Washington Council of the Blind
Statement of concurrence
To:  ARCHITECTURAL AND TRANSPORTATION BARRIERS COMPLIANCE BOARD (Access Board) Draft Guidelines on Public Rights-of-Way 36 CFR Parts 1190 and 1191 [Docket No. 02-1] RIN 3014-AA26 Published in the Federal Register June 17, 2002

The Washington Council of the Blind (WCB),[ ... ], an affiliate member of the American Council of the Blind (ACB) and one of Washington States premier Grassroots consumer based organizations, agrees with the findings and proposed guidelines set forth by the Access Board in regard to accessible public rights-of-ways. WCB is committed to making all public areas accessible to people with disabilities especially those who are blind and visually impaired. Although WCB agrees with the majority of the recommendation of the report, three areas of particular interest to blind and visually impaired persons will predominate this written commentary. They include accessible pedestrian signals (APS), tactile warnings, and way finding mechanisms. WCB supports all of the above named issues and herein has outlined its position statement for each.

The Americans with Disabilities Act (ADA) guarantees the right to the access of information to people who are disabled. APS devises convey the same information received by sighted pedestrians from the walk/don't walk signals and street signs to blind and visually impaired persons in an accessible format. If sighted pedestrians are assumed to be safer by the use of such information then it should be equally obvious that blind pedestrians will also benefit from this information. Some blind individuals and organizations will contend that quality orientation and mobility skills are all that is necessary to safely traverse an intersection. WCB agrees with the premise that mastery of good orientation and mobility skills is paramount to the safety of all blind travelers. The installation of APS equipment is not intended to replace mobility skills training. They are intended to provide usable information to assist blind pedestrians in the decision making process as they determine when it is safe to cross. In a superlative situation where all blind persons had identical impairments; equal mobility skills; and where all intersections were of the traditional four corner plus design; a reasonable argument could exist to delay the installation of APS devices. Unfortunately the reality of the situation is much different than this imaginary proposition. Many in the blind community have additional conditions that can impair their mobility. Afflictions associated with age, physical disabilities and partial or total hearing loss effect a large percentage of the population. The volume of traffic on our roads and the complexity of intersections have increased exponentially over the past few years. The convergence of three or four main arterials at a single intersection is now commonplace. In many cases it is no longer possible for blind pedestrians to reliably determine when the walk signal is activated by using the sound of traffic flow. Deaf-Blind persons are unable to use traffic cues even at ideal intersections. Detectable warning strips are essential along train and subway platforms. In these areas oncoming trains push air currents into odd patterns, and the noise of the trains along with crowds of people alter ones ability to judge distances. Detectable warnings can and do save lives. They are not only intended to add an extra level of safety for blind travelers but for those who are sighted as well.

At crosswalks detectable warnings in curb cuts give an extra level of protection to blind individuals who may accidentally travel into the line of traffic without being aware of it. Given the gradual slope of many curb cuts in use today WCB recommends the adoption of guidelines for the placement of some type of detectable warnings at crosswalk curb cuts. These are especially important in locations where the curb cut is not aligned with the crosswalk.

Way finding systems are also important for visually impaired persons especially in large open areas and parking lots. These systems also help to indicate proper travel directions to reach doorways and other public facilities. These systems provide the blind with directional information to assist them in making safe travel decisions. WCB supports the use of way finding systems and encourages the board to investigate and use both high-tech and low-tech way finding systems. Way finding systems are especially important when more conventional methods of detecting ones direction such as using the sun are not available.

WCB strives to improve the well being of all blind and visually impaired people and asks the Access Board to remember that people with vision loss come from many different backgrounds with varying educational experiences and they do not have the same level of proficiency in orientation and mobility skills. Therefore, WCB asks that the Draft Guidelines on Public Rights-of-Way be adopted to enable and ensure the safety of all citizens. Please do not wait for another person to be needlessly injured or killed. WCB is saddened when any pedestrian suffers from injuries that are preventable. The Washington Council of the blind believes these tragedies can be greatly reduced, and implores the board to take action before another.