Edward Bell, M.A., NOMC
|
October 8, 2002 |
Dear Access Board:
I am writing this letter to voice my opposition to the proposed guidelines for
environmental modification. In particular, I am concerned about the mandates for
Accessible Pedestrian Signals (APS) and detectable warnings proposed at
virtually all street corners. I am a certified orientation and mobility
specialist (NOMC), and have had experience teaching students to travel across
many different types of intersections. Furthermore, I am a blind person, and
therefore have personal knowledge of the dangers, or perceived dangers, inherent
in our public rights-of-way. I hope that you will consider my comments in view
of my credentials and experience as a professional in the field as well as a
consumer.
The vast majority of intersections across this country have remained unchanged
for decades, yet thousands of blind pedestrians have safely navigated the
streets of America without the assistance of accessible pedestrian signals.
Nevertheless, there have recently been built intersections which are large,
complex and which may be appropriate for intersection adaptation. These are rare
occasions, however, and should not become the rule for the rest of the country.
I have traveled in my hometown safely, but I have also traveled in many large
metropolitan cities, suburban communities and rural areas without the use of any
environmental modification. More importantly, I have taught novice, intermediate
and experienced students in similar areas with considerable success. As such,
there has not been a place where I was either unable to travel or teach that was
unsafe without APS or truncated domes.
accessible pedestrian signals already exist at some intersections, and I have
had some experience with them. In addition, I was recently present at an
orientation and mobility conference during which the newest models of accessible
pedestrian signals were being tested. I can say unequivocally that the
demonstrated models presented a greater danger than a solution to blind and
visually impaired individuals. The intention of the design is noble, however,
the devices fall far short of providing a needed function. Perhaps consultation
with consumers during the development stage, rather than during the evaluation
phase will assist manufactures in the development of better designs.
Advocates of environmental modification embrace the proposed guidelines as a
desirable solution, yet blind consumers regard many types of accessible
pedestrian signals as a nuisance and potential danger. The chirping sounds of
the walk signal and the buzz of the locater tones can be confusing, and present
a sufficient distraction to prevent the blind person from correctly identifying
the traffic patterns. While walk/don't walk signals are a good idea, they do not
control the traffic. Thus, blind and visually impaired pedestrians must be able
to monitor the traffic flow without interference of extraneous sounds. Advocates
present APS as a necessary accommodation to actuated traffic lights in which the
cycle is controlled by traffic flow. These types of intersections, however, are
currently controlled by pedestrian signals already in place. As I have already
said, blind pedestrians depend on the movement of traffic, or the absence of
traffic, to determine that it is safe to cross a street. Since existing
pedestrian signals at actuated traffic signals already control the cycle for
pedestrians, making them accessible is unnecessary, a waste of money and a
potential danger.
I do trust and believe that the Access Board will come to see that the proposed
guidelines on environmental modification are excessive, unnecessary and ill
planned. As a mobility professional and as a blind pedestrian I will be more
than happy to be a part of any future guidelines for accessibility. Please feel
free to contact me at any time if I can be of assistance, and together we can
make the public environment a safer place for everyone, without making it a
potential danger to anyone in the process.
Sincerely,
Edward Bell, M.A., NOMC
Doctoral Student, University of Arkansas
Fayetteville Arkansas
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