Transport Committee - Plug-in vehicles, plugged in policy?Written evidence from Guide Dogs

1. About Guide Dogs

1.1 Guide Dogs provides a range of mobility and other rehabilitation services and campaigns to increase the independence, well-being and dignity of blind and partially sighted people throughout the UK. Services are delivered through district teams working with other local voluntary and statutory agencies to identify individuals whose mobility would be enhanced by the provision of a guide dog or other mobility services. Guide Dogs currently provides guide dogs to over 4,500 blind and partially sighted people.

1.2 Additional mobility services are offered to those who apply for a guide dog and who need some initial mobility training prior to taking on a dog or to those for whom a guide dog is not really a suitable aid to independence. This includes both teaching people how to use a cane and sighted guide training for family members so they can lead their loved ones safely and confidently both indoors and out.

1.3 We also campaign passionately to break down barriers—both physical and legal—to enable blind and partially sighted people to get around on their own.

2. Executive Summary

2.1 Guide Dogs supports the introduction of more environmentally sustainable forms of transport, but would like to raise attention to the potential safety implications of increased numbers of low carbon vehicles on the road.

2.2 As low carbon vehicles (also known as quiet vehicles) tend to be very quiet, Guide Dogs are concerned about the safety implications for blind and partially sighted people and other vulnerable road users. The sound of a vehicle is used as a cue for blind and partially sighted people to help them navigate safely.

2.3 Research is being carried out to ascertain how quiet vehicles can be made audible and consequently safer for blind and partially sighted people and others who rely on hearing vehicle noise. There is also work currently taking place at international level to implement regulations stating minimum noise levels for these vehicles.

2.4 Guide Dogs recommends that artificial sounds be installed on quiet low carbon vehicles. These sounds should be discernable, recognisable as the sound of a vehicle and indicate the speed, direction and distance from the listener.

2.5 With regard to the installation of charging points for low carbon vehicles, Guide Dogs would like to see local authorities taking steps to ensure that charging cables do not present a trip hazard for blind and partially sighted people.

3. Guide Dogs’ Concerns about Low Carbon Vehicles

3.1 In the last few years, there has been a rise in the interest in vehicles with low carbon emissions, including quiet internal combustion engines, electric and hybrid vehicles, with an increasing number coming onto the market. Guide Dogs recognises the environmental benefits of these vehicles and their role in improving fuel economy and reducing carbon emissions. However, electric, hybrid and low noise internal combustion engine vehicles, some of which operate on electric power at low speed, are virtually silent, particularly at speeds under 20 mph. Thus there are serious implications for the independent mobility and safety of blind and partially sighted people and a wider range of other vulnerable pedestrians and road users.

3.2 Guide Dogs also believes that low carbon vehicles will also have implications for other groups of pedestrians and road users including older people and young children and also cyclists. A report by the USA National Highway Traffic Safety Administration stated that hybrid and electric vehicles are nearly twice as likely to be involved in accidents with pedestrians as vehicles with internal combustion engines.1

3.3 Blind and partially sighted people, like other vulnerable pedestrians and road users, are reliant on audible environmental cues to assist with their mobility and orientation. The sound of a vehicle’s engine is used as a primary cue and clear indicator to establish its movement, speed and proximity. This is particularly important when crossing roads, especially when there are no controlled pedestrian crossings with audible and tactile indicators. The sound of oncoming traffic, or absence of this sound, is used as a cue to assess when it is safe to cross the road.

3.4 Most vehicles with an internal combustion engine have a distinct sound and range of noises to indicate their actions and movement. These are familiar to most blind and partially sighted people, who can detect a vehicle’s presence and estimate its type and size by what it sounds like.

3.5 Guide Dogs believes that low carbon vehicles need to have a way of indicating their presence, direction of travel towards or away from the listener, speed and rate of acceleration or deceleration. Vehicles should also emit a sound when reversing along with other less predictable elements of manoeuvring, like for example, being parked up but the drive train is engaged and ready to move off.

4. Political Response

4.1 Research in Japan, the US, UK and Europe has aimed to determine the cause for blind and partially-sighted peoples’ concern, looking at technological and legislative ways to make quiet vehicles audible and safer for pedestrians and other vulnerable pedestrians and road users.

4.2 Work has been done to understand the concerns of blind and partially-sighted people, regarding their ability to hear vehicles at differing speeds, and whilst the vehicles are performing different manoeuvres. Research has also been undertaken to look at possible alternative sounds to replace the noise generated by a conventional combustion engine on electric and hybrid vehicles.

4.3 Regulations have been implemented in the US and Japan to protect the interests of pedestrians in relation to quiet and hybrid vehicles, as well as international regulations being developed by the United Nations Economic Commission for Europe (UNECE), through the Working Party on Noise (GRB) and its informal sub-group Quiet Road Transport Vehicles (QRTV). An announcement is expected to be made later this year.

5. Recommendations for the Safety Implications of Low Carbon Vehicles

5.1 Guide Dogs believes that any sound generated by a quiet internal combustion engine, hybrid or electric vehicle needs to be distinct so as to be recognised as a vehicle, and indicate its distance from the listener, direction and speed of travel. The sound must also be discernible in a wide range of environmental conditions—from quiet country lanes to busy town centres. It should also indicate the type and size of the vehicle to differentiate between different–sized cars.

5.2 Consideration must also be given to the safety of people with hearing impairments. Older people often have reduced sight and hearing. Any sound used for electric and hybrid vehicles should be at least as discernible to people with impaired hearing as the majority of petrol and diesel vehicles.

5.3 Consideration should also be given to the requirement for sound to be generated within a vehicle to indicate its movement. Many blind and partially sighted people can determine information about the movement of a vehicle when travelling in it from the engine sound.

6. Charging Points

6.1 With regard to charging points for low carbon vehicles, local authorities must consider the design and location of public charging points, to ensure they are located away from pedestrian routes and cables do not present a hazard to pedestrians. The issue of charging vehicles at private residences where there is no off-street parking must also be considered, as this may potentially involve running cables across footways.

April 2012

1 Incidence of Pedestrian and Bicyclist Crashes by Hybrid Electric Passenger Vehicles: Technical Report. U.S. Department of Transportation, National Highway Traffic Safety Administration, September 2009.

Prepared 20th September 2012