MACS Response to the Guidance on Inclusive Design for Town Centres and Busy Streets Consultation - March 2024

Question 1: Please give us any comments relating to Principle 1 and what it is trying to achieve (300 word limit)

MACS are happy with the content of Principle 1 in terms of encouraging organisations to continually engage with the public and potential end users of any scheme they are developing. At the time of responding to this consultation, the link to the Participation Framework had been archived and was not available. This should be considered before this document goes live. 

Robust and meaningful engagement should be undertaken with end users, and this should also involve the ‘engagers’ undertaking disability awareness training, and this should be recommended. If the teams who are engaging with potential end users are not trained, many individuals may be excluded as there are many ways to communicate. A lack of training could build in barriers to communication - for example those whose first language may not be English and those who may require additional language support, those who may not understand 2-dimension plans and may benefit from modelling, or those who may benefit from having a meeting on the actual site of the works where proposals could be explained in ‘real life’, etc.

Question 2: Please give us any comments relating to Principle 2 and what it is trying to achieve (300 word limit)

MACS welcomes the recommendation of early engagement with potential end users in any scheme and in particular the recommendation of engaging once the scheme has been completed which will enable designers to learn from this scheme and take improvements into any future schemes.

Early engagement with potential end users will enable the design team to learn from people with lived experiences who will be able to share their experiences of negotiating similar schemes and identifying barriers which the team should try and design out and / or overcome in their scheme.

Linked to principle number 2, engagement will need to be planned into the process and not an afterthought and it is good practice to remunerate participants for their time in passing on their personal expertise and experiences, therefore a budget should be built into the engagement process.

If required, an Equality Impact Assessment should be started at the earliest possible stage in this process to ensure that as many people as possible covered by Protected Characteristics as possible are included and a record kept of the interaction.

Question 3: Please give us any comments relating to Principle 3 and what it is trying to achieve (300 word limit)

MACS agrees that all engagement materials should be accessible, from the initial advertising of any engagement event through to the synopsis of any event. Perhaps the document should give an example of a non-accessible approach. For example, architects 2D drawings setting out proposals are inaccessible to many people who do not readily understand drawings or particularly individuals with visual impairment who will not be able to see the plans. Any session could be augmented with tactile plans, text descriptions, models of sections of the street, walk abouts with small groups visiting the street where design team members might explain proposals on site. 

As previously stated, members of the design team should be trained in disability awareness training so that effective and inclusive engagement is carried out. In providing accessible engagement materials this will aid this process.

Question 4: Please give us any comments relating to Principle 4 and what it is trying to achieve (300 word limit)

It is important that as many people with varying opinions and abilities can provide their views. Individuals who belong to groups may only meet once per month and it is therefore vital that enough time is given to disseminate information, allow for discussion and feedback. MACS acknowledges and agrees that the capacity of local and national organisations who may be able to contribute may be limited.

Question 5: Please give us any comments relating to Principle 5 and what it is trying to achieve (300 word limit)

Accessible and inclusive engagement events can be challenging to organise in trying to cater for as many differing abilities as possible. Design Teams should also be encouraged to attend local groups who meet regularly rather than members of these groups attending an organised event. Many individuals will feel comfortable in their regular meeting settings with their usual support systems in place; for example, BSL interpreters, advocates etc. 

It may help by providing an inaccessible example. For example, an event held just after 9am can be difficult for many people to attend for various reasons; personal care timings as some individuals cannot stipulate exact times for their care packages, availability of accessible transport not being utilised for school runs, or if the event is in the evening the local transport might stop at 6pm. Can the venue(s) be reached easily by accessible public transport?

Question 6: Please give us any comments relating to Principle 6 and what it is trying to achieve (300 word limit)

MACS welcomes the commentary around separation between different users which is a complicated issue and would recommend that detectable kerbs should wherever possible be an edge to a pavement that is higher than the cycle way or carriage way, with the drop to the cycle way or road being 60mm, but with dropped kerbs provided at crossing points. 

Splayed kerbs are appearing in our environments, but we would advocate that splayed kerbs should not be introduced until there is rigorous research completed on the impact these kerbs have for disabled people.

We are concerned about the potential for ‘level surface’ streets with tactile paving used to demarcate the pedestrian space from motor traffic and would advocate that this design should not be recommended. We appreciate the intention of recommending this type of installation in ‘low flow and low speed’ areas, however, will these areas always be low flow and low speed should a major housing development be built for example. We would of course recommend an EQIA for any such development that records those who have been engaged with and consulted.

Question 7: Please give us any comments relating to Principle 7 and what it is trying to achieve (300 word limit)

MACS welcomes the recommendation of at least 2m width for a clear route for pedestrians. The word pedestrians can relate to anyone walking or wheeling along the pavement area. Negotiating busy streets for some people can be difficult due to the number of barriers that can be present; bins, seats, utility boxes etc making it extremely tiresome, inconvenient, and sometimes dangerous for individuals whose vision is impaired or those who are using mobility aids including wheelchairs. A clear safe route that can be negotiated with strong accessible features such as buildings or boundary walls help many long cane users to navigate independently.

It is good to see reference made to the need for pick up and drop off points but the reference to ‘support vehicles’ is unhelpful. These are presumably meant to be for cars and taxis, but the language used is confusing and could result in designers thinking about motorised scooters or similar rather than cars and taxis and would recommend a phrase such as vehicles needed by disabled people.

It is good that the definition reminds designers that streets need to be accessible for “essential taxi and essential car users”, but it does not define what this means. This would benefit from describing that there are people because of their disability, age, or other circumstances that are dependent on taxi or private vehicles and they must not be excluded from accessing busy streets.

Wheels For Wellbeing have produced various documents providing guidance and advice on accessible cycle storage and it is recommended that this organisation is signposted within the guidance so that design teams can see examples of nonstandard bikes and how much space is required to store them.

Question 8: Please give us any comments relating to Principle 8 and what it is trying to achieve (300 word limit)

MACS welcomes the guidance on crossings which can be particularly confusing for many people – what is the different between a controlled crossing and an uncontrolled crossing. It should be noted that paragraph one and two repeat themselves.

“The type, location and frequency of placement of crossings should be tailored for a particular location and considered on a case – by - case basis by planners and designers in line with the outcomes of engagement with the local community”. MACS are unclear if Local Authority planners will have an input into this specific area of any design.

Tactile paving is a given at crossings – whether controlled or uncontrolled and it may be that this paragraph is not required within the guidance – merely a link to the guidance on tactile paving to aid designers in their choices of colours e.g. red at controlled crossings.

Question 9: Please give us any comments relating to Principle 9 and what it is trying to achieve (300 word limit)

MACS welcomes the section on materials which when chosen and / or laid incorrectly can build in so many barriers for many different street users.

MACS also welcomes the comments in relation to street works and the need for any temporary works and reinstatements to meet certain standards.

Question 10: Please give us any comments relating to Principle 10 and what it is trying to achieve (300 word limit)

MACS welcomes this section on consistency and is an issue that MACS raises frequently. Consistency in design enables many people to navigate their environments independently as recognition of styles and previous schemes will be learned and if there any barriers they will have been identified and navigated in previous schemes.

It would be helpful for readers of the final document to understand that there is ongoing research / concluded guidance in various areas affecting the built environment including but not limited to Floating Bus Stops, Continuous Footways , EV Charging etc so that designers know there may be other guidance documents to consider.