Professional Development and Research Institute on Blindness

October 25, 2002

     
PROFESSIONAL DEVELOPMENT AND RESEARCH INSTITUTE ON BLINDNESS
LOUISIANA TECH UNIVERSITY

TO: Architectural and Transportation Barriers
Compliance Board

RE: Audible Signals at Intersections and Truncated Domes


The Professional Development and Research Institute on Blindness (The Institute) is a department in the College of Education at Louisiana Tech University, a member of the University of Louisiana System. This Institute was created to provide an alternative to the traditional university professional development and research programs which have existed throughout America for a good number of years. We have institutionalized techniques and philosophies developed by the blind themselves into a university program.

A brief summary of our views is as follows: We recognize that the real problem of blindness is attitudinal rather than physical—that is, public notions about blindness are extremely negative and expectations for blind people are virtually nonexistent. Properly trained blind persons can compete on terms of equality with their sighted peers and can negotiate the environment without modification. We believe strongly that requiring the general public to commit an inordinately large number of scarce tax dollars to provide accommodations for the blind which are unnecessary, is wasteful and will result in creating a backlash of negativity which will simply be heaped upon the attitudinal barriers which already exist. The ATBCB must be as concerned as we are with breaking down rather than creating additional artificial, attitudinal barriers.

Based upon the preceding, this Institute wishes to go on record as opposing any sweeping regulations which would mandate unnecessary environmental modifications purportedly intended to make specific information at street corners accessible to the blind population. The proposed guidelines offered by the Public Rights-Of-Way Access Advisory Committee (PROWAAC) are objectionable and improper for the following specific reasons:

1) There is currently a profound lack of consensus among consumers as to the need for the suggested modifications;
2) Debate also exists between rehabilitation professionals as to the need for and appropriateness of the proposed modifications;
3) There is insufficient statistical data to demonstrate either the effectiveness of or need for accessible pedestrian signals (APS) and truncated domes;
4) Traffic engineers and architects across the country oppose the guidelines on the basis of economic and pragmatic concerns;
5) APS technology has not been standardized. Consequently, serious consideration should be given to eliminating the proposed guidelines on environmental modification while a more comprehensive and acceptable solution can be sought; and
6) Even though the law has apparently never been stressed, the ATBCB is specifically charged with the legal responsibility for eradicating, not creating, attitudinal barriers.

Clearly, the vast majority of intersections across America need no modifications in order to be safely traversed by blind and visually impaired pedestrians. This is evident by the mere fact that, to date, only a miniscule number of intersections have been equipped with accessible pedestrian signals or tactile warnings, yet thousands of trained blind individuals travel daily without mishap throughout the country. Moreover, many blind and visually impaired pedestrians oppose environmental modification, stating that they are a nuisance and may, themselves, present a danger. Additionally, no quantifiable data exist to support claims of increased safety for blind pedestrians at modified corners. The mere presence of altered intersections may be undesirable because any benefit which might be reaped from their installation may be overshadowed by their unfavorable public image. This fact is important since it may actually serve to impede the integration of blind people into society as a whole. Conversely, blind people who have not been trained will not be traveling independently and, therefore, the supposed need for modification is not nearly as great as some allege.



The PROWAAC has promoted nationwide environmental modifications on the basis that public rights-of-way present an eminent danger to blind pedestrians. This presumption is based on anecdotal testimony by some orientation and mobility instructors who believe that blind travelers are ill-equipped to cross controlled intersections safely. The modification of the environment, however, has been erroneously suggested as the necessary solution. The assumption is that the problem automatically resides with the environment rather than with the blind pedestrians’ preparedness to negotiate that environment safely.

Nevertheless, it is recognized that some intersections are unusually wide, irregularly shaped, or may otherwise present a challenge to the blind pedestrian. It is at these types of intersections where accessible pedestrian signals may offer assistance if appropriate standards were met. The technology exists today that would provide for the development of APS that are helpful, yet which are not also a hazard to the blind, or an annoyance to the general public.

The Institute endorses the orientation and mobility methodology and philosophy used by blind consumers for decades and now institutionalized and taught at Louisiana Tech University. The structured discovery method of teaching blind and visually impaired consumers has demonstrated unparalleled success to date. The basis of this revolutionary method is grounded in the conviction that trained blind persons can learn to gather, synthesize and discriminate relevant information from which to form judgments and act accordingly in the environment as it exists.

Due to the inherent unpredictability of the environment, it is a basic tenet of this model to teach individuals to navigate through various environments without reliance on excessive accommodation. As has been noted, however, isolated situations exist in which APS may be useful. The proposed guidelines, however, not only call for universal installation of APS, but mandate that in certain situations they be controlled automatically. Where such accessibility could be considered appropriate, blind consumers should be given the ability to control APS, and to be given the option to decide whether and when their use is necessary. Additionally, it is apparent that all of the available options have not been thoroughly examined by the PROWAAC. More suitable alternative devices currently exist, and consumers should be provided with the opportunity to choose the locations and style of devices to be installed. In the meantime, blind consumers must continue to be taught safe and effective means for navigating the streets regardless of the eventual outcome of the debate on environmental alterations.



The Institute recognizes the fact that there is a woeful lack of formal research in the area of environmental modification. While there have been a few studies, they have been flawed and their results are insufficient to warrant the installation of APS and tactile surfaces. Furthermore, theses studies have been funded by commercial producers of detectable warnings—companies which have an enormous economic interest in the outcome of the debate! In fact, a review of the literature suggests that there has been considerable effort in analyzing the composition and manufacturing standards for such devices, while providing no relevant justification for their widespread installation. The proponents of APS and tactile warnings continue to promote their need; however, their dogmatic advocacy cannot replace sound research design and statistical evidence.

To require that public rights-of-way be altered to assist blind persons without first establishing this need is fiscally irresponsible and will create the kind of attitudinal barriers against the blind referred to above. Municipalities will be forced to incur great expense for systems whose need is still in question. Traffic engineers and policymakers nationwide have expressed their concern that this proposal is excessive and wasteful. Unfortunately, threats of litigation have been aimed at local governments that fail to install accessible pedestrian signals upon request. These threats are untenable at best, and are not a valid justification for the wholesale installation of APS and tactile warnings.

This Institute strongly supports the position that any policy which recommends standards for implementation of accessible pedestrian signals and detectable warnings must be based on a demonstrated need and consensus of consumers. Since no statistical data exist to support such a need, no policies should be adopted which would require widespread modifications to intersections. In settings where APS may be deemed advisable, moreover, blind consumers and The Institute must have input into both their location and composition. This Institute stands ready to participate in research that is meaningful, well-constructed and conducted with sufficient numbers of sites and subjects to insure reliability. In this manner, appropriate recommendations can be provided to guide future intersection design. In addition, proper research can help to determine if and to what extent environmental modifications are necessary and whether alternative methods of travel training might alleviate the concerns for accessibility. Whatever remedy is ultimately adopted; it must be developed in consultation with rehabilitation professionals, traffic engineers and especially the blind consumers who are most directly affected.

We of the Professional Development and Research Institute on Blindness are pleased to have had this opportunity to submit comments on this controversial issue. If we can be of assistance, we may be contacted at any time at [ ... ].