Petition on Shared Space from NFBUK
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"Dear Prime Minister,
Further to our petition on the 24 April 2018 we are re-petitioning the UK Government on the problem of shared space road design. Although we welcome the Government acknowledging that shared space is a problem for disabled people, we, along with the other organisations which have signed this petition, are very concerned regarding how the issue is being managed. We therefore appeal to the Government to enforce Equality Legislation and to prevent any further discrimination against disabled people through the use of shared space road design by undertaking the following actions:
- Call an immediate halt to the introduction of shared space road layouts in residential and urban locations. This should include schemes currently going through planning, which should be reassessed to ensure they provide accessible and inclusive designs.
- Ensure all existing shared space schemes undergo an urgent accessibility audit and remedial works to ensure safe access for all.
- Ensure all shared space schemes under construction or let for construction are immediately reassessed to establish how accessibility can be enhanced.
- Fully implement the recommendations of the Women and Equality Select Committee Report: Disability and the Built Environment: Building for Equality, published by 19 April 2017 on shared space (1).
These requests are not new and are based on recommendations and requests set out in Ministerial letters, parliamentary reports, position statements and government consultations, some of which have emerged since our petition on the 24 April 2018, which include:
- Rt Hon Kit Malthouse, Minister for Housing, letter to Maria Miller MP, Chair of the Women and Equalities Select Committee, 4 September 2018. He wrote that while the shared space “pause” directive applies to new schemes, authorities may wish to consider how schemes under construction or where a contract has been let for construction can be adapted to enhance accessibility (2).
- Rt Hon Nusrat Ghani, Parliamentary Under Secretary of State, Department for Transport (DfT) wrote a letter on 25 July 2018 to all Local Authorities requesting a pause to all level surface shared space and alerting them to the withdrawal of Guidance supporting shared space Local Transport Note 1/11 (3).
- The DfT’s Disabled Persons Transport Advisory Committee stated that shared space discriminates unlawfully and is contrary to Section 21 of the Equality Act 2010, published in its position statement on the 13 June 2018 (4). This report also highlighted the fact that shared space affects not only blind people but has negative effects on many other people including people with neuro-diverse or mental health conditions or those with learning difficulties,
- Rt Hon Sarah Newton, Minister of State for Disabled People, Health and Work, raised serious concerns that shared space is contrary to the Equality Act 2010 in letters sent to the Secretary of State Rt Hon James Brokenshire for Housing, Communities and Local Government and to the Rt Hon Nusrat Ghani Parliamentary Under Secretary of State, DfT 15 May 2018 (Attachment 1).
- The House of Commons, Women and Equality: Disability and the Built Environment Report, published 19 April 2017 (1) called for shared space to be halted and all existing schemes to be reviewed and modified.
- Lord Holmes Report July 2015 called for shared space to be halted and all schemes audited (5).
We recognize that the UK Government did take some action to halt shared space road design when it called for a pause on the use of level surface road layouts on 25 July 2018 (2). However, an amendment set out in a letter from the Minister for Housing and Planning and the Parliamentary Under Secretary of State for the DfT, sent to all Local Authorities in England on the 28 September 2018 (Attachment 2), served to reduce coverage of this pause. The advice in that letter stated that the pause was now limited to level surfaces in high pedestrian / traffic areas such as those found in high streets. The letter also mentioned a number of design features and approaches which when used would allow elements of shared space road design to be used in new schemes.
This definition was unexpected, unfair and unjustified. The revised advice given to Local Authorities is not sufficient to protect disabled people from the problems created by shared space designs and hence from discrimination as defined under the Equality Act 2010. It is clear that the discrimination created by shared space road design is not limited to level surfaces in busy town centres, but also affects pedestrians where shared space paths and bus boarders have been created as part of in cycle schemes, where the pavement and cycle lane are the same height and/or the cycle lane is directly in front of the bus stop.
This impact is clearly illustrated by one of the petitioners, Michelle Hough, who is fighting against a shared space road layout in a residential area. Her 11 year old daughter, Millie, has Alstrom Syndrome, which has left her registered blind and with hearing loss. They live on the edge of a new housing estate being built behind her family home in St Agnes, Cornwall. Millie has a buddy Guide Dog and the new scheme will have no pavements. Assistance dogs are trained to halt at kerbs; as the new scheme will have no separate pavements or kerbs this will prevent Millie from independently walking around her neighbourhood to visit friends, or indeed to visit the dog-walking area close to her home.
Michelle has raised these serious matters for the past two years with Cornwall Council, Sanctuary Homes and Homes England and has repeatedly asked for pavements to be included in the scheme; her requests have been completely ignored. She took to blocking the building site with her car in September 2018 to raise concerns (6). Her story brings home the devastating impact the shared space policy has on families with disabled children - and more importantly, how this could be prevented by the simple action of the Government calling a halt to the use of shared space designs, as requested in this petition.
It is clear that the advice given to Local Authorities on the 28 September 2018 (Attachment 2) on the location of shared space pause and types of urban design was misjudged. We ask you to urgently address this concern and to write to all Local Authorities to remind them of their obligations under the Equality Act 2010 and to remove the limitations set out in that advice.
It is also our understanding that the research promised in the same letter, while being described as being aimed at creating places that are accessible, inclusive and well designed, is limited to high streets. If our understanding is correct then we would also ask why the research is being limited to high streets please?
Many of the problems created by the use of shared space can be resolved by providing pedestrian protection through use of a clearly defined standard height kerb in residential or urban areas where there are moving vehicles (including cyclists), to give pedestrians safe routes through which they can access their homes and local amenities for shopping, work and social life. This, along with adequate provision of controlled push button crossings, will ensure disabled people can independently access these areas.
Finally we would also request your personal intervention to help in ensuring that pavements are added to the St Agnes Housing Estate in Cornwall during its final phase of construction, to ensure that Millie, her Buddy Guide Dog and her future Guide Dogs will be able to access the area without having to share space with moving vehicles. The scheme is Government Funded by Homes England and it is our understanding that pavements could still be added. Millie’s future independence depends on the installation of pavements and we ask for this matter to be resolved as a matter of urgency.
We thank you in advance for your urgent attention to this matter and look forward to your reply.
Sincerely yours,
Andrew Hodgson President
National Federation of the Blind of the UK
