Washington Council of the Blind
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October 28, 2002 |
Washington Council of the Blind
Statement of concurrence
To: ARCHITECTURAL AND TRANSPORTATION BARRIERS COMPLIANCE BOARD (Access
Board) Draft Guidelines on Public Rights-of-Way 36 CFR Parts 1190 and 1191
[Docket No. 02-1] RIN 3014-AA26 Published in the Federal Register June 17, 2002
The Washington Council of the Blind (WCB),[ ... ], an affiliate member of the
American Council of the Blind (ACB) and one of Washington States premier
Grassroots consumer based organizations, agrees with the findings and proposed
guidelines set forth by the Access Board in regard to accessible public
rights-of-ways. WCB is committed to making all public areas accessible to people
with disabilities especially those who are blind and visually impaired. Although
WCB agrees with the majority of the recommendation of the report, three areas of
particular interest to blind and visually impaired persons will predominate this
written commentary. They include accessible pedestrian signals (APS), tactile
warnings, and way finding mechanisms. WCB supports all of the above named issues
and herein has outlined its position statement for each.
The Americans with Disabilities Act (ADA) guarantees the right to the access of
information to people who are disabled. APS devises convey the same information
received by sighted pedestrians from the walk/don't walk signals and street
signs to blind and visually impaired persons in an accessible format. If sighted
pedestrians are assumed to be safer by the use of such information then it
should be equally obvious that blind pedestrians will also benefit from this
information. Some blind individuals and organizations will contend that quality
orientation and mobility skills are all that is necessary to safely traverse an
intersection. WCB agrees with the premise that mastery of good orientation and
mobility skills is paramount to the safety of all blind travelers. The
installation of APS equipment is not intended to replace mobility skills
training. They are intended to provide usable information to assist blind
pedestrians in the decision making process as they determine when it is safe to
cross. In a superlative situation where all blind persons had identical
impairments; equal mobility skills; and where all intersections were of the
traditional four corner plus design; a reasonable argument could exist to delay
the installation of APS devices. Unfortunately the reality of the situation is
much different than this imaginary proposition. Many in the blind community have
additional conditions that can impair their mobility. Afflictions associated
with age, physical disabilities and partial or total hearing loss effect a large
percentage of the population. The volume of traffic on our roads and the
complexity of intersections have increased exponentially over the past few
years. The convergence of three or four main arterials at a single intersection
is now commonplace. In many cases it is no longer possible for blind pedestrians
to reliably determine when the walk signal is activated by using the sound of
traffic flow. Deaf-Blind persons are unable to use traffic cues even at ideal
intersections. Detectable warning strips are essential along train and subway
platforms. In these areas oncoming trains push air currents into odd patterns,
and the noise of the trains along with crowds of people alter ones ability to
judge distances. Detectable warnings can and do save lives. They are not only
intended to add an extra level of safety for blind travelers but for those who
are sighted as well.
At crosswalks detectable warnings in curb cuts give an extra level of protection
to blind individuals who may accidentally travel into the line of traffic
without being aware of it. Given the gradual slope of many curb cuts in use
today WCB recommends the adoption of guidelines for the placement of some type
of detectable warnings at crosswalk curb cuts. These are especially important in
locations where the curb cut is not aligned with the crosswalk.
Way finding systems are also important for visually impaired persons especially
in large open areas and parking lots. These systems also help to indicate proper
travel directions to reach doorways and other public facilities. These systems
provide the blind with directional information to assist them in making safe
travel decisions. WCB supports the use of way finding systems and encourages the
board to investigate and use both high-tech and low-tech way finding systems.
Way finding systems are especially important when more conventional methods of
detecting ones direction such as using the sun are not available.
WCB strives to improve the well being of all blind and visually impaired people
and asks the Access Board to remember that people with vision loss come from
many different backgrounds with varying educational experiences and they do not
have the same level of proficiency in orientation and mobility skills.
Therefore, WCB asks that the Draft Guidelines on Public Rights-of-Way be adopted
to enable and ensure the safety of all citizens. Please do not wait for another
person to be needlessly injured or killed. WCB is saddened when any pedestrian
suffers from injuries that are preventable. The Washington Council of the blind
believes these tragedies can be greatly reduced, and implores the board to take
action before another.