RNIB response to the Department for Transport’s Transport Accessibility Action Plan

1. Introduction

The Royal National Institute of Blind People (RNIB) promotes the interests of blind and partially sighted people and those at risk of sight loss, across the UK. We are led by a trustee board with over 80 per cent blind and partially sighted people.We have around 30,000 people in our RNIB Connect community, the vast majority of whom have sight loss. Our ambition is to change the world for those living with, and at risk of, sight loss. We take action to prevent avoidable sight loss, provide support and services to enable independence and campaign to create a fully inclusive society.

In this response you will find:

  • Information about how we gathered our evidence and who we worked with
  • A brief summary of our response
  • Our response to your questions
  • Our response to your actions
  • A list of all of the recommendations we make (which can also be found within the text)

2. Our evidence

We have supplemented our extensive knowledge gained through transport policy and campaigns work by holding dedicated workshops and a survey in response to this consultation.

Survey

We ran a short survey for three weeks in October and November which 636 blind and partially sighted people completed from across the UK (90 per cent of whom are based in England). A summary of our findings will be sent with this response. Where we do not provide source material as footnotes or state the source within the text, the statistics we quote will be from this piece of research.

Workshops

We held five workshops with blind and partially sighted people in London, Birmingham, Bristol, Manchester and Newcastle. Over 80 people attended our workshops.

Quotes and examples

Unless otherwise stated the anonymous examples and quotes we use in this report are from our dedicated survey and workshops.

Working in partnership

We have worked in partnership with other sight loss organisations to hold our workshops and promote our survey. We have held workshops in partnership with Thomas Pocklington Trust, Birmingham Sight Loss Council, Newcastle Vision Support and North East Action on Transport. We have also engaged with Guide Dogs as part of our response.

3. Summary

3.1What’s missing from the Action Plan?

Walking

We are disappointed that so little is included in this Action Plan in relation to walking and making walking easier for disabled people, and blind and partially sighted people in particular. We have included in our response detailed evidence of how street obstacles such as cars parked on pavements and A-boards continue to cause accidents and difficulties for pedestrians with sight loss. We also include evidence of how cycling infrastructure such as shared cycle routes and shared space in general are making parts of the country ‘no go’ areas for blind and partially sighted people. Walking and the rights of disabled pedestrians must be urgently considered not only in this action plan but more widely in guidance and regulations.

Electric vehicles

We are also surprised to see the omission of electric vehicles from the Action Plan. As these vehicles can be silent, they pose a particular risk to people with sight loss. Although we wholeheartedly support cleaner vehicles to help the environment these vehicles need to be safe for our roads. As it is currently EU regulations which govern electric vehicles and the sound they make, it is essential that in light of Brexit the UK government introduces its own legislation that ensures manufacturers provide sensible noise options for these vehicles. We recommend that these vehicles produce a sound similar to other vehicles which cannot be switched off by the vehicle owner.

Recommendations:

DfT must ensure that UK legislation makes all new electric vehicles have audible sounds which cannot be overridden or switched off by the driver;

And older cars which are currently silent must have audible devices which cannot be switched off retrofitted.

Local authorities must ensure that electric vehicle infrastructure does not become an obstacle for people with sight loss.

Driverless Cars

It is vital that the Automated and Driverless Vehicles Bill and related regulations, guidance and policies take into account blind and partially sighted people. If designed with the sight loss community in mind, driverless vehicles could bring independence to many. It is clear from our research and workshops that being unable to drive is the single biggest barrier to spontaneous transport that blind and partially sighted people face. Yet this technology could transform the lives of people with sight loss completely, but only if their use of these vehicles is planned from the start.

As pedestrians however, driverless vehicles pose a couple of risks: firstly that they are electric vehicles and so are currently silent (please see our response above in terms of silent vehicles); also, it is vital that the onboard computer systems are trialed with blind and partially sighted people, so that the vehicle’s sensors can respond to all kinds of pedestrians and pedestrians’ behaviour.

Recommendations:

DfT and manufacturers must ensure that the sight loss community is involved in the development and testing of driverless vehicles.

3.2Summary of our findings

There are currently estimated to be more than 2 million people living in the UK with sight loss. This figure is set to double by 2050. Of the current 2 million, 360,000 are registered as either severely sight impaired or sight impaired (blind or partially sighted.) [[1]]

Access to transport is consistently cited as a top concern for blind and partially sighted people; forty percent of those we surveyed through our ‘My Voice’ survey in 2015 told us they were unable to make all of the journeys they wanted to. Over half told us that they needed support to get out of the house. [[2]]

We welcome that DfT are focusing on spontaneous travel as seventy nine percent of people with sight loss told us that they could not travel whenever or wherever they liked. Not being able to rely on using a timetable and other transport information was one of the biggest barriers they faced, along with not being able to rely on ticket offices to be open and staffed.

We also welcome the interest from DfT in ticketing and ticket machines as only six percent of people with sight loss were able to use a ticket machine without difficulty. Over half said it was impossible for them to use a ticket machine, with thirty percent finding it difficult to use them. New, more accessible ways of providing tickets need to be developed as a priority.

Our survey and workshops have shown that blind and partially sighted people rely on transport staff for support and to enable them to travel. The way this assistance is provided and the understanding of the staff providing it is vital for it to work properly. With a trend of cutting staff from ticket offices being rolled out across the country, many passengers are concerned that they are not able to receive the level of support they need.

3.3Our recommendations

Throughout our response we make recommendations in response to the evidence we have or the actions outlined in the action plan. All of the actions are contained in Annex One of this response. But here is a summary of the recommendations we make, which cut across themes within the action plan.

The DfT Accessibility Action Plan must be updated to include detailed sections on:

  • Disabled pedestrians
  • Cycling infrastructure and its impact on blind and partially sighted people
  • The impact of shared space on disabled people
  • Silent vehicles

All local authority, civil service and transport staff (bus, coach, taxi, rail, tram, maritime and air) must receive disability equality and awareness training. The training should include:

  • Disabled people’s rights including reasonable adjustments (and relevant policies such as concessionary passes and disabled person’s rail card where applicable)
  • How to guide a person with sight loss
  • The different canes and their uses
  • Guide dog policies (and pet passports for air and maritime staff)
  • Understanding hidden impairments

DfT must urgently update both ‘Inclusive Mobility’ and tactile paving guidance,involving blind and partially sighted people in the process.

DfT must encourage transport providers, regulators and associations as well as local authorities to engage more meaningfully with disabled people, including blind and partially sighted people.

DfT should introduce and support, through funding, universal all-day free travel for blind and partially sighted people across England; as it is in London and Scotland.

The Bus Services Act 2017 regulations should be introduced swiftly and include:

  • Clarity that onboard information solutions mean audio and visual displays on buses available to all
  • Mandatory reporting on audio and visual announcement compliance on buses by bus operators

‘Access for All’ funding must be increased by the Government and used to tackle:

  • Tactile markings at stations
  • Modifications to platforms where possible, to alleviate the gap between the train and platform issue
  • Providing audio solutions for navigation around accessible toilets

DfT, working with the Rail Delivery Group, should ensure that more stations offer ‘turn-up-and-go’, and that adequate staffing levels must are provided.

The rights of disabled air and maritime passengers need to be protected in UK law in anticipation of Brexit.

DfT should monitor guide dog refusal prosecutions.

  • Guidance should be drafted by DfT for magistrates emphasising the importance of fines as a deterrent
  • Local authorities should be encouraged to prosecute when they receive a complaint of guide dog refusals

4. Response to questions

Question 1: Concessionary Bus Pass

We have carried out considerable work in relation to the concessionary bus pass over the last decade, supporting blind and partially sighted people facing difficulties using them and challenging local authorities wishing to restrict their use. Fourteen percent of calls relating to buses that we received to the RNIB ‘Campaigns Hotline’ in the last year related to difficulties with the concessionary bus pass. [[3]]

We completely support the concessionary bus pass and the independence it brings to blind and partially sighted people who rely on public transport. There are, however, problems with the way the bus pass is delivered by local authorities, which mean that people with sight loss are not able to benefit from the independence the pass brings. The issues most consistently raised by blind and partially sighted people with us are:

  • There is great inconsistency in the rules used by local authorities, which affect the times the pass can be used and the symbols used on the card
  • This means that neighbouring authorities that bus routes cut through often have different rules
  • Bus drivers and council staff are often unaware of the rules or confused by them - this leads to poor advice being given to customers
  • There is particular confusion and inconsistency in terms of companion bus passes and how they are issued, and their rules of use
  • We regularly receive complaints about bus drivers refusing bus passes when they should accept them - this leads to incidents of passengers being refused access to the bus and being left at the road side

Many local authorities over the last decade have made cuts to the usage policy for the pass meaning that it can only be used after 9:30am. We are opposed to this policy and have actively challenged local authorities who propose such changes. We have had some success in challenging restrictions but many local authorities now provide the minimum they are required to.

We have also worked with bus operators to increase awareness of the bus pass and its importance to blind and partially sighted people. We estimate that between 70 -80 per cent of the bus industry has now signed up to our Bus Charter [[4]], which includes pledging to ensure that bus drivers are aware of the relevant rules around concessionary bus passes. We still hear from bus operators that the information they receive from local authorities is not always clear and helpful.

The Government has targets around getting more disabled people into work and RNIB wants to see more blind and partially sighted people working and travelling independently, yet this policy undermines those goals. It is also a deterrent to spontaneous travel, which we expand upon in our response to question 8.

But even where councils have kept the all-day bus pass there is a real problem with bus services being cut, particularly early morning and later evening services, making it impossible for blind and partially sighted people to travel to work on public transport (which is the most cost-effective option for both the person and government, when the alternative is taxi travel either paid for privately or through Access To Work, or simply that a person with sight loss cannot work). Places most affected by these cuts to bus services are often rural where taxis are often in short supply (please see our response to action 5 on page 31).

Recommendations:
  • The Government should introduceuniversal, all-day, free travel for blind and partially sighted people across England, as currently exists in London and Scotland
  • DfT should guide local authorities to provide clear, universal rules for concessionary passes, especially in relation to companion passes
  • Local authorities must be encouraged and guided to carry out better Equality Impact Assessments when planning to cut bus services - especially those running before 9:30am and after 4:30pm
  • Training must be provided to bus drivers and local authority staff in relation to the rules around concessionary bus passes

Question 2: Information regarding disabled people’s rights to flying

We are concerned that if the EU regulations are not considered carefully before Brexit, and alternatives put in place, disabled people could lose their rights to air travel. It is vital that provisions against discrimination are added to UK law. In relation to this, the role of the Civil Aviation Authority (CAA) as enforcer must be strengthened. As the designated enforcement body, they are required to take measures necessary to ensure that the rights of disabled persons are respected. However, the CAA have informed us that they have no power to deal with individual complaints and that their powers only relate to “the collective interests of consumers”. This leaves a question mark over whether the UK has adequately enforced the regulation as it currently stands? Any new legislation must ensure that a proper enforcement body and/or powers are implemented.

In terms of the information available, it is on the whole easy to find via a Google search, or via airline and airport websites. Some websites provide slightly more comprehensive information than others. Similarly, some websites are easier to use and more accessible than others. It is, however, rather surprising that the Code of Practice on access to air travel is located in an archived part of the UK government website. This may give the wrong impression that the Code of Practice is out of date or no longer applicable.

There is, however, a lack of information in regards to traveling with a guide dog. This is of particular importance as we are aware of recent examples of guide dogs being forcibly removed from their owners when border officials are unsure about information held within the pet passport. The seizure of the dogs without notice can have a profound impact on a disabled person’s life and independent mobility, and it is not clear to RNIB that Border Control undertake any sort of risk assessment before quarantining the dog. In all of the cases that we are aware of, there was no risk to the public from the dog. It was usually a case of the paperwork having not been completed by the vet properly. Even where a slight risk exists, that needs to be weighed against the risk to a guide dog user of removal of the dog, and an informed decision made as to whether removal is necessary. It should always be a priority for guide dogs to be returned to their owners.

It is clear that the information for guide dog users is not adequate or accessible, and the DfT needs to give consideration to how this information (including information in the pet passport) can be improved and made accessible. There also needs to be a review of the use of these powers in respect of guide dogs by border control.

Our main concern is not about the information itself, but that the rights of disabled people outlined within the information are not adhered to by airports and airlines. When we receive complaints from blind and partially sighted people about air travel they tend to be in the following areas: