Valley Gardens Project Phase 3 – An Accessibility Audit by The Get Involved Group (GIG), Possability People

Date of Audit – 22nd October 2020


1.0      Introduction


1.1 Background

The Get Involved Group were asked to carry out an accessibility review of the proposed site, pre-design and build of the area which will form phase 3 of the Valley Gardens Project.

Valley Gardens is the name given to the green spaces that run from St Peter’s Church to the Palace Pier. The project area focuses on the green spaces and the surrounding roads and footways.

The northern section of Valley Gardens is referred to as Phase 1 (St Peter’s) and Phase 2 (Victoria Gardens). Phase 3 refers to the area from the Old Steine to the Palace Pier roundabout, which forms the southern half of Valley Gardens.

Fig.1 - Map of Phase 3 Area

On the day of the Audit, Graeme Trelford-Davies (Engagement & Inclusion Lead), Mandy Crandale (Operations and Development) and Clare Burgess (Student Placement) were given a walking tour of the sites by Oliver Spratley (Principal Transport Planner), taking in the completed works on phase 1 & 2, and the proposed area for phase 3. It should be noted that no work has taken place in this area at this juncture, though the majority of design work has now been completed. Oliver took us through the site and explained how it would look and work upon completion. This was very useful, as it helped us to explain to our auditors any proposed changes that they flagged as an issue in the site’s current state.

During the initial site visit, it became apparent that the best purpose of the audit would be to find and report on the following:

·         Issues which present an immediate hazard to disabled people, with risk of serious injury or death, and which need to be reported and rectified promptly.

·         Areas which are problematic for disabled people that may require some temporary mitigation measures, given that the completion date for the proposed work is over two years into the future.

·         Areas where we agree with the design proposals and corroborate BHCC’s case for implementation.

·         Further recommendations, that have not been previously mentioned in the design proposals.

1.2 Audit Team and Method.

In addition to the Possability People team previously mentioned, we were accompanied on the audit by two long standing GIG members – Ricky Perrin, who is a full time wheelchair user (and his dog!) and Iris Keppler, who is visually impaired and has mobility issues.

The journey started at the entrance to the Palace Pier and proceeded in a clockwise route, ending at the same point. All road crossings and pathways around the route were also accounted for.

Detailed notes were taken of all findings, and discussed in detail, which can be found in the following section.










2.0        Findings

The journey was divided into roughly 8 different areas, as laid out below, with comments on our findings within each area.

2.1 Crossing from Palace Pier to Royal Albion Hotel

We identified some sets of Tactile paving Strips near this crossing, the purpose of which was not clear (Fig.2).  Although identifiably hazard strips to those without visual impairments, they were quite worn and their purpose unclear to our visually impaired auditor – a risk here is that the Strips may lead the user into barrier, with a potential for injury.


We also identified that the Heritage barriers across walkway (Fig. 3/4) are a potential hazard for the visually impaired or wheelchair users and anyone with mobility issues, particular when the area is densely packed with people and they are unable to be detected until in very close proximity.  We believe they may be in place to prevent vehicles driving on the pathway, and that to do so may cause a dangerously heavy load on the archways below.  However, with the proposed plans to install modern hostile vehicle mitigation bollards across the whole of the seafront site, these heritage bollards become surplus to requirement.  We recommend that they are removed from this site and repurposed in a space where they represent less of a hazard.

Fig.3                                                                     Fig. 4



2.2 Crossing between Royal Albion Hotel to Old Steine/Harry Ramsdens –

There is no tactile paving at drop Kerb on the side nearest RA Hotel, and the ramps are too steep at both sides for wheelchair users or people with reduced mobility to navigate safely. (Fig.5)


Cars in RAH and nearby car parks overlap the kerb meaning the pathway is obstructed and too narrow for a wheelchair or two people walking side by side. The below picture shows that the entire pavement is taken up by cars, in an area where many of the pavements are extremely inaccessible or narrow (Fig. 6/7)

Fig. 6                                                         Fig.7





2.3 Around YHA towards bus stops

This area of the site is without doubt, the most hazardous and difficult part for disabled people to safely navigate.

There are major Issues with drop curbs and narrowness of pavements. It is entirely impossible for a wheelchair user or mobility impaired person to traverse this area safely, and at several times, it would be necessary to walk into the path of vehicles that are entering or leaving the parking spaces. There is a serious and immediate risk of injury in this area, and we recommend that either the work is prioritised for the early stages of the build, or that some kind of temporary measures, such as widened temporary pavements are installed. It is our opinion that with the completion of works being late 2022, that this area needs to be improved with haste, and that 2 years is too long for it to remain in its current state. Most disabled people who know this area know to completely avoid it, but for people who are unfamiliar with the layout, it could cause major issues.

(Fig. 7).                                                  (Fig. 8).

Moving towards the front of the YHA building, there is a sudden Raised platform, which can catch one unawares, and could be a trip hazard for visually impaired people.

Heading towards the car park, the area is generally obstructed by bins and bike racks, but we are aware that this car park is due to be removed and turned into a more open public space.

Our members have informed us that they completely avoid this part of the town centre, often going considerably out of their way to do so and significantly inconveniencing themselves.


2.4 Crossing bottom of North St

There were some issues caused by A frames on pavement causing an obstruction in this area.  We were unsure of the regulations around distance from building, but felt they may have been too far out into the walkways.  It would be good to have clarification of the guidance around this

Questions were raised as to whether the Phone Boxes staying or being removed?  They are right in the middle of the walkway at present, and are in a deteriorated state and serve little purpose in current times.  It was suggested that if they are staying, they be moved to a part of the walkway that is less obstructive.



2.5 Around Art Deco Bus Stops

No major issues around this area, and the walkways are fairly smooth and clear, though we are aware that the current design plan for this area will remove the road completely and be a wide paved area past the pavilion.  We agreed that this is a good idea and will make the journey much more enjoyable and make better use of the space in this area, much of which currently serves little purpose (such as the dead end lane to the side of the war memorial).  There are plans to turn the Art Deco bus stops into public service hubs of some description, though no decisions have been made as yet.  Current suggestions include bike repair hubs, recharging points, information stands and retail units.

2.6 Crossing from Bottom of North Street towards St James St (past war memorial)

No major issues in this area at present

2.7 Old Steine (pathways around and inside)

No issues identified, but we were made aware that the pathways will be changing inside the Steine and additional crossings to the east and west sides with corresponding pathways would be installed. We collectively agreed that this is very important, as crossings are currently poor, and include a hot spot for serious injury and death which could be alleviated by these measures.

2.8 Crossing from Pavilion to bottom of Edward St

Because of the differential on the pelican crossing, the middle section of the road appeared to be susceptible to congestion, which was described by one of the participants as a ‘holding pen’ and becomes quite congested.  This raises problems of its own during social distancing measures being in place, but is generally a minor hazard because of the congestion.  How will this crossing look when the layout has been changed?

2.9 Strip from Bottom Edward St to Harry Ramsdens

We identified no major issues with this area, though we did stop to look at the design plans that we had been given, and agreed that the area would be easier to walk through under the new design, though this will result in a loss of parking spaces near the ‘Glass Pavilion Building’

2.10 Crossing from Harry Ramsdens to Sea Life Centre

We noted a very short amount of time to cross at this point before lights change, which was deemed to be not long enough for a person with mobility issues to safely cross.  It is a wide section of road, however, under the new crossing, the road width appears to be shorter, as the roundabout is being removed and the crossing being placed nearer to the junction.

2.11 Bottom of Marine Parade

This area is not strictly part of the Phase 3 area, though we were asked to look over this area. We are pleased that the road has now been reopened to traffic, but converted to a one way system.  However, we identified some issues with the disabled parking bays near the pier, as illustrated by Fig.9 below, in which you can see our Auditor Ricky’s car and the issues he faced.

The disabled parking bay is on the right hand side of the road, but there are heritage barriers at the edge of the pavement, which prevent vehicle doors from being fully opened and can cause an obstruction when trying to get wheelchairs, equipment or people out of the vehicle.

We recommend that these heritage barrier posts are removed from this area and repurposed elsewhere. Alternatively, the disabled parking bays could be moved to the other side of the road where there are no obstructions.



3.0         Other issues raised


3.1          Allocation of parking spaces and Disabled bays


There are currently 49 parking bays within the phase 3 development area, of which 34 are pay and display, 9 are shared, 4 are Doctors bays and 2 are dedicated disabled bays.


The current design plans state that the total number of bays will be reduced to 21, 4 of which will be disabled bays. We still feel that this number is very low and this sentiment is shared by our colleagues within the B.A.D.G.E community group.


Furthermore, we acknowledge that not all disabled drivers/passengers hold Blue Badges. This may be for a number of reasons, such as current ineligibility, personal choice, or lack of awareness of eligibility, to name but a few. For this reason, we would recommend looking at a number of designated wider ‘accessible bays’ that are marked as such, but do not require possession of a blue badge.






3.2          Toilets and changing facilities


There are no local authority operated public toilets in the entirety of the Valley Gardens development site.  We note that the nearest toilets are the Changing Places toilets on Madeira Drive and The Level, and the toilets in Pavilion gardens.  These are not always within a suitable distance for disabled people, and while it seems unviable that additional provision can be made, there may be an opportunity to consult with local businesses and facilities to reach an agreement where disabled people may use the toilet facilities without purchase/membership/patronage.  This would be suitable mitigation for the lack of nearby toilet facilities, in our opinion.



3.3          Rotating cones on pedestrian crossings


As part of the audit, we checked that all rotating cones were in working order, and found that many were not.  Particularly around the Palace Pier and Royal Albion Hotel area, 8 such cones were found not to be working at all.  These were immediately reported to the relevant council department, but we would like to seek clarification of the frequency that these are routinely checked, and suggest that they are checked by the council at least monthly.  This facility is a lifeline and important safety precaution to partially sighted people in the city, and when they are not functioning correctly, they may cause a person to take unsafe risks, resulting in serious injury or death.


3.4          Consistency of lighting


Much of the lighting on the roads and in public spaces is due to be altered, replaced or reconfigured, and our auditors raised this issue, as it is an important one for safety, and feeling secure, in particular for visually impaired people. It is of particular importance that the consistency of light cover is taken into consideration as part of this phase.  Our auditor Iris spoke at length about how with her particular type of visual impairment, changes in the quality and brightness of light provision can have a serious effect. For example, where a journey takes place where the light quality is constantly changing, this can become disorientating, anxiety inducing, and also may contribute to trips and falls.  We recommend that particular attention is paid to ensuring the levels of light are consistent throughout the site.


Though not part of this audit, GIG members and staff embarked upon a late evening walk around of the pathways through Victoria Gardens (part of Phase 2) as it is believed similar lighting will be used in phase 3.  It was noted that although the cycle path area is well lit, the walkways are not, and the light levels are not consistent.  It was remarked upon that this pathway did not feel safe as a disabled person, and even more so as a female.




4.0          Summary List of Recommendations

More detailed information about this is in section 2 of this report, but for ease of access, each recommendation can be found in brief here.

·         Address unidentifiable tactile paving strips near Palace pier – Royal Albion hotel to avoid risk of visually impaired persons walking into barrier


·         Remove and repurpose heritage barriers across walkway near Palace Pier. These will be superfluous following the introduction of Hostile Vehicle Mitigation bollards.


·         Consider prioritising the work around the Royal Albion Hotel and YHA premises if possible, so that it is completed near the beginning of the schedule.  If this is not possible, consider some mitigation measures such as temporary widening of pathways and vehicle enforcement to prevent vehicles overhanging the pavements, and rectifying issues with drop curbs.


·         Approach YHA to discuss solutions to issues caused by raised platform outside  their premises


·         Provide GIG with definitive clarification of guidance around distance of A Frames from business premises.


·         Advise GIG at earliest opportunity about a decision on call-boxes, and discuss suitable placement for them if they are to remain.



·         Remove and repurpose heritage barrier posts from disabled parking bays on Madeira Drive, or move these bays to the other side of the road.


·         Consider increasing the number of ‘Blue Badge’ parking bays from 4 to 6.  Consider also the introduction of some wider accessible bays that do not require a blue badge.


·         Look into provision of toilet and changing facilities within Phase 3 area.  If there are no options for providing this, consult with local businesses to reach an agreement of use of their facilities for disabled people with purchase/membership/patronage


·         Seek clarification of routine checks for rotating cones on pedestrian crossings. If this is less than once per month, look to increase the frequency.


·         Take into consideration the consistency of lighting provision so that there is even cover in the darker hours.




7.0 Summary, Acknowledgements and Closing Comments

In summary, we felt that the design plans for Phase 3 of the Valley Gardens project show a great improvement on the current state of the site, with a wide range of inclusive accessibility features.  Since the initial Audit detailed here, an online design workshop has been held with some of our members and stakeholders, and progress on some of the recommendations made in this report are already being taking into consideration, such as the YHA platform issue, and some concession to the fact that more dedicated disabled bays may need to be made.

A further design workshop is to be held in February 2021, and there is a commitment to carry out further accessibility audits on the site as stages of the work are completed.


We would like to thank the transport planning department at Brighton & Hove City Council for their support and clear communication in embarking upon this work, and in particular, Oliver Spratley, as our main contact for this workstream.

Thanks also to our Auditors, Ricky & Iris, and all involved with making sure that this work gives disabled people a true voice and sense of ownership of the city in which they work and live.


Graeme Trelford-Davies

December 2020.