DPTAC response to Department for Communities and Local Government consultation on the White Paper Planning for a Sustainable Future

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Introduction
Q.1 The proposed package of reforms
Q.2 Introduction of national policy statements
Q.3 Content of national policy statements
Q.4 Status of national policy statements
Q.5 Consultation on national policy statements
Q.6 Parliamentary scrutiny
Q.7 Timescale of national policy statements
Q.8 Review of national policy statements
Q.9 Opportunities for legal challenge
Q.10 Transitional arrangements
Q.11 The preparation of applications
Q.12 Consultation by promoters
Q.13 Consulting local authorities
Q.14 Consulting other organisations
Q.15 Statutory consultees' responsibilities
Q.16 The infrastructure planning commission's guidance role
Q.17 The infrastructure planning commission's advisory role
Q.18 Rules governing propriety
Q.19 The commission's role at the point of application
Q.20 Scope of infrastructure planning commission
Q.21 Electricity system
Q.22 Gas infrastructure
Q.23 Other routes to the infrastructure planning commission
Q.24 Rationalisation of consent regimes
Q.25 The commission's mode of operation
Q.26 Preliminary stages
Q.27 Examination
Q.28 Hard to reach groups
Q.29 Decision
Q.30 Conditions
Q.31 Rights of challenge
Q.32 Commission's skill set
Q.33 Delivering more renewable energy
Q.34 Joined up community engagement
Q.35 More flexible response to a successful legal challenge
Q.36 Removing the requirement to list Supplementary Planning Documents in Local Development Schemes
Q.37 Sustainability appraisal & Supplementary Planning Documents
Q.38 Permitted development for non domestic land and buildings
Q.39 Neighbour Agreements
Q.40 Minor amendments of planning permission
Conclusion
Appendix: Disabled People in the Population
Appendix: Population Trends in Disability

Introduction

1. The Disabled Persons Transport Advisory Committee (DPTAC) welcomes the opportunity to comment on this consultation by the Department for Communities and Local Government Department for Communities and Local Government consultation on the White Paper Planning for a Sustainable Future. While the content of the consultation goes beyond DPTAC's remit, we consider that the proposals discussed have significant implications for transport.

2. The Executive Summary to the White Paper begins with the statement that "Planning is of fundamental importance to the quality of people's lives". This is no truer than when in the context of considering the interests of disabled people. The planning system will be a key factor in the achievement of an inclusive and accessible built environment and accessible transport infrastructure.

3. This consultation is therefore particularly relevant to the interests of the Disabled Persons Transport Advisory Committee (DPTAC) and we welcome this opportunity to offer comments. Because of the close relationship between the built environment and the transport environment, we also welcome the fact that the White Paper is being promoted jointly by the Secretary of State for Communities and Local Government and the Secretary of State for Transport, as well as those for Environment, Food and Rural Affairs and for Trade and Industry (now the Department for Business, Enterprise and Regulatory Reform).

4. Before commenting on the specific questions in the consultation, we would make three general points. Firstly we were encouraged by the Disability Equality Strategy (DES) published by the Department for Communities and Local Government in December 2006^[1]. This referred to a commitment by the Department to promote a better environment which was "inclusive and responsive to the disabled people's needs" (page 14 of the DES). The Disability Equality Strategy went on to say that "accessibility would be a cornerstone of future built environments so that disabled people would be free to participate fully within their local areas ... without barriers" (page 14 of the DES) and that the Department would seek the provision of accessible infrastructure wherever the opportunity arose.

5. We therefore feel an opportunity has been missed in the setting out of the five core principles in paragraph 1.37 of the White Paper. While it may be implicit in the statements, we feel that in terms of the Disability Equality Duty and the Disability Equality Strategy commitments, there should have been explicit reference to the promotion of fully inclusive development as a key priority.

6. Secondly, the delivery of the planning system relies heavily on the role of local authorities and their responsibilities for planning, building control and transport. We would therefore draw attention to the publication in 2006 by the Disability Rights Commission of Planning, buildings, streets and disability equality^[2], guidance on the Disability Equality Duty and the Disability Discrimination Act 2005 for local authority departments responsible for planning, design and management of the built environment and streets. This emphasises the importance of actually involving disabled people in the planning process as an integral part of achieving accessibility and inclusive development with reference to the role local access groups or panels.

7. Thirdly we would draw attention to the fact that disabled people and those with a long-term illness account for well over 10% of the population. With this in mind, 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.

8. Meeting the needs of disabled people by promoting an accessible and inclusive built environment and accessible transport infrastructure is of considerable economic benefit to the country. It allows disabled people to exert their spending power and it enables them to become or remain part of the country's workforce. We have attached more details of the numbers of disabled people in the UK and the nature of their impairments as an appendix to this response.

9. We have four overarching principles on which we base our 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 service provider.

10. These principles are the basis of our response to this consultation. Annex 1 sets out further relevant factual information.

Q.1 The proposed package of reforms

Do you agree that there is a strong case for reforming the current system for planning for nationally significant infrastructure?

Do you agree, in principle, that the overall package of reforms proposed here achieves the objectives that we have set out?

If not, what changes to the proposed reforms or alternative reforms would you propose to better achieve these objectives?

11. We see this as an opportunity for nationally strategic projects to demonstrate best practice in promoting fully accessible development and particularly in relation to transport infrastructure. It is essential that any streamlined procedures still allow for the full involvement of disabled people in the development of the proposals from initial stages through to the commissioned project.

12. Where nationally strategic transport projects are proposed we also believe there should be a specific opportunity for DPTAC to be involved. We would like to see comparable opportunities made available for the involvement of bodies such as Equality 2025 and the Inclusive Environment Group of the Commission for Architecture and the Built Environment where relevant.

Q.2 Introduction of national policy statements

Do you agree, in principle, with the introduction of national policy statements for key infrastructure sectors in order to help clarify government policy, provide a clearer strategic framework for sustainable development, and remove a source of delay from inquiries?

If not, do you have any alternative suggestions for helping to achieve these objectives?

13. We agree the need for national policy statements. We would make the point that such statements should be consistent with the commitments given in the Disability Equality Strategy of the Department for Communities and Local Government regarding inclusive design principles and the involvement of disabled people in the planning process.

14. Again we see a role for DPTAC in advising where policy statements relate to the development of the transport environment. And again we would like to see comparable opportunities made available for the involvement of bodies such as Equality 2025 and the Inclusive Environment Group of the Commission for Architecture and the Built Environment where relevant.

Q.3 Content of national policy statements

Do you agree that national policy statement should cover the core issues set out above?

Are there any other criteria that should be included?

15. We believe that the core issues should include the need for an equivalent of the Access Statements that now accompany local planning applications.

Q.4 Status of national policy statements

Do you agree, in principle, that national policy statements should be the primary consideration for the infrastructure planning commission in determining individual applications?

If not, what alternative status would you propose?

16. It is essential that the planning commission is bound by the same obligations under the Disability Discrimination Act 2005 as Government and local government and that the needs of disabled people are fully taken into account where appropriate. We are concerned that a simultaneous consultation by the Department for Communities and Local Government on the Equalities Review could lead to a weakening of these obligations and we are covering this matter in detail in our response to that consultation.

Q.5 Consultation on national policy statements

Do you agree, in principle, that these proposals would ensure effective public engagement in the production of national policy statements, including with local communities that might be affected?

Are there any additional measures that would improve public and community engagement in their production?

17. We agree that at all stages in the development of national policy statements in draft, there should be thorough consideration of evidence including informal consultation with relevant experts or organisations such as DPTAC.

18. It should be noted that consultation with many disabled people will require attention to be given to ensuring that the consultation is open to people with specific requirements such as those with sight or hearing impairments or those with learning difficulties or mobility impairments. This has implications for the nature and format of the consultations.

19. We have set out our thoughts on this in detail in our response to the current Cabinet Office consultation on Effective Consultation. That consultation ends some weeks after the present one, and we intend to copy our response to it to the Department for Communities and Local Government so that it can take into account our advice. We extent to the Department for Communities and Local Government our invitation to Cabinet Office to be involved in developing further advice on this matter.

Q.6 Parliamentary scrutiny

Do you agree, in principle, with the intention to have Parliamentary scrutiny for proposed national policy statements?

What mechanisms might ensure appropriate Parliamentary scrutiny?

20. In DPTAC we have considerable experience of giving evidence to the Transport Select Committee and to the Joint Committee on the Disability Discrimination Bill. We believe that the Transport Committee or an ad hoc body like the Joint Committee would be highly competent to scrutinise policy statements relating to transport infrastructure. We would expect there would be an opportunity for organisations such as DPTAC to give evidence to any scrutiny committee.

Q.7 Timescale of national policy statements

Do you agree, in principle, that 10-25 years is the right forward horizon for national policy statements?

If not, what timeframe do you consider to be appropriate?

21. We have no comment on specific time frames. However we believe that the time frame may depend on the transport sector involved and the amount of other change taking place in related policies at UK and European levels. It may therefore not be appropriate to have a single time frame for all modes of transport.

Q.8 Review of national policy statements

Do you agree that five years is an appropriate period for the Government to consider whether national policy statements remain up to date or require review?

What sort of evidence or circumstances do you think might otherwise justify and trigger a review of national policy statements?

22. A good example of how change of circumstances can affect policy statements is the introduction of the Disability Equality Duty under the Disability Discrimination Act 2005. We note that many current government policy statements pre-date the new duties and these policy statements now ought to be reviewed and revised in the light of the new statutory obligations. Five years would otherwise seem to be a reasonable time for regular reviews.

Q.9 Opportunities for legal challenge

Do you agree, in principle, that this opportunity for legal challenge would provide sufficient and robust safeguards to ensure that a national policy statements is sound and that people have confidence in it?

If not, what alternative would you propose?

23. It is disappointing to think that with a robust system for consulting on and testing it, any proposed national policy statement would need to have its soundness questioned. However we agree there should a mechanism to appeal against a policy that seemed to be in conflict with other policies or principles.

Q.10 Transitional arrangements

Do you agree, in principle, that subject to meeting the core elements and standards for national policy statements Paper, policy statements in existence on commencement of the new regime should capable of acquiring the status of national policy statements for the purposes of decision making by the commission?

If not, what alternative arrangements do you propose?

24. We have no objection to this proposal provided that the same level of scrutiny took place as for new statement, and that the interests of disabled people were not compromised in the process. As indicated above, many policy statements pre-date the Disability Discrimination Act 2005.

Q.11 The preparation of applications

Do you agree, in principle that promoters should have to prepare applications to a defined standard before the infrastructure planning commission agrees to consider them?

25. This proposal is generally in line with the requirements for a developer submitting a proposal to the local planning authority. We would expect an appropriately detailed Access Statement to form part of the submission.

Q.12 Consultation by promoters

Do you agree, in principle, that promoters should be required to consult the public before submitting an application to the infrastructure planning commission?

Do you think this consultation should take a particular form?

26. It is essential that the promoter of a nationally significant project consults with the public and this consultation should include a specific requirement to consult with disability organisations both national and local - national, such as DPTAC, to cover strategic issues and local to ensure that specific issues for local users and those who live nearby are addressed. Please refer also to our comments on accessible consultation set out above at paragraph 19.

Q.13 Consulting local authorities

Do you agree, in principle, that relevant local authorities should have special status in any consultation?

Do you think the local authority role should take a particular form?

27. We agree regarding the need for consultation - particularly in the light of the disability equality duties pertaining to local authorities. This should include regional bodies and Passenger Transport Authorities in their own right, as well as their constituent authorities.

Q.14 Consulting other organisations

Do you agree, in principle, that this list of statutory consultees is appropriate at the project development stage?

Are there any bodies not included who should be?

28. An obvious omission would seem to be DPTAC (particularly since the Commission for Architecture and the Built Environment is listed).

Q.15 Statutory consultees' responsibilities

Do you agree in principle that the Government should set out, in legislation, an upper limit on the time that statutory consultees have to respond to a promoter's consultation?

If so, what time limit would be appropriate?

29. The twelve week time limit associated with government consultations would seem an appropriate starting point for any formal consultation stage, unless this is extended in the current Cabinet Office consultation on Effective Consultation that we have referred to above. However, the limit should not begin until al the consultative material has been made available in alternative formats to suit the needs of disabled consultees.

Q.16 The infrastructure planning commission's guidance role

Do you agree in principle that the commission should issue guidance for developers on the application process, preparing applications, and consultation?

Are there any other issues on which it might be appropriate for the commission to issue guidance?

30. We agree about the need for guidance and we would expect this guidance to cover issues such as the need for information to be available in alternative formats.

Q.17 The infrastructure planning commission's advisory role

Do you agree in principle that the commission should advise promoters and other parties on whether the proposed project falls within its remit to determine, the application process, procedural requirements, and consultation?

Are there any other advisory roles which the commission could perform?

No comment.

Q.18 Rules governing propriety

What rules do you consider would be appropriate to ensure the propriety of the commission's interactions with promoters and other parties?

31. Where commission members may have a conflict of interest they should stand aside. They should be required to abide by the principles of the Committee on Standards in Public Life.

Q.19 The commission's role at the point of application

Do you agree, in principle, that the commission should have the powers described above?

Are there any other issues the commission should address before or at the point of application?

32. As indicated above, we would expect the commission to ensure that there had been adequate consultation with the interests of disabled people and that all submissions included full access statements.

Q.20 Scope of infrastructure planning commission

Do you agree, in principle, that these thresholds are appropriate?

If not, what alternative thresholds would you propose?

33. The interest of DPTAC lies in transport infrastructure in particular. We believe that to set absolute thresholds is potentially contentious and also open to the effects of incremental increase - for example, a series of development proposals which are each under any nominal threshold but which could be cumulatively detrimental. We note too, that rail and light rail projects are not included. We see a danger of different rules applying to different types of transport infrastructure project. (See also comments on question 23 below).

Q.21 Electricity system

Do you agree in principle that all projects necessary to the operational effectiveness, reliability and resilience of the electricity transmission and distribution network should be taken by the commission?

If not, which transmission and distribution network projects do you think could be determined locally?

34. We have no comments to make on this proposal.

Q.22 Gas infrastructure

Do you agree in principle that the consenting regime for major gas infrastructure should be simplified and updated, rationalising the regime to bring nationally significant decision making under the commission.

35. We have no comments to make on this proposal.

Q.23 Other routes to the infrastructure planning commission

Do you agree, in principle, that it is appropriate for ministers to specify projects for consideration by the commission via national policy statements or ministerial directions to the commission?

If not, how would you propose changing technology or sectoral circumstances should be accommodated?

36. We believe that this measure would help to address our concerns regarding question 20. We believe that these directions should themselves be subject to the Parliamentary scrutiny proposed at Question 6.

Q.24 Rationalisation of consent regimes

Do you agree, in principle, that the commission should be authorised to grant consents, confer powers including powers to compulsorily purchase land and amend legislation necessary to implement nationally significant infrastructure projects?

Are there any authorisations listed that it would be appropriate to deal with separately, and if so which body should approve them, or that are not included and should be?

37. We agree the desirability of rationalising the different development consent regimes and the creation of a unified single consent regime with a harmonised set of requirements and procedures. However, this would only seem to emphasise the difference between railway and non-railway projects.

Q.25 The commission's mode of operation

Do you agree, in principle, that the proposed arrangements for the commission to deal with cases is an appropriate way to ensure that consideration is proportionate and that an appropriate range of specialist expertise is brought to bear on the final decision?

If not, what changes or alternative mode of operation would you propose?

38. We would expect the members of any commission to have appropriate training in disability equality and awareness as is expected of local authority planning officers in the same decision making position.

Q.26 Preliminary stages

Do you agree in principle that the list of statutory consultees set out above Is appropriate at the determination stage?

Are there any bodies not included who should be?

39. Again there would seem to be the obvious omission of DPTAC form the list of statutory consultees.

Q.27 Examination

Do you agree in principle that the procedural reforms set out above would improve the speed, efficiency and predictability of the consideration of applications, while maintaining the quality of consideration and improving the opportunities for effective public participation?

If not, what changes or other procedural reforms might help to achieve these objectives?

40. Some disabled people could have difficulty in giving detailed written submissions and would require appropriate support at any inquiry (palantypists/signers/etc). Again these are set out in our response to the current Cabinet Office consultation on Effective Consultation. that we have referred to above.

Q.28 Hard to reach groups

What measures do you think would better enable hard to reach groups to make their views heard in the process for nationally significant infrastructure projects?

How might local authorities and other bodies, such as Planning Aid, be expected to assist in engaging local communities in the process?

41. This is particularly relevant to disabled people and organisations representing them. We are aware of increased funding for Planning Aid which was announced in connection with the passing of the Planning and Compulsory Purchase Act (2004). We would like to know if the increase of £1.5m mentioned is additional to the previously announced increase? We mention this in the light of very limited apparent progress subsequent to the previous announcement of increased funding.

42. We understand that Disability Wales is undertaking a research project on capacity building for access groups on behalf of the Disability Rights Commission.

43. The other comment we would make is to refer again to the guidance for planning authorities published by the Disability Rights Commission and mentioned in our introductory comments regarding the Disability Equality Duty. This publication contains useful guidance on how best to involve disabled people in the planning process.

Q.29 Decision

Do you agree that the commission should decide applications in line with the framework set out above?

If not, what changes should be made or what alternative considerations should it use?

44. We agree in the expectation that the commission would be covered by the Disability Equality Duty.

Q.30 Conditions

Do you agree in principle that the commission should be able to specify conditions in this way, subject to the limitations identified, and for local authorities to then enforce them?

If not what alternative approach would you propose?

45. We agree with the general principle while noting that local planning authorities are bound by the Disability Equality Duty. The authorities would have to be funded and resourced to implement the enforcement obligations.

Q.31 Rights of challenge

Do you agree, in principle, that this opportunity for legal challenge to a decision by the infrastructure planning commission provides a robust safeguard that will ensure decisions are taken fairly and that people have confidence in them?

If not what alternative would you propose?

46. We agree that the right of challenge seems a reasonable safeguard.

Q.32 Commission's skill set

What experience and skills do you think the commission would need?

As we have indicated previously, we would expect the commissioners also to have received appropriate disability awareness training.

Q.33 Delivering more renewable energy

What types of non residential land and property do you think might have the greatest potential for microgeneration and which should we examine first?

47. We have no comments to make on this proposal.

Q.34 Joined up community engagement

We think it is important to enable a more joined up approach to community engagement locally. We propose to use the new "duty to involve" to ensure high standards but remove the requirement for the independent examination of the separate planning Statements of Community Involvement. Do you agree?

48. We support the principle of joined up community engagement and the 'duty to involve.' However, we are concerned about removing the requirement for a Statement of Community Involvement. If the necessary involvement is done well, presumably some plans and records will be retained. The requirement for a statement should therefore not be onerous and should be seen as an additional safeguard both for the developer and the community.

Planning submissions should include a clear access statement and we believe there may be a case for a disability impact assessment to accompany both submissions and, indeed, government policy statements.

Consultations should be available with an easy read version and in alternative accessible formats and the availability of these should be publicised.

Better ways of consulting need to be considered - plans are often inaccessible to visually impaired people and difficult to understand by many. Relying on planners to interpret plans can lead to problems of assumptions on both sides where the planners may not always be aware of what may be key issues for disabled people. This came to light in recent research in which we have participated regarding the use of shared surfaces in residential areas. 3-D computer generated modelling and physical models can be particularly useful in this respect.

Q.35 More flexible response to a successful legal challenge

Do you agree that the High Court should be able to direct a plan (both at local and regional level) to be returned to an earlier stage in its preparation process, rather than just the very start?

49. We have no comments to make on this proposal.

Q.36 Removing the requirement to list Supplementary Planning Documents in Local Development Schemes

Do you agree, in principle, that there should not be a requirement for supplementary planning documents to be listed in the local development scheme.

50. If there is a need to refer to Supplementary Planning Documents, it would seem perverse if they were not to be listed. All documents which the consultees might need to consider should be listed.

Q.37 Sustainability appraisal & Supplementary Planning Documents

Do you agree in principle that there should not be a blanket requirement for supplementary planning documents to have a sustainability appraisal, unless there are impacts that have not been covered in the appraisal of the parent DPD or an assessment is required by the SEA directive.

51. We would seek assurances that the interests of disabled people would not be prejudiced by this change and would wish to comment on draft guidance before it is published.

Q.38 Permitted development for non domestic land and buildings

Which types of non residential development offer the greatest potential for change to permitted development rights? What limitations might be appropriate for particular sorts of development and local circumstances?

52. It is essential that any changes to permitted development do not discriminate against disabled people as potential users or employees.

Q.39 Neighbour Agreements

What is your view on the general principle of introducing a streamlined process for approval of minor development which does not have permitted development rights and where the neighbours to the proposed development are in agreement?

53. There is an obvious danger where there is also a requirement for building consent and the developer does not recognise that this still applies.

Q.40 Minor amendments of planning permission

Do you agree that it should be possible to allow minor amendments to be made to a planning permission?

Do you agree with the approach?

54. We have no comments to make on this proposal.

Conclusion

55. DPTAC welcomes the opportunities presented by this consultation. It is essential that the government strikes the right balance between, on the one hand, bringing forward at the earliest possible opportunities the benefits to disabled people flowing from major transport infrastructure projects, and on the other ensuring that disabled people have a voice to ensure that those very projects are accessible to them.

56. Several other consultations, notably the current Cabinet Office consultation on Effective Consultation, and the Department for Communities and Local Government's own consultation on the Equalities review, are relevant to this one. It is essential that decisions arte taken in a coordinated way and that action on this consultation awaits the consideration of responses to those others.

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

Appendix: Disabled People in the Population

1. 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.

2. 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^[3]. While higher numbers of children are being born and living with impairments than ever before^[4], levels of disability do increase with age.

3. Currently 985,000 people live with learning disabilities^[5]. 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.

4. 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^[6].

5. 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.

6. Disabled people live throughout the community. One in four households has a disabled resident^[7]. The need for access for disabled people is not limited to specific areas, but is present throughout the wider transport system.

Appendix: Population Trends in Disability

7. 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^[8]. 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%.

8. The Department for Work and Pensions estimated in 2004 that disabled people have a spending power of around £80 billion each year^[9]. 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.

9. 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.

10. 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"^[10], and in our response to it^[11].

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