Joanne Jordon

October 17, 2002

 

to the NABCB Committee

I am writing to you on our position regarding Accessible Pedestrian Signals and Detectable Warnings. I am a member of the National Federation of the Blind. I decided to join this organization in 1993 when a local blind woman with a dog guide fell off a subway platform and died. Because of this I decided that I must adapt to the environment and got a longer cane. That cane has saved me many times. I live in Massachusetts. Below is our position from our national office and our resolutions regarding this subject. I also think in certain cases there should be pedestrian signals, but the blind person should have the choice to activate them them selves APS's and detectable warnings are extreme and generally unnecessary. In the vast majority of situations we are able to travel competently without such costly modifications to our environment.

Many of us believe there is no situation that calls for an accessible pedestrian signal, and our resolutions contemplate their use only in limited situations. They should only be used when traffic patterns do not provide the clues we rely upon to know it is safe to walk.

Accessible pedestrian signals should never be used to provide directional guidance. Many proponents of these devices argue to the contrary. However, there is no support for this assertion, and those who seek to rely upon APS's for directional guidance are risking their safety. This is why NFB resolutions only permit vibrotactile APS's in those situations where one is appropriate. Such devices inform the blind pedestrian that it is safe to walk and nothing more than that.

No research exists regarding the effect of locator tones for every APS on blind pedestrians. Those who use dogs want an easy way to locate the APS, but the effect all this extra noise will have on the ability of all of us to travel safely has never been considered. For the average intersection, there will be 8 beeping points of sound over the general traffic noise making it exceedingly difficult to judge traffic. In addition, the draft guidelines require consistent placement, which should make locator tones unnecessary. Not only are the tones unnecessary, they may well prove to be exceedingly unpleasant for many.

These guidelines also require detectable warnings at every crosswalk. Our resolutions state that detectable warnings should only be considered if the slope of the curb ramp is 1-15 (1 inch of rise or fall for every 15 inches of run) or flatter. Anything with a slope greater than 1-15 is readily detectable with or without a cane.

 

Resolution 2002-16

 

WHEREAS, the Public Rights-of-Way Access Advisory Committee (PROWAAC)

of the Architectural and Transportation Barriers Compliance Board (ATBCB)

issued a report called "Building a True Community" which proposed new standards

and regulations to govern the building and rebuilding of public

rights-of-way such as streets, sidewalks, and other outdoor public

areas so that individuals with disabilities can access them; and

 

WHEREAS, this report contained recommendations regarding Accessible

Pedestrian Signals (APSs), which are electronic devices that alert the

blind pedestrian in an audible or vibrotactile manner when the traffic signal has

changed so that it is safe to walk; and

 

WHEREAS, the report recommended that an APS shall be provided at any

intersection where the timing of a pedestrian signal is altered by

push button actuation and where the signal includes a leading

pedestrian interval, a period of time during which the pedestrian is

allowed to start crossing before vehicular traffic is allowed to move; and

 

WHEREAS, the report further recommended that APSs with an optional-use

feature be installed at intersections where pedestrian crossing

intervals are pretimed and not affected by the push of a button; and

 

WHEREAS, pursuant to resolutions adopted by this organization, the

Federation submitted a minority report urging that the ATBCB mandate

APSs in situations only where the built environment did not provide sufficient nonvisual

clues for a blind pedestrian to know when it was safe to cross and that all

APSs be vibrotactile so that unneeded and distracting noise not be

emitted into intersections; and

 

WHEREAS, on June 17, 2002, the ATBCB published a draft guideline based

on the PROWAAC report, essentially disregarding both the PROWAAC

report and the Federation's recommendations and calling instead for APSs with locator tones to be

installed at every intersection with a pedestrian signal; and

 

WHEREAS, the PROWAAC report proposed installing APS in an overly broad

number of places but at least limited the installation to some degree

and further provided for an optional activation feature, thereby

giving each pedestrian the choice of using or not using the APS; and

 

WHEREAS, the board's draft guidelines will force installation and use

of APSs at every signalized intersection in America while costing tax

payers many billions of dollars; and

 

WHEREAS, at the majority of intersections the existing environment and

traffic pattern provide sufficient nonvisual cues for blind persons to

cross the street safely without APSs, and blind people do so every day: Now,

therefore,

 

BE IT RESOLVED by the National Federation of the Blind in convention

assembled this ninth day of July, 2002, in the City of Louisville,

Kentucky, that this organization condemn and deplore the ATBCB's narrow-minded and

uninformed view of blindness as expressed in the draft guideline

proposing to require the installation of APSs at all signalized

intersections in America; and

 

BE IT FURTHER RESOLVED that this organization urge the ATBCB to

reconsider and reject the extreme position taken on APSs in its June

17, 2002, draft guidelines and adopt a position on the placement and

use of APSs that is more realistic and consistent with the prevailing view among the blind themselves.

Resolution 2002-12

 

WHEREAS, the Public Rights-of-Way Access Advisory Committee (PROWAAC)

of the Architectural and Transportation Barriers Compliance Board (ATBCB)

issued a report called "Building a True Community," which proposed new

standards and regulations to govern the building and rebuilding of public

rights-of-way such as streets, sidewalks, and other outdoor public

areas so that individuals with disabilities can access them; and

 

WHEREAS, this report contained recommendations in the form of a

definition and also a set of requirements for installation of

detectable warnings, describing them as raised truncated domes in a

strip two feet deep and spanning the entire width of the curb ramp and

painted bright yellow or otherwise highly contrasting

in color with the surrounding surface; and

 

WHEREAS, these raised truncated domes are thought by some to give the

blind pedestrian a tactile warning underfoot that something hazardous lies

ahead; and

 

WHEREAS, on June 17, 2002, the United States Architectural and

Transportation Barriers Compliance Board (ATBCB) published draft

guidelines for public rights-of-way, substantially adopting the PROWAAC report regarding detectable

warnings; and

 

WHEREAS, the ATBCB's draft requirement for a detectable warning

surface two feet deep where the ramp, landing, or blended transition connects to a

crosswalk and in other areas rests on the fallacy that public

rights-of-way without such brightly colored tactile markings are

unsafe for blind people and that taxpayer dollars must be devoted to

universal installation of these strips of colored domes; and

 

WHEREAS, rather than being supported by a demonstrated and factual

need, the ATBCB's draft guideline is based on nothing more than fear of

blindness  and lack of knowledge about how blind people travel independently and

safely and could bring the entire regulation, if enacted, under fire in the

courts and city halls of America; and

 

WHEREAS, pursuant to Federation policy as set forth by previous

resolutions, the National Federation of the Blind filed a minority report

advocating that detectable warnings be placed only at intersections at which the

approach to the street is at a slope of one inch downward for every fifteen inches

of sidewalk, commonly called a slope of 1:15 or flatter, since

intersections with an approach to the street of 1:15 or less are

virtually flat and are the only places where it may arguably be

difficult for a blind person to determine when the sidewalk ends and

the street begins; and

 

WHEREAS, intersections with street approaches which slope at an angle

steeper than 1:15 are readily detectable underfoot whether the blind

person is using a cane, a dog, or no mobility tool whatsoever, and therefore do not

require the installation of expensive truncated dome strips to ensure that

blind people detect the street; and

 

WHEREAS, the ATBCB's draft guideline is now subject to public comment

and will not become a final and enforceable rule if the facts about

blindness and independent travel are presented and understood, but

previously suspended requirements for detectable warnings which differ

from the current draft guidelines are technically now in effect, the suspension having lapsed, making a

resolution of this issue inevitable: Now, therefore,

 

BE IT RESOLVED by the National Federation of the Blind in convention

assembled this ninth day of July, 2002, in the City of Louisville,

Kentucky, that this organization vigorously oppose the ATBCB's draft guidelines calling

for the universal installation of detectable warnings; and

 

BE IT FURTHER RESOLVED that this organization petition the ATBCB to

reinstate the suspension on guidelines for detectable warnings while

further consideration is given to the draft guideline on public rights-of-way, in order to

avoid confusion and needless installation of warning strips that are

apt to be inconsistent with the eventual guideline regardless of the

result; and

 

BE IT FURTHER RESOLVED that this organization urge the ATBCB to adopt

a final guideline based on facts rather than fear and which may

include installation of detectable warnings only when the slope of the

curb ramp at an intersection equals 1:15 or less.