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I am John McGaffey, President of Polara Engineering Inc. a manufacturer of Accessible Pedestrian Signals.

In general the proposed guidelines are quite good and long needed for standardization of APS's. However there are two items I wish to comment on.

1106.4.2 requires every sign to have the street name on it per 703.2. 703.2 requires raised letters. This requirement will make the signs very expensive and a maintenence nightmare for cities. I strongly recommend this requirement be removed. The requirement of the street name in braille on the sign or the option of an informational speech message that states the street name instead of braille would be a better choice.

In the places where the requirement of +2 to +5 dB above ambient is required, this is too limiting and will not allow for adequate adjustment of volumes to hear the units on very noisy intersections or where the pole placement is poor. A 2 dB change is virtually undetectable by the human ear and cannot be accurately measured. On an intersection with poor pole placement even 5 dB over ambient could be inadequate for a person to hear the walk indication when standing at the crosswalk. I feel a more realistic and functional range is +3 dB to + 10 dB with guidelines that the higher limit applies intersections with poor pole placement or high traffic ambient noise conditions.

I believe the implemention of these guidelines will significantly help towards standardizing these types of signals and drive their cost down so they will be easily affordable. Currently the cost for 8 units to outfit a standard intersection is approximately $ 4000 which is not unreasonable. However, if they become a standard feature, I believe this cost could drop by 23-35 percent, possibly more.

Sincerely,

John F. McGaffey
Polara Engineering Inc.