RNIB response to the Department for Transport’s Transport Accessibility Action Plan (Accessible Streets and Shared Space)

Response to Action 1:accessible streets

We welcome the updating of Inclusive Mobility and in fact have been asking DfT to review it for some years now. We formally called for the update in 2015 when we published our ‘Who Put That There?’ report and are disappointed that progress is still only at the planning stage. It is essential that blind and partially sighted people are involved in the review of any guidance relating to Inclusive Mobility or tactile paving from an early stage. Shared space schemes and cycling infrastructure need to also be tackled within Inclusive Mobility. We call for a moratorium on all new shared space schemes until their impact on disabled people, especially those with sight loss, has been assessed and addressed within relevant guidance and regulations. In fact, the progress on inclusive environments indicated at 4.4 of the action plan is being completely undermined by the spread of shared spaces.

With regard to the tactile paving review, our understanding is that the results of the previous consultation showed a need to review this guidance and that a decision has already been taken to deliver new guidance. RNIB, along with other sight loss organisations, was invited to sit on a working group scoping out the proposed review, however, this work seems to have abruptly ended with no notice to participants. Like Inclusive Mobility, we believe there is a clear need to review this guidance and work should be undertaken on this as a matter of urgency (in conjunction with the Inclusive Mobility work). In the absence of updated guidance, local authorities will continue to ignore existing guidance leading to a further deterioration in the position of tactile paving. We note, for example, that TfL will shortly put out their own consultation on tactile paving in the absence of action from the Government. As the consultation document points out, consistency in this area is vital and so the Government must take a lead.

Enforcement and compliance with regulations and guidance is an ongoing problem. There are many stations and streets which still do not comply with the current Inclusive Mobility guidance. Our recent survey showed that over one third of respondents said that the lack of tactile strips on train station platforms made it difficult for them to travel. Inclusive Mobility sets out that tactile strips should be used, but at many stations they are not.

Recommendations:

  • DfT must update both Inclusive Mobility and tactile paving guidance urgently,involving blind and partially sighted people in the process
  • DfT must ensure that the guidance is promoted extensively and it is monitored to encourage compliance

Accessible streets - Additional Points

The AAP must address the way blind and partially sighted people are excluded from consultation processes due to inaccessible information

We have received multiple complaints about the inaccessibility of local consultation processes in relation to public space and cycling planning schemes.

In practice, most public consultation processes seem to have routinely failed to communicate accessibly with the public via notices, documentation and maps in accessible formats such as large print, audio, braille and accessible digital formats, which are crucial to enable blind and partially sighted people to participate.

The lack of properly considered accessibility provisions directly impacts blind and partially sighted people’s ability to know about, and participate in, the consultation process. It leaves them partly or wholly excluded from these consultations. Failure to reach out and engage with the wider community who may be affected, means only very narrow sections of the local population who are blind or partially sighted are reached.

When consultations are over and schemes go on to be constructed and completed, reports from people who contact us reveal there is typically a lack of viable on-the-ground accessible systems enabling blind and partially sighted people to accessibly alert and report any adverse experience or incident. This results in the loss of critical feedback from this often severely affected section of the public.

For example, local notices promoting feedback opportunities communicate only by visual means alone, as do online and social media opportunities, meaning blind and partially sighted users of the public space remain unaware of these opportunities to feedback.

In addition, Apps provided by local authorities that could promote and enable feedback on the accessibility of recently completed public space developments are typically not fully accessible and/or cater only for sighted users and fail on specific usability requirements of blind and partially sighted people. For example, Apps do not facilitate users who cannot visually identify the precise location of an incident or the nature of a vehicle(s) involved in an incident.

Ensuring the AAP speaks to planners and architects so they understand “appearance” is a multisensory concept that includes tactile and touch perception of public spaces

We believethe DfT’s AAP is a great opportunity to improve the accessibility of Britain’s public spaces for blind and partially sighted people by recognising and promoting that the use of the term “appearance” and the meaning of “well designed” throughout all related communications is, critically, more than just about visual concepts.

‘Accessibility’ is not and should never be treated as a requirement to be bolted-on to the end of a design process or as a mitigation against a separate criteria. Accessibility is a natural human requirement that exists in the population.

For a design process to be ‘social model’ rather than ‘medical model’ every design should evolve inclusively, rather than have inclusion bolted on at the end.

  • The definition of “appearance” must fully include tactile and touch into the definition by proactively educating and re-directing the ‘shared space’ development community away from visually biased concepts and towards a multi-sensory comprehension of the term.
  • The AAP must reinforce that accessibility is an end-to-end design process and not a bolt-on process of mitigation.
  • We think all design guidance starting with LTN 1/11 must not only sharply distinguish but practically direct the different design requirements of a. partially sighted people and b. blind people, as related but experientially separate user groups.
  • Design guidance must ensure each group’s differing requirements, often poorly understood and inevitably confused by architects and planners, are practically addressed in engaging and deliverable ways for those developer communities.
  • We think that by addressing the lack of clarity that LTN 1/11, Manual for Streets and Inclusive Mobility guidance has unfortunately left between the needs of these separate user groups, the Department for Transport will be able to improve understanding and therefore motivation amongst architects and planners, which should result in improved adherence to the guidance.

Urgent need for AAP to reverse the loss of controlled crossings and standard kerbs

Quote from member of the public:

“This has huge implications for my independence and wellbeing. I and other members of the Northumberland Low Vision Action Group are registered blind, some of us are guide dog users, and others use a long cane. Blind and partially sighted people, particularly guide dog owners and long cane users, use the kerb as a navigation clue to know where they are in a street and which way they are facing.”

“The removal or reduction of the delineation between the pavement and carriageway poses great difficulty for people who are blind or partially sighted. Many blind and partially sighted people, disabled and elderly people including myself feel unable to use and thereby avoid shared surface areas.

“Most of us can only use controlled pedestrian crossings i.e. they must have visual, audible and tactile signals as well as the correct tactile paving surfaces.”

Through public space consultations and multiple examples of the feedback above, we know signal controlled crossings and standard kerbs are being systematically reduced and removed from public spaces around the country. This is due to ‘shared space’ design approach, which resists signal control crossings because the fundamental philosophy places eye-contact at the heart of the space sharing and traffic flow mechanism. It also replaces conventional kerbs with flush or near-flush surfaces.

We know signal control crossings are fundamentally important as a reasonable adjustment for all blind and partially sighted pedestrians who, due to their disability, often cannot make the necessary eye-contact with cyclists and motorists as other pedestrians.

While the green pedestrian signal is protected and as DfT state in this consultation document “so that people know they can cross with safety” which we agree is a critical factor to blind and partially sighted pedestrians, we therefore believe that:

  • The AAP must proactively address and act to reverse the reductions and loss of signal control crossings by explaining their crucial importance as both a “safety” and an “an accessibility” adjustment in all public space and cycling scheme designs, retrospectively as well as in planning and construction.
  • We think the AAP has a crucial role to make this issue prominent throughout DfT advice and guidance relating to accessibility infrastructure, in order to help turn-around the losses of signal control crossings that have taken place, and consequently impacted the ability of blind and partially sighted people to be in personal control of their own safety when attempting to make a pedestrian journey through a public space.
  • We are also aware of signal control crossings that have been installed in public spaces but, due to the share space design approach, are rendered unavailable to blind and partially sighted pedestrians due to the failure of the design to incorporate high contrast and tactile “findability” of these crossing facilities.
  • We think the AAP should instigate action to address these critically important issues by setting up a taskforce to address and reverse the loss of signal control crossings in recent public space re-developments, as well as advise, advocate and support resolution of issues arising from schemes being planned and consulted on.

The loss of standard kerbs has also taken place across the country as a result of public space re-developments, and also minor changes to road junctions where ‘raised tables’ are installed.

  • We think the AAP must proactively address the loss of standard kerbs by restating the real value to blind and partially sighted peopleof these design features, for example:
  • By setting out that standard height kerbs and kerb upstands of 60mm and higher are detectable by blind and partially sighted people and to draw attention to the recent Judicial Review of Lisburn council (Northern Ireland) in relation to the difficulties caused by lowered kerbs.
  • Explain that kerbs of standardkerbsprovide unequivocal and binary information as to the status of the adjacent surfaces, unlike tactile strips which cannot convey this level of information as a stand-alone feature, and subsequently have multiple meanings.
  • The AAP should highlight to planners, architects and local authorities that providing equivocal information as to the status of adjacent surfaces is unacceptable and that as a general rule, a kerb with an upstand of 125mm is the only unequivocal way of installing the necessary adjustment for blind and partially sighted pedestrians.

AAP must create a strongly practical and implementable version of inclusion and move beyond simply encouraging others to work it out for themselves

In the consultation DfT state that wide -ranging guidance on street design that they provide to practitioners includes references to the need for inclusive design. For example ‘Manual for Streets’ and ‘Manual for Streets 2’ published in 2007 and 2010 respectively.

  • We cannot agree with this because we cannot see how inclusion is clearly covered. This is a crucial area that we think the AAP can act to correct.

Inclusive Mobility guidance is fundamentally important but the AAP needs to address guidance such as Manual for Streets that directly contradicts it.

We agree with DfT that Inclusive Mobility is a key piece of guidance, and should enable local authorities to deliver accessible public realm environments.

  • Westrongly support DfT’s objective to ensure that it is used consistently by all local authorities.
  • We think DfT must act to give Inclusive Mobility strength and prominence in the AAP.

However we think DfT must also ensure that the flexibility that Manual for Streets guidance espouses in relation to the need for adherence to the Inclusive Mobility guidance is addressed, to end the current contradictions between these two sets of guidance that are undermining the essential need for universal standards.

Extracts from Manual for Streets Guidance that contradict the importance of adhering to Inclusive Mobility Guidance:

“2.6.1 A major concern expressed by some highway authorities when considering more innovative designs, or designs that are at variance with established practice, is whether they would incur a liability in the event of damage or injury.”

“2.6.2 This can lead to an over-cautious approach, where designers strictly comply with guidance regardless of its suitability, and to the detriment of innovation. This is not conducive to creating distinctive places that help to support thriving communities.”

“2.6.3 In fact, imaginative and context-specific design that does not rely on conventional standards can achieve high levels of safety. The design of Poundbury in Dorset, for example, did not comply fully with standards and guidance then extant, yet it has few reported accidents. This issue was explored in some detail in the publication Highway Risk and Liability Claims.14”

The above entries in Manual for Streets guidance are concerning when it comes to issues of disability equality because many of the requirements are “standards” based and revolve around the need for consistency. An example of this issue which we frequently come across is the use of ‘setts’ rather than a kerb (or corduroy paving). The use of setts is entirely untested as a delineator and no testing has been done on detectability and the necessary widths and the impact on people with mobility difficulties.

The “innovative” approach espoused by Manual for Streets guidance is also problematic because it means that each area is using different materials for different purposes which limits the ability of blind and partially sighted people to move around freely between areas. This is an issue emphasised by the DfT in its consultation on the Accessibility Action Plan and is behind the standards based approach.

Also the reference made in 2.6.3 above from Manual for Streets to ‘Poundbury’ is unhelpful as the design of this town almost entirely ignored the requirements set out in the DfT’s Inclusive Mobility guidance.

  • The AAP must recognise the contradictions caused by Manual for Streets guidance highlighted above, the problems they cause and undertake to correct them.
  • Inclusive Mobility guidance is also hindered by the problems that exist in LTN 1/11 and that by resolving the problems in LTN 1/11 there will be a great opportunity for Inclusive Mobility to positively influence public space design as originally intended.

DfT’s review Inclusive Mobility guidance must take account of societal changes

  • We believe the guidance must now also be revised to take into account the way UK public spaces are changing as policies on de-carbonisation, public health and driverless vehicle technology take effect.
  • The replacement of “easily hearable” vehicles with “extremely difficult or impossible to hear” vehicles (bicycles, electric vehicles).
  • The introduction of new street obstacles such as electric charging points.
  • The introduction of driverless vehicles and pods.

Response to Action 2: shared space

We welcome DfT’s involvement with CIHT on their work on shared space. However, this review has been ongoing for a number of years and it is not clear when it will conclude. In the meantime many schemes are being planned or are in-development by local authorities across the country, thatinvolve a shared space design approach.

We therefore urge the Government to implement the recommendation of the Women and Equalities Committee.

Recommendations:

  • DfT must write to local authorities requesting that they cease implementation of shared space schemes in particular any scheme that involves the removal of kerbs and controlled crossings
  • DfT must ensure kerbs and crossings are retrofitted to all shared space schemes.
  • DfT must urgently replace LTN 1/11 with new guidance which reinforces universal accessibility standards involving blind and partially sighted people in the process

Shared Space - Additional points

AAP must clarify the need for safety and accessibility adjustments to facilitate “sharing” for blind and partially sighted pedestrians in “shared space”.