Memorandum submitted by the Disability
Rights Commission
INTRODUCTION
The DRC is delighted that London has successfully
bid to host the Olympic and Paralympic Games. We are also delighted
that both Games are to be organised by an Olympic Development
Authority (ODA) as this provides an opportunity for a joined-up
approach to access for disabled people, including in transport
through the establishment of an Olympic Transport Plan.
The 2012 Olympic Games provide an historic opportunity
to dismantle major transport barriers to disabled people's participation
in London (and beyond) life and make the capital and the UK more
widely a global standard bearer for the access and inclusion of
disabled people. The opportunity of a more inclusive London with
disabled people as visible, participatory citizens should be a
legacy of the 2012 games that we aim to secure.
With seven years to go before the Games come
to London it is vital to start planning for transport improvements
with immediate effect. We must also work to ensure that all disabled
people across Britain gain from 2012 by ensuring that all Olympic
venues/training facilities across the country are beacons of accessibility
(including travel to/from); making sure everyone can access and
enjoy the games; and seizing the opportunity to involve disabled
people at all levels.
Diversity and inclusion must be the defining
characteristics of the Games and the way they are promoted—including
in all transport aspects. In that way every disabled person will
get the message: you belong.
ACCESS, INVOLVEMENT
AND INCLUSION:
SETTING NEW
STANDARDS
A legacy of the 2012 Olympics must be state
of the art transport facilities and an infrastructure fully accessible
to all.
Accessible facilities
London's bid team pledged accessible and inclusive
design for all facilities at the 2012 Olympics. We applaud this
commitment and are anxious to view and comment on specific plans.
`Design for all' will involve ensuring that all facilities (both
Olympic and Paralympic) are accessible to, and usable by, as many
people as possible without the need for `special' adaptation or
specialised design (which can also result in additional costs
as the DRC has brought to the Transport Committee's attention
previously[3]).
For the 2012 Games the access requirements of paralympic athletes
and disabled spectators should be taken as the `norm' and be the
starting point for the design of all facilities and adaptations
made for all Olympic competitors. All too often it is the other
way round. London 2012 should feel confident of setting a new
standard.
The same principles must be applied to Olympic
venues outside London (eg sailing in the Solent) and include training
facilities across the country and must cover travel to and from
venues.
Future use of and access to facilities by disabled
Londoners and Britons also needs to be considered from the outset.
Similarly there could and should be major dividends
in relation to the wider infrastructure that will be put in place
to support the games—the transport network, additional accommodation
(including access to it) and the entire infrastructure.
An accessible transport network
It is to be welcomed that nine out of ten London
buses are now accessible to many disabled people and all will
be by the time of the Olympics. However, this does not necessarily
include provision for visual and audible announcements which will
be vital to ensuring sensory impaired people get around safely
and independently. This will, of course, also benefit the many
foreign visitors expected to visit London and other venues for
the Olympics.
The ODA's Olympic Transport Plan should be used
to initiate the delayed improvements to London's tube network.
The Jubilee Line and Docklands Light Railway are accessible when
lifts are in operation but the whole of Stratford station is currently
not accessible for example due to the lifts being out of order.
A disabled person wanting to travel to the Olympics or Paralympics
may want to travel from their nearest tube station—if they
cannot get to the platform their access will be inhibited. Just
40 of London Underground's 275 stations are currently step-free[4]
and those with steps include those nearest to venues for the 2012
Games (eg Lords cricket ground). It is important to note that
access defined as `step-free' by Transport for London (TfL) only
refers to step-free access to platforms and does not mean someone
can safely board/alight a train, nor does it address other important
access issues such as audible and visual announcements, or having
staff available to assist passengers.
TfL aims for 25% of tube stations to be step-free
by 2010 and 50% to have step-free access by 2015. The DRC believes
that securing the 2012 Games can now result in a more ambitious
attitude. An additional investment of £2-3 billion would
make 90% of London Underground stations accessible for disabled
people. At the very least the 50% target should be brought forward
to 2012 and should include wider accessibility provisions for
people with mobility impairments, sensory impairments and learning
disabilities. If this were to be achieved most disabled people
will be within reasonable proximity of an accessible tube station
in time for the Olympics. All 253 London Underground owned stations
are due to be refurbished and modernised over the next six years
and this represents another significant opportunity to maximise
accessibility features—at each and every station.
The DRC is concerned that funding will be diverted
from other transport projects in order to improve London transport
facilities at the detriment of citizens elsewhere and particularly
disabled people who may face a delay or postponement to much needed
transport improvements in other parts of the country.
Disabled people travelling from around the country
will be anxious to see much more rapid and radical action on railway
station accessibility. The National Audit Office's latest report
"Maintaining and improving Britain's railway stations"
echoes the DRC's longstanding concerns at how slow the rail industry
has been to respond to the requirements of Part 3 of the Disability
Discrimination Act (DDA) 1995 and in particular the October 2004
duties which mean that those who provide a service to the public
need to consider removing or adapting any physical barriers that
make it difficult for disabled people to receive a service. ATOC
and the SRA have stated that more than half of Britain's stations
are not fully accessible to disabled people—based on `step-free'
assumptions of what is accessible that ignore other accessibility
requirements (mentioned above). Step-free access also often means
using the different entrances to one station to get to each platform.
If you are relying on other forms of public transport to get to
and from the station this may well mean that the station is still
not actually accessible and a station labelled `step-free' can
even involve walking on a busy main road with infrequent pavements
to get from one platform to another[5]).
The DRC does not believe this would be an adequate situation for
disabled participants and visitors from Britain and abroad in
2012 and needs to be addressed in the Transport Plan.
In March 2005 the Department for Transport (DfT)
announced plans to spend £370 million on improving accessibility
at 285 stations over the next 10 years. The SRA, whose responsibility
in this area has now been transferred to DfT, has proposed a strategy
prioritising the available money at the busiest stations so that
over 80% of journeys would be from step-free stations by 2015.[6]
The DRC believes that this should also be brought forward to 2012
in the light of the successful bid and adapted to ensure a better
accessibility standard be used than `step-free'. This will need
to be combined with alternative accessible transport provision
to ensure disabled people can get to accessible stations from
which to make their onward journeys.
Discrimination by airlines and on ships is also
an issue for disabled people and could blight the experience of
disabled visitors to the 2012 Olympics. Airlines and shipping
are not covered by the DDA but there is evidence of discrimination
in both. Compliance with voluntary access standards has not worked.
Following the successful bid it is now the time for firmer action—we
reiterate our call for the Government to make regulations bringing
airlines and shipping under the DDA.
Enabling participation—disabled people as
spectators
The DRC is anxious to ensure that disabled people
from across Great Britain and abroad are able to enjoy the Olympics
and Paralympics. The DRC wishes to ask the ODA what concessions
will be available to disabled people wishing to attend the Olympics
and Paralympics—in transport services and beyond. We also
expect security will be a concern and would like to see access
and the security procedures working in tandem to ensure fluidity
of movement for all visitors and competitors.
The DRC wishes also to scrutinise access to
venues and provisions for spectator transport to ensure effective
arrangements are made for disabled motorists and blue badge holders
for example.
TRANSFORMING ATTITUDES
TOWARDS DISABLED
PEOPLE AND
PROMOTING INVOLVEMENT
A further legacy of the 2012 Games could be
a demonstration of the positive contribution disabled people make
to society and culture which would combat the exclusion and isolation
experienced by so many disabled people in Britain today and counteract
negative perceptions of disabled people as being `vulnerable'
or `dependent' for example. Disabled people need to be involved
at every level and the celebration of diversity must be a central
and defining aspect of branding for 2012 as a whole—including
in the design and implementation of the Transport Plan.
Part of transforming attitudes towards and improving
perceptions of disabled people in a transport context is the provision
of training to all transport staff—particularly those on
the front-line of service delivery and the DRC is keen to know
how TfL and others will be ensuring staff are trained in time
for the 2012 Games.
While it is vital that 2012 engages and inspires
disabled and non-disabled young people and leads to wider opportunities
to access and enjoy sport we do not want to see older disabled
people left out. The Commonwealth Games in Manchester had a major
volunteers programme as, it is expected, will the 2012 Olympics
and this would be another major opportunity to demonstrate diversity
to visitors whilst providing opportunities to disabled people
young and old to make a positive contribution to the games—but
only if the Transport Plan facilitates disabled people's access
to events/venues and their opportunities to volunteer at the Games.
Community involvement will clearly be crucial
to the success of the Olympics as a whole and we would particularly
highlight the importance of the ODA fully engaging with disabled
people and their organisations in the provision of the Transport
Plan. The DRC believes we need strategies for involving disabled
people in every level of the planning and delivery of all aspects
of the games.
REALISING A
VISION OF
MAKING INCLUSION
A REALITY
REQUIRES:
ODA to be given specific duties to promote disability
equality
The ODA will be covered by the general duty
to promote disability equality enshrined in the recent Disability
Discrimination Act 2005 (coming into force December 2006). However,
they will not be covered initially by the specific duty as they
are not on the list of bodies covered by the specific duty. This
is primarily because at the time the regulations were published
(September 2005) the ODA was not yet legally constituted. They
may be placed on the specific duty list at the first review (but
not before 2006) but there is no guarantee of this. If the ODA
is only covered by the general duty they will not have to produce
a Disability Equality Scheme and will be in the same grouping
as much smaller-effecting organisations, eg parish councils.
The DRC believes it is imperative that the ODA
is covered by the specific duty as soon as possible to ensure
that disabled people are treated as equal citizens and their needs
met in the same manner as others. The ODA must develop its Disability
Equality Scheme at an early stage so that it is central to its
delivery mechanisms and to ensure policies and strategies are
impact-assessed from the very start. If there is no requirement
to produce a Disability Equality Scheme the opportunities outlined
above may be squandered. One of the key requirements of a Disability
Equality Scheme is the effective involvement of disabled people
which would also boost disabled people's contribution to (and
stake in) the Games' success.
Accessibility experts on the ODA and LOGOC Boards
We welcome the fact that the National Paralympic
Committee of Great Britain and Northern Ireland will be represented
on the London Olympic Games Organising Committee (LOGOC). It is
also important for the ODA and LOGOC to recruit board members
who are experts in accessibility and inclusive design. This will
be a vital step to complement the involvement of disabled people
and their organisations in voluntary fora such as the Access Forum
which the DRC is aiming to participate in.
The DRC shares DPTAC's disappointment that the
reported five key objectives of the Olympic Transport Strategy
Team at TfL make no reference to accessibility, inclusion or disability.
We believe that a disabled person on the ODA board should lead
on access issues, supported by dedicated staff possessing the
skills, training and experience to ensure that all Olympic events
and associated services and information are delivered inclusively.
CONCLUSION
Disabled people have a huge amount to contribute
to the success of the 2012 Olympics and Paralympics. Their involvement
and inclusion at every level will assist in the achievement of
a successful Olympic Games—but is only possible if the transport
network is capable of delivering for disabled people in time.
All stand to gain if we plan effectively now for fully accessible
and inclusive facilities, transport and infrastructure. The DRC
looks forward to working with the ODA, LOGOC and stakeholders
to realise the vision of a truly inclusive and diverse Olympics
and hopes that the work of the Transport Committee will assist
in the delivery of the transport network we all require.
September 2005
3 In our evidence to the `Disabled People's Access
to Transport: A year's worth of improvements?' inquiry. Back
4
http://www.tfl.gov.uk/tfl/ph_underground.shtml Back
5
This is not hypothetical and is the situation at Taff's Well station
for example. Back
6
And here we re-iterate our concerns with using `step-free' as
a benchmark of accessibility. Back
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