THERE has been scant comment so far on the accessibility report commissioned by Bath & NE Somerset Council (B&NES) following the publication of its proposal to ban virtually all traffic – including Blue Badge cars and taxis – from the historic centre on alleged anti-terrorist security grounds. This might in part be because the 60-page report – by Atkins, a design, engineering, and project management consultancy that’s a subsidiary of the Canadian company, SNC-Lavalin, which claims to be ‘experts at mastering complexity’ – is written in a form of English designed to be understood only by management consultants and other experts at mastering complexity. It’s to be hoped that a plain English translation has been given to the councillors who will make a decision on the so-called ring-of-steel package, which comprises:
- 24/7 vehicle access restrictions within the city centre’s most crowded streets
- Strengthened secure vehicle access points operated by the council’s CCTV control room
- Purpose-designed reinforced static and sliding protective bollards and street furniture
Buried in the accessibility report is an assessment that suggests the proposed ban on Blue-Badge cars could be binned: ‘ … From an equity perspective, we would be obligated to question the reasonableness of excluding vehicles used for the purposes of enabling access. We are of the view, especially following stakeholder engagement, that in order to maintain equity of access that B&NES Council would be best advised to devise security protocols that enable rather than exclude access for Blue-Badge holders if at all possible and, whether by car, by taxi or care organization.’
The report (extracts from which have been edited) takes note of the following factors facing disabled Blue-Badge holders in Bath:
- Blue Badges are issued only where someone is not able to walk further than 160ft/50m. The [proposed] restrictions would result in people having to travel more than 160ft.
- For some blind people this is further than they can reasonably navigate.
- For some people with mobility difficulties this is further than they can walk; if they could walk further it would involve enduring intolerable pain.
- Using a car also reduces the likelihood of tripping and falling on Bath’s uneven streets by enabling people to get close to their destination which may not be wheelchair accessible.
- Some might ask ‘why cannot people use a wheelchair?’ The problem here is that many of Bath’s pavements are uneven, too narrow, and obstructed by street furniture.
- There are insufficient dropped kerbs. Moreover, wheelchairs would be of little use for blind and partially-sighted people who are able to walk independently.
- There are significant changes in level across the city if people were to use manual chairs, while obtaining and using powered wheelchairs to make such journeys is not as straightforward as people might imagine. For example, it would appear that Shopmobility is currently located too far from the shops and that take-up in its use may be impacted by the problems posed by the current streetscape.
The report goes into considerable detail about the possibilities for permitting access to Blue-Badge cars, and also the problems raised in doing so:
‘The consistent feedback that we obtained from stakeholder engagement was that Blue Badge holders ought to be provided access and that security protocols be devised around their use. The eligibility and administrative hurdles were seen as potentially being too much of a barrier to what many considered are legitimate and a necessary basis for access. Having heard the testimony of Stakeholder panelists, we would agree that an over-complicated permit system could be a problem. However, what is apparent, is that there would need to be some form of security protocol used by Access and Security staff that could easily link cars and taxis with Blue Badges holders, including occasions when taxi drivers have been asked to pick up a Blue Badge holder. Moreover, there are other vehicles such as those operated by social care service providers, health and social care workers, and meals-on-wheels providers and a service such as, or similar to, dial-a-ride services that ought to be permitted access on a basis other than occupants holding Blue Badges, or at the very least meeting agreed criteria for assistance.’
The shuttle solution?
The viability of electric shuttle transport into the security zone is also examined. ‘It was worth noting that this approach is not uncommon in large transportation domains such as major rail stations and airports where travel distances are known to be too great. It is also reported that Cardiff introduced an electric shuttle service. Even so, points to consider would be as follows:
• How would this effect the viability of Shopmobility and would it work in conjunction with Shopmobility and/or make a shuttle service less or even more viable?
• The Cardiff example utilized golf buggies and many transport domains examples don’t carry wheelchair users in their chairs and consequently it would be wise to explore options that utilized the electric version of the London cab rather than offer a solution that did not include space for wheelchair users.
• Would an electric shuttle service function as a form of timetabled bus service or could they be called upon and/or even booked?
• It might even be seen as a positive attraction and chargeable for use by those without disabilities.
• It may be that if some form of electric shuttle service were provided, this might offer some solutions if there were an exchange point for particular deliveries that other residents might seek.’
The study suggested that permitted access could be given to those who met particular criteria, such as:
- Holding evidence of their access requirements, such as a Blue Badge or evidence from a doctor that supports a person’s need for a permit (so that those with injuries, awaiting surgery or not otherwise eligible for a Blue Badge can gain essential access, even for a limited period.
- Satisfying the security services that they don’t present a likely threat.
- Either living within the proposed security area/zone or immediately outside it (such as those who currently have difficulty accessing bays that are
regularly obstructed by others), or living within Bath and within a pre-determined catchment/hinterland (such that Bath can reasonably be considered as their local city).
- Regularly working in the proposed security area/zone.
Security … weighing the risks
The study does not question directly the security assumptions on which the traffic ban is said by the council to be based, but it does record the challenges to those suppositions that have been made by scheme’s critics.
‘It is recognized that Hostile Vehicle Mitigation (HVM) proposals are intended to reduce the risk posed by Vehicle as a Weapon attacks and that the HVM proposals are also part of a layered security system that includes awareness training for front line staff, additional CCTV, temporary HVM measures put into place for events such as the Christmas Market, and the police’s “Project Servator” which raises the presence of police officers in the centre when necessary. However, we would also recommend that the risk perspective also considers the impact of proposals on people over time and the risks that these impacts have on individuals who would be adversely affected. We therefore recommend that whilst it is recognized vulnerability can come in the form of short and well recognized security-related events, overall project assessment takes into account the “vulnerabilities” experienced by multiple people as a result of the detrimental effect on their wellbeing over time. This is because the accumulative result of barriers and hurdles preventing people from gaining feasible access to destinations enjoyed by others can significantly affect people’s wellbeing.
‘Whilst an assessment of security is not our remit, given the pressures placed on accessibility posed by proposed changes (even with mitigations), there are questions that have been raised during public consultation and by those with whom we have talked to, such as:
- What will the proposed measures do to prevent terrorist attacks that do not involve vehicles?
- If someone was wanting to introduce a bomb, would they not use other means of entering the area other than by a vehicle?
- Is footfall the only criteria that terrorists look for, and are not local concentrations of people, such as outside pubs, clubs, places of worship and waiting for buses outside the security area/zone just as likely to also attract hostile vehicles?
- Is allowing Blue Badge holder access to the security area any more likely to present a risk than any of the above and, if not, then why consider that excluding Blue Badge holders limits the risk if, like water, the risk can be more easily directed elsewhere?
- Mention has been made of security threat levels and that current national alert levels are at Substantial. Would it not be more reasonable and proportionate if restrictions were related to the threat levels in force at the time and only if the threat went higher than a particular level or there was particularly relevant intelligence would restrictions be increased? And, if threat levels dropped, would there then be scope to lift restrictions? Similarly, if it were known that footfall drops below a particular threshold on particular days in the week or year, could not restrictions also be lifted on these days?
‘We don’t intend to be conclusive by raising these security questions, but believe it important to address the “other side of the coin,” through these questions.’
Decisions on the ‘ring-of-steel’ plan are expected to be made by Bath Council’s ‘cabinet’ on June 23.