APPENDIX 34
Memorandum submitted by the Joint Committee
for the Mobility of Blind and Partially Sighted People
1. INTRODUCTION
The Joint Committee on Mobility of Blind and
Partially Sighted People (JCMBPS) welcomes London's success in
winning the bid to hold the 2012 Olympic Games.
The Joint Committee is an independent body consisting
of representatives of the principle organisations of and for blind,
deafblind and partially sighted people with a specific interest
in mobility.
It is estimated that there are 9.8 million adults
in Britain likely to be covered by the Disability Discrimination
Act (22% of the adult population),[15]
plus 0.7 million children[16].
There are over a million registered blind and partially sighted
people. Almost two million people with significant sight loss[17]
would have difficulty, even with the aid of glasses, in recognising
a friend across the street. Many also have additional disabilities,
particularly hearing loss, and experience serious problems moving
around the built environment. Those engaged in providing services
and facilities in transport and the built environment should always
take their needs into account.
It is predicted that over the next 30 years
— The proportion of the population
over 65 will increase by 40%;
— The number of people aged over 65
will double;
— The proportion over 80 will increase
by 100%and the total number over 80 will treble
— Over the same period the overall
population will increase by less than 7%.
The JCMBPS believes that blind, deafblind and
partially sighted people should be able to move around safely
and independently. This is currently often not the case and barriers
may be physical, operational or attitudinal. 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
JCMBPS 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. JCMBPS believe that London's transport system has
become more accessible as a result. It is therefore disappointing
that the five 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.
JCMBPS 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
JCMBPS 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[18]15
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 ninety% 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
JCMBPS 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 JCMBPS' 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.
JCMBPS 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
15 Source: DRC Disability Briefing December 2004 from
Family Resources Survey, 2002-03. Great Britain. Based on the
DDA definition of disability and the publication of a User's guide
to disability estimates and definition, available online at http://www.dwp.gov.uk/asd/asd5/ih2003-2004/IH128userguide.pdf
In the Family Resources Survey (FRS) an adult is defined as all
those aged 16 and over, except for 16 to 18 year olds in full
time non-advanced education. Back
16
Source as above. In the Family Resources Survey (FRS) a child
is defined as someone aged under 16, and aged 16 to 18 year olds
who is in full-time non advanced education and living at home. Back
17
Figures from the 1999 DSS Research report No.94 "Disability
in Great Britain" indicated there were an estimated 1.97
million people with a significant sight loss. Back
18
http://www.tfl.gov.uk/tfl/ph-underground.shtml Back
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