Introduction:
This is a response on behalf of the National Federation of the Blind of the United Kingdom (NFBUK).
NFBUK was established in 1947 and is an independent, non-political, self-help group and registered charity. Through campaigning and representation, NFBUK seeks to improve the overall quality and welfare of daily life, for all blind, deaf-blind, partially sighted and those people whose sight impairment is part of multi disability, in the UK. This includes, equal access to and safe freedom of movement within the built environment.
NFBUK welcomes this opportunity to respond to the consultation. However, we are disappointed that we were not involved in the inaugural meeting held on 21 November 2014 in London, to discuss the matter.
NFBUK is a democratic membership led organisation and regularly consults/communicates with its members on all aspects affecting their daily life. Hence NFBUK is the genuine voice of blind people in the UK.
As a result of their repeated persistent campaigning, NFBUK were instrumental in securing the introduction of tactile surface guidance in 1978.
We agree that the guidance needs to be reviewed and updated to ensure that it is fit for purpose and we urge the Department to begin this process as a matter of urgency.
We are concerned that piecemeal changes to the guidance could lead to further departure from the guidance even where the guidance remains relevant.
Response to consultation questions:
Question 1
Relaxation of the requirement for the back edge of an area of blister paving to be perpendicular to the crossing direction:
- Do you agree with this amendment to the tactile paving guidance?
- If you do not agree what are your objections?
Response:
We do not agree with this proposal. It would appear that it is motivated as merely a quick fix for road engineers and not a genuine attempt to sort out any conflicting guidance. It will likely only lead to further confusion in the orientation of blind, deaf-blind and partially sighted users.
We are concerned that the curved approach may be impractical because it will require those installing the tactile paving to have to cut many more tiles to achieve the correct shape. This impacts upon costs as well as the time taken to lay the paving. If the paving is not installed correctly this could lead to increased trip hazards and there may also be maintenance issues.
Question 2
Replacement of the requirement for blister paving at a controlled crossing to be red with a requirement for at least a 50% contrast ratio with the surrounding paving:
- Do you agree with this amendment to the tactile paving guidance?
- If you do not agree what are your objections?
Response:
We do not agree with this proposal, as it is only aesthetics driven for sighted people and does nothing to help blind, deaf-blind or partially sighted people. Past research has clearly identified red to be the preferred and most easy colour, to identify that it is a controlled crossing point.
We are concerned that the use of minimum contrast rather than a specific colour undermines the principle of uniformity (highlighted in the Newham case). We are also concerned that local authorities may not have resources or capacity to hold the necessary range of colours of tactile paving to achieve the necessary contrast.
Question 3
Introduce a universal requirement for the boundary between carriageway and footway to be demarcated with tactile paving wherever they are at the same level:
- Do you agree with this amendment to the tactile paving guidance?
- If you do not agree what are your objections?
Response:
We are strongly opposed to this proposal. We are very concerned that this will only open the floodgates for more shared spaces on the grounds that advocates will think this corduroy paving option will remove the objections of blind people to shared spaces, as follows: Blind people who navigate with the aid of a long cane or a guide dog rely upon kerbs, pedestrian crossings and other surface features to guide them to their destination, and because they cannot see moving vehicles they are also unable to negotiate right–of–way with motorists, and are therefore excluded from streets which have no safe, vehicle free footways and walking routes.
The removal of kerbs and pedestrian crossings contravenes the Public Sector Equality Duty because it discriminates against people with various disabilities, and NFBUK is therefore campaigning for the re-installation of kerbs and pedestrian crossings to all streets from which they have been removed, and therefore cannot endorse any measures which could encourage the removal of even more of these essential streetscape features.
Therefore, we believe that the best way of delineating the carriageway and the pavement is through the continued use of a kerb. In accordance with the requirements of “Inclusive Mobility – Best Practice Guidance” we believe that the kerb should be at least 125mm. We are concerned that this proposal may lead to the green light being given to the increasing use of flushed/shared surfaces.
We urge the Department to write to local authorities explaining the importance of and necessity for of the use of a kerb and the potential discriminatory effect of removing them.
Question 4
Suggestions for crossing improvements:
- Do you agree that where signal controlled crossings have two push button boxes they should both have tactile rotating cones?
Response:
It is the policy of NFBUK to call for the introduction of “puffin” style crossings at all controlled crossings and these routinely require to be fitted with rotating knurled cones below the control box. Your statement “have two push button boxes, they should both have tactile rotating cones” is misleading. All controlled crossings (with the exception of zebra’s), have one control box at either side of the full carriageway. Are you suggesting that there be two boxes to each side of the carriageway? One with its back to oncoming traffic and the other facing the oncoming traffic? If it is the latter, then this takes no account of the ethos and thinking behind the safety approach in installing “puffin” style crossings i.e. by installing the back of the control box towards the direction of the oncoming traffic, effectively this means that when all pedestrians are looking at the red/green person display, before stepping off the pavement, they can satisfy themselves that the traffic is actually stopping and not jumping the red light. With far side signalised crossings, the tendency has been that pedestrians observe the “wait” sign going out and simply step off the pavement without checking that the traffic has actually stopped, thus increasing the accident/injury rate.
- Do you agree that push button boxes at signal-controlled crossings should have tactile arrows indicating the crossing direction?
Response:
This proposal will potentially only assist a very small limited number of users. How would a long cane user or guide dog handler, hold on to their cane or dog and at the same time the rotating knurled cone and vibrating arrow? We would respectively refer you to and recommend the trials on “traffic signals for the 21st century”, recently undertaken by Transport Scotland in collaboration with the DFT. Implementing the findings from this research would benefit far more blind, deaf-blind and partially sighted users.