To the Minister of Development of Communities and Territories of Ukraine
Alexey Chernyshev
Copy: Ministry of Infrastructure of Ukraine
National Police of Ukraine
To the Commissioner of the President of Ukraine for people with disabilities
Valeriy Sushkevich
Government Commissioner for the Rights of Persons with Disabilities
Tatiana Barantsova
Request.
on the regulation of the installation of ground traffic restrictors in areas of pedestrian paths
We would like to draw your attention to the fact that in cities and towns of Ukraine, the installation of barriers on pedestrian paths and sidewalks to prevent vehicles from entering these areas is becoming increasingly widespread. However, such barrier elements are often used, which often pose a threat to the safety and health of pedestrians.
Various structures and barriers in the way of pedestrians pose a high risk of injury to many categories of pedestrians, and pose a danger and threat to people with profound visual impairments (blind and visually impaired) and people with musculoskeletal disorders. Such structures pose a threat and risk of injury to other categories of people with limited mobility, namely
- small children (up to 6 years old);
- persons with temporary health disorders, such as abnormal blood pressure, fever, and vestibular disorders;
- people after injuries, strokes, with impaired balance, etc;
- all categories of pedestrians who move along the relevant paths at dusk and in the dark, or during the day in bright sunny weather;
- persons who were distracted while driving (phone, external factors);
- persons under stress or intoxication, etc.
The corresponding structures and barriers are traumatic for almost all pedestrians every year seasonally from late autumn to spring, when obstacles are hidden under a layer of snow or ice that hides even contrasting barriers (see the photo in the appendix).
The fact that various decorative vases with flowers or 80 cm high bollards were previously installed on pedestrian paths was more or less tolerable. But when they started installing various barriers in the form of balls, hemispheres, pyramids, 0-30 cm high posts, and other restrictive structures randomly at the discretion of their owners, it became a direct threat to pedestrians! Often these spheres and hemispheres are made of dark granite material for «aesthetics». In rainy weather, their surface glistens and merges with the sidewalk surface, making them invisible.
And recently, in Lviv, at the newly constructed facility «Reconstruction of Dvirtseva Square in Lviv,» new «masterpieces» have appeared in the form of irregularly shaped concrete prisms up to 20-30 cm high, which are installed with an edge up and merge with the general paving. It seems that such a «work» is intended not so much as a barrier for vehicles, but rather a danger to people!
At the same time, we note that a number of current Ukrainian regulations stipulate that the installation of various obstacles and barriers on traffic routes is not allowed. In particular:
DBN B.2.2-40:2018 Inclusiveness of buildings and structures
Definition of the concept:
path of movement - a pedestrian path used by IHH to move around the site (paths, sidewalks, ramps), as well as at the entrance to a building or structure and inside buildings and structures (horizontal and vertical communications).
5.1.2 It is necessary to provide conditions for unimpeded movement around the site.
5.1.10 Columns, information stands and road fences shall not be installed on pedestrian routes.
DBN B.2.3.-5 Streets and roads of settlements
5.3.1
No road fencing, poles, advertising structures, temporary structures, manhole pits and rainwater inlets, stairs and porches, etc. may be installed on the pedestrian zone of the sidewalk.
DBN B.2.2-5:2011 Landscaping of territories
4.20.7 Landscaping elements that may become an obstacle for people with disabilities should be placed in a single line outside the pedestrian zone. These obstacles should be marked using bright and contrasting colors.
But in fact, it seems that the above examples of barriers on pedestrian paths in all cities and towns of Ukraine are illegal? In this case, it requires an administrative response.
In view of the foregoing, we are kindly requesting:
- Provide an official explanation of the current regulatory acts of Ukraine that regulate the installation of ground-based traffic limiters in the area of pedestrian paths. What shape and size should they be and what exactly should they look like?
- Provide references to the current regulatory legal acts of Ukraine that unify the types, types and varieties of the mentioned restrictors and clearly define the rules for their installation and dismantling on the ground.
- Raise the issue of introducing appropriate amendments and additions to the state building codes and standards regarding specific requirements and prescriptions for the types and location of ground traffic barriers in pedestrian areas.
In our turn, we propose to spell it out as follows:
If it is necessary to restrict the entry of a vehicle onto the sidewalk in pedestrian crossing areas, it is allowed to install restrictive bollards/bolards at least 70-80 cm high, at least 0.25 m in diameter with a contrasting reflective strip 0.3 m wide or completely different in color from the color of the surface on which they are installed (i.e., in contrast). The distance between the columns should be at least 90 cm.
Photographic illustrations of blatant violations
pedestrians' rights to safe movement
