Comment from Cartwright, Paul

The Proposed Guidelines for Public Rights-of-Way (docket number ATBCB 2011-04) do not prevent excessively loud locator tones on accessible pedestrian signals. A clear and enforceable volume standard is needed. The MUTCD guidance suggests a maximum of 5 dBA louder than ambient sound. Making that the standard should be sufficient. R209.1 requires accessible pedestrian signals and pedestrian pushbuttons comply with sections 4E.08 through 4E.13 of the MUTCD. Section 4E.12 does require pushbutton locator tones to be intensity responsive to ambient sound, and to be audible 6 to 12 feet from the pushbutton, or to the building line, whichever is less. However, this evidently can be read as a minimum range for audibility, not a maximum. MUTCD only provides a guidance on maximum volume, not a standard. This MUTCD guidance (Section 4E.11, where a setting of a maximum of 5 dBA louder than ambient sound is suggested) is not always followed, even though it’s been in place for some time. I live a quarter-mile from an intersection with locator tones and we can hear them on summer nights. Even during rush hour, the tones can be heard on the sidewalk more than 100 yards away. Requests to the state Department of Transportation by Helena’s Department of Public Works and by private citizens in recent years have been followed by inspections but no change in the signal volume. Least this be taken as a problem with one particular department, I have noticed similar excessively loud locators in other cities. Most recently, when I was in Phoenix, a signal near a park was so loud that no people were sitting anywhere in the park near the intersection, even though the park was otherwise crowded.