Edward Bell, M.A., NOMC

October 8, 2002

Dear Access Board:

I am writing this letter to voice my opposition to the proposed guidelines for environmental modification. In particular, I am concerned about the mandates for Accessible Pedestrian Signals (APS) and detectable warnings proposed at virtually all street corners. I am a certified orientation and mobility specialist (NOMC), and have had experience teaching students to travel across many different types of intersections. Furthermore, I am a blind person, and therefore have personal knowledge of the dangers, or perceived dangers, inherent in our public rights-of-way. I hope that you will consider my comments in view of my credentials and experience as a professional in the field as well as a consumer.

The vast majority of intersections across this country have remained unchanged for decades, yet thousands of blind pedestrians have safely navigated the streets of America without the assistance of accessible pedestrian signals. Nevertheless, there have recently been built intersections which are large, complex and which may be appropriate for intersection adaptation. These are rare occasions, however, and should not become the rule for the rest of the country. I have traveled in my hometown safely, but I have also traveled in many large metropolitan cities, suburban communities and rural areas without the use of any environmental modification. More importantly, I have taught novice, intermediate and experienced students in similar areas with considerable success. As such, there has not been a place where I was either unable to travel or teach that was unsafe without APS or truncated domes.

accessible pedestrian signals already exist at some intersections, and I have had some experience with them. In addition, I was recently present at an orientation and mobility conference during which the newest models of accessible pedestrian signals were being tested. I can say unequivocally that the demonstrated models presented a greater danger than a solution to blind and visually impaired individuals. The intention of the design is noble, however, the devices fall far short of providing a needed function. Perhaps consultation with consumers during the development stage, rather than during the evaluation phase will assist manufactures in the development of better designs.

Advocates of environmental modification embrace the proposed guidelines as a desirable solution, yet blind consumers regard many types of accessible pedestrian signals as a nuisance and potential danger. The chirping sounds of the walk signal and the buzz of the locater tones can be confusing, and present a sufficient distraction to prevent the blind person from correctly identifying the traffic patterns. While walk/don't walk signals are a good idea, they do not control the traffic. Thus, blind and visually impaired pedestrians must be able to monitor the traffic flow without interference of extraneous sounds. Advocates present APS as a necessary accommodation to actuated traffic lights in which the cycle is controlled by traffic flow. These types of intersections, however, are currently controlled by pedestrian signals already in place. As I have already said, blind pedestrians depend on the movement of traffic, or the absence of traffic, to determine that it is safe to cross a street. Since existing pedestrian signals at actuated traffic signals already control the cycle for pedestrians, making them accessible is unnecessary, a waste of money and a potential danger.

I do trust and believe that the Access Board will come to see that the proposed guidelines on environmental modification are excessive, unnecessary and ill planned. As a mobility professional and as a blind pedestrian I will be more than happy to be a part of any future guidelines for accessibility. Please feel free to contact me at any time if I can be of assistance, and together we can make the public environment a safer place for everyone, without making it a potential danger to anyone in the process.

Sincerely,

Edward Bell, M.A., NOMC
Doctoral Student, University of Arkansas
Fayetteville Arkansas