Memorandum from the Technical Advisors
Group (TAG) (BBS 03)
As you may recall the Technical Advisors Group
(TAG) represents a large number of local authorities in the country,
these include those with highway and transport responsibilities;
such as Transport for London, most London boroughs, Metropolitan
authorities, Unitary authorities and also many of the districts
and towns in two tier authorities—where the county is responsible
for Transport Issues. All our authorities have car parking responsibilities.
Many of the authorities who we represent are also responsible
for Social Services.
We have set out our comments in accordance with
the terms of reference as follows:
Should the Assessed Eligibility Criteria be changed
and, if so how?
Should the age at which children can qualify for
a badge (either because of a specific medical condition or on
the basis of the Assessed Eligibility Criteria) be changed?
It is accepted that there is a case for some
minor alterations to the assessed eligibility such as raising
the maximum age that a child can qualify for a Blue Badge due
to special medical conditions, such as those resulting in a dependence
on bulky medical equipment, or the need for emergency medical
treatment from two years to three years of age.
There may also be a case for persons with conditions
such as Crohn's Disease or Colitis, or who are registered as partially
sighted to be allowed to hold a Blue Badge because of their condition.
However, any assessment for such people subject to these medical
conditions should be based on maintaining, both in practice and
in the public's perception, the link between the Blue Badge and
the mobility impairment that all badge holders are supposed to
have. There must already be Blue Badge holders who have these
conditions, but because of mobility problems, they have been issued
with the permit because they qualified on impaired mobility grounds.
The key point of the badge is mobility and not
for so-called "non-mobility" conditions, like Crohn's
and colitis, must be considered on a case by case basis, ie the
applicant must demonstrate that they have no mobility or extremely
restricted mobility without the badge. Naming the conditions will
be perceived by the public as an entitlement.
Should people who are severely mentally impaired
or who have extremely disruptive behavioural problems be able
to qualify for a badge under the assessed eligibility criteria?
There may also be a case for persons with conditions
such as autism, Alzheimer's, learning difficulties, and other
mental health problems, to qualify for a Blue Badge. However,
any assessment should have to be based on maintaining, both in
practice and in the public's perception, the link between the
Blue Badge and mobility impairment. Again it is considered that
the DfT should avoid naming specific medical conditions as this
would quickly lead from a possible entitlement to an "actual"
entitlement, particularly in the public's opinion. An independent
mobility assessment by an Occupational Health Therapist or panel
of expert GPs should be identifying any applicant who has severe
mobility impairment and should therefore be recommended to be
issued with a Blue Badge. Therefore, it might be appropriate not
to extend the current arrangements.
Again as with the first question each case should
be assessed on its own merits to determine the degree of "mobility"
impairment, ie can the applicant be mobile without a badge (anyone
can be transported in a car assisted or otherwise), and if not,
to what extent does the badge make the difference between mobility
and non-mobility. As an example, someone with a mental illness
could be capable to getting to and from a car, wherever it is
in a reasonable amount of time. Another person may take half an
hour to get to the vehicle, half an hour back, so the Blue Badge
parking concessions may be helpful.
Should the minimum badge issue period be lowered
from the current three years?
Yes there are occasions when it is desirable
to issue a Blue Badge for periods of less than three years. For
example, those applicants who qualify for a Blue Badge as recipients
of the Higher Rate Mobility Component of the Disability Living
Allowance (HRMCDLA) entitlement may not have that allowance extended
when it is reviewed every three years, or that the review is due
in the near future.
Should local authorities have more discretion
to vary the yellow-line and on-street parking concessions (eg
allowing badge holders to park without charge for more time in
some areas and less in others depending on local traffic conditions
and disabled access)?
Yes, there must be sufficient flexibility as
in the case of central London, to take account of local traffic
and parking conditions, which may not allow any parking or allow
for greater periods of stay where appropriate. Changes to the
health provision are moving some services away from hospitals
and demand may increase at doctor's surgeries with little or no
off-street parking. However, we feel that they should be consistent,
clearly publicised and well understood.
Should the London Concession (the regulations
that exempt the four central London boroughs from the national
Blue Badge Scheme) be redrawn so that it is aligned with the London
Congestion Charge Zone (recognising that the zone may alter in
size)?
No, the traffic and parking conditions throughout
central London justify the retention of the current concession,
which was introduced in 1971, and despite many initiatives they
remain similar. Currently the central London area includes the
whole of the City of London, Royal Borough of Kensington &
Chelsea and the City of Westminster and part of the London Borough
of Camden south of Euston Road. There might be justification for
extending the area to include those parts of the Congestion Charging
Zone outside the four central London Boroughs (ie the London Boroughs
of Hackney, Hammersmith and Fulham, Islington, Lambeth, Southwark
and Tower Hamlets).
The inclusion of parts of six other London Boroughs
would introduce additional administration costs for a new local
scheme for them. Any individual local authority ought to be able
to decide whether it should be included in a special concession
area.
The Department for Transport's proposal to alter
the boundary of this concession area to coincide with the Congestion
Charging Zone would result in none of the 10 London Boroughs being
entirely within the concession area and is likely to cause greater
confusion than the current scheme. It would also require a comprehensive
review of all waiting and loading restrictions in those parts
of the existing concession area removed from it. At present, the
single and double yellow line waiting restrictions provide much
of the loading space required within areas that have had Controlled
Parking Zones designed around the current arrangements and where
additional provision has been provided for Blue Badge holders.
There are presently over 500 Blue Badge holder bays in the City
of Westminster alone.
The key thing is whether this is justified or
not. Restricting the kerbside in a wider area where currently
blue badge holders have full concessions needs to be justified
first and foremost. These boroughs have not asked to be included,
so any local scheme introduced is likely to give the same or similar
concessions as currently provided, and yet there would be new
administration and infrastructure costs.
Are there any other changes which should be made
to the concessions associated with a Blue badge?
It is believed that the opportunity to incorporate
other mobility related benefits should not be missed with the
current review of the Blue Badge scheme. There could be cost savings
in extending the remit of the Blue Badge scheme to include other
programmes, such as reduced taxi fares (TaxiCard), access to accessible
private hire vehicles and public transport fare concessions.
What would be the likely impact of any proposed
changes on the number of people holding badges, the availability
of disabled parking spaces and on local government administration
and costs?
It would depend on the extent of the proposed
changes to Blue Badge eligibility to include groups who may not
present the physical symptoms &/or have the mobility problems
associated with most Blue Badge holders. If the rules and guidance
were seen to relax or deviate from the raison d'etre of the Blue
Badge- mobility and accessibility, then there would be a considerable,
but unknowable, impact on the numbers of badges issued, a reduction
of vacant Blue Badge parking space, and increased administration
and costs.
There are over 250,000 Blue Badge holders in
Greater London. An increase of 5% in badge issue in London would
be at least 12,500 more Blue Badges. For one central London Borough
a 5% increase in daily usage would be at least 615 more vehicles
entering the central area. With the free congestion charge it
does not take a huge increase in badge issue to affect the availability
of space.
Opening up the scheme on a blanket condition
basis could have far reaching implications for kerbside management
and the credibility of the scheme. Case by case assessment is
therefore the best way forward if new categories are included
in the scheme.
OTHER COMMENTS
While we welcome the DfT's suggestion encouraging
the setting up local/regional databases for lost or stolen badges,
we are keen to see a central database of Blue Badges issued, and
we suggest that it be administered through the DVLA. We believe
that a central database would help to tackle some of the widespread
Blue Badge fraud and negate the value of stolen badges.
We consider that having a common database held
by the DVLA(or similar organisation) and accessible by enforcement
and issuing agencies should help reduce some of the fraud, as
it would allow quick checks to be made of the badge when the driver
is not in the vehicle and hopefully make theft of Blue Badges
a fruitless exercise.
The Blue Badge scheme could be reformed by allowing
the local/highway authority to process, evaluate, and approve
the application, and the DVLA (or similar organisation) to issue
the permit. The DVLA could also administer the centralised database
to which the highway and enforcement authorities could access
for lost and stolen Blue Badges. This would also make it easier
for enforcement officers to identify forged and fraudulently used
badges.
We note that Blue Badge issuing authorities
are encouraged by the DfT to use independent medical/mobility
advice when assessing the eligibility of applicants. This relates
to concerns that some GPs are being pressured into agreeing to
support badge applications, and also the Government's policy to
reduce the load on GPs. This is welcome providing the highway
authorities receive sufficient resources to fund these contracts,
eg in the case of one London Borough it pays £110 per applicant
for the OT service.
We seek the introduction of new technologies
into the Blue Badge (bar codes, chips, etc) to allow enforcement
officers to identify the Blue Badge holder without needing to
see the photograph and name of the badge holder. This would allow
discreet checks to see if the badge is reported stolen, a forgery
or being misused. New technologies and a central database would
allow quick checks to be made of the badge when the driver is
not in the vehicle.
Perhaps under certain circumstances, (ie a persistent
evader, a person with outstanding arrest warrants, etc), and with
Police supervision, enforcement officers be allowed to enter vehicles
to retrieve a Blue Badge reported stolen by the permit holder.
The vehicle could be entered by using the appropriate tool or
in the case of an emergency by smashing a side car window to gain
entry?
We also urge the DfT to reinstate the use of
vehicle registration marks (VRM) on the Blue Badge permit to reduce
fraud and misuse. We feel it was a grave mistake when the European
style Blue Badge was introduced that VRMs were no longer required,
as they had been on the old Orange Badge. We feel that this simple
step would go a long way to ensuring the reduction of fraudulent
use of the Blue Badge permit.
While the ethos of the scheme is mobility for
disabled persons, we would like to see it a requirement that applicants
nominate vehicle registration marks to be used and that a badge
can be refused if a nominated vehicle (on the badge or not) was
registered to a persistent evader.
We would also like to see attendance allowance
included in the eligibility criteria for passenger applicants
(for over 65's when HRMCDLA discontinues).
We would also suggest that the concession allowing
Blue Badge holders to park on Double Yellow Lines (DYLs), for
up to 3 hours, should be withdrawn. On the basis that DYLs are
installed at key locations, ie busy junctions, narrow streets,
etc; there should be no allowance for any parking whatsoever.
This concession is currently not available to Blue Badge holders
in central London and does not appear to unduly inconvenience
the disabled.
In order to compensate for the withdrawal of
the DYL concession highway authorities should be encouraged by
the DfT to install more Blue Badge parking bays. This should be
provided in areas where parking is a problem and the DfT should
supply financial assistance for new Blue Badge parking bays. Of
course another advantage is that Blue Badge parking bays are reserved
solely for Blue Badge holders.
February 2008
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