For safer design for all, we need less scaremongering and fewer simplifications

— There’s huge common ground, framing cycling and disability against each other is destructive.

Comment & Analysis / Long Read: The Irish Wheelchair Association acted irresponsibly in the launch of its ‘Getting Nowhere’ this week. The association resorted to using actors to exaggerate the level of conflict between people cycling and bus users; it has latched onto scaremongering imported from the UK, where cycling has been made into a “culture war” issue.

There are serious issues, including significant factual errors in the report’s key findings.

Nothing in this article is to say there’s zero issue with bus stop design or zero issue with people cycling. But the kind of approach taken—even if it’s mixed in with some reasonable-sounding words and phrases—does not help anybody.

It’s not going to help vulnerable pedestrians, including wheelchair users, people with reduced sight, older people, or children using buses, and it’s also not going to help wheelchair users and others using mobility devices, including disabled cyclists, older people, or children who use cycle tracks.

Children wanting cycle lanes is a “tiered of ableism hiding behind other policy”

The acknowledgements section of the report only has this:

“I’d like to thank Gary Kearney for his tremendous work in this space and for his guidance. Many thanks, Gary, for the time you took to meet with me. And, to all those who tirelessly campaign for a safe accessible transport infrastructure.”

The significance of this being listed as the only acknowledgement is noteworthy because Gary Kearney’s influence is echoed in large parts of the report, and he has been involved for a long time in trying to import UK-style scaremongering about cycling to Ireland.

He is a non-elected member of the Dublin City Council transport committee, but Kearney still thinks children writing to councillors seeking safe cycle lanes amounts to a “tiered of ableism hiding behind other policy”.

As covered previously, Kearney also has a record of defending motorists parking on footpaths (he’s on the record as saying so more than once), he has repeatedly defended restrcive kissing gates (which block people with disabilities generally because they also block people cycling), and when a TD was knocked down by a motorist with footage recorded on CCTV from a building, Kearney said: “A story from a rabid cyclist who hates motor vehicles and refuses to wear the RSA approved safety gear. Hobble on.”

He has denied he is “anti-cycling” but has opposed a large number of cycle routes, mainly saying he’s against shared spaces, but has also said he has been against projects with little or no shared spaces.

“People with disabilities can and do cycle”

Deep within its report, the Irish Wheelchair Association accepts that “people with disabilities can and do cycle,” but this is only an add on to how the report generally refers to people with disabilities and people who cycle as two separate groups without any possable overlap. The Irish Wheelchair Association is not alone on using language that pits cyclists and disabled people, influenced by Kearney and others, the National Disability Authority has taken a similar approach when talking about bus stops and cycle paths.

It is wrong for any professional disability group to talk about disabled people and cyclists as if these are two groups with no overlap. There are some disabled people who use bicycles for exercise or leisure, but there are also disabled people who use bicycles for independent travel. There are also others who want to but don’t feel safe doing so given the danger, mainly from motorists.

The range of disabled people who cycle includes people who cannot walk very far but can cycle a lot further with less or no pain compared to walking. It also includes cognitive disabilities that make driving impossible or dangerous. People can also have issues that make using public transport harder.

While issues with public transport should be tackled (which is something the IWA puts little to no focus on), allowing for a choice of mobility options to suit different people is important. For example, somebody with a compromised immune system or who is unable to deal with crowds for other reasons should have the choice of safer cycling rather than their car (or buying a car) being the only option.

The UN Convention on the Rights of Persons with Disabilities applies to all disabled people, not just those that a service provider or any other group is focused on.

And it’s not only people cycling who benefit from high-quality segregated cycle paths. The video below is from the Netherlands, but we also know this is not something that only happens in the Netherlands, and, there’s experience elsewhere that a wider range of cycle path users will start to emerge once networks of safe cycle routes.

The Irish Wheelchair Association or whoever was involved with producing videos for the report hired or enlisted actors for the videos without providing any transparency that actors were involved.

These videos are very likely going to make disabled people more fearful when crossing and using cycle paths. This is only part of the issue with things not being as they seem in the report.

The likely reason for needing actors is that, a very high percentage of the time, watching cycle paths at bus stops is a bit like watching paint dry. The majority of the time at most bus stops, not only is there no conflict, there’s no interaction between people walking and cycling; they generally arrive at the crossing points at different times.

This, again, is not to dismiss all concerns but to say that the end result in these videos — and also highly edited videos from the UK — is manipulated or exaggerated for effect.

Cycle paths or access to public transport generally?

Maybe a more underhand part of the report was developing a report with the pretext that it’s about access to public transport generally when the report is dominated to such a level about pitting cycling and disability against each other.

The Irish Wheelchair Association seeks more consultation from authorities, but the replies on Twitter and elsewhere from people with disabilities make it clear the focus on cycle paths at bus stops was a targeted one. There’s little or no mention of the many barriers facing disabled people who are trying to access public transport.

For example, the functionality of lifts is one of the main barriers to accessing the rail service, but there’s no mention of lifts (or elevators) in the summary report, and the only mention of it in the full report is quoting a policy document without focusing on it.

There is also no mention of the experience disabled people have with having to give advanced warning before using public transport or the issue of bus drivers refusing to ask parents with prams to fold them up. There is also no mention of the inaccessibility of so many Bus Éireann and other coaches, the lack of accessible bus stops in rural areas, or even the number of bus stops in urban areas that do not have Kassel kerbs or insufficient space.

Motorists cause significant issues for disabled people generally, but in terms of accessing public transport, parking or stopping illegally at bus stops, blocking footpath or crossing access to stops and stations (which also happens with poorly placed bicycles), and non-blue badge holders blocking disabled bays at or near public transport hubs, they can cause major issues.

Cyclists are mentioned, including in quotations, nine (9) times in the summary and 28 times in the full report. Motorists (including drivers) are not mentioned in the summary and are only referred to when referencing design guidance in the full report.

Cycling vs human rights

This following paragraph is the ‘Getting Nowhere’ summary report:

“Interestingly, by conservative estimates, cyclists are mentioned three times more than any reference to disability in DMURS. The two objectives, safety for cyclists and safety for pedestrians with disabilities, are not inherently in conflict with one another. Yet, cyclists are a priority in national and regional transport policy and projects, and in design. People with disabilities are not. Human rights are not prioritised in the same way that cycling infrastructure has been.”

And something similar is mentioned as a key finding in the main report document:

“Cyclists are a priority in national and regional transport policy and projects, and in design. People with disabilities are not. Human rights are not prioritised in the same way that cycling infrastructure has been. By conservative estimates, cyclists are mentioned three times more than any reference to disability in DMURS.222 The two objectives, safety for cyclists and safety for pedestrians with disabilities, are not inherently in conflict with one another. However, in the absence of legally binding accessibility minimums for cycling infrastructure, human rights are being compromised….”

There’s a lot to unpack in the above. Despite claims elsewhere of not pitting cyclists against disabled people, this is clearly not the case here.

The inclusion of these paragraphs in the summary and key findings of the report is significant; it is more likely that people like politicians will read through the summary. While cyclists are a priority, it’s worth noting that pedestrians are a higher priority in all of the major government designs and policy guidance.

According to the UN, “road safety is a human rights issue” and “climate change is a human rights issue.”. The driving force behind cycling infrastructure is road safety, increased mobility, and climate action. But most of the ways where it is claimed that cycling is a priority and people with disabilities are not is not true or exaggerated.

Rather than look at what works and what does not, the report demands minimum standards without being clear what these standards would cover.

IMAGE: An ‘island bus stop’ without a cycle path beside it.

Design Manual for Urban Roads and Streets

The above quotes from the report are also misleading about DMURS, or the Design Manual for Urban Roads and Streets. That guidance mentions pedestrians 115 times but only mentions cyclists half as much.

The line “Yet, cyclists are a priority in national and regional transport policy and projects, and in design. People with disabilities are not” is at best misleading; while disabled people are not mentioned, people with disabilities are pedestrians, cyclists, public transport users, etc. who are mentioned. Children and older people are also mentioned; DMURS is not implying that they are never pedestrians, cyclists, public transport users, etc.

The full report might have a solid point in criticising DMURS for not having more details on access and mobility for people with disabilities and the broad range of requirements people have. This is at least partly linked to the issue of a lack of integrated design guidance (which has highlighted a few times). Currently, there’s guidance from a number of state agencies and departments that govern the design of streets and roads.

DMURS might not be the perfect document, and it could be improved, but if DMURS were even half implemented, our streets would be a far more accessible place for people with disabilities than the status quo where the standards of footpaths is lacking, and crossings are all too often just missing from where they should be.

The full Irish Wheelchair Association report said: “DMURS assumes the needs of nondisabled pedestrians are the same as the needs of pedestrians with disabilities.” It’s not clear that this is the case; as the report notes, DMURS singles out disabled people a number of times along with other more vulnerable road users.

The main problem with DMURS is that its basics have not been implemented more widely. The actual details of the DMURS, as opposed to just a word search, would immeasurably improve the lives of disabled people who want to access their communities, especially those outside of cars or those who want the option of not only relying on their cars or somebody else, including service providers like the Irish Wheelchair Association.

Another problem is that often local authorities and the NTA’s BusConnects team claim they have followed DMURS when they are not doing so. A large part of this stems from not following the hierarchy of road users— for example, providing bus priority by reducing footpath space in highly populated areas to fit in bus lanes rather than reducing space for cars.

Other examples are not providing crossings on all sides of junctions or roundabouts or leaving the scraps of space to people walking and cycling after providing for drivers.

IMAGE: An extract from which seeks, among other things, less use of shared footpath-type areas.

Shared spaces

The same key finding (it’s quite a long finding with no paragraph break) in the report states:

“Emerging guidance on cycle lane infrastructure is increasingly aimed at creating shared pedestrian spaces to encourage cycling, yet shared spaces pose a danger to people with disabilities. Shared spaces are, ‘generally not supported by people with a disability and is not recommended by IWA as a safe and inclusive design approach to the design of urban streetscapes.'”

Unless the report’s author was thinking of a very loose definition of “shared spaces”, the above is inaccurate.

The NTA’s Cycle Design Guidance notes that “As shared spaces are disliked by both pedestrians and cyclists, transitioning to shared space should only be consider in constrained locations and where a shared crossing, e.g. toucan crossing, is being implemented.”

Another section of the manual states: “Footpaths should be clearly separated from cycle lanes and tracks wherever practicable. This reduces potential conflicting movements between pedestrians and cycle traffic and provides a more comfortable facility for all users.”

The previous manual, the National Cycle Manual, had similar advice. The report argues for legally binding minimum standards, it’s unclear how you could apply this to shared space — the idea that there is never shared space (ie rural roads, urban lanes, car parks, etc) is not viable.

A number of design examples that include shared elements — such as some bus stop designs with shared elements (such as “Shared Bus Stop Landing Zone” designs which are not “island” bus stops), are listed in the manual as “For use in constrained locations only where island bus stop/bus stop relocation is not feasible and where no. of bus passengers boarding/alighting and cycle flows are also low.”

The problem here is that there was no strong requirement for avoiding these shared designs in the BusConnects design manual — which this website highlighed — and these designs are an all too common feature in the BusConnects routes at the decision stage with An Bord Pleanála. There needs to be a practical look at how these shared designs are avoided, including how designers of projects can find the space or better locations for bus stops. That includes relocating some stops, which is a contentious issue.

There is also an idea that some people have that anything they do not like is labeled as “shared space”. This includes where pedestrians have to cross a cycle path or cyclists have to cross a footpath (unaided by traffic lights), however, such a space is a crossing or crossing point (for one user or the other). It is no more shared space than when a person has to interact with vehicles when crossing at a side street or crossing any part of a street or road where there is no crossing available.

It is deeply unhelpful to muddy the waters this much. And while others may be engaging in it intentionally, the Irish Wheelchair Association and the National Disability Authority should distance themselves from the use of such confusing phrasing.

Sadily, it is not the only talking point that the report uses… in another key finding, the report states:

“The differing levels of investment between disability retrofitting and inclusive design in ongoing projects compared to that of cycling paints a good picture of the inequities entrenched in transport priorities and projects. For example, the Department of Transport funds the multi-annual ringfenced Public Transport Accessibility Retrofit Programme. And yet, this retrofit programme receives significantly less funding than other transport initiatives, such as cycling, and has not been updated since 2021.227 The UNCRPD general comment on accessibility explicitly outlines that sustained sufficient funds are needed to continue to remove barriers to accessibility in older infrastructure. This is an ongoing trend in government transport policy; priority and investment in the human right to access public transportation infrastructure does not see the same visibility nor support as the goal to increase cycling.”

A footnote outlines: “There is less investment in the NTA’s Public Transport Accessibility programme program (28 million euro for the four-year program) than in cycling investment (projected at 365 million euros a year)…”

Except there is no cycling investment programme that is funded to the tune of €365 million per year. The Active Travel funding is promised to be the equivalent of €360 million per year for the lifetime of the Government.

The Active Travel programme includes both pedestrian and cycling projects. Projects concidered to be “cycling projects” are also often much more than just cycling, including new or improved footpaths, crossings, traffic calming, and bus stop improvements. There are also standalone projects with these elements without much or any cycling elements.

This was in the context of €1.1 billion allocated to a mix of local, regional, and national roads this month.

Common ground

This article is too long already to go into the design of bus stops too much, but take one example — a key design point is that cycle path crossings should not be located at bus shelters where sightlines between people cycling and bus users are impaired. But this is a design fault at some Clontarf to City Centre route bus stops. It’s one of the oldest issues, but the council was distracted by scaremongering.

Another example of the concept that pedestrians should not have to cross cycle paths and how this can be a double-edged sword can be seen at junctions. This is a design feature of BusConnects and other projects where it is viewed that it’s better to have one longer crossing, including a red light for the cycle path at the same time as the roadway.

It might sound like something not to worry about. But it’s the equivalent of 6-7 car lanes at once rather than crossing ~2m cycle tracks separately from the main carriageway. Crossing the cycle path separately would reduce the width needed to be crossed at once down to around 5 lanes or lower, depending on the layout.

Design that lengthens the time needed to cross could mean a lot for some people with disabilities, older people, and young children. But that critical safety risk is being overshadowed. It’s what happens when you look at a single element of a system rather than the system as a whole.

There’s a huge common ground between disability groups and cycling groups in terms of seeking safety and accessibility, but framing cycling and disability against each other is destructive. That applies even when there’s a sprinkle of platitudes added while there’s serious issues with your key points.

IMAGE: Can you see the elephant in the room? There’s at least two possible solutions to making the boarding area at this bus stop less shared and more of a dedicated space for pedestrians: (1) running the cycle path behind the rebuild of the shelter (which could have been done as part of the project that built the cycle path and rebuilt the shelter), or (2) removing a section of the car parking and shifting the roadway to allow for a wider bus platform. But the elephant in the room is that there’s a not raised, not signalised and not marked pedestrian crossing across the main road. The yield markings, solid white lines, rumble strips and slow markings are reserved for the cycle path.


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