DPTAC response to Department for Transport consultation on Cycling Infrastructure Design

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Our Comments

1: Do you think this guidance document is useful as a single source of reference?

The stated aim of the Local Transport Notes published by the Department for Transport is to summarise the many areas of best practice regarding specific aspects of transport policy and practice into single documents. In this case we note the intention is to bring together the current Government guidance and advice on providing and planning for cycle friendly infrastructure that is already publicly available. To that extent we therefore welcome this document.

2: Are there sections of advice with which you particularly agree / disagree?

This is not the first consultation in recent years on cycling infrastructure design. In 2004, the Department consulted on a draft Local Transport Note on Policy, Planning and Design for Cycling and Walking and DPTAC commented at length. In many respects, therefore, the current consultation seems to have gone backwards since there is currently no equivalent consideration of walking. This is unfortunate - particularly since the current document makes reference to the recently published Manual for Streets which makes it clear that the interests of pedestrians should be given priority over cyclists and other road users. Both Manual for Streets and the current consultative document also make it clear that shared use of footways by cyclists and pedestrians should be considered as a last resort. It is therefore unfortunate that the cover of the document should feature shared use!

The document also needs to recognise the obligations under the Disability Equality Duty under the Disability Discrimination Act 2005. This requires engagement with disabled user groups in the development and implementation of any measures such as cycle infrastructure to ensure the interests of disabled people are not prejudiced and, indeed, so that they are actively promoted. The Local Transport Note would do well to refer to "Planning, buildings, streets and disability equality", the guide to the Disability Equality Duty and Disability Discrimination Act 2005 published by the Disability Rights Commission in 2006 in order to assist local authority departments responsible for planning, design and management of the built environment and streets.

We would also make specific comment at this point regarding the A-frame arrangement promulgated in paragraph 7.13.6 and Figure 7.7. This poses problems for blind and partially sighted people because of the inwards sloping sides and we are totally opposed to this arrangement.

We also believe that the suggestion of RADAR key operated gates is not a practical proposition for wheelchair and scooter users.

3: In what ways could the guidance be improved?

While the obvious interest of DPTAC relates to non-cyclists, there are many disabled people who enjoy cycling and it is vital to be aware of whether they may require specific features to help them. The other aspect of which it is essential to be aware is the potential for provision for cyclists also to help the users of wheelchairs and scooters. This is referred to in passing in paragraph 2.6.2 but it is not developed. We believe the draft guidance in its current form is missing a major opportunity to improve conditions for the many disabled people reliant on such appliances.

We would also draw attention to Manual for Streets which stresses the need for inclusive design and emphasises the implications of the Disability Discrimination Act 2005. As we have indicated in our response to question 2 above, both aspects require engagement with disabled user groups in the development and implementation of any measures to ensure their interests are not prejudiced and, indeed, so that they are actively promoted. We therefore believe the Local Transport Note ought to refer to "Planning, buildings, streets and disability equality", the guide to the Disability Equality Duty and Disability Discrimination Act 2005 published by the Disability Rights Commission in 2006.

4: Are there any issues covered in Cycle Friendly Infrastructure (1996) which you feel should have been included (and updated) in this draft?

We note that the current consultation was produced with the assistance of the Cycling England advice team. We believe this means that the document suffers from the same shortcomings as the 1996 publication which involved the Bicycle Association, the Cyclists' Touring Club and the Institution of Highways and Transportation. There is no mention of any involvement of disability groups in either case. There is of course an even greater imperative attached to this now with the introduction of the Disability Equality Duty in December 2006. We note too that while reference is made to at least one publication from the Scottish Government (Sharing Road Space, 2001) there is no reference to what is a more relevant publication from north of the border - Cycling by Design, consultation document published in January 2000 (see www.scotland.gov.uk/library2/cbd/cbd-00.asp).

We mention this because although it predates the Disability Discrimination Act 2005, it effectively anticipates the Disability Equality Duty when it states:

"The conversion of footpaths, footways and areas free from motorised traffic to permit cycle use should not be regarded as a general or area-wide remedy to cycle safety problems but should be confined to specific links and locations where clear benefits can be derived from such conversion. In such situations it is imperative that the benefits to the cyclist are balanced against any increase in risk and inconvenience to pedestrians. Any potential loss of use and attendant loss of mobility, particularly to disabled, elderly, blind or partially sighted people, will require full and detailed consideration."

Indeed there is much practical advice contained in this consultative document (not least in regard to shared use) which we feel would bear consideration for inclusion in this Local Transport Note.

5: Any other comments?

We offer the following detailed comments on the draft document.

In paragraph 1.2.1 it is stated that, in urban areas, "the preferred form of provision is to try to achieve conditions where cyclists are content to use the carriageway". This is a statement that we in DPTAC should fully endorse. Paragraph 1.2.3 goes on to indicate that any situation where cyclists share space with pedestrians "has the potential to introduce conflict". Unfortunately the behaviour of some cyclists is such that this is not just possible but inevitable. The text does acknowledge the particular problems of blind and deaf pedestrians. There would seem an opportunity to stress the need for detailed consultation with local disability groups whenever any consideration is being given to shared use.

Paragraph 1.5.2, in discussing risk and liability, suggests that "it can be beneficial to involve representatives from user groups". The user groups are not specified but we should stress in our response that consultation with the local access officer and disability groups is essential and a clear requirement under the Disability Discrimination Act 2005.

Section 1.6 deals with Cycle Audits. Manual for Streets indicates a preference for quality audits which address all aspects including Access Audits and indicates that the auditing process is an ongoing one that applies throughout the development and implementation of the proposal. The Manual also refers to Inclusive Mobility in this respect (although this latter document is unfortunately lacking in consideration of cycling infrastructure).

Section 2 goes on to consider Design Parameters. Paragraph 2.6.2 refers to the opportunity to accommodate the needs of wheelchair users on infrastructure designed for cycling. This, however, is not developed and there is no reference to appropriate dimensions among the welter of other dimensions relating to cycles, tandems and cycle trailers. As indicated in our response to question 3 above, this would seem a real missed opportunity.

Paragraphs 3.2.2 and 7.13.2 refer to the minimum gap that should be left between bollards intended to stop the passage of road vehicles. The figures quoted are 1.5m with an absolute minimum of 1.2m. These figures which we endorse are of particular interest since the bollards surrounding the Home Office building opposite the Department for Transport offices in Great Minster House are at a much closer spacing! We have previously drawn attention to the problems that the Home Office bollards cause for many wheelchair users.

While the apparent emphasis at the beginning of the draft document is to discourage shared use of pedestrian areas, Section 3.4 seems to encourage shared use in the busiest pedestrian areas - town centres and pedestrianised streets in particular. Paragraph 3.4.7 does indicate that "pedestrians and cyclists often ... favour a marked cycle route within pedestrianised areas". Paragraph 3.4.8 goes on to discuss how this might be achieved through the use of design features and different surfaces although signing and coloured surfacing are not favoured. The paragraph does, however, acknowledge the opportunity to create "a legible environment for blind and partially sighted people". We would draw attention to the work carried out by DPTAC with respect to Home Zones and also to current work by the Guide Dogs for the Blind Association into shared surfaces and the use of delineators to give guidance to blind and partially sighted pedestrians.

Section 4 deals with speed reducing measures. Table 4.1 refers to the use of shared surfaces with an absence of kerbs and fewer signs and road markings. It acknowledges the problems this can pose for blind and partially sighted people but goes into no detail (again we see an need to recognise the work by DPTAC into Home Zones and by the Guide Dogs for the Blind Association into shared surfaces).

Paragraph 4.7.1 refers to the use of stone setts as a traffic calming device and again suggests this can pose problems for blind and partially sighted people! There is no mention of the even greater difficulties they may pose for other disabled people including those with arthritis and wheelchair users!

Figure 4.7 shows an example of a ramped cycle pass at a road narrowing. It is difficult to distinguish detail in the small photograph but the accompanying text suggests that the on carriageway cycle lane is ramped up on to the footway area so cyclists do not get trapped by a localised narrowing of the carriageway. This could not only cause problems for an unwary pedestrian but the photograph seems to show a pedestrian crossing facility with dropped kerbs and tactile paving which is bisected by the raised cycleway!

Figure 5.4 is a photograph showing a combined bus and tram stop in Manchester where the raised boarder is divorced from the adjacent footway (and the bus/tram shelter!) by a cycle lane that has been diverted off the carriageway. In fairness the text does acknowledge could lead to conflict with the interests of passengers but why highlight it as an example? The potential conflict should at least be acknowledged in the caption to the photograph.

Paragraph 6.10.3 refers to the use of two-way cycle lanes to one side of a street and the difficulties they may cause for other road users including pedestrians. There is no specific mention of disabled people in this respect though it is easy to imagine the issues for blind and partially sighted people in particular in trying to cross a street where there may at least three directions of traffic with which to contend - two-way cycle traffic and one-way vehicular traffic! The text does indicate that such arrangements should be the subject of a risk assessment prior to introduction and carefully monitored after implementation. Again there would seem to be a need to refer specifically to involving local disability groups at all stages.

Section 7 deals with Off Road Cycle Routes. The section begins with reference to the use of abandoned railway lines but quickly gets into shared use of pedestrian routes. It becomes worrying when it is indicated that on commuter routes, cyclists would wish to maintain speeds of 12-20mph without losing momentum. This has very clear adverse implications for the interests of disabled people who have sight or hearing impairments.

Conversely there are potential benefits for users of wheelchairs and scooters. We believe that the document should be encouraging the development of off road routes for use by both cyclists and wheelchair users as a matter of course. This will of course have implications for design standards.

Paragraph 7.9.1 again refers to the problem of cycleways and bus stops and suggests that the potential for conflict is a reason why shared use of footways is unpopular. The option that is favoured in the draft document depends on sufficient space being available to allow the cycleway to pass behind the bus shelter and any waiting passengers.

In a section with the headline Managing User Conflict, paragraph 7.12.1 stresses that "on-carriageway options should be exhausted before deciding to convert footways to cycle tracks". Presumably what is referred to here is shared use of footways and this needs to be clarified in the text.

Section 7.13 deals with access control. Paragraph 7.13.1 indicates that "most designs are inconvenient ... and may be hazardous to blind or partially sighted people". Paragraph 7.13.2 refers to the preferred spacing of bollards (see 10 above). Paragraph 7.13.4 refers to the need for arrangements "to accommodate wheelchair users to comply with the Disability Discrimination Act". This section needs to be clarified to indicate that the obligations under the Disability Discrimination Act 2005 extend to consideration of the needs of all disabled people.

We are therefore surprised and disappointed to read in paragraph 7.13.5 about reference to the use of a low hooped bar (shown as 0.32 m high in Fig 7.6) particularly when the text then goes on to say that this type of barrier "is now recognised to be a hazard to blind or partially sighted people and is included in this draft for illustrative purposes only. In practice, a full-height barrier should be provided." If this is the case, why mention or illustrate it? The retention of diagram 7.6 with no qualifying text could suggest this is an acceptable measure.

We are also concerned about the A-frame arrangement promulgated in paragraph 7.13.6 and Figure 7.7. This poses problems for blind and partially sighted people because of the inwards sloping sides and we are totally opposed to this arrangement.

We also believe that the suggestion of RADAR key operated gates is not a practical proposition for wheelchair and scooter users and would be opposed to this suggestion.

Paragraph 7.14.2 and Figure 7.8 refer to the use of half barriers at "blind" corners. We are concerned that this might create a problem for blind and partially sighted users.

In paragraph 7.15.1, reference is made to a new tactile paving detail that is not covered in existing guidance. However, the related diagram is not available for comment.

Section 7.16 deals with maintenance. It is absolutely essential that care is paid to the need for regular maintenance including maintaining safe surfaces that are free from ponding; that are swept and cleaned frequently; that are well lit where appropriate; and that are kept clear of overhanging and overgrown vegetation. Users should be involved in determining and monitoring maintenance regimes and this should form part of the development and implementation of proposals.

In Section 8 regarding Junctions, Figure 8.5 is unclear. It appears to show a cyclist using a cycleway on the carriageway with an Advanced Stop Line. However, there also appears to be a cyclist on the footway which seems to have a dividing line down the middle. However, the half nearest the carriageway leads straight into a signal pole!

Section 9 dealing with Cycle Track Crossings covers both crossings on dedicated cycle only tracks and shared use situations. A distinction needs to be drawn between the two situations because there are important differences in the potential conflicts of interest. It also seems strange that there is reference to the signing of crossings but no reference to the need to ensure correct use of tactile paving.

Paragraph 9.3.5 and Figure 9.3 relate to the "bent out" cycle track crossing arrangement that features on the cover of the draft document. The particular example relates to a shared use footway/cycleway. Ironically although shared, the side road crossing is referred to as being cycle priority - no priority for pedestrians!

Paragraph 9.7.1 on zebra crossings would seem better placed immediately after the section on signal controlled crossings since technically, zebra crossings are also controlled crossings. The suggestion that it is illegal to cycle across a zebra crossing will come as a surprise to many cyclists and seems inconsistent when compared with other forms of crossing.

Regarding parking of cycles (Section 10), paragraph 8.2.21 of Manual for Streets indicates that "cycle stands need to be located clear of pedestrian desire lines and generally closer to the carriageway than to buildings. They should be detectable by blind or partially sighted people. A ground level tapping rail at either end of a run of stands should be provided".

We believe the Section 12 references need to be extended to include:

• "Planning, buildings, streets and disability equality", the guide to the Disability Equality Duty and Disability Discrimination Act 2005 published by the Disability Rights Commission;
• research by DPTAC into Home Zones (www.dptac.gov.uk/pubs/pm/homezones/index.htm);
• and by the Guide Dogs for the Blind Association into shared surfaces (www.gdba.org.uk/uploads/media/Report_of_UK_Focus_Groups_02.pdf).

We would also suggest inclusion of reference to:

• "Cycling by Design", consultation document published by the Scottish Government in January 2000 (www.scotland.gov.uk/library2/cbd/cbd-00.asp);
• "Cycle-Friendly Infrastructure", the guidelines are produced by the Institution of Highways and Transportation (www.iht.org/publications/technical/cyclefriendly.asp).

Any other general comment that you would like to make concerning this consultation

We would draw attention to the work carried out by DPTAC with respect to Home Zones and also to current work by the Guide Dogs for the Blind Association into shared surfaces and the use of delineators to give guidance to blind and partially sighted pedestrians.

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