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Pedestrian safety fears raised over floating bus stops on new cycle lane in Bath

Similar infrastructure elsewhere has faced opposition – but councillor says people just need to get used to it

Floating bus stops on a new cycle lane in Bath have come under criticism due to claims that the infrastructure puts pedestrians getting on and off buses at risk.

The cycle lane on the A4 Upper Bristol Road is modelled on a concept common in the Netherlands and elsewhere, and which is increasingly being rolled out in the UK, in which segregated bike lanes on roads used by buses run alongside the footway at bus stops, which are placed on an island between the footway and the main carriageway.

Upper Bristol Road

Pedestrians using zebra crossings to access the bus stop islands have priority over cyclists, who should stop if someone is crossing the cycle lane ahead of them.

But BBC News reports that concerns have been raised about potential conflict between cyclists and pedestrians.

Local resident Dominic Violante told the broadcaster: “Stepping off the bus into a cycle lane – it’s an accident waiting to happen.

“The road has been made more narrow to fit the system which makes it dangerous for vehicles too – it is absolutely ridiculous,” he claimed.

But Bicycle Mayor for Bath, Saskia Heijltjes, said: “It is safe, when I am cycling, it is clear to me that I need to stop for bus users – the markings on the path are easy to see.”

The infrastructure, which is being funded by the Department for Transport, is being installed by Liberal Democrat-controlled Bath & North East Somerset council, which has also produced a video showing how the bus stops function.

Councillor Matt McCabe pointed out that it was in line with nationally agreed standards for active travel infrastructure.

“Once people get used to it, and cyclists realise that they must stop or they are breaking the law, it will become safe,” he said.

Upper Bristol Road lies very close to road.cc’s office in Green Park Station, and website co-founder Dave Atkinson outlined why he believes the segregated cycle lane is necessary.

“Cycle lanes are always only as good as the worst bit, and the provision into the city centre from Weston and Newbridge, which is predominantly flat and easily cycleable for many people, is patchy at best.

“So the council deserves credit for at last making a proper attempt to introduce a separated cycling corridor along the Upper Bristol Road.

“The road has been narrowed but there’s no reason it should be any more dangerous or congested for vehicles than it was: no traffic lanes have been removed. A safer alternative for getting into the centre is a must to get people to change their transport habits, and this scheme is a solid start.”

He pointed out that besides the floating bus stop, “There’s a couple where there’s no island so you’re actually standing on the cycle lane to get on the bus. Having said that, I’d class the bus stops along that route as sparsely populated,” he added. An example of one of those is shown below.

A major benefit of floating bus stops in terms of improving the safety of cyclists is that it avoids the need for them to overtake stopped buses, which can often cause conflict with oncoming motor traffic.

Bath Cycle Lane Bus Stops - 10.jpg

They have been introduced on a number of segregated cycle routes in London and elsewhere in recent years.

However, as in Bath, their installation is often accompanied by people raising concerns about the safety of pedestrians crossing to and from the bus stop.

In 2016, St Thomas’s Hospital tried unsuccessfully to block a floating bus stop outside the hospital on Westminster Bridge, claiming it would put patients and their families at risk – although as cycling blogger Mark Treasure highlighted at the time, cycling was already permitted on the footway there.

> Top London hospital tries to block segregated cycle lane

More recently, in October this year the National Federation of the Blind and 162 other disability campaign groups representing disabled people handed in a petition to Number 10 Downing Street calling for an end to the installation of floating bus stops due to the danger they claimed such infrastructure posed to disabled people.

Sandy Taylor, who is registered blind and uses public transport to travel around Glasgow, said that it was “like playing Russian roulette” to cross the cycle lane to access the island and the bus stop.

> “Like playing Russian roulette”: Blind people raise concerns about ‘floating’ cycle lane bus stops

When the sustainable transport charity Sustrans analysed 28 hours of video footage from a floating bus stop on Hills Road in Cambridge, however, it found that “all interactions” between road users there showed “safe, normal behaviour.”

It added that 99 per cent of cyclists filmed had no interaction with pedestrians, and that of the 42 interactions that did happen between pedestrians and cyclists, all were at peak times, and all scored one or two on a five-point hazard scale.”

Simon joined road.cc as news editor in 2009 and is now the site’s community editor, acting as a link between the team producing the content and our readers. A law and languages graduate, published translator and former retail analyst, he has reported on issues as diverse as cycling-related court cases, anti-doping investigations, the latest developments in the bike industry and the sport’s biggest races. Now back in London full-time after 15 years living in Oxford and Cambridge, he loves cycling along the Thames but misses having his former riding buddy, Elodie the miniature schnauzer, in the basket in front of him.

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38 comments

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paulrattew | 1 year ago
3 likes

So, this is at the start of my daily commute (I live just up the hill from there and commute into central Bristol). 

It's not perfect, but I have yet to see a single problem. It's self evident how to use it and everyone seems to be being pretty sensible. I'm sure there will be some conflict caused by people being twats or just being idiots - riders failing to look out and give way to pedestrians, pedestrians standing in the cycle lane instead of on the pavement or the island - but I've yet to see it. 

I would far rather that they had installed a wider two way route on one side of the road - the sort that can be used by emergency vehicles in emergencies (like you see with ambulances along the Embankment in London). By having a narrow lane on both sides of the road it means there is no room for emergency vehicles to bypass vehicular traffic when the road is very busy. Cars can only move over so far, whereas bikes can completely disappear from the bike lane (as, to use the same example again, evidenced by behaviour on Embankment). That said, it's not a bad lane. I'm not convinced it serves much of a purpose, but hopefully once (if) there is a more integrated network it will induce some demand

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BIRMINGHAMisaDUMP | 1 year ago
3 likes

It's just anti cycle infrastructure 'hysteria'. You could raise exactly the same concerns about a zebra crossing, for example. But people don't. Because they accept that (most) motorists behave sensibly around zebra crossings. Just as the vast majority of cyclists behave sensibly around floating bus stops. 

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Rendel Harris replied to BIRMINGHAMisaDUMP | 1 year ago
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BIRMINGHAMisaDUMP wrote:

It's just anti cycle infrastructure 'hysteria'. You could raise exactly the same concerns about a zebra crossing, for example. But people don't. Because they accept that (most) motorists behave sensibly around zebra crossings. Just as the vast majority of cyclists behave sensibly around floating bus stops. 

Agree on the ones with a strip between the kerb and the cycle lane for the passengers to wait/disembark, but not on the ones where the passengers have to step from the bus straight into the cycle lane; they are as if you had a zebra crossing going straight up to the door of a building with no pavement on which pedestrians can wait and check it's safe to cross and where oncoming traffic can't see anyone crossing until they're actually on the zebra.

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HoarseMann replied to Rendel Harris | 1 year ago
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Well it's not great, but in that last photo, you can see a shared use path sign - so even if it was all pavement, you could still cycle on it, but without any speed humps or crossing signage. So I don't think it's necessarily made things less safe.

The Dutch example shared by Chris is the way to go, a pavement island where passengers board, and crucially, no zebra crossing for the pedestrians. Make it their problem to cross the cycle lane safely, then you can't complain about dangerous cyclists.

Plus, to be fair, it's far more disruptive for a cyclist to have to stop for crossing pedestrians than a pedestrian to just pick a gap in the flow of bikes. If the worst were to happen, a ped/rider collision is not as bad as a ped/car, so the argument for zebra stripes is not as strong. Plus it'll hopefully prevent bus passengers from queuing on the crossing if it's not there, blocking the lane for cyclists and forcing them to wait or go into the road and mix with traffic. 

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brooksby replied to HoarseMann | 1 year ago
2 likes

HoarseMann wrote:

The Dutch example shared by Chris is the way to go, a pavement island where passengers board, and crucially, no zebra crossing for the pedestrians. Make it their problem to cross the cycle lane safely, then you can't complain about dangerous cyclists.

I completely agree with you.

(however, the high point of many peoples' days seem to be complaining about dangerous cyclists...)

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chrisonabike replied to Rendel Harris | 1 year ago
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(Not at you personally, just a caution to the "but but ... we can't do that")
Let's get real - this change for the UK is - sadly - the work of generations. Plural. Unless all the red-tops / wherever people go for their meeja these days get behind it...

However hundreds of people get off buses RIGHT INTO THE CYCLE PATH every day in Copenhagen:

https://robertweetman.wordpress.com/2017/09/17/copenhagen-bus-stops/
(Scroll down to "Loading/ unloading from/to cycle track")

Is it ideal? I wouldn't say so - there's a better way - but it seems to work. Millions of people cross cycle paths daily in NL. But can I guarantee it is safe for the blind? No. Not is crossing the road. Is it better overall? I'd say so, people can do their own research.

https://bicycledutch.wordpress.com/2019/06/12/how-hard-is-it-to-cross-th...

So again I understand (because CHANGE!! And currently "packs of marauding drivers"). And because the UK apparently specialises in cargo cult infra and sabotaging simple and workable ideas. It often seems we're desperate to make perfect the enemy of "much better than now" though. Often by taking things to logical extremes that we just ignore when it comes to motor traffic.

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Bmblbzzz replied to chrisonabike | 1 year ago
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chrisonatrike wrote:

(Not at you personally, just a caution to the "but but ... we can't do that") Let's get real - this change for the UK is - sadly - the work of generations. Plural. Unless all the red-tops / wherever people go for their meeja these days get behind it... However hundreds of people get off buses RIGHT INTO THE CYCLE PATH every day in Copenhagen: https://robertweetman.wordpress.com/2017/09/17/copenhagen-bus-stops/ (Scroll down to "Loading/ unloading from/to cycle track") Is it ideal? I wouldn't say so - there's a better way - but it seems to work. Millions of people cross cycle paths daily in NL. But can I guarantee it is safe for the blind? No. Not is crossing the road. Is it better overall? I'd say so, people can do their own research. https://bicycledutch.wordpress.com/2019/06/12/how-hard-is-it-to-cross-th... So again I understand (because CHANGE!! And currently "packs of marauding drivers"). And because the UK apparently specialises in cargo cult infra and sabotaging simple and workable ideas. It often seems we're desperate to make perfect the enemy of "much better than now" though. Often by taking things to logical extremes that we just ignore when it comes to motor traffic.

From the notes at the bottom of the Robert Weetman blog: 

Arrangements like this can create real issues for people with visual impairments who depend on bus access, but who are worried about collisions with people cycling. Where people are already badly excluded by wider issues of street design, this additional loss can be very serious. Even if fears are unfounded it is wrong to ignore or downplay these fears.

This gets to the heart of the problem; blind people are already excluded from the street, more so then cyclists, and the nature of their disability means they don't know what's there until it gets too close; so their instinct is not to trust.

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chrisonabike replied to Bmblbzzz | 1 year ago
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... which I have said before. And I believe the blogger's background is in working with people with disabilities so he's up on that.
However while I know that recently some groups affected have raised concerns - and we should engage with them - what I see over and over is either "selective concern". We seem OK with electric cars (quiet at low speed), electric scooters... and so often it's e.g. there's a busy four lane 40mph road which people are expected to cross, but now you're putting in a 1.5m cycle track? Think of the disabled!

Alternatively it's a "you can do it if it changes nothing" eg. You can have a metre or so from the road but we have buses - oh, now there's potential conflict... no, our street is too narrow (except for the 7m used by motor traffic).

I think there are ways to deal with concerns and particular issues, again often looking at the wider area or specific requirements of a place, but it often seems to become an exercise in shooting down any change because it doesn't solve all problems at once. Or simply requires change for motor traffic.

For me the questions are "can we continue the same way, making more space for motor traffic? If not what can we do about that? If cycling (or "wheeling") Is part of the answer how do you get to a place where that becomes a normal mainstream transport mode? "

The answer to the last isn't "by *encouraging cycling* (with posters! by saying its a good thing! ), by tacking on the odd isolated and compromised facility - where it doesn't impact motor traffic". Because we've done that for well over 25 years with very little to show.

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Bmblbzzz replied to chrisonabike | 1 year ago
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Re "selective concern" that is undoubtedly true in terms of "think of the disabled!" but the blind/disabled people I know seem equally concerned about electric cars as bikes. And e-scooters, parked haphazardly on the pavement, are a real bugbear for them! 

As to "encouraging cycling", I think there's probably more normalising-power in mainstreaming walking (and possibly even e-scooters!) as they seem more universally accessible. But we won't get anywhere without addressing planning, economic factors such as jobs and housing, etc.

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chrisonabike replied to Bmblbzzz | 1 year ago
1 like

Agree - for the UK this would be system- level change. Hence "generations". But significant changes do happen in human affairs. We can either just ignore changes, be reactive or - *as already happened with the car* - attempt to direct affairs. After all the last PM managed to make a significant (negative) economic impact in no time at all...

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Christopher TR1 | 1 year ago
3 likes

There's one on my commute. I always switch to the road to avoid the future bus passengers as they mill about, eyes glued to smartphones, headphones in ears. If a bus is stopped at the bus stop, I overtake on the outside, as normal.

I can imagine in some situations it may be preferable to use the bike path but I think most cyclists will use their own judgment about the safest, fastest passage. Especially in the Uk, where it is not mandatory to ride on the cycle lane if one exists.

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mattw | 1 year ago
3 likes

Looking at the photo at the top of the piece, is that a floating bus stop?

I thought a floating bus stop had the passengers waiting on the road side of the cycle lane on the Island, so that there is no crossing jam at the point when the bus arrives - and the passengers cross one by one over a number of minutes to reduce conflict.

That also does not meet LTN 1/20 section 6.6.10:

The island between the cycle track and the carriageway needs to be wide enough for people to stand and wait for a bus and to site a shelter if one is to be provided. The island should be a minimum of 2.5m wide, which will accommodate parents and buggies, visually impaired people with a guide dog or a person using a wheelchair to allow a bus wheelchair ramp to be deployed.

That island is *not* 2.5m wide; the pavement should have been narrowed by perhaps 0.8m and the bus shelter placed on the island, with a couple of bollards robust enough to seriously dent a car and protect the queue.

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Bmblbzzz replied to mattw | 1 year ago
2 likes

Good point. Decent guidelines meet sub-par implementation, as so often happens. 

But on the width: most pavements are not 2.5m wide (though that one probably is). Add say 1m for the pavement itself and the same for the cycle lane – pretty much bare miminum in both cases – and you need 4.5m of space to implement a floating bus stop. Obviously you can take some of that from the carriageway (again, as has been done in the photo) but 4.5 is wider than a standard UK lane so only some. It really means floating bus stops should only be used on wide main roads which have some leeway in pavement and carriageway width. In effect, not many places.

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AlsoSomniloquism | 1 year ago
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If a "floating" bus stop is one which has the cycle path around it, what is the definition of this one which has the cycle path go through it?

Yes I know it is a technically a shared path, however as the one side normally gets filled with people waiting, cyclists including myself, have cycled the other side where people sit and has more actual room to get past on. 

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chrisonabike | 1 year ago
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Honestly, the UK does sound like a fusspot at the seaside sometimes.  "No, it's very dangerous in the water, people drown sometimes.  I know there are people going in, but they'll get wet.  Well they may be swimming but that's not something I am going to do..."

Just look at how it's done already (the UK is great at doing it completely wrong then saying "there! It doesn't work!"), and do it.  If you still think the world will end subscribe to some local Dutch / Danish / Spanish (etc.) papers for a period and look out for stories of "several die in cycle crash at 'death trap' bus stop".

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mattw replied to chrisonabike | 1 year ago
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I don't see any examples in the linked article of road corridor width restricted as where "bus stop boarders" are being used.

AFAICS the floating bus stop adds 2.5m to the width of the bus stop (specced in LTN 1/20) compared to an example with a bus stop boarder - and that's a lot of extra space to find in a restricted road corridor.

Councillor Matt McCabe's comment sounds like "solution by assumption that it is solved", but it's a genuinely tricky problem - and I don't know where you get an extra 2.5m from say if it is a tight urban road corridor with buildings or fences.

Lane widths have minimum values of 3m for buses, cycle tracks can be made 2 way to save 1m over 2x single direction tracks, but it's not an easy one unless you get into making it one way or completely clear one side of parking (though that may already have been done with double yellows already).

And I don't think we have an apetite to apply such remedies with their ripples of impact on other streets as is perhaps necessary.

 

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chrisonabike replied to mattw | 1 year ago
2 likes

EDIT EDIT - Robert Weetman on what they do in Copenhagen - skip to "Loading/unloading from/to cycle track" and read from there.  It's basically "people get off onto the cycle track" but there aren't any fancy humps or "warning!" signs.  Looks a bit crap but apparently it's common, it doesn't take up extra space.  So maybe it's just "people will get used to it?"

Ranty Highwayman's got some recent info on the UK situation.  I don't see any of this design though - likely because he's trying to show good designs.  This one doesn't look like one - I'm borderline on whether it's one of those "build it like this and you'll ensure only the current few ever come".

Unfortunately "change" often means "things can't stay the same".  This is where things founder in the UK.  We're OK with grudgingly making a 4.5 metre carriageway 3.5 m (in Edinburgh the bus folks are *very* pushy about 3.5m) and thus find say 2m total for reallocation between cycling and footway.  We might even at a push remove parking on one side.  But any futher than that?  Are you taking us back to 1920?

As you identify, at some point something has to give, which is often going to have "network implications".

So is this just a waste of time and we should give up?  OK, it's the UK, we have now tied both hands and one leg behind our back with "but we can't... but we must also be able to ...".  OK - what about some not brilliant ones from ages ago shown in BicycleDutch's video (see pic)?  If we use the length of the bus stop to accommodate people (time to reintroduce the queue back into UK culture!) and we bring the cycle track into the existing footway a bit, can we get a metre's width for people to stand on?  Not great but where we "have to" it looks possible maybe?  Better than "no cycle track then!" or "cyclists dismount" and easier than "this road will become one-way".

We're also trapped in the UK by our "multi-functional roads".  It has to have through traffic (can't delay that either!), buses, be a busy (shopping?) destination, children need to cross the street AND it's the only space we have for a cycle path...

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mattw replied to chrisonabike | 1 year ago
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The reason for 2.5m islands is eg people in wheelchairs who are longer, or asomeone pushing a child. which will not be accommodated across a 1m wide island.

The demanded 3.5m bus lane is strange - LTN 1/20 says that lanes between 3.1 and 3.9mm encourage close passes.

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chrisonabike replied to mattw | 1 year ago
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On "but disabled / blind people".  I am sympathetic because the UK streetscape (well, just the UK in general) fails to make life easier and often makes life a lot harder for them.  So any change would seem unwelcome given they've such a raw deal.  Plus "change" may be harder.  And people here often co-opt them with "selective concern".

Unfortunately I don't see things improving for them with "more car" - especially if it's "more electric car".  On the other hand where there is much more active travel there is greater potential for more accessible space.  Plus less risk from motor traffic.  Finally - it's not perfect in countries where there is mass cycling (because humans can be selfish and are often ignorant - so they'll be so on bikes, buses, in cars...) but bus stop bypasses are pretty uncontroversial elsewhere.  NL has them, has a ton of cycling AND is rated a very good place for pedestrians.  Plus supports independent mobility for "cycle" users of all kinds.

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OnYerBike | 1 year ago
5 likes

The "floating bus stops" with an island as shown in the picture at the top of this article seem fine, and as far as I can tell are working well in many locations.

The "bus stop boarders" that don't have an island and passengers embark/disembark directly onto the cycle path seem like a bad idea.

With an island, everything works OK most of the time. Passengers wanting to borad can stand and wait on the island. Passengers disembarking go first onto the island, and then cross at the zebra crossing. Cyclists, seeing someone crossing or waiting to cross at the zebra crossing ought to give way, and on the occassion a cyclist fails to give way, the pedestrian at least has a chance of spotting the oncoming cyclist and reacting to avoid a collision. If there is no-one crossing or waiting to cross, a cyclist can continue past even while a bus is at the stop (for example sorting tickets for boarding passengers, raising or lowering the access ramp, or waiting for time keeping purposes).

Without an island, passengers waiting to board will inevitably block the cycle lane from the moment a bus is visible, until the last passenger has boarded. Disembarking passengers may appear at any time, and they will have limited ability to see oncoming cyclists, and oncoming cyclists will have little to no warning that a passenger is about to disembark. Arguably the prudent course of action would be to not pass the bus at all while it is at the stop, but the signage in the photos says "give way to pedestrians crossing" - taken at face value, cyclists are permitted to pass the bus while it is at the stop, despite the fact that a passenger may disembark at any moment. So compared to the "floating bus stop", the "bus stop boarder" appears to engineer in both long waits for cyclists and far higher levels of potential conflict. 

Bus stop boarders are included in LTN 1/20, athough with a lots of notes of caution: "This technique is not common, and research is ongoing into the impacts. [...] To help minimise conflict, the area should have a width of 1.5m to 2.0m with a further footway width of 2.0m to 3.0m behind the bus stop [...] Because of the potential for conflict this brings between pedestrians and cyclists, this layout is best suited to bus and tram stops with less frequent services and lower passenger and pedestrian volumes. Where a bus/tram stop boarder is being considered, early engagement with relevant interested parties should be undertaken, including those representing disabled people, and pedestrians and cyclists generally. Engaging with such groups is an important step towards the scheme meeting the authority’s Public Sector Equality Duty."

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Car Delenda Est replied to OnYerBike | 1 year ago
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Yeah I fail to see the difference between this and any other cycle lane on the pavement

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Steve K | 1 year ago
5 likes

I do understand the concerns about floating bus stops, but when I hear people complain about having to cross the cycle lane to get on the bus, they never seem to make any comment about having to cross the road to get a bus going in the opposite direction.

My proposal is that every floating bus stop should be accompanied with a zebra crossing across the main carriageway.  As a result, the slight increased inconvenience getting on/off the bus on one side of the road will be more than compensated by how much easier it is to cross the road when getting on or off a bus going in the opposite direction.

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nniff | 1 year ago
4 likes

If you think those are bad, you should look at the ones on CS7 in London - they feature automatic dismounting facilities in the shape of abrupt, kerb-guarded chicanes, harsh speed bumps and, as a result of the latter, deep flooding fore and aft when it rains. 

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Rendel Harris replied to nniff | 1 year ago
2 likes

I agree, they're not good, especially the speed bumps. I noticed recently that they've taken one out, just after the petrol station past Colliers Wood tube going north, I did wonder if that was a precursor to a general remodelling but nothing else seems to have changed.

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Mungecrundle | 1 year ago
7 likes

Exactly the same concerns were raised about floating bus stops in Cambridge. The design has not turned out to be problematic beyond the imagination of a small but persistently vociferous rump of anti cyclist driver lobbyists.

Link to the Sustrans analysis of floating stops in Cambridge. https://www.google.com/url?sa=t&source=web&cd=&ved=2ahUKEwiVkPe56uz7AhWy...

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Shades replied to Mungecrundle | 1 year ago
1 like

It's on my commuting exit from Bath; for a cautious, or less experienced cyclist, the Upper Bristol Rd isn't ideal so these lanes aren't targetted at someone like me (happy to use them though), more to encourage them onto their bikes (or scooters).  What makes me laugh is that all the cars that overtake you exiting Bath, you overtake them at the Windsor Bridge traffic light queue.  The c#ckwombles who oppose these lanes will wheel out any excuse (nobody using them/restricts emergency services/no parking/slows traffic (pollution)/the river path is nearby blah blah); what they want to say is "I hate cyclists and want to use my car unrestricted and unhindered".  As part of this they narrowed a turning (Marlborough Lane) to slow traffic turning (and speeding) up a rat-run; as it was on my route I engaged with some of these nutters on-line who were shouting about it.  What a waste of time.  I usually walk/cycle around Bath and only use a car if absolutely necessary and the city is infested with speeding, inconsiderate motorists.  No more polite requests to try other forms of transport or slow down; time to start bearing down on these c#cks.

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Rendel Harris | 1 year ago
2 likes

Yes to the example of the one in the top photo, no to the one in the bottom photo, I do think people disembarking need a space to stop and look to check for bikes before crossing the cycle lane rather than having to step straight into it.

Of course if we went back to the good old fashioned Routemasters with the rear platform passengers would be able to see a long way down the cycle lane before disembarking…

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Steve K replied to Rendel Harris | 1 year ago
3 likes

Rendel Harris wrote:

Yes to the example of the one in the top photo, no to the one in the bottom photo, I do think people disembarking need a space to stop and look to check for bikes before crossing the cycle lane rather than having to step straight into it.

I agree about the second one being a no-no.  As a cyclist, you really should stop whenever there's a bus at the stop in case someone steps off the bus - in which case, what's the point of the bypass as you might as well wait behind the bus.

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Car Delenda Est replied to Rendel Harris | 1 year ago
2 likes

That's forgetting that some passengers won't have the eyesight necessary.

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Rendel Harris replied to Car Delenda Est | 1 year ago
0 likes

Car Delenda Est wrote:

That's forgetting that some passengers won't have the eyesight necessary.

Ah well, if we reintroduced the old-fashioned Routemasters we would need conductors as well (creating jobs as well as greatly increasing the safety of vulnerable passengers) who would be able to tell visually impaired passengers when it was safe to disembark.

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