RNZFB Submission:
Sustainable Transport – Update of the New Zealand Transport Strategy
29 February 2008

The Royal New Zealand Foundation of the Blind (RNZFB) is a disability support service constituted under the Royal New Zealand Foundation of the Blind Act 2002.  The Foundation is the primary provider of vision-related habilitation and rehabilitation services to approximately 11,700 blind, deafblind and vision-impaired New Zealanders.

Half of our members are over age 80. Two-thirds are over age 65.  Their ability to safely move about in public spaces is a prime concern of the Foundation.  It is fair to say that if you “get it right” for blind people, everyone benefits by clear, accessible and safe design.  We also note that more than 90,000 people self-identified in the New Zealand Disability Survey undertaken in 2001 by Statistics New Zealand as having a vision impairment that cannot be corrected by glasses.  And with New Zealand’s ageing population, there is a “tidal wave” coming made up of Kiwis who do not see, or in many cases hear, as well as they did when they were younger. This must be taken into consideration when planning transportation.

The RNZFB’s vision is that blind and vision-impaired people have the same opportunities and choices as other citizens to participate fully in society. Our mission is to remove the barriers that inhibit independence of blind and vision-impaired individuals, and to promote their participation in all aspects of life.

The RNZFB agrees with the seven guiding concepts outlined below, understanding that moving people safely and securely includes ensuring equitable access for everyone to participate fully in society.

For people who are blind, deafblind or vision-impaired, accessing the walking environment and public transportation is not always equitable or affordable. 

We recommend that walking and cycling targets be separated and recognised as different modes of transportation.  The infrastructure and planning for each mode are different.  More intermediate targets around behavioural change are needed as these are a requirement within many of the targets.

For matters of safety, we recommend that footpaths be limited to pedestrians.  Vehicles, including bicycles and mobility scooters, should be separated from pedestrians.  Not only are our members unable to see these fast-moving and potentially dangerous vehicles, they frequently cannot hear them either, which creates a growing danger that must be addressed.

There needs to be a more cohesive approach between governmental target-setting and regional implementation.  The Government should take more responsibility in the implementation of strategies to meet the targets.

There are a number of strategies, policies and best practice guidelines mentioned within the discussion paper as well as bylaws and other standards not directly referred to relating to access for persons who have impairments that impact on transportation environments.  There needs to be consolidation and processes for compliance that is mandatory.

Are the targets being prioritised by cost effectiveness?  This needs to include the social and hidden costs of that target not being implemented i.e. not having an accessible walking environment leads to more vehicles on the road and health costs of inactivity.  Not being able to access the walking environment or public transportation with no access to a private vehicle leads to social isolation, especially for those with a vision impairment.  More analysis of how the different targets influence and impact upon each other is required.

1.    Assisting economic development

More discussion on which traffic should be prioritised for predictable and improved travel times is required, as well as additional targets on how these are to be achieved.  For example, to reduce congestion what strategies will be utilised – promoting public transportation, priority lanes, congestion funding  and/or other cost incentives?  More analysis of how each action/target impacts on other modes of transportation is required – i.e. increasing the roading network to cater for the number of vehicles impacts on access within that environment for pedestrians and cyclists and increases emissions. 

Congestion pricing is a solution as long as funding is used for sustainable transport targets.  It should not be used solely to increase roading capacity – the safety and mobility of pedestrians should always be considered as well. 

Does having predictable travel times and reducing congestion ensure a reduction in single car occupancy?

Travel Planning initiatives, concessions for public transportation and walking and cycling modes should also be used and targets and guidelines for Territorial Authorities provided.

2.  Assisting safety and personal security

We fully support meeting world best practice safety standards for all modes of transport but would like there to be further research to determine and mandate these.  There are currently a number of best practice guidelines and standards for Urban Design and Access but these are not legal requirements (i.e. NZ Standard 4121 2001: Design for Access and Mobility – Buildings and Associated Facilities, RTS 14,and the NZ  Pedestrian Planning and Design Guide).  Unless there are agreed with Universal Design Standards that are mandated by government, then we will continue to have walking environments and public transportation systems that do not permit safe and equitable access for all - including blind, deafblind and vision-impaired people..

“Providing safer crossing points for pedestrians” is not the only safety issue.  The entire walking environment (and cycling environment) needs to be reviewed and targets around them developed.  Again, we must stress the danger to vision-impaired people posed by mobility scooters, bicycles and (increasingly) super-quiet hybrid cars.   We note that pedestrian hospital admissions and injuries from falls while travelling are not shown in this report but are an issue.  Kerbs not built to best practice have resulted in tripping for the less mobile and wheelchairs tipping over.

There should to be more recognition of real and perceived safety concerns around walking before programmes are implemented.

A target for road deaths should not be stated.  NZ should aspire to Vision Zero.

3.  Improving access and mobility

As noted in the discussion document we have an ageing population which will impact on the demand for all aspects of the journey to be accessible and connected.  This target requires an integrated approach to provision and a number of intermediate targets.  As mentioned earlier, there are best practice guidelines and standards that provide information on how this can be achieved but these are not always incorporated into the design and implementation processes.  NZ Standard 4121 is in need of updating and once this is done would be a leading document in setting NZ Accessible Design Standards along with RTS 14, and any agreed standards on Urban Design and Accessible Vehicle Design.   There are aspects within the National Accessibility Design Performance Standards that are not explicitly detailed such as use of contrast, consistency, elimination of glare, the specifications for signage and positioning of systems to name a few.  Without the detail there are areas that could still be inaccessible.

To achieve this target there needs to be a legal requirement that Design Standards are met and documented.

To improve and have predictable travel times, ease congestion and have access to board and disembark, public transportation must be addressed.  The Accessible Journey report noted that bus drivers have issues with the time taken to assist people who use wheelchairs to board and exit vehicles.  This could also include older persons who use walking frames or support canes, and who require the bus to kneel and time to manipulate their frame to their seat before buses or trains move.  Some of these issues relate to the vehicle design and can be addressed through design standards.

Implementing the initiatives in Getting There, on foot or by cycle, are essential.  There needs to be national consistency with the application of walking and cycling strategies and the Government should take a role in the implementation of these with Local Authorities.  We fully support more funding being provided for walking projects.

For many persons on benefits, affordability is an issue.  There needs to be a review of the costs of transportation.

We agree that there are insufficient transport options for rural areas and would support research into these areas.  Peak traffic flows could indicate the need for other options i.e. park and ride at city edges, extending bus routes for peak times, improving access for pedestrians and cyclists or light rail where options other than private vehicles currently do not exist.  Accessing current rural bus networks where there are no connecting footpaths and major arterial roads with no prioritised crossing points isolate those who have limitations on their mobility, particularly those who have a vision impairment.  This is also an issue in cities where access to Public Transportation at uncontrolled road crossings and on busy streets is required.

Increasing Public Transportation Services will not directly improve access for those who have limitations on their mobility unless all aspects are accessible.

4.    Protecting and promoting public health

As mentioned in the previous section, there need to be intermediate targets for Urban Design best practice and an NZ Accessible Design Standard to invite and promote walking as a mode of transportation and these will link into the targets.  More funding should be available for walking projects to achieve these target sand link to appropriate strategies such as Health and Disability, Older Persons, Getting There.

5.    Ensuring environmental sustainability

We agree that funding for greater provision of public transportation, walking and cycling needs to be increased.  This needs to include targets around accessibility and design.

Targets supporting travel planning and associated incentives are required.  For example, businesses encouraging use of public transportation rather than providing car parks for employees not incurring fringe benefit taxes.