APPENDIX 33
Memorandum submitted by the Guide Dogs
for the Blind Association
INTRODUCTION
Guide Dogs for the Blind Association welcome
London's success in winning the bid to hold the 2012 Olympics.
Guide Dogs was pleased that London 2012 set
up a Disability Sub Group of which we were part and that they
have fully involved us in consultation to make sure that these
are the most successful Olympic Games. Guide Dogs looks forward
to remaining a member of the Disability Sub Group of London 2012
to make sure that these Games are as accessible as possible.
With seven years to go before the Games come
to London it is vital to start planning for transport improvements
with immediate effect. All travel routes to and from Olympic facilities
must be fully accessible; making sure everyone can access and
enjoy the games; and seizing the opportunity to involve disabled
people at all levels. A transport system fully accessible for
disabled people would be a fitting legacy of the Olympics.
TRANSPORT
Requirement to Consult
Guide Dogs are disappointed that there is no
requirement to consult the Government's Disabled Persons Transport
Advisory Committee (DPTAC) or other disability organisations about
the Olympic Transport Plan. With London hosting the Paralympics
it is essential that all transport is accessible. Such a requirement
would also be consistent with the requirement on the Mayor in
the GLA Act 2000 to produce a timetabled Accessibility Plan for
disabled people in consultation with DPTAC and other disability
organisations. Guide Dogs believe that London's transport system
has become more accessible as a result. It is therefore disappointing
that the 5 key objectives for the Olympic Transport Strategy Team
at TfL do not refer to accessibility for disabled people or inclusion
but this highlights the need for the consultation that we ask
for.
The Olympic Delivery Authority will be covered
by the general duty to promote disability equality enshrined in
the recent Disability Discrimination Act 2005 which will come
into force in 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
by the time the DED regulations are published in September ODA
will not yet be legally constituted. They may be placed on the
specific duty list at the first review (but not before 2006) and
we have no guarantee of this. If ODA is only covered by the general
duty they will not have to produce a disability equality scheme
and will be in the same bracket as organisations like parish councils.
Guide Dogs believe that it is imperative that
the Olympic Delivery Authority is covered by the specific duty
as soon as possible and this must be provided for in the Bill.
The Authority must develop its Disability Equality Scheme at an
early stage so that it is central to their delivery mechanisms
and so that policies and strategies are impact assessed from the
beginning. If there is no requirement to produce a Disability
Equality Scheme we fear the huge opportunities outlined above
could be squandered. One of the key requirements of a Disability
Equality Scheme is effective involvement of disabled people and
so this would boost disabled people's contribution to and stake
in making the transport related to the Game fully accessible.
TRAFFIC REGULATION
ORDERS
Clause 12 of the London Olympics Bill provides
for the introduction of traffic regulation orders. We hope that
in introducing these, the Authority will consider the needs of
both disabled pedestrians and Blue Badge Holders.
ACCESSIBLE BUSES
Guide Dogs welcome the fact that all buses in
London will comply with the Bus and Coach Regulations introduced
under the Disability Discrimination Act prior to both the 2017
deadline and the 2012 Olympics. However, we are disappointed that
these regulations don't include a requirement for visual and audible
announcements. However, the recent decision of Transport for London
to provide visual and audible announcements on all buses by 2009
is welcome and we hope that other parts of the Country will follow
London's good example and visual and audible announcements will
be available on all buses before 2012.
Visually impaired people using buses rely on
bus drivers to tell them when they have arrived at their stop
and some drivers are more helpful than others. A visually impaired
passenger who gets off at the wrong stop is left in a very vulnerable
position that can lead them to be misled or preyed upon. Mr Mainwaring
was attacked after becoming lost in Manchester after getting on
the wrong bus. The gang had offered to help him but instead kicked
and punched him and robbed him of his mobile phone, cash and credit
card. If there had been audible announcements on buses Mr Mainwairing
would have realised that he was on the wrong bus a lot earlier
and avoided being attacked.
LONDON UNDERGROUND
The ODA's Olympic Transport Plan should be used
to initiate the delayed improvements to London's tube network.
The Jubilee Line Extension is meant to be accessible but due to
the lack of consultation the Jubilee Line Extension was not designed
in a way which makes it accessible to blind and partially sighted
people. It is therefore essential that designers are professionally
trained in accessibility issues and RNIB's Joint Mobility Unit
has been funded to draw up training materials in partnership with
RIBA, RICS and others. 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[14]14
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. We welcome the
fact however that existing and new Underground staff are being
disability equality training.
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 sensory impairments. 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.
We also welcome the fact that under the Disability
Discrimination Act 2005 there is now an End Date for the Rail
Vehicle Accessibility Regulations of 2020. Whilst this will be
after the Olympics we would welcome an assurance that the trains
serving the Olympics will be fully compliant with the Rail Vehicle
Accessibility Regulations at or before the commencement of the
Games in 2012.
RAILWAYS
Guide Dogs 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 Guide Dogs' 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 accessibility requirements for blind and partially sighted
people.
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.
Guide Dogs 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.
AIRLINES AND
SHIPPING
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.
Animal reception facilities should be set up
at all airports and ferry terminals that are likely to receive
visitors to the Games. The facilities would have the capacity
to check Guide Dogs and other Assistance Dogs complying with quarantine
regulations known as Pets introduced by DEFRA.
It is anticipated that Guide Dog and Assistance
Dog owners will wish to attend all events at the Games.
12 September 2005
14 http://www.tfl.gov.uk/tfl/ph_underground.shtml Back
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