible and safe travel for the blind. There are adequate cues available to detect the transition from sidewalk to street. Therefore, detectable warning should only be installed when the slope is virtually flat, referred to as 1:15
Audible Traffic Signals
* 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 better promote safety.
* Locator tones should not be included in the final guidelines and may be subject to further research.
Detectable Warnings
* 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
Miriam Vieni, September 8, 2002
I am writing in support of the proposed regulations from the Public Rights of Way Advisory Committee. As a blind person, I believe that there is a need for detectable warnings and accessible pedestrian signals. As the environment becomes more complex, our safety depends on detectable warnings at places where vehicular traffic is likely to be found and accessible pedestrian signals. There are streets in the town of Westbury, Long Island (where I live) which I will not cross because I cannot see (nor can I hear) regular traffic patterns. I believe that the lives of blind people are at stake.
Miriam Vieni
Yasmin Reyazuddin, September 23, 2002
Greetings Board members,
I am writing to you about the proposed guidelines to install Audible traffic signals and detectible warnings at every intersection in the country.
Blind people have traveled safely with least numbers of injuries or harm to themselves. The long white cane has been our tool to navigate the obstacles on the streets. The motorists need to know about the white cane laws and be punished for not yeilding to the blind pedestrian. Complex intersections can be navigated when the blind person listens to the traffic pattern and crosses safely. Detectable warnings and audible signals are expensive and should be restricted by all means. As a taxpayer, I do not wish any more expenses on the local government.
I would like to add that the Audible signals will cause more confusion on the streets for blind pedestrians and detectable warning strips will be dangerous to people who for one reason or other drag their feet.
Yasmin Reyazuddin
Sligo creek chapter of NFBMD
Charlie Dennis, October 4, 2002
Dear Friends,
PLEASE don't approve the audible traffic signals and detectable warnings. While these things may be necessary in some situations, it is hardly necessary to put them everywhere. If they are to be installed, please let blind people, rather than concerned sighted people, tell you where to put them.
In most situations, there are already audible traffic signals and detectable warnings in place. The edges of curbs are detectable, as is the space between an El-car and the El-platform; a blind person can tell where he is simply by properly using his cane. In most situations, if the sound of traffic is in from of us, it means we can't cross the street yet; if the traffic sounds are to our right or left, it means we're free to go forward. Audible signals would be necessary only in areas where there are other noises in the mix.
Audible signals can break down or malfunction; if that happens, lawsuits are very likely soon to follow. Sighted people would be put at risk by detectable warnings, because they usually go too fast to notice them. A blind person who needs audible signals or detectable warnings will either have someone with vision with him, or ask for help--yep, good old human interaction--the best things in life are free!
Sincerely,
Charlie Dennis
National Federation of the Blind, Chicago Chapter
Dear Access Board:
My experience with audible signals and detectable warnings has been a frustrating and difficult one. As a blind person traveling with a white cane I listen to the flow of the traffic. With the audible noise of these signals I found it extremely difficult to hear the flow of the traffic.
Also, detectable warnings at every curb seem to me a totally ridiculous expense of taxpayers' money. They are not only not needed but not wanted.
Sincerely,
Joy Stigile
Mike McAviney, September 15, 2002
As a totally blind person who must cross streetsalone, access train platforms and other traffichazards with only a cane to guide me, I want to saythat I found the detectable warnings and accessiblepedestrian signals that I have encountered in Japan,Great Britain, and occasionally in the U.S. to be oftremendous help and I hope you will officially supportthem.
Having the signals audible on both sides of the streetgives me a beginning point to step off the curb aswell as an aiming target for crossing streets,particularly helpful when the streets angle slightly.
If you tour the RNIB (Royal National Institute for theBlind) facilities in Great Britain, you would see howthe tactile detectible warnings on the floor signal tothe blind person that he is passing in front of adangerous area (such as a door opening out into ahall) or that there is a curb or obstacle ahead.
In Japan, the tactile detectible warnings come in twopatterns: parallel lines mean it is clear to travelin the direction of the parallel lines; half circlesraised (truncated domes) means there is danger aheadsuch as a curb or a railroad platform dropoff.
Such traffic aids would make blind people moreindependent and self-confident with mobility travel. It would give them a safety net. You try crossing astreet or navigating across a platform and into atrain while blindfolded and using only a cane, and youwill see what I mean!
Mike McAviney
Debbie Kuczwara, October 28, 2002
To Whom it may concern:
I am writing in response to the detectible warning signals and curb cuts. I strongly disagree with The National Federation's belief that there should be no detectible warning signals. I am visually impaired and use the warning signals every time I cross a street that has a signal. I have some vision but I can't see well enough to cross a busy street without one. The way our signals are set up here in Kentucky, is that they are not activated unless the person crossing the street wants to activate it. This doesn't interfere with the traffic at all.
As far as the curb cuts are concerned, I find those helpful as well. Sometimes it's hard to tell when you are getting close to crossing a street because there isn't a step down into the street. If there is a textured curb cut, this lets you know that you are getting close to the street. Since most of them are yellow it is fairly easy for a low vision person to see these. I also find these very helpful.
In closing, I would urge you to increase detectible warning signals and textured curb cuts not decrease them. I know there are many people here in Louisville that find them helpful. We are trying to get more added. These signals help me live a more independent life. Without these signals, I would not be able to go to work and other places on my own. Thank you for your consideration.
Sincerely:
Debbie Kuczwara
Karen J. Clayton, October 5, 2002
I wish to express my opposition to the proposed rules regarding audible traffic signals (ATS) and detectable warnings. Philosophically, I believe such adaptations are unnecessary and mandates are wrong. I think they present logistical problems and are financially burdensome.
Most intersections provide adequate information--trafic patterns and change in grade--to allow safe crossing. As written, the guidelines require locator tones for "don't walk" and ATS tones for "walk." This may actually decrease safety because of the constant distractions added to the soundscape. Detectable warnings or ATS may enhance safety when the grade is nearly flat (1:15 or less) or the geometry of the intersection is complex. Current law requires the use of ATS when appropriate for safety but allows municipalities to make that determination.
I see several problems with the universal placement of truncated domes to identify the end of the sidewalk. In northern regions, leaves and snow and ice will become packed into the spaces between the domes. Who will clear them? We have become accustomed to curbcuts for wheelchairs. Will domes not interfere with travel for persons in wheelchairs? They are also a potential safety hazard for those who have difficulty walking. For example, one could twist an ankle stepping on the edge of the dome.
The cost of placing these modifications at each intersection far outweighs the perceived benefits. Many of the current traffic signals in my city need to be replaced because of age but have not been due to cost; the modifications would only add to it. And what about the many intersections not currently equipped with signals? The rule for detectable warnings appears to apply to all intersections--even rural
areas. These communities do not have enough traffic to justify the
cost of warnings and signals.
Please do not impose these extreme provisions on the American people.
Karen J. Clayton
Kathy Blackburn, October 20, 2002
To Whom it May Concern:
I am a blind person writing to support implementation of the public rights-of-way guidelines for accessible traffic signals and detectable warnings. Those blind people who tell themselves and others that they do not need accessible traffic signals are living in the past. In recent years, streett intersections and traffic patterns have become more complicated. Drivers have become more aggressive, and cars are being built to run more quietly. In such an environment, blind pedestrians need every bit of information available to assist them in judging when it is safe to cross the street. Furthermore, the state-of-the art signals' spoken messages can give us valuable orientation information which sighted people receive without question or debate.
I also support implementation of the standards for detectable warnings. If a street is quiet, it is possible to enter the street unknowingly where detectable warnings are lacking.
Please implement these guidelines so that all pedestrians will travel more easily and safely.
Sincerely,
Kathy Blackburn
Mary Ann Lareau, October 18, 2002
Dear Access Board Members:
Blind folks do not need detectible bumps and beeping poles at every intersection. There may be instances where audible traffic signals could be helpful. However, they should only be considered when traffic cues cannot be determined by blind pedestrians. We acknowledge that there are some situations where detectible warnings should be installed. When we are unable to tell the difference between sidewalks (including medians and islands) and the street, detectible warnings are appropriate. However, most situations do not require audible signals or detectible warnings.
We are the blind and we know what we need. There is a true risk that our pedestrian ways will become less safe with the installation of audible traffic signals and detectible warnings.
Blind people travel safely every day without adaptations to the built environment. Moreover, suitable and sufficient alternative methods and information are normally available to provide us full and equal access without modification. Modifications should be considered only when sufficient nonvisual cues are not otherwise available.
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 better 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
Sincerely
Mary Ann Lareau,
Secretary, NFBM
Dear Sir:
I am writing to oppose both audible traffic signals, (APS) and detectable warnings' installations at all intersections in our nation. These would be of more use to travelers who are blind if each intersection thought by someone to have a problem were considered individually both by the traveler and by his/her city officials to address difficulties with the intersection.
Blanket installation of either APS signals or detectable warnings at all walk/don't walk intersections could prove to be hazardous to blind travelers. Overall installation would also be extremely expensive and perhaps difficult for up-keep and/or maintenance if cement formations of certain dectectable warnings were subjected to long-term weathering.
Thank you for your attention.
Sincerely,
Debra Baker