Address: Kath Locke Centre, 123 Moss Lane East,
Hulme, Manchester M15 5DD Tel: 0161 455 0219
Email: admin@mdpag.org.uk Web: mdpag.org.uk
TfGM Bus Priority Consultation: Manchester City Centre and
Oxford Road.
Response from Manchester Disabled People’s Access Group
(MDPAG)
1.
Summary of proposals
MDPAG requests that the Committee gives favourable consideration
to the following proposals:
1.1
1.2
1.3
1.4
1.5
Undertake a detailed design assessment of and consultation on the
Dutch style cycle lanes, including the inclusion of visual and audible
features, to protect the safety of pedestrians crossing the cycle lanes
to and from bus stops, with a report to TfGMC before general approval
for the scheme is given.
Undertake a detailed assessment of access to premises and services
for disabled people, including access by blue badge holders, and
provide additional accessible parking bays to in appropriate locations,
to Department for Transport and Design for Access 2 standards.
The provision of additional controlled crossings where the changes will
increase traffic flow and where hazards for pedestrians have already
been identified, including the top of Portland Street, Charlotte Street,
Minshull Street and Nicholas Street.
Undertake improvements to signage for pedestrians and car drivers to
ensure clear routes to premises particularly along Upper Brook Street,
access to premises and services from Cambridge Street/Lloyd Street
North/Upper Lloyd Street, around Oxford Road, Portland Street and
the Northern Quarter.
Undertake improvements to the highway and pavements along
pedestrian routes, particularly on Portland Street and in the Northern
Charity Registration No. 1133526
Company Registration No. 6929240
1.6
1.7
1.8
1.9
Quarter, including well designed and regularly maintained crossing
points.
Provide additional on-street accessible parking bays near to the
restricted routes.
Provide accessible parking bays, adjacent to or shared with loading
bays along the restricted routes, which will be made available to
delivery vehicles.
Provide clear access to restricted areas for blue badge holders where
access is required to premises and services for disabled people.
Consider a change of policy, allowing the inclusion of Blue Badge
holders in the list of vehicles allowed access to the restricted routes.
2.
Introduction
2.1
MDPAG recognises the importance of improving public transport,
reducing carbon emissions and encouraging healthy modes of
transport around Manchester. However, we have been aware from our
members, from access surveys undertaken for Manchester City
Council and from other disabled people who contact us, that public
transport and travelling around the highways and pedestrian routes in
Manchester can be very hazardous, frustrating and frightening for
some disabled people. We represent disabled people with a range of
impairments and who may have multiple impairments, including visual
and hearing impairments, mobility impairments including wheelchair
users, have learning difficulties or cognitive impairments, neurodiverse people, people with mental health issues and people who have
long term health conditions.
MDPAG welcomes the proposals to improve pedestrian and transport
facilities along the routes.
Our response to the consultation identifies some concerns raised by
disabled people around elements of the bus priority proposals, which
could seriously affect the health and safety of disabled people and
create barriers which would make areas of the city and the use of
public transport impossible for some disabled people to use. The lack
of safe crossings around Piccadilly Gardens have already made this
area unsafe for some disabled people, who avoid visiting this area.
(Ref. The Key Routes Access Surveys, carried out for Manchester City
Council). For example, some of the proposals appear to make it
impossible to drop off disabled people at the Piccadilly Interchange to
use buses or the Metrolink service.
The issues we raise are also relevant to the safety of children using
certain routes and of older people, who may have impairments but do
2.2
2.3
2.4
2.5
2.6
2.7
2.8
2.9
not identify as disabled people. This is relevant to Manchester’s status
as a UN declared ‘Age-Friendly City’.
The concerns raised by MDPAG and our inability to endorse all of the
proposals are also informed by the lack of design detail in the
proposals and the limited information about access to premises for
blue badge holders and disabled people who are currently dropped off
to venues, including voluntary sector, health service, public sector and
private sector services by private cars or private hire cars.
We strongly urge the Transport for Greater Manchester Committee
members to ensure that a disability impact assessment is carried out
before approval is given to the proposals, which would include a
detailed assessment of the safety for disabled people and other
pedestrians of the “Dutch style” cycle lanes. It should also include
parking and access to buildings and services for disabled people
within 50m of the parking and drop off points, as recommended in
Design for Access 2, the Council’s approved policy on inclusive
design, and the location of additional parking for blue badge holders
and private hire cars.
Some buildings, providing health and support for disabled people or
people with health problems and community buildings, within the areas
of the proposals, would also need to ensure access to and accessible
parking near to their entrances, as outlined in Building Regulations
(Part M 2013). This is also relevant for disabled people who want
access to private and commercial services.
The impact assessment should also consider the impact of the
proposals on crossing points, particularly along Portland Street,
Minshull Street and along Upper Brook Street because of the
anticipated increased volume of traffic. Currently, there is a lack of
controlled crossing points which use visual and audible signals to
identify a safe time to cross along some of these routes and
improvements to these crossings have not been included in the
proposals or the engineering drawings for the city centre.
(Ref: http://www.tfgm.com/buspriority/pages/website/pdfs/City-centreengineering-drawing-May2013.pdf, and other engineering drawings
included in the consultation documents).
At the consultation meeting held with TfGM on Friday 5th July,
disabled people identified continuing problems with using buses,
including the behaviour of some bus drivers who discriminate against
disabled people, the lack of and unreliability of accessible buses on
many routes around Manchester and the inability or unwillingness of
the bus operators and TfGM to deal effectively with complaints. This
leads to many disabled people feeling unable to use buses and
instead, having to rely on friends, family, the use of blue badges and
2.10
2.11
taxis, including private hire taxis. It was explained that these issues will
be considered as part of the renegotiation of the Greater Manchester
Quality Bus Partnership. However, it was unclear to participants that
this will definitely lead to improvements in access to public transport. In
particular, it is vital that access to all parts of Manchester by blue
badge holders is retained.
A further recommendation made at the meeting by MDPAG was that
the restricted lanes, planned to be available only to buses, hackney
cabs, emergency vehicles and cyclists, should also be available to
blue badge holders to ensure that access to premises and services is
maintained. This was also part of our responses to the local and GM
Transport Plans. Many cameras operating on city centre highways
could be used to monitor this as they do for use of bus lanes and
speeding. It was explained by TfGM to the meeting, that this was a
policy decision made by the TfGMC. MDPAG proposes that this policy
be adopted by TfGM to support the accessibility of the bus priority
scheme.
MDPAG is willing to contribute to further discussions, access surveys
and design developments in order to ensure that any proposals do not
create additional hazards for disabled people and can support, in the
future, proposals which would make Manchester a more accessible
city and more eligible to apply for the European Accessible Cities
Award, launched by the European Commission in May 2010, which
includes the accessibility of transport schemes.
3.
Restriction of routes to general traffic, including blue badge
holders
3.1
Oxford Road
3.1.1 Under the current proposals there are sections of Oxford Road which
will not be accessible to blue badge holders and disabled people who
are unable to use buses or taxis, notably the Manchester Museum
because of the proposed removal of the small amount of parking
currently nearby. Although TfGM have advised that accessible parking
will be made available through barriers, by the University of
Manchester, from Cambridge Street, this may not be clear to disabled
people. MDPAG proposes that there is a clear signage policy to
ensure that access to public facilities are easily available to disabled
people and clearly identified along Cambridge Street/Lloyd Street
North/Upper Lloyd Street.
3.1.2 We note that there is an additional accessible parking bay provided in
the proposals for disabled people on Grafton Street, but recommend
3.1.3
3.14
3.15
3.16
3.17
3.2
additional bays to allow people who are not visiting the hospital to
access other services in the area on Oxford Road.
There is a centre for people with sickle cell disease on Denmark
Road/Oxford Road, who are likely to need additional accessible
parking. We note that an additional accessible parking bay is planned
for Denmark Road, but because it is likely to be used by users of the
Art Gallery and other services along Oxford Road, we recommend that
this provision is increased to at least two bays, particularly as the bays
currently in front of the Art Gallery will be removed.
For traffic moving south from the city centre, it is not currently possible
to turn right along Upper Brook Street to access various buildings,
including the Aquatic Centre and university buildings, and most traffic
currently uses Oxford Road. Once this has been restricted, there
appears to be no way that people will be easily able to access this
area. It is recommended that if Upper Brook Street is to be extended,
as previously agreed by TfGM, that more right turns are incorporated
into the scheme from Upper Brook Street and that it is possible to turn
right into the Aquatic Centre car park.
MDPAG welcomes the proposal to maintain a route for general traffic
along Oxford Street past the St James Building and the Palace
Theatre, and would recommend increasing the accessible parking
bays on Oxford Street from 1 bay to 3 bays. It is hoped that additional
parking is also maintained along this route.
The consultation proposes better facilities for pedestrians at junctions
and crossings. MDPAG would welcome further controlled crossings for
pedestrians and further details of the proposals, and would be willing
to comment on any designs and facilities, particularly in relation to
meeting the needs of disabled people.
MDPAG has serious concerns about the proposals for “Dutch style”
cycle lanes, outline in section 3.
City Centre
3.2.1 MDPAG welcomes the commitment to improve pedestrian
crossings along this route but we understand from the consultation
that some crossings have not been included for improvement. We are
concerned that the proposals will mean that the traffic flow into
Charlotte Street from Portland Street will be increased with many more
buses using the route and currently there is no controlled crossing for
pedestrians. This is particularly hazardous for visually impaired and
hearing impaired people and also for people with mobility impairments
and children. We urge TfGM to install a controlled crossing over
Charlotte Street along Portland Street, with audible and visual signals.
3.2.2 Similarly, there is no controlled crossing point, accessible from both
sides over Minshull Street, along Portland Street. As the route will
divert traffic into this street, MDPAG urges TfGM to install a controlled
crossing with audible and visual signals.
3.2.3 There is also a need for a controlled crossing at Nicholas Street for
pedestrians as there will still be a stream of traffic crossing over from
Sackville Street and additionally, cyclists able to turn left from Portland
Street.
3.2.4 There are also difficulties for pedestrians crossing over Portland Street
from Piccadilly Gardens and from the bus stops at the top of Portland
Street to the Thistle Hotel area as there are no controlled crossings
and no new crossings identified in the plans. Many pedestrians
currently cross in this area and it is possible that this will increase with
the additional buses. It is currently hazardous for disabled people and
it is an opportunity to improve safety for all pedestrians by providing a
safe crossing point.
3.2.5 The pedestrian route along Portland Street is poorly maintained with a
number of obstacles, potholes, uneven surfaces and poorly designed
crossing points, particularly at New York Street and Charlotte Street.
MDPAG urges TfGM and Manchester City Council to improve the
design and maintenance of Portland Street, including maintenance
and provision of the street furniture, particularly as increased bus
services may increase the number of pedestrians along this route.
(Ref. Key Routes survey for Manchester City Council, MDPAG).
3.2.6 It is unclear with the increased traffic along Faulkner Street whether
parking bays will be lost. MDPAG recommends that there is a review
of accessible parking bays in China Town and that TfGM ensures that
accessible parking bays for disabled people are provided throughout
this area.
3.2.7 MDPAG is greatly concerned at the effect of the closure of the route to
general traffic down Aytoun Street to Portland Street, as this was a
way to reach the businesses along Piccadilly Gardens behind the bus
stops and was an important drop off point for disabled people,
including visually impaired people, to reach the Metrolink and bus
services in Piccadilly Gardens. The new proposals will mean that there
is no safe dropping off point for disabled people, to enable them to use
the public transport services at Piccadilly Gardens. The access points
at the other side of Piccadilly Gardens, near Market Street, are too far
away for some people to access the services and are a hazard for
visually impaired people, who would need to travel across Piccadilly
Gardens. MDPAG strongly urges TfGM to allow access to the layby
and businesses, from Aytoun Street to Portland Street for blue badge
drivers and to make it clear that access along this route is allowed.
MDPAG has been assured verbally from TfGM that this would be
acceptable, but signage needs to reflect that drivers will not be
prosecuted if they use this route for access and not as a through route.
3.2.8 The consultation video also proposes that access to some delivery
bays will be maintained along the restricted routes and MDPAG
recommends that these delivery bays should also be made available
for dropping off disabled people to these businesses and services.
Sufficient parking bays for disabled people should also be provided
near to these business and services.
4.
Dutch style cycle lanes
4.1
MDPAG are unable to support the development of these cycle lanes
as no detailed designs were available to reassure disabled people that
they would not be at risk from cyclists. The design proposes that
disabled people, and other pedestrians, including children and older
people, would have to cross over a cycle lane to travel to and from the
bus stop and the pedestrian route, while cyclists are moving along the
lanes. It is envisaged by TfGM that the numbers of cyclists will
increase along the route and at certain times of the day, there could be
a constant stream of cyclists travelling along the lanes.
There is ample evidence from other cycle lanes and routes, that many
cyclists who would be travelling along the lane, are unlikely to stop for
pedestrians and that they do not consider that some pedestrians are
not able to see them coming, are unable to hear any warnings or are
unable to move quickly. People with no vision are unable to “negotiate”
a safe crossing with cyclists, which is why Manchester City Council
agreed not to support shared spaces, for pedestrians and traffic,
including cyclists, in Manchester as part of its policy.
An earlier Manchester transport strategy agreed a hierarchy of road
users, with pedestrians as a priority. Without a controlled crossing,
which would indicate to disabled people that it is safe to cross over the
cycle lane, there are likely to be a number of collisions and accidents,
and many disabled people will just avoid the route, making the service
inaccessible to them and effectively excluding some disabled people
from this service. The cycle lane is also hazardous to cyclists if they
collide with pedestrians. Parents and children will also find this
proposal extremely worrying, as children often wander around “safe”
pedestrian routes and are unable to anticipate problems.
The consultation notes that “all accessibility requirements will be
provided for in the final design”, but this comment does not provide
sufficient information for disabled people to judge the safety of the
provision.
4.2
4.3
4.4
4.5
4.6
4.7
5.
At the consultation meeting on 5th July, TfGM recognised the need for
visual and audible signals for disabled people to feel safe while
crossing these lanes and for accidents to be avoided, but were unable
to provide the technological or design solutions. Without these detailed
proposals and specifications, it is not possible for MDPAG to support
the provision of these lanes, as the lanes are considered extremely
hazardous to disabled people and would create additional hazards to
existing pedestrian access to and from bus stops along pedestrian
routes.
MDPAG members and other disabled people from other organisations
present at the consultation meeting, were informed that the principle of
the cycle lanes had to be agreed before further design work was
carried out. We consider this to be an extremely bad approach as the
final design solutions may still be hazardous. We were also told that if
there were accidents once the lanes had been installed, TfGM would
review the situation. MDPAG considers this to be ethically and
financially a bad strategy, and that it might be in breach of equality
legislation and building regulations. MDPAG very strongly urges TfGM
not to approve these cycle lanes until further design work has been
undertaken and disabled people consulted.
TfGM suggested that one or more designs could be tested and
MDPAG would welcome this strategy, but strongly recommends that
the design and testing process is undertaken and a report provided for
the TfGMC, before the principle of the cycle lanes is agreed.
MDPAG would be pleased to facilitate further discussion and
consultation with disabled people to ensure that the proposals are as
inclusive as possible.
Flick Harris,
Chair, Manchester Disabled People’s Access Group (MDPAG),
on behalf of members and trustees of MDPAG
July 12th 2013