Consultation on the draft Traffic Signs Regulations and General Directions 2014.
Response from Royal National Institute of Blind People (RNIB)
12 June 2014
Introduction
1. about us
As the largest organisation of blind and partially sighted people in the UK, RNIB is pleased to have the opportunity to respond to this consultation.
We are a membership organisation with over 10,000 members who are blind, partially sighted or the friends and family of people with sight loss and more than 80 per cent of our Board of Trustees are blind or partially sighted. We encourage them to be involved in our work and regularly consult with them on government policy and their ideas for change.
As a campaigning organisation of blind and partially sighted people, we fight for the rights of people with sight loss in each of the UK’s countries. Our priorities are to:
•Stop people losing their sight unnecessarily
•Support independent living for blind and partially sighted people
•Create a society that is inclusive of blind and partially sighted people's interests and needs.
We also provide expert knowledge to business and the public sector through consultancy on improving the accessibility of the built environment, technology, products and services.
Our response
Please find below our considered feedback relating to the specified parts of the draft regulation.
2. Section3 – Reducing sign clutter
Regarding “3.2Over-provision of signs can have a detrimental impact on the environment and can dilute important messages. If they result in information overload for drivers they can contribute to driver distraction, which can have an impact on road safety.”
2.1 RNIB wishes to draw attention to how the over-provision of signs also has significant impacts on the pedestrian footpath especially affecting people who cannot see the polls and posts on which the signs are mounted. We believe that moves to reduce the number of polls and posts that obstruct the pedestrian footpath will have direct beneficial effects on the mobility of blind and partially sighted people across the country. We hope this element of the new regulations will result in the removal of a significant proportion of polls and posts from pavements and that monitoring of the effect of this new regulation is regularly assessed and reported.
2.2 We also welcome the Departments sponsorship of the Chartered Institution of Highways and Transportation ‘Reducing Sign Clutter Award’ to promote good practice, amongst local authorities and urge the department to develop and promote this initiative to enable it to deliver real and long-term benefits.
2.3 The design of some signs is problematic. Blind and partially sighted people tell us that signage designed in a hoop style as outlined in the Traffic Advisory Leaflet 3/13: Traffic bollards and low level traffic signs are, in practice, difficult or impossible to detect with a white cane. We request that Local Authorities take this issue into account and refrain from using hooped traffic signs on pavements. We also request that impact assessments are conducted on other low level signs to identify the risk of other sign designs at low level having similarly negative impacts.
3. Section 4 – Parking Signs and waiting restrictions.
3.1 All too often people with sight loss find the pedestrian footpath blocked by a parked car. Typically this is where a car has parked on a pavement or dropped curb. The effect is to limit their ability to walk down a street or cross a road safely. As a means of helping drivers to recognise where parking is not permitted, RNIB is pleased to see that ‘Signing the Way’ recommends new sign design for parking signs, which we hope goes some way to improve road user understanding of parking restrictions.
4. Section 5 – Measures to improve cycling facilities
4.1 RNIB recognises the government’s objectives to reduce car usage and encourage cycling. However, feedback from blind and partially sighted people highlights that cycle traffic frequently has serious implications on blind and partially sighted pedestrians. RNIB has many examples where collisions have occurred between pedestrians and cyclists at points where cycle routes cross or merge with pedestrian footpaths.
4.2 Many blind and partially sighted people report collisions with cyclists and many more report near misses. Physical injuries are more common than we anticipated. Near misses often have emotional impacts on an individual’s confidence levels which are essential for maintaining functional mobility skills. Where actual physical collisions occur, these have much greater and long lasting negative implications on people’s ability to travel independently.
4.3 RNIB believes greater attention and profile needs to be given to these issues because the problems increase as the amount of cycle traffic increases. We anticipate the rise in cycle traffic to result in a corresponding rise in blind and partially sighted people’s fear of getting out and about.
4.4 We know that blind and partially sighted people have been able to positively use the TO objection process as a means to engage with the local authority to highlight problems and concerns. In some instances facilities have been changed or abandoned after the local authority have considered impacts on blind and partially sighted pedestrians.
We therefore have serious concerns about the removal of TOs for cycling facilities. Traffic Orders (TO) and the accompanying off road signage is vital to ensure that cyclist understand the rules and where and when they are permitted to ride. They also enable pedestrian awareness of their rights and how to negotiate their way. Removing signs will inevitably relax further the sense amongst many cyclists that they can ride on the pavement, which is already one of the most common complaints that blind and partially sighted people raise with RNIB. Lack of signage seems almost certain to promote confusion amongst pedestrians and cyclists and make it more difficult for people to know their rights and make appropriate complaints.
5. Section 6 – Traffic signals and pedestrian crossings
5.1 Crossing the street is an essential part of negotiating our built environment. The provision or otherwise of safe crossing points affects everyone's ability and desire to use their local streets, but lack of safe crossing points does affect blind and partially sighted people extremely seriously, some can feel so concerned about their ability to get around that they decide not to go out at all on their own, when in fact they do possess the mobility skills to get out and about. For many white cane users there is no possibility of independently crossing roads, even with moderate to light traffic levels, within acceptable personal safety margins.
5.2 Traffic signals are critical in reducing conflicts between road users, manage traffic flow and provide safe, accessible places to cross.
5.3 To ensure that Pelican and Puffin crossings are accessible it is essential that the DfT clearly states that local authorities and planners should provide facilities which enable disabled people to cross the road safely. This includes the provision of dropped paving, appropriate tactile pavement to mark crossing points, together with audible and tactile signals on the crossing beacons themselves.
Joanne “Some crossings I use don’t have tactile rotating cones fitted and don’t beep, I literally just have to make my best guess and walk out in front of the traffic when I think it has stopped. I hate doing this because it feels so unsafe but what else can I do, I cannot stand waiting for ever and its worse when I have an appointment to get to.”
Other feedback
We wish to draw attention to some accessibility problems with the consultation document itself and the documents provided on the linked web pages.
Regarding the consultation document, while the general accessibility is good and the format (Word) is compatible with screen reading software, contrary to the statement at top on accessibility, the document did actually contain various graphical elements containing essential information that had no text alternative. All information conveyed using visual means should be accompanied by a text alternative.
Regarding documents for download on the linked web page: PDFs are provided with a disclaimer warning they may not be accessible for screen reader users. The provision of either accessibly tagged PDFs ought to remove the need for this sort of statement. The publication of untagged PDFs with no parallel Word alternative for screen reader users is problematic, particularly because many people who rely on assistive technologies are accessing online materials outside of office hours and often without sighted help. Online materials should be equally accessible to disabled users and non-disabled users especially as the technology does permit this using widely available technology. A website which forces some users, due to a sensory impairment, to have to email for an accessible copy of a document, is not really in practice a fully accessible website.
Further information and input from RNIB
RNIB welcomes all opportunities to submit further input to the consultation process.
We hope the above feedback raises awareness of the specific issues faced by blind and partially sighted people in a clear and coherent way. Our intention is to draw attention to aspects that might not necessarily be at the forefront of people’s minds but, for the people we represent, are very much part of everyday experience.
Please don’t hesitate to contact us for further information or to discuss issues in more detail.
Thank you.
Hugh Huddy and Tracy Dearing
RNIB Policy and Campaigns team
Tel 020 791 2123
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