The Birmingham Sight Loss Council’s local area response to the Department for Transport Draft Action Plan: Improving the travel experience for disabled passengers

Image shows the Birmingham Sight Loss Council attending Parliament to undertake a Touch Tour of both Houses.

Contents

Introduction......

Background......

Executive Summary......

Case Studies......

Knowledge base......

References......

Introduction

The Birmingham Sight Loss Council (BSLC) is made up of a group of volunteers living with sight loss locally. Our aim is to represent and act as a voice for blind and partially sighted people and encourage organisations to make reasonable adjustments that can improve the daily lives of people living with sight loss.

The BSLC are supported by Thomas Pocklington Trust (TPT), a registered charity which offers people who are blind or partially sighted support to lead an independent life. TPT are committed to increasing awareness and understanding of the needs of people with sight loss and to developing and implementing services, which meet their needs.

The Royal National Institute for the Blind’s (RNIB) Sight Loss Data Tool shows that over two million people in the UK are blind or partially sighted, with 27,570 living in Birmingham.

Background

The Birmingham Sight Loss Council was setup one year ago and in that short period of time we have started to make a real impact on our city. From asking the Midland Metro Alliance design team to considerinstalling tactile markers for the disabled boarding zone on platforms in the next phase of the tram extension; to assisting Transport for West Midlands with it’s initiative to make bus stop signage and information simpler to understand;and taking part in the new Transport for West Midlands disability awareness training video for bus drivers (providing the practical support behind the RNIB Bus Charter).

Members of the Council sit on a range ofsteering groups including Access Birmingham, Network Rail New Street Station Access Forum and the Women and Equalities Select Committee Oral Evidence Session on Disability and the Built Environment.The BSLCcontinue to ask for a more joined up approach with a cross-platform Accessible transport forum for our city, in order to ensure all progress and ideas reach all modes of transport and we leverage a more joined up approach. Our philosophy is simple; we can only build a better life for our community if we take an active role in shaping the future.

Images show use of tactile for disabled boarding zone at tram stops, low level bus number information on a bus stop and disability awareness filming with transport for West Midlands

Executive Summary

From gathering evidence via an online questionnaire (available at the following link )and detailed case studies, alongside our forum work, we have reviewed your draft action plan and sought to outline below the additional points that we would like to be included in your plans. Our points include the following:

  • Severely Sight Impaired individuals are currently entitled to Blue Badges on safety grounds, and this risk has risen with silent hybrid vehicles, not fallen;
  • We continue to call for national pavement parking legislation;
  • We suggest implementation of Rail and Air Assist customer satisfaction surveys and advocate the move to more “turn up and go” across the rail network;
  • We highlight that safety critical rail platform edge tactiles are being implemented at a much slower rate that step free access in our region;
  • We have provided evidence for guidance updates and insight for upcoming consultations including Audio Visual talking bus consultation; Grab Pole issues within PSVAR; and Terrorism Impact Bollards colour contrast bandings;
  • The impact that Local Government budget pressures is having on the infrastructure we rely on to get out and about including crossing control points and tactiles maintenance and delivery; and
  • Further points outlined in the following sections.

Buses

Whilst London has delivered 100% of its bus fleet with Next Stop Announcements, sadly our city has only reached about 10% installation. We also have the added complication that a good proportion of these new buses are failing to talk in the city centre (a GPS tracker issue, whichwe continue to raise and work with National Express West Midlands and Transport for West Midlands). We would very much like to be included in your consultation process around the national requirements for Bus Next Stop Announcements, and at a high level would like the following to be considered:

  • Inclusion of a speaker near the entry door and announcements of route and direction at the point of boarding (so far missing on many city roll outs including Birmingham);
  • Review of timings of Next Stop Announcements to give adequate preparation time to disembark (often only announcement is too close to arrival);
  • Improved issue reporting protocol and escalation path to the Department for Transport when system issues are not rectified.

As a community, we have campaigned long and hard for this vital piece of technology to be delivered country-wide, please can we have assurances that this further round of consultation will be swift and will the Secretary of State provide us with a clear timetable for nationwide delivery?

Image shows the interior of a new National Express Platinum bus with grab poles the same colour as the surroundings

The BSLC have also raised concerns to National Express West Midlands recently about new buses being rolled out with grab poles being the same colour as the floor and walls, therefore lacking high contrast visibility. Please could the Department for Transport review their Public Sector Vehicle Accessibility Regulation(PSVAR)[1]guidance wording on this point and ensure that no further operators follow this approach.We are concerned that we will cause harm to others when we fail to hold on at the crucial moment and fall onto other passengers.

When asked about features that should be included in a national standard for accessible bus travel, many respondents selected more than one option. An overview of the answers is below.

  • 100% said Sight Loss Awareness training for drivers
  • 91.7% said Colour Contrast grab rails.
  • 83.3% said Accessible position of Contactless Card Reader
  • 75% said Bus entrance platform lowered as standard
  • 66.7% said Contrasting interior (walls/ceiling/floors/seating)

Other suggestions included an Audio Announcement for when the bus pulls up to a stop as the doors open, announcing the bus number, or an announcement at the bus stop saying what the approaching bus’s number is as standard.

Disabled Bus Pass – Pre 09:30 Travel

Restricting access to the bus network at peak time outside of Londonimplies that the disabled world can start later in the day. We disagree with this assumption. Be it hospital appointments, Department of Work & Pensions appointments, not to mention Volunteering commitments (our main route back into the work place and giving back to society) can all start before we can use our bus pass.

91.7% of respondents said that the pre-9.30am bus pass for disabled people that is currently available in London should be made available in Birmingham also.

Train Stations

As the Netherlands report [2]completion of their station tactile roll out, in our region, that goal seems a very long way off indeed.

We note that you have used a good example from our region of a station, which has been made fully accessible - Acocks Green. The investment at Acocks Green included lift access and platform edge tactiles. We would like to share images of two further recent upgraded stations in our region at Stratford-Upon -Avon and Henley-In-Arden.

Images show Acocks Green station with platform edge tactiles and lifts, whilst Stratford Upon Avon and Henley in Arden have new lifts, but no platform edge tactiles.

Whilst lift access has been installed, platform edge tactiles have not. We are concerned that visually impaired passenger safety has been viewed as a low priority in our region with recent upgrade programs.

To give you an idea of how this is impacting on the ground, of the sample of West Midlands stations reviewed - 71% have step free access whilst only 45% have platform edge tactiles installed. As we expect the number of smaller stations with manned offices to decrease, our risk of injury continues to grow.

Out of the survey participants 83.3% are regular rail users. The most common railway stations used by the participants are Birmingham New Street, Birmingham Moor Street, Snow Hill, Sutton Coldfield and Selly Oak.

When asked about the accessibility of these stations, responses were mixed. Some rated New Street Station between 6-8 (out of 10, with 10 being the highest), whereas some said that it is very difficult to navigate due to being so open. The lowest rating in this question was 5 and the highest is 9; most responded with a 7.

Of the comments that accompanied this question, it was very clear that staff assistance or a manned office is vital at train stations.

One respondent commented:
“if someone is not at Selly Oak or University and I need to pick up tickets it is impossible to do using the computer screens and I have had to travel without tickets I have pre-booked because of this.”

Another station was rated 1 out of 10 for accessibility due to the lack of a manned office.

From these responses we feel that more still needs to be done on station accessibility however, further consultations are needed on a more local scale to ensure that smaller stations are adapted for accessibility, not just the larger, city centre stations. The main recommendation is to have more staff available to assist passengers, particularly at smaller stations.

Train Audio Visual Next Stop Announcements

We welcome the Department’s plan to deliver additional train carriages with Audio Visual announcements for West Midlands Trains by 2021.

Rail Passenger Assist

As in so many areas of transport accessibility, London has led the way. Transport for London has been successfully running “Turn up and Go” for some time, it works really well, including drivers taking proper responsibility for the passengeronce on board until handed over to station staff at your destination. We welcome Mersey Rail’s steps in this area and encourage all other train operating companies to follow this lead. Disabled passengers deserve to have the same right to spontaneous rail access the rail network.

We also think it is time for Passenger Assist services to be performance managed through customer surveys via text message after travelling. The visually impaired community continues to face barriers to Rail sector surveys as they are always handed out in on platforms in inaccessible formats. We need to start properly working out where the system works well, rewarding staff accordingly for their efforts, but also pin pointing the problem areas and working together to help solve them.The BSLC still hear far too many stories of visually impaired passengers left on trains, where train operators fail to communicate and on board teams do not correctly pass across to station staff. Train operating companies are quick to report how many access requests they have each year, but it is the success rate, confirmed by the disabled community that should be reported.

Disabled Railcard

We welcome the Department’s view that it will continue with the Disabled Rail discount scheme. The BSLC would however, like to see a move towards a single, globally recognised disabled identification scheme. Maintaining multiple forms of identification for multiple bodies is extremely time consuming for us all. Regarding the Disabled Adult Railcard, 66.7% of survey respondents have a railcard, with all of them using it when booking their own train tickets.

The main advantages of the railcard according to the survey responses are the ability to take a companion for support on a reduced fare and reduced fare for themselves also.

When asked about the impact there would be should they not be able to use the railcard, most said that they would not be able to go out as much. Responses included:
“I would have to travel less and resort to using the bus which is more difficult”
“Not being able to get out, leaving you socially isolated”
“Would not use the trains”

We feel from this evidence supplied, the Disabled Adult Railcard should be kept in its current guise.

Taxis and Private Hire Vehicles

We remain frustrated with the volume of refusals to carry Guide Dogs by this sector. The high volume of incidents is not reflected in the handful of annual prosecutions and license removals.

We welcome Guide Dogs call for more consistent disability awareness training across all local authorities.

Recent penalties delivered by the courts have been really low and license removals seem to be moving towards short term temporary suspensions, neither promoting true equality.

We would also request the Department should set up and maintain a national database for license holders who have been prosecuted or received suspensions to close the current loop hole of self-certification by drivers re-applying for licenses in different boroughs following a suspension.

The hardest part for licensing enforcement is the current lack of evidence submitted by Guide Dog owners. I think we are going to see an increase of Guide Dog owners wearing bodycams in future in order to deliver the change in mind set in certain cities across the country.

All drivers licensed in Birmingham undertake disability awareness training however it is unclear how much of this covers sight loss awareness.

In Birmingham, all training for taxi and private hire vehicles takes place face to face. This gives the Licensing Authority a sense of the people they are hiring. All knowledge, medical and occupational health checks are conducted in-house whereas this may not be the case for other Local Authorities. This means any medical exemption certificates are issued by the Licensing Authority themselves.

It is against the law for drivers to refuse an assistance dog unless they have a medical exemption certificate. Since April 2015, Birmingham City Council Licensing Authority has prosecuted or attempted to prosecute 15 drivers for refusing a Guide Dog.

Many drivers in Birmingham are licensed in other surrounding areas such as Wolverhampton, but if an offence has taken place in Birmingham, it is for Birmingham Licensing Authority to deal with.

We have also found there are a number of taxi and private hire companies that are using apps to manage orders, including Uber. A big issue we have found is that drivers can refuse a job through the app (possibly because the driver has a Guide Dog) and no action can be taken. This is still illegal but is currently not regulated.

Of the people surveyed, 66.7% have experienced poor service from a taxi company or driver related to their sight loss.

When asked what could improve their experiences, the most common answers were Sight Loss Awareness training for drivers and Accessible Apps for booking taxis (each receiving 83.3% of votes). The next common answer was more knowledge about reporting bad experiences to the relevant Licensing Authority with 66.7% of votes, and 33.3% of people said that assistance when hailing a cab would improve their experience.

25% of respondents mentioned issues with taxis refusing Guide Dogs showing that this is still a very relevant issue for Guide Dog owners in Birmingham.

Pedestrians

We support the campaigns of the National Organisations on shared spaces. The current trend by the Architect community to over ride functional safety requirements for the visually impaired community continues to need careful monitoring.

An example of a Shared Space in Birmingham City Centre is surrounding the grounds of St Philip’s Cathedral on Colmore Row. This is a very busy area that includes street parking, a taxi rank, bus stops and a one way system for cars. There are no accessible crossings for visually impaired people (crossings with an audio beep or a tactile spinning cone to identify that it is safe to cross) to exit the Square. A visually impaired person is at a very high risk if wanting to cross the road. We feel that the aesthetics of Shared Spaces are more important to Town Planners than the safety of blind and partially sighted people. We request a moratorium on Shared Space planning until Government Regulation is introduced that takes the safety of these people into consideration. At the very least, more consultations need to take place with local disabled people before plans are approved.