RNIB response to the Public Consultation on the Midland Road and Euston Road/Judd Street Junction — Proposed Walking and Cycling Improvements

About RNIB

RNIB is the largest organisation of blind and partially sighted people in the UK. We are a membership organisation with over 24,000 members. Our members are predominantly blind, partially sighted or have friends and family who have sight loss. Over ninety per cent of RNIB Charity trustees are blind or partially sighted.

We campaign for the rights of blind and partially sighted people in each of the UK’s countries. Our priorities are to:-

• Be there for people losing their sight.

• Support independent living for blind and partially sighted people.

• Create a society that is inclusive of blind and partially sighted people’s interests and needs.

• Stop people losing their sight unnecessarily.

We provide expert knowledge to business and the public sector through consultancy on improving the accessibility of information, the built environment, technology, products and services.

RNIB regularly supports blind and partially sighted people to make the built environment more accessible. We also advise decision makers, such as local authorities, on how to make the built environment more accessible for blind and partially sighted people.

About sight loss in the UK and London

Almost two million people in the UK are living with sight loss that has a serious impact on their daily lives and activities. This equates to almost one person in thirty, whose ability to access the pedestrian environment is potentially limited or compromised by their visual impairment. It is predicted that by 2050 the number of people with sight loss in the UK will double to nearly four million.

Although sight loss affects people of all ages, as we get older we are increasingly likely to experience sight loss and in the UK one in five people aged 75 and over are living with sight loss. This rises to one in two people over the age of 90.

Around 360,000 people are registered blind or partially sighted in the UK. In London there are estimated to be 41,000 people who are blind or partially sighted.

RNIB Headquarters

RNIB has its headquarters building, including a flagship Customer Service Centre, on Judd Street. This Customer Service Centre is visited by thousands of blind and partially sighted customers from across London and the UK each year. We also have many blind and partially sighted staff, volunteers and trustees, working in and/or visiting the building.

The preferred site for the relocated Moorfields Hospital, at St Pancras Hospital, will also be very close to the Midland Road route and there is likely to be an increased number of blind and partially sighted people travelling along Midland Road and the cycle superhighway extension as people travel between RNIB and Moorfields.

This proposal is likely to have a very significant impact on all blind and partially people visiting our building and using the surrounding area.

Lack of consultation

Given the location of RNIB’s headquarters, it was somewhat surprising that no attempt was made to consult with RNIB in advance of the publication of the consultation.

Equality Impact Assessment

As a public authority, Camden Council is subject to the Public Sector Equality Duty and is required to have “due regard” to equality outcomes in everything it does. In particular, the Council is required to ensure that it eliminates discrimination, advances equality of opportunity and fosters good relations between, amongst others, disabled and non-disabled people.

Given the proposal affects the location of the headquarters of a large national disability charity, we would have expected Camden to undertake an initial equality impact assessment in order to understand what the potential impact of this proposal would be on blind and partially sighted people visiting and working in RNIB HQ and as pedestrians in the surrounding areas. It does not appear that Camden has complied with this duty. Clearly consultation with RNIB would have been the starting point for any assessment.

The design is also impacted by the substantive provisions of the Equality Act which makes it unlawful for a service provider/those providing a public function to discriminate. This includes the requirement to make reasonable adjustments where a physical feature puts a disabled person at a substantial disadvantage in comparison to a person who is not disabled. The duty to make reasonable adjustments is anticipatory in that it requires consideration of, and action in relation to, barriers disabled people face in accessing services/public functions before an individual disabled person makes use of a particular service/function.

Sight loss and cycling

RNIB supports programmes that reduce traffic and make cycling and walking better for people. As an employer we promote cycling amongst our staff by participating in the cycle to work scheme and providing storage and changing facilities for staff and volunteers who choose to cycle to work.

However, we are becoming increasingly concerned about how new cycling and public realm schemes are planned, applied and consulted on with many local authorities adopting designs that encroach into walking areas, create shared use spaces and potentially place people with sight loss at risk.

Blind and partially sighted people also tell us that the behaviour of some cyclists intimidates them and impacts upon their independent mobility. They report cyclists jumping red lights and cycling past them on crossings; clearly not realising the negative impact that this can have particularly on people with sight loss. We have had at least two members of staff who have been hit by cyclists whilst crossing Tavistock Place as a result of the cyclists jumping red lights. Blind and partially sight people report cyclists shouting at them to “get out of the way” and ringing their bells angrily. This low level anti social behaviour impacts upon blind and partially sighted people’s confidence and independence.

The Council (and cyclists) must not assume that all blind people are easily identified by their having either a cane or a guide dog. Many people with sight loss carry neither a cane nor use a guide dog. Even those using a white cane will not necessarily be easy to spot.

We are also aware that local authorities do not generally monitor the number of minor collisions or near misses experienced by pedestrians with cyclists or provide accessible routes for pedestrians to report such incidents. We would request that Camden confirm whether they collect this data and how pedestrians can report such incidents.

Our campaigners also regularly tell us that they have experienced more problems with cyclists than with motorised vehicles. Motor vehicles are generally not silent and, for partially sighted people, are easier to see.

Rerouting the Cycle Superhighway

As a result of the above, RNIB is very concerned about the decision to route the cycle superhighway down Judd Street and we have asked TfL to explore alternative options.

We note, for example, that the London Cycle Network Route 6 currently runs along Cartwright Gardens (currently closed to traffic as a result of construction work) and Mabledon Place and across Euston Road on to Ossulston Street and up to Camden or along Brill Place where it joins Midland Road and up to Islington i.e. it follows the existing route on Judd Street just one block across. This is obviously part of the existing route which the new proposals will feed into and it is not at all clear to RNIB why this route is no longer considered suitable for cyclists.

On the East side of Judd Street there is another cycling route which runs down from Tavistock Place, along Belgrove Road and then across Euston Road onto Pancras Road. Again this appears to provide a safe route from the cycle superhighway extension across the Euston Road to connect up to the London Cycle Grid. Again it is not clear to RNIB why this route could not be upgraded.

Current conditions on Judd Street

The level of traffic on Judd Street has increased significantly since the implementation of the two way cycle lane trial on Tavistock Place. Again this was done without any consultation with RNIB and it is not clear that any equality impact assessment was undertaken prior to implementation.

It is RNIB’s understanding that this is still a trial and yet the consultations that have been issued by TfL and Camden appear to assume that the two way cycle lane will remain. This rather prejudges the outcome of the trials and any subsequent consultation.

Clearly RNIB would like to see the level of traffic reduced to pre-trial levels as this also negatively impacts on blind and partially sighted people using the pelican crossing. Vehicles frequently occupy the crossing unlawfully and the timings on the crossings have been changed (again without consultation) — presumably to accommodate the increased levels of traffic — but this has led to a significant increase in the level of waiting time especially for blind and partially sighted pedestrians who have little choice but to wait for the “green man” in order to know when it is safe to cross. We are sure that there is also a significant increase in the level of pollution.

It would appear that RNIB and other residents and businesses on Judd Street have been presented with a ‘fait accompli’ that in order to see a reduction in the level of traffic on Judd Street caused by the extension of the cycle lane on Tavistock Place we are expected to agree to the extension of the cycle superhighway on Judd Street and the Midland Road proposals. This is Hobson’s Choice.

Substantive comments on Consultation

Impact of limiting access to Judd Street

Although we are keen to see a reduction on the level of traffic on Judd Street, RNIB is concerned about the impact that any closure will have on staff members and visitors arriving at RNIB by motor vehicle either taxi cab or private car (driven by friends and relatives). It will also significantly reduce the availability of black taxis to be hailed outside the building which will place an additional burden on RNIB staff to call for private hire vehicles.

Given the impact of the closure of Tavistock Place and the significant increase in vehicles on Judd Street — most of which appear to be vans and taxis — we are concerned that inadequate consideration has been given to the displacement of traffic from Judd Street and we note that the consultation document only discusses the impact on journey times on Euston Road. We would be grateful if you could provide us with a map of the wider area showing the expected displacement of traffic from Judd Street and impact upon journey time. In our view there does not appear to have been any evaporation of traffic in the last 5 months. This proposal therefore risks putting further pressure on the roads surrounding Tavistock Place.

We are particularly concerned about the potential displacement of traffic into side streets, with, for example an increased number of vehicles turning left onto Hastings Street (and Bidborough Street) west side which is an uncontrolled crossing point for accessing RNIB’s building. This will clearly pose a difficulty for blind and partially sighted pedestrians.

If Judd Street is closed to through traffic, is it anticipated that some vehicles will be reversing into the current crossover outside O’Neills? Again this poses a risk to blind and partially sighted pedestrians.

Enhanced public realm (Option 1)

This area at the bottom of Judd Street effectively appears to be a small public space with a cycle lane running through it. It is obviously essential that any such space includes, at the very least, a detectable kerb of at least 60mm (in keeping with UCL research) with appropriate contrasting pavement (RNIB’s preference would be for a standard height kerb) in order to ensure that blind and partially sighted people do not accidentally find themselves in the path of oncoming cycles.

Cycle Parking (option 2)

We do not consider that the pavement is sufficiently wide to allow for cycle parking in this area. This area is already problematic for pedestrians because of the tables and chairs, customers, street furniture outside O’Neills. Additional cycle parking will only exacerbate the situation.

Parking at grade at the bottom of Judd Street

RNIB would like the parking at grade in front of Camden Town Hall to be removed. This is a narrow stretch of pavement which is very busy. Pedestrians are regularly forced onto the parking bays. Blind and partially sighted pedestrians are unable to detect that they are walking onto a parking area and are therefore at risk of bumping into vehicles parked there or approaching/departing. Currently Camden vehicles appear to treat this area as their own parking space.

In the event that it is necessary to retain this parking area then a detectible kerb needs to be installed of at least 60mm depth with sufficient tonal contrast. RNIB’s preference would be for a standard height kerb with a tactile dropped kerb for access.

Controlled crossing on Euston Road (West side)

RNIB would support the ending of the left turn on to Euston Road from Judd Street in order to facilitate the introduction of a controlled crossing on the West side of Euston Road. This is a popular crossing place for pedestrians including RNIB (sighted) staff members in order to access the British Library and bus stops on the North side of Euston Road. The current arrangements are not safe. A controlled crossing would also enable blind and partially sighted staff members, volunteers and visitors to cross safely at this side of the junction to access the North side of Euston Road, without the necessity of using three controlled crossing in order to reach the same destination.

Stepped cycleway

We would be grateful if you could provide clarification as to the depth of the pavement kerb in areas where there is proposed to be a stepped cycleway. As above, we would expect this to be at least 60mm with contrasting surface; RNIB’s preference would be for a standard height kerb.

Deliveries Entrance

Consideration needs to be give to the installation of tactile paving at this entrance to warn blind and partially sighted people of the presence of (delivery) vehicles.

Hatched area

We note with some concern that the carriageway and cycle lane have been raised to the level of the footway apparently creating a shared space area. The risk that such areas pose for blind and partially sighted people is well documented1 . This will place blind and partially sighted people at risk of inadvertently walking into the cycle way and carriageway. This is unacceptable. The footway needs to be differentiated from the cycle lane and pavement by a detectable kerb of at least 60mm with sufficiently contrasting roadway/cycleway; RNIB’s preference would be for a standard height kerb.

We also note that the footway outside the Francis Crick Institute is very narrow and we would seek clarification as to as to the proposed width.

Removal of Pelican Crossing

We note that the plans show a zebra crossing outside the entrance to St Pancras Station without showing that this was previously a controlled crossing. RNIB is very concerned about the proposal to remove the controlled crossing. Blind and partially sighted people need to know when it is safe to cross the road as they are unable to see oncoming traffic. They are also unable to hear cyclists and electric vehicles. This reassurance cannot be achieved with a zebra as it requires a blind person to step onto the road before there is an obligation for motorists and cyclists to stop. Although not foolproof as noted above, cyclists are more likely to stop at a red light than a zebra as are motorised vehicles.

It appears that the tactile on the central refuge area is inadequate and not in accordance with tactile paving guidance (see below)

If a zebra is retained there is insufficient differentiation between the white stripes and the carriageway. This will only worsen over time.

Tactile Paving

We note that the tactile paving used at the controlled crossings throughout the plan is not marked as red. Please note that we would expect all tactile paving along this route to be in keeping with the National Guidance on Tactile Paving. This means that it should be red and the tactile tail needs to be 1200mm. TfL new Streetscape Guidance (which we have objected to) must not apply. Given that visitors in this area will come from all over the country it is important that the paving is consistent with National requirements.


Clearly the materials used in the scheme need to be carefully considered and we would seek clarification as to the materials to be used for paving, carriageways and delineations etc.

Any surface must be hard wearing in order to prevent it degrading and becoming a trip hazard (as has happened in many shared space schemes) and consideration needs to be given to the requirements for reinstatement following work by utility contractors. It must also be slip resistant in all weather conditions.

Linked Proposal/Developments

We have responded separately (in similar terms) to the TfL consultation on extending the cycle superhighway down Judd Street. A copy of that response is attached. However, the proposals are clearly inextricably linked and a decision on any one aspect of the scheme cannot be made independent of the other proposals. It is also very difficult to separate the impact of the Tavistock Place trial and the current closure of Cartwright Gardens from any decisions regarding the future use of the area.

We would therefore request that before any decision is made as to the best way forward all proposals are considered together ‘in the round’ and in consultation with RNIB and other interested groups in order to find an acceptable way forward for all concerned.


17 March 2016

1 See for example Accidents by Design — The Holmes Report on Shared Space http://chrisholmes.co.uk/news/accidents-by-design-the-holmes-report-into-shared-space/