DPTAC response to consultation on the Second Three Year Review of the
Department for Transport's Road Safety Strategy

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• Introduction
• General comments
• Key issues in the consultation
• Conclusion

Introduction

1: The Disabled Persons Transport Advisory Committee (DPTAC) welcomes the opportunity to comment on the Second Three Year Review of the Department for Transport's Road Safety Strategy. We believe that meeting the transport needs of disabled people is an integral feature of any road safety strategy for the country.

2: The 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 the 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 broad 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 policies and infrastructure 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 safe and 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.

Key issues in the consultation

Scope of review

15: While DPTAC very much welcomes this opportunity to comment on the second three year review of the Road Safety Strategy^[8], we are concerned about the lack of reference to the needs of disabled people. This is a matter which will have to be addressed under the new Disability Equality Duty under the Disability Discrimination Act 2005 which affects all the Department for Transport's functions from 4 April 2006.

16: The Department for Transport has advised us that the scope of the review is to "report on progress towards the target; identifying, where possible, the most effective measures and assessing the priority areas for action with associated delivery plans for the period remaining to 2010". While Ministers may not consider it appropriate to add new targets to the strategy at this stage, we remain concerned that the current targets say nothing about how to make improvements to the road safety of disabled people. The strategy has another four years to run, a period which could allow considerable progress.

17: One aspect of the review is to develop a timetable for actions to develop a road safety strategy for when the present one expires in 2010. We recommend that the Department for Transport sets in hand the action necessary so that, by 2010, it will be in a position to set meaningful targets for how the road safety of disabled people will be improved based on evidence based baselines and with established means of achieving them.

Disability Equality Duty

18: It is timely that the Road Safety Division of the Department for Transport is considering the implications for disabled people of its work, as the Department is now preparing for the introduction of the Disability Equality Duty on 4 December 2006.

19: The Department for Transport is subject to both the general duty and the specific duties under the Act. The Secretary of State also has a specific duty to report on progress. The first report is due by 1st December 2008 and every three years thereafter.

20: In terms of the general duty, the decisions and actions of the Department for Transport and the highway and police authorities and others with which it takes forward road safety 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.

21: Not only is there an expectation of positive action, but the duty is retrospective - the Department for Transport 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. This could include the failure to take account of the needs of disabled people in developing the Road Safety Strategy.

22: In drawing up a strategy for meeting their obligations under the Act, in respect of road safety we would expect the Department for Transport and these others 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 road safety 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 partner local authorities and others is dependent on the promotion of an inclusive approach to road safety.
• 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.
• Ensuring that staff receive the necessary training and support.

23: We would expect the Department for Transport to be developing an overall strategy and action plan in respect of road safety as required under the Act, while but local transport authorities and partnerships will need to translate this into local action plans.

24: As far as the Road Safety Strategy is concerned, under Theme 1 we would expect to see recognition of the needs of disabled children, including those with learning difficulties. Under Theme 2, we would expect driver training to emphasise the need to be aware of pedestrians who have hearing or sight impairments. Under Theme 4, safer infrastructure also has to be inclusive and accessible infrastructure. In this connection, we would mention the new Department for Transport publication "Manual for Streets" currently being finalised. Safer speeds, Theme 5, are also very important for disabled people, many of whom have difficult in coping with traffic at the best of times.

25: Under Theme 8, Safer Pedestrians, Cyclists and Horseriders, there is reference to vulnerable groups and particularly cyclists. Disabled people feel particularly vulnerable and, while this might not be reflected in statistics, we know that many disabled people feel disenfranchised by the current transport environment. This includes, paradoxically, new Home Zones (see separate comment at paragraph 35 ff).

26: Finally, in Chapter 4 we would expect to see actions and targets relating specifically to improving conditions for disabled people.

Existing data, statistics and research

27: At present the Department for Transport collects very little data that is detailed enough to help form a view as to the extent to which the road safety risks of disabled people might be different from or the same as those of the population in general and, if they are different, what action might be needed to fine-tune road safety policies to meet the needs of disabled drivers, passengers and pedestrians. For example, although we know from our own research^[9] that disabled people travel less than most people, but do so disproportionately by car, we do not know what risk this puts them at compared to car drivers and passengers without disabilities. That would be likely to depend on the time of day they travel, the vehicles they travel in and the roads they travel on, among many other factors that are simply not yet known.

28: Recently the Department for Transport has collected statistics on contributory factors to accidents^[10]. These include "impairment or distraction", a category that includes fatigue, alcohol, drugs, distracted drivers and cyclists who wear dark clothing, as well as illness and disability. However this only covers situations where impairment is a factor in causing the accident and the figure is based on judgments made by the reporting police officer at the accident scene.

29: We are pleased that the Department has sponsored and published some research in this area. However the conclusions of that research are primarily that little is known and much more needs to be done. For example two of the Department's recently published projects conclude respectively that:

"Whilst it seems likely that disabled people are at increased risk of road accident involvement, it is not possible to establish the most at-risk groups as there has been insufficient research in this area."^[11]

and

"anecdotal evidence has indicated that children and adults with disabilities may be at increased risk of road accident involvement, but the extent and nature of the problem has not been systematically assessed."^[12]

30: We recommend that the Department ensure that data is collected about disabled people involved in road accidents as drivers, passengers, riders or pedestrians.

Mobility scooters

31: A specific area where the statistics are uncertain relates to Class 2 and Class 3 vehicles, commonly and hereafter referred to as "mobility scooters". These can be invaluable for many disabled people in increasing their mobility and freedom. They have also proved to be a threat and a danger to some disabled people, when driven irresponsibly. The Department of Transport has recently completed research on the use on highways of mobility scooters^[13], and Ministers are considering the recommendations.

32: Our concern here is how statistics are collected on accidents involving mobility scooters or wheelchairs. The police are apparently not able to identify mobility scooters in the accidents that they report, and it may be that they and wheelchairs are included in the category "Other vehicle". We recommend that the Department ensure that data is collected about mobility scooters and wheelchairs that may be involved in road accidents.

Adapted vehicles

33: Another area where data collection could be improved is with details of road accidents involving public and private transport vehicles that have been adapted to meet the needs of disabled people. These would include minibuses and private cars. Such adaptations are becoming increasingly important as more older and disabled people have been used to driving for much of their lives and wish to continue to do so. Additionally from December 2006 car hire will be covered by Part 3 of the Disability Discrimination Act 1995. We recommend that the Department ensure that data is collected about private and public transport vehicles involved in road accidents that have been adapted for disabled people.

Need for further data and research

34: Clearly the Department for Transport needs to collect to establish the variables relevant to disabled people's road safety risk. This process needs to start now if the government is to have the data it needs to set baselines and plan appropriate interventions by 2010 when the new road safety strategy needs to be in place. DPTAC stands ready to advise on research proposals and to serve on steering groups directing such research.