MR. POMERANTZ: Good afternoon. I am Mitch Pomerantz. I am off today, but I am paid by the
City of Los Angeles to be our ADA compliance
officer. I am actually here, however, representing
the American Council of the Blind. I am the
organization's second vice president and I got
tabbed for this duty because in the past three years
my wife, Donna, and I have in fact taken a couple of
cruises, the most recent was on Carnival this past
April. So we do have some direct experience
cruising, myself as someone who is totally blind, my
wife as someone who is visually impaired.
Generally, ACB supports the proposed guidelines here. Presumably you have received comments from our organization that have been submitted, hopefully they have been submitted. If not, they will be submitted in short order. I just want to make a couple of comments in some areas. We certainly support the Access Board's proposals regarding protruding objects. We obviously don't know whether a path, circulation path, is accessible. So we certainly support the guidelines covering all paths of travel.
I particularly had some interesting experiences on our cruise in April because we obviously had a room that was not accessible and would not have fallen into the guidelines here, because I had three separate, very close run-ins with the protruding television set. I assume that had we had an accessible room, I wouldn't have had that difficulty. But for about the first three or four days, it looked like I had been in a fight because I kept finding that television set, which standing up caught me right about there. So ultimately we got it down. But that certainly created a bit of a problem for us.
Regarding elevators, ACB supports Section 407 as it complies with the ADA accessibility guidelines requirements. In cases where vessels have more than one entry deck and simple on-car control buttons to orient users to the main entry floor, where that can't be provided, we believe very strongly in verbal announcements indicating which floor is the entry level. We did not have that situation on either of our cruises. It was the same deck, regardless of the ports that we got to.
However, on our most recent cruise it was very helpful to have the automatic and the verbal announcements, although much as in landside buildings, those automatic announcements aren't always automatic. They don't always function. So you still have to be paying attention to where you are and check to make sure when you get to your stop that you are at the right floor either by looking at the Braille or by checking the light. My wife is able to see that, assuming that the lighting is appropriate and there is sufficient contrast.
But that we certainly believe in the automatic, in the verbal announcements of the floors. That helps us considerably.
With regard to the transition plates, that certainly can be an issue and a concern. An awful lot of people who cruise are older, and the incidence of blindness is much higher among older persons who may not have gotten the opportunity for good mobility training. So we support having a visual contrast with adjacent passenger walkways either light on dark or dark on light, as long as there is sufficient contrast to make it possible for someone who isn't using a cane or a dog, has limited vision, to see that they are coming to the beginning of or end of a transition plate.
We also support the effort to have sound on cane contrast and perhaps even a different texture for that transition plate. So that, again, it gives us one more opportunity to -- one more cue that we are coming to the end of the dock, boarding the ship or vice versa for that matter.
So we hope that the Board will continue those efforts and would adopt those.
ACB supports your consideration for inclusion of tactile warning features on transition plates. A detectible warning as currently defined in the ADAG sections 4.1.3, 15 and 4.7.7 and 4.29 and 10.3.8 alerts blind and visually impaired passengers of other transition areas such as curb cuts and platform edges, which may pose a threat of injury if not identified in a tactile manner.
As transition plates provide safe access between the vessel and the land, the entrance and exit points of that transition platform should be marked with a tactile strip such as those tactile strips used on platform edges or subways and curb ramps, providing blind and visually impaired passengers with the same information available to sighted passengers. ACB believes that both vessel owners and manufacturers of transition plates should follow and be responsible for following such requirements, and we are willing to assist in the development of such a tactile warning.
Accessible signage. This is something, again, we've had some very specific experience with. Our organization supports the requirement that information be communicated effectively to customers who are blind or visually impaired via accessible signage. We urge the Department to ensure that signage requirements in Section 703 as they concur with the ADAG 4.30 requirements be enforced, allowing the passenger to access the information in an independent manner.
Our most recent cruise, Carnival, did a very good job with the Braille signage. The print signage was very difficult. The contrast was not always sufficient to make it possible for visually impaired passengers such as my wife to see it. The other thing is -- and I am not sure there's much you can do about this, but a lot of these ships, they like to use mirrors and other decorations that make it very difficult for someone with a visual impairment who does use their eyesight to some extent to find the sign amongst the mirror and the glare and the other decorations ship board.
Automatic teller machines and fare machines, we very much support what the Access Board has come up with. We are seeing in the country, thanks to our efforts, accessible talking automatic teller machines with tactile controls. We believe that those should be available ship board as well. Our organization urges that the Department require all automatic teller machines and fare machines that are available to the public on passenger vessels be accessible to and usable by persons with disabilities. We commend the Department by recognizing the usefulness security and efficiency of automatic teller machines and fare machines that are accessible to all passengers.
We unequivocally support the inclusion of specific accessibility requirements in the final passenger vessels rule. The accessibility requirements that are critical for inclusion in the final rule are the physical access specifications contained in the ADA accessibility guidelines and the specifications in the 508 standard for electronic and information technology.
Automatic teller machines and fare machines provided for public use should be required to meet the minimum physical accessibility requirements that are prescribed in Section 707 of the ADA accessibility guidelines. Section 707 of ADAG covers automatic teller machines and fare machines.
Make one final comment regarding directional and information signs. Again, as with Section 703, ACB concurs with what you have included in the section.
We want to thank you for the opportunity to present both written comment and to provide oral testimony regarding this matter. More and more blind and visually impaired persons are taking the opportunity to cruise. We plan on doing so in the future and hope that to the extent possible, given everything that we are hearing today, that all cruise lines will be made as accessible as possible under the circumstances. So I will stop here and see if there are any questions.
MR. [GARY] TALBOT [BOARD MEMBER]: Thank you very much. I have one question on transition plates. Is that the gangway, what we earlier called the gangway, the ramp that connects the ship to the dock, is that what you were referring to as a transition plate?
MR. POMERANTZ: Yes.
MR. TALBOT: When you mentioned the sound on cane, the tactile indicators, where would you like to see those positioned so that they would benefit you?
MR. POMERANTZ: Well, where we find them on subway -- two different things. The detectible warnings, of course, are placed such that we know that we're coming to the end of the curb and entering the street. So perhaps detectible warnings at the edge of the pier. And conversely as you egress the ship, just prior to getting on to the gangway. The sound on cane and the tactile textural difference perhaps could be placed on the gangway. It's being done landside with materials that withstand all kinds of bad weather and heavy pedestrian traffic, probably heavier on a day-to-day basis than you would find boarding and getting off of any cruise ship even.
So there are tiles that can be affixed to the gangway that would provide a path of travel and would delineate for someone using a cane, that this is the gangway, and they need to keep straight or follow that path.
MR. TALBOT: Thank you very much. Are there any other questions?
MR. [JAMES] ELEKES [BOARD MEMBER]: Yes. Just a few. I am Jim Elekes. Perhaps in listening you have identified myself as being blind, as well. When you are talking about cane contact, I just want to follow Gary's line of questioning. If you have a ramp and there is a degree of increase or decrease in the grade, would a transition plate or a different sound cane on contact or texture indicate that you are about to get a gradation change? Would you take it as far as that so to ensure that there's an avoidance of tripping?
MR. POMERANTZ: Yeah, I think so because, again, we're dealing with a significant number of folks over the age of 60, 65, who are losing their vision who are still to some extent relying on their vision and do not have the kind of mobility training that someone like myself who has been blind for 45 years has. And so any additional cue to assist them in navigation, this isn't a significant expense or significant difficulty to install and certainly not terribly costly.
MR. ELEKES: The other question. In spaces where the signage, the accessible signage, cannot be placed to read customarily left to right, have you experienced -- I have seen recently and I don't know if you have experienced it, vertical signage where the Braille reads up and down, likewise the print, that is to forward the information, is there any thoughts as to an alternative placement of signs or alternative positioning of the Braille or the large print?
MR. POMERANTZ: I have not encountered that. I think the problem with so much of these, I mean, I am of a generation where I am just beginning to start looking for accessible signage. I have lived all my life not having accessible signage, and so I sometimes have to be reminded, "Oh, there's Braille signage here. You have to look for it. You have to read it."
I don't know, we're still at that phase or that point where we're not necessarily going to automatically look for it. I think for an experienced Braille reader it might not be a problem, but you do have options in ADAG if you can't put a sign on a strike side of a door, there are alternatives where you can put signage that we kind of look at, okay, that's Plan B, that may be where the sign is. I would rather look for those kinds of alternatives than put the sign sideways. I think that probably creates more problems than it solves.
MR. ELEKES: Thank you.
MR. TALBOT: Thank you very much. We really appreciate your input.
MS. [PAMLEA] DORWARTH [BOARD MEMBER]: What does the acronym ACB stand for?
MR. POMERANTZ: Oh, I'm sorry. American Council of the Blind. I thought I said that.
MS. DORWARTH: You may have, but I'm hearing impaired and I didn't catch it.
MR. TALBOT: Mitch, was that testimony for both you and Donna?
MR. POMERANTZ: No, she has a few things she wants to add.