DPTAC response to Olympic Delivery Authority consultation on the draft Olympic Transport Plan
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Introduction
1. The Disabled Persons Transport Advisory Committee (DPTAC) welcomes the opportunity to comment on this consultation by the Olympic Delivery Authority on the Olympic Transport Plan and associated documents. We believe that the 2012 London Olympics provides the opportunity to both bring about a step change in the accessibility of transport in London and to significantly improve the accessibility of other parts of the United Kingdom where Olympic events are held, as well as encouraging greater use of public transport by those disabled people who are not prevented from doing so by the design and operation of transport systems.
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 long-term illnesses make up about 17% of the population or about 10 million people, including people with limiting longstanding illnesses. Of these 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], disability levels do increase with age.
7. Currently 985,000 people live with learning disabilities[3]. Of whom 796,000 are adults over 20. 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[4].
8. Using a broad definition of disability, a 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. The Disability Discrimination Act 2005 will have increased the figure, as it classes AIDS, cancer and multiple sclerosis as disabilities from the point of diagnosis. 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[5].
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[6]. 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 or so 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[7]. 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[8]. 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"[9], and in our response to it[10].
Key issues in the consultation
15. We will begin by setting out a number of issues relating to the draft overall. This will be followed by Annex A which is a table of drafting suggestions, linked to specific pages and sections of the consultation document.
Scope and accessibility of the consultation
16. DPTAC welcomes the scope of the consultation, the availability of easy to read summaries of key documents and full copies in a range of accessible formats, the long time scale for consultation, and the preparedness of senior staff to discuss the plan face to face with stakeholders.
Future consultation
17. DPTAC welcomes the fact that the Olympic Delivery Authority consulted DPTAC in advance on an outline draft of the Olympic Transport Plan. As a result, we believe that the comments we are now making are less far reaching and fewer in number than would otherwise have been the case. While DPTAC is disappointed not to have been named on the face of the London Olympic Games and Paralympic Games Act 2006 as a statutory consultee, we look forward to continuing involvement in the work of the Authority through the Access Panel, the Accessible Transport Panel, stakeholder forums and other processes.
18. By involving ourselves, the Accessible Transport Panel and the wider disability community at an early stage, the Olympic Delivery Authority could make many disability access improvements for relatively small amounts of money by including them as part of other works. This approach would be well aligned to the recommendations of the recent Eddington Report[11]. DPTAC recommends that such schemes are monitored to prevent access only being considered at a late stage and thereby becoming less effective and more costly. The Olympic Delivery Authority might even consider a contractual penalty where works are carried out which are subsequently found not to have included the access provisions required.
Prominence of access and inclusion in the draft
19. DPTAC warmly welcomes welcome the Plan overall. The prominence and thoroughness with which issues of inclusion and accessibility have been addressed has been rarely equalled and never bettered in any documents that current DPTAC members can recall coming before us. We look forward to ensuring and confirming the high promise of this Plan.
20. There needs to be a timetable for making transport more accessible for disabled people, produced in consultation with the DPTAC Olympic Working Group and other relevant stakeholders (similar to that in the London Mayor's Transport Strategy), so that the Olympic Delivery Authority can monitor progress towards this commendable vision.
21. Integrated ticketing offers great potential to ensure that disabled people use the most appropriate transport for them, taking advantage of public transport opportunities where possible and having quality alternatives where not. However this will rely on trained staff asking the right questions at an early stage to those ordering tickets. We shall return to these issues of communication and training later.
22. DPTAC would like to see this attention to the needs of disabled people reflected elsewhere in the work of the Olympic Delivery Authority. The website, for example has front page links to health and safety and to security, as well as two to sustainability, but none to inclusion or accessibility. Of course, accessibility and inclusion are not only issues for transport, though that is where our remarks have been focussed, in line with our remit.
Format of published Olympic Transport Plan
23. DPTAC agrees that access and inclusion issues should feature throughout the draft, rather than be relegated to a specific section. However, when the final draft is published on line, we suggest that means might be found to enable readers to draw together easily all the references to specific issues, such as disability, safety, or sustainability, that are contained within the Plan, should they wish to do so.
Part 3 of Disability Discrimination Act
24. Since 4 December 2006, it has been unlawful for transport operators to discriminate against disabled people using buses, coaches, trains, tubes, trams, taxis, private car hire, vehicle rental and vehicle recovery services. Operators must also make reasonable adjustments to their services so that disabled people can use them. This is a consequence of lifting the exemption that transport had from Part 3 of the Disability Discrimination Act 1995. It would be appropriate for the Olympic Transport Plan to refer to these provisions, and also (in due course) to any further lifting of the exemption in relation to water and air travel. This is a matter that the Department for Transport is actively considering at the time of writing.
Disability equality duty
25. The period of preparation of the Olympic Transport Plan has coincided with the introduction of the disability equality duty. In its draft Equality and Diversity Strategy issued in January 2007, the Olympic Delivery Authority has confirmed that this duty applies to it, though obviously it was not able to fulfil the deadline of 4 December 2006 for the production of a Disability Equality Scheme.
26. We have already brought to the attention of the Department for Transport the fact that its own Disability Equality Scheme[12] contains no reference to the Olympics.
27. Our understanding of the Disability Discrimination Act 2005 is that the Olympic Delivery Authority is subject to both the general duty and the specific duties under the Act. The Secretary of State for Transport is also subject to the general duty, as well as having a specific duty to report on progress. The range of functions for which the Olympic Delivery Authority is responsible is such that we would expect the Olympic Delivery Authority to be involved in supporting the Secretary of State in his specific duties in relation to transport. The first report is due by 1st December 2008 and every three years thereafter.
28. In terms of the general duty, the decisions and actions of the Olympic Delivery Authority in respect of transport 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.
29. Not only is there an expectation of positive action, but the duty is retrospective - the Olympic Delivery Authority 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 any failure to take account of the needs of disabled staff and visitors in respect of Games travel information and transport.
30. DPTAC recommends that this duty and its implications are described fully in the Olympic Transport Plan.
Illustrations
31. DPTAC notes that, while there are a number of high quality and appropriate pictures in the Plan of athletes with disabilities, there is a marked absence of disabled people in the pictures and artistic impressions of spectators and travellers. While we accept that these illustrations are only indicative, and cannot do justice to people with less visible disabilities, we would recommend that future drafts, and other documents produced by the Olympic Delivery Authority, represent disabled people in proportion to their presence in the population.
Maps
32. While DPTAC realises that the maps need to be diagrammatic, those in the draft plan showed no indication of the carrying capacity of the carriageways and this makes it hard to judge the adequacy of the routes.
Information, communication and signage
33. Accessible information and communication are essential if transport is to be accessible to disabled people. It covers the provision of information face to face, through websites, telephones, text phones, mass media and printed media.
34. Making information accessible for disabled people cannot be achieved simply by taking impairments one at a time. For example, a person may live with both a learning difficulty and a hearing impairment, or with a sight impairment and a mobility disability.
35. In this respect signage is particularly important. While we are aware that the construction and placement of signage are likely to be among the last aspects of the Olympic preparations to be completed, they need to be considered soon. Research may be necessary to establish what did and did not work most effectively in previous Olympic Games, and to commission and carry out research on effective and inclusive signage. DPTAC stands ready to assist and support this work in relation to transport.
Training for staff
36. Training will be a key element in the effective delivery of Olympic transport, beginning with the Olympic Delivery Authority's own staff, and including designers, contractors, and transport operators, staff and volunteers. DPTAC recently initiated a research project on best practice in relation to the disability awareness of front line transport staff, and we stand ready to involve the Olympic Delivery Authority in this research and to share our results with them.
37. Support and commitment from management are crucial to achieving truly high standards and long term change. To ensure that planning for the future incorporates disability issues from the outset, DPTAC recommends that disability equality training should include everyone in the organisation.
38. Training of this kind is not a one-off activity. Refresher training should be given regularly, for example, to take account of relevant technological and legal developments.
Training for disabled people
39. Many disabled passengers may have little recent experience of using various transport modes, because of bad past experience, what they have heard about the experience of others, or because information about more accessible services is not accessible to them. The Olympic Delivery Authority should have considered providing promotional material in a range of media and in alternative formats, encouraging disabled people to take advantage of Olympic travel opportunities. This would help to achieve the Authority's legacy aim of greater use of public transport by disabled people in the future.
40. DPTAC also recommends that the Olympic Delivery Authority considers the provision of travel training for disabled people to take this familiarisation process further. This could be delivered by face to face training sessions, escorted travel or virtual means such as websites and DVDs.
The pedestrian environment
41. Improvements to transport need to clearly include inclusive pedestrian environments. For example we have been concerned about, (and have been involved in research into). a recent trend in the design of streets and public spaces which involves shared surfaces.
42. In this connection, the encouragement of cycling (including disabled people who cycle), needs to involve specific cycling routes and facilities, rather than shared routes with pedestrians, with ample cycle parking well designed and located away from pedestrian routes.
Conclusion
43. DPTAC welcomes the opportunities presented by the consultation on the Olympic Transport Plan by the Olympic Delivery Authority. We believe that the 2012 London Olympics provides the opportunity to build on the work of successive government, local authorities, transport operators and organisations of disabled people including ourselves, to improve the accessibility of disabled people. Our ambition is not only to have an Olympic transport system that allows every disabled competitor, spectator and staff member to play a full part in the Games, but that allows those visiting to take away with them a vision of accessible transport for their own countries, towns and cities.
Neil Betteridge
Chair of Disabled Persons Transport Advisory Committee
4/24 Great Minster House
76 Marsham Street
London SW1P 4DR
Tel: 020 7944 8012
E-mail: dptac@dft.gsi.gov.uk
Annex A - DPTAC comments on text of draft Olympic Transport Plan
| Page | Comment |
| 19 (2.31) | Need to acknowledge that staff and volunteers include those with impairments. |
| 23 (3.8) | An inclusive games requires not only environment to be accessible but information, transport and services. See comments on information and communication at paragraphs 33-35 above. |
| 23 (3.8) | No definition is offered of accessibility. Emphasis should be on Inclusiveness, which does not only mean promoting 'physical access', but also takes account of all disabled people by creating accessible environments and transport that everyone can access and benefit from. It aims to remove barriers which create undue effort, separation or special treatment, and enables everyone to participate equally in mainstream activities independently with choice and dignity. |
| 24-25 (3.20) | No mention of statutory advisory bodies such as DPTAC. |
| 25 (3.26) | Spectator transport is described as accessible but not Olympic and Paralympics family transport or that for staff and volunteers - this seems anomalous, transport for both groups should be "safe, secure, inclusive, fast, reliable frequent, friendly, accessible, environmentally-friendly and simple". |
| 26 (3.29) | DPTAC should be consulted on the transport assessment that forms part of the environmental impact assessment, that supports the planning application, and on the Access Statement insofar as it relates to transport. |
| 27 (3.40) | Add DPTAC to the Accessible Transport Panel Announce membership of the Panel soon so it can start work.
Detailed consultation of local groups both in London and at other locations needs to be inclusive and accessible in documentation, language, venues, publicity, processes and information. The Department for Transport has issued useful guidance to staff entitled "Consultation guidance: disabled people" and this could no doubt be made available to the Olympic Delivery Authority. |
| 30 (4.4) | The Plan needs to clarify what is meant by "some" disabled parking and who this will be made available to. Blue Badge holders? What about people from outside the UK where they may be no equivalent badge (e.g. USA).
The Olympic Delivery Authority needs to ensure that an Olympics which encourages as many people as possible to walk, cycle and use public transport does not unduly disadvantage those who because of their impairment cannot do so - whether Olympic related travel or non- related travel affected by the Olympics. |
| 31 (4.9) | The need to provide 3,900 chauffer driven cars could have a negative impact on the number of taxi drivers available for dial-a-ride transport for disabled people, especially during a traditional holiday period for drivers. This was suggested by the calculations in a Go-Skills workforce report on the Olympics. The number of coach drivers needed could also present similar though less severe problems. We look forward to further details from the Olympic Delivery Authority as to how they will address this issue. |
| 31 (4.10) | The impact of the Olympic Route Network route closures and diversions on Blue Badge Parking for disabled people needs to be evaluated and additional parking provided elsewhere. There may be similar impacts for disabled pedestrians and users of public transport, and details of road closures and diversions needs to be widely and accessibly circulated. The Accessible Transport Panel and the wider disability community should be involved in the agreement of temporary traffic orders on the Olympic Transport Network to make sure that they do not unduly disadvantage disabled people, and also in the setting in hand of measures to mitigate their impact. |
| 32 (4.15) | The strategy needs to contain more details of the design and funding of the "public and community transport-based accessible network ... established to provide accessible transport options to every venue". |
| 33 (4.17) | Test events need to involve disabled people in proportion to their expected participation in Olympic and Paralympics audiences in terms of both number and range of disabilities. |
| 34 (4.22) | The strategy states that "an 'accessible network' will be developed to ensure that spectators with restricted mobility are able to access venues." Access should not be restricted to those with mobility impairments but cover all disabilities. DPTAC has raised this issue at Stakeholder Forums and the developing ideas should be more widely circulated. |
| 34 (4.25) | There needs to be more detail about the facilities for disabled people outside London including the provision of accessible transport information. For example, it appears likely that public transport will play a greater role, with less of a bespoke mobility service. How are existing community and other transport providers to be involved in this process? |
| 37 (5.10) | What plans are there to offset the income foregone by Transport for London as a result of the free travel afforded to athletes and team officials? This income has been assumed to be available, among other things, to support the provision of accessibility features on transport throughout London. |
| 39 (5.21) | It is important that these supplementary bus services offer at least an equal level of accessibility in terms of meeting both Public Service Vehicle Accessibility Regulations and non-statutory provisions such as the audio visual announcements that Transport for London will have provided on all its scheduled bus services by 2012. |
| 43 (5.46) | Agree with the need for enforcement of Olympic Lanes on the Olympic Route Network. Will this be done by police or borough civil enforcement officers, and what steps will be taken to ensure that this is not at the expense of the enforcement of parking elsewhere, including that of the Blue Badge Parking Scheme and London borough schemes? |
| 44 (5.58) | DPTAC welcomes the intention that "All staff will receive specialist training regarding the needs of Olympic Family members and spectators who have a disability." See our comments at paragraphs 36-38 above in the main text. |
| 46 (6.2) | The assumptions on parking need to be quantified. 100% of parking is to be for disabled visitors, but how many places are assumed to be needed? |
| 47 (6.10) | There is an issue about the availability of accessible hotel rooms which are unlikely to become available in the numbers needed unless steps are taken. It is important to bear in mind the continuing need for accessible accommodation to meet London's business and leisure needs during the Games period. |
| 48 (6.11) | DPTAC needs to be kept informed about progress with modelling the origins of Olympic visitors and the modes of transport they are expected to use.
There may be a role for taxis taking disabled people to and from venues through other parts of London. There could be an interaction and conflict with Olympic Route Network which would need to be mitigated. |
| 49 (6.25) | DPTAC welcomes the consideration given to the disabled workforce. |
| 49 (6.26) | We would question the 7% and 1% figures for disabled people having difficultly or being able to negotiate escalators and stairs. Londoners by 2012 will have a history of being able to use low floor buses and an increasingly accessible rail network. This may well lead to higher expectations and an increasing preparedness to travel to the Games. Furthermore the demographic trends that we have set out above suggest that the incidence of disability will be higher by 2012 than it is now. |
| 51 (Fig 6.3) | The tube map on page 51 should show stations with level access expected to be in place by 2012, like the one on page 84. |
| 52 (6.41) | What undertakings have been received from rail companies with pre-2004 franchise agreements that they will operate as though their contracts included an Olympic clause? |
| 53 ff | DPTAC has concerns about the accessibility of rail stations used for Olympic transport. This includes level access, wayfinding, audible and visual information, lifts, and staffing levels. The Chair of our Rail Working Group has raised issues about stations including St Pancras and Stratford International where provision needed to be improved to meet the provisions of the Stations Code. These included a number of issues of concern to people with sight impairments such as poor light levels, colour contrast, glass manifestation and a planned "silent station" policy at St Pancras; as well as the lack of alternatives to very small lifts when they were out of operation. DPTAC had concerns at being consulted so late in the day. |
| 62 (Fig 6.10) | DPTAC seeks reassurance about the quality, reliability and safety of the temporary elevators at Prince Regent and Custom House stations for disabled people and the other temporary provision that is described. DPTAC considers it to be acceptable (though regrettable) for the number of instances of an accessibility feature provided for Olympic capacity travel volumes to be removed after the Games. It is not acceptable for the feature itself (e.g. a lift) to be removed |
| 64 (6.109) | DPTAC members will inspect a mock up of the Olympic Javelin during the consultation period. However we are concerned about how the need to allow disabled people to embark and disembark safely will interact with the very brief station dwell times. |
| 68 ff | It is necessary for further consideration to be given to the accessibility of non-London stations such as Broxbourne and Brentwood which (based on information on the National Rail website) appear to have very limited accessibility features at present. |
| 70 (6.139) | While it is true that "the transport infrastructure is in place to cater for the anticipated demand" of capacity matches at football venues outside London, they may not have the infrastructure in place to accommodate the number of disabled spectators who will wish to attend an Olympic event. |
| 71 (6.139) | The figures of 22,000 coaches and 11,000 coach operators in the UK is questionable as it would give an average of only two coaches per operator. |
| 71(6.141) | All the features of operational plans will need to take into account accessibility, notably station capacity and circulation, tests events, security, shuttle buses, staffing, training, late night services.
The accessible transport panel needs to be involved in this work. It can draw on work undertaken by the Metropolitan Police Disability Independent Advisory Group, Transport for London and the Metropolitan Police to learn the lessons of 7/7 from the perspective of disabled people. |
| 72 (6.154) | The availability of coaches needs to include an estimate of the proportion of these which will meet Public Service Vehicle Accessibility Regulations (PSVAR) and also the number which will be low floor. PSVAR only applies to scheduled services, though the rights of disabled passengers under Part 3 of the Disability Discrimination Act apply to all coaches. Drop off facilities need to take account of the time needed for disabled passengers with disabilities to embark and disembark. The assistance needs will also need to be factored into plans. |
| 72 (6.155) | Information and training need to cover disability awareness issues. See comments on information and communication at paragraphs 33-35 above. |
| 73 (6.163) | While "Coach-based park and ride services are not planned to serve the Central Zone venues due to the ample provision of existing public transport options", tube services are not accessible to many disabled people. |
| 73 (6.168) | The successful operation of informal park and ride at rail stations may require review of and provision of additional accessible parking spaces. Some disabled drivers and passengers will need to continue to use these facilities for non-Games transport. |
| 74 (6.1.76) | Dedicated temporary bus services need to be accessible to disabled people, including the provision of audible and visual on-board announcements as are to be provided on scheduled services. |
| 76 (6.184) | Community transport, dial-a-ride, Capital Call and taxi services are indeed important for disabled people. See comment on page 31 above. Taxi drop off and pick up points need to be accessible, and provision made for Freedom card contractors to be identified and used by those moving round and leaving the venues. |
| 77 (6.199) | DPTAC welcomes the attention given to river transport services which also need to be inclusively provided. |
| 78 (6.208) | The use of cruise ships for accommodation should be considered in the context of the needs of disabled people. DPTAC is currently developing revised guidance in this area which will be made available to the Olympic Delivery Authority. |
| 83 (6.219) | DPTAC welcomes the commitment to access and inclusion. |
| 83 (6.220) | Some underground stations closest to venues (e.g. St Johns Wood, Colindale) are not planned to be fully accessible by 2012 |
| 84 (6.228) | Capacity issues relating to community transport, dial-a-ride and Capital Call need to be addressed, given other commitments they have to meet the needs of disable people. |
| 84 (6.229) | The Plan makes much play of building on the successful Games Mobility Service at the Manchester 2002 Commonwealth Games. We are not aware of any work with disabled people to establish what was most and least effective about this service and how it can be constructively built on. We recommend that this work is set in hand. |
| 84 (6.230) | The proposed golf court escort service may need further thought for those who are unable to bend their legs. We recommend that disabled people are consulted on possible vehicle designs at an early stage. |
| 84 (6.231) | The Games Mobility Service needs to meet the needs of dogs accompanying disabled people at venues and at transport interchanges or points where there are likely to be long waiting periods; access to designated and secure spending areas, water supply etc. There should be a definition of assistance dogs that includes those other than guide dogs. This is available in existing Department for Transport guidance. There will need to be appropriately trained staff/volunteer assistance should be available. |
| 86 (6.236) | While we support the idea of integrated ticketing, we would like to know how the pricing will take account of the discounts that some disabled travellers will be entitled to. |
| 86 (6.239) | Real time travel information needs to be provided in media that are accessible to disabled people. |
| 89 (7.6) | DPTAC welcomes the proposed access strategy for venues and the audit of all Olympic overlay facilities. The guidelines that underpin these should be consulted on and published. |
| 90 (7.9) | The simulation of crowd movements will need to involve proportionate numbers of disabled people. This includes preparations for fire and other evacuation plans. Assistance may be needed by some disabled people during crowd movements. Staff will need to be visible and distinguishable. |
| 90 (7.16) | See comment on parking relating to page 30 above. |
| 124ff | Road events, especially on weekdays where there are fewer alternatives, have particular potential to disrupt accessible travel routes. See comments in relation to page 31 above. |
| 136ff | Accessibility of Blue Badge parking at regional venues needs clarification. See comment on parking relating to page 30 above.
Some rail stations for regional venues are some way from the venues themselves and access arrangements for disabled people have not been described. |
| 154 (10.25) | Airports need to be prepared for more disabled people, some with assistance dogs for which additional clearance provision will need to be made. Information on this provision is crucial. To the extent that the current system works it is because frequent fliers with dogs have a high degree of understanding and tolerance of the idiosyncrasies of the current system. This will not be the case for many Olympic visitors, who will also have language issues. DPTAC has brought this to the attention of Defra but it is not yet clear what plans are being set in hand.
Information about the Pet Passport scheme will need to be published on the official Olympic web site and widely available to participants and spectators etc who may consider bringing their guide or other assistance dog in to the UK. It will be useful to work with the European Disability Forum, European and International Guide Dog and Assistance Dogs forums, European Blind Union and other international forums can help to publicise this and ensure early advice is available to guide/assistance dog owners. |
| 158 (10.30) | The Channel Tunnel rail link is likely to have to be compliant with the Technical Standard for Interoperability by 2012, which should increase rail accessibility. |
| 158 (10.31) | On cruise ship and sea travel please see note referring to page 78 above. We would contest the view that there will not be a significant number of Olympic family members arriving in the UK via sea ports. Given the limited accessibility of many flights from the Republic of Ireland at present, it may well be the case that some Paralympians will have no choice but to arrive by ferry. |
| 160 (11.2) | Wheelchair users are mentioned specifically, but transport provision also needs to meet the needs of other impairment groups. |
| 161ff | Our comments on Olympic venues, accommodation, transport, routes and information above are equally relevant to Paralympic events. |
| 164 (11.22) | It is not clear how the separation and reuniting of disabled people and their equipment will be effected. Disabled people should not be separated from assistance dogs any longer than necessary. |
| 168ff | Our comments on Olympic venues, accommodation, transport, routes, information and emergency and contingency planning are equally relevant to cultural and opening and closing events. Public transport in the main venues, expected to include Hyde Park, Victoria Park and the riverside promenade need to be audited for accessibility, as does Blue Badge and other London borough parking. |
| 176 (14.11) | Search facilities need to respect the dignity of disabled people and they should not be separated from companions, equipment and assistance dogs. |
| 179 (15.9) | DPTAC is disappointed that the legacy benefits of the London Underground investment directly related to the Olympics contain no reference to accessibility, though this is added at 15.21. |
| 181 (15.21) | DPTAC agrees that the Olympics could provide the opportunity to encourage disabled people to continue to make greater use of public transport after the Olympics. We remain concerned that the emphasis is very much on physical accessibility for those with mobility impairments rather than disabled people more generally. The legacy needs to cover staff, training, information and services as well as physical infrastructure. One legacy element might well be more positive attitudes towards disabled travellers by the general public and it would be helpful if this was baselined and benchmarked. |
| Env Report | The comments above need to be read across into the Transport Plan that forms part of the Environmental Report (pages 5 to 17). |
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", at www.dwp.gov.uk/mediacentre/pressreleases/2006/feb/drc-015-090206.asp.
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, at www.learningdisabilities.org.uk.
4: www.dfes.gov.uk/pns/DisplayPN.cgi?pn_id=2002_0276.
5: K Williams, T Savill and A Wheeler "Review of the road safety of disabled children and adults", 2002, available at www.trl.co.uk.
6: James Ruppert, Independent June 15, 2004.
7: DRC Report for Party Conferences 2004.
8: www.dwp.gov.uk/mediacentre/pressreleases/2004/dec/spending.asp.
9: 2005, at www.cabinetoffice.gov.uk/strategy/work_areas/disability/.
10: 2005, at www.dptac.gov.uk/consult/11.htm.
11: www.dft.gov.uk/about/strategy/transportstrategy/eddingtonstudy/.
12: December 2006, available at www.dft.gov.uk/about/sr/disabilityequalityduty/disabilityequalityscheme/.
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