(Especially for Transport Infrastructure Ireland, National Transport Authority, and Local Authority Planners).
The below are based on the principles set out in detail in VVI’s Manual of Accessible Planning for Pedestrians (VVIMAPP), with some recent additions which have resulted from the lived experience of VVI members. It is based on the Human Rights approach, including the principles of universal access, as opposed to ideology or majoritarianism.
Quick Contents.
- Consultation with DPROs.
- Accessible Communication of Plans.
- Access All Areas For Certain 4-Wheeled Vehicles.
- Segregated Safe Zones for Pedestrians.
- Safe Pedestrian Crossings.
- Clearance on Footways and Pedestrian Desire Lines.
- Wayfinding in Open Areas.
- Access to Public Transport.
- Works and Maintenance.
1. Consultation with DPROs.
In 2018, Ireland ratified the UN Convention on the Rights of People with Disabilities (CRPD). A general obligation of this Convention is that Disabled Persons Representative Organisations (DPROs) – must be “closely consulted with and actively involved” in all consultations affecting disabled people (CRPD, Article 4 (3).
In its General Comment No. 7 (GC7), the UN Committee explained that this means distinguishing DPROs from all other civil society organisations in consultations (cf. GC7, paras. 13, 49, etc.), and that DPRO views and opinions be prioritised over all other civil society organisations (ibid., paras. 13, 23, 56, etc.). Consultations should be continuous, and not one-off (para. 32), and ultimately, co-design is what is envisaged when one looks at the totality of General Comment 7.
Voice of Vision Impairment (VVI) is Ireland’s DPRO specifically regarding issues relating to visually impaired people. As such, VVI has a central role to play in terms of disability-proofing our streetscapes and other built environment.
2. Accessible Communication of Plans.
Any of the below features, where relevant to a design, must be detailed in the textual description of the drawings and other plan descriptions. This should also include, at the beginning of a description, a summary of the changes to be experienced by each mode of transport if the plan is implemented – in order of hierarchy (segregated pedestrian space, segregated cyclist space, public transport access (including SPSVs), and private 4-wheeled vehicle access (including deliveries, local permits, and blue badge, with proximity of nearest accessible parking bays).
Useful resources for accessible communications, generally, are found at:
VVIMAC – VVI’s Manual of Accessible Communications
https://vvi.ie/our-policies/accessible-communications-policy/
including
Electronic Documents.
https://vvi.ie/our-policies/accessible-communications-policy/6-electronic-documents/
For an excellent example of screenreader-accessible drawings, see:
2022, Dublin City Council, Duke/Anne Street Part 8,
https://consultation.dublincity.ie/housing/duke-st-anne-st-sth-part-8/
Section 14. Text description of drawings-Accessible version.docx
https://consultation.dublincity.ie/housing/duke-st-anne-st-sth-part-8/supporting_documents/14.%20Text%20description%20of%20drawingsAccessible%20version.docx
3. Access All Areas For Certain 4-Wheeled Vehicles.
3.1. Basic Principle.
3.2. Limited Access Instead of “Pedestrianisation”.
3.3. Permiability Between Cycleways and Main Carriageway.
3.1. Basic Principle.
Blue-badge vehicles, small public service vehicles (SPSVs), local traffic, and home deliveries must be able to access all streets in a freeflowing-legible manner: i.e., in so far as is possible, to be able to make door-to-door journeys. This is because the ‘Active Travel’ modes are, to varying degrees, inaccessible to much of the population.
3.2. Limited Access Instead of so-called “Pedestrianisation”.
Blue badge and SPSVs vehicles need to access all areas in so far as is practicable. This means that so-called ‘car-free’ or ‘pedestrianised’ zones need to provide access for such vehicles for disabled drivers and passengers to not be excluded from such zones. This is a matter of Human Rights versus recent planning orthodoxy.
3.3. Permiability Between Cycleways and Main Carriageway.
Many disabled people (including visually impaired people) necessarily rely on door-to-door transport, including by private (e.g., blue badge) vehicle.
The further away the drop-off point, the more difficult it is to safely locate the destination for visually impaired and other disabled people. If the vulnerable pedestrian is also required to cross a cycleway in order to find that destination, this poses a dangerous gauntlet or barrier for them to surmount, as well as making accessibility of the final destination more difficult, if not impossible.
Similarly, visually impaired people may veer off course while crossing a road at a designated crossing, and find themselves encountering a cycleway kerb, which is both disorientating, as well as being a trip-hazzard. It should also be remembered that while pedestrians are entitled to cross a carriageway within 15 meters of a designated crossing, for accessibility reasons, a visually impaired person may not be able to locate the exact location of the crossing, and so, end up inadvertently finding the trip-hazzard kerbs delineating cycleways from the main carriageway.
Accordingly, delineating cycleways from the main carriageway by use of kerbs or other barriers is necessarily disablist planning – disability by design, and is, thus, the opposite of universal design.
By contrast, segregation by road-markings are non-discriminatory if done with close consultation and active involvement of VVI and planners.
4. Segregated Safe Zones for Pedestrians.
4.1. Introduction.
4.2. Kerbed Segregation of Pedestrians.
4.3. Differential Surfacing.
4.4. No Parking Protected Cycle Lanes.
4.5. Alternatives to Bollards.
4.6. High Contrast Colour Schemes.
4.7. Adequate Lighting.
4.1. Introduction.
Pedestrians must be segregated from all vehicles (including cyclists) by design. This means no shared space in any form and under any other name.
4.2. Kerbed Segregation of Pedestrians.
By default, This means front-facing upstanding kerbs of a minimum of 100mm delineating footways from all other transport lines. Because of erosion and illegal mounting of footpaths by cyclists, we recommend the Northern Irish standard of kerbs being 125mm rise from the carriageway.
Note that guide dogs are liable to ignore any kerb lower than 60mm, and just keep walking, possibly bringing their owner directly into oncoming traffic.
4.3. Differential Surfacing.
Where streets are too narrow to have footways of 2m wide on both sides, “differential surfacing” is the next best alternative. Note that this is not the same as hazard strips, guidance strips, or drainage as guidance, all of which are inadequate.
Differential surfacing works on the principle of the footways being smooth and the carriageway being more roughly hewn, e.g., by using small cobbles. Differential surfacing does not necessarily mean use of differing materials.
Use of the more roughly-hewn effect for the carriageway means that the wheels of vehicles are more audible. It also means that a visually impaired pedestrian walking on a footway will have useful landmarks for knowing when we are crossing (otherwise flat or flush) junctions.
4.4. No Parking Protected Cycle Lanes.
“Parking protected cycle lanes” should not be considered, because they are intrinsically dangerous to vulnerable passengers and drivers crossing from a parked car to a footpath or in the opposite direction.
4.5. Alternatives to Bollards.
Bollards are usually very difficult to detect for visually impaired people, and so, frequently cause collision between bone and steel – leading to injuries. As such, bollards should never be used if there’s a chance of visually impaired pedestrians colliding with them.
By contrast, kerbs, raised beds or planters can serve a similar function while also providing visually impaired people with orientation (which bollards cannot do).
A plan B, i.e., less preferable, is that bollards exist in a woodchip surface area, so that we know to avoid them, and so that we have a landmark for orientation.
4.6. High Contrast Colour Schemes.
High contrast colouring between footways and other traffic zones should be intrinsic to any design. Remember that your idea of what is high contrast, and that of a visually impaired person may differ widely, and it is our perspective which matters.
4.7. Adequate Lighting.
Footways must be well lit at all times. As with other features, a planner’s idea of what constitutes sufficient lighting may differ widely from the perspective of a visually impaired person. For reasons of universal design, as well as of general public safety, the brightness of the nocturnal streetscape in city and town centres should, in so far as is practicable, seek to emulate daylight conditions, while minimising light-polution.
This includes the principle that the more even the light, the better, since dark stretches and shadows make safe navigation more difficult by visually impaired people who have useful sight.
In the interests of fuel conservation, targeted lighting and use of LED technology are recommended, and that an eye always be kept on fuel conservation technologies and positioning, but always within the parameters of universal design – including the lighting needs of visually impaired people.
5. Safe Pedestrian Crossings.
5.1. Always Dished (or dropped) Crossings.
5.2. Guidance to Signal Crossings.
5.3. No ‘raised’/’table’ Crossings.
5.4. Audio Signal Crossings.
5.5. Limited Use of Uncontrolled Crossings.
5.6. Placement of Signal Poles.
5.7. No Twocan Crossings.
5.8. Differential Surfacing on Carriageways at Crossings.
5.9. No Staggered Crossings.
5.10. No Rainbow Crossings.
5.1. Always Dished (or dropped) Crossings.
As per S19 of the Equal Status Act (2000) there must be dished crossings at all junctions. We extend this to say there must be dished crossings at all designated crossings, as is currently the norm.
5.2. Guidance to Signal Crossings.
Where possible, blistered tactile should run from the inshore to a signal crossing. The type of blistered tactile must be detectable by visually impaired people with low sensitivity in their feet (such as those with diabetic neuropathy), as well as being adequately comfortable for wheelchair users.
For the sake of consistency and reliability, blistered tactile should only ever be used to indicate the location of crossings, and must not be used for any other information.
5.3. No ‘raised’/’table’ Crossings.
De facto, dished crossings means no “raised” or “table” crossings – otherwise known as “continuous footpaths/sidewalks,” which are hazardous to many visually impaired people.
Raised crossings are often problematic regarding orientation, since previous orientation landmarks such as kerbs and dished crossings are no longer present. It is not just long-cane-users who experience this serious disablement, but guide dogs are trained to use kerbs as the key reference points, and without kerbs and dished crossings, they are prone to bringing their handler off course, especially where there are “raised junctions.”
Some of us can lose our balance if we inadvertently stray onto the sloped edge of the raised/table crossing. Tactile paving, such as corduroy, delineating the sloped edge on either side, is not a solution, since they are particularly prone to erosion, given the amount of traffic – including heavy goods vehicles and buses – going over them.
5.4. Audio Signal Crossings.
Accessible Pedestrian signal crossings should be the default at all pedestrian crossings. Apart from the real safety risks of silent crossings, if we do not feel safe, we will be less likely to visit an area (Holmes Report, 2015). This means the default provision of parabolic audio and haptic signals accessible to visually impaired people without any need for extra technology (such as portable devices).
Locator beacons should be clearly audible, regardless of ambient noise. This is more difficult where the footpath is too wide.
5.5. Limit Use of Uncontrolled Crossings.
Since signal crossings should be the norm, zebra crossings should be the exception. However, where zebra crossings exist, they too need to be dished, and if belisha crossings are used, the top signal light needs to be permanently powered, not solar-powered, since the latter type cannot last one third of a winter night.
5.6. Placement of Signal Poles.
Traffic lights should be to the right of the dish, and no more than 10cm in from the outshore.
5.7. No Twocan Crossings.
Twocan crossings are tantamount to shared space, and so should not be considered, since they endanger the safety of vulnerable pedestrians. An adult cyclist may not be able to react in time to the unexpected movement of a vulnerable pedestrian; but this case is even more stark when speaking of cyclists under the age of 14.
5.8. Differential Surfacing on Carriageways at Crossings.
A visually impaired person can veer off course while crossing a road. Use of smooth crossing surfaces at crossing zones on carriageways, with small cobbles (for a rougher surface) for 50 meters either side of such crossings (and as smaller squares at centre of crossroads), will help keep visually impaired pedestrians on track when crossing, but will also help us hear oncoming vehicles (including where engines are too quiet).
5.9. No Staggered Crossings.
Staggered crossings, i.e., pedestrian islands that are railed or caged off, apart from two small entry/exit gaps, are confusing to many visually impaired people, e.g., in terms of locating the entrance, and in terms of orientation, especially if one looses one’s way while trying to find the entry/exit point.
Furthermore, there is no empirical evidence that these devices contribute, in any way whatsoever, to the safety of pedestrians.
As such, they should be phased out, and replaced with crossings of universal design.
5.10. No Rainbow Crossings.
At least since 2022, a trend has emerged where local authorities have been using rainbow colouring as underfoot signage for crossings of carriageways. While the motives of solidarity with the LGBTQIA+ community are well-meant and laudible, it is as reckless to play with traditional markings for road-crossings, as it would be for any other signage.
Non-pedestrian road-traffic, including cyclists, can be colour-blind, and so be confused by the markings; and similarly, any such cyclist or driver from out of town might also be confused by this novel design.
Pedestrians with low vision may also be confused by the new markings, and this may get even more difficult as the colours erode through natural weathering.
As with all things safety-related, the precautionary principle should be used. Consider rainbow flags in certain positions, instead.
6. Clearance on Footways and Pedestrian Desire Lines.
6.1. Height Clearance.
6.2. Clear Width.
6.3. Street Furniture.
6.4. Parking (including of Bicycles).
6.5. Inshores.
6.6. Outdoor Dining.
6.7. Hazzards of “Flexi-Zones”.
6.8. Charging Points.
6.1. Height Clearance.
There should be a height clearance of at least 2.4m – e.g., in relation to signage, posters, hanging-baskets, ‘for sale’ signs etc. This also means strict enforcement of regulations, including with regard to private trees encroaching on the public realm, and the maintenance of all plants under the responsibility of the local authority.
In other public spaces, slanted girders, backs of stairs and footbridges need to be closed off from the public where the height clearance is less than 2.4m. This is because many visually impaired people cannot see them, and end up sustaining head injuries as a result of the subsequent collision.
6.2. Clear Width.
Where possible, there should be a 2m width clearance on kerbed streets, also meaning no drains in that clearance.
Footways wider than three metres can be difficult to navigate by visually impaired pedestrians, and can appear akin to an open space, with no useful landmarks or orientation for us. As such, on wide streets, we recommend the imaginative use of raised beds or planters, as well as other street furniture such as properly plynthed, or boundried, benches (6.5, above).
6.3. Street Furniture.
On narrow streets, the placement of street furniture should depend on close consultation and active involvement of DPROs (with VVI having a special position, along with Physical Impairment Ireland (PII), given our particular areas of speciality and constituencies).
- on kerbed footpaths, street furniture, such as poles, bins, or advertising hoardings (if they must exist), should be on the same consistent line, just in from the outshore.
- all street furniture should have the widest point at the base, so that it can be detected by a long cane. We recommend that all street furniture, except for traffic lights, should have a 20cm rim at the base, as boundary for combinations of hard rubber, woodchip or sand/gravel as differential surfacing to indicate that a potential collision hazard is close by.
6.4. Parking (including of Bicycles).
Parking of any vehicles, including bicycles, must never be on the footpath. Such parking should be beyond the outshore, which is much more doable when the footpath is not made unnecessarily wide.
6.5. Inshores.
Effort should be made to make inshores as smooth as possible. For example , a pole adjacent to an inshore wall can cause a long cane to snag. Such features can be mitigated by, in this case, surrounding the base of the pole with mulch/gravel, like the bicycle stands at Heuston Station. Where there is a total rebuild, such poles should be behind (on the inside of) the wall, where possible.
Differential surfacing should be used to differentiate the inshore at wide entrances, e.g., to certain premises run by the Office of Public Works. Once again, this involves the footway remaining smooth, but a rougher or cobbled effect marking the inshore so that we can maintain direction.
Where such long entrances are private, a speed-bump could represent the inshore.
6.6. Outdoor Dining.
Where permission has been granted for outdoor dining, this activity should always be on the inshore, with consistent and solid boundaries, with height clearance of 2.4m on on awnings and canopies etc. Such windbreaking boundaries should always have a solid base at ground level, so that they can be detected by long-cane users.
Dining facilities further out on the street impedes our navigation, and massively increases chances of collision with those carrying scalding substances from the dining area across the footpath to the outshore or middle of the street (where dining areas can be placed).
6.7. Hazzards of “Flexi-Zones”.
Flexi-Zones, or “flexible zones” is the concept that a particular zone – pedestrian or otherwise, can also have a change of function, for example, that it can become a pop-up market or entertainment venue, etc.
Where such pop-up events require traffic diversions, such as change of bus-routes, this can disorientate a visually impaired person, and such lack of certainty is likely to put us off travelling at all if we know about it in advance.
Where such pop-up events are expected to occur in pedestrian-only zones, this can also be very disorientating for, and exclusionary of, visually impaired people. The only way such pop-up events will not impede visually impaired people is if clear segregation of pedestrian-only zones (i.e, footways), remain clearly delineated from the event space (e.g., from stalls and podiums etc.), to allow for safe accessibility of through-traffic of pedestrians. For more information, see all other subsections in this section 6, as well as “Differential Surfacing” (4.3), and “Wayfinding in Open Areas” (7).
6.8. E-Vehicle Charging Points.
Where e-vehicle charging points are planned, the cables must never be a trip hazard for pedestrians. E-vehicle charging points should be accessible to all visually impaired people, as future-proofing.
7. Wayfinding in Open Areas.
7.1. Introduction.
7.2. Optimal Guidance System.
7.3. Plan B.
7.4. Need to Limit Footway Width.
7.1. Introduction.
In open areas, such as plazas, visually impaired people need tactile orientation. Depending on the context, and in close consultation and active involvement of VVI and other DPROs, this tactile orientation can be of two varieties.
7.2. Optimal Guidance System.
Where congregation for events such as concerts are not envisaged, such as in plazas at the front of public transport hubs, raised beds or landscape planters should be used to guide pedestrians in the desire line. This creates avenues (for our orientation), as well as being good for the greening of the urban environment.
7.3. Plan B.
Where large spaces exist with the potential for public events etc., this tactile orientation may be underfoot – through “differential surfacing”. For example, the use of contrasting small cobbles for the general area, with smooth surface for the footway guide. Compare South William Street in Dublin 2 or the Front Square of Trinity College Dublin, which are far from perfect, but demonstrate the general concept.
In this context, our preference is that the pedestrian desire-lines or main footways be smooth, with all other parts being small cobbles or roughly-hewn finish. The small cobbles, if raised at an angle to 10cm at the interface with the footways, would further help to delineate footways from the general area.
7.4. Need to Limit Footway Width.
There appears to be a trend to wider footways, with the presumption that this is necessarily good for pedestrians and makes life more difficult for four-wheeled-vehicles, which generally lose space as a result.
On the latter point, those who have limited or no access to active travel modes depend on four-wheel vehicle access to their entire community (see A.3 above).
However, visually impaired pedestrians find it much more difficult to navigate wide open spaces, such as those caused by footways wider than 3m.
As such, width of footways should be based on current and expected footfall ratios, and if wider than 3m, raised beds and differential surfacing need to be combined to make sure that we have landmarks to orient ourselves by at all times.
8. Access to Public Transport.
8.1. Distribution of Bus Stops.
8.2. Safe Access to Public Transport.
8.3. Indicator Strips.
8.4. Warning Tactile for Steep Drops.
8.5. Bus Stop Poles and Shelters.
8.6. Help Points and Other Orientation at Stops.
8.1. Distribution of Bus Stops.
8.1A. Distance to A Bus Stop.
8.1B. Bunching/Clustering.
8.1A. Distance to A Bus Stop.
In urban areas, no pedestrian walking on a street footway should be more than 400m from the nearest bus stop, but 200m should be aimed for, where possible. This is because many people have mobility impairments, for a variety of reasons.
8.1B. Bunching/Clustering.
Where too many buses are expected to stop in the same area, buses often are not able to pull right up to their designated stop, and often, even cannot pull into the kerb, at all, meaning that intending passengers have to make their way out onto the carriageway to get on a bus. Such a manoeuvre presumes a fair degree of sight in order to navigate one’s way, independently, to and from the bus doors; or even to see that the desired bus has come in at another stop, or out on the carriageway.
Bus stops must have ample space, and realistic timetabling to make sure that bunching or clustering does not occur. This may also include separate stops ffor tour buses, and good strategic planning in terms of buses and heavy traffic from other vehicles.
8.2. Safe Access to Public Transport.
A passenger should not have to cross a cycle lane in order to board or exit any form of public transport. For example, buses should always be able to pull right into the kerb to facilitate safe passenger access and egress.
Similarly, ‘island’ bus stops and Luas stops are disablist design, since they endanger passengers, and especially vulnerable passengers. While signal crossings can mitigate against such hazard, it is an expensive and awkward sticking plaster for what is intrinsically disablist and cyclist-first planning. Furthermore, cyclists are even more likely to break the lights when they do not have heavier vehicles to think about.
Consequently, the only safe solution for island bus stops is to have cyclists dismount at sluicegates or at platformed pedestrian crossings sloping from 100 to 160mm. Otherwise, such designs should not exist.
8.3. Indicator Strips.
Glued rubber strips should run from the inshore to the pole of a bus stop or head of a taxi-rank, or to either end of a longer public transport stop, such as a bus shelter or a tram stop.
8.4. Warning Tactile for Steep Drops.
While higher platforms, such as 160mm, are necessary to avoid vulnerable pedestrians losing their balance and falling while getting on and off buses, there should be four-losenge tiles adjacent to the rims of such steps, such as on the Luas platforms, so that we can know in advance that there is a very steep step or a bus pick-up point ahead.
8.5. Bus Stop Poles and Shelters.
Pus Stop poles should be bright yellow, and have the relevant number(s) present in raised (high contrast) print, as well as in Grade 1 Standard English braille. Also, the name of the stop should be legible in the same modes. The names of stops should also exist in the same modes at the corners of signs at tram stops, as well as at help points in tram stops and at bus shelters.
The use of ‘braille indicators’ on signage – i.e., half-moon or semicircular blobs, are unnecessary clutter, and potentially confusing and disorientating for a braille-reader, especially since they may need to find the information in a hurry.
Bus stops should have adequate seating, with shelter, where possible. Seating should be on a 20mm high plinth, with the base being at least as wide as the widest opint in the seating structure, with foot-rest space at the front. This means that it is less likely that visually impaired passengers or pedestrians will trip over the feet of seated persons, and also make the seating easier to find and to be used as a landmark by us.
An innovative design-feature, as used in bus shelters in Edinburgh, allows passengers to recharge devices via USB connections. This is particularly useful when thinking of digital connectivity in terms of wayfinding.
8.6. Help Points and Other Orientation at Stops.
At tram stops and bus shelters, there should be an easily locatable help button which is manned 24/7.
The use of a glued-down rubber tactile strip should run from the normal front point of the most forward door on the tram, to the help button in the inner side of the platform or waiting area.
9. Works and Maintenance.
9.1. Publicise Works.
9.2. Onsite Guides.
9.3. Proper Fencing of Sites.
9.4. Temporary Surfacing.
9.5. Diversions.
9.6. Temporary Signage.
9.7. Maintenance.
9.1. Publicise Works.
The works stage of all plans should be widely advertised, including in a multiplicity of accessible formats and media types, to inform the relevant population that works are imminent or ongoing.
9.2. Onsite Guides.
While works are ongoing to bring the plan to fruition, guides should be available to safely guide disabled pedestrians through work sites without delay.
9.3. Proper Fencing of Sites.
Cones and tape are wholly inadequate as fencing. Metal or plastic barriers must be installed.
9.4. Temporary Surfacing.
Where a temporary surface like tarmacadam is installed during works on a concrete pavement, it should be level (or flush) so as not to cause a trip hazard or cause vulnerable pedestrias to lose their balance.
9.5. Diversions.
Where footpath works divert pedestrians onto the road, it is essential that step free/dished access is maintained and that a temporary foot-way is protected by plastic or metal fencing to ensure pedestrians don’t interact with road traffic.
9.6. Temporary Signage.
By law, signs should be at least 2.3m clear of the ground, but we recommend 2.4m clearance to be on the safe side.
Also, works signs should always be round – since angled signs cause more injury to visually impaired people whose faces collide with them.
9.7. Maintenance.
- footways and crossings should be appropriately monitored for impediments, whether human-made or natural. For example, wet leaves or ice can cause loss of balance, and injury, and in both cases, known black-spots should be prioritised for monitoring and amelioration.
- erosion of underfoot cues, such as tactile paving, differential surfacing, and kerb-heights should be be systematically monitored through a plan that ensures coverage of all areas consistently.
- where pedestrian crossings involve technology, an accessible, flexible, and efficient reporting mechanism should be maintained in addition to regular monitoring and maintenance.