Enfield Council's deputy leader has defended the borough's cycle lanes schemes against accusations of discrimination made by a charity that supports blind and partially sighted people.
The criticism of Enfield Council is contained in a press release issued on 19th February by the National Federation of the Blind of the UK (NFBUK) and relates in particular to the design of bus stop bypasses and bus stop boarders along the A105 between Palmers Green and Enfield Town. The NFBUK contend that the designs are in breach of UK equality legislation because "there has been no real consideration of the needs of blind or frail people" and claim that "anyone can see the design is flawed and inherently dangerous".
In a response released to Palmers Green Community, Councillor Daniel Anderson says that Enfield Council "emphatically rejects" the allegation that it has been ignoring its obligations under the Equality Act. He says that the council had previously written to the NFB UK and provided them with copies of the Council reports which included details of the Equalities Impact Assessment. According to the deputy leader, the council has welcomed advice and feedback from many parties, including Enfield Disability Action, Guide Dogs for the Blind, Enfield Vision and the Centre for Accessible Environments. With regard to bus stop boarders, he says that Transport for London is reviewing their safety and Enfield will consider the outcomes and make adjustments if appropriate.
The full texts of the press release and response are shown below.
National Federation of the Blind of the UK Slams Councils for Illegal Road Designs
PRESS RELEASE: National Federation of the Blind of the UK Slams Councils for Illegal Road Designs
19th February 2019
The National Federation of the Blind of the UK (NFBUK) is concerned at the number of councils that are ignoring their obligations under UK Equality law and designing road layouts that make towns more inaccessible to blind people.
NFBUK President Andrew Hodgson said:
We have visited several areas recently where planners have clearly not considered the needs of blind and disabled people. The mini-Holland cycle lane schemes funded by Transport for London (TfL) have created real distress for blind and disabled people. In Enfield bus bypass and ‘Copenhagen’-style shared use boarder bus stops have been introduced which create dangers for all passengers, but especially those who are blind. In Waltham Forest they have installed ‘Copenhagen’-style crossings, which are raised tables at road junctions. These create particular problems for those of us who use white canes or guide dogs to help us get around. It is very difficult to determine where to stop on these arrangements.
Research in Denmark revealed that bus stop boarders present a particular hazard for all pedestrians: their introduction led to an increase in collisions with passengers from 5 to 73 - a 1,725% increase in collision rates on what had been expectedi. NFBUK has regularly pointed out the dangers of bus boarder bus stops for all passengers but especially blind people. Bus stop bypasses (also known as ‘floating’ or ‘island’ bus stops) also present dangers. After years of complaint about bus stop bypasses TfL finally commissioned the Transport Research Laboratory (TRL) to investigate how to improve the safety of bus bypass arrangements. Their report last year recommended that Zebra crossings be installed at all such bus stops, although TRL found little improvement in the numbers of cyclists who stopped for pedestrians on bus stop bypasses after zebra crossings were addedii.Many other recent changes to road layouts have brought particular dangers for blind people. For example, controlled crossings have been removed in the ‘Connecting Leicester’ scheme to improve walking and cycling in the city. However, many blind and partially sighted people now call it ‘Disconnecting Leicester’, as the removal of controlled crossings from key junctions has rendered once accessible routes from the train station now inaccessible.
At some places in Enfield, pedestrians have to cross the cycle lane first before they reach crossing controls or get on or off a bus. NFBUK Shared Space Coordinator Sarah Gayton said:
I was shocked at what I saw in Enfield. I had been told it was bad but had no idea quite how bad it would be. The shared space bus stop puts two very vulnerable groups in the same place at the same time, pedestrian and cyclists. Anybody can see the design is flawed and is inherently dangerous. The scheme is a disaster for blind people. It is difficult to see how this could have been approved as acceptable. It seems to me there has been no real consideration of the needs of blind or frail people.
In Chorlton, Manchester, a new cycling scheme has been proposed which has ignored the needs of blind, disabled and vulnerable pedestrians who are supposed to be protected by Section 21 of the Equality Act. NFBUK support worker Peter Monk (a member of the Royal Town Planning Institute) analysed these latest proposals and said:
The scheme has total disregard for disabled people's rights of access to street environments. The scheme will create over 30 bus stops that disabled and frail passengers will not be able to use to board and alight from buses. Seventeen bus stops are designed as bus stop "islands" (bypasses) with cyclists routed around the back of the bus stop; designs which have been found in independent trials in London not to arrest cyclist speed or result in cyclists giving way to bus passengers.
There are potentially 14 bus stops which are even more dangerous, with cyclists routed along the section of pavement where people step up or wheel up onto and off buses known as Copenhagen style bus stops and known in Enfield as bus stop boarders.40% of bus drivers in 5 cities in Denmark including Copenhagen, have witnessed bus passengers being involved in collisions at both these types of bus stopsiii.
NFBUK offered to work with the Manchester team in August 2018 on these issues but this offer of cooperation was not taken up. In Enfield, a formal letter of complaint to the Leader and Chief Executive elicited a response not from the Leader, but instead from an officer that said that the scheme design had been ‘carefully considered’. NFBUK President Andrew Hodgson said:
If the needs of blind and disabled people had been properly taken into account in designing the Enfield mini-Holland scheme we would not have ended up with this dangerous and discriminatory scheme. It is for this reason that we have recently supported a petition organised by Enfield residents and submitted to the Government asking for a strengthening of the law relating to Equality Impact Assessments. If these Administrations had properly fulfilled their duties in this regard we would not be having to fight such discriminatory schemes now.
NFBUK recognises the value of attempting to encourage more active transport. However, designs must enhance and safeguard the independent mobility of disabled and vulnerable pedestrians and their safe access on and off of public transport, as well as ensuring the safety of cyclists. NFBUK is happy to engage with design teams to ensure that future infrastructure changes fully take the needs of all pedestrians into account.
ii Greenshields S, Davidson S Bus Stop Bypasses Surveys of pedestrians and cyclists. PROJECT REPORT PPR855 https://trl.co.uk/sites/default/files/PPR855%20- %20Bus%20Stop%20Bypasses%20- %20Surveys%20of%20Pedestrians%20and%20Cyclists.pdf
iii [iii] 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-busstops
Response from deputy leader of Enfield Council
Response from deputy leader of Enfield Council
Please see a detailed response to questions asked on this matter.
NFB UK says councils like yours are ignoring their obligations under the Equality Act by introducing such schemes. How does the council respond?
We emphatically reject that allegation. On the contrary Enfield Council is fully committed to equality in everything we do. This involves having due regard to the needs of diverse groups when designing, evaluating and delivering services. This is in order to eliminate discrimination, advance equality of opportunity and access and to foster good relations between different groups in the community. These obligations are listed under the Equalities Act 2010 and the Council embodies these obligations in all of our services from design to implementation. We have previously written to the NFB UK and provided them with copies of the Council reports. Details of the Equalities Impact Assessment for the A105 project are discussed at para 11 of this report: https://governance.enfield.gov.uk/documents/s56332/PART%201%20Report%20-%20Cycle%20Enfield%20A105.pdf. The referenced appendix is here:https://governance.enfield.gov.uk/documents/s56136/Appendix%20E%20-%20Predictive%20Equalities%20Impact%20Assessment%202.pdf.
What efforts did the council make to listen to blind and partially-sighted people before introducing these bus stops?
Cycle Enfield is about transforming our high streets and town centres for the benefit of all users. That being so, at every stage of the design process, the Council has welcomed the advice and feedback of many parties and have embarked on several consultations. Groups such as Enfield Disability Action, Guide Dogs for the Blind and Enfield Vision have been invited to engage with us and we continue to welcome their feedback. Enfield Council has also worked directly with the Centre for Accessible Environments to help ensure we fully understand the perspectives of more vulnerable road users.
Although new in Enfield, the bus-stop designs have been used in other parts of London, the UK and Europe. We believe that the current design for bus boarders in Enfield does make it clear that pedestrians have right of way. In addition, the installation of buffer strips, ramps, signage and distinctive paving all inform cyclists that they are entering an area used by pedestrians and must give priority to pedestrians.
In our response to NFB UK, we reiterated that as we continue to deliver this programme, we will continue to explore more ways to constructively engage with a range of community groups. As part of this, we are interested to hear the views of organisations who represent people who are visually impaired / have particular accessibility requirements. This is the case in both informing early design work, and also in listening to any specific issues that are raised post construction. Working together in a constructive way will be positive for all members of the community.”
What action will the council take now to address these concerns?
In our response to NFB UK, we explained how Transport for London (the funders of the Cycle Enfield programme) is currently conducting a London-wide review of bus stop boarders, which includes the design implemented as part of Cycle Enfield. We will consider any outcomes of this carefully in-conjunction with TfL and if appropriate make adjustments.
We have also reiterated that as we continue to deliver this programme, we will continue to explore more ways to constructively engage with a range of community groups. As part of this, we are interested to hear the views of organisations who represent people who are visually impaired / have particular accessibility requirements. This is the case in both informing early design work, and also in listening to any specific issues that are raised post construction. Working together in a constructive way will be positive for all members of the community.