I've had no major objections except for one pointing out that TAL 4/91 and TAl 5/91 for audible indicators allow for them to be switched off at night, and only suggest rather than require tactiles as well in those circumstances. In the light of that I've deleted the last sentence in 2.1 and the second sentence of 2.2. I've also reworded the first paragraph and changed "It is suggested ..." to "TCUG will recommend ...", in 1.2, 2.2, 3.2 and 4.2. See below for the completed document. I will now send this to DfT and ask them to take it up with the Audit Commission, and will also forward the recommendations to all TCUG members and ask them to use them when preparing the next BV165 performance indicator. Peter Bull BV165 - TCUG recommended clarification of the indicator In many local authorities, those with the reponsibility for preparing the information for BV165 (The percentage of pedestrian crossings with facilities for disabled people) are TCUG members. They have a number of concerns about the detailed definition of some parts of the indicator. We feel that unless clear guidance is given the figures produced by different authorities will be incompatible, and part of the basis of CPA will be undermined. The four main areas of concern are set out below, together with the detailed definitions TCUG members have agreed to use to prepare figures for the revised 2002/3 indices - it is suggested that the Audit Commission may wish to incorporate these definitions in any more detailed guidance it may issue in the future. 1.1) The definition asks for "... the percentage of signal controlled crossings ...". It is not clear what is to be counted as one crossing. Do crossings on dual carriageways count as one crossing or two? Does a major junction or signalled roundabout with many crossings all controlled by one controller count as one crossing or many? Is it reasonable that a pelican on a minor single carriageway should have the same impact on the indicator as a major junction with four or more dual-carriageway arms? 1.2) TCUG will recommend that a signal-controlled crossing be defined as carrying pedestrians from one footway to another footway, irrespective of any intermediate islands or refuges. So that a mid-block crossing of a single or dual carriageway would count as one crossing, and a four-arm junction with crossings on all arms would count as four crossings, whether the arms were single or dual carriageways. 2.1) The definition asks for "... audible and tactile signals (as appropriate) ...". Does this mean that only crossings which incorporate both audible and tactile indicators count, as might be argued are necessary to cater for the deaf blind? If so, in order to improve their performance indicators, most authorities would have to divert resources away from providing tactile facilities at those existing sites which cannot have audible facilities, towards providing tactile indicators at sites which already have audible indicators. The effect would be to divert investment from one minority - the visually impaired - to a much smaller minority - the deaf blind. 2.2) TCUG will recommend that a crossing fitted either with audible indicators or tactile indicators (as appropriate depending on local conditions) would comply. 3.1) The definition asks for "... dropped kerbs ... installed in accordance with ... Guidance on the use of tactile paving surfaces, DTLR 1999 (dropped kerbs and tactile paving)". This publication states that kerbs should preferably be flush with the carriageway for the benefit of wheelchair users, with a maximum upstand of 6mm. Many authorities are concerned that drainage problems can lead to ponding at truly flush sites, which discourages pedestrians from standing near the kerb edge. This can restrict the pedestrian's visibility of oncoming traffic and make them less visible to drivers, they may also step outside the kerbside detection zone of puffin crossings. Most authorities adopt a nominal 6mm upstand and at least one came to an agreement with their local disabled representatives many years ago for a 12mm upstand. Other authorities point to the difficulty of laying stone kerbs in conservation areas to exact measurements so that kerbs laid to a nominal 6mm upstand may vary slightly in practice - would any variation above 6mm lead to non-compliance for the site? 3.2) TCUG will recommend that compliant crossings should have an upstand on dropped kerbs of a nominal 6mm, with a tolerance of +/- 6mm, but that any policy to lay crossings with an upstand greater than 6mm should only be adopted with the agreement of local disabled groups representing both the visually-impaired and wheelchair users. 4.1) Finally the definition states "It is assumed, however, that for each of the crossings included in the BVPI an assessment will have been made by the local authority, against the above guidance, and that those crossings counted as meeting the BVPI will have the facilities appropriate to their local conditions." This clause could be construed to allow local conditions, which might include local agreements and policies, to over-ride any of the other definitions. Wide application of this "local conditions" option would make comparison of the indicator between different authorities meaningless. 4.2) TCUG will recommend that this "local conditions" option should only apply to the decision whether or not audible or tactile indicators are appropriate at a particular site. ---------------------------------------------------------------------- Planning Transport & Highways, Sheffield City Council, Howden House, 1 Union Street, Sheffield, S1 2SH Tel: (0114) 273 6174 The information in this email is confidential. The contents may not be disclosed or used by anyone other than the addressee. If you are not the addressee, please tell us by using the reply facility in your email software as soon as possible. Sheffield City Council cannot accept any responsibility for the accuracy or completeness of this message as it has been transmitted over a public network. If you suspect that the message may have been intercepted or amended please tell us as soon as possible. ----------------------------------------------------------- A message from the TCUG mailing list. For information about the list visit //www.freelists.org/webpage/tcug