DPTAC response to Office for Disability Issues consultation Disability equality: how will we know we are making progress?

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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 this consultation by the Office for Disability Issues on Disability equality: how will we know we are making progress? We believe that the creation of the Office for Disability Issues provides the opportunity for a more focussed lead and for better coordination of the inclusion of disabled people across government policies and their delivery.

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 travel where everyone else goes with the same quality of travel experience, at no greater cost, and encountering no additional barriers. We want to ensure that significant changes occur to transport before 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:

• Public investment can only take place if those who provide and spend the money take into account the accessibility of disabled people.
• Those who provide transport services will make accessibility for disabled people part of the main stream of their activity.
• Those who provide transport services will fully and meaningfully involve disabled users and non-users in deciding the accessibility of transport services.
• Those who provide transport services are responsible for accessibility for disabled people.

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 Department of Social Services survey reported that the provisions of the Disability Discrimination Act 1995 covered some 11.7 million people, including 6.5 million people of working age. The Disability Discrimination Act 2005 has increased the figure, as it designated 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. 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, while information that is easy to read might be accessible to some people with learning difficulties, but not to others.

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 the 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. Our response will use the questions posed in the Office for Disability Issues' own consultation document. However DPTAC will only comment on the questions which we feel are most linked to our transport remit.

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 four regional stakeholder events that were organised.

Future consultation

17. DPTAC regards this consultation as one element of a dialogue between ourselves and the Office for Disability Issues that has included presentations to our Main Committee and an invitation to be involved in the work that led to the establishment of the Equality 2025 advisory body. We look forward to continuing involvement in the work of the Office.

What does equality for disabled people mean to you?

18. Our remit concerns transport policy as it affects the mobility of disabled people. The aim we set out in paragraph 2 above "to ensure that disabled people can travel where everyone else goes with the same quality of travel experience, at no greater cost, and encountering no additional barriers" encapsulates what we understand by equality. Our Main Committee confirmed this definition in March 2007.

Can you describe any examples of equality for disabled people you have experienced or know about?

19. Equality for all disabled people has not yet been achieved, in DPTAC's opinion, for any mode of transport. Ministers have the power to regulate for standards of accessibility for taxi, buses, coaches, and for light and heavy rail, and have done so for all except taxis. However, end dates for compliance have not yet been reached for any mode of transport.

20. Moreover, these standards will not of themselves make transport accessible to all disabled people. For example, the Public Service Vehicle Accessibility regulations do not require buses to have audible and visual information systems at any time in the future. Yet these are crucial for buses to be accessible to passengers with sight and hearing impairments. Aviation and shipping are still governed by voluntary agreements, although a European Regulation will soon regulate air travel for disabled people, its impact remains to be seen.

21. Further and more detailed examples are given in our oral and written evidence to the Transport Select Committee's two investigations of Disabled People's Access to Transport of transport for disabled people, its investigation of bus and train fares, and its investigations of bus services and of train fares, and its current scrutiny of air travel. All but the last ongoing study are available on the House of Commons Transport Committee website and we can provide copies if required.

Do you think there should be a single measure of equality, or that we need to measure progress on different aspects of disabled people's lives?

22. Even in the single area of transport, we do not believe that it is likely that a single measure of equality can ever do full justice to the experience of disabled people.

If you think we need more than one measure, what do you think should be the five main features of equality that are measured?

23. We are not able to confirm that five would be an appropriate number. However we would suggest that the measures chosen need to address:

• the quality of the travel experience of the disabled person;
• the numbers of disabled people using transport services over time;
• the affordability of the service;
• the availability of the service across the country;
the accessibility of information about the service.

24. In this respect we strongly endorse the suggestion in the consultation document that "to determine the nature and extent of improvements over time, we could monitor the accessibility of trains, buses, coaches, taxis, stations and other facilities, and also whether there are changes in disabled people's views and experiences on accessibility."

What aspects of life for disabled children and their families do you think it most important for us to monitor over time?

25. Since our remit is transport, we are not well placed to comment on wider issues of life for disabled children. However, we do think that the monitoring of transport for disabled children is important. For example, the government is currently consulting on changes to the law in relation to the provision of Blue Badges for children under two. This is likely to significantly improve transport for some disabled children. Facilities for disabled children and their families matter very much. However, so does transport for disabled parents travelling with children (who may or may not themselves be disabled), an area which sometimes receives far less attention. An area of concern which has been brought to our attention is the limited availability of accessible toilets in connection with transport, particularly for older disabled children. The PAMIS organisation has produced a Changing Places toilet recommendation^[11] which will need to be considered alongside the provisions of the Part M building regulations.

What aspects of transition to adulthood for disabled young people do you think it most important for us to monitor over time?

26. Responsibility for the provision of transport for disabled people often becomes less clear during and after the transition from childhood to adulthood. For example, students may need access to a concessionary fare provision both where they live and where they study and these may be under the jurisdiction of different local authorities who can prove reluctant to provide concessions to disabled non-residents. It is too early to tell if the new Disability Equality Duty will help to resolve these problems.

27. The RITE project^[12] published in 2006 involved young people with complex physical and communication needs leaving the comparatively well supported and resourced school system to go on to Further Education and independent adult life. It explored a number of these issues of transition in a full and sensitive manner.

What do you think are the most important issues in respect of employment that we ought to monitor?

28. Research by Leonard Cheshire^[13] demonstrated that disabled people often cite the unavailability of transport as a reason for not being able to take up a job interview or accept suitable employment. Concessionary fares can be a disincentive, as they are often not available in the early morning or late at night. Transport should be monitored as an employment issue.

Are there any other issues in respect of disability equality that we ought to monitor?

29. While transport is important for education and for employment, it is also crucial in respect of the participation of disabled people in civil life, leisure, sporting and cultural activities. These are an as important a part of the quality of life of disabled people as they are for anyone else.

What so you think are the most important issues in respect of independent living that we ought to monitor?

30. The consultation documents asked for views on the monitoring of direct payments. We will not offer a view on this, as their consideration in respect of transport is at a very early stage. However, we will take this opportunity to advise you of our views on the applicability of these payments to transport.

31. DPTAC is supportive of the general argument that disabled people should have greater control over the resources that are available to meet their needs. The government has argued that direct payments can offer users increased choice and provide services that are more efficient. In transport, the choice of service is simply not there at the moment for many disabled people, as we have shown above. It would seem to be too early to move to direct payments for transport services. More work is also needed to establish whether or not direct payments would increase the efficiency of transport services.

32. We are currently exploring direct payments with researchers for the Department for Transport. Among the issues we are examining are: Concerns around

• the potential that such payments could have to reduce eligibility, by focussing provision on the those with the greatest need only;
• the anticipated reliance on personal assessment (which is effectively means testing), which we know can reduce the take up of benefits;
• the interaction with the Mobility component of Disability Living Allowance, where views differ on the scope and purpose of this allowance.

Conclusion

33. DPTAC welcomes the opportunities presented by the consultation from the Office for Disability Issues on Disability equality: how will we know we are making progress? The Office for Disability Issues needs to know what progress it is making. For this to be possible, it must establish baselines for the affordability and availability of transport for disabled people, to measure the quality of their travel experience, and to monitor progress on improving all three of these measures.

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

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