Submission details
| Submission ID | 12132 |
|---|---|
| Organisation | Parents of Vision Impaired NZ |
| Name | Dr Graham |
| Date | 2 July 2026 |
| Option 1: Complete school zone safety upgrade (1 = completely oppose, 5 = completely support) |
5
|
| Option 2: Targeted school safety upgrade (1 = completely oppose, 5 = completely support) |
2
|
| Option 3: Signalised pedestrian crossing on Peachgrove Road, at Wilson Street (1 = completely oppose, 5 = completely support) |
2
|
| Option 4: Focused on parking and enforcement on Peachgrove Road (1 = completely oppose, 5 = completely support) |
1
|
| Other: Do nothing at all (1 = completely oppose, 5 = completely support) |
1
|
| Please share any comments you have about why you chose to support/oppose the different options. |
PVI strongly supports Option 1 – Complete School Zone Safety Upgrade, and opposes Options 2 and 3 as insufficient responses to the safety and accessibility problems this consultation itself identifies, including congestion, poor visibility, unsafe crossings, illegal parking and regular near misses.
It provides the most equitable, accessible and future-focused solution by creating a safer environment for disabled children and young people, reducing conflict between vehicles and pedestrians, improving independent mobility, applying Universal Design principles, and delivering a consistent, corridor-wide safety upgrade rather than isolated improvements. We encourage Council to ensure that detailed design continues to include accessibility expertise, including tactile ground surface indicators, appropriate crossing design, clear wayfinding, good lighting, and ongoing engagement with disabled people and disability organisations throughout the design process. PVI further recommends that, should Option 1 proceed, Hamilton City Council undertake an accessibility audit during detailed design in partnership with blind and low vision people, orientation and mobility specialists, and disability organisations, including Blind Low Vision NZ. This should cover tactile ground surface indicators, crossing alignment, bus stop design, lighting, vegetation management and wayfinding, and should apply Road Traffic Standard 14 (RTS14) in full, including physical separation between any pedestrian and cycling facilities, to ensure the completed corridor is genuinely accessible in practice, not only in design intent. |
| How important or unimportant was retaining parking spaces on Peachgrove Road when deciding your support/opposition to each of the options? |
Neutral
|
| For Option 1: Do you support adding raised pedestrian and cycling crossings on nearby streets at an additional $600,000, bringing the total project cost to $5.4m? |
Yes
|
| Please provide any additional comments you may have about raised pedestrian and cycle crossings for Option 1. |
PVI strongly supports Option 1. It is the only option that applies a genuine, corridor-wide Universal Design approach rather than treating isolated hazards while others remain.
A safer environment for all Children and young people who are blind or have low vision experience the road environment differently from their sighted peers. Many cannot accurately judge vehicle speed or distance, see a driver's eye contact or signalled intent, identify vehicles emerging suddenly from between parked cars, or safely navigate spaces where pedestrians and vehicles compete for room. Removing most on-street parking improves sightlines for everyone and reduces the likelihood of pedestrians emerging unexpectedly from between vehicles. Parked cars also obstruct the orientation cues that low vision pedestrians rely on to navigate safely. Reducing congestion and unsafe turning movements creates a calmer environment that benefits students with vision impairment, neurodivergent students, and younger children who may struggle to interpret complex traffic situations. Universal Design benefits everyone Waka Kotahi's Pedestrian Network Guidance (2025) states that designing an environment for pedestrians should take a Safe System approach and meet universal design principles, defining universal design as the design of an environment so it can be accessed, understood and used to the greatest extent possible by all people, regardless of age, size, ability or disability. It specifically identifies tactile ground surface indicators and audible tactile traffic signals as key features that assist people who are blind or have low vision. Option 1 best reflects these principles through a continuous accessible path of travel along the corridor, improved and consistently designed crossings, safer bus stops, fewer vehicle conflict points, and a predictable walking environment. This benefits blind and low vision pedestrians as well as people using wheelchairs, guide dogs, white canes, mobility aids, prams and scooters. Physical separation, not shared paths PVI asks Council to ensure that any cycling facility delivered as part of Option 1 is physically separated from the pedestrian path, rather than a shared space where pedestrians, cyclists and scooters mix. Blind Low Vision NZ's position on shared spaces is that pedestrians who are blind or have low vision cannot reliably detect the boundary between a footpath and a cycling or shared area using paint markings or signage alone, and that signage and courtesy-based approaches do not provide the certainty that a physical, detectable separation does. Blind Low Vision NZ instead recommends physically separated cycle paths, and that Road Traffic Standard 14 (RTS14) — Guidelines for facilities for blind and low vision pedestrians — is applied and enforced, including a continuous accessible path of travel of at least 1.8 metres. We ask that Blind Low Vision NZ be consulted directly during detailed design, consistent with their stated position. A Safe System approach and the case for lower speeds Option 1 aligns with the Safe System approach underpinning Waka Kotahi's Road to Zero strategy, which recognises that people make mistakes and that roads should be designed so those mistakes do not result in death or serious injury. The World Health Organization's guidance on managing speed confirms that vehicle speed is a major determinant of both crash likelihood and crash severity, and that lower speeds substantially reduce the risk of pedestrians being killed or seriously injured. Raised crossings and school-zone traffic calming, features of Option 1, are recognised as effective measures because they encourage drivers to slow at locations where pedestrians are expected to cross. Independent mobility matters For many disabled young people, being able to travel independently to school, bus stops or nearby destinations is a critical part of developing confidence and life skills. Parents frequently report that unsafe road environments are one of the biggest barriers to allowing their children greater independence. Article 20 of the United Nations Convention on the Rights of Persons with Disabilities calls on governments to facilitate the personal mobility of disabled people with the greatest possible independence, and Article 9 requires equal access to the physical environment and transport. The New Zealand Disability Strategy 2016–2026 likewise commits to accessible communities that enable disabled people to participate fully. Infrastructure that prioritises safe, predictable walking routes gives effect to these commitments. Parking should not outweigh safety We acknowledge that removing on-street parking may inconvenience some parents and carers. However, convenience should not take precedence over safety. The consultation notes that more than 200 unrestricted parking spaces already exist on surrounding streets and that alternative short-stay parking can be provided where required. A short additional walk is a reasonable trade-off for a significant reduction in risk of serious injury to children travelling to and from school. Long-term value Although Option 1 has the highest upfront cost, it offers the greatest long-term value. Building comprehensive, accessible infrastructure once is more efficient than delivering smaller improvements that later require costly upgrading, and it aligns with Council's wider Eastern Pathways programme to create safer, more accessible routes for students walking, cycling, scooting and using public transport. |
| For Option 2: Do you support adding raised pedestrian and cycling crossings on nearby streets at an additional $300,000, bringing the total project cost to $4.3m? |
No
|
| Please provide any additional comments you may have about raised pedestrian and cycle crossings for Option 2. |
While Option 2 would improve safety at some locations, PVI does not support it because it leaves avoidable accessibility and safety barriers in place.
Disabled pedestrians do not travel through only one or two intersections; they need an accessible and predictable route from beginning to end. A route is only as accessible as its least accessible section, and inconsistent infrastructure increases cognitive load and uncertainty, making independent travel significantly more difficult for people who are blind or have low vision. We are concerned that a partial upgrade may delay delivery of a genuinely accessible corridor for many years, while leaving known risks unaddressed at the locations left untreated. |
| For Option 3: Do you support adding a raised pedestrian and cycling crossing on Wilson St at an additional $150,000, bringing the total project cost to $1.2m? |
No
|
| Please provide any additional comments you may have about a raised pedestrian and cycle crossing for Option 3. |
PVI does not support Option 3, as it addresses only a single crossing location while leaving the broader safety and accessibility problems of the corridor unresolved.
Students travelling to and from school approach the area from many directions and do not all use one crossing point; disabled students may also choose particular routes based on accessibility rather than directness. A single signalised crossing would provide a benefit at that location but would do little to improve the overall accessibility or safety of the wider school environment. Option 3 does not reflect Universal Design principles, nor New Zealand's commitments under the Disability Strategy and the United Nations Convention on the Rights of Persons with Disabilities, which recognise access to the physical environment as fundamental to participation. We consider Option 1 to be the only option that delivers a genuinely accessible and future-focused outcome for this corridor. |
| Are you giving feedback on behalf of an organisation? |
Yes, I am a spokesperson
|
| My organisation's name is |
Parents of Vision Impaired NZ
|