Aloha, Access Board!

I would like to comment on the draft guidelines under consideration--specifically, the parts referring to detectable warnings & audible traffic signals (ATS). There are some parts I'd agree with if they were slightly modified & some parts I'm against.

First of all, I'd like to say that I'm blind, sometimes use a wheelchair & have lived in 2 cities in which ATS were used (Honolulu, HI had constantly ticking ATS that ran 24/7 & Fayetteville, AR have chirping ATS that run only when the button is pressed) & have seen several types of detectable warnings in many more cities (including truncated domes), so I've had some experiences with each of the items under consideration. I'll share some of these experiences below to illustrate my points, but first, here is my position on the issues under consideration:

1. I want to see ATS *only* on intersections in which the geography or signalization is complex and/or in which there are no useful non-visual cues for crossing.

2. I strongly prefer vibro-tactile signals (in the shape of an arrow, if necessary to clarify complex signalization) as opposed to audible ones.

3. I'm against audible locator tones--instead, I strongly prefer a standard pole (perhaps with one square corner or oval, as opposed to round).

4. I want detectable warnings (if any) *only* at the top end of a slope in which the decline is not detectable by my cane (say, 1 in. rise / 15 in. run).

Whenever I've heard ATS in the past, they were on standard, 4 way or T intersections (usually near a school for the blind, rehab center, college, etc.). For example, the University of Hawai`i had at least 3 that I know of--one near the dorm, one near the parking garage & one near the bus stop (several blocks West & North on a perpendicular street). Then, there was one several block South on the street with the bus stop near the store, bank, copy shop, etc. I walked down to these places often & always wondered why those particular locations were chosen....

Here is the route: I don't need the two ATS along the street running in front of my dorm because I stay on the South side to go to the bank (campus is North, across the street). I cross to the West side of an intersecting street, but I'm South of the bus stop & there's no ATS here even though the signalization is a little more complex than at the other 3 locations (2 are T intersections, one's just one road; this one's a multi-lane 4-way) & there is *much* more traffic (it's here that drivers decide to split off depending on where they're going). I travel South, passing through on & off ramps to the freeway (negotiating traffic with drivers who are already thinking about merging with flowing traffic) & through some more standard intersections. If I am going to the store or bank or catching a bus on the route that stops near the bank, I don't even reach the 2nd signal on this street (the 1st is, as I'd said, near the bus stop to the North). If I am dependent on these signals & going to the copy shop, it's important that I remember to cross to the West side (as
above) because the copy shop is on the Southwest corner of this 4-way intersection & the audible signals here signal foot traffic going North-South, not East-West (just like the 2 on the perpendicular street--the one by the bus stop goes East-West).

How could I have gotten across those intersections & on & off ramps without signals if I wasn't trained to pay attention to traffic & environmental cues? I lived in HI before I was fortunate enough to receive quality cane travel training, but my parents had taught me about traffic flow & paying attention.

Not all blind people have been fortunate enough to receive the type of quality training I've received. There are a lot of issues that contribute to this (the quality of training O&M instructors traditionally receive, attitudes held by some VR administrators,
etc.) & cost is among them (although, I showed HI how it was actually cheaper for them to send me to a training center than to pay their own staff to give the type of intensive training I wanted).

There are a lot more intersections than blind people--consider the
following: quality training takes, on average, 6-9 months at about $3500/month. Let's call it 8 months & $4000/month for easy math--that's $32,000 per blind person. Next, multiply $32,000 by the number of blind people in the U.S. Now, multiply the cost of an ATS by the number of intersections in the U.S. Remember that there are fewer blind people than intersections & some complicated intersections will need more than one ATS.

Finally, subtract the cost for the people who've already received quality training from the total cost of training & subtract the cost per ATS for each intersection on which the one decided on to be the standard type is already installed from the total cost of installation (only a small percentage for each) & you'll see dramatically different figures in favor of quality training. It's less expensive & the people who receive it are more independent & are more productive members of society (i.e., they give as well as take).

I'm going to combine points 2 & 3 here as some of my examples address both. Remember those ticking signals I mentioned above? They constantly tick loudly so that people can find the intersection--slowly when it's not safe to cross & quickly when it is. Well, I lived on the 7th floor of a dorm about 50 feet from one of them & they got to be *very* annoying because *they never turn off*.

BTW, if an intersection is so complicated that a blind person needs help determining when to cross because non-visual cues are not present or useful, I don't like the idea of the technological solution being turned off at a certain hour (which was one solution suggested for the above problem) because blind people are not like children--we travel whenever we need to do so, including the middle of the night.

Deciding on a standard pole would eliminate the need for locator tones because (a) we'd know what to look for & (b) the shape of the pole would tell us this intersection is equipped with a signaling device that may be used by the blind. Some ATS I've encountered are only activated when I press the button, so (if I didn't already know there was an ATS there) there isn't anything telling me one is available, should I need it. Also, with locator tones & audible signals indicating it's safe to cross, I don't have the option *not* to use them. There are times (because of my chronic illness not related to my blindness) in which I experience "sensory overload". At these times, extra sounds are not only distracting, but also dangerous.

Vibro-tactile signals (with an arrow when necessary) are most helpful & desirable for 4 reasons: they are optional, don't cause the level of noise pollution that ATS do, can also be used by the deaf & deaf-blind & (if an arrow is used) unambiguously signal the direction that is safe to cross.

If I relied on audible signals & went to a new place, I'd have to know that this sound means it's OK to cross East-West & that sound means it's OK to cross North-South. (If we *have* to have ATS, at least come up with one type to use everywhere so that we don't have to guess every time we encounter a new type....) If no one is around to help me, how will I figure this out? By listening to traffic. Also, just as drivers should still look both ways before crossing an intersection in case another driver runs a red light, pedestrians need to double-check traffic--whether by looking (if sighted) or listening (if blind)--to be sure it's safe to cross. If I have to listen to traffic to ensure my safety anyway, what's the use of the ATS (except for complex intersections either by geography--like a round-about--or signalization).

With good training & attention to one's cane, most blind people can find steps, edges of railway platforms & so on as the tip of one's cane drops when a step down is encountered & runs into a step up. Training & attention will also tell most people where there is a significant slope.

I've heard of people (blind & sighted) falling off railway platforms. In many of the cases, however, rushing was also a factor (other factors included being pushed off by a crowd, falling on purpose (suicide attempt) & so on). People--sighted or blind--become careless when rushing. In fact, *after* detectable warnings were installed in Atlanta, a *blind* person fell off the platform (I'm not sure of the details of the case, but the truncated domes didn't prevent the fall...).

Another factor with domes is the risk for actually *causing* a fall. Women wearing high heels (myself included) find the uneven surface difficult to navigate--I've heard of women (blind & sighted) falling when they didn't expect to encounter this surface. Also, encountering the detectable warning is one more input to process.

For example, when we had a seminar at a school for the blind, there is one type of truncated domes at the top of a set of 4 steps. The first time I encountered them, they made me stop in my tracks because I didn't quite know what to make of them (I guess some might say they did their job). My sudden stop, though, was not advisable for 2
reasons: (a) I was carrying a heavy load & inertia almost caused me to fall forward--down the stairs--& (b) there was someone behind me who was also carrying a load--had he not detected my stop with his cane & had he not had quick reflexes, we would have both tumbled down the stairs. Now, had my cane detected the drop off, I would have quickly assessed how far the drop went & continued on without breaking my stride. When I encountered those steps on subsequent occasions, I remembered the domes, but they always caused me to pause slightly to be sure of my footing as I walked atop them.

One thing to keep in mind with the above example is that we were both using canes even though we both have significant residual vision. If we were not using canes & were carrying the boxes, the truncated domes might have been helpful to show us where the steps were. However, by using our canes, we can walk more quickly & still detect drop-offs & handle them gracefully under just about all conditions whether or not they have detectable warnings.

Finally, in regards to ramps ... I'm not sure what exactly is written (if anything) about detectable warnings & ramps in the draft guidelines, but I'd suggest them only when necessary.

The ADA requires a slope of at least 1 in. rise / 12 in. run for wheelchair access. As a manual wheelchair user, I can tell you that the opinion of myself & others is that even this slope can be difficult to manage--especially if there is a long ramp with few or no flat areas in which to rest. Unless we go to the expense of installing "hill-helpers" (which is, then, one more set of parts on which to perform maintenance), we often have to take a running start to build up momentum, then push the rest of the way manually (with hands and/or fee--not all wheelchair users have lost the use of their feet). Bumps at the top & bottom of every ramp would take some of our momentum away & cause us to expend more energy going up hills (this is simple physics).

Detectable warnings at the top of very slightly sloping ramps *might* help me because, if I'm carrying on a conversation while I'm walking, I *might* not notice that my cane is indicating a very slight slope. This is also helpful to me when I'm using my chair as any slope--even a slight one--gives my chair more momentum & (if I'm not expecting
it) can cause me to roll faster than I'd anticipated.

In short, technology has helped us in many ways (talking computers, Braille & speech portable notetakers, etc.), but if we rely on technology when we could rely on ourselves (after receiving quality training), we become more dependent. Also, the general public, if they don't know any better (which, most of them don't as quality training is not available to all blind people yet), will see us as dependent on that technology & as incapable of traveling independently without them (i.e., teachers & employers will not expect us to be able to travel to, from & during school & work if there are no ATS or detectable warnings in & around their building(s) & so on).

In closing, I'd like to share a story & a couple questions.

There was a student attending college who had not been fortunate enough to receive quality training. Despite his ability to travel by plane between HI & MD (with sighted assistance) & despite the fact that he was a graduate student, he could not find the crosswalk without the help of the ATS. On several occasions (usually when it rained), the ticking traffic signals near our dorm failed (if they ticked at all, it was only softly). As you know, when it rains, sounds are louder & more muffled as cars drive by. Well, I ended up having to call the appropriate agency to get someone out to fix these signals after I helped this student back to his building (I was on my way back from class when I found him wandering around trying to find the crosswalk).

When he graduated with an advanced degree, what do you think potential employers thought (since he didn't receive quality training before seeking a job) when they discovered he can't travel where there aren't any ATS unless he has assistance (either by a sighted person or a trained blind person)? Also, given the tendency of people to generalize ("I know what blind people are capable of because I know so-and-so & s/he is blind."), what do you think they'll think of future blind applicants (before they learn their degree of cane travel ability) who may be equally qualified for the job by degree or experience?

I appreciate your time & attention to my concerns.

Sincerely,

Ronalene White
 

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