Professional Development and Research Institute on Blindness
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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 [ ... ].
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