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To, The Managing Committee, Chennai City Connect, 9th Floor, SKCL Towers, Triton Square, unit no c3 - c7, TVK Industrial

Estate, Guindy Chennai, Tamil Nadu 600032

Subject: Analysis of the ITDP Regulations from the perspective of Persons with Disabilities.

Sir/Madam, On behalf of Persons with Disabilities in India, who are estimated to be around 10% of the total Indian Population, we would like to place on record our appreciation for the work being done by Chennai City Connect, especially in light of the fact that the venture is non profit and is being done by professionals who are taking time out from their schedules to try and make Chennai a better place to live in. A better road layout system is beneficial for people of all ages, backgrounds and abilities. The document “Better Streets, Better Cities” contains many laudable measures and again we would like to say that these were much needed.

However, we believe that if the city is to become truly inclusive for persons with disabilities such as those who use crutches, wheelchairs or mobility scooters, the deaf, and the blind and visually impaired, certain additional measures must be taken. By including such measures in a preliminary planning stage, the ultimate costs of such inclusions will be minimal and relative to this, the benefits to persons with disabilities in the city of Chennai will be tremendous. Besides persons with disabilities, the elderly stand to benefit greatly from these measures. As you are aware, India became a signatory to the United Nations Convention on the Rights of Persons with Disabilities in the

year 2007, which mandates that measures must be taken to make all public infrastructure and services accessible for persons with disabilities

Specific Feedback And Input

While considering the needs for pedestrian design, a clear provision needs to be made for those pedestrians with disabilities. As you aware India has not yet formulate clear standards with respect to access to pavements and the road system and therefore international standards must be adopted, on the lines of what has been done in the United Kingdom1.

PART A: Footpaths With regard to Footpaths (Para 2.1 of Better Streets, Better Cities), the provisions made in the document2are extremely important, however, the inclusion of other provisions in light with international standards may help in making the footpaths more accessible for persons with disabilities as well as the population in general: Grade3: The sidewalk grade ideally should not exceed 5 percent. In cases where the gradation is beyond this, a level landing must be installed. The size of this landing should be large enough to allow wheelchair users to stop and rest without blocking the flow of pedestrians. In areas with steep slopes, consider installing wide sidewalk corridors that permit the wheelchair user to travel in a zig-zag motion.

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http://assets.dft.gov.uk/publications/access-inclusive-mobility/inclusive-mobility.pdf pp. 2.3 A continuous unobstructed minimum width of 2m ƒ No breaks or obstructions at property entrances and side streets ƒ Continuous shade through tree cover ƒ No railings or barriers that prevent sideways movement on and off the footpath ƒ Elevation over the carriageway (e.g. +150mm) and adequate cross slope for storm water runoff. At the same time, the elevation should be low enough for pedestrians to step onto and off of the footpath easily ƒ Surmountable gratings over tree pits to increase the effective width of the footpath 3 Guidelines taken from http://www.bikewalk.org/pdfs/sopada_fhwa.pdf, p. 9.
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Cross Slope4: The maximum cross slope permitted by the Americans with Disabilities Act Accessibility Guidelines (ADAAG) is 2 percent. Severe cross slopes require wheelchair users and other pedestrians to work against the effects of gravity to maintain their lateral balance. Pedestrians using crutches or canes may be forced to turn sideways in order to keep their base of support at a manageable angle. Severe cross slopes can cause wheelchair users to veer towards the curb and into the street, the impact of which are compounded when combined with steep grades and uneven surfaces. See Annexure A for illustration. Handrails5 : Where the grade drop-off adjacent to the sidewalk is 460 mm or more, a handrail or guard is recommended as an aid to persons with visual limitations. Continuous handrails should be provided on both sides of all ramps or stairs, or wherever three or more steps are provided. Handrails should be of a smooth, easy to grip design, no more than 50 mm in diameter; and mounted at an appropriate height. Handrail ends should terminate either by turning down, or by going into the wall as an aid to persons who have visual limitations. Where height differences are significant, guards are required on both ramps and stairs. Handrails and/or guards should not be located within 1000 mm of any roadway. Surface materials6 The following need to be kept in mind while deciding the surface materials for sidewalks: • Changes in level: The material should not be cobbled etc. and should be consistent in level.

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Id. http://www.toronto.ca/diversity/pdf/accessibility_design_guidelines.pdf, p. 6. http://www.bikewalk.org/pdfs/sopada_fhwa.pdf p. 11

• Firmness, stability, and slip resistance: The material should be durable for use by wheelchair, crutches and other assistive devices regardless of the season. • Dimensions of gaps, grates and openings: Tiled surfaces should not have grates, and there should be no fear of crutches or wheels entering into any. • Visual consistency: Decorative textured surface materials can make it more difficult for pedestrians with vision impairments to identify detectable warnings, which provide critical information about the transition from the sidewalk to the street. For these reasons, brick and cobblestone are not recommended. Creative alternatives include smooth walkways with brick trim, and colored concrete.

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Zones: The ITDP document gives three zones into which the sidewalk area is divided7.It is important for these divisions to be clearly demarcated by means of colour, and by some minor surface indicators which are discernable to persons with vision impairment. With regard to driveway crossings, part of frontage, they should be designed with the principles of recognizing that frontage is public property and needs to be create impediments to persons with disabilities from enjoying their right to public way8: Curb Ramps9: • Curb ramp slopes must be regulated in a manner that creates least impediments for persons with disabilities. The heights of curbs must

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A. Pedestrian zone. This zone provides continuous space for walking and should be clear of any obstructions. It should be at least 2m wide. B. Frontage zone. Provides a buffer between street-side activities and the pedestrian zone. Next to a compound wall, the frontage zone can become a plantation strip.

C. Furniture zone. This is a space for landscaping, furniture, lights, bus stops, signs, and private property access ramps. 8 http://www.bikewalk.org/pdfs/sopada_fhwa.pdf p. 17 9 http://www.bikewalk.org/pdfs/sopada_fhwa.pdf p. 21.

also be limited to permit easy access to sidewalks in case a curb ramp is inaccessible for any unforeseen reason. • Users must have enough room to maneuver towards the direction of the crosswalk. There must be a bottom level landing of clear space outside the direction of motor vehicle travel. A level landing at the top of the ramp is also a must. • A strip of detectable warnings must be installed at the bottom of a perpendicular curb ramp. • People with vision and cognitive impairments have difficulty detecting where the street begins and ends. Detectable warnings, contracting surface materials, and barrier posts are measures that can be used to convey the transition between the street and sidewalk at depressed corners. • Significant changes of grade as pedestrians travel from the down slope of the ramp to the up slope of the gutter can cause wheelchair users to fall forward and should be limited accordingly. See Annexure B for illustrations

PART B: Pedestrian Medians and Refuges

1. With regard to Pedestrian Medians and Refuges (Para 2.5 of Better Streets, Better Cities), the design should insist on curbed or barrier medians to physically separate pedestrians and motorists rather than painted flush, or gates/fences. Furthermore, all medians should be accessible to pedestrians.

2. The nose of the median should be extended beyond the crosswalk. If a cut through is provided, it should be at of a width which allows two wheelchair users to pass each other. In addition the edges of the cut through must be perpendicular to the street being crossed.

3. Ramped medians should have a curb ramp at either end and a level landing, again large enough to accommodate a wheelchair. For all medians, cut through or ramped, a strip of detectable warnings should be located at the entrance and exit.

4. In case of a Corner Island, the design should be similar to those of the median. The island should be raised and designed with curb ramps or a pedestrian cut-through along with detectable warning strips.

See Annexure C for Illustration

PART C: Pedestrian Crossing

In cases of Pedestrian Crossing (Para 2.6 of Better Streets, Better Cities) the following additional guidelines should be in place to assist persons with disabilities: Traffic Signals10: Both audible and flashing crossing signals should be provided as an aid to persons who have hearing or visual impairment. • Audible pedestrian signals should be loud enough to be heard clearly above the ambient noise (i.e.: at least 15 decibels louder than ambient noise). • Two different audible pedestrian signals, identifying when it is safe to cross either direction, (as indicated by a separate tone) are required for persons with visual disabilities. • Where extended time is required to cross, (e.g., by seniors and persons with disabilities), a clearly marked pedestrian button should be available and mounted on a pole beside the curb cut, at an accessible height for persons with disabilities.
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Guidelines from http://www.toronto.ca/diversity/pdf/accessibility_design_guidelines.pdf p. 35.

• Tactile features should be provided as an aid to persons who have both hearing and vision limitations. (ie. A tactile or vibro-tactile feature on pushbuttons.) • In locations frequently used by seniors or persons with disabilities e,g, near gardens, special schools, special homes etc. crossing timing should be provided to permit pedestrians, or wheelchair users to cross safely.

PART D: Landscaping

With regard to Landscaping (Para 2.7 of Better Streets, Better Cities ) as the document points out trees11 are also one of the most common causes of sidewalk cracks and changes in level. When water is limited, tree roots tend to push through the surface and spread out rather than down to look for new water sources. Tree branches should be maintained as hanging branches can be a safety hazard, especially for pedestrians with vision impairments who may not detect them. Other pedestrians with mobility impairments may have difficulty bending under them.

PART E: Bus Stops

Regulations regarding Bus Stops (Para 2.8 of Better Streets, Better Cities) should be disabled friendly and ideal guidelines can be found here12. See Annexure E for Illustration.

PART F: Street Furniture

1. Regarding Street Furniture (Para 2.10 of Better Streets, Better Cities) and furniture zones, street furniture can cause problems for both

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Id. http://assets.dft.gov.uk/publications/access-inclusive-mobility/inclusive-mobility.pdf para

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wheelchair users and for people who are visually impaired of making it apparent to people with reduced mobility13.

2. The positioning of posts, poles etc. must be consistent and away from general lines of movement. Thus lamps (and signs) should be mounted on walls or buildings whenever possible; if not, then placing them at the back of the footway as near the property line as possible is acceptable.

3. Waste bins should continue down or close to ground level and should be of a rounded design. Bins should be colour contrasted to their surroundings. Bins, Bollards and flowerbeds should adhere to a minimum height so as to not create problems for persons with low vision.

PART G: On Road Parking

1. On Road Parking (Para 2.11 of Better Streets, Better Cities) must include accessible parking which is needed for drivers using wheelchairs or with other mobility difficulties. Along with at major areas of commerce and recreation, accessible parking is especially needed near major transit stops, for use by those who wish to transfer from a car to a bus or train.

2. Reserved Parking must be demarcated with a sign with the international symbol of accessibility mounted high enough so it can be seen while a vehicle is parked. Adequate space must be kept on both sides of the vehicle for entry/exit and unloading of wheelchairs, scooters or other mobility devices14.

See Annexure D for illustration.

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Guidelines from http://assets.dft.gov.uk/publications/access-inclusive-mobility/inclusivemobility.pdf pp. 3.7 14 http://www.independentliving.org/mobility/mobility.pdf p. 5.

PART H: Street Lighting

Street lighting (Para 2.14 of Better Streets, Better Cities) is indeed very important for people with disabilities. All public thoroughfares and pedestrian routes need illumination to ensure safe access for persons with disabilities at sidewalks, bus stops, or parking areas leading to public facilities or amenities. The following are the guidelines as prescribed under the Toronto Accessibility Design Guidelines15. 1. Lighting levels of 100 lux. (10 ft. candles) measured at the ground of all accessible pedestrian entrances are recommended as an aid to persons with visual disabilities. 2. At frequently used pedestrian routes (including paths, stairs, and ramps) recommended lighting levels should be 30 lux. (3 ft. candles). 3. In accessible parking areas, lighting levels are recommended to be a minimum of 50 lux (5 ft. candles) at accessible parking spaces and along accessible routes from areas of parking to accessible entrances. 4. Lighting sources should be selected and located at, or beside steps and stairs, to ensure clear definition of treads, risers, and nosings. 5. All lighting over pedestrian routes should be evenly distributed, provide a reasonable colour spectrum, and minimize cast shadows for persons with low vision. 6. Supplementary lighting should be provided to highlight all key way-finding signage. 7. Lighting standards or posts should be mounted to one side of pedestrian walkways so as not to inhibit free movement of persons using mobility aids. 8. Low-level lighting standards should be tall enough to clear usual levels of water logging accumulation.

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http://www.toronto.ca/diversity/pdf/accessibility_design_guidelines.pdf p. 36

9. Overhead light fixtures should be mounted on standards that ensure clear headroom of 2030 mm is available, below fixtures or supports, as an aid to persons with visual limitations. 10. Lighting of landscape on special site features should be designed and installed to minimize direct glare to both pedestrians and building users.

Conclusion As mentioned above, the changes/additions specified are necessary for persons with disabilities to have equal access to the city of Chennai and its streets and pavements. These changes/additions are in line with international standards and we firmly believe that the incidental costs and efforts of including them at this stage will be minimal, yet the benefits which can be achieved for persons with disabilities would certainly set new precedents for all Indian cities. In the light of the above, we strongly urge Chennai City Connect to incorporate the suggestions mentioned above to ensure that the document “Better Streets Better Cities” adheres to the principles of equality and non-discrimination as enshrined in the Constitution of India, and also to ensure that India is compliant with its obligations to its disabled citizens and to the international community under the UNCRPD. In conclusion, we deeply appreciate the hard work and effort that has gone into the preparation of the document “Better Streets Better Cities” and sincerely hope that the additional measures benefitting the disabled while planning street design be incorporated in your plan.

We would also like to place on record our willingness to assist you on this issue.

Thanking you,

Inclusive Planet Centre for Disability Law and Policy Amba Salelkar Email: amba.salelkar@gmail.com

With input from 1. AccessAbility Shivani Gupta. Email: shewany@gmail.com

To be added

Annexure A

From: http://www.bikewalk.org/pdfs/sopada_fhwa.pdf p. 10

Annexure B – Curb Ramps

From http://www.bikewalk.org/pdfs/sopada_fhwa.pdf p. 21

Annexure C Corner Islands and Medians

From http://www.bikewalk.org/pdfs/sopada_fhwa.pdf p. 32

Annexure D: Parking Spaces

From http://www.independentliving.org/mobility/mobility.pdf p. 6

Annexure E: Bus Stops for the Disabled

From

http://assets.dft.gov.uk/publications/access-inclusive-

mobility/inclusive-mobility.pdf