Written evidence submitted by Guide Dogs (ATR0077)

About Guide Dogs

Guide Dogs provides mobility services to increase the independence of people with sight loss in the UK. Alongside our mobility work we campaign to break down physical and legal barriers to enable people with sight loss to get around on their own terms. Current estimates suggest there are two million people with sight loss in the UK of which around 360,000 are registered as blind or partially sighted. [1]

Introduction

Guide Dogs welcomes the opportunity to respond to this inquiry into ways of increasing active travel across the UK. As well as the benefits identified in the Cycling and Walking Investment Strategy (CWIS) for active travel, there are additional benefits for improving landscapes for walking for people with disabilities. For blind or partially sighted people walking, alongside public transport, is the primary means of travelling independently. Yet all too often walking fails to be the “easy, normal or enjoyable” mode of transport. Of the two million people in the UK with sight loss, 180,000 rarely leave the house alone, contributing to loneliness, isolation and poor health. The choice is not therefore between walking and taking a car, but instead between being able to leave their homes or being isolated. Walking is a lifeline to these people, making it essential that the Government considers the accessibility requirements of this group as part of its very welcome focus on improving walking infrastructure.

At Guide Dogs we therefore recognise the benefits to active travel, however we also recognise the risks. Many blind or partially sighted people will avoid going out alone because they do not feel confident walking the streets. Our services, including the guide dog service, mobility training and My Guide sighted guiding partnerships, aim to allow people with sight loss the freedom to live their lives and engage with active travel, but a safe walking environment is necessary to achieve that goal.

As Parliament’s Women and Equalities Committee pointed out in their 2017 report on disability and the built environment, “the public spaces through which people need to move can be prohibitively excluding”.  The behaviour of road users, the accessibility of the street environment and safety features in vehicles all contribute to how safe blind and partially sighted people feel when walking and are necessary to consider when looking to increase active travel across the UK.

Guide Dogs supports the general vision of the CWIS of working towards better safety, better mobility and better streets. Fundamental to the realisation of the Government’s vision to increase walking and cycling is the provision of clearly delineated and safe routes for walking and cycling.

A recurring theme across our response is the lack of clear, relevant and up to date guidance from the Government, resulting in confusion among local authorities, and blind and partially sighted people facing inconsistent and often highly inaccessible urban environments.

Recommendations:

1. Extend the law which has been in place in London since 1974 prohibiting pavement parking except where expressly permitted to the rest of England and Wales.
2. Ensure that there are clearly defined, appropriately located cycle parking for dockless hire bikes so they do not cause an obstruction and prohibit active travel by vision impaired people.
3. Recommend that charging points for electric vehicles be installed on the road rather than on the pavement if installation on the pavement would reduce the width below the recommended minimum.
4. Involve disabled people in the design of new cycling infrastructure to ensure areas where cyclists and pedestrians interact do not become inaccessible.
5. Where possible, segregate walking and cycling paths so that blind and partially sighted people feel able to navigate safely and comfortably.
6. Monitor areas where cyclists and pedestrians share space to ensure that disabled people continue to feel confident and safe in using the area.
7. If bus stop bypasses are used, they must at a minimum include adequate pedestrian-controlled crossings.
8. Involve disabled people are involved in the update of the guidance on shared spaces.
9. Existing shared spaces to be subject to road safety audits.
10. As a matter of priority, update the guidance for the use of tactile paving.

Risks to active travel

1. Pavement parked vehicles

1.1.  Cars parked on the pavement are a dangerous obstruction for people with vision impairments, as well as wheelchair users and parents with young children. They cause people to risk injury by having to walk in the road, which is especially dangerous for people with sight loss who cannot see oncoming traffic. Further, irresponsibly parked cars can act as an unexpected hazard for cyclists when parked in cycle lanes.

1.2.  Pavement parking is a widespread practice: almost three quarters of UK adults have been forced to walk into the road because of a vehicle parked on a pavement. Over half of those surveyed by YouGov in 2014 said they saw vehicles parked on pavements on a daily basis.[2]

1.3.  A survey by Guide Dogs showed 97% of blind or partially sighted people encounter problems with street obstructions, and 90% of those had experienced trouble with a pavement parked car. In the worst cases, obstacles can deter people from leaving home alone – the same survey showed 40% of visually impaired respondents said street clutter made them less willing to go out on their own.[3]

1.4.  In addition to the physical obstruction that pavement parked cars cause, cars and lorries are one of the main contributing factors to damage caused to our pavements through mounting kerbs and parking. The weight of the vehicles either cracks paving or subsides the tarmac surface, thereby damaging the pavement and in some cases the infrastructure under the pavement. Damaged pavements can then pose a risk to pedestrians, who could trip and injure themselves. This risk is increased for people who are blind or partially sighted. 

1.5.  Pavement parking is an offence in London, except where specifically permitted by the council. Outside London, it is permitted except where councils restrict it street by street using Traffic Regulation Orders (TROs). However, councils report that they struggle to deal with unsafe pavement parking with these existing powers. Guide Dogs undertook Freedom of Information research which found that councils are not generally using TROs to address pavement parking: only 37 councils across England and Wales reported introducing a TRO specifically to combat pavement or verge parking. The FoI research also found that TROs are very expensive: a single small-scale order can cost up to £10,000, not including any works that may be required, and into the hundreds of thousands for a large complex order.

1.6.  We would like to see the successful parking regime which has been in place in London since 1974 extended to the rest of England and Wales. This call is supported by councillors, the public and stakeholder groups including the Local Government Association, Living Streets and the British Parking Association. Recent guidelines on physical activity and the environment by the National Institute for Clinical and Healthcare Excellence also recommend keeping pavements clear of parked cars to provide a safe walking environment.[4] The wide range of organisations calling for national legislation on pavement parking shows the grave impact that pavement parking has upon all pedestrians.

1.7.  Following a private member’s bill on this issue in 2015, the Government committed to conduct research into the best solution to tackle problematic pavement parking.

1.8.  Giving councils the powers to manage unsafe pavement parking effectively would promote a safe walking environment and enable people with sight loss, as well as other pedestrians, to use the streets with confidence. Our recommendation is for the model which has worked successfully in London since the 1970s, where pavement parking is not permitted except in designated areas, to be rolled out across the rest of England and Wales. Guide Dogs welcomes the measures introducing a prohibition on pavement in the Transport (Scotland) Bill in the Scottish Parliament that is currently being scrutinised.

1.9.  After a significant delay, we were pleased that Transport Minister Jesse Norman committed his Department to undertaking research on the prevalence of pavement parking and possible solutions. This research is underway and conclusions are expected to be drawn by the end of the year.

2. Street Clutter

2.1.  In addition to pavement parked cars, navigating the streets can also be problematic for vision-impaired people as pavements are obstructed by café furniture, advertising ‘A’-boards or other street clutter. Whilst the entry of dockless hire bikes into the market may encourage certain individuals to cycle more, it is essential that there are clearly defined, appropriately located cycle parking so that this addition does not prohibit active travel by vision impaired people.

2.2.  Similarly, the growth of electric vehicles as an alternative mode of transport requires a corresponding growth of roadside charging infrastructure. However, the placement of charging points can create problems for blind and partially sighted people. Charging cables are a potential trip hazard and where charging points are placed on the pavement, they are an additional obstacle which narrows the effective width of the pavement. The guidance document Inclusive Mobility (2002) recommends that pavement width should be sufficient to allow two wheelchair users or guide dog owners to pass each other (2m), or where this is not possible, 1.5m, or in exceptional cases a minimum of 1m. Where the installation of a vehicle charging point on the pavement would reduce the width below the recommended minimum, we believe that guidance should recommend that the charging point be installed on the road instead, for instance in place of on-street parking.   

3. Cycling Infrastructure

3.1.  With the focus on expanded provision for cycling, it is even more important that disabled people are involved in the design of new infrastructure to ensure areas where cyclists and pedestrians interact do not become inaccessible. Without careful design, increased numbers of cyclists could create accessibility problems for people with sight loss.

3.2.  Where cyclists and pedestrians share space, cyclists can approach without audible warning at speeds which make it difficult for blind and partially sighted people to navigate safely and comfortably. Even where this does not result in a collision, the uncertainty and perception of danger can prompt people with sight loss to avoid these areas.

3.3.  There are particular concerns around shared use paths[5], where cyclists and pedestrians share the same area of pavement. Research by the RNIB has found that 73 per cent of blind and partially sighted people said they were ‘not confident’ using a path or pavement shared with bicycles, and over half would avoid a shared route if an alternative was available.[6] Shared use paths can be challenging to navigate for blind and partially sighted people even when cycle traffic is light, but in many cases, as outlined by the charity Living Streets, the volume and speed of cycle traffic is inappropriate to allow pedestrians to use them in comfort. When considering shared use paths, local authorities should be required to take pedestrian comfort levels into account.

3.4.  Even when segregated, cycling infrastructure can become a barrier for people with sight loss where insufficient attention is given to crossing facilities. Guide Dogs research shows that a lack of safe crossing points is a major barrier for people with sight loss.[7]

3.5.  We recommend a commitment to segregation of walking and cycling where possible, and continued monitoring of areas where cyclists and pedestrians share space to ensure that disabled people continue to feel confident and safe in using the area.

3.6.  There are also concerns around bus stop bypasses[8], where bus users must cross a cycle path to reach a bus stop. Bus stop bypasses present a physical barrier to accessing public transport, particularly when installed on an already narrow pavement or where they lack any crossing provision. If bus stop bypasses are to be considered, they must at a minimum include adequate crossings, which should be pedestrian-controlled rather than informal or courtesy crossings where pedestrians have no legal priority.

4. Shared Spaces

4.1.  Whilst we welcome the focus on active transport, we are concerned that some design approaches aimed at reducing the dominance of cars have in fact made streets less accessible for blind and partially sighted people. Shared space schemes, which often include the removal of key safety features such as kerbs and controlled crossings, can be dangerous and disorientating for people with sight loss. Guide dogs struggle to assist their owners in shared spaces because they are trained to stop at kerbs and crossings. Without these essential safety features, crossing the street can be dangerous.

4.2.  Guide Dogs surveyed almost 2500 people about their experiences of shared spaces. Over three quarters reported they felt less safe in a shared space with kerbs removed than in a traditional street layout, and of the blind and partially sighted people surveyed, 75% said that raised kerbs and 92% said that controlled crossings are essential to make streets safe.[9]

4.3.  The Women and Equalities Select Committee found significant evidence that shared spaces exclude disabled people. [10] The dangers of shared spaces were confirmed by a recent academic study in the Netherlands, which found that “shared space areas can be highly complicated to navigate and also potentially dangerous for some visually impaired people…This is especially true for those using a guide dog.”[11]

4.4.  Shared spaces have been linked to a number of accidents. In Coventry, zebra crossings were reinstalled on shared spaces after a fatal accident involving a partially sighted pensioner. The coroner concluded that an accident was inevitable given the layout of the shared space.[12]

4.5.  The Department for Transport (DfT)’s existing guidance on shared space[13] does not send a clear message to councils. As noted by a Lords committee, it contains “only a brief reference to the Equality Act, and where the problems of disabled people are dealt with, there is little specific guidance”.[14]

4.6.  The Government’s Inclusive Transport Strategy, published in July 2018, committed to the temporary withdrawal of existing guidance on shared spaces and called for local authorities to pause planned shared spaces in England. This follows Guide Dogs’ campaign for a pause while guidance is updated, which was echoed by experts from the Women & Equalities Committee of MPs as well as design industry bodies.

4.7.  Guide Dogs would like to see better safety for pedestrians through the preservation of pedestrian-only pavements. We recommend that the government ensures that disabled people are involved in the update of the guidance on shared space, and for existing shared spaces to be subject to road safety audits.

5. Poor quality Tactile Paving

5.1.  The use of tactile paving is essential for many individuals with sight loss. However, the guidance for the use of tactile paving – which provides vital guidance to local authorities in planning accessible streetscapes, including technical diagrams and specifications for specific scenarios, such as crossings and raised tables - is now out of date, which can create confusion amongst local authorities about which parts of guidance they should follow.

5.2.  There are examples all over the country of streets where local authorities have not followed the guidance, for example through installing tactile paving which has insufficient colour contrast, or installing hard metal studs which cause problems for wheelchair users rather than the smooth blister paving prescribed in the guidance.

5.3.  Given the variation in quality and appropriateness of tactile paving, many people who are blind or partially sighted do not have the confidence to rely on tactile paving for them to navigate independently, which reduces their ability to engage in active travel.

5.4.  The 2012 Accessibility Action Plan included plans to update the guidance by 2014. After a protracted delay, this commitment has been reiterated in the 2018 Inclusive Transport Strategy. Guide Dogs strongly urges the Department to swiftly consult and publish the much-delayed guidance.

October 2018