1655 West Farwell Avenue - Apartment 2B

Chicago, Illinois 60626

August 31, 1993

Architectural and Transportation Barriers Compliance Board

Office of the General Counsel

1331 F Street NW

Washington, DC 20004-1111

Dear Sir or Madam:

As a blind person, I strongly favor suspension of requirements for installation of detectable warnings in all locations, including rail stations, pending thorough and comprehensive study.

Significantly, both Miami and San Francisco have mild climates with no snow and ice. Yet the current federal regulations implementing the Americans with Disabilities Act (ADA) mandate detectable warnings on all rail systems nationwide, including the large commuter rail and rapid transit systems of Chicago and the northeastern cities, based on this obviously flawed study and demonstration project on Metro-Dade and BART.

Having experienced detectable warnings as a blind person riding rapid transit, I find that they hinder, rather than enhance my safety. On a platform, I move most safely and confidently when I can find the edge and walk along it, a few feet in, using a long cane. When boarding the train, I find the platform edge, the side of the car and the doorway. When I rode Metro-Dade and Bay Area Rapid Transit (BART), the detectable warning material severely obstructed the movement of my cane. The first time I touched it, I nearly lost grip of my cane, not expecting the drastic change in texture between the rubber material, with its truncated domes, and the smoother concrete platform.

To date, the Chicago Transit Authority (CTA) has installed some detectable warning materials in only one demonstration site. Even though CTA used detectable warning material made of metal and fiberglass, my cane tip still became caught in it as I boarded trains. Further, snow and ice tended to cover the truncated domes and accumulate between them. In all these instances, I felt more secure sliding my cane along the train car body to the door than through the detectable warning material.

As background, I have been blind all my life. I took an interest in mass transit ever since childhood, realizing that I would not drive because of my blindness. I learned to ride CTA, in particular, and transit in general, before any discussion of detectable warnings. In my travels, I have ridden rail rapid transit, intercity and commuter rail, and light rail systems throughout the United States and Canada, as well as several European countries. I also have taught many blind people to travel independently -- crossing streets and riding mass transit confidently and safely. For the past twenty-five years, I've been a member of the National Federation of the Blind (NFB). I benefit every day through the positive philosophy of NFB.

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The Federation has a positive attitude about blindness. It asserts that, with proper training and opportunity, blind people can and do compete on equal terms with their sighted colleagues in all activities of life. NFB has long stressed the importance of mass transit, while opposing modifications of the built environment for blind people, such as detectable warnings.

I note a striking contrast between the Federation's positive attitude and the negative attitude of those who advocate detectable warnings. Unfortunately, far too many professionals who work with the blind have very low expectations about blindness. In this instance, they assert erroneously that rapid transit is unsafe for blind people. Yet, the Federal Transit Administration (FTA), formerly Urban Mass Transit Administration (UMTA), chooses to pay more heed to the so-called experts, rather than the rank-and-file blind across this nation. A few years ago, for example, UMTA commissioned a study by Professors Alec Peck and Billie Bentzen, of Boston College From its opening statement throughout the rest of its pages, this study reflected a pervasive and clear negative bias against rail rapid transit, as a safe, efficient travel mode for blind people.

I understand that the current rule does not require detectable warnings in such places as curb ramps, hazardous vehicular areas, and around reflecting pools, until the completion of further study. This rule only defers, until January 26, 1995, but does not suspend, detectable warning requirements for rail station platforms. Thus, I strongly urge the Architectural and Transportation Barriers Compliance Board to suspend requirements for installation of detectable warnings in all locations, including rail stations, pending thorough and comprehensive study. Further, I strongly urge ATBCB ultimately to remove permanently any requirements for installation of detectable warnings from federal regulations, including those implementing the Americans with Disabilities Act (ADA).

Cordially,

Steven Hastalis

1655 West Farwell Avenue, Apartment 2B

Chicago, Illinois 60626

October 10, 1994

Ms. Judy Heumann

Architectural and Transportation Barriers Compliance Board

1331 F Street N.W.

Washington, D.C. 20004-1111

Dear Ms. Heumann:

I write to express my thoughts and concerns regarding installation of detectable warnings in rail stations. I take a fundamentally different approach from that which underlies the U.S. Department of Transportation (DOT) directive, implementing the Americans with Disabilities Act (ADA), that rail systems throughout the country install detectable warnings along platform edges. As a blind person, I strongly favor suspension of such requirements.

I support the extension which Washington Metropolitan Area Transit Authority, (WMATA) received on the U.S. DOT's deadline for installing detectable warnings in key stations, pending study of this issue over the next several months. As you may know, WMATA installed a demonstration site of detectable warning material toward the north end of the southbound side of the subway platform under Washington D.C. Union Station. On Monday afternoon, June 27, I encountered this site as a rush-hour commuter and business traveler. A southbound train arrived just as I came down the escalator from Amtrak, my shoulders loaded with baggage. As I quickened my pace to reach the rear car of this train, my cane tip became caught in the detectable warning material. Although I knew about this installation, I still felt frustrated and surprised, inasmuch as this material kept me from using the platform edge as a guide. I then walked along, away from the detectable warning material, following others' footsteps and the sound of the train standing about fifty to one hundred feet ahead of me on my right. Train sounds such as air compressors and air-conditioners, as well as footsteps, while useful environmental cues, do not and cannot substitute for the definite reference and guide which the platform edge provides. I felt relieved to reach the granite platform edge past this material and the open door of this train.

I have ridden Metro Rail many times over the years, beginning with the first section of its Red Line between DuPont Circle and Rhode Island Avenue in January, 1977. I much prefer the granite platform edge to the detectable warning material with the raised, truncated domes.

On a personal note, I have been blind all my life. As a young blind child, I became seriously interested in mass transit, realizing that I would never drive. I had cane travel instruction during the summer of 1964. I quickly realized that I could move about safely and efficiently -- crossing streets, riding mass transit or traveling in any public places, using many cues which are inherently part of the environment. Since then, I have traveled extensively in the Chicago area, as well as in cities throughout the United States, Canada and Europe. My experience is by no means unique. Thousands of blind persons throughout the country travel safely and confidently by mass transit every day. Fortunately, when I learned to travel with the cane, there was not even implicit suggestion of modifications of public facilities specifically for blind persons. Had detectable warnings or other modifications been in common use then, I do not believe I would have gained the confidence or competence to travel independently. I would have been at a loss at locations where detectable warnings or other modifications had not been installed.

For the past twenty years, I have traveled at least 150 miles per week on mass transit, mostly rail. Over the past eighteen years, I have taught many blind persons to travel confidently and competently, crossing streets and riding transit. I will recount these examples.

Within the past few months, I gave a travel lesson to a young blind man; we rode downtown on Chicago's newest rapid transit route, the Midway Line. Of course, I pointed out the importance and practicality of finding the platform edge, and using it as a guide to walk straight. In this manner, we boarded and alighted the trains safely, without the obstruction and hindrance of detectable warning materials with raised, truncated domes.

In November, 1992, I participated as an instructor in the Travel Seminar which the NFB of California held at its state convention in Sacramento. I took my student on a walk of several blocks, perhaps a mile and a half. I lent him my carbon-fiber straight cane and used my telescopic cane which I carry as a spare. He much preferred our long, light-weight canes to his short, heavy collapsible cane. He moved with increasing speed and confidence as we walked through downtown Sacramento. Along our way, I showed him a car stop on the light rail system. We examined the braille on the ticket vending machine and the detectable warning in the street, adjacent to the rails. I asked to try my student's collapsible cane on the detectable warning, to feel any possible contrast with my metal-tipped carbon-fiber cane. While both canes became stuck in it, the collapsible cane, with its nylon tip, stuck much worse. My student didn't like the feel of the metal tip on the detectable warning, and when I suggested that he try his cane, he nervously declined.

In the summer of 1987, I gave a travel lesson to a blind lady who moved to Washington D.C. about a year earlier. For three hours we rode most if not all of the Blue, Orange and Yellow Lines on Metro Rail. We boarded and alighted trains at several stations. I worked with my travel student on practical cane techniques for escalators, stairs and platform edges. She has ridden Metro Rail safely ever since.

As a blind person who has ridden rapid transit throughout this country and several others, I find that detectable warnings hinder, rather than enhance my safety. On a platform, I move most safely and confidently when I can find the edge and walk along it, a few feet in, using a long cane. When boarding the train, I find the platform edge, the side of the car and the doorway.

As an active member of the National Federation of the Blind (NFB), I whole-heartedly support its philosophy that, given proper training and opportunity, blind persons can and do travel efficiently, safely and independently without the necessity of exotic, expensive modifications of the built environment, such as detectable warnings. These and other modifications of public facilities, ostensibly to benefit blind persons, instead tend to reinforce negative attitudes about blindness and waste precious public money. Such modifications, convey to the public, blind and sighted alike, the harmful and misguided notion that blind persons cannot travel or otherwise lead their lives unless the world is specially built and altered. Blind persons receiving travel training in places with detectable warnings may be less willing or able to travel in areas which are not so modified. The sighted public may be more inclined to discriminate against blind persons, falsely assuming that great effort and expense are required to make facilities of employment, housing or transportation accessible to the blind. Further, employers, transportation providers and managements of other public accommodations might deny their programs and services to blind persons, by reason of the absence of such modifications in existing facilities. For your information, I have enclosed brochures detailing the positive programs and philosophy of the NFB. I encourage you to consult with the rank and file blind, as represented by the National Federation of the Blind, if you have questions or concerns about this or other transportation issues related to blindness and blind persons.

I strongly urge permanent rescinding of all federal regulations or requirements including those implementing the Americans with Disabilities Act (ADA), for installing detectable warnings in all locations, especially rail stations.

I look forward to your reply.

Cordially,

Steven Hastalis

cc:	The Honorable Federico Pena

Jack Evans, Chairman, WMATA

enc.	What is the National Federation of the Blind

Do You Know a Blind Person