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					DPTAC response to consultation on Welsh
Transport Strategy "Connecting Wales"


DPTAC response to consultation on Welsh Transport Strategy
"Connecting Wales"

Introduction................................................................................................ 1
General comments .................................................................................... 2
     Disabled People in the Population ...................................... 2
     Population Trends in Disability ........................................... 3
     A strategic approach to designing inclusively ................... 4
Key issues in the consultation ................................................................. 5
Theme 1: To achieve a more effective and efficient transport system .. 6
     Use of technology ................................................................ 6
     Introduction of new infrastructure when required ............. 7
     Better co-ordination of transport fleets .............................. 7
Theme 2: To achieve greater use of the more sustainable and healthy
forms of transport ..................................................................................... 7
     Improving the attractiveness of alternatives to the private car
      ............................................................................................... 7
     Rail Network.......................................................................... 9
     Smarter Pricing ..................................................................... 9
     Access for disabled people ................................................. 9
Theme 3: To minimise the need to travel ................................................ 9
     Land Use Planning ............................................................... 9
Additional comments .............................................................................. 10
     Public Transport Users’ Committee .................................. 10
     Awareness training ............................................................ 10
     Consultation process ......................................................... 10
     Disability equality duty....................................................... 11
Conclusion ............................................................................................... 13

Introduction
1.      The Disabled Persons Transport Advisory Committee (DPTAC)
        welcomes the opportunity to comment on the Welsh Transport
        Strategy "Connecting Wales". We believe that meeting the transport
        needs of disabled people is an important and integral feature of any
        transport strategy for the country.

2.      The United Kingdom 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


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DPTAC response to consultation on Welsh
Transport Strategy "Connecting Wales"

          goes and that they can do so easily and without extra cost. We would
          like to see this happen by 2020.

3.        DPTAC has identified four overarching principles on which to base its
          advice to Government, other organisations and disabled people.
          Those principles are that:

         Accessibility for disabled people is a condition of any investment
         Accessibility for disabled people must be a mainstream activity
         Disabled people should be involved in determining accessibility
         Accessibility for disabled people is the responsibility of the provider

4.        These principles are the basis of DPTAC‟s response to consultations.
          In this response, we set out some general issues before making
          comments specific to this consultation.


General comments

Disabled People in the Population
5.        DPTAC‟s principal concern is to ensure accessibility for disabled
          people. By this, we mean inclusive transport systems that are easy to
          reach, use and understand by all, in safety and comfort.

6.        Disabled people and those with a long term illness account for some
          10% of the population, including people with limiting longstanding
          illnesses; of which, 4.6 million are over state pension age and 700,000
          are children.1 While higher numbers of children are being born and
          living with impairments than ever before2, levels of disability do
          increase with age.

7.        Currently 985,000 people live with learning disabilities.3 796,000 of
          these are adults aged 20 or over. The adult figure will increase to
          855,000 (plus 7%) in 2011 and 891,000 (plus 11%) in 2021. It has
          been estimated that some 7 million adults have literacy problems.


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"
2
  Improving the Life Chances of Disabled People 2005 at
http://www.strategy.gov.uk/downloads/work_areas/disability/disability_report/pdf/disability.pdf
3
  Foundation for People with Learning Disabilities 2006,
http://www.learningdisabilities.org.uk/html/content/need2know_lives_ld.pdf
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DPTAC response to consultation on Welsh
Transport Strategy "Connecting Wales"

8.      Using a broader definition of disability, an Omnibus Survey by the
        Department of Social Services reported that the provisions of the
        Disability Discrimination Act 1995 covered approximately 11.7 million
        people, including 6.5 million people of working age. Multiple
        disabilities were common, as illustrated by prevalence figures
        indicating that a third reported sensory deficits, a third learning
        difficulties, half mobility problems and roughly as many impaired
        physical co-ordination. Long-term illnesses such as Alzheimer‟s
        disease and mental illness were included in the estimated total
        number of people affected by disability.4

9.      Disabled people are not an homogenous group with identical needs.
        The needs of people with mental health problems or learning
        disabilities are distinct from those of wheelchair users for example.
        Even among people with similar impairments, needs vary, for
        example, profoundly deaf people will not benefit from induction loops.

10.     Disabled people live throughout the community. One in four
        households has a disabled resident.5 The need for access for disabled
        people is not limited to specific areas, but is present throughout the
        wider transport system.
Population Trends in Disability

11.     The number of people over state pension age is projected to increase
        by 11.9% from 10.9 million in 2002 to 12.2 million in 2011 and the
        population aged 80 and over is projected to grow from 2.5 million in
        2002 to nearly 5 million by 2031.6 The proportion of the working
        population will increase, as retirement ages advance. Over the same
        period that will bring about these changes in the population profile, the
        overall population will increase by about 9%.

12.     The Department for Work and Pensions estimated in 2004 that
        disabled people have a spending power of around £80 billion each
        year7. Planning strategically to design transport facilities that meet the
        needs of disabled people is likely to further increase this amount, as


4
  K Williams, T Savill and A Wheeler “Review of the road safety of disabled children and adults” 2002,
available at http://217.118.128.203/store/report_detail.asp?srid=2710&pid=211
5
  James Ruppert, Independent June 15, 2004
6
  DRC Report for Party Conferences 2004
7
  www.dwp.gov.uk/mediacentre/pressreleases/2004/dec/spending.asp
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DPTAC response to consultation on Welsh
Transport Strategy "Connecting Wales"

      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 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
      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.
A strategic approach to designing inclusively

15.   There is enormous scope and opportunity to improve accessibility for
      disabled people but it will require a strong and continuing commitment
      at all levels.

16.   Terms such as „access' and 'accessibility‟ can be interpreted in
      different ways. By access for disabled people, we mean inclusive
      transport services that are easy for everyone to reach, use, afford and
      understand in safety and comfort. This is consistent with the
      government's aim of delivering transport that works for everyone.
      Disabled people will expect 'accessibility' to refer to whether they can
      reach and use transport easily to get to places, rather than simply if a
      place or service is easy and quick to get to compared with other
      places.

17.   Accessibility for disabled people is often only considered in terms of
      detailed design. DPTAC believes this is no longer sufficient.
      Considering accessibility for disabled people must underpin strategic
      decisions, investment and policies, with evidence of how diversity was
      considered in making decisions. We also seek evidence of joined up
      action by all parties involved in transport service provision. This may
      require education, training and continuing professional development in
      disability issues for those involved in the planning, design and
      management of transport systems, as well as at the front line.

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DPTAC response to consultation on Welsh
Transport Strategy "Connecting Wales"

18.   It is not only disabled people who benefit from this approach. There
      are currently a further 18 million people who would directly or
      indirectly benefit. These include older people, families with small
      children under the age of five, carers, friends and relatives who
      accompany people with disabilities, and tourists and others whose
      first language may not be English, Indeed it is fair to say that all
      members of society benefit to some degree from what we can call
      “inclusive design”.

19.   An inclusive approach to design creates transport that can be used by
      everyone, regardless of age, gender, ethnicity or disability. This
      makes facilities truly functional, efficient and sustainable. Inclusive
      design recognises and accommodates differences in the way people
      use transport and provides solutions that enable them to take part in
      mainstream activities equally, independently, and with choice and
      dignity.

20.   Inclusive transport planning does not attempt to meet every single
      need, but considers people‟s diversity and breaks down unnecessary
      barriers and exclusions in a manner that benefits us all. This is
      significant because although society and individuals have invested
      heavily in enabling people to manage their personal circumstances
      effectively (e.g. by providing aids and adaptations for disabled
      people), many people remain unnecessarily „disabled‟ by ill-conceived
      facilities and services.

21.   DPTAC welcomes the commitment that the UK government has made
      to accessibility being a condition of public money being spent in
      support of its Ten Year Plan "Transport 2010", and its similar
      commitment in respect of the Wales Transport Framework.

22.   Private and public investors of any transport project need to know
      whether investment plans meet the need of disabled people. They will
      also need evidence that people at all levels of responsibility
      understand how to provide accessibility for disabled people effectively
      to prevent a waste of resources.

Key issues in the consultation
23.   We recommend that there should be a clear and highlighted statement
      early in the transport strategy recognising the commitment to improve

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DPTAC response to consultation on Welsh
Transport Strategy "Connecting Wales"

      access for disabled people. Building in accessibility for disabled
      people in all new investment is a condition of public money being
      spent and a condition of support from the Assembly. This was referred
      to in paragraph 3.3.6 of the Transport Framework for Wales and is a
      condition of funding for public transport in Section 7 of the Transport
      (Wales) Act 2006.


Theme 1: To achieve a more effective and efficient transport system

24.   We welcome the objectives set within this theme of striving for an
      effective and efficient transport network.

Use of technology

25.   Technology is developing at a rapid pace which enables access to
      real time information, such as timetables, routes, and possible delays
      more available than it has ever been. However, this information
      needs to be available in accessible formats so that the whole
      community of Wales benefits from it.

26.   We recommend the provision of a one-stop transport telephone
      information line that can give travel information on all types of
      transportation. This telephone number should be a free call or local
      rate telephone number and those operating it should be familiar with
      Typetalk.

27.   Travel information web sites should be fully accessible - approved
      accessibility standards set by organisations such as the World Wide
      Web Consortium (W3C) and tested through web accessibility tools
      such as Watchfire Bobby, which are designed to help expose barriers
      to accessibility. The Disability Rights Commission has published a
      standard "PAS 78: a guide to good practice in commissioning
      accessible websites". Where documents are published on the Internet
      they should be easily accessed and downloaded, with the option of a
      single file as well as a number of smaller files for each section. We
      recommend a simple text or 'Word' version is also available as a
      single download because some text to sound software used by people
      with visual disabilities cannot read PDF documents.

28.   Clearly audible and visible information on public transport, such as
      buses and trains and at bus and train stops are important for disabled

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DPTAC response to consultation on Welsh
Transport Strategy "Connecting Wales"

      people. This type of information has been found to be of great
      assistance to wider public transport users. This has been
      demonstrated in trials by Transport for London of audible and visual
      information on buses.

29.   However even simple options like large print Welsh and English
      timetables are not as widely available as they should be, given how
      easily they can be produced with current technology.
Introduction of new infrastructure when required

30.   All new transport infrastructure should be fully accessible and meet
      current best practice standards. Disabled people need to be involved
      at all stages of design and development. This should be
      supplemented by the use of qualified and experienced access
      consultants

31.   Pedestrian environments and links and interchanges between
      transport modes are no less important than the facilities that they link
      such as stations or vehicles.
Better co-ordination of transport fleets

32.   Many disabled people, particularly those living in rural areas, rely on
      community transport and that provided by such bodies as education
      departments and health authorities.

33.   Sufficient funding must be allocated to ensure that community
      transport is effective, affordable to users and available in all the
      Regional Transport Consortia areas. It is vital that such services are
      able to cross local authority boundaries and be available at times that
      users will find beneficial, including weekends and evenings.


Theme 2: To achieve greater use of the more sustainable and healthy
forms of transport

Improving the attractiveness of alternatives to the private car

34.   We welcome the emphasis in the Wales Transport Strategy on the
      need to encourage more people in Wales to use public transport. We
      share the belief, stated in the document, that the Assembly needs to
      address the current dominance of the car in Wales.
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DPTAC response to consultation on Welsh
Transport Strategy "Connecting Wales"

35.   It is however important to recognise that for some disabled people use
      of a car may be the only option to travel to some destinations. Our
      research shows that car travel, often in a car driven by someone else,
      is a common mode of transport for disabled people. Parking provision,
      traffic law enforcement, road safety and road user charging polices
      need to take this into account. We have published a position paper on
      road user charging that sets out important principles for pilot studies
      such as that which might be carried out in Cardiff. These comments
      are also relevant to the section in the consultation document on
      “Managing the demand for different routes through pricing and
      regulation”.

36.   In the development of a walking and cycling strategy the Assembly
      could usefully take account of the importance of accessible pedestrian
      environment and use standards such as those set out in the
      Department for Transport‟s ”Inclusive Mobility” and Transport for
      London‟s “Streetscape Guidance”.

37.   We support the proposal to improve cycling networks, and believe that
      due consideration must be given to the safety of disabled people,
      particularly pedestrians with sensory impairments, when cycle
      routes/lanes are being designed. It is vital that cycle lanes and
      pedestrian footpaths are clearly defined as separate areas and
      effective tactile and visual markings indicate these defined areas.

38.   The issue of the lack of confidence and even avoidance of
      inaccessible and/or unsafe environments has been highlighted in a
      recent report published by the Guide Dogs for the Blind Association,
      “Shared Surfaces in the Public Realm”. DPTAC is carrying out its own
      research on how Home Zones could be made more sensitive to the
      needs of disabled people, and we will brief the Welsh Assembly on
      the results of this work when they are available.

39.   For more information, the Assembly should note the advice in the
      Disability Rights Commission guidance on “Planning, Buildings,
      Streets and Disability Equality”, which, although it refers to local
      authorities, is also relevant to the work of the Welsh Assembly
      Government.




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DPTAC response to consultation on Welsh
Transport Strategy "Connecting Wales"

Rail Network
40.   The Transport Strategy recognises that the rail network is limited in
      Wales and that many groups of people do not have ready access to it.
      We welcome the proposal to improve links to rail networks and to
      improve long distance bus and coach services. These must be fully
      accessible.
Smarter Pricing
41.   We welcome the continued commitment to offer a concessionary bus
      fare scheme for older and disabled people in Wales. We also
      commend the decision not to impose restrictions on when the
      concessionary pass may be used. We believe that the Assembly
      should consider the provision of concessionary fares across transport
      modes – particularly use for taxis and community transport in rural
      areas. We would draw its attention to the Department for Transport‟s
      ongoing research on community transport and reducing social
      exclusion, and research planned by the Commission for Integrated
      Transport on taxis and social inclusion.

Access for disabled people

42.   The draft Transport Strategy for Wales rightly addresses the difficulty
      disabled people encounter when trying to access bus and train
      services. We therefore welcome the commitment given in the
      Transport Strategy that “there will still be a need, however, to continue
      to improve routes to bus and train stations, to ensure that services are
      accessible for all”.


Theme 3: To minimise the need to travel

Land Use Planning
43.   We welcome the proposal to ensure that there is joint thinking
      between; health, education, retail and employment, where transport is
      considered at the earliest planning stage. Decentralisation of such
      facilities so that they are within easy reach of people‟s homes will help
      ease of access to proper healthcare, education, employment
      opportunities, leisure and retail services.




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DPTAC response to consultation on Welsh
Transport Strategy "Connecting Wales"

Additional comments

Public Transport Users’ Committee

44.   DPTAC welcomes the proposal to establish a new Public Transport
      Users‟ Committee in Wales “to ensure the passengers‟ voice is
      heard”, and we have discussed this with Assembly officials. The
      Assembly must consider carefully how this body will deal with access
      and disability issues. One option is to establish a Disabled Persons‟
      Transport Committee which could be structured and have a similar
      remit to that of the Mobility and Access Committee for Scotland.
      (MACS). The recent decision of Scottish Ministers to maintain MACS
      alongside a new Public Transport Users‟ Committee should be taken
      into account.
Awareness training

45.   All transport providers should ensure that their organisations have an
      effective disability awareness training programme in place, for all staff.
      In addition to front line transport staff, disability equality training should
      be provided throughout the transport sector to all those whose
      decisions will impact on the design, development and operation of the
      transport system. Such training should be developed and delivered
      with the involvement of disabled people. Training may focus on
      awareness of how transport affects different people and their ability to
      move around independently. It may also focus on understanding the
      technical solutions and applications that contribute to more inclusive
      transport.

Consultation process
46.   Local authorities and transport providers should be explicitly required
      to clarify who is being consulted, about what questions, in what time-
      scale and for what purpose. They should ensure disabled people and
      those concerned with access are consulted on a range of issues, not
      just those specifically focussed on disabled people. Principles of
      inclusive transport should always underpin policy development and
      should not be a separate issue.

47.   Transport providers and local authorities need to make documents
      widely available, with the fullest use of electronic means (though not
      to the exclusion of others), and effectively drawn to the attention of all
      interested groups and individuals. Making documents widely available
      should include doing so in alternative formats at the time that they are
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DPTAC response to consultation on Welsh
Transport Strategy "Connecting Wales"

      initially published. These could include Braille versions, audiotapes,
      large print, easy-to-read versions with illustrations.

48.   Documents such as local transport plans are often advertised in small
      print public notices in newspapers. We believe that such notices
      should also be advertised in other locations, such as; talking
      newspapers, local and regional radio, local organisations representing
      disabled people, and accessible web sites.

49.   Consultation processes, including meetings, must be accessible in
      their venues, timing, organisation and documentation, and the
      language used needs to be inclusive. Inclusiveness may require
      building the capacity of the organisations involved so that they are
      able to engage fully. Facilities required may include signers, induction
      loops, Blue Badge parking facilities, good connections to public
      transport And facilities for assistance dogs. The Department for
      Transport has produced guidance for engagement with disabled
      people (e.g. "Consultation guidance: disabled people" at
      http://transnet.dft.gsi.gov.uk/doc2.asp?docId=141950&catId=69406).

Disability equality duty

50.   Our understanding of the Disability Discrimination Act 2005 is that the
      Welsh Assembly is subject to both the general duty and the specific
      duties under the Act. The Assembly has specific duty to report on
      progress. The first report is due by 1st December 2008 and every
      three years thereafter.

51.   In terms of the general duty, the decisions and actions of the
      Assembly and local authorities and partnerships with transport
      responsibilities will have to have due regard to the six principles of

  o Promoting equality of opportunity
  o Eliminating discrimination
  o Eliminating harassment
  o Promoting positive attitudes
  o Encouraging participation by disabled persons
  o Treating disabled people more favourably than others.



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DPTAC response to consultation on Welsh
Transport Strategy "Connecting Wales"

52.   Not only is there an expectation of positive action, but it is worth
      stressing that the duty is retrospective – the Assembly and transport
      authorities will be expected to take action to rectify the consequences
      of past decisions and actions that failed to give due regard to disability
      equality.

53.   In drawing up a strategy for meeting their obligations under the Act,
      we would expect the Assembly and transport authorities to
  o Demonstrate real leadership in the promotion of an inclusive transport
    environment
  o Review the continued relevance of current policy statements and
    action plans and amend these as appropriate
  o Ensure that future policies, practices and action plans recognise the
    accommodation of the needs of disabled people as a mainstream
    activity and indeed as a positive feature
  o Review the effectiveness of past funding of trunk road projects
    regarding the promotion of an inclusive transport environment
  o Promote remedial action/programmes to deal with identified
    deficiencies and prioritised in consultation with local groups
    representing disabled people
  o Ensure that any recommendations regarding funding given to the
    Highways Agency, partner local authorities, public transport operators
    and others is dependent on the promotion of an inclusive transport
    environment
  o Monitor good practice regarding positive action and encourage its
    adoption elsewhere
  o Monitor progress towards the creation of an inclusive transport
    environment in a way that is meaningful
  o Engage actively and regularly with local organisations representative
    of disabled people
  o Ensure all staff (from the top to the bottom of the organisation) are
    aware of the Disability Equality Duty and that they take account of this
    in their daily work
  o Ensure that staff receive the necessary training and support

54.   We would expect the Assembly to be developing an overall strategy
      and action plan as required under the Act but local transport

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DPTAC response to consultation on Welsh
Transport Strategy "Connecting Wales"

      authorities and partnerships will need to translate this into local action
      plans.


Conclusion


55.   DPTAC welcomes the opportunities presented by the consultation on
      the Welsh Transport Strategy. It is particularly timely given the
      deadlines of the Disability Equality Duty. Together they offer the
      prospect of a specifically Welsh vision that is inclusive of disabled
      Welsh people, and that also builds on wider good practice.


Neil Betteridge, Chair, Disabled Persons Transport Advisory Committee
4/24 Great Minster House
76 Marsham Street, London SW1P 4 DR
Telephone Number 020 7944 8012
Email address Dptac@dft.gov.uk

Date: 19 October 2006




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