I recently became aware of the draft guidelines proposed by the Architectural and Transportation Barriers Compliance Board which address accessibility in the public right-of-way. In particular, I would like to comment on the provisions which are of greatest concern to pedestrians who are blind or visually impaired: the use and design of detectable warnings on curb ramps (1104.3.2, 1105.4.2, and 1108) and the use and design of accessible pedestrian signals (1106).

As an individual who is blind and also as a director of an educational program which serves children and adults who are blind, the proposed guidelines present a number of problems. First, the proposed rules are two broad in scope and serve to create a more confusing environment rather than a safer one. In our programs, which have operated and evolved over 150 years, we teach both children and adults who are blind to learn to use the long white cane, their hearing, and other environmental clues to guide them through the community. We attempt to give them skills which will be transferable to any travel environment. Sometimes, we deal with students whose travel ability is limited by additional disabilities. In these cases we give them additional training techniques which help them to make wise choices when traveling in the community. In all cases, the one sure thing we can train them to rely on is their cane and their own senses. Our experience in training students is that they are better prepared to tackle any situation if first they have mastered the general skills which allow them to analyze the environment and make meaningful decisions based on that information. The guidelines, as proposed, would be so wide sweeping that in many cases the audible pedestrian signals will mask the clues we teach students to rely on. The provisions for detectable warnings are similar in that there are many cases where they create a false sense of security, diminish the responsibility of the blind person themselves, and create expectations which are not met in every travel situation. For example, we train students to travel in some areas where travel through parking lots or across frontage roads is required. These areas often contain situations that will not include detectable warnings and if students begin to expect them when they are not there, they may be putting themselves in a more dangerous position.

Secondly, we must recognize the true responsibility of the community and the government. As a Wisconsin State agency, we are constantly battling to maintain the funding that we have. In local school districts, many blind children are not receiving proper orientation and mobility services, if at all, because districts can not find staff or are unwilling to spend the money. Yet, these guidelines propose spending thousands of dollars to further diminish the responsibility of the blind traveler and interfere with the skills of travel that have been essential to independent travel for decades. I am not supportive of letting dollars run the show. However, I also recognize that choices must be made. I would also never put our blind children in a position that would diminish their future in any way. These guidelines will put an unnecessary burden on the community to implement equipment which is unnecessary; it will put an unnecessary burden on programs for training blind people because we will have to fight even harder to convince the public of why our programs are essential; it will send a negative message about all blind people even though there is only a small handful which prefer to rely on one system of signals rather than a set of skills for success; and who will bare the burden when a pedestrian signal fails and a blind person is killed because they followed the signal rather than the other clues of the environment?

Lastly, there are adaptations that are necessary and helpful to people with disabilities in the environment. Many of these are addressed in the guidelines and will make a difference in the independence of these pedestrians. However, these particular guidelines will have a negative effect on blind people, their status in society, and the programs established to train the blind. The Access Board, would be wise to leave the decision up to local communities and local blind consumers who can best judge the patterns and characteristics of intersections based on their unique qualities. Furthermore, where is the research that supports these guidelines? I have read extensively in the field of blindness and have yet to see good research that supports these adaptations. Yet, in the city of Janesville where we run our programs, not every street is required to have a sidewalk for pedestrians but they will be required to have an APS at the corner? I have read about the research on which beep or noise would be best from an APS and even there the research has said that there is no consensus. This lack of good research, including good research on the methods and tools used to train blind people to travel, worries me. If we do not start to truly examine how we are preparing blind children to go about the world, we are not going to have to worry about them crossing the streets, we are going to have to worry about them leaving the house.

Let's focus our energy on training blind people and save the adaptations for those situations where they are truly needed, as determined by blind people in the area on a case by case basis. I hope the board will consider the negative impact these guidelines would have and instead provide some recommendations and/or research which will truly advance the cause of independent travel for blind people.

I appreciate this opportunity to provide comment. Thank you.

Mark A. Riccobono, Director
Wisconsin Center f/t Blind & Visually Impaired