Written evidence submitted by the National Federation of the
Blind of the UK (ATL0072)

 

Evidence of the systematic failure to protect the safety and accessibility of bus stops in active travel schemes in the UK

 

For the Transport Select Committee Inquiry on Accessible Transport – Legal Obligations by the National Federation of the Blind of the UK (NFBUK)

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Shared used bus stop boarder in Waltham Forest, London. Our President, who is blind, steps off a bus with a colleague. His white cane is longer than the width of the cycle lane (link to film).

 

 

 

 

 

 

 

 

 

 


Contents

 

Executive Summary

1.0              Bus Stops In Active Travel Schemes

2.0            Evidence Against Floating Bus Stops and Shared Use Bus Stop Boarders

2.1             Evidence Previously Submitted To The Transport Select Committee

2.2             Evidence to Illustrate How Bus Stops in Active Travel Schemes Discriminate Against Blind and Visually Impaired People in the UK

2.2.1     Leicester

2.2.2     Edinburgh

2.2.3     Glasgow

2.2.4     London

2.3             Transport for London Research on Bus Stop Bypasses Demonstrates The Majority of Cyclists Not Stopping To Let People Cross

2.4             Shared Bus Stop Boarder Removed Islington

2.5             Pedestrian and Cyclist Collisions and Near Misses in Denmark

2.6             Bus passenger hit by rented e-scooter New Zealand

2.7             The Telegraph Report

2.8             Canadian Federation of the Blind Won Human Tribunal Against Use of Bus Stop Bypasses

3.0            Organisations NFBUK Has Raised Concerns with On Bus Stop Designs in Active Travel

3.1             NFBUK Raised Concerns With the Following Organisations

3.2            NFBUK Request for Bus Stops To Be Included in Draft Transport Scotland / DfT Accessible Guidance Ignored

3.3             NFBUKS Concerns Over Living Streets Research Into Bus Stop Bypasses

3.4             Consultations NFBUK have responded too and been ignored.

4.0              National Petitions Submitted To Halt Any Further Floating Bus Stops and Shared Use Bus Boarders

5.0              Outcomes of Efforts To Raise Concerns on Discriminatory Design In Bus Stops In Active Travel Schemes

6.0              Recommendations

 

Appendices

Appendix A: NFBUK Evidence Submitted to The Transport Select Committee in 2019 Active Travel Inquiry

Appendix B: Islington Tribune Cycle Lane that pedestrians branded dangerous is axed. Published 4 March 2016

Appendix C: Urgent Petition on Safety and Accessibility at Bus Stops in the UK Appendix D: Urgent Need To Update Government Guidance

Appendix E: References


Executive Summary

 

The National Federation of the Blind of the UK (NFBUK) has raised significant concerns over the changes made to bus stops in active travel schemes across the UK. Bus stops have traditionally allowed bus passengers access to and from the bus direct from the pavement. In active travel schemes cycle lanes are sandwiched in between the pavement and the bus stop or they are positioned in front of the bus stop where bus passengers are expected to step into a live cycle lane to get on an off a bus. These designs are not safe or accessible for blind and visually impaired pedestrians. These designs are discriminatory and there use should have stopped.

 

The NFBUK have provided evidence to many organisations both governmental and civil society to illustrate how unsafe and discriminatory the new designs are; however, our concerns have been systematically ignored. Not only have these designs been built, but they have also been included in both national and local cycle design standards resulting in more local authorities using the designs.

 

The Equality Act 2010, the Public Equality Sector Duty and the Equality Impact Assessment process should have stopped this happening, but they have all overwhelmingly failed to protect blind, deafblind and visually impaired bus passengers, as well as many others disabled and vulnerable bus passengers from unsafe bus stops used in active travel schemes. It is nothing short of a national scandal and one that needs urgent attention and redress is needed to stop the situation getting any worse.

 

1.0            Bus Stops In Active Travel Schemes

 

The NFBUK have consistently raised concerns over the change of designs at bus stops in active travel schemes. Bus stops have traditionally been direct from the pavement to the bus giving safe access to blind and visually impaired bus passengers to board and alight from a bus. However, there has been a drive to install bus stops in active travel schemes which route cycle lanes in between the pavement and the bus stop or directly in front of the bus stop where passengers are expected to step into when getting on and off a bus. These designs are known as:

 


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Photo 1 Floating bus stop with a zebra crossing across the cycle lane. A bus

passenger is on the zebra crossing and is stepping back to let the cyclist go through as shown in this film.

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Photo 2: Shared use bus stop boarder in Waltham Forest, London. NFBUK President, who is blind steps off a bus with a colleague. His white cane is longer than the width of the cycle lane (link to film).

 

These designs are not safe or accessible for blind and visually impaired bus users or pedestrians. The cycle lanes act as a barrier as cyclists do not want to stop to let bus passengers cross and the designs are inaccessible for blind people to use independently.

 

Since lockdown cycle lanes are now also being used by a number of different legal and illegal e-micro-mobility vehicles, including e-bikes, e- scooters, e-skateboards, e-unicycles and all sorts of cargo bikes, with many using the cycle lanes at speed.

 

Blind and visually impaired people are no longer able to safely access these bus stops independently as they used to before, due to these new bus stop designs being used in active travel schemes.


2.0            Evidence Against Floating Bus Stops and Shared Use Bus Stop Boarders

 

The following evidence is given to validate our position against the use of floating bus stops and shared use bus stop boarders.

 

2.1            Evidence Previously Submitted To The Transport Select Committee NFBUK provided evidence against the use of floating bus stops and shared use bus stop boarders to the Transport Select Committee Active Travel Inquiry in 2019. This evidence is relevant to this inquiry and is given in Appendix A.

 

2.2            Evidence to Illustrate How Bus Stops in Active Travel Schemes Discriminate Against Blind and Visually Impaired People in the UK

 

Following on from the evidence provided in Appendix A, NFBUK resumed site visits and filming of bus stop bypasses in London, Glasgow, Edinburgh and Leicester after the pandemic and have undertaken searches on social media about these bus stops.

 

2.2.1     Leicester

In Leicester there is a cycle lane which has been constructed between the bus stops and the pavement outside the train station (Photo 3). NFBUK filming, site visit and observations exposed the following:


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Photo 3: Cycle Lane outside Leicester Train Station separating the bus stops from the pavement. There is a small upstand used to try and separate the cycle lane from the pavement. The pavement is a sandy colour and the cycle track a light grey colour. There is a cyclist riding the wrong way down the cycle track and 2 people walking in the cycle track.

 

2.2.2     Edinburgh

The NFBUK undertook a site visit to Leith Walk where a shared use bus boarder had been constructed. Sandy Taylor, NFBUK representative explained on this film how confusing and inaccessible the new design was for blind and visually impaired bus passengers and pedestrians. This was reported by The Edinburgh Reporter ii and by BBC February 2023iii.

Photo 4: Shared use bus stop boarder, Leith Walk, Edinburgh. A cycle lane has been installed on a pavement with wrong use of tactile paving trying to indicate where the cycle lane is. People waiting in, behind and in front of the cycle lane for bus. Temporary bus stop pole on side closest to the road.


2.2.3     Glasgow

In Glasgow many concerns have been raised about the design of Sauchiehall Street, by Sandy Taylor from the NFBUK. This has happened before, during and after its construction over its design and how it is not safe or accessible for blind and visually impaired people.

Photo 5: Sauchiehall Street, Glasgow. With a cyclist riding past a person wanting to cross the cycle lane from the bus shelter side. There is a small upstand separating the cycle lane and the pavement and bus island. There is tactile on the cycle lane but it is laid incorrectly. The pavement is grey and the cycle lane is a sandy colour.

 

2.2.4     London

Appendix A contains evidence from blind and visually impaired bus users not being able to use bus stop by passes in London. This situation has not changed since COVID and more problems have occurred with schemes that have been implemented since. NFBUK have continued to film bus stops in London, all of which have demonstrated the designs are not fit for purpose. Bus passengers are focused on catching the bus and cyclists are not stopping making the designs unsafe and unworkable.


These films show how impossible it is to get on and off a bus in safety:

Photo 6 Shared use bus boarder in Waltham Forest. Showing the NFBUK President Andrew Hodgson standing next to the bus stop pole, while a powered wheelchair users get on the bus with the ramp from the cycle lane. While a cargo bike rides onto the pavement inches behind Andrew Hodgson to get past and another cyclist rides in between Andrew and the Wheelchair user boarding the bus.


2.3            Transport for London Research on Bus Stop Bypasses Demonstrates The Majority of Cyclists Not Stopping To Let People Cross

Research commissioned by TfL clearly demonstrated the presence of zebra crossings did not affect cyclist behaviour with the majority of cyclists not giving way to the people wanting to cross at the zebra crossing, as well as no improvements in cyclists recognising the presence of a zebra crossing.

 

 

2.4            Shared Bus Stop Boarder Removed Islington

A shared use bus boarder had already been removed in Islington in 2016 as reported by the Islington Tribune ‘Cycle Lane that pedestrians branded dangerous is axed’ 4 March 2016 (Appendix B). The article explains how a shared use bus stop boarder was constructed without the needs of blind and visually impaired bus users taken into account. The Equality Impact Assessment had not worked to prevent the bus boarder being built and it was only when blind residents got involved they managed to get it removed, this quote from the paper for one of the blind people stated:

 

“It’s wrong in so many ways,” said Mr Ernstzen, who is chairman of Healthwatch Islington. “On a common-sense level or from an equality impact assessment perspective this fails.”

 

2.5            Pedestrian and Cyclist Collisions and Near Misses in Denmark

There is significant evidence to show in Denmark bus stops in active travel schemes are not safe and they have been a consistent confusion for both cyclists and bus users on how to use the different designs safely. From our research it is clear the bus stop designs are not safe and never have been. It is not understood why this evidence has been ignored in the UK. How did these dangerous, inaccessible and frightening designs get through the Equalities Impact Assessments and any of the many Road Safety Audits new schemes have to go through to ensure the safety of all road users, including vulnerable road users?


 

 

 


to see if anyone got off the bus, but when it didn't she cycled

on. At the same moment, however, a woman got out of the bus, and the cyclist did not have time to brake. The cyclist fell off his bike and suffered a gash on one of his elbowsxx.

 


 

 

2.6            Bus passenger hit by rented e-scooter New Zealand

This report from New Zealand Herald 6 April 2021 shows how a bus passenger was seriously hurt getting off a bus onto a shared used bus stop

/ pavement by a rented e-scooterxxviii in June 2019. The victim stated the following: "Clearly the speed pummelled me, turning me into a human spear, my feet not even touching the ground. Onlookers were shocked to the core."

 

2.7            The Telegraph Report

Recent report from the Sunday Telegraph (online version 18th March and published verion 19th March 2023) and covered by the Daily Mail further illustrate how many cyclists are not stopping to let people pass the zebra crossing at bus stop bypasses, with only 1 in 10 stopping to let people pass.

 

2.8            Canadian Federation of the Blind Won Human Tribunal Against Use of Bus Stop Bypasses

NFBUK are aware the Canadian Federation of the Blind (CFB) won a human rights tribunal against the use of bus stop bypasses.

However, the proposed solution for the flashing lights was not discussed or agreed with themxxix. The solution was imposed on them, and they have not accepted this a solution as it is not safe. The flashing lights are


accompanied by an acoustic message at the crosswalk between the sidewalk and the floating bus stop, where the audible signal warns pedestrians to cross with caution and says ‘vehicles may not stop’. The Canadian Federation of the Blind (CFB) have rejected this as a safe solution and blind people are now not using these floating stops as they are not safe. There has been a recent protest about the continued use of the bus stops by the Canadian Federation of the Blind (CFB) to demonstrate this on 21 March 2023 by the Times Colonist xxx.

 

3.0            Organisations NFBUK Has Raised Concerns With On Bus Stop Designs in Active Travel

 

3.1            NFBUK Raised Concerns With the Following Organisations

The NFBUK has raised concerns and / or provided evidence on these concerns with the following organisations, by one or more the following means: by meetings, by providing evidence or by third parties.

 

 

3.2            NFBUK Request for Bus Stops To Be Included in Draft Transport Scotland

/ DfT Accessible Guidance Ignored

There has been an ongoing working group that has been jointly funded by the Scottish Government and the Department for Transport to produce Guidance on ‘Inclusive Design in Town Centres and Busy Street Areas.

Requests were made by NFBUKs representative in Scotland, Sandy Taylor, who was part of this working group to include bus stops in that work but this was rejected. Instead, a 2 year research project on bus stop bypasses and continuous pavements was awarded to Living Streets by the Department for Transport. NFBUK have very strong concerns over this research and believe that it will not address our access requirements for


direct access to and from the bus stop from the pavement. Further concerns are given in Section 3.3 below.

 

3.3            NFBUKS Concerns Over Living Streets Research Into Bus Stop Bypasses The NFBUK are extremely worried about the research being undertaken by Living Streets on bus stop bypasses and continuous pavements on behalf of the Scottish and UK Government. In a recent ‘Roads for All’ meeting in Scotland, the author of the research said that in Canada floating bus stops had been successful. However as explained in Section

2.8 above, the Canadian Federation of the Blind (CFB) won a human rights tribunal against the case. Concerns were raised about the design and the author said that flashing lights had been installed to resolve the concerns. However, this solution was never agreed or discussed with the Canadian Federation of the  Blind (CFB)xxxi. The solution was imposed on them and they have not accepted this a solution. The flashing lights are accompanied by an acoustic message at the crosswalk between the sidewalk and the floating bus stop, where the audible signal warns pedestrians to cross with caution and says ‘vehicles may not stop’. The Canadian Federation of the Blind (CFB) have rejected this as a safe solution and blind people are now not using these floating stops as they are not safe. There has been a recent protest about the bus stops by the Canadian Federation of the Blind (CFB) to demonstrate just this on the 21 March 2023 by the Times Colonist xxxii.

 

3.4            Consultations NFBUK have responded too and been ignored.

NFBUK have responded to a number of consultations for active travel schemes and requested designs of bus stops / shared use bus boarders not to be used in designs to:

 

 

It is clear that our concerns, evidence and advice have been systematically ignored by these organisations, who have continued or are planning to use these designs in schemes and do not address concerns with existing schemes.

 

4.0            National Petitions Submitted To Halt Any Further Floating Bus Stops and Shared Use Bus Boarders


NFBUK organised a petition backed by over 160 supporting organisations from across the UK. The petition is given in Appendix C requesting the following:

 

 

The petition has been submitted / handed to the:

 

 

Following NFBUKs petition being presented to the Mayor of London he has announced an inquiry into the safety of bus stops in active travel


schemes. However, the Mayor has not stopped any schemes that were in planning going forward with their discriminatory designs being part of the street transformations. It is feared this safety review will be a whitewash and the designs will be continued to be used.

 

5.0              Outcomes of Efforts To Raise Concerns on Discriminatory Design In Bus Stops In Active Travel Schemes

 

Nothing really has happened.

 

Floating bus stops and shared use bus boarders are still being used in active travel street transformations.

 

NFBUK’s concerns and evidence have been systematically ignored and the designs are now part of outdated national guidance issued by the Department of Transport in 2020 and 2022 (see Appendix D Urgent Need To Update Government Guidance), with schemes continually being designed, given planning permission and being constructed. This further excludes blind and visually impaired bus users from using bus stops in active travel schemes and putting others in danger if they try to use them on their own.

 

It is abhorrent that a design that discriminates against the safe and independent access needs of blind, visually impaired and disabled people to access a bus safely and independently is still being funded by the public purse and used in active travel schemes.

 

NFBUK also have grave concerns over the forthcoming results of the Living Streets Report into bus stop bypasses and do not believe the concerns raised about their use will be taken on board. There are also concerns that the Mayors safety review will also not address the concerns raised by our Petition.


6.0            Recommendations

 

The NFBUK would recommend the following:

 

Regulation is urgently needed to ensure access to catch a bus is direct from the pavement without having to cross or step directly into a cycle lane.

 

It would also recommend the following actions be undertaken as detailed in our petition mentioned in Section 4.

 


Appendices

 

Appendix A: NFBUK Evidence Submitted to The Transport Select Committee in 2019 Active Travel Inquiry

 

Appendix B: Islington Tribune Cycle Lane that pedestrians branded dangerous is axed. Published 4 March 2016 by Joe Cooper

 

Appendix C: Urgent Petition on Safety and Accessibility at Bus Stops in the UK Appendix D: Urgent Need To Update Government Guidance

Appendix E: References


Appendix A Previous Evidence Submitted to Transport Select Committee

 

The following extracts are from previous evidence submitted to the Transport Select Committee Inquiry on Active Travel from Section 5.

 

5.0            Bus Stop Bypasses and Copenhagen-Style Bus Stop Boarders

 

Both ‘bus stop bypasses’ and Copenhagen-style bus stop boarders (‘shared use’ bus stops) have been introduced into the UK, based on designs first used

in Denmark and Holland.

 

Bus stop bypasses are arrangements where the cycle lane runs behind the bus stop, leaving passengers on an island between the carriageway and the cycle lane. Department for Transport (DfT) and other bodies have claimed that cyclists should give way, for pedestrians. However, research commissioned on the concerns raised by Caroline Russell from the Greater London Assembly, from her observations that cyclists were not stopping for disabled peoplexxxiii, was undertaken by the Transport Research Laboratory (TRL) on behalf of Transport for London (TfL), illustrated that the great majority do not stop even with the addition of zebra crossingsxxxiv. The data showed that 60% of cyclists did not give way to pedestriansxxxv after zebra crossings were installed.

 

In Scotland, it is recognized that zebra crossings are not accessible to all disabled people. Scottish Government guidance is that they should not be used because they are not accessible to disabled people. However councils who are in receipt of UK Government City Deals or similar major infrastructure funding via the Scottish Government or its agents, are being discouraged from kerb separation from cycle tracks, or from providing signal crossings with conventional dropped kerbs in such schemes.

 

NFBUK were told at a public meeting, on 22 May 2019 that despite the Scottish Government's stance on zebra crossings, zebras are to be put in to help people cross the bus stop bypasses in a half mile long cycle track being built, without kerb separation, along the middle of the pavement on one side of Glasgow's Sauchiehall Street. Another example of concern to NFBUK is that Highlands and Islands Council have been told that they will not be eligible to apply for a further

£4.8m of funding to enhance a main shopping street (Academy Street) in the regional centre of Inverness, if that Council insists on keeping all the existing signal crossings with conventional dropped kerbs for pedestrians to cross that street as local people want." See: https://highland.public- i.tv/core/portal/webcast_interactive/419124.


Copenhagen-style bus stop boarders consist of an area of shared space (shared by pedestrians and cyclists) that require bus passengers to cross the cycle lane to board or alight from the bus (note that DfT Local Transport Note 1/11xxxvi confirms that areas shared by cyclists and pedestrians fall into the category of ‘shared space’).

 

Copenhagen-style bus stop boarders designs have been widely claimed to be safe, despite the fact that, evidence from Denmark has for many years revealed that these bus stop designs are unsafe, which are given below in Section 5.1.

 

Note that Copenhagen-style bus stop boarders arrangements are unsafe for all bus users and for cyclists; the public appear not to be aware of the presence of the cycle lane and the majority of cyclists are failing to give way to pedestrians. Copenhagen-style bus stop boarders designs will have a severe effect of the independently mobility of blind, partially sighted people, as they will actively avoid them as they simply cannot tell if there are cyclists present in the cycle lane.

 

Regarding Copenhagen-style bus stop boarders, it is important to recognise that:

 

 

Evidence is given below to highlight safety and accessibility concerns of both designs of bus stops and raise questions on research undertaken to allay these concerns.

 

5.1            Pedestrian and Cyclist Collisions and Near Misses Demark

 


 

 

 

Denmark has a long-standing culture of cycling and these crash figures are indicative of the problems created when two vulnerable road users are forced to share space. It should be remembered that while there is a higher number of collisions between pedestrians and motor vehicles, this is due to the higher base rate of motor vehicles and journeys.

5.2            Pedestrian Cyclist Collisions and Near Misses Enfield, UK

 

Evidence from Enfield on the problems experienced by bus passengers using Copenhagen-style bus stop boarders illustrates how frightening and

dangerous this type of bus stop is for bus passengers. These are just some of the experiences from people using the bus stop borders reported in a FOIxliii and from a residents group:


 

speed, nearly hitting me. As I tried to pull myself back towards the bus to avoid the cyclist, the bus door was shutting on my arm as I was still holding the rail. Fortunately, the bus driver realised what was happening and opened the door. The cyclist very nearly hit me. He was wearing headphones – I shouted ‘You’re going to kill someone’ but he didn’t even look back at me, let alone say sorry. I am not sure if he even heard

me.” Six days after this, the gentleman had another incident: “The same thing happened to me again on the 27 May, with a cyclist speeding by, and my arm getting trapped in the bus door as I tried to keep myself steady, and pull myself out of the cyclist's way. These incidents were very frightening and have made me very nervous when using bus boarders with cycle lanes.”

 

elderly? It's only a matter of time before someone is killed. It's a stupid design and nearly killed me tonight.”


 

 

 

 

 

 


5.3            TRL Report PPR854 Bus Stop Bypasses – Analysis of pedestrian and cyclist behaviour via video

 

The TRL Report into behaviour of pedestrians and cyclists at bus stop bypasses analysed the potential ‘levels’ of severity of interaction between cyclists and pedestrians by using 5 categories of level of interaction. Concerns are raised to the number of the 3 higher levels of interaction, which are classified as following:

 

 

The TRL report documented a decrease from 20 to 10 higher levels of interaction after zebra crossings were installed into the bus stop bypasses. The NFBUK is concerned that:

 

 

NFBUK undertook its own observational filming at bus stop bypasses to establish if more higher level interactions were taking place (details given in Section 5.4). The observations found:

 

 

Concerns have to be raised over the ability of the TRL report to capture the higher-level interactions occurring on a daily basis on the cycle lanes.

 

It has to be made clear that TRL report did state:

 


The NFBUK looked into how the TRL research was undertaken, as it could not understand how such low levels of higher-level interactions were not observed. It found that actual numbers of cyclists and pedestrians collected for the research amounted to:

 

 

This means that in rush hour periods – when people are in a hurry, there are more buses and far more passengers, as well as more cyclists - there is significant potential for many more of the higher level interactions to take place. The design of this research therefore failed to collect data at the times when higher-level interactions were likely to have been observed. The very low data sample is potentially missing many of the higher-level interactions between pedestrians and cyclists on a daily basis. It is difficult to understand why the research would have been undertaken in this manner.

 

Concerns are also raised on how Transport for London have interpreted the results of the TRL reports on the bus stop bypasses. Its conclusion that zebra crossings are the solution to resolve significant concerns over the accessibility and usability of bus stop bypasses being raised by disabled people is not safe. The use of TRL results, which are not significantly significant to justify this cause of action,xliv is simply not safe.

 

NFBUK also have great concerns on how the TRL research was undertaken with the accompanied visits to bus stop bypasses with disabled peoplexlv:

 


5.4            NFBUK Film Evidence of Pedestrian and Cyclists Interactions At Bus Stop Bypasses

 

5.4.1     Westminster Bridge Heading Southbound by St Thomas Hospital 24/09/18

 

NFBUK undertook it own filming on 24 September 2018 of pedestrian and cyclist’s interactions at the Bus Stop Bypass just South of the Westminster Bridge (southbound) opposite St Thomas Hospital. Filming took place during the afternoon rush hour. This bus stop bypass had a zebra crossing with belisha beacons. From 72 minutes of film from it was determined that there were in total 16 ‘high level interactions’, comprising:

 

-         5 very near misses

-         11 near misses

 

The NFBUK were alarmed at how chaotic, dangerous and intimidating the bus stop bypass environment is for pedestrians and for cyclists. It is clear the two vulnerable groups have very different uses of the space and both travel at very different speeds:

 

 

NFBUK took evidence from a partially sighted member who cannot access St Thomas hospital independently due to the introduction of the bus stop bypasses, the person in question now has to take hospital transport for her annual check up which meant that she has to wait all day at the hospital to get a lift home from hospital transport.

 

Screen shots of the filming are given below which illustrates some of the key problems identified at the bus stop:

 

Buses off loading directly into the cycle lane Up to 3 buses were witnessed trying to use the bus stop bypass at the same time. Passengers were expected to get on and off the third bus directly from the cycle lane. This is very dangerous as it puts cyclists and pedestrians in the same space, it creates a barrier for disabled people to access the bus in this location and creates a higher level of stress for bus passengers trying to find their bus in such a chaotic situation. It is very clear that the bus stop island cannot cope with the number of bus passengers needing to travel on public transport and it is over crowded.

The 2 screen grabs below from the filming illustrates this behavior.


 

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Pedestrians walking all over the cycle lane Pedestrians walking down the zebra crossing and not looking at the direction of the approaching cyclists but are going in the direction of the bus stop. Cyclists shouting at pedestrians they approach them, startling and shocking the pedestrians. The following 3 screen grabs illustrate this behaviour.


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The next 3 screen grabs further illustrate this point and illustrates how cyclists will try and not stop and weave through pedestrians to carry on their journey. This behaviour is shocking for the bus passengers who do not appear to realise that they are on a cycle lane as they are heading in the direction of the bus stop.



 


Cyclists not reducing speeds, cyclist weaving through pedestrians

Some cyclists pass through the bus stop bypasses at speed and they are clearly not going to give way and pedestrians having to step back to let them pass. The following 3 screen grab illustrates this point as the mans foot next to the zebra crossing is placed onto the zebra crossing and then pulled back with the approaching cyclist.

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5.4.2     Westminster Bridge Heading Southbound by St Thomas Hospital 23/05/19

 

Filming was undertaken 23 May 2019. 150 minutes were filmed at bus stop bypass for tourist’s bus tours, heading south over Westminster Bridge from 10.14am to 12.44pm, which was not in rush hour. There is no zebra crossing on this bus stop bypass. During this period, it was assessed there were:

 

 

Screen grabs from the photos illustrate some of these interactions and the chaos at the start of the bus stop by pass. It is a very confusing chaotic situation for tourists to find themselves in and it was clear very few knew that it was a cycle lane.

 

Tourist in near collision with cyclist The tourist had to stop and go backwards. The cyclist was telling her to watch out but he did stop to let her pass and swerved to the right.

Cyclist collides with pedestrian

 

 

 

 

 

 

 

 

 

 

Very near collision with tourist


The following 3 screen grabs illustrate 2 people trying to cross the cycle track, they do not look up the track for cyclists, and when cyclists approaches and rings bell, the two go in different ways. The cyclist’s wheels actually leave the ground due to emergency stop performed.

 

 


Chaos at the start of the bus stop bypass Following 2 screen grabs illustrates how confusing and chaotic the bus stop bypass environment is for pedestrians, bus passengers and cyclists. Tuk tuks are in the actual cycle lane on Westminster bridge waiting for customers, taxies are trying to drop off passengers into the cycle lane and people walking down the cycle lane.

 

 

Further filming was undertaken at the bus stop bypass mentioned in Section

5.4.1. The analysis of the data is still on going, however the following screen grabs from the filming clearly illustrate the same problems identified during the original filming.

 

Pedestrians still walking out into cycle lanes and very near collisions occurring with cyclists. Illustrated in the following 4 screen grabs.



 


 

Buses drivers off loading ad picking up passengers in the cycle lane with cyclists weaving in and out of pedestrians. Illustrated in the next 3 screen grabs.

 


 

 

Cyclists continually riding over pavements, tuk tuks using pavements, business and cyclists using pedestrian crossing. Illustrated in next 3 screen grabs.


 

 

Person being pushed over the cycle lane, with the person pushing looking in direction of bus stop and not in direction of cyclists. Bus passengers are standing on zebra crossing waiting for the bus to arrive.


5.4.3     Filming On Oxford Road, Bus Stop Bypass Manchester

Filming of a blind person trying to cross a bus stop bypass on Oxford Road in Manchester on 15 August 2018. Recorded 27 cyclists passing with just 2 stopping for the blind pedestrian in 14 minutes. The 3 screen grabs below illustrates cyclists going past the blind man with cane on the zebra crossing.

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5.5            NFBUK London Transport Representative on Bus Stop Bypasses

 

A number of questions have been asked by the Active Travel Committee on zebra crossings at bus stop by passes yet no blind people have been invited by the Committee to take part in the Inquiry sessions. The NFBUK London Transport Representative has the following comments regarding these bus stop arrangements and the research undertaken:

 

‘I took part in the Bus Stop Bypasses Working Group convened in 2016-17 by Transport for London, representing Transport for All and the NFBUK. I believe we held at least four meetings at which papers that included diagrams of crossings and features being considered were distributed to Working Group members. I received electronic copies of all this material. I was adequately able to read texts verbalised via my computer but I could not interpret anything diagrammatical. As this is appears to be standard, I found it necessary to ask for clarification on details and eventually resorted to taking sighted colleagues with me to meetings.

 

On one occasion my request for Tactile diagrams was acceded to when a simple diagram of a bus stop with a bypass was provided. I was able to confirm that the diagram verified my understanding of the layout of a typical bus stop with a bypass: I had by then visited the first trial stops installed at Stratford, East London. I did remark to my colleagues present at the meeting that I was surprised to realise that the place where buses were required to stop had the words "BUS STOP" painted there on the carriageway.

 

"At no time during the deliberations of the Working Group or since have I felt that bus stop bypasses are workable or justified. I am aware of the vulnerability of cyclists on the carriageway when passing buses and would like to have cycling prosper as a means of travel; but, in the creation of bus stop bypasses, the safety of cyclists has been gained at the expense of the comfort and safety of pedestrians who simply want to get on or off a bus. Lots of pedestrians know that they could be injured if they collide with a speeding cyclist so they give way to cyclists out of fear.

 

Who has the right to declare that cyclists have priority over pedestrians?

 

Crossing a bus stop bypass at a busy time may be a matter of luck for the fleet- footed or an inconvenient wait for the average bus passenger. Some people choose to avoid bus stops with bypasses altogether. That is part of the price that pedestrians pay for the freedom of cyclists to speed unhindered on their way. Bus stop bypasses should be halted and alternative designs and solutions


should be trialled to resolve this problem.

 

All bus passengers should be able to get on and off the bus without having to first negotiate with cyclists to access public transport.

 

The bus stop bypasses cannot be reconfigured to be functional and safe for all. At present in London there are simply not enough transport corridors to cross geographical features like the Thames or railways. More bridges across these barriers must be contemplated to give more and better options for new cycle routes to open up.

 

5.6            Difficulties Encountered by a Visually Impaired Traveller Since the Introduction of the Cycle Super Highway

 

This is a personal experience from a blind member of the NFBUK, whose life has been severely impacted by the introduction of the cycle super highway and bus stop bypasses.

 

‘I will try to outline my experience as a totally blind pedestrian and user of public transport in central London, particularly at bus-stops where the 2-way cycling super highway has been introduced. There aren't many other visually impaired travellers living in this locality, but, presumably, such people elsewhere will be subjected to similar experiences too as the bike lanes become the norm in other areas. Along with many other totally blind, registered blind and partially sighted pedestrians, I am registering my utter dismay at the development of ‘bus stop bypasses’, that is, cycle lanes which run between pavements and bus stops.

I live very near to the Blackfriars road and have experienced serious limitations to my daily travel, due to the creation of a cycle superhighway, the 2 way cycle lane which runs the length of the Blackfriars Road. Since the cycle lane was built, I have not been able to use any of the affected bus stops (bus stops that have been converted to ‘bus stop bypasses’) without assistance. This means that I can’t access any north-bound busses that cross Blackfriars Bridge. The bike lane, which is very busy during rush hour, becomes under used in off peak times. When walking between the junction with Stamford Street and Southwark tube on one occasion, using my long cane, I realized that I was veering into the cycle lane, due to the uneven pavement and the apology for some sort of inadequate tactile indication to mark the difference between the pavement and the cycle lane.

 

Very occasionally, I have tried to use the bus-stops, having to seek help from the general public, and have experienced a situation of being isolated on a long strip


of paved area in the middle of the road, with cyclists whizzing past behind, and traffic crawling along, nose to tail, ahead of me.

 

Normal bus-stops aren’t particularly accessible for visually impaired people anyway, as assistance has to be sought from fully sighted members of the public to verify bus numbers etc. However, the island bus-stops cut the blind person off from the public walking past on the pavement, plus the busses have to line up behind each other on the island. This also causes problems while alighting from the bus, as it’s impossible to tell which way to turn to find the crossing point, which isn’t very safe once discovered. I once did this with a friend with full sight, and as the bike-lane was empty, she just jay-walked casually across which any pedestrian with sight would do in the circumstances.

 

I once had to wait for a bus on a rainy Sunday morning. The bus ahead of it stopped while the bus behind it, which I needed, slipped past. A member of the public getting off the stopping bus kindly waited for another 13 minutes to enable me to catch the bus I needed. I was then late for my appointment.

 

If a blind person were to attempt crossing to an island bus-stop, in order to do this, they would have to listen out for quiet bicycles going parallel to the traffic which renders them inaudible. The stop nearest Southwark underground, (near to TFL headquarters) is clearly defined with a pedestrian crossing, but, due to background noise caused by the echo from the railway bridge plus passing trains, this situation is made far worse.

 

The newly designed Elephant and Castle has also had a serious impact on my travelling arrangements. In the daytime, I used to be able to cross 3 large roads by making use of the underpasses which have now been filled in. The changes to the pedestrian crossings there to accommodate cyclists, plus the bike lanes in the middle of pavements, have completely restricted my independence in the area.

 

All these developments have forced me to seek completely different routes to most destinations that I have to reach locally, and I don’t believe that many officials concerned with issues regarding traffic planning have any idea how much impact this has had on my life and that of other blind people. To add to all this, various bus routes are now going to be restricted, altered or stopped altogether, which will further complicate travelling arrangements.

 

I have met various TFL staff to discuss these issues, representatives of the cycling lobby and local spokespeople. When Valerie Shorecross was deputy mayor, I tried to register my concerns with her at a couple of public meetings, her


understanding of access related to the step free environment rather than registering that barriers are being created for visually impaired pedestrians. (I'm not sure whether island bus-stops are hazard free for wheelchair users either.)

 

My disappointment stems from the fact that I would like to support cyclists as I am an environmentalist myself, and realize they are literally making an effort on a daily basis to make our air less polluted. I feel, however, that the present design of the cycle super highway creates pollution instead of diminishing it, not least for the cyclists themselves, as the 2 lanes of traffic on the other side of the road are often reduced to a walking pace. Cyclists, as well as using the bike lanes, can also have the option of using any road they choose.

 

While I know many responsible cyclists, I am often assailed by irresponsible ones not stopping while I wait to cross a pedestrian crossing or at a red light, and sometimes even on pavements. I have the impression that cyclists also make use of other transport modes such as busses, cars, taxis etc, particularly in bad weather conditions and certainly wouldn’t take kindly to being prevented from making use of their preferred transport options.

 

My personal view is that the cycle super highway was introduced with no regard to visually impaired people, and little regard to many other disabled people. I hope that my comments will, at least, be taken on board re your consultation, and I hope that some of the issues I have outlined can be overcome in some way’.

 

5.7            Legal Action Against Bus Stop Bypasses In Canada

 

Legal action is currently being taken in Canada by the Canadian Federation of the Blind (CFB) on the use of bus stop bypasses due to the inaccessibility of these designs for blind and partially sighted peoplexlvii xlviii.

5.8            NFBUK Recommendations for Bus Stop Bypasses and Copenhagen-style bus stop boarders

 

It is clear that these designs are not fit for purpose for the bus passenger or the cyclist and it has created a dangerous barrier to access public transport for blind, partially sighted, disabled and vulnerable pedestrians. In the light of this, NFBUK are requesting bus stop bypasses and Copenhagen-style bus stop boarders are halted, with immediate effect and new design solutions trialled to resolve the issue of cyclists navigating bus stops. NFBUK recommends that:

 


Existing ones removed with out delay. There is precedent, with one being removed in Islington in 2016, as concerns for blind and partially sighted passengers, as well as other vulnerable passengers had not been consideredxlix.


Appendix B Islington Tribune: Cycle lane that pedestrians branded dangerous is axed. Published 4 March 2016 by Joe Cooper

 

Text of article given below in screen grab (link is no longer active http://archive.islingtontribune.com/cyclelaneaxed). The Independent London

 

 

Newspaper Islington Tribune              Picture of

Olav Ernstzen and Elizabeth Jones at the cycle lane that’s to be removed (given in the screen grab of the article below)

 

THE Town Hall has agreed to remove a raised cycle lane between the pavement and the road which has been branded “terrifying” by visually impaired people. The lane has been raised to the level of the pavement so cyclists are not impeded by buses stopping. But Tufnell Park barrister Olav Ernstzen points out that it puts vulnerable pedestrians in danger by forcing them to step into the cycle lane. Cyclists racing home along New North Road pass inches from people stepping off buses at the stop at Elizabeth Avenue, Canonbury.

 

“It’s wrong in so many ways,” said Mr Ernstzen, who is chairman of Healthwatch Islington. “On a common-sense level or from an equality impact assessment perspective this fails.” Mr Ernstzen said bus travel was vital for the independence of disabled people in the borough. “It’s also a worry for parents with a baby in a buggy, wheelchair or mobility scooter users and people just coming home with shopping,” he added. “Cyclists have the choice of putting pedestrians at risk or, if they choose to go outside the bus where they now have less room, putting themselves at risk.” The cycle lane is on the way to Moorfields Eye Hospital.

 

Elizabeth Jones, who set up Talking News Islington, said: “When I step off the bus I put my stick first. If that got caught in a cyclist’s wheel there could be a


pile-up.” The council has agreed to remove the raised lane after admitting to Mr Ernstzen that it had not followed its own equalities policy. Transport chief Councillor Claudia Webbe said: “Our designs here could have been better as it is clear that Mr Ernstzen’s needs were not considered. “The council has listened to the concerns and I have requested the removal of this ‘shared space’ and a better solution for cycle safety that does not disadvantage bus passengers, particularly those who are disabled.” Mr Ernstzen and Ms Jones are working with the Thomas Pocklington Trust to try to establish a support and advocacy group for people with sight loss in Islington. Most other London boroughs have their own dedicated groups.

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Olav Emstzen and Elizabeth Jones at the cycle lane that's to be removed

 

Published: 4 March, 1016 by JOE COOPER


ubTishw: 4 Mim;h, l0Hi by JOE COOPER

 

l"HE. Town H.111I l bus auccd lo rcrmv,c a rahed cycle hmc bclwcoo the pncmcflt and the road which ha

been br:in ''lterrifyiBj;;"by vima.lly i rnpo,ir;:4 p«iple.

 

The l..!ne has btein raised m lhe lcvcl of the pavemem oo cyclis1:s: aJC noc impeded by buses nt1pplng,

 

But T\lfuell Parlt bll1Ti:st(:!'Oleav Em tz:cn point, out !Ml ii p11 vulnerable p,ll trfa11;5 in ,bnguby fon;ing

!hem 10 tep into 1hc cycle lane.

 

Cycli ts racins; home along New NorttJ Road pass inchc.s from pcc !c m:pplns; off' bus.::s al the stop 31

Efu.lil>etll "'C□l!-'1'., Car110abury,

 

'"h's w'°"J!: la ,so mllny wwys ." said Mr EmS!Z<:n, who ii drairman or Heu.hhwa1.ch ]:lliOr,!ll<>n.

 

"Oa a commo□-S¢nsc te,·el or from a,11 squarlity i111pac1 as5essmen1 pc pe.;tivc thi5 falls:'

 

Mr Emstz.cn s11id bu 1rnvel was vital fut- the i:mdcpe:mdence al' disabled people in die borol!IJlh,

 

'"It's also a worry for p;'!rl!:llts with a b:tby in a buggy, cheair ormobility scoote:r users and people just eoming llome wilh slloppiDg," he il.dd.ed. "CyclJ ts have tbe coolce of p1ming pedesm:ins a1 ri k or, if lhcy t:boosc 10 o ouisidc !he bus where 1hey now !rave lcsi: room, pulling iliolll!li:lvecs at risk."

 

The cycle lane is on Ille way to Moo:melcts Eye Hospital.

 

Eli:z.i.beth Jones, who set np Tnlking  cws lsllngtu□•swd; '"Wilen I step off the bus I put my slick firsl. JI'

lh:al gm caught in 9 eycllsl's wheel lhi= CQuld be a pile-up."

 

Tue c011ru:il h  ayccd to remove me raised !aJIC after admitting to Mr Ernstzen Iha, it h d 001 follo,wcd Lt

own "'luufaies policy.

 

Tr:!.llsport crud CouDcillor Cla dfa Webbe nid: ''Ollr desi.sf,s here coold ha,ve beea beuer as ii is ci.ev thit

fr Etru;tw1',s .needs ""lffl: llOt considered.

 

''The council ha listi,ncd m the conm.-ms and I h,r1,1i, requru.too the r,,mo,vru of this •,hared .,pare' and a tiener :solutjo rm cycle sarety lll:11 doc met disad,.:mlllge bw p:usenge;rs, Pffl'l.LOUl:uly!hose wno 111e di$a.bloo:•

 


fr F.m.:i;tzm 1111d M Jones arc w in,s with th Thom,.. l'c)cltlingtm, 'I'rusl to iry tg c,tarblish 11. S11p n. and voc:ii;;:,- gro11p fo:r people wilh sight lo i lsliagton. Mosl ,olher London borooghs h!!Ne dleir own dedicaled groups.


 

 

opyrigbt C e-w Journal FAJ.te·r_p:rises Ltd, 201!1, AI.I

Rl!l,h.ts R.eservedl. 11.e by              ,MeH              1 !iJ!li H ted

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Appendix C Urgent Petition on Safety and Accessibility at Bus Stops In The UK

 

Rt Hon Rishi

Sunak The Prime Minister Number 10 Downing Street

London, SW1A 2AA

 

11 January 2023

Dear Prime Minister Rt Hon Rishi Sunak

 

Urgent Petition on Safety and Accessibility at Bus Stops In The UK

 

The National Federation of the Blind of the UK (NFBUK) are still extremely worried about the safety and accessibility of bus stops in the UK and we are handing this petition in against the use of floating bus stops and Copenhagen style bus stops in active travel schemes across the UK. This petition was handed into Number 10, along with a copy for the next Prime Minister and one addressed to you personally on the 18 October 2022 for International White Cane Safety Day, however nothing has happened and we urgently need action on this petition please. It is backed by over 160 supporting organisations from across the UK and we would welcome your Governments urgent action on this petition please. So blind, visually impaired, older, disabled and vulnerable bus passengers can access the bus directly from the pavement as they have always done.

 

The NFBUK strongly believe blind, visually impaired, older, disabled and vulnerable bus passengers should not have to cross cycle lanes or step into a cycle lane to get on and off a bus. Active travel schemes have and are being introduced across the UK to accommodate cycle lanes, with many schemes include changes to existing bus stops, where they become separated from the pavement by cycle lanes, which become sandwiched in-between the pavement and the bus stop. There are two designs:

 

 

Both are not safe or accessible for blind, visually impaired, older and many vulnerable groups of bus passengers and they create a barrier to accessing public transport independently. The NFBUK has provided significant evidence to


why these types of bus stops should not be used to the Department for Transport however this has been ignored.

 

In Canada the Canadian Federation of the Blind (CFB) won a human rights tribunal against the floating bus stop designli. In Denmark the injuries to bus passengers caused by cyclists went up from 5 to 73 after the Copenhagen style bus stop design was introducedlii and in 2016 a Copenhagen style bus stop was removed in Islington in London as it did not take into account the safety and accessibility needs of blind and visually impaired bus passengers, as explained in Appendix A.

 

There is also a rapidly changing way people are now using e-bikes, e-scooters and other e-devices to get around. Many e-devices are already too fast for the bus stop cycle infrastructure and many are modified to go even faster. Expecting people who cannot see, who cannot move very fast or who are using mobility aids to step on and into a cycle lane with speeding cyclists and people using e- devices is simply not safe. No blind, deaf blind visually impaired, disabled, older person and vulnerable bus passengers should be expected to do as it puts there lives in danger. All buses should be allowed to pull up directly to the pavement and all bus passengers have the right to be able to stand on a pavement to get on and off a bus.

 

The NFBUKs petition, backed by over 160 supporting organisations (list given below) is therefore calling for the following from your Government:

 

is protected.


The NFBUK believe that different designs can be used to ensure the safety of cyclists and allow direct access to and from the bus for all bus passengers. We are aware that blind people are not able to simply catch a bus now due to the cycle lanes and we cannot accept designs that actively discriminate against independent access to public transport. This design does not work for many other bus passengers too and it is essential that access to public transport is made safe and accessible for all.

 

We would also appreciate an urgent meeting with you and the Secretary of State for Transport so we explain our concerns and to show our film ‘What is happening to the safety and accessibility of our Great British Bus Stops? In the meantime we hope the Government acts on the concerns raised in this petition with a matter of urgency.

Kindest regards Andrew Hodgson,

President, National Federation of the Blind of the UK

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Photo 1 Example of Floating Bus Stop, Whitechapel in London


This shows a cycle lane running behind of the floating bus stop at Whitechapel in London. There is a zebra crossing present, however, there is a lady in red who is jumping back because the cycle rider is riding directly at her at speed. This design is not safe or accessible and should not be in use in the UK.


 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Photo 2 Example of Copenhagen Style Bus Stop


Sarah Leadbetter and her Guide Dog Nellie are seen standing in the middle of a cycle lane in Birmingham on a zebra crossing at the bus stop. There is not a bus pulled in at the time of the photo. It is very dangerous to get on the bus by standing in a cycle lane and also getting of the bus directly into a cycle lane. This design is simply not safe or accessible and should not be in use in the UK.

A person walking a dog on a sidewalk Description automatically generated with medium confidence

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Supporting organisations for the petition:


1: East Dunbartonshire Visually Impaired Peoples Forum, Scotland 2: Pocklington Lodge Tenants’ Association, London

3: Eastbourne Access Group 4: Blind Aid, London

5: Defiant Sports CIC, Defiant Sports Inclusion Hub, Eastbourne 6: Sandwell Visually Impaired

7: Eastbourne Blind Society

8: National Pensioners Convention

9: Tamworth and Lichfield Brain Injury Support Group 10: Newcastle Vision Support

11: Henshaws, Manchester

12: Bournemouth Blind Society 13:Lincoln & Lindsey Blind Society

14:Leeds Society for Deaf and Blind People 15: Buckinghamshire Disability Service

16: Dorset Blind Association

17: Open Wings Adult Learning, Nottingham 18: Independent Disability Council Leeds

19: Children Living with Autism Parent Advocacy Network 20: The Access Committee for Leeds

21: Action on Disability London

22: Hackney Disability BackUp, London 23: Insight Gloucestershire

24: Hearing Loss Cornwall 25: Age UK Sunderland 26: Visibility Scotland

27: Merlin MS Centre, Nr St. Austell 28: Sightseekers, Chorley

29: Action Disability Kensington and Chelsea (ADKC)

30: National Association of Disabled Staff Networks (NADSN) 31: Sight Action, Inverness, Scotland

32: 4 Sight Vision Sight, West Sussex 33: Sheffield Royal Society for the Blind 34: Age UK Gateshead

35: MyVision Oxfordshire 36: Age UK Gloucestershire

37: Age UK Hammersmith and Fulham, London 38: OneChiswick, London

39: Deafblind Scotland

40: Sight Support Derbyshire 41: My Sight Nottinghamshire

42: Angus Talking Newspaper Association


43: The Scottish Centre for Personal Safety 44: Blind in Business

45: Southampton Sight

46: Community Broadcasting Services (Coventry) 47: Southwark Irish Pensioners Project

48: Disability Equality Scotland 49: Merton Vision, London

50: Bridgend Visually Impaired Society 51: East Sussex Vision Support

52: Kingston Association for the Blind, London 53: The Partially Sighted Society

54: Barnsley Blind and Partially Sighted Association 55: Coventry Resource Centre for the Blind

56: Visually Impaired in Camden, London 57: Ruils-Independent Living, London

58: Sight Scotland and Sight Scotland Veterans 59: Bucks Vision

60: Disabled Staff Network DSN University of Nottingham 61: Disability Advice Service Lambeth (DASL)

62: Visually Impaired Society of Richmond (VISOR) London 63: Chronic Illness Inclusion

64: Forth Valley Sensory Centre, Scotland 65: Visual Impairment Merthyr Tydfil, Wales 66: Deafblind Enablement

67: Essex Blind Charity

68: West London Residents Association 69: Nystagmus Network

70: Blind in Greenwich, London 71: Bromley Experts by Experience

72: Merton Centre for Independent Living, London

73: Lambeth Pensioners Action Group (LAMPAG), London 74: Gloucestershire Deaf Association

75: Blind in Greenwich

76: Spinal Injuries Scotland 77: Beyond Sight Loss, London

78: Western Enfield Residents Association, London 79: Devon in Sight

80: Wales Council of the Blind

81: London Sports Club for the Blind

82: Bedfordshire NARPO Branch National Association of Retired Police Officers 83: Yorkshire Coast Sight Support

84: Staffordshire Sight Loss Association


85: Fight for Sight

86: Disability Rights UK 87: Inclusion London

88: Bristol and District Blind Bowls Club

89: Outlookers - The Local Sight Loss Charity 90: Wakefield District Sight Aid

91: European Guide Dogs Federation

92: Bradbury Fields - A division of Catholic Blind Institute, Liverpool 93: Chesham Visually Impaired Bowling Club

94: Cornwall Branch NARPO National Association of Retired Police Officers 95: Waltham Forest Blind Association

96: Cam Sight Cambridge

97: East Cheshire Eye Society 98: Glasgow Disability Alliance 99: Warwickshire Vision Support 100: Braille Chess Association

101: North East Sensory Services, Scotland 102: Vision Support Harrogate District 103: Halifax Society for the Blind

104: Croydon Vision

105: Hornsey Pensioners Action Group 106: Wales Council for Deaf People 107: Association of British Commuters 108: Sutton Seniors Forum

109: N-Vision, Blackpool, Flyde & Wyre Society for the Blind 110: Vision PK, Scotland

111: Vision Norfolk

112: Visionary

113: Blind and Sight Impaired Society (BASIS) 114: Deafblind UK

115: Kent Association for the Blind 116: Moorvision Devon and Cornwall 117: Age UK London

118: Esme’s Umbrella

119: Open Sight, EastLeigh, Hampshire 120: Thomas Pocklington Trust

121: Enfield Vision, London 122: Southend in Sight

123: Vision Support Barrow & District 124: Goalball UK

125: Sight Support Worthing 126: AGE CONCERN BANSTEAD


127: Age UK Barnet

128: Galloways Society for the Blind 129: Retina UK

130: Sight Concern Worcestershire 131: Sight Loss Shropshire

132: Age UK Bexley 133: Focus Birmingham

134: Vision North Somerset

135: Walsall Society for the Blind 136: Torch Trust

137: Blackburn and District Blind Society

138: Borders Older People's Forum, Scotland 139: Tonbridge & Malling Seniors Forum

140: UK Keratoconus Self-Help and Support Association 141: Bristol Older people’s Forum

142: Bardet-Biedl Syndrome UK

143: Hastings and St Leonards Seniors’ Forum 144: Redditch Older Peoples Forum

145: Macular Society

146: Age UK Coventry & Warwickshire 147: Age UK Manchester

148: Age UK Bristol

149: Age Concern Eastleigh 150: Sutton Vision

151: Galloways Society for the Blind 152: Age UK Leicester Shire & Rutland 153: VICTA

154: National Federation of the Blind of the UK Leeds Branch 155: Sight Action Havering

156: Sight Support Hull & East Yorkshire 157: Vision Support, Chester

158: Hereford Vision Links 159: Sight for Surrey

160: Centre for Disability Studies, University of Leeds 161: CVI The Cerebral Visual Impairment Society 162: Whitefield Blind Aid Committee

163: South London Resource Centre. For Visually Impaired People.

 

Appendix A Islington Tribune Article Cycle lane that pedestrians branded dangerous is axed. ( Already Given in Appendix B above)

Appendix D Urgent Need To Update Government Guidance


National Federation of the Blind of the UK (NFBUK) is concerned that current UK government guidance to local authorities on the design of streets is unclear and out of date.

 

The latest versions of government guidance which covers the design or redesign of streets are the: 2020 (LTN1/20) design of new cycle infrastructure, the 2022 reissue of the 1998 Use of Tactile Paving (TP) guidance, and the 2022 reissue of the 2004 Inclusive Mobility (IM) guidance.

 

As a result of the failure to update and reshape guidance with new knowledge about physical access needs, the safety particularly of blind or visually impaired people and other disabled people of all ages going forward, has been put at serious risk.

 

Local Authority awareness of DDA built environment reasonable adjustment duties

 

In April 2021, NFBUK submitted, in writing, a range of matters which in the experience of its blind and visually impaired members, required urgent updating, at Department of Transport public consultation workshops about street design. One issue raised concerned poor awareness by councils across the UK about DDA duties.

 

Changes to drafts put forward for workshop participants to discuss were put forward by the Federation and endorsed by representatives of the Guide Dogs and RNIB service charities, but little notice was taken of the inputs made. The High Court on 17th March 2023, in response to a judicial review claim (CO/1583/2022), has declared that the way that the public consultation was carried out by the Secretary of State on that occasion was unlawful.

 

The reasonable adjustment duties applying to street design and other statutory activity by local authorities and other public bodies, first came into law in 2005, under the Disability Discrimination (Amendment) Act 2005 which brought the DDA into primary legislation.

 

In part, lack of awareness of this change may have arisen because, soon afterwards, the 2010 Equality Act not only carried forward the DDA, but extended legal protections to many other groups in local communities. However, the new duties on local highway authorities from 2005 are not noted in the 2020 LTN1/20 document, or in the 2022 refresh versions of the Tactile Paving and Inclusive Mobility guidance documents.


Moreover, the guidance given to local councils in the re-issued 2022 DfT guidance documents is almost suggesting that adjustment duties may be optional rather than obligatory. In the 2022 Inclusive Mobility (IM) document, under 1.4 this advice is given:

 

“The guidance will also be of interest to those looking to make reasonable adjustments in response to requirements set out in Section 20 of the Act.”

 

Safety risk

 

The Health and Safety Executive HSE commissioned research into use of tactile paving, published as long ago as 2005 (Tactile Paving Survey Report, HSL 2005/07). The research concluded that the “DDA will result in increasing use of tactile paving”.

 

The 2005 research also found that “merely giving guidance on good practice appears to be insufficient and is unenforceable”.

 

There is no mention of the safety risk from using tactile paving incorrectly, or the failure to explain reasonable adjustment duties, in the 2022 re-issued guidance documents.

 

People who cannot feel tactile paving through the soles of their feet

 

The 1998 TP guidance document cautioned designers to note that many people with Diabetes 2, which often leads to visual impairment in a person who cannot then feel tactile paving or differentiate tactile surfaces.

 

Since then the number of cases of Type 2 diabetes in the UK has increased so much that Diabetes UK estimate it affects 4.3 million people (diagnosed) and 850,000 (undiagnosed), with 90% of whom are believed to have type 2 Diabetes. Number of people living with diabetes in the UK tops 5 million for the first time.

 

However there is no advice to switch designs away from tactile warnings of space shared with motorists or cyclists, and towards navigation for all being reliant on kerbing which is dropped at the recommended 100M intervals in the IM document, in either of the 2022 re-issued guidance documents,

 

Physical Separation from motor traffic or cyclists


Government policy on whether pedestrians should share space with motorists or cyclists has moved on since the Women and Equalities Select Committee examined this, and recommended (in Report HC 631, published in 2017) that the practice should end.

 

This is not reflected in the 2022 refresh of the 1998 TP document and the 2004 IM document guidance.

 

Both documents continue to suggest that a white line raised by 25mm (which, it is now known, that trained assistance dogs used by blind people cannot follow) is an effective delineator where ever a cycle track is proposed to be marked onto a pavement.

 

In addition, both documents continue to suggest that a low kerb 25mm high (which research carried out in 2009 by University College London (UCL) specialist PAMELA laboratory found was too low to be detectable by all long cane using blind or visually impaired people relying on a long cane for safe navigation) can be used instead of full height kerb. A minimum height of at least 60mm height kerbs was determined that all white cane users and Guide Dogs would recogniseliii.

 

There is no reference in either document to the pauses to further shared space designs instructed by UK government in England; or to the link to the HC 631 Report which has been introduced into the NPPF national planning framework practice guidance for England.

 

Conflict between nation guidance

 

In answer to the question “How can places be designed to be age-friendly and accessible for all?”, the NPPF “beta” Planning Practice Guidance says, “The inclusive and age-friendly design of public spaces such as town centres, and of individual buildings, including housing, has clear benefits.” (Paragraph: 018 Reference ID: 63-018-20190626 Revision date: 26 June 2019).

 

Neither of the 2022 refreshed guidance documents makes it clear that the half- kerb “stepped cycle track” arrangement which the Department of Transport has advocated in its own LTN 1/20 cycle infrastructure guidance issued in July 2020, should now be the default design, throughout the UK. Had the guidance taken this on board, the recommendation would have been to separate a pavement from a contiguous cycle track, and that the half-height kerbing recommended should have the dropped kerb crossings at least every 100M for wheeled pedestrian traffic advocated in the 2004 and 2022 IM guidance.


Instead the two refreshed documents state, without any evidence, that

a ”trapezoidal” block, or any other raised strip, are options which can safely be used to separate pedestrians from cycle traffic. Under 5.1, the TP document states:

 

“A kerb at least 50mm high or a strip of light coloured material that can be detected with a cane is likely to be more effective at helping visually impaired people to detect and negotiate the track. This could be achieved by using an alternative raised strip which is trapezoidal in cross section, or some other textured material”.

 

When local authorities are confused about widely recognised barriers or the actual conflicts that blind or disabled people have faced, blind or visually impaired people, in particular, will exclude themselves from situations where they cannot safely make independent use of streets, bus stops and other transport facilities.

 

None of the three street design documents listed clearly points out that this kind of exclusion is defined as discrimination under current primary legislation (the Disability Discrimination Act as amended in 2005, and the Equality Act 2010 which reincorporated the Disability Discrimination Act as amended), and is therefore unlawful under UK law.

 

Guidance on floating bus stops (bus stop by-passes)

 

A new feature introduced without public consultation or explanation into the LTN1/20 guidance, is the so-called “floating bus stop”, or bus stop bypass for cyclists. Floating bus stops are where the bus stop boarding point has been floated off from pavements by a cycle lane. The same bus stop bypass diagram has been inserted into the “CD 195 Designing for Cycle Traffic” specification for trunk roads and motorways in England, Scotland, Wales, and Northern Ireland.

 

However bus stop bypasses have recently been investigated by a national newspaper (The Sunday Telegraph, 19 March 2023 online version published 18 March 2019) which counted fewer than one in ten of cyclists at sites in London stopping to give way when confronted by bus passengers getting on or off bus stops.

 

The newspaper investigation claims that the evidence that this is what would happen (ie.g. TRL Report for Transport for London PPR 855 July 2018), was known to the Mayor of London, in advance of the Mayor’s decision to install some 50 of these floating bus stops in Greater London.


Previous Transport for London design guidance (London Cycling Design Standards (LCDS)) which was published in 2014 followed widespread public consultation. This local guidance recommended (at 4.3.8) that designs should be balanced against Equality Act access for all requirements. The principle stated in that local guidance should be that at bus stops, cyclists on a street cycle track would stop behind a waiting bus unless it was safe to overtake it. However this guidance principle was subsequently dropped by Transport for London.

 

Climate change and internationally developed regulations

 

Putting obstacles in the way of people safely using public transport has to be especially concerning, as the UK is a signatory to the international Paris Climate Change Agreement.

 

As a result, the UK Transport Decarbonisation Plan notes there has to be a shift from use of private cars to other modes including walking and public transport, and to modes like e-bikes to overcome local topography and bus service deficiencies for shorter trips and to silent running e-vehicles for longer trips.

 

A further difficulty for blind or visually impaired people is that the “bonfire” dumping of safety regulations may include those worked out by EU and Japan to ensure that newly manufactured e-vehicles, which are almost silent at low speeds, give out a warning sound of their approach.

 

Other UK Regulations made in response to an EU directive, in jeopardy of repeal, include guidance issued to councils and other public bodies across the UK about how public sector websites should be inclusively formatted for the screen reader software used by blind and visually impaired people.

 

There is no mention in the 2020 TN1/20 guidance, or in the 2022 TP or IM guidance, of regulations protecting blind or disabled people’s access to transport; to the climate change imperative for many more people to walk or propel themselves in wheelchairs or with walking frames on shorter journeys; for more signal crossings to be included in street designs; or for bus stop and other transport hub infrastructure to be expanded and made more hospitable - not less accessible - to people who are blind or disabled.


Appendix E References


 


i https://www.leicestermercury.co.uk/news/local-news/blind-leicestershire-


woman-calls-new-7744285

ii https://theedinburghreporter.co.uk/2022/12/leith-walk-is-no-go-area-for- blind-pedestrians/

iii https://www.bbc.co.uk/news/uk-scotland-64464404

iv https://www.nfbuk.org/do-blind-people-have-a-future-in-glasgow-in- scotland-and-in-the-uk-or-will-climate-change-adaptations-design-them-out- of-town/

v https://glasgowguardian.co.uk/2017/11/24/shared-space-plan-for-glasgow- streets-criticised/

vi https://roadsafetygb.org.uk/news/glasgow-sauchiehall-street-revamp- slammed-by-blind-charity/

vii https://www.glasgowlive.co.uk/news/glasgows-blind-playing-russian- roulette-25336907

viii https://www.bbc.co.uk/news/uk-scotland-glasgow-west-60431429

ix https://squidex.mkmapps.com/api/assets/ipm/shared-to-inclusive-space- article.pdf

x https://londonnewsonline.co.uk/blind-londoners-in-danger-over-floating- bus-stops/

xi Jensen, S U, Rosenkilde, C, Jensen, N (2010) Road safety and perceived risk of cycle facilities in Copenhagen. https://nacto.org/wp- content/uploads/2010/08/Cycle_Tracks_Copenhagen.pdf; and Jensen, S U, (2007) Bicycle Tracks and Lanes: a Before-After Study https://pdfs.semanticscholar.org/604f/424a94e4886c54ce20f0b1d6d39b44f715 60.pdf?_ga=2.12322804.1927912829.1549794606-976542883.1549794606

xii Hauschildt, L S (2014) New campaign to avoid chaos at Danish bus stops http://www.cycling-embassy.dk/2014/08/18/new-campaign-to-avoid-chaos-at- bus-stops/

xiii https://politiken.dk/forbrugogliv/forbrug/dintransport/art5527002/Kaos-ved- busstoppesteder-Passagerer-bliver-torpederet-af-cyklister

xivhttps://politiken.dk/forbrugogliv/forbrug/dintransport/art5603134/Vigepligt-

ved-stoppesteder-forvirrer-både-cyklister-og-buspassagerer

xvhttps://politiken.dk/forbrugogliv/forbrug/dintransport/art5527099/Emma-

blev-kørt-ned-af-cyklist-

xvi https://jv.dk/esbjerg/politi-soeger-vred-cyklist

xvii https://www.berlingske.dk/samfund/teenagedreng-paa-elloebehjul- paakoerer-pige-i-nordjylland

xviiihttps://m.facebook.com/story.php?story_fbid=pfbid02ASW8bNiJLpjJbmV7t

5gxeBGLm4xHb3E598cegAhBpqQEY7sgHYacjrPJBt394WRil&id=549528832


xix https://www.tvsyd.dk/soenderborg/helicopter-hentede-kvindelig- fodgaenger-efter-uplyke-med-el-cykel

xx https://aarhus.lokalavisen.dk/112/ECE14715649/politirapporten-cyklist- vaeltede-efter-sammenstoed-med-buspassager/

xxi https://www.sonderborgnyt.dk/se-dig-for-naar-du-staar-ud-af-bussen/ xxii https://via.ritzau.dk/pressemeddelelse/kaos-ved-busstoppestederne- danskerne-ved-ikke-hvem-der-har- vigepligt?publisherId=9709319&releaseId=13650463

xxiii Hauschildt, L S (2014) New campaign to avoid chaos at Danish bus stops http://www.cycling-embassy.dk/2014/08/18/new-campaign-to-avoid-chaos-at- bus-stops/

xxiv https://politiken.dk/forbrugogliv/forbrug/dintransport/art5527002/Kaos-ved- busstoppesteder-Passagerer-bliver-torpederet-af-cyklister

xxv https://via.ritzau.dk/pressemeddelelse/hver-tredje-ved-ikke-hvem-der-har- vigepligt-ved-busstoppestedet?publisherId=9709319&releaseId=9892882

xxvi https://www.tv2kosmopol.dk/kobenhavn/chauffor-om-bus-kaos- passagerer-og-kollegaer-pakort-flere-gange

xxvii https://www.dr.dk/nyheder/regionale/bornholm/fjernbusser-i-opraab- passagerer-risikerer-blive-koert-ned-og-cyklister

xxviii https://www.nzherald.co.nz/nz/cctv-footage-shows-horrifying-moment- bus-passenger-hit-by-lime-scooter/DI65ZPWWYT3UNZ4DRBG5R5I7BQ/

xxix https://www.cbc.ca/news/canada/british-columbia/bc-floating-bus-stops- human-rights-tribunal-1.5811152

xxx https://www.timescolonist.com/local-news/updated-guidelines-for-floating- bus-stops-fall-short-for-blind-pedestrians-advocates-6732054

xxxi https://www.cbc.ca/news/canada/british-columbia/bc-floating-bus-stops- human-rights-tribunal-1.5811152

xxxii https://www.timescolonist.com/local-news/updated-guidelines-for- floating-bus-stops-fall-short-for-blind-pedestrians-advocates-6732054

xxxiiihttps://www.london.gov.uk/sites/default/files/prioritising_people_nov2016.p

df

xxxiv PUBLISHED PROJECT REPORT PPR854 Bus Stop Bypasses Analysis of pedestrian and cyclist behaviour via video Greenshields S, Chowdhury S, Jones P March 2018

xxxv PUBLISHED PROJECT REPORT PPR854 Bus Stop Bypasses Analysis of pedestrian and cyclist behaviour via video Greenshields S, Chowdhury S, Jones P March 2018

xxxvi https://www.gov.uk/government/publications/shared-space

xxxvii https://www.disabilitynewsservice.com/minister-calls-on-her-own- government-to-act-on-shared-space-street-designs/

xxxviii Jensen, S U, Rosenkilde, C, Jensen, N (2010) Road safety and perceived risk of cycle facilities in Copenhagen. https://nacto.org/wp-


content/uploads/2010/08/Cycle_Tracks_Copenhagen.pdf; and Jensen, S U, (2007) Bicycle Tracks and Lanes: a Before-After Study https://pdfs.semanticscholar.org/604f/424a94e4886c54ce20f0b1d6d39b44f715 60.pdf?_ga=2.12322804.1927912829.1549794606-976542883.1549794606

xxxix Hauschildt, L S (2014) New campaign to avoid chaos at Danish bus stops http://www.cycling-embassy.dk/2014/08/18/new-campaign-to-avoid-chaos-at- bus-stops/

xl https://politiken.dk/forbrugogliv/forbrug/dintransport/art5527002/Kaos-ved- busstoppesteder-Passagerer-bliver-torpederet-af-cyklister

xlihttps://politiken.dk/forbrugogliv/forbrug/dintransport/art5603134/Vigepligt-

ved-stoppesteder-forvirrer-både-cyklister-og-buspassagerer

xliihttps://politiken.dk/forbrugogliv/forbrug/dintransport/art5527099/Emma-

blev-kørt-ned-af-cyklist-

xliiihttps://www.whatdotheyknow.com/request/request_for_information_about_

mo_2?nocache=incoming-1309200#incoming-1309200

xliv New cycle infrastructure on London’s streets Summary report of on-street trials July 2018 Major of London, Transport for London

xlv PUBLISHED PROJECT REPORT PPR853 Bus Stop Bypasses Accompanied visits of people with disabilities to Bus Stop Bypasses Greenshields, S, TRL July 2018

xlvi PUBLISHED PROJECT REPORT PPR853 Bus Stop Bypasses Accompanied visits of people with disabilities to Bus Stop Bypasses Greenshields, S, TRL July 2018

xlvii https://vancouverisland.ctvnews.ca/this-is-a-question-of-these-people-s- safety-human-rights-expert-on-bike-lanes-complaint-1.4215837

xlviii https://www.timescolonist.com/local-news/bike-lane-bus-stops-dangerous- for-blind-suit-4663778

xlix http://archive.islingtontribune.com/cyclelaneaxed

l https://www.tv2lorry.dk/amp/329838

li https://www.cbc.ca/news/canada/british-columbia/bc-floating-bus-stops- human-rights-tribunal-1.5811152

lii https://www.researchgate.net/publication/237524182_Bicycle_Tracks_and_ Lanes_a_Before-After_Study.

liii https://www.ucl.ac.uk/civil-environmental-geomatic-engineering/sites/civil- environmental-geomatic- engineering/files/steps_project_for_guide_dogs_association.pdf

 

 


May 2023