Memorandum by National Federation of the
Blind of the United Kingdom (IT 25)
"A NEW DEAL FOR TRANSPORTBETTER
THE GOVERNMENT'S WHITE PAPER ON THE FUTURE OF TRANSPORT
1.1 The National Federation of the Blind of
the United Kingdom (NFB) is the largest campaigning organisation
of blind, deafblind and partially sighted people in the United
1.2 The Environment Committee of the National
Federation are pleased to respond on all matters relating to access,
mobility, transportation and the built environment as it affects
blind, deafblind and partially sighted people.
1.3 The National Federation would like to take
this opportunity to congratulate the authors of this document
upon their clarity and presentation.
1.4 There are nearly 2 million blind, deafblind
and partially sighted people known to organisations' representing
visually impaired people. However, the true figure is much larger,
many people deny that their sight is failing for fear of losing
their employment; others have age-related problems where sight
loss is but one of a series of afflictions. With an aging population,
set by 2030 to outnumber the working population, these figures
will grow to alarming proportions. Unless the nettle of provision
of integrated transport and an accessible environment is grasped
now; many elderly and disabled people will be condemned to social
1.5 "New Deal" attempts to address
the problems, however, the safe and accessible solutions will
prove very costlycheaper options will lead to social exclusion.
2. A NEW DEAL
2.1 Better places to live
Revision and strengthening of planning laws
is essential. Stronger measures and financial incentives to reuse
existing land within towns and cities must be encouraged and promoted.
The use of green field sites creates pressures upon the local
infrastructure which have led to an imbalance in general provision.
The future designs of housing must reflect the needs to which
the housing must be put. Peaceful and tranquil, easy to access
areas for disabled and elderly people. Family units which can
provide for growing families, to meet their needs within the built
environment for example, close to schools. Construction of parks
to provide "green lungs", leisure areas, tree-lined
streets to improve air quality and amenities. The use of water
to provide for cooling of air in the summer heat and interest
features in winter.
2.2 Local transport plans
Are but the building blocks to a national strategy,
which must be the aim. The creation of new powers for local authorities
must be properly funded. The commitment that the criteria of how
local powers will be used is welcome. They should however complement
a county-wide, regional and national strategy. Local transport
plans should create an inclusive system of transport and be complementary
one to another.
2.2.1 The key for blind, deafblind and partially
sighted people is better accessible information, coupled with
physical assistance at all interchanges. Both buildings, vehicles
and all interchanges should reflect fully the requirements of
Part III of the Disability Discrimination Act 1995.
2.2.2 Introduction of tolls and charges
Disabled drivers, those with an Orange/EU Badge
and currently in receipt of a "free" tax disc should
be permitted an exemption from all tolls and charges. This exemption,
should also apply to vehicles used for the conveyance of disabled
people. Even with accessible transport, not all disabled people
will be able to use it. Special arrangements will have to be made
for adequate disabled parking spaces close to town and city centres,
so that disabled people can get from their car to do their shopping,
business or leisure pursuits. A statutory requirement to provide
such parking, may well be necessary. Tolls and charges can blight
tourism; for example in the West Country the failure to continue
with the road programme will reduce business prospects and drive
away visitors, further worsening employment prospects within the
2.2.3 Rural areaslack of transport services
It will never be viable to run transport services
in rural and out-of-town areas. Consequently, the car will remain
the only option for many people. To prevent that use would be
to socially exclude them. For blind, deafblind and partially sighted
people this is also true. They often live in areas which have
cheaper housing, because they rely upon benefits. Without car
or taxi transport they would become prisoners, excluded from society.
Special arrangements will be needed to help
rural areas and out-of-town areas. This could be done by special
tax discs, special tax exemptions for using environmentally friendly
2.3 More and better buses
There should be a Strategic Bus Authority (SBA)
to oversee the national provision of bus transport and ensure
a national coverage. This authority would also compliment the
Strategic Rail Authority (SRA).
2.3.1 The SBA could enforce higher standards
both of provision and good practice, as well as oversee the introduction
of the new style DDA accessible buses.
2.3.2 Quality partnerships should not be unusual
and co-operation between transport providers and local highway
authorities should be encouraged in all areas. Placing Quality
Partnerships on a statutory basis will ensure that the standards
of requirement of provision of accessible vehicles are met and
rapidly implemented. That a national standard of awareness training
for staff is developed which will benefit not only disabled people
but all the travelling public as well.
2.3.3 The Disability Discrimination Act 1995
regulations for buses and coaches is one area which should not
be relaxed for any reason. It will result in higher quality buses
and this will benefit all the travelling public, not just the
2.3.4 Concessionary fares for elderly and disabled
people are essential. There is a strong link between aging and
disability. However for younger disabled people the problems of
affordability of public transport are still a major concern, as
many are unemployed and totally reliant upon benefits. The DLA
Mobility Allowance does not reflect the true costs of travel,
even at a concessionary rate. The RNIB Needs Survey showed that
only one in four blind people of working age was in employment.
2.3.5 Quality Contracts should establish a criteria
which would reflect best practice in the United Kingdom. The National
Federation look forward to consultation on this criteria, to reflect
passenger needs, especially for the blind, deafblind and partially
2.4 Better railway trains
The new SRA will enable integration across the
whole railway network, as well as promoting good practice and
improved passenger and goods vehicles. The SRA can also assist
in attracting inward investment in better designs of track, signalling
and buildings, which will lead to a higher standard of public
safety, punctuality and public confidence in the system. Likewise
SRA could enforce the introduction of "affordable fares"
more effectively upon train operating companies, which will be
the key to greater public use.
2.4.1 Fares and ticketing
The use of area or issue of travel cards brings
many benefits to rail travellers, especially those who are blind,
deafblind or partially sighted. The Disabled Persons Railcard
offers many benefits to disabled people throughout the railway
network, the exception, so far, being The Heathrow Express Link,
which refuses to accept this card. The drawbacks with the Card
are that it can only be purchased from the Centre at Newcastle,
unlike other nationally accepted discount cards.
2.4.2 Physical interchanges between bus and rail
Local Transport Plans should consider interchanges
and the requirements of disabled people to use them. It would
be useful to establish a national standard of requirements to
meet disabled and elderly peoples needsremember by 2030
the population of retired people will outnumber those in work
by three to one. The National Federation would be happy to assist
in the formulation of such standards.
2.4.3 Timetables, co-ordination and stability
In requiring a standard electronic format for
information, it must be understood, that such systems must be
easily convertible into accessible formats both for the blind,
deafblind and partially sighted.
2.4.4 Passenger information
Clear, comprehensive and up to date information
is essential for all. The blind, deafblind and partially sighted
cannot generally access the current mediums of information so
it is vital that they can receive it in an accessible medium for
example lack of audible announcements at stations and on trains.
These are simple to overcome, for the deaf the provision of soundloops
would be a cheap and simple method of enabling many of them to
It should be possible to provide a national
transport information service, which could be available as part
of the new digital television revolution. The setting up of a
National Special Needs Service would enable disabled people to
obtain information on journeys and accessible routes and book
their assistance. The loss of BR databases of station information
has resulted in a fragmented system, with little hard information
on access to and from station. An example of good practice has
been Kent County Council's "Out and About" Guide
for disabled people, which gives information about access to stations
and bus transport in all of its local authority areas, together
with information on specialist support and help services and taxis.
2.5 Better safety and security
Many pedestrians, especially the blind, deafblind
and partially sighted are intimidated by the close proximity of
cyclists who have now been permitted to use footways, as segregated
only by a white line or unsegregated shared facilities. Ensuring
a physical separation between cyclist and pedestrians and cyclists
and other road users should be the "norm".
2.5.1 The reduction in staffing levels at Railway
and bus stations has resulted in the general public failing to
use these facilities out-of-hours. All Railway and Bus Stations
should be patrolled. The physical presence of station and bus
staff prevents crime and gives confidence to the public to use
systems. It will also create new employment opportunities which
is part of this Government's election manifesto.
2.5.2 Improvements to the lighting and security
of the built environment is essential. Areas which are well lit
and patrolled have found reductions in crime and vandalism.
2.6 Better Taxis
The National Federation welcomes the proposed
new Regulations under the DDA 1995 which will make all taxis accessible
to all disabled people. However, the National Federation are concerned
to ensure that the excuse that a guide dog is an "unclean
animal", will not be grounds for refusal to carry a blind
or deafblind person. In many areas of the country taxi companies
are run by muslims or employ muslim drivers and this has proved
a major obstacle.
2.6.1 The vast majority of blind and deafblind
people use a taxi on a regular basis to get around. Police Crime
Prevention advice has encouraged this because it is door-to-door,
safe and secure. Blind people are considered a "soft target"
for the opportunist thief, because they are not aware of what
is around them.
2.6.2 A recent survey of our membership found
that well over 65 per cent use taxis on a regular basis as the
main source of transport. One hundred per cent indicated that
if they could afford the cost, they would always use a taxi. Since
the introduction of shared facilities for cycles, 80 per cent
have begun to use taxis because they fear an accident with pedal
cyclists on the footway. Ninety per cent admit that they find
the cost of a taxi exceeds their mobility budget and benefits
should reflect fully the true costs of daily travel by
2.6.3 In many Scandinavian countries, according
to a recent European Blind Union Survey (EBU) give blind, deafblind
people between £3,200 and £5,000 a year tax free to
pay for taxi fares to keep them off the footways. In the United
Kingdom the average return taxi fare is £10, thus blind and
deafblind people would need £5,200 per annum to cover such
3. A MORE INCLUSIVE
The Disability Discrimination Act 1995 has pointed
the way. The implications of Part III of the DDA 1995 have as
yet to be fully appreciated by Government and Local Authorities,
as well as Transport Providers. The reality is that:
all future planning decisions must
take full account of the needs of all disabled people;
all local authority and national
cycle strategies must take full account of Part III of
the DDA and of the NDC letter relating to "footways being
facilities"; to ensure absolute safety and segregation for
blind, deafblind and partially sighted people from all forms of
vehicular traffic on the footway (including cycles, skate boards
and roller blades);
making the built environment and
all facilities totally accessible to all disabled people.
If this is not achieved, whatever the cost,
then disabled people will remain socially excluded. The ripple
effect of this failure will contribute to a colossal increase
in social security benefits, social service support and health
4. EVERYONE DOING
The National Federation welcomes the idea of
partnerships and individual responsibility and will contribute
to such consultations provided and the outcomes continue to benefit
all disabled people. The National Federation expects results and
a very swift implementation of Part III of the DDA by all Local
Authorities. It expects additional and proper levels of funding.
It would be willing to assist Government as a watchdog.
5. SUSTAINABLE TRANSPORT
5.1 Better Health
Most blind, deafblind and partially sighted
people would prefer to walk, if they could. Exercise is beneficial
to good health and for those living alone, association with others
is essential for good mental health. Any policy which reduces
this ability would be seen as discriminatory, leading to social
exclusion and placing greater, rather than lesser costs upon the
5.2 More jobs and a stronger economy
The National Federation see this as an opportunity
to reverse the trend to destaff railway stations and to reduce
the overall staffing levels on buses. By increasing enforcement
officers, police, construction of new DDA bus, train and taxi
vehicles and making the built environment accessible will in itself
create many new job opportunities.
5.3 Silent vehicles
Blind, deafblind and partially sighted people
are concerned at reports of electrically powered vehicles, solar
cars, silent gas vehicles, pedal cycles. All such vehicles are
silent and would be difficult for visually impaired people to
detect. It will be necessary for such vehicles to have a "buzz"
which is easily detectable from other traffic noise to indicate
5.4 Pedestrian environment
Illustrated by the National Federation's video
"Get Streetwise!", which can be obtained from
our Head Office and lasts for 11 minutes, it is a must to see
what problems the blind, deafblind and partially sighted face
when walking on our pavements. The slogan "Pavements are
for People!" says it all. Pedestrians and cyclists do
not mix! When sighted people become concerned it is time to act.
The National Federation have supplied with this response Press
Cuttings covering a range of accidents "on the footway"
from a fatal to confrontation.
5.4.1 Within the Cycle Strategy, no mention
is made of the effects of the Governments Walking Policy, or Part
III of the Disability Discrimination Act 1995 (DDA1995)the
Governments intention to challenge policies which contribute to
"social exclusion". The use of "shared facilities",
in any form, will contribute to "social exclusion" of
disabled people, especially the blind; as well as elderly people
who will "fear" to go out.
5.4.2 The Environment Committee of the National
Federation of the Blind of the United Kingdom (NFB), have compiled
from newspaper cuttings and information supplied by its membership,
statistics relating to accidents between cyclists and pedestrians
on the footway.
The following, which covers England only, deals
with the period from January 1996 to date:
Fatal accidents1 (Tyler case Southend)
Serious accidents426 (those that require
Non serious/incidents860 (these range
from near misses to knocks)
These figures form the "tip of the iceberg".
Based upon them the National Federation have called for national
statistics to be kept by the police and DETR. Existing criteria
for Safety Audits are flawed, without accurate statistics, they
are based upon misleading assumptions.
5.4.3 Sussex Police Authority in a July 1998
statement, listed the third most serious public concern, as "confrontation
with pedal cyclists riding on the footway". The public need
to have a safe environment to walk in, "pavements are for
people to walk" not to cycle upon. Cycles are vehicles and
should be segregated from pedestrians at all times.
5.4.4 After the case of R v Garner (Worthing)
many Crown Court Judges are currently critical of the way in which
advice has been given by DETR to Highway Authorities. They view
"unsegregated pavement shared facilities" as "inherently
dangerous, especially for the blind." They are also concerned,
that by using part of the footway to create a cycle track, the
DETR and the Local Highway Authorities are sending out the "wrong
message" to cyclists about riding on the footway.
5.4.5 Section 329 of the Highways Act 1980,
gives a single definition of a cycle track; it can be either a
separate highway or part of a highway. There is no distinction
between those constructed from new and those converted from all
or part of the footway. This definition needs to be redefined
more accurately. It is confusing and has led to many incorrect
and dangerous assumptions by Highway Authorities. This is the
real cause of the problem and one that needs to be put right at
a national level.
5.4.6 The "broadbrush" nature of the
DETR Advice Notes has merely led to further costly confusion.
5.4.7 Amendments to Road Traffic Law
The police, through the Traffic Committee of
ACPO have indicated that they are unwilling to get involved in
policing cycle tracks, until such time as they are given additional
funding and the law is amended in various areas to bring in:
Licensing of all cycles.
3rd Party Insurance for all cyclists.
The offence of failing to stop and
report accidents must be extended to include cyclists.
5.4.8 Our concern is that a decision resulting
from the several civil actions, currently pending, may make the
use of such "shared facilities" illegal. With all the
resulting problems and cost for local highway authorities, of
removing them, DETR are aware that the National Organisations
representing blind people, may well bring a "friendly action",
under the DDA1995, to establish in Law the validity of Part III
as it affects "shared facilities". What is at stake,
is legally what is considered to be "reasonable".
5.4.9 The outcome of the recent Public Enquiry
in Coventry, gives a lead. Local Highway Authorities, as a result
of this ruling, must ensure that blind, deafblind and partially
sighted people are not placed in "confrontation with cyclists
and are safeguarded".
5.4.10 The use of pavement "shared facilities"
as described in Local Transport Note 2/86, either "segregated
by a delineator strip" or "unsegregated", were
seen as presenting a danger to blind, deafblind and partially
sighted people. DETR are currently reviewing this Note.
5.4.11 The Raj Kumar letter sent by the National
Disability Council, was in response to a question relating to
a definition of "a pavement, footway or footpath; being
a `facility' designed to segregate pedestrians from other forms
of vehicular traffic" and confirmed that a pavement,
footway or footpath, was indeed a facility under Part III of the
5.4.12 The Shared Facilities Policy of the Joint
Committee for Blind and Partially Sighted People of the United
Kingdom (JCMB) has been amended. It now contains a Resolution
which is supported by all its constituent organisations calling
for the abolition of "shared facilities". This document
and its Resolution can be obtained from the Joint Mobility Unit,
RNIB 224 Great Portland Street, London WIN 6AA.
5.4.13 The Pedestrians Association and the Non
Motorised Policy Group, which includes Sustrans', are now calling
for the removal of "shared facilities". Sustrans' has
produced several leaflets relating to the relationships between
pedestrians and cyclists and cyclists and disabled people. However,
they are misleading and do not fully reflect the implications
of Part III of the DDA1995, because Sustrans' does not agree with
them and views the Act as a serious threat to the National Cycle
5.4.14 There are over 8 million disabled people
in the UK, who have difficulty getting about. 0.5 million are
in wheelchairs. The RNIB's Needs Survey currently states that
there are in excess of 1.6 million visually impaired people, known
to the RNIB and other Service Providers. However, a more realistic
figure would be in excess of 2 million blind, deafblind and partially
sighted people suffering from age related problems who do not
bother to include "blindness" within their list of problemsthey
all deserve a safe pedestrian environment.
5.4.15 Many blind, deafblind and partially people
are now "fearful" to go out alone. Some who have been
involved in accidents with cyclists on the footway, now refuse
to go out, because they are traumatised. The cost of keeping single
blind people in their own homes is £10,000 per annum, plus
additional support costs borne by local and national health bodies.
Such policies can be easily proved to contribute to "social
5.4.16 The vast majority of blind, deafblind
and partially sighted people and for that matter disabled and
elderly people in general would prefer to be able to walk/move
safely and freely on the footway, without fear of being "brushed"
by cyclists. Cyclists do not stop for pedestrians or get off their
cycles, they normally "push on" through. With the predicted
increase in pedestrians using footways this is a real hazard.
6. TECHNOLOGY TAKING
Whilst new technological advances can help,
the National Federation feel that many simple improvements can
be just as, if not more, cost effective. Many organisations "for"
blind people will be offering and promoting the use of technology,
which they are prepared to sell to transport providers. For example
RNIB "REACT", which is a wayfinding scheme. Many blind,
deafblind and partially sighted people could not afford to purchase
or rent the controllers, let alone be able to use them. The fatal
flaw is that there is no substitute for physical assistance, to
carry bags, answer questions or ensure that you are put in the
right carriage/train or on the right bus. Advice should be taken
from organisations "of" disabled peoplethe consumerson
what technology is appropriate rather than waste scant resources
on expensive gadgets which we don't need.
7. MAKING A
The National Federation welcomes the Integrated
Transport Commission who will oversee and monitor the new indicators
to see how its policies and programmes are affecting different
groups. The National Federation would like to see an indicator
relating to Mobility Training of blind, deafblind and partially
sighted people included. Likewise an indicator for abolition of
pavement shared facilities and construction of new footways in
8. MAKING IT
The National Federation welcomes the proposals
to make it easier to walk and proposals set out for increasing
the priority to be given to walking. Likewise the removal of street
furniture and clutter, such as "A" Boards. There is
a "conflict of interest" for local authorities, between
the profits generated by the sale of licences for such footway
use and the needs to provide a safe accessible environment for
all. This area needs to be looked at closely. The need for safety
provisions relating to extensions to shops, restaurants, cafes
needs to be considered. A blind person blundering into a crowded
seating area outside a restaurant can easily cause a fatal accident,
as well as injure themselves. All extension sites should be fenced
in and local authorities given powers to enforce such prudent
8.1 Local Authorities should be encouraged to
make all existing pedestrian crossings both audible and tactile.
Also to introduce tactile guidance and information on all pedestrian
8.2 The effects of Part III of the DDA1995 must
be fully enforced as a footway, footpath, pavement and pedestrian
area is now deemed a "facility" and must be made fully
accessible and safe to all disabled people, including the blind.
8.3 The National Walking Strategy presents an
opportunity to return pavements to pedestrians and to encourage
all Local Authorities to construct footways where they currently
do not exist.
9. MAKING IT
The National Federation and the RNIB are both
very concerned that by allowing cyclists to share footways, the
wrong message has been sent out to cyclists. They seek to ensure
that such shared facilities will be abolished. This is particularly
important in relation to safe routes to school, where many inexperienced
school children could be the cause of very serious accidents and
by advocating the use of pavements the Government is aiding and
abetting the commission of an offence, which sets a very poor
example to young people.
9.1 By constructing dedicated cycleways in the
carriageway, which segregate both pedestrians and other motor
vehicles from cyclists. The design of these cycleways should be
sufficiently wide to permit overtaking and the use by tricycles.
This latter vehicle seems currently to have escaped the planners,
but in reality will become more common as time and other policies
within the White Paper begin to take effect.
10. MAKING IT
10.1 The National Federation welcomes the new
Commission and expects it to represent the needs of all passengers
including disabled passengers, in addition it would expect representation
on the Commission from the Disabled Persons Transport Advisory
Committee and of organisations "of" Disabled People.
10.2 The National Federation looks forward to
establishing good relations with the Commission and hopes that
they will permit them to consult with them and advise them on
matters affecting blind, deafblind and partially sighted people.
11. FUNDING OF
11.1 Clearly transport will require funding
from the tax payer to make it affordable for all. However, local
businesses may wish to join in a partnership with local transport
providers to enable workers to travel, shoppers to access town
shopping centres and enjoy leisure amenities. Footwear manufacturers
could sponsor awards for good pedestrian design. The need for
dial-a-ride and similar community services will reduce as buses
become more accessible and the funding can be moved to compliment
the drive for more accessible public transport.
12. REDUCING SOCIAL
12.1 For blind, deafblind and partially sighted
people, the barriers to walking created by Cycle Policy is an
example of a Policy directly excluding disabled people. Not being
able to access information about buses and trains further contributes
to exclusion. The failure of local authorities to properly consult
with or provide material in accessible media is yet another example
12.2 There is need for statutory compliance
by all local authorities to meet all disabled peoples needs and
provision. The excuse that they cannot afford the cost should
be subject to punitive fines on the authority concerned. Only
by such measures will disabled and elderly people see change within
their community and cease to be excluded. Experience has shown
that there is no other option to force change.
13. BETTER ENFORCEMENT
Unless the suggestions set out in paragraph
5.4.7 are implemented it will be difficult to enforce many of
the protections that pedestrians are now seeking. The National
Federation are aware that many offences which impact upon blind,
deafblind and partially sighted people are considered minor by
police . . . this attitude needs to be changed.
14. WORKING TO
The National Federation is prepared to work
both with Government, Local Government and the transport providers
to achieve the objectives of New Deal.
6 In Switzerland there is a simple system of licensing
of cycles which is both effective and cost efficient. Modern technology
will permit forms of electronic licensing using barcodes. Back