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I am writing to you as both a blind person, and as a professional providing Orientation and Mobility services to blind persons here in the state of Nebraska. I have also worked as a professional O&M instructor in the Philadelphia area, with extensive experience with both mass transit, including both trains and light rail systems, and complex traffic light controlled intersections. I hold a Masters degree in Orientation and Mobility, from Louisiana Tech University, and National Orientation and Mobility Certification.

It is my understanding that at the current time there is a strong effort to establish Federal regulations that would extend and more firmly enforce existing regulations regarding detectable warning strips, and also require "accessible traffic signals" for blind pedestrians. I have several serious concerns in this regard, and I believe that such regulations would, in spite of their superficial appearance, prove very detrimental to the quality of life for blind persons.

In regard to detectable warning strips, the comment has been made that large numbers of blind persons are being injured, or even dieing by falling off of train and subway platforms, and that it is well documented that these deaths have resulted from the lack of detectable warning strips. While this claim has been made repeatedly,, the "documented evidence" is yet to be brought forward to support this claim. Yes several blind persons in recent years have fallen from platforms, and a few have even died. These are truly tragic occurrences; however, I believe some perspective is needed to fully understand this issue. The question should be posed, is the rate of accidents of this type involving blind persons actually greater than those occurring among persons without disabilities? To my knowledge they are not.

Those that promote the installation of detectable warning strips and accessible traffic signals state that for proper safety of blind travelers such devices are essential. If we accept the proposed theory that blind persons have a greater need for safety measures than the general public, then we must also accept the misguided belief that blind persons face a far greater degree of difficulty and danger in their daily lives.

Should we accept this notion that blind persons face an above average level of difficulty and danger, then we must consider what creates these conditions for blind persons. There appears to be the implicit belief that blindness itself so significantly reduces an individual's awareness of the environment that functioning in the world without modification is simply unreasonable. Given this supposed truth regarding blindness, then how is it possible to explain the thousands of blind persons that live full and productive lives, including utilizing public transportations systems of every description and cross even the most complex of intersections independently on a regular basis. Also, if such threats to our personal safety truly exist, then why would so many blind persons prefer that such devices only be installed in those rare circumstances where blind persons themselves have determined they would be of benefit?

Some might argue that living with the resultantly increased levels of frustration, anxiety, and fear faced by blind persons that result from the numerous environmental challenges they confront in the course of daily travel, it should be expected that the average blind person will also face a significantly increased level of depression. Certainly sources of danger that would create these emotional conditions can not be considered to be limited to curbs, intersections, and the edges of train platforms, surely under this belief system the world must be a virtual death trap for the hapless blind traveler. It should be further pointed out that Some of the results of depression can include fatigue and a reduced quality of health, and therefore potentially a decreased degree of both physical function and perhaps even a reduced ability to attend to critical environmental factors, resulting in less effective judgment. Therefore should we accept this very misguided stereotype of blind persons, then we must assume that a greater than average number of the accidents that befall blind persons are the result of depression induced dysfunction, such as a lowered level of awareness or possibly alcohol or substance abuse, or even suicide. It is well known that the majority of accidents occurring on train or subway platforms, which involve the general public, are associated with fatigue, alcohol or substance abuse, or even suicides. Given the probability, based upon this mythical approach to blindness, that blind persons are even more likely to live with a reduced level of awareness, abuse alcohol or other substances at above average levels, or more frequently resort to suicide, the likelihood that detectable warning strips will have any meaningful impact upon the number of blind persons being injured or killed in these situations is minimal at best, and the installation of such devices will do very little to alleviate the purported excessive levels of stress created by the myriad of environmental hazards that blind persons reportedly confront in the course of independent travel.

Should we rationally examine the reality of life for the majority of blind persons, we find that in fact it differs very little from the life of the average individual who is not blind, except in the manner in which the tasks of daily living are approached. With proper training and the utilization of proper techniques, blind persons manage the environment with an equal degree of awareness and effectiveness as compared with their normally sighted counterparts. Given this fact, then it is clear that there are no outstandingly greater sources of difficulty or danger in a blind person's life. It can be expected that such individuals represent a cross section of society, with no greater tendency to experience frustration, anxiety, or fear, and therefore are no more likely to feel depressed. Therefore blind persons are no more likely to fall from train or subway platforms, or enter dangerous situations unaware of the circumstances, than are any other persons. They will also have no lesser or greater tendency toward those behaviors that will increase the likelihood that they will be injured or killed through fatigue, intoxication, or their own intention.

In addition, there is no evidence to support the implicit belief that detectable warning strips will in fact improve a blind person's awareness of the environmental conditions they are associated with. What is critical in safe independent travel is the utilization of effective techniques, and the appropriate level of awareness necessary to the conditions through which the person is traveling. An individual traveling in or around a train or subway platform certainly should be aware the somewhere nearby there is an edge, and where these warning strips are to be placed in regard to traffic, there are certainly many available environmental cues that should alert anyone that is paying even the most minimal degree of attention to the nature of the situation. Should these individuals fail to be aware of their circumstances based upon the abundant environmental information, including a high volume of auditory cues, not to mention relatively significantly obvious drop offs at the edge of the platform, that should be detected by the same sort of cane techniques utilized in locating a detectable warning strip, is it truly reasonable to expect that they will be able to recognize a warning strip, even if that is the only thing they are focused upon finding?

It may be argued that these strips are necessary to provide additional information to persons with secondary disabilities. In deed some of these individuals may benefit from these devices; however, it has been my experience in nearly fourteen years of teaching, that those individuals that can locate these devices reliably usually do not need them, and those that most need this type of information simply cannot make use of it due to being easily disoriented and overwhelmed by the level of information they must process to travel in these high demand situations. Therefore only a very small group of people are likely to benefit from such devices.

Similar issues exist with regard to "accessible traffic signals". It is argued that these systems permit blind persons to know with certainty when the traffic light has changed in their favor, and this will increase their personal safety. This is an over simplification of the process of crossing a street. Any pedestrian has many other matters to attend to while crossing a street at an intersection with a traffic light. There is the possibility that cars may pass through the light very late in the cycle, even after the light has turned green for the cross traffic. Cars moving parallel to the pedestrian may turn across the persons path of travel while they are in the process of crossing the street. also, the pedestrian must cross in a direct path to the correct corner, without entering the parallel flow of traffic, or otherwise interfering with the flow of traffic through the intersection. A blind traveler can very successfully accomplish these tasks through the utilization of auditory and, to a lesser degree, tactile information available in the environment, without modification. In fact, at the majority of intersections controlled by a traffic light, determining when the light has changed is the least difficult of the activities involved in crossing a street. There are some intersections that present conditions that maybe best addressed by accessible traffic signals; however, this decisions should not be made by traffic engineers, who have no direct knowledge of blindness, but rather by persons having the appropriate experience and expertise, that are among, or have been appointed by, members of the organized blind themselves. There may even be some situations in which detectable warning strips are appropriate; however, again this is a decision that can only be made properly by the blind themselves.

Why should I express such a level of concern regarding the improper or excessive utilization of such devices in regard to blind persons? There are several reasons. First, these devices for the most part address a perceived need, rather than a real one. Therefore they waste resources, and reinforce the myths and misconceptions about the ability of blind persons. They create a dependency upon devices that may fail when they are needed most, for example, warning strips can become snow or ice packed in winter creating, a condition in which a blind traveler who has come to depend upon the information they provide will be unable to access the feedback the warning strip normally presents. The packing of ice and snow into the warning strips will likely also present a more serious hazard to pedestrians, and interfere with efforts to properly clear pedestrian pathways. These strips also may increase the probability that women wearing high heels, or other persons relying on orthopedic devices, such as support canes, will stumble or fall more easily. Accessible traffic signals, as with any mechanical device, can break down, and who other than the unsuspecting blind traveler is likely to notice that there is a problem. Should the individual have developed a significant dependency upon such devices, this could leave that person either with no options, or even in danger. Even when such devices are in proper order, if the blind individual does not have the other necessary skills to function safely in the world, then little is gained.

This is a very serious matter, since the funding of programs providing rehabilitation training are often the target of budget cutting efforts, on both the state and Federal levels. The misconception that detectable warning strips and accessible traffic signals are an effective replacement for good Orientation and Mobility training could easily be accepted by persons that are unfamiliar with blindness, especially when some blind persons promote these devices as essential to safe and effective travel for blind persons.

There is also another fact that should be considered in this matter. Many of the people that are promoting these devices, are individuals that refuse to utilize appropriate adaptive devices, such as the long white cane, preferring in stead to rely upon their very limited and unreliable vision. Certainly, should a motorist that is determined to need corrective glasses to safely operate a motor vehicle, and chooses not to do so, resulting in a collision ending in either injury or death, will not inspire a national effort to modify the roadway and highway system to accommodate such irresponsible behavior. There are also a number of these blind persons that have refused to receive proper training in order to travel safely, and although they do carry a white cane, they often lack the skills to utilize them effectively. Again, our society would have little tolerance for those that would attempt to operate motor vehicles without proper training, and it is unlikely that efforts would be made to modify the environment to meet the needs of such untrained drivers. Our society clearly takes the sensible course of action in these matters related to motor vehicle operators, we require those persons with correctable vision to wear corrective glasses when driving, and when they fail to do so we hold them responsible for their actions. We provide a variety of training programs for people to learn safe methods of driving, and we hold those individuals refusing to obtain such training responsible for the results of their actions. I am not suggesting that blind persons that refuse to use an appropriate mobility device, or refuse training should be punished, or in any way restricted, but rather that like any other member of our society, they should be expected to accept responsibility for their choices and actions.

It will be pointed out that the situation is not this simple, since many states do not offer blind persons access to proper training. This statement is both correct and fair; however, since the issue of installing such environmental modifications also involves a very great investment of taxpayer dollars, then why not use this money where it will do the most good. The funds necessary to make such extensive modifications on a national scale could easily afford every blind person in our country, that wishes to receive such services, the sort of proper training that would allow them to function safely, and would also likely lead to them becoming more effective and productive members of society.

I hope that you will give consideration to the issues I raise here, and that the information I have provided to you will assist you in better understanding the inappropriateness of installing detectable warning strips and accessible traffic signals in all but a very rare number of situations. Please recognize that my statements, in spite of the responses from those that would be critical of them, are not motivated by either arrogance or a disregard for the safety of blind and visually impaired persons, but rather by the desire to make certain that valuable, limited, resources are devoted to activities that will provide blind persons with the greatest benefit, and not those that are both unproven, and likely to reinforce the negative stereotypes of blind persons held by so many members of our society.