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RNIB Cymru writes to the Chief Executive of Cardiff Council calling for dangerous new bus stops to be redesigned

Dear Mr. Orders,

Cardiff Cross City Cycleways and Access to Bus Stops

We are writing to formally report our ongoing concerns regarding changes to the city centre that are negatively impacting blind and partially sighted people. In particular, the inaccessibility of the bus stop designs which are part of the Cardiff Cross City Cycleways project. We are extremely disappointed with the Council’s continued failure until very recently to account for the needs of blind and partially sighted people and other disabled pedestrians in navigating the city. Last month we were told that Cardiff Council would be seeking funding to remove the Bus Borders. This is an important step forward, and we set out in this letter why it is essential that this commitment is progressed as a matter of urgency.

Our concerns about these schemes and issues arising from the introduction of new street layouts in response to the pandemic, had been raised in June 2020, which led to the council’s Equality and Accessibility Group (EAG) being reconvened.

There was some encouraging progress, but an increasing number of issues were raised by RNIB and Guide Dogs, via the EAG, which resulted in a letter to the Council leader, Cllr Huw Thomas, in February 2022, (a copy of this letter is enclosed).

The designs that we are referring to are located at Dumfries Place, Newport Road, the Kingsway and Castle Street. All lack the basic safety features necessary to keep blind and partially sighted people safe. To catch a bus, a blind or partially sighted person is expected to cross a cycle lane. Some stops have zebra crossing markings but do not have tactile markings which allow blind and partially sighted people to detect the presence of a crossing point. There is no kerb demarcation between the pavement and the cycle lane which would enable a blind person to detect that they are stepping into a cycle lane. Unlike other designs in the city, these have no signal-controlled crossing points to give blind or partially sighted pedestrians confidence that oncoming cyclists would come to a reliable stop.

Council officers have been warned, not only by sight loss organisations, but also by professional highways consultants that these designs are unsafe and inaccessible, but they have taken no substantive steps to address the situation. Furthermore, we understand that the designs do not comply with Active Travel Wales guidance, a fact that has been confirmed by the Deputy Minister for Climate Change, Lee Waters MS via correspondence with Guide Dogs Cymru in February 2022. This letter has been attached for reference.

We have gathered evidence from blind and partially sighted residents of Cardiff who tell us that they “cannot begin to describe the terror” they feel at having to use these bus stops. Some were not made aware of the changes in designs and so did not initially know that they were walking into live cycle lanes when catching their regular buses. Blind and partially sighted people have reported having near misses with cyclists and their guide dogs becoming confused and disorientated by the unfamiliar designs. Sadly, many people have told us they have lost confidence in using these stops and are choosing not to use buses to access the city centre.

As a public authority, Cardiff Council is subject to the Public Sector Equality Duty (PSED) and is required to demonstrate "due regard" to the need to eliminate unlawful discrimination, advance equality of opportunity and foster good relations between, amongst others, disabled and non-disabled people.

The Equality Act 2010 (Statutory Duties) (Wales) Regulations 2011 require public authorities to assess the likely impact of a decision (such as a new public realm scheme) and to consider whether the decision would have a disproportionate impact on people sharing one or more protected characteristic, including disability. Where a potential detrimental impact on people who share a protected characteristic is identified, authorities must then take steps to implement any necessary changes to mitigate the impact. Under the same regulations, authorities must consider the need to involve or consult people with one or more of the protected characteristics, including disability, when they assess impact.

Until now, it is not at all clear that the Council has considered its duty to promote disability equality in relation to the impact of this cycling infrastructure that has been installed around the city. Where equality impact assessments have been undertaken and negative impacts have been noted, there is little further consideration or attempt at mitigation. With the commitment from Welsh Government to implement the Social Model of Disability throughout its policy and practices, local authorities should be looking to follow suit, but we see little evidence that Cardiff Council understands the Social Model in its application to street design accessibility.

The importance of consultation and engagement

Good consultation and engagement are key to the effective discharge of the PSED and yet, as we have outlined in our previous correspondence, feedback from the EAG and its members appears to have largely been ignored. Responsible officers have not attended when schemes they are leading on are discussed so specific details cannot be explained at the time. Queries raised during meetings by representatives of RNIB and Guide Dogs are often not answered, and plans have often been shared as inaccessible PDF documents containing drawings which are technically complex and inaccessible to visually impaired members.

Despite our frustrations, we have engaged constructively with the EAG in good faith. Our concerns about the bus border designs were noted in the minutes of the EAG in October 2021, and a formal complaint submitted by Guide Dogs was acknowledged via an email from a council officer on 13 October. Guide Dogs raised this complaint following a report from a vision impaired bus passenger who stepped directly into a cycle lane off the bus because he wasn’t aware of the danger.

Subsequent meetings record ongoing concerns:

November 2021 – following a site visit organised by Guide Dogs, attended by local vision impaired residents, one of the council officers involved in the delivery of the scheme and the Chair of the EAG, there was agreement to review the designs in early 2022. We were told that interim measures would be installed such as signage instructing cyclists to slow down and that an external review would be commissioned. Although some steps have been taken, they don’t sufficiently allay the concerns of people with a vision impairment. In addition, the external review, which was eventually conducted in Autumn that year, was not accessible to vision impaired EAG members. It failed to address all the safety issues, as explained in the minutes from the meeting in December 2022.

As the capital of Wales, Cardiff should be an exemplar of equality and we have seen how this can be done. The former Cardiff Council Access Focus Group (CCAFG), chaired by Dr Robert Gravelle, was held up as a best practice example and we worked together to find inclusive solutions which worked for most, if not all, residents and visitors. That success was built on good communication and a commitment to genuinely hear and respond to the concerns of disabled people and those with other protected characteristics. We would like to work together with you to return to this model.

RNIB Cymru and Guide Dogs Cymru have made considerable efforts to engage with the Council on the matters outlined above and to highlight the problems blind and partially sighted people continue to experience. We were therefore delighted when in a meeting of the EAG on 21 August, (2023), we were told that Cardiff Council would be seeking funding to remove the Bus Borders. This is of course good news, and we are pleased that the Bus Island at Wood Street now has a signalised crossing which is a much safer option for all pedestrians, but particularly those with sight loss.

Guide Dogs Cymru and RNIB have commissioned an Access Audit of the Bus Borders by an independent, external consultant which will take place later this month. We would be pleased to share this with you in the hope that it will inform your plans for redesigning the existing schemes.

We now request a formal discussion, as soon as possible given the risks to vision impaired people of any further delays, to look at next steps for removing the bus borders and the timetable for this crucial change.

Yours sincerely,

Ansley Workman, Director, RNIB Cymru

Eleanor Briggs, Head of Policy, Public Affairs & Campaigns, Guide Dogs