DPTAC response to consultation on Welsh Transport Strategy 'Connecting Wales'

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Introduction

1. The Disabled Persons Transport Advisory Committee (DPTAC) welcomes the opportunity to comment on the Welsh Transport Strategy "Connecting Wales". We believe that meeting the transport needs of disabled people is an important and integral feature of any transport strategy for the country.

2. The United Kingdom government set up DPTAC under the Transport Act 1985 to advise it on the transport needs of disabled people. Our aim is to ensure that disabled people can go where everyone else goes and that they can do so easily and without extra cost. We would like to see this happen by 2020.

3. DPTAC has identified four overarching principles on which to base its advice to Government, other organisations and disabled people. Those principles are that:

• Accessibility for disabled people is a condition of any investment
• Accessibility for disabled people must be a mainstream activity
• Disabled people should be involved in determining accessibility
• Accessibility for disabled people is the responsibility of the provider

4. These principles are the basis of DPTAC's response to consultations. In this response, we set out some general issues before making comments specific to this consultation.

General comments

Disabled People in the Population

5. DPTAC's principal concern is to ensure accessibility for disabled people. By this, we mean inclusive transport systems that are easy to reach, use and understand by all, in safety and comfort.

6. Disabled people and those with a long term illness account for some 10% of the population, including people with limiting longstanding illnesses; of which, 4.6 million are over state pension age and 700,000 are children^[1]. While higher numbers of children are being born and living with impairments than ever before^[2], levels of disability do increase with age.

7. Currently 985,000 people live with learning disabilities^[3]. 796,000 of these are adults aged 20 or over. The adult figure will increase to 855,000 (plus 7%) in 2011 and 891,000 (plus 11%) in 2021. It has been estimated that some 7 million adults have literacy problems.

8. Using a broader definition of disability, an Omnibus Survey by the Department of Social Services reported that the provisions of the Disability Discrimination Act 1995 covered approximately 11.7 million people, including 6.5 million people of working age. Multiple disabilities were common, as illustrated by prevalence figures indicating that a third reported sensory deficits, a third learning difficulties, half mobility problems and roughly as many impaired physical co-ordination. Long-term illnesses such as Alzheimer's disease and mental illness were included in the estimated total number of people affected by disability^[4].

9. Disabled people are not an homogenous group with identical needs. The needs of people with mental health problems or learning disabilities are distinct from those of wheelchair users for example. Even among people with similar impairments, needs vary, for example, profoundly deaf people will not benefit from induction loops.

10. Disabled people live throughout the community. One in four households has a disabled resident^[5]. The need for access for disabled people is not limited to specific areas, but is present throughout the wider transport system.

Population Trends in Disability

11. The number of people over state pension age is projected to increase by 11.9% from 10.9 million in 2002 to 12.2 million in 2011 and the population aged 80 and over is projected to grow from 2.5 million in 2002 to nearly 5 million by 2031^[6]. The proportion of the working population will increase, as retirement ages advance. Over the same period that will bring about these changes in the population profile, the overall population will increase by about 9%.

12. The Department for Work and Pensions estimated in 2004 that disabled people have a spending power of around £80 billion each year^[7]. Planning strategically to design transport facilities that meet the needs of disabled people is likely to further increase this amount, as more disabled people become creators of the national wealth, rather than consumers of its state benefits.

13. Meeting the transport needs of disabled people by providing inclusive transport will be of considerable economic benefit to the country; both allowing them to exert this spending power and enabling them to become or remain part of the country's workforce.

14. The mobility of disabled people is also a precondition for the achievement of a wide range of government objectives such as independent living; full participation in civil society; and the maintenance of good physical and mental health through access to recreational and cultural facilities. Some of these links were brought out in the Prime Minister's Strategy Unit's report "Improving the Life chances of Disabled People", and in our response to it.

A strategic approach to designing inclusively

15. There is enormous scope and opportunity to improve accessibility for disabled people but it will require a strong and continuing commitment at all levels.

16. Terms such as 'access' and 'accessibility' can be interpreted in different ways. By access for disabled people, we mean inclusive transport services that are easy for everyone to reach, use, afford and understand in safety and comfort. This is consistent with the government's aim of delivering transport that works for everyone. Disabled people will expect 'accessibility' to refer to whether they can reach and use transport easily to get to places, rather than simply if a place or service is easy and quick to get to compared with other places.

17. Accessibility for disabled people is often only considered in terms of detailed design. DPTAC believes this is no longer sufficient. Considering accessibility for disabled people must underpin strategic decisions, investment and policies, with evidence of how diversity was considered in making decisions. We also seek evidence of joined up action by all parties involved in transport service provision. This may require education, training and continuing professional development in disability issues for those involved in the planning, design and management of transport systems, as well as at the front line.

18. It is not only disabled people who benefit from this approach. There are currently a further 18 million people who would directly or indirectly benefit. These include older people, families with small children under the age of five, carers, friends and relatives who accompany people with disabilities, and tourists and others whose first language may not be English, Indeed it is fair to say that all members of society benefit to some degree from what we can call "inclusive design".

19. An inclusive approach to design creates transport that can be used by everyone, regardless of age, gender, ethnicity or disability. This makes facilities truly functional, efficient and sustainable. Inclusive design recognises and accommodates differences in the way people use transport and provides solutions that enable them to take part in mainstream activities equally, independently, and with choice and dignity.

20. Inclusive transport planning does not attempt to meet every single need, but considers people's diversity and breaks down unnecessary barriers and exclusions in a manner that benefits us all. This is significant because although society and individuals have invested heavily in enabling people to manage their personal circumstances effectively (e.g. by providing aids and adaptations for disabled people), many people remain unnecessarily 'disabled' by ill-conceived facilities and services.

21. DPTAC welcomes the commitment that the UK government has made to accessibility being a condition of public money being spent in support of its Ten Year Plan "Transport 2010", and its similar commitment in respect of the Wales Transport Framework.

22. Private and public investors of any transport project need to know whether investment plans meet the need of disabled people. They will also need evidence that people at all levels of responsibility understand how to provide accessibility for disabled people effectively to prevent a waste of resources.

Key issues in the consultation

23. We recommend that there should be a clear and highlighted statement early in the transport strategy recognising the commitment to improve access for disabled people. Building in accessibility for disabled people in all new investment is a condition of public money being spent and a condition of support from the Assembly. This was referred to in paragraph 3.3.6 of the Transport Framework for Wales and is a condition of funding for public transport in Section 7 of the Transport (Wales) Act 2006.

Theme 1: To achieve a more effective and efficient transport system

24. We welcome the objectives set within this theme of striving for an effective and efficient transport network.

Use of technology

25. Technology is developing at a rapid pace which enables access to real time information, such as timetables, routes, and possible delays more available than it has ever been. However, this information needs to be available in accessible formats so that the whole community of Wales benefits from it.

26. We recommend the provision of a one-stop transport telephone information line that can give travel information on all types of transportation. This telephone number should be a free call or local rate telephone number and those operating it should be familiar with Typetalk.

27. Travel information web sites should be fully accessible - approved accessibility standards set by organisations such as the World Wide Web Consortium (W3C) and tested through web accessibility tools such as Watchfire Bobby, which are designed to help expose barriers to accessibility. The Disability Rights Commission has published a standard "PAS 78: a guide to good practice in commissioning accessible websites". Where documents are published on the Internet they should be easily accessed and downloaded, with the option of a single file as well as a number of smaller files for each section. We recommend a simple text or 'Word' version is also available as a single download because some text to sound software used by people with visual disabilities cannot read PDF documents.

28. Clearly audible and visible information on public transport, such as buses and trains and at bus and train stops are important for disabled people. This type of information has been found to be of great assistance to wider public transport users. This has been demonstrated in trials by Transport for London of audible and visual information on buses.

29. However even simple options like large print Welsh and English timetables are not as widely available as they should be, given how easily they can be produced with current technology.

Introduction of new infrastructure when required

30. All new transport infrastructure should be fully accessible and meet current best practice standards. Disabled people need to be involved at all stages of design and development. This should be supplemented by the use of qualified and experienced access consultants.

31. Pedestrian environments and links and interchanges between transport modes are no less important than the facilities that they link such as stations or vehicles.

Better co-ordination of transport fleets

32. Many disabled people, particularly those living in rural areas, rely on community transport and that provided by such bodies as education departments and health authorities.

33. Sufficient funding must be allocated to ensure that community transport is effective, affordable to users and available in all the Regional Transport Consortia areas. It is vital that such services are able to cross local authority boundaries and be available at times that users will find beneficial, including weekends and evenings.

Theme 2: To achieve greater use of the more sustainable and healthy forms of transport

Improving the attractiveness of alternatives to the private car

34. We welcome the emphasis in the Wales Transport Strategy on the need to encourage more people in Wales to use public transport. We share the belief, stated in the document, that the Assembly needs to address the current dominance of the car in Wales.

35. It is however important to recognise that for some disabled people use of a car may be the only option to travel to some destinations. Our research shows that car travel, often in a car driven by someone else, is a common mode of transport for disabled people. Parking provision, traffic law enforcement, road safety and road user charging polices need to take this into account. We have published a position paper on road user charging that sets out important principles for pilot studies such as that which might be carried out in Cardiff. These comments are also relevant to the section in the consultation document on "Managing the demand for different routes through pricing and regulation".

36. In the development of a walking and cycling strategy the Assembly could usefully take account of the importance of accessible pedestrian environment and use standards such as those set out in the Department for Transport's "Inclusive Mobility" and Transport for London's "Streetscape Guidance".

37. We support the proposal to improve cycling networks, and believe that due consideration must be given to the safety of disabled people, particularly pedestrians with sensory impairments, when cycle routes/lanes are being designed. It is vital that cycle lanes and pedestrian footpaths are clearly defined as separate areas and effective tactile and visual markings indicate these defined areas.

38. The issue of the lack of confidence and even avoidance of inaccessible and/or unsafe environments has been highlighted in a recent report published by the Guide Dogs for the Blind Association, "Shared Surfaces in the Public Realm". DPTAC is carrying out its own research on how Home Zones could be made more sensitive to the needs of disabled people, and we will brief the Welsh Assembly on the results of this work when they are available.

39. For more information, the Assembly should note the advice in the Disability Rights Commission guidance on "Planning, Buildings, Streets and Disability Equality", which, although it refers to local authorities, is also relevant to the work of the Welsh Assembly Government.

Rail Network

40. The Transport Strategy recognises that the rail network is limited in Wales and that many groups of people do not have ready access to it. We welcome the proposal to improve links to rail networks and to improve long distance bus and coach services. These must be fully accessible.

Smarter Pricing

41. We welcome the continued commitment to offer a concessionary bus fare scheme for older and disabled people in Wales. We also commend the decision not to impose restrictions on when the concessionary pass may be used. We believe that the Assembly should consider the provision of concessionary fares across transport modes - particularly use for taxis and community transport in rural areas. We would draw its attention to the Department for Transport's ongoing research on community transport and reducing social exclusion, and research planned by the Commission for Integrated Transport on taxis and social inclusion.

Access for disabled people

42. The draft Transport Strategy for Wales rightly addresses the difficulty disabled people encounter when trying to access bus and train services. We therefore welcome the commitment given in the Transport Strategy that "there will still be a need, however, to continue to improve routes to bus and train stations, to ensure that services are accessible for all".

Theme 3: To minimise the need to travel

Land Use Planning

43. We welcome the proposal to ensure that there is joint thinking between; health, education, retail and employment, where transport is considered at the earliest planning stage. Decentralisation of such facilities so that they are within easy reach of people's homes will help ease of access to proper healthcare, education, employment opportunities, leisure and retail services.

Additional comments

Public Transport Users' Committee

44. DPTAC welcomes the proposal to establish a new Public Transport Users' Committee in Wales "to ensure the passengers' voice is heard", and we have discussed this with Assembly officials. The Assembly must consider carefully how this body will deal with access and disability issues. One option is to establish a Disabled Persons' Transport Committee which could be structured and have a similar remit to that of the Mobility and Access Committee for Scotland. (MACS). The recent decision of Scottish Ministers to maintain MACS alongside a new Public Transport Users' Committee should be taken into account.

Awareness training

45. All transport providers should ensure that their organisations have an effective disability awareness training programme in place, for all staff. In addition to front line transport staff, disability equality training should be provided throughout the transport sector to all those whose decisions will impact on the design, development and operation of the transport system. Such training should be developed and delivered with the involvement of disabled people. Training may focus on awareness of how transport affects different people and their ability to move around independently. It may also focus on understanding the technical solutions and applications that contribute to more inclusive transport.

Consultation process

46. Local authorities and transport providers should be explicitly required to clarify who is being consulted, about what questions, in what time-scale and for what purpose. They should ensure disabled people and those concerned with access are consulted on a range of issues, not just those specifically focussed on disabled people. Principles of inclusive transport should always underpin policy development and should not be a separate issue.

47. Transport providers and local authorities need to make documents widely available, with the fullest use of electronic means (though not to the exclusion of others), and effectively drawn to the attention of all interested groups and individuals. Making documents widely available should include doing so in alternative formats at the time that they are initially published. These could include Braille versions, audiotapes, large print, easy-to-read versions with illustrations.

48. Documents such as local transport plans are often advertised in small print public notices in newspapers. We believe that such notices should also be advertised in other locations, such as; talking newspapers, local and regional radio, local organisations representing disabled people, and accessible web sites.

49. Consultation processes, including meetings, must be accessible in their venues, timing, organisation and documentation, and the language used needs to be inclusive. Inclusiveness may require building the capacity of the organisations involved so that they are able to engage fully. Facilities required may include signers, induction loops, Blue Badge parking facilities, good connections to public transport And facilities for assistance dogs. The Department for Transport has produced guidance for engagement with disabled people.

Disability equality duty

50. Our understanding of the Disability Discrimination Act 2005 is that the Welsh Assembly is subject to both the general duty and the specific duties under the Act. The Assembly has specific duty to report on progress. The first report is due by 1st December 2008 and every three years thereafter.

51. In terms of the general duty, the decisions and actions of the Assembly and local authorities and partnerships with transport responsibilities will have to have due regard to the six principles of:

• Promoting equality of opportunity.
• Eliminating discrimination.
• Eliminating harassment.
• Promoting positive attitudes.
• Encouraging participation by disabled persons.
• Treating disabled people more favourably than others.

52. Not only is there an expectation of positive action, but it is worth stressing that the duty is retrospective - the Assembly and transport authorities will be expected to take action to rectify the consequences of past decisions and actions that failed to give due regard to disability equality.

53. In drawing up a strategy for meeting their obligations under the Act, we would expect the Assembly and transport authorities to:

• Demonstrate real leadership in the promotion of an inclusive transport environment.
• Review the continued relevance of current policy statements and action plans and amend these as appropriate.
• Ensure that future policies, practices and action plans recognise the accommodation of the needs of disabled people as a mainstream activity and indeed as a positive feature.
• Review the effectiveness of past funding of trunk road projects regarding the promotion of an inclusive transport environment.
• Promote remedial action/programmes to deal with identified deficiencies and prioritised in consultation with local groups representing disabled people.
• Ensure that any recommendations regarding funding given to the Highways Agency, partner local authorities, public transport operators and others is dependent on the promotion of an inclusive transport environment.
• Monitor good practice regarding positive action and encourage its adoption elsewhere.
• Monitor progress towards the creation of an inclusive transport environment in a way that is meaningful.
• Engage actively and regularly with local organisations representative of disabled people.
• Ensure all staff (from the top to the bottom of the organisation) are aware of the Disability Equality Duty and that they take account of this in their daily work.
• Ensure that staff receive the necessary training and support.

54. We would expect the Assembly to be developing an overall strategy and action plan as required under the Act but local transport authorities and partnerships will need to translate this into local action plans.

Conclusion

55. DPTAC welcomes the opportunities presented by the consultation on the Welsh Transport Strategy. It is particularly timely given the deadlines of the Disability Equality Duty. Together they offer the prospect of a specifically Welsh vision that is inclusive of disabled Welsh people, and that also builds on wider good practice.

1: Department for Work and Pensions press notice 9 February 2006 - "Updated estimate of the numbers of disabled people including people with limiting longstanding illnesses, and their associated spending power".
2: Improving the Life Chances of Disabled People 2005 at www.cabinetoffice.gov.uk/strategy/work_areas/disability.aspx.
3: Foundation for People with Learning Disabilities 2006, www.learningdisabilities.org.uk.
4: K Williams, T Savill and A Wheeler "Review of the road safety of disabled children and adults" 2002, available at www.trl.co.uk.
5: James Ruppert, Independent  June 15, 2004.
6: DRC Report for Party Conferences 2004.
7: www.dwp.gov.uk/mediacentre/pressreleases/2004/dec/spending.asp.

Neil Betteridge, Chair, Disabled Persons Transport Advisory Committee
4/24 Great Minster House
76 Marsham Street
London SW1P 4DR

Telephone number: 020 7944 8012
Email address: dptac@dft.gsi.gov.uk

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