Submission on Requirements for urban buses in New Zealand 2011

The NZ Transport Agency was seeking feedback on proposed changes to the Requirements for urban buses in New Zealand (RUB), including making the RUB New Zealand’s common standard for urban bus quality used by regional councils and Auckland Transport when tendering and managing their urban bus service contracts.

Our submission on this review endorses the RUB becoming a common standard across New Zealand, asks for stronger requirements on audio/visual on-board information, and makes other blindness-specific recommendations.

Introduction

This is the Royal New Zealand Foundation of the Blind’s submission on the 2011 review of the NZ Transport Agency's Requirements for urban buses in New Zealand.

Royal New Zealand Foundation of the Blind

The Royal New Zealand Foundation of the Blind (the RNZFB) is New Zealand’s main provider of sight loss services to blind and partially sighted people. The RNZFB's vision is empowering and supporting blind and partially sighted New Zealanders to ensure that they have the same opportunities and choices as everyone else.

The RNZFB advises government, business and the community on inclusive standards to ensure that blind and partially sighted people can participate and contribute equitably. The RNZFB also provides its members with the adaptive skills they need to lead independent lives. One of the core services provided is training in orientation and mobility skills so that members can travel independently.

The RNZFB has more than 11,500 blind and partially sighted members nationwide, including many who are deafblind. The recommendations made in this submission will also benefit members of the community who have vision loss but do not meet the Foundation's eligibility criteria. In the New Zealand Disability Survey 2006, more than 71,000 New Zealanders self-identified as having a vision impairment that could not be corrected by glasses.

Accessible public transport

Providing reliable, accessible public transport options is vital for blind and partially sighted people, who often rely on public transport to get around as they can not drive. In practice, blind and partially sighted people face barriers in using buses in New Zealand. The Association of Blind Citizens of New Zealand publication "Is this the right bus?"[1]  outlines some of these barriers and the solutions needed.

Improving accessibility for people with vision loss will benefit the whole community. The Human Rights Commission's Accessible Journey [2] inquiry found that:

"all the changes that make public land transport more accessible for disabled people also improve access for non-disabled people, and therefore contribute directly to increased use of public transport."

The legal mandate for improving accessibility was strengthened by New Zealand's recent ratification of the UN Convention for the Rights of Persons with Disabilities.[3]

Requirements for urban buses in New Zealand 2011

The RNZFB welcomes the opportunity to provide input to this review of the Requirements for urban buses in New Zealand (RUB). The RNZFB provided feedback prior to the 2008 publication of the RUB, and was pleased that our feedback was incorporated well.

Detailed comments on this draft RUB follows. In summary, the RNZFB's comments are:

• The RNZFB supports making the RUB a common quality standard for all urban bus services in New Zealand, but would like to see guidance incorporated to make it easier for councils to include additional accessibility features in buses.
• The RNZFB supports the increased aisle width in this version of the RUB.
• The RNZFB suggests expanding the definition of priority seating to include the front seats opposite the driver.
• Abrupt changes in lighting can make navigation more difficult for partially sighted people. The RNZFB asks NZTA to consider specifying higher lighting levels inside the vehicle while stopped, reducing as the vehicle moves away from the stop.
• There is a need for clear on-board announcements to provide information on upcoming stops. The RNZFB would support expanding the RUB to include provision of clear visual and audio real-time information.
• The RNZFB has developed guidelines on accessible signage which contain clear, specific guidance that has been widely endorsed by the blind community in New Zealand. The RNZFB recommends that the RUB make specific reference to the RNZFB accessible signage guidelines.
• Guidance on design of the external destination display is helpful, but the RNZFB would welcome expanding this to include audio announcements of route numbers and destinations, and specific reference to the RNZFB accessible signage guidelines.
• Increasingly, self-service ticket machines or validators are used on urban buses in New Zealand. The RNZFB submits that where these are used, machines should be accessible to blind and partially sighted people.
• Future reviews of the standard should include wider consultation with disabled people and the disability sector to better understand experiences and requirements.
• The RNZFB welcomes NZTA's initiative to scope national public transport infrastructure guidelines and would welcome opportunities to partner with NZTA on this project.

Detailed recommendations

Common quality standard

The RNZFB supports making the RUB a common quality standard for all urban bus services in New Zealand as outlined in 1.2 Purpose and scope, rather than a minimum guideline.

Creating common expectations across the country will ensure that basic accessibility considerations are addressed consistently. Standard design of features will also make bus travel more predictable for blind and partially sighted passengers. In turn, this will make it easier to teach and acquire orientation and mobility skills.

The RUB consultation document comments that consistent design will help people with sensory impairments to "know what to expect and how to use the facilities on board" (p10). The RNZFB agrees that this is likely to ensure greater confidence and therefore increased usage of buses by blind and partially sighted people.

The proposed funding condition requires councils to apply to NZTA if they wish to install additional or higher requirements than those specified in the RUB. NZTA may approve such installations if they represent "value for money". It is important that this process does not become a disincentive for councils wishing to make their public transport options more accessible. The RNZFB would like to see additional guidance added to clarify that greater accessibility is part of the "value" being sought.

Access

The RNZFB supports the increased aisle width to 800mm in this draft RUB. A wider aisle provides more turning space for people with guide dogs, wheelchairs or other mobility aids.

The priority seating area as identified in section 3.1 is shown only behind the driver for those using fixed seating. People who are blind, deafblind or partially sighted and require driver assistance to identify their destination often sit at the front opposite to the driver. This helps the driver to remember their requirements. The RNZFB asks if the definition of priority seating could be expanded to include the front seats on the opposite side to the driver.

Lighting

Section 4.5 Lighting recommends a lighting level of 65 lux in the fare paying area and 12 lux forward of the priority seating area. This abrupt change in lighting will make navigation more difficult for some partially sighted people whose eyes do not adjust rapidly with changes in lighting. The lighting level in the fare paying area is recommended at 65 lux initially, but extinguished on door closure and prior to moving off. The RNZFB asks if the lighting forward of the priority seating area could be higher than 12 lux when boarding, and reduced to 12 lux when the bus closes its doors and leaves the stop.

On-board announcements

Clear audible on-board announcements are of critical importance in allowing blind and partially sighted passengers to commute independently. Such announcements should include the bus route and destination, as well as real-time updates on upcoming stops and places of interest.

As in the 2008 publication, the draft RUB includes ducting and mounting points to enable later ready fitment of electronic equipment. The RNZFB would strongly support expanding the RUB to require such electronic equipment to be installed in all urban buses, including clear audio and visual displays.

Electronic visual displays should be clear and legible, with adequately sized text, good colour contrast between text and background, and words written with initial capitals only, rather than all upper case.

Audio announcements should be clearly audible, and should ideally provide the same level of information as the visual screen. Audio announcements are important for blind and partially sighted people, but also benefit the wider public including tourists unfamiliar with the area, infrequent travellers, people with low levels of literacy or for whom English is a second language, and people who have difficulty reading information on a screen.

Internal signage

As noted in 6.0 Facilities for passengers with impairments, the Passenger Service Vehicle Rule 1999 includes requirements for signage to aid people with vision and hearing impairments.

This Rule contains very limited guidance on tactile signs, stating in part 8.5(2) that “If a passenger service vehicle is fitted with a sign that incorporates raised lettering or symbols to assist visually-impaired passengers, the letters or symbols must be at least 0.8 mm above the surface of the sign."

In 2010, the RNZFB published guidelines on accessible signage including braille, clear print and raised print. [4] The guidelines were developed in response to requests for clear guidance from the signage industry, and involved review of international best practice and consultation with RNZFB members and consumer organisations representing blind people as well as expert RNZFB staff.

If tactile signs are used in New Zealand's urban buses, the RNZFB accessible signage guidelines are the most appropriate reference to follow, as they contain clear, specific guidance that has been widely endorsed by the blind community in New Zealand. The guidelines also contain guidance on print signage design to ensure greater accessibility for partially sighted people.

The RNZFB recommends that the RUB makes specific reference to the RNZFB accessible signage guidelines.

External destination display

A clear external destination display is an essential tool for blind and partially sighted people to identify the correct bus. The guidance included in section 5.3 External destination display is helpful. The RNZFB would welcome a specific reference to the RNZFB accessible signage guidelines, which contain guidance on accessible visual design of signage.

Eye-level signage on the side of the bus adjacent to the door may be especially helpful to partially sighted people who are unable to read the signage on the front of the bus. RNZFB would support expanding this to include an audio announcement of the bus route number and destination available to passengers waiting at the bus stop. This would help blind and partially sighted passengers to identify the correct bus, which is particularly important at stops that are used for multiple routes. The iBus project in London implemented such announcements.[5]

Ticketing machines

Increasingly, self-service ticket machines or validators are used on urban buses in New Zealand. The RNZFB submits that where these are used, machines should be accessible to blind and partially sighted people. For example, machines should have tactile, audio and clear visual feedback where relevant. The RNZFB would be happy to provide further advice on design requirements for accessible ticketing machines.

Consultation

The consultation document states that workshops on the RUB were held in early 2011 with people with physical, sensory and cognitive impairments. The RNZFB is not aware of service providers or Disabled People's Organisations being invited to such workshops.

The RNZFB recommends that future reviews of the RUB should include wider consultation with disabled people and the disability sector to better understand experiences and requirements. This could include working with the disability reference groups that have been established by local government around the country, such as Auckland Transport's Accessibility Advisory Group. It could also include working with service providers including the RNZFB to disseminate information.

National public infrastructure guidelines

The RNZFB welcomes NZTA's initiative to scope a project to develop national public transport infrastructure guidelines, as outlined in section 1.2.3 Items not included. The RNZFB would welcome opportunities to partner with NZTA on this project to ensure that infrastructure standards developed would be accessible for blind and partially sighted people.

Further Information

The Foundation would welcome opportunities to provide more information if required. Please direct any questions to:

Moira Clunie
Insights, Policy & Advocacy Manager
Telephone: +64 9 355 6938
Email: mclunie@rnzfb.org.nz

Royal New Zealand Foundation of the Blind
Private Bag 99941
Newmarket
Auckland