Submission on the Land Transport Rule: Traffic Control Devices Amendment [2010]

This is the Foundation's submission on the draft Land Transport Rule: Traffic Control Devices Amendment [2010]. The draft Rule proposed changes to Land Transport Rule: Traffic Control Devices 2004, which sets out the requirements for the design, construction and use of traffic control devices.

The Foundation's submission commented on visibility of signage, accessible pedestrian environments, the continued need for audio/tactile signals at pedestrian crossings and signage in shared spaces.

Full text of submission

The Royal New Zealand Foundation of the Blind (the Foundation) is New Zealand's primary provider of vision-related habilitation and rehabilitation services to blind and partially sighted people.

This submission is made on behalf of the Foundation's 11,700 members, but will also benefit the 90,000 New Zealanders that identify as having a vision impairment that cannot be corrected by glasses.

Access to safe pedestrian environments is essential for blind and partially sighted people, who are often more vulnerable than other pedestrians. Safety initiatives which address the needs of blind and partially sighted pedestrians will improve safety factors for all pedestrians.

Proposal 5

It is proposed that the Rule be amended to replace the existing provisions for managing traffic entering a roundabout.

Roundabouts are difficult to negotiate for persons who are blind, partially sighted or deafblind due to the constant traffic noise and lack of priority on any of the crossings. Multi lane roundabouts are extremely dangerous due to the volume of traffic, constant traffic flows from all directions, direction of gaze of the driver and the speed vehicles are travelling. Signalising the roundabout and including a mid block signalised pedestrian crossing (set back from the approaches to and exits at an appropriate distance to allow vehicles time to safely observe the light activated by the pedestrian and stop) on all approaches/exits would make the crossings accessible. The distance the signalised crossing is set back is crucial as noted in the proposal.

Proposal 6

It is proposed that clause 6.6 of the Rule be amended to allow nearside mid-block pedestrian traffic signal displays.

The RNZFB supports the installation of nearside displays, but want it noted that these must not replace the tactile/audible displays required by pedestrians who are blind, partially sighted or deafblind.

Proposal 7

It is proposed to amend clause 6.6 of the Rule to allow road controlling authorities to install countdown pedestrian signals or 'clocks'.

The RNZFB supports the installation of countdown signals, but want it noted that these must not replace the tactile/audible displays required by pedestrians who are blind, partially sighted or deafblind.

Proposal 11

It is proposed to amend clause 11.4 of the Rule to clarify aspects of defining paths and to recognise changes made in the Road User Rule in defining 'shared paths'. It is also proposed to define a pedestrian symbol for use on shared paths to assist in defining usage of those paths.

The colour, location, height, size and contrast of the sign for visibility for those who have vision impairment must be taken into consideration. Shared paths must be logical and consistent in design nationally to ensure all users are aware of how they are to be used i.e. keeping to the left or right and who has priority at areas of conflict.

Issue 1: Minimum size of signs

For pedestrians who have some degree of vision impairment it is essential that signs are able to be visually located and understood. This includes aspects of design (colour, size, font, legibility, style) and location (contrast to immediate background, logical placement and lighting). If signs are too small, unclear or hard to read they will not communicate instructions effectively.

Issue 3: Shared zone sign

There are two aspects that must be incorporated into the sign

(i) this is a shared zone

(ii) the pedestrian has the priority

In the examples shown this is not communicated. Could there be a give way symbol included in the sign around the car/vehicle and bicycle?

As shared space is a relatively new concept to New Zealand and is now being implemented around the country, it would be beneficial to have the speed limit posted to encourage vehicles not to exceed the limit.