Joanne Jordon
|
October 17, 2002 |
to the NABCB Committee
I am writing to you on our position regarding Accessible Pedestrian Signals and Detectable Warnings. I am a member of the National Federation of the Blind. I decided to join this organization in 1993 when a local blind woman with a dog guide fell off a subway platform and died. Because of this I decided that I must adapt to the environment and got a longer cane. That cane has saved me many times. I live in Massachusetts. Below is our position from our national office and our resolutions regarding this subject. I also think in certain cases there should be pedestrian signals, but the blind person should have the choice to activate them them selves APS's and detectable warnings are extreme and generally unnecessary. In the vast majority of situations we are able to travel competently without such costly modifications to our environment.
Many of us believe there is no situation that calls for an accessible pedestrian signal, and our resolutions contemplate their use only in limited situations. They should only be used when traffic patterns do not provide the clues we rely upon to know it is safe to walk.
Accessible pedestrian signals should never be used to provide directional guidance. Many proponents of these devices argue to the contrary. However, there is no support for this assertion, and those who seek to rely upon APS's for directional guidance are risking their safety. This is why NFB resolutions only permit vibrotactile APS's in those situations where one is appropriate. Such devices inform the blind pedestrian that it is safe to walk and nothing more than that.
No research exists regarding the effect of locator tones for every APS on blind pedestrians. Those who use dogs want an easy way to locate the APS, but the effect all this extra noise will have on the ability of all of us to travel safely has never been considered. For the average intersection, there will be 8 beeping points of sound over the general traffic noise making it exceedingly difficult to judge traffic. In addition, the draft guidelines require consistent placement, which should make locator tones unnecessary. Not only are the tones unnecessary, they may well prove to be exceedingly unpleasant for many.
These guidelines also require detectable warnings at every crosswalk. Our resolutions state that detectable warnings should only be considered if the slope of the curb ramp is 1-15 (1 inch of rise or fall for every 15 inches of run) or flatter. Anything with a slope greater than 1-15 is readily detectable with or without a cane.
Resolution 2002-16
WHEREAS, the Public Rights-of-Way Access Advisory Committee (PROWAAC)
of the Architectural and Transportation Barriers Compliance Board (ATBCB)
issued a report called "Building a True Community" which proposed new standards
and regulations to govern the building and rebuilding of public
rights-of-way such as streets, sidewalks, and other outdoor public
areas so that individuals with disabilities can access them; and
WHEREAS, this report contained recommendations regarding Accessible
Pedestrian Signals (APSs), which are electronic devices that alert the
blind pedestrian in an audible or vibrotactile manner when the traffic signal has
changed so that it is safe to walk; and
WHEREAS, the report recommended that an APS shall be provided at any
intersection where the timing of a pedestrian signal is altered by
push button actuation and where the signal includes a leading
pedestrian interval, a period of time during which the pedestrian is
allowed to start crossing before vehicular traffic is allowed to move; and
WHEREAS, the report further recommended that APSs with an optional-use
feature be installed at intersections where pedestrian crossing
intervals are pretimed and not affected by the push of a button; and
WHEREAS, pursuant to resolutions adopted by this organization, the
Federation submitted a minority report urging that the ATBCB mandate
APSs in situations only where the built environment did not provide sufficient nonvisual
clues for a blind pedestrian to know when it was safe to cross and that all
APSs be vibrotactile so that unneeded and distracting noise not be
emitted into intersections; and
WHEREAS, on June 17, 2002, the ATBCB published a draft guideline based
on the PROWAAC report, essentially disregarding both the PROWAAC
report and the Federation's recommendations and calling instead for APSs with locator tones to be
installed at every intersection with a pedestrian signal; and
WHEREAS, the PROWAAC report proposed installing APS in an overly broad
number of places but at least limited the installation to some degree
and further provided for an optional activation feature, thereby
giving each pedestrian the choice of using or not using the APS; and
WHEREAS, the board's draft guidelines will force installation and use
of APSs at every signalized intersection in America while costing tax
payers many billions of dollars; and
WHEREAS, at the majority of intersections the existing environment and
traffic pattern provide sufficient nonvisual cues for blind persons to
cross the street safely without APSs, and blind people do so every day: Now,
therefore,
BE IT RESOLVED by the National Federation of the Blind in convention
assembled this ninth day of July, 2002, in the City of Louisville,
Kentucky, that this organization condemn and deplore the ATBCB's narrow-minded and
uninformed view of blindness as expressed in the draft guideline
proposing to require the installation of APSs at all signalized
intersections in America; and
BE IT FURTHER RESOLVED that this organization urge the ATBCB to
reconsider and reject the extreme position taken on APSs in its June
17, 2002, draft guidelines and adopt a position on the placement and
use of APSs that is more realistic and consistent with the prevailing view among the blind themselves.
Resolution 2002-12
WHEREAS, the Public Rights-of-Way Access Advisory Committee (PROWAAC)
of the Architectural and Transportation Barriers Compliance Board (ATBCB)
issued a report called "Building a True Community," which proposed new
standards and regulations to govern the building and rebuilding of public
rights-of-way such as streets, sidewalks, and other outdoor public
areas so that individuals with disabilities can access them; and
WHEREAS, this report contained recommendations in the form of a
definition and also a set of requirements for installation of
detectable warnings, describing them as raised truncated domes in a
strip two feet deep and spanning the entire width of the curb ramp and
painted bright yellow or otherwise highly contrasting
in color with the surrounding surface; and
WHEREAS, these raised truncated domes are thought by some to give the
blind pedestrian a tactile warning underfoot that something hazardous lies
ahead; and
WHEREAS, on June 17, 2002, the United States Architectural and
Transportation Barriers Compliance Board (ATBCB) published draft
guidelines for public rights-of-way, substantially adopting the PROWAAC report regarding detectable
warnings; and
WHEREAS, the ATBCB's draft requirement for a detectable warning
surface two feet deep where the ramp, landing, or blended transition connects to a
crosswalk and in other areas rests on the fallacy that public
rights-of-way without such brightly colored tactile markings are
unsafe for blind people and that taxpayer dollars must be devoted to
universal installation of these strips of colored domes; and
WHEREAS, rather than being supported by a demonstrated and factual
need, the ATBCB's draft guideline is based on nothing more than fear of
blindness and lack of knowledge about how blind people travel independently and
safely and could bring the entire regulation, if enacted, under fire in the
courts and city halls of America; and
WHEREAS, pursuant to Federation policy as set forth by previous
resolutions, the National Federation of the Blind filed a minority report
advocating that detectable warnings be placed only at intersections at which the
approach to the street is at a slope of one inch downward for every fifteen inches
of sidewalk, commonly called a slope of 1:15 or flatter, since
intersections with an approach to the street of 1:15 or less are
virtually flat and are the only places where it may arguably be
difficult for a blind person to determine when the sidewalk ends and
the street begins; and
WHEREAS, intersections with street approaches which slope at an angle
steeper than 1:15 are readily detectable underfoot whether the blind
person is using a cane, a dog, or no mobility tool whatsoever, and therefore do not
require the installation of expensive truncated dome strips to ensure that
blind people detect the street; and
WHEREAS, the ATBCB's draft guideline is now subject to public comment
and will not become a final and enforceable rule if the facts about
blindness and independent travel are presented and understood, but
previously suspended requirements for detectable warnings which differ
from the current draft guidelines are technically now in effect, the suspension having lapsed, making a
resolution of this issue inevitable: Now, therefore,
BE IT RESOLVED by the National Federation of the Blind in convention
assembled this ninth day of July, 2002, in the City of Louisville,
Kentucky, that this organization vigorously oppose the ATBCB's draft guidelines calling
for the universal installation of detectable warnings; and
BE IT FURTHER RESOLVED that this organization petition the ATBCB to
reinstate the suspension on guidelines for detectable warnings while
further consideration is given to the draft guideline on public rights-of-way, in order to
avoid confusion and needless installation of warning strips that are
apt to be inconsistent with the eventual guideline regardless of the
result; and
BE IT FURTHER RESOLVED that this organization urge the ATBCB to adopt
a final guideline based on facts rather than fear and which may
include installation of detectable warnings only when the slope of the
curb ramp at an intersection equals 1:15 or less.