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DPTAC response to Department for Transport consultation on the Draft Local Transport BillThis Document has also been made available in Adobe Acrobat and MS Word formats for downloading. Adobe Acrobat version: DPTAC response (129k) Introduction Introduction1. The Disabled Persons Transport Advisory Committee (DPTAC) is pleased to have the opportunity to the Department for Transport's consultation on the Draft Local Transport Bill. 2. The Transport Act 1985 established DPTAC to advise Ministers on disabled people's transport needs. 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 we base our advice to government. Those principles are that:
4. These principles are the basis of our response to this consultation. We have also included some essential statistics relating to the numbers and nature of disabilities at Annex A to this response. 5. We have tried to answer the specific questions in the consultation but begin with some general comments. 6. Past legislation regarding disability discrimination has resulted in considerable advances in the development of accessible transport infrastructure and services. However, there is a long way to go before many of the current barriers to movement by disabled people are eliminated. Until this occurs, the quality of life of many disabled people and their ability to access services and opportunities will continue to be seriously impaired. 7. Inaccessible transport means that disabled people are less able to secure and retain employment, obtain medical treatment, enjoy a full social life, or travel with whom they want, where they want and, especially when they want. Compared to others, disabled travellers may need to plan further ahead, pay more to travel, experience embarrassment and stigmatisation when they do so, and find themselves more tired at the end of a journey. This will have a significant effect on their preparedness to travel in future. 8. DPTAC welcomes the process of publishing a draft Local Transport Bill. This enables stakeholders to consider not only the policy changes but also the legislative means of bringing them about. It holds out the prospect at best of developing a broad consensus on the way forward, and at worst clarifying and reducing areas of disagreement between stakeholders, ensuring a far easier passage for the Bill than might have otherwise have been the case. 9. We are pleased to report that the Department for Transport consulted us on the formats in which the consultation package would be produced, helping to ensure that accessible copies were made available in more formats and earlier than in some past consultations. 10. We are pleased to note on Page 29 of Volume One of the consultation that the Government remains "committed to an accessible transport system in which disabled people have the same opportunities to travel as other members of society." 11. We also welcome the recognition of the role of Community Transport. Improving the quality of local bus servicesQ1 (a) - Voluntary partnership agreements12. The consultation proposes developing scope for voluntary partnership agreements to be made between councils and groups of bus operators, rather than single operators as at present. The benefits of these agreements could include the provision of better quality vehicles. 13. Disabled people (and indeed many other passengers) would benefit from the faster introduction of vehicles that meet the Public Service Vehicles Accessibility Regulations 2000 (PSVAR). These specify minimum technical accessibility requirements designed to make buses and coaches accessible to disabled people, including wheelchair users. PSVAR applies to all new buses and coaches with more than 22 passengers used on local or scheduled services and introduced since 31 December 2000. All single deck buses will need to be compliant by 1 January 2016 and all double deck buses by 1 January 2017. 14. While 50% of the full size bus fleet is already accessible, we are concerned that this is concentrated in the metropolitan areas and particularly in London, whose fleet is already 100% wheelchair accessible. 15. DPTAC believes that the PSVAR ought to cover other important features, such as the provision of audible and visual information systems on vehicles and at bus stops. DPTAC believes regulations requiring such systems to be installed for all bus routes are long overdue. These would greatly increase the accessibility of buses and coaches for people with visual, hearing and learning disabilities. They would also benefit people whose first language is not English and they would benefit tourists and other visitors and older travellers. Transport for London are obviously convinced of the social and economic benefits of such a system as they are, as you will be aware, in the middle of fitting audio/visual to its entire fleet. 16. Voluntary agreements offer the potential to speed up the roll out of PSVAR compliant buses across the country. This would give an opportunity to local groups of disabled people to influence bus operators at a much earlier stage. As a result, the roll out of compliant buses could have greater impact upon disabled people. The involvement of local groups of disabled people would also to give bus operators a greater understanding of disability issues. 17. However, there could also be some inconsistency across the country as disabled people in some local authority areas may have to wait many more years for accessible vehicles than other people do. For this to happen, bus routing and frequency would need to reflect the needs of disabled people. Infrequent bus services, especially in rural areas, mean that disabled people are often not able to get to realise the benefit of accessible vehicles. 18. Moreover, there is a risk that a council's agreement with a few large operators could act against smaller operators, including but not restricted to community transport providers, that also provide scheduled services. Whilst the goal of through ticketing and other partnership proposals should be beneficial for the passenger, it needs to be done in a way that protects competition. Partnership agreements therefore need to be transparent and need to be open to new players as well as existing ones in specific areas. Q1 (b & c) - Quality partnerships / quality contracts19. The proposals should make it easier to introduce quality bus contracts which replace competition on the road with competition to deliver a range of bus services. The fact that, as we indicated above, London buses have high levels of accessibility for passengers with mobility impairments we believe is because Transport for London has effectively been able to exercise compulsory use of quality bus contracts when these powers were not readily available in other parts of the country. 20. We note that the test will include that a scheme should increase use of bus services rather than being "the only practicable way" of delivering them as at present. Contracts will be approved by an Approvals Board rather than by the Secretary of State as at present. 21. The potential advantages for disabled people are that the ability for local authorities to set targets for the punctuality of services will create more reliable services for disabled people, though the targets will need to be sensitive to the needs of disabled people. Reliability goes hand in hand with clear communication, such as advertising which routes/buses on any given timetable will be fully accessible. Affordability may also be an issue for some of the proportion of disabled people who do not fall within the definition of disabled people that is used for the purposes of concessionary bus fares. 22. However it is possible that the emphasis on increasing bus patronage could lead to authorities going for "quick wins" such as commuter services rather than more challenging services which might be of more benefit to disabled people. Low levels of patronage in rural areas (for example) do not mean that a service is not vital for the few people who use it. In some rural areas, bus frequency can be as low as one bus a day to the local town centre. It could also divert attention from increasing the numbers of more accessible vehicles. 23. We therefore recommend that any public investment in Quality Partnerships or Quality Contracts must have full accessibility for disabled people as a condition of this investment. 24. Similar concerns to those expressed above in respect of competition apply to Quality Partnerships. More accessible bus stops and information systems would be welcomed as would the introduction of accessible vehicles and increase frequencies but this should not unduly restrict new entrants into the market. 25. We propose that where local authorities propose to include Quality Contracts in their transport strategies, then they should have a statutory duty to consult either the Disabled Passengers Transport Advisory Committee (DPTAC) or the consultative mechanism for local disabled people that they have set up in connection with its disability equality duty. We recognise that DPTAC would need to be resourced to undertake any such role. 26. Local authorities need to ensure that the public money being used to purchase a public service quality contracts should conform to best practice on accessibility issues. The procurement potential is vast, without adding significantly to the overall cost. The introduction of audio visual announcements on buses, the use of the new DPTAC specification for small buses and a requirement on minimum levels of training and customer care would significantly enhance the travelling experience of people with disabilities. Q1 (d) - Bus punctuality27. Punctual and reliable public transport is particularly important for disabled people. This obviously applies to wheelchair users relying on the arrival of a wheelchair accessible vehicle. However many disabled people find it distressing standing for a long time (especially if there is no shelter and no seating at bus stops) and people with hearing or sight impairments or with learning difficulties have more problems coping with disruption to services. However, it is also important to ensure that the way that punctuality is defined and managed allows for service considerations such as the deployment of ramps for wheelchair users, the use of audible and visual announcements between stops and allowing passengers to reach seating before buses move off. Q1 (e) - Community transport28. We note the proposals to remove some restrictions to the current regulatory regime for community transport relating to the payment to drivers, the size of vehicles, and the issuing of permits throughout Great Britain. We believe this could have the potential to greatly increase the range and flexibility of community transport services. This form of transport is of great importance to the significant numbers of disabled people who live in areas which are not served by a traditional bus route, such as those in very rural areas, or those who live in streets which are too narrow to accommodate a standard bus, or who cannot make the journey to their nearest bus stop. It is also likely to increase the accessibility of the network as a whole as it will bring in more disabled passengers to the transport network. 29. However it is also possible that expectations could exceed resources. It is possible that the current voluntary driving workforce may have a reasonable expectation to be paid and this could affect driver supply. Moreover demand for community transport often exceeds supply in peak times as it is booked up. This puts those disabled people who wish to travel at peak times (to their place of work, for example) at a disadvantage. Q1 (f) - Other measures30. It is proposed that Private Hire Vehicle operators could be eligible for a special licence to operate a taxi-bus. This may increase the supply of such services and could therefore increase the supply of vehicles that would be available to certain disabled people. Services would need to be consistent with Part 3 of the Disability Discrimination Act 1995 in relation to the supply of goods and services. This could help to provide public transport to some of those who do not currently have access to standard bus services. However this should not be used as an excuse to delay the introduction of fully accessible standard buses. 31. The consultation refers to provision for increased flexibility for local authorities to subsidise bus services in order to provide better frequency, hours, vehicles and routes. We consider that this could lead to greater numbers of PSVAR compliant buses sooner. Authorities would also have the scope to set services to a timetable which better meets the needs of more disabled people, especially those who live in outlying areas, and those who wish to travel outside of the core bus operating hours. As we have noted above in respect of Quality Contracts, subsidy should take account of the needs of disabled people, and be carried out with regard to the authority's disability equality duty. It is also important that appropriate links are established between neighbouring authorities to ensure that cross border services are also delivered to appropriate standards. Q3 - Public interest criteria32. We would expect the introduction of PSVAR compliant vehicles to be an essential element of any quality contract. They would be a necessary complement to the provision of accessible bus stop infrastructure by the local transport authority. There is therefore considerable potential benefit to disabled people from the introduction of such contracts and we would expect local transport authorities to recognise this in their consultation documents. Q4 - Role of Traffic Commissioner re bus punctuality33. We note the proposal to give stronger powers for the traffic commissioners to require performance data from local authorities as well as participation in hearings, and a power to make recommendations for future performance. If performance scrutiny has to be carried out in the light of the Commissioner's disability equality duty, as we believe it should, we would expect the bus service needs of disabled people to be taken into account. We believe that this requirement should be clarified and emphasised in any guidance. Q5 - Powers regarding subsidy34. As indicated in our response to Q1(f), we see considerable scope to improve conditions for travel by disabled people in this provision through the early deployment of PSVAR compliant vehicles. Reforming local transport governanceQ6 - Need for reform35. We believe in the need for review of all arrangements from time to time and we have made reference above to some of the benefits of the Transport for London regime regarding the exceptional investment in accessible buses. One of the key barriers to movement by disabled people is the variation in investment in accessible transport infrastructure what they can expect from one local authority area to another. Disabled people need to have confidence that certain minimum provisions will be available at all stages of their journey. However, the review needs to cover the coordination of all modes of transport (road and rail based). 36. We note that this aspect of the proposed legislation is applicable in England only. However, we are also aware that all local authorities in Scotland are members of regional transport partnerships involving various numbers of adjacent authorities and we are surprised that, in terms of case studies, no reference has been made to this or indeed to the different regimes that prevail in Wales and Northern Ireland. We also see a considerable interaction between planning policy and transport policy and would expect to see this reflected in any subsequent guidance or directions that may arise from this proposed legislation. Q7 - Need for flexibility in arrangements37. There major differences both in the nature of development patterns and local authority structures in England. It would therefore seem sensible that the arrangements should be able to reflect local circumstances. We understand this is a feature of the system that applies in Scotland. Q8 - Lead body on proposals for revised governance38. The draft Bill states that major cities must and other authorities can review and propose changes to transport governance, with new powers to be decided on a case by case basis, which could include additional Passenger Transport Authorities, based on guidance on the process issued by the Secretary of State. Economic activity and retail, education, social and health facilities tend to focussed in cities and it would seem natural that the cities that lie at the centre of city conurbations would wish to take a lead in their journey to work area. However, the situation seems less clear where the city in question does not have an associated conurbation. The answer would seem to lie in the flexibility of arrangement promulgated by the preceding question. From the point of view of DPTAC, we would wish to be assured that whoever took the lead, that body was fully aware of the need to involve disabled people in the decision making process. Q9 - Limitations on the extent of change that might be permitted39. We note that the Secretary of State would have the power to direct authorities to prepare a scheme containing provisions for the establishment of a Passenger Transport Authority, even if the authorities concerned were not minded to do so of their own accord. 40. There is evidence that Passenger Transport Authorities have the potential to offer better organised and coordinated and less fragmented transport services. This can be helpful to disabled people, who research has shown, suffer particularly when changing modes or travelling between individual authority areas. 41. In the spirit of the proposed legislation, it would seem inappropriate to limit the extent of change that might evolve (bearing in mind that government has the ultimate control where change of legislation is required in order to enact the change). It would therefore seem more appropriate to specify the minimum expectations of any review. From the point of view of DPTAC, we would expect that any proposals would reflect the four key principles outlined in our introductory comments. Q10 - Development over time42. There is a risk that initiatives in transport, including those to improve the accessibility of transport, may drift during the period when governance changes are being considered. Guidance should refer to the disability equality duty on all such authorities. 43. It is also possible that there might be inequality where some local authorities in an area did not wish to step up to proposing changes to the way transport in their area is governed. Q11 - Changes to powers and duties of Passenger Transport Authorities44. We note the intention to amend the powers of existing Passenger Transport Authorities with reference to climate change and to powers of well being. We are also concerned about the implications of the current move by Government towards the concept of equal opportunities. There is a very specific disability dimension when it comes to consideration of transport and this applies irrespective of the ethnic origin, gender, beliefs or orientation of the disabled traveller. 45. The Disability Discrimination Act 2005 represented a marked advance in the promotion of the interests of disabled people - not least in the fact that it introduced a duty on public authorities to publish a disability equality scheme and action plan by December 2006. We see this Bill as an opportunity to reinforce this aspect of the duties of Passenger Transport Authorities. Q12 - Integrated transport strategy46. We have previously expressed our concern about the effects of the fact that not all local authorities are required to produce a local transport plan in terms of the impact on the Disability Equality Duty and the associated action plans. We also note the separate consultation on the local transport plan process and will be responding to that in due course. We believe that it is impractical for a local authority to demonstrate that it is meeting its obligations under the Disability Equality Duty with regard to the transport function if it does not prepare and publish a local transport plan. 47. We note the intention to replace the current duty on Passenger Transport Authorities to produce a local transport plan and a bus strategy by a duty to provide an integrated transport strategy and implementation plan. 48. DPTAC hopes that this will lead to better coordination of buses and other modes of transport. DPTAC reserves its position on the implications of this for the enhancement of rail services further consideration in the light of further information that is to be provided. 49. Integrated transport strategies have however had a chequered history, and some modes of transport will remain outside the control of those drawing up the plan. This may lead to aspirational statements in the integrated transport strategy (particularly where these are long term covering periods of up to 15 years), rather than deliverable and measurable targets and objectives, with a clear strategy of how to reach them. We are also concerned that initiatives to improve accessibility could drift in the transition from the old to the new planning scheme. 50. In developing local transport strategies, we consider that Passenger Transport Authorities should have a statutory duty to consult either the Disabled Passengers Transport Advisory Committee (DPTAC) or the consultative mechanism for local disabled people that it has set up in connection with its disability equality duty. We again recognise that DPTAC would need to be resourced to undertake any such role. Taking forward local road pricing schemesQ13(a) - Local freedom, flexibility and accountability51. DPTAC has published a position paper on road pricing which we have sent to the government and to all local authorities involving in the Transport Innovation Fund pilot schemes. We commend this guidance to government in taking forward road pricing schemes and have attached it to this response at Annex B. 52. DPTAC anticipates that, as in the London congestion charging scheme, any discounted charging regime would be based on exemption from charges for Blue Badge Holders in recognition of the reduced mobility of disabled people. We recognise that there are concerns about the enforcement of the Blue Badge Scheme but measures in hand and under consideration by the Department for Transport will significantly improve the enforceability of the Scheme. DPTAC would commend any scheme for traffic demand management and road user charging that went beyond discounted charges and actually delivered positive benefits to disabled people. 53. In particular in any road user charging scheme, DPTAC would expect the following:
54. It is proposed that there would be local accountability for road pricing plans rather than approval by Secretary of State, though he/she would issue guidance on the approval process. DPTAC agrees that there is potential benefit in developing schemes that are appropriate for local people in faster and more locally accountable ways. However, there could also be inconsistency between schemes, varying interpretations of the guidance, and schemes which make different assumptions about and provision for disabled people. We are already concerned about other emerging differences in transport service provision for disabled people, for example in the fees that can be charged for a Blue Badge in Scotland, compared to the rest of the country. 55. We need to ensure that not only are disabled people are not subject to unacceptable additional costs as a result of road pricing but that they actually receive a positive benefit. We suggest that any authority that puts forward proposals on road pricing should have a statutory duty to consult both with the Disabled Persons Transport Advisory Committee (DPTAC) and with the consultative mechanism for local disabled people that it has set up in connection with its disability equality duty. We recognise that DPTAC might need to be resourced to undertake any such role but we do not anticipate a major rush of schemes at any one time. 56. DPTAC also considers that the term "local accountability mechanisms" is vague and that this needs full and urgent clarification. 57. It is noted that it is the intention that revenues from road pricing schemes be used for transport purposes throughout the life of the scheme rather than in only the early stages. If proper account is taken of the disability equality duty then this could give a boost to continuous improvement with respect to disability and access issues, keeping routes accessible and at a high standard. 58. However if such resources are not properly allocated and safeguarded, it could be unclear where these revenues actually go and who will benefit from them. The Secretary of State's guidance would be essential to ensure that the revenue is spent efficiently and that the work done is monitored. 59. The consultation proposes that road pricing schemes should have regard to the environmental impact of road pricing schemes. There are demonstrable links between some aspects of environmental quality, health and disability, for example for people with breathing difficulties. It is important that these issues are considered both inside and outside the charge and even the local authority area. 60. However, the need for such a specific provision should be clearly demonstrated. Authorities should already be taking account of environmental consequences and considerations in al that they do and we feel that the case for additional legislation could be more effectively stated. 61. It is proposed that the Secretary of State will no longer be able to require a public inquiry into a road user charging scheme, though it will still be possible for one to be held. While this could speed up the process by which people, including disabled people, enjoy the benefits of such a scheme, it is essential that local people, including disabled people, are still fully consulted. Q13(b) Consistency62. Existing road user charging schemes vary considerably in terms of the nature of the scheme and the concessions that may be offered. If road pricing schemes are to become more prevalent, consistency of on-vehicle equipment, vehicle classifications, signing and concessions is essential in the interests of disabled travellers. Disabled people tend to have lower household income; they are often reliant on the use of the private car for travel and less able to use public transport alternatives; they are less able to use some methods of payment; and the vehicles they may be obliged to use vary depending on the nature of their disability and the size of their family. 63. The consultation includes a proposal to vary the price of a road user charging scheme by the method of payment chosen. This will only be acceptable where all payment methods are equally accessible to disabled people. Q13(c) Information64. The information that may be required by the operating authority will presumably include estimates of the likely number of disabled users. We also assume that any concessions for disabled travellers will be based on the ownership of a valid Blue Badge. The risk of abuse and hence loss of revenue to operators is such that we see the need for a nationally accessible database of Blue Badge holders as an essential complement to the development of road pricing schemes. We would draw attention to our continued campaign for such a database to be established and indeed Government accepted this recommendation in 2002. 65. We would also expect Government to be interested in the uptake of concessions in connection with its duties under the Disability Discrimination Act 2005. Payment of DPTAC members66. Finally, DPTAC welcomes the provision for the payment of DPTAC members, many of whom are putting in considerable time and effort as unpaid advisers to and on behalf of government. At present DPTAC is only one of two Non Departmental Public Bodies for which the Department of Transport is responsible whose members are not paid. Disabled people working on other such bodies, for example Equality 2025 and the Disability Rights Commission, are also paid. 67. We are however concerned about the impact that accepting a paid position might have on the benefits of disabled people, even if the payment is declined. This issue does not seem to have yet been resolved by the Department for Work and Pensions in respect of any of the bodies for which disabled members are currently paid and needs urgent consideration. Concluding comments68. The proposals for the better delivery of bus and community transport, the governance of local transport, and for road user charging, raise a number of issues relating to the delivery of services for disabled people and their involvement in the decision making process. We believe that, if strengthened and referred to appropriately, the disability equality duty will achieve what is necessary. It has the potential to help ensure: that public investment takes place with full account taken of accessibility to disabled people; that those who provide transport services make accessibility for disabled people part of the main stream of their activity; and that those who provide transport services fully involve disabled users and non-users in determining the accessibility of transport services and are responsible for accessibility for disabled people. Grahame Lawson and Dai Powell Tel: 020 7944 8012 Date: 9 September 2007 Annex A: Disabled people in the population / population trends in disability1. The principal concern of DPTAC 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 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. While higher numbers of children are being born and living with impairments than ever before, disability levels do increase with age. 3. Currently 985,000 people live with learning disabilities, 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. 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. 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. The needs of disabled people may be best met by any, all or combinations of: adapted forms of communication, attention to light and sound levels, easy to read signage and wayfinding, planning for assistance dogs, the presence of suitably trained and empowered staff, and appropriately designed physical infrastructure such as ramps, lifts and surfaces. 6. Disabled people live throughout the community. One in four households has a disabled resident. The need for access for disabled people is not limited to specific areas, but is present throughout the wider transport system. Population trends in disability7. 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. 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. 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", and in our response to it. Annex B: DPTAC position statement on road user charging1. This position statement sets out the position of DPTAC with regard to road user charging schemes. It is intended to give guidance to government, local authorities, private operators and consultants involved in considering, promoting and running such schemes. Introduction2. The cost of maintaining and developing the road network in the UK is currently secured through national and local taxation. Vehicle users contribute through vehicle excise duty, taxation on the purchase of vehicles, transport services and fuel and through parking fees. 3. Congestion imposes further costs on society in terms of delays, unreliable journey times, road safety and atmospheric pollution. 4. At present the costs to the road user of using roads are not directly linked to the cost to society of providing and using roads. Road user charging is being championed by Government and others as a fairer and more transparent way of funding transport expenditure and of managing the way our roads are used. Road user charging, however, has implications for the interests of disabled people. This statement represents the views of DPTAC on the subject. 5. The relevant DPTAC objectives on this matter are:
Why road user charging?6. Road user charging is seen as offering benefits in terms of managing the use of the road network and encouraging the use of public transport alternatives. The benefits include:
7. DPTAC recognises that disabled people potentially have as much to gain from this as anyone. Disabled drivers and passengers will benefit from reduced and more reliable journey times. Disabled passengers will also benefit from investment in public transport and disabled pedestrians and those who live near roads will benefit from reductions in atmospheric pollution. Road user charging also has the potential to offer positive financial benefits to disabled people. Existing road user charging schemes8. Road user charging is not a new concept and there are various existing examples to be found in the UK:
9. In some cases, the charge is made to help in paying for cost of constructing and maintaining the bridge, tunnel or motorway. In the case of Durham and London, the purpose is to limit the number of vehicles entering the core area. 10. The London scheme has seen a substantial reduction in delays and the number of vehicles entering the central area. Journey times for buses and taxis have greatly improved and travellers have shifted from car to public transport. Travel by disabled people has been helped by concessions for Blue Badge Holders (who are not charged) and by complementary investment in new low floor buses. Future developments11. A proposed scheme for a city wide congestion charging scheme in Edinburgh was abandoned in February 2005 when it failed to gain public support in a referendum. There are, however, other proposals in other parts of the UK. These include more congestion charging schemes and a further section of toll motorway. 12. Despite the setback in Edinburgh for the proponents of road user charging, government in England and in Scotland has indicated a continuing interest in road user charging. The technology to support road user charging is also developing rapidly both in the UK and elsewhere in Europe. 13. The Secretary of State for Transport has said that he wishes the UK to move towards a national system of road pricing. There is an emphasis in the distribution of the new Transport Innovation Fund in England towards those local authorities that included traffic demand management measures such as road user charging in their submissions. Accommodating the needs of disabled people in road user charging schemes14. DPTAC recognises that road user charging is increasingly likely to feature in transport policy and financing in future. In considering road user charging schemes DPTAC believes that:
15. Any scheme for road user charging which increases the costs of travelling by car is likely to have a disproportionate effect on the lives of disabled people. The reasons are that:
16. A key feature prior to the introduction of the London congestion charging scheme was extensive consultation with different user groups including groups representing disabled people. This led to the introduction of concessions for Blue Badge Holders and for vehicles that are not liable for Vehicle Excise Duty (such as Dial a Ride vehicles). 17. Concessions in other existing road user charging schemes also tend to be based on possession of a Blue Badge and/or exemption from Vehicle Excise Duty and/or receipt of the higher rate of the mobility component of the Disability Living Allowance. 18. In Durham, the primary objectives of the County Council included improving access for disabled people. However, it is noted that in fact existing disabled parking bays were removed from the Market Place and replaced with Loading Bays for use at any time. There are no general exemptions for Blue Badge Holders. Provision for disabled people is made through subsidy of the local Shopmobility Scheme and through the provision of a high quality easy access bus service linking the station and various car parks to the city centre. While parking on street is free for Blue Badge Holders, there is a charge for off street parking. 19. The introduction of the London congestion charging scheme was accompanied by major investment in new low floor buses. However for buses, trams and trains to be fully accessible to all disabled people, it is essential to ensure that not only the vehicles but also the bus/tram stops and stations and the associated footway approaches are accessible and well maintained. Information about transport options needs to be accessible. Public transport vehicles have to be fitted with visual and audible announcements and operatives need to have appropriate disability equality training. 20. However, there is also a danger that as travel by private car is made more expensive, there is an opportunity for public transport service providers to increase their charges. This would lead to a double impact on disabled people. We therefore believe there is a need for some form of equity audit associated with all road user charging schemes to ensure that the benefits are locked in and so that any increases in costs for disabled travellers are offset (by say reductions in transport related taxation or the introduction of mileage allowances). The technology now becoming available for implementing and enforcing road user charging schemes could be used to promote such concepts of social inclusion. 21. In any road user charging scheme, DPTAC would therefore expect the following:
22. DPTAC anticipates that, as in the London congestion charging scheme, any discounted charging regime would be based on exemption from charges for Blue Badge Holders in recognition of the reduced mobility of disabled people. DPTAC recognises that there are concerns about the enforcement of the Blue Badge Scheme but measures in hand or under consideration by the Department for Transport will significantly improve the enforceability of the Scheme. 23. Finally, we would commend any scheme for traffic demand management and road user charging that goes beyond discounted charges and actually delivers positive benefits to disabled people. ReferencesIn preparing this position statement, the following references have been of particular assistance.
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/. 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. |
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