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									DPTAC response to the Second Three Year Review of
the Department for Transport’s Road Safety Strategy

DPTAC response to consultation on the Second
Three Year Review of the Department for Transport’s
Road Safety Strategy


                                              Contents



Introduction .............................................................................................1
General comments .................................................................................2
     Disabled People in the Population ......................................2
     Population Trends in Disability ...........................................3
Key issues in the consultation ..............................................................4
     Scope of review ....................................................................4
     Disability Equality Duty ........................................................5
     Existing data, statistics and research .................................7
     Mobility scooters ..................................................................8
     Adapted vehicles ..................................................................9
     Need for further data and research .....................................9
     Home Zones ..........................................................................9
     Travel training .....................................................................10
     Highway construction ........................................................ 10
Conclusion ............................................................................................ 11

Introduction
1.      The Disabled Persons Transport Advisory Committee (DPTAC)
        welcomes the opportunity to comment on the Second Three Year
        Review of the Department for Transport’s Road Safety Strategy. We
        believe that meeting the transport needs of disabled people is an
        integral feature of any road safety strategy for the country.

2.      The government set up DPTAC under the Transport Act 1985 to
        advise it on the transport needs of disabled people. Our aim is to
        ensure that disabled people can go where everyone else goes and
        that they can do so easily and without extra cost. We would like to
        see this happen by 2020.




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DPTAC response to the Second Three Year Review of
the Department for Transport’s Road Safety Strategy

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

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

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


General comments

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

6.        Disabled people and those with 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.

8.        Using a broad definition of disability, an Omnibus Survey by the
          Department of Social Services reported that the provisions of the

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 the Second Three Year Review of
the Department for Transport’s Road Safety Strategy

        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 more disabled people become creators of the national
        wealth, rather than consumers of its state benefits.

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 the Second Three Year Review of
the Department for Transport’s Road Safety Strategy

13.    Meeting the transport needs of disabled people by providing
       inclusive transport policies and infrastructure will be of considerable
       economic benefit to the country; both allowing them to exert this
       spending power and enabling them to become or remain part of the
       country's workforce.

14.    The mobility of disabled people is also a precondition for the
       achievement of a wide range of government objectives such as safe
       and independent living; full participation in civil society; and the
       maintenance of good physical and mental health through access to
       recreational and cultural facilities. Some of these links were brought
       out in the Prime Minister's Strategy Unit's report "Improving the Life
       chances of Disabled People", and in our response to it.


Key issues in the consultation

Scope of review
15.    While DPTAC very much welcomes this opportunity to comment on
       the second three year review of the Road Safety Strategy8, we are
       concerned about the lack of reference to the needs of disabled
       people. This is a matter which will have to be addressed under the
       new Disability Equality Duty under the Disability Discrimination Act
       2005 which affects all the Department for Transport's functions from
       4 April 2006.

16.    The Department for Transport has advised us that the scope of the
       review is to "report on progress towards the target; identifying,
       where possible, the most effective measures and assessing the
       priority areas for action with associated delivery plans for the period
       remaining to 2010". While Ministers may not consider it appropriate
       to add new targets to the strategy at this stage, we remain
       concerned that the current targets say nothing about how to make
       improvements to the road safety of disabled people. The strategy
       has another four years to run, a period which could allow
       considerable progress.

17.    One aspect of the review is to develop a timetable for actions to
       develop a road safety strategy for when the present one expires in
8
 "Tomorrow's Roads Safer for Everyone", 2000,
http://www.dft.gov.uk/stellent/groups/dft_rdsafety/documents/page/dft_rdsafety_504644.hcsp
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DPTAC response to the Second Three Year Review of
the Department for Transport’s Road Safety Strategy

      2010. We recommend that the Department for Transport sets in
      hand the action necessary so that, by 2010, it will be in a position to
      set meaningful targets for how the road safety of disabled people
      will be improved based on evidence based baselines and with
      established means of achieving them.

Disability Equality Duty
18.   It is timely that the Road Safety Division of the Department for
      Transport is considering the implications for disabled people of its
      work, as the Department is now preparing for the introduction of the
      Disability Equality Duty on 4 December 2006.

19.   The Department for Transport is subject to both the general duty
      and the specific duties under the Act. The Secretary of State also
      has a specific duty to report on progress. The first report is due by
      1st December 2008 and every three years thereafter.

20.   In terms of the general duty, the decisions and actions of the
      Department for Transport and the highway and police authorities
      and others with which it takes forward road safety 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.

21.   Not only is there an expectation of positive action, but the duty is
      retrospective – the Department for Transport 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. This could include the failure to take
      account of the needs of disabled people in developing the Road
      Safety Strategy.




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DPTAC response to the Second Three Year Review of
the Department for Transport’s Road Safety Strategy

22.   In drawing up a strategy for meeting their obligations under the Act,
      in respect of road safety we would expect the Department for
      Transport and these others 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 road safety 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
    partner local authorities and others is dependent on the promotion
    of an inclusive approach to road safety
  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 Ensuring that staff receive the necessary training and support

23.   We would expect the Department for Transport to be developing an
      overall strategy and action plan in respect of road safety as required
      under the Act, while but local transport authorities and partnerships
      will need to translate this into local action plans.

24.   As far as the Road Safety Strategy is concerned, under Theme 1
      we would expect to see recognition of the needs of disabled
      children, including those with learning difficulties. Under Theme 2,
      we would expect driver training to emphasise the need to be aware

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DPTAC response to the Second Three Year Review of
the Department for Transport’s Road Safety Strategy

        of pedestrians who have hearing or sight impairments. Under
        Theme 4, safer infrastructure also has to be inclusive and
        accessible infrastructure. In this connection, we would mention the
        new Department for Transport publication "Manual for Streets"
        currently being finalised. Safer speeds, Theme 5, are also very
        important for disabled people, many of whom have difficult in coping
        with traffic at the best of times.

25.    Under Theme 8, Safer Pedestrians, Cyclists and Horseriders, there
       is reference to vulnerable groups and particularly cyclists. Disabled
       people feel particularly vulnerable and, while this might not be
       reflected in statistics, we know that many disabled people feel
       disenfranchised by the current transport environment. This
       includes, paradoxically, new Home Zones (see separate comment
       at paragraph 35 ff).

26.    Finally, in Chapter 4 we would expect to see actions and targets
       relating specifically to improving conditions for disabled people.
Existing data, statistics and research

27.    At present the Department for Transport collects very little data that
       is detailed enough to help form a view as to the extent to which the
       road safety risks of disabled people might be different from or the
       same as those of the population in general and, if they are different,
       what action might be needed to fine-tune road safety policies to
       meet the needs of disabled drivers, passengers and pedestrians.
       For example, although we know from our own research9 that
       disabled people travel less than most people, but do so
       disproportionately by car, we do not know what risk this puts them
       at compared to car drivers and passengers without disabilities.
       That would be likely to depend on the time of day they travel, the
       vehicles they travel in and the roads they travel on, among many
       other factors that are simply not yet known.

28.    Recently the Department for Transport has collected statistics on
       contributory factors to accidents10. These include "impairment or
       distraction", a category that includes fatigue, alcohol, drugs,

9
  "Attitudes of Disabled People to Public Transport " DPTAC
http://www.dptac.gov.uk/research/apt/index.htm
10
   For example the 2006 "Contributory factors to road accidents" at
http://www.dft.gov.uk/stellent/groups/dft_transstats/documents/downloadable/dft_transstats_612594.pdf
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DPTAC response to the Second Three Year Review of
the Department for Transport’s Road Safety Strategy

       distracted drivers and cyclists who wear dark clothing, as well as
       illness and disability. However this only covers situations where
       impairment is a factor in causing the accident and the figure is
       based on judgments made by the reporting police officer at the
       accident scene.

29.    We are pleased that the Department has sponsored and published
       some research in this area. However the conclusions of that
       research are primarily that little is known and much more needs to
       be done. For example two of the Department’s recently published
       projects conclude respectively that

       "Whilst it seems likely that disabled people are at increased risk of
       road accident involvement, it is not possible to establish the most at-
       risk groups as there has been insufficient research in this area."11
       and

       "anecdotal evidence has indicated that children and adults with
       disabilities may be at increased risk of road accident involvement,
       but the extent and nature of the problem has not been
       systematically assessed."12

30.    We recommend that the Department ensure that data is collected
       about disabled people involved in road accidents as drivers,
       passengers, riders or pedestrians.

Mobility scooters

31.    A specific area where the statistics are uncertain relates to Class 2
       and Class 3 vehicles, commonly and hereafter referred to as
       “mobility scooters”. These can be invaluable for many disabled
       people in increasing their mobility and freedom. They have also
       proved to be a threat and a danger to some disabled people, when
       driven irresponsibly. The Department of Transport has recently
       completed research on the use on highways of mobility scooters13,
       and Ministers are considering the recommendations.

11
   "Road Safety Research Compendium of Research Projects 2004/2005" (at
http://www.dft.gov.uk/stellent/groups/dft_rdsafety/documents/page/dft_rdsafety_037842.pdf) page 26
12
    "Review of the road safety of disabled children and adults" at
http://217.118.128.203/store/report_detail.asp?srid=2710&pid=211) page 16
13
   “Review of Class 2 and Class 3 Powered Wheelchairs and Powered Scooters (Invalid Carriages)” at
http://www.dft.gov.uk/stellent/groups/dft_mobility/documents/page/dft_mobility_611260.pdf
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DPTAC response to the Second Three Year Review of
the Department for Transport’s Road Safety Strategy

32.    Our concern here is how statistics are collected on accidents
       involving mobility scooters or wheelchairs. The police are
       apparently not able to identify mobility scooters in the accidents that
       they report, and it may be that they and wheelchairs are included in
       the category “Other vehicle". We recommend that the Department
       ensure that data is collected about mobility scooters and
       wheelchairs that may be involved in road accidents.

Adapted vehicles

33.    Another area where data collection could be improved is with details
       of road accidents involving public and private transport vehicles that
       have been adapted to meet the needs of disabled people. These
       would include minibuses and private cars. Such adaptations are
       becoming increasingly important as more older and disabled people
       have been used to driving for much of their lives and wish to
       continue to do so. Additionally from December 2006 car hire will be
       covered by Part 3 of the Disability Discrimination Act 1995. We
       recommend that the Department ensure that data is collected about
       private and public transport vehicles involved in road accidents that
       have been adapted for disabled people.
Need for further data and research

34.    Clearly the Department for Transport needs to collect to establish
       the variables relevant to disabled people’s road safety risk. This
       process needs to start now if the government is to have the data it
       needs to set baselines and plan appropriate interventions by 2010
       when the new road safety strategy needs to be in place. DPTAC
       stands ready to advise on research proposals and to serve on
       steering groups directing such research.
Home Zones
35.    A “home zone” has the aim of extending the benefits of slow traffic
       speeds within residential areas and gives greater priority to non-
       motorised users. Home Zones use design to limit vehicles to very
       low speeds, well below 20mph with the aim of improving the quality
       of life in residential roads by making them places for people, instead
       of just being thoroughfares for vehicles14.



14
   "Home Zones: Challenging the future of our streets" Department for Transport 2005, at
http://www.dft.gov.uk/stellent/groups/dft_susttravel/documents/divisionhomepage/610453.hcsp
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DPTAC response to the Second Three Year Review of
the Department for Transport’s Road Safety Strategy

36.     The strategy states that “if the pilot schemes are successful, we
        foresee home zones being introduced on a large scale” (page 55).
        The three year review explicitly links home zones with road safety
        objectives, and describes Home Zone initiatives as among
        “measures that have the potential to deliver noticeable
        improvements for vulnerable road users between now and 2010”
        (page 55).

37.     DPTAC is concerned that Home Zones as developed in this country
        might not fully take account of the needs of disabled people. We
        are therefore carrying out research on Design Standards for Home
        Zones15 with the objective of providing guidance on making Home
        Zones’ street environment safer, convenient, accessible, and
        acceptable and user friendly for all disabled people. We will make
        this work available to the Department for Transport as soon as it is
        completed and hope that it will inform future policy on Home Zones.
        We also commend work by the Guide Dogs for the Blind
        Association on the related concept of shared surfaces16.

Travel training

38.     One finding that has emerged from the research that the
        Department for Transport has conducted on road safety referred to
        above is that travel training has considerable potential to improve
        the road safety of disabled people. The road safety strategy in
        future needs to take account of this potential. The Mobility and
        Inclusion Unit is about to complete research on travel training17.
        The strategy should be reviewed in the light of this, to ensure that
        this evidence generates effective measures to reduce the risk of
        accidents to disabled people.
Highway construction


39.     At present, there is no legal requirement to carry out access audits
        to any new or major reconfiguration of highway developments, as
        there is, for example, to carry out a health and safety audit DPTAC
        recommends that consideration be given to requiring local


15
   Details at http://www.rmd.dft.gov.uk/project.asp?intProjectID=12145
16
   "Shared Surface Street Design: Guide Dogs Research Project" at
http://www.guidedogs.org.uk/sharedsurfaces
17
   “DDA Regulations Travel Instructions for Disabled People- Literature Review” at
http://www.rmd.dft.gov.uk/project.asp?intProjectID=11324
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DPTAC response to the Second Three Year Review of
the Department for Transport’s Road Safety Strategy

      authorities to carry out such audits as part of their Disability Equality
      Duty.

Conclusion


40.   DPTAC welcomes the opportunities presented by the consultation
      on the Road Safety Strategy. It is particularly timely given the
      deadlines of the Disability Equality Duty. We recommend that
      there should be a clear and highlighted statement early in the road
      safety strategy recognising the commitment to reduce road
      accidents involving disabled people, and strategies throughout it to
      meet that commitment.


Grahame Lawson, Chair of Personal Mobility and Local Authority Working
Group, 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: 28 November 2006




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