Memorandum from the Disabled Persons Transport
Advisory Committee (DPTAC) (BBS 09)
1. The Disabled Persons Transport Advisory
Committee (DPTAC) is grateful for the invitation to submit a memorandum
and give evidence to the inquiry by the House of Commons Select
Committee on Transport into the Blue Badge (Disabled Parking)
Reform Strategy. We understand that the Committee decided to carry
out this investigation in order to inform their response to the
Disabled Parking Reform Strategy which the Government plans to
publish in the late Spring.
2. As you know, DPTAC was established under
the Transport Act 1985 to advise the Government on the transport
needs of disabled people. DPTAC has identified four overarching
principles on which we base our advice to Government, other organisations
and disabled people. These are that:
— Accessibility for disabled people
is a condition of any investment;
— Accessibility for disabled people
must be a mainstream activity;
— Users should be involved in determining
accessibility; and
— Achieving accessibility for disabled
people is the responsibility of the provider.
3. These principles are also the basis on
which we offer the following comments.
INTRODUCTORY REMARKS
4. You have asked for comments on certain
specific aspects but first we would make some general remarks.
Since it was introduced in 1971, the Blue Badge has had a dramatic
effect on improving accessibility for many disabled people in
the course of their daily lives. We in DPTAC initiated a comprehensive
review of the Blue Badge some 10 years ago and this culminated
in a series of recommendations to Ministers in 2002. Most of these
were accepted by Government but implementation is still incomplete.
Therefore, 10 years on from the start of our review, we would
wish to be assured by Government that implementation of any measures
that may be agreed as a result of this review should be pursued
much more timeously.
5. However, we also know that it is impossible
to consider issues of eligibility separately from issues of administration
and enforcement. We therefore welcome the recognition of these
links in the consultation document issued by the Department for
Transport.
6. Finally in these initial comments, we
would draw attention to the original purpose of the Orange (now
Blue) Badge in 1971 which was to assist those who qualified for
a Badge to visit shops and other places (mainly in town centres).
The basic concessions then and now related solely to parking on-street
and relate to allowing Badge holders to park on-street closer
to their destination than might otherwise be the case. There have
been significant changes in the nature of our town centres since
then with pedestrians given increasing priority on many streets
in and around town centres while at the same time, we have seen
a massive growth in the number of supermarkets and out of town
shopping centres served by large off-street car parks.
7. The context in which the Blue Badge operates
has therefore changed and the value and extent of the on-street
concession has therefore been diminished. At the same time, the
Blue Badge has become a proxy to help service providers such as
the operators of the supermarkets and out of town shopping centres
to meet their obligations under the Disability Discrimination
Act 2005 by designating spaces in their car parks for use by Badge
holders.
Should the Assessed Eligibility Criteria be changed
and, if so, how?
8. The assessed eligibility criteria account
for almost two out of every three badges that were issued in England
in 2007 (1.451 million out of a total of 2.318 million). Indeed
the number and proportion of badges that are issued under the
criteria is higher than it has been at any time since 1995. There
are also now almost twice as many badges issued under the assessed
eligibility criteria (1.451 million) than there were in 1995 (0.783
million). We understand that this is both placing a strain on
the availability of parking spaces and devaluing the badge in
the eyes of many disabled people who have significant difficulty
in walking. We therefore have concerns about any suggestion that
the net should be spread wider unless consideration is also to
the adoption of much more rigorous regimes for assessment and
for enforcement of abuse of the scheme.
9. There are many good reasons for amending
the assessed eligibility criteria not least of which is to eliminate
some of the differences and discrepancies that exist between the
different criteria that are deployed for different purposes by
both national and local government. The obvious one and the example
that is quoted in the consultation document is the discrepancy
between the current assessed criteria and those used for assessing
eligibility for the Higher Rate Mobility Component of Disability
Living Allowance (HRMCDLA). This discriminates against many people
over the age of 65.
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?
10. We can see the logic of increasing the
age criterion from 2 to 3 years as this is in line with the regulations
relating to the Higher Rate Mobility Component of Disability Living
Allowance (HRMCDLA). Under the age of 3, we also believe that
irrespective of the walking ability of the child, their mobility
would rely significantly on the use of a pushchair.
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?
11. While sympathetic to the problems experienced
by parents and cares, we are not necessarily convinced of the
mobility benefits that would derive from including people with
severe mental impairment or disruptive behaviour patterns. However,
we do acknowledge the benefit of including these conditions in
the assessed eligibility criteria as helping to align the criteria
with those pertaining to HRMCDLA.
Should the minimum badge issue period be lowered
from the current three years?
12. We can see benefits for people who have
genuine short term disabilities. Such a proposal needs to be accompanied
by measures to ensure that such badges are issued quickly enough
to be useful and that they are returned and cancelled at the end
of the time period.
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)?
13. One of the strengths of the current
scheme is the fact that it is a national scheme and the basic
concessions are the same throughout England (apart from the four
central London boroughs). We believe that in the interests of
clarity, consistency and fairness for disabled people this should
continue to be the case. However, we would have no objection in
principle if an authority were to choose to offer a more favourable
concession so long as this was available to all Blue Badge holders
and not just those who lived in the local authority area. There
is always the possibility that other authorities would also seek
to match these more relaxed concessions!
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)?
14. We believe this is the wrong question
and one which only arises because the current Congestion Charge
regime gives exemption for vehicles occupied by Blue Badge holders.
15. One of our recommendations in 2002 was
that the London boroughs be brought into the national scheme.
This was in the interests of clarity, consistency and fairness
for the many disabled people who are still not able to use public
transport options despite acknowledged improvements. This argument
was not accepted by the Government and the four boroughs in question
have themselves continued to oppose the suggestion.
16. However, we believe that extending the
exemption zone to match the Congestion Charge boundary would exacerbate
the situation for Blue Badge holders by merely increasing the
area that is not part of the national scheme. We would draw attention
to the fact that although London buses may be wheelchair accessible,
the lack of audio-visual announcements discriminates against the
much large number of people who have sight and hearing impairments.
Current footway and bus stop infrastructure also needs considerable
work before it can be considered in any way to be fully accessible
for disabled people.
17. Instead, we still believe that the London
boroughs should be brought into the national scheme. The issues
that have been raised by the boroughs relating to parking and
security, we believe, can be resolved by other means.
Are there any other changes which should be made
to the concessions associated with a Blue badge?
18. There are two aspects to this issue.
The first is the nature of the concessions and the other relates
to the role of the Badge itself.
19. Regarding the first, many of the issues
relating to the use of the Blue Badge relate to off-street parking
at supermarkets and in other off-street parking areas. However,
these currently fall outwith the scope of the Blue Badge scheme.
It would seem sensible to amend the scheme to include off- street
parking areas. There are, of course, issues relating to enforcement
and the powers of inspection that are currently available to enforcement
officers employed to deal with on-street waiting restrictions.
We believe, however, that there is nothing in principle to stop
these powers being extended to enforcement of off-street parking
areas that are managed by local authorities.
20. In terms of the second, the Blue Badge
is only one of the tools available to improve mobility for disabled
people. Accessible public transport, community transport, concessionary
transport and taxicard also form part of the overall palette or
menu of measures that should be considered.
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?
21. We understand that the Department for
Transport has commissioned research into the subject of the number
of Badges and we await the results with interest.
22. As we have indicated above, the number
of on-street spaces in many town centres has declined as pedestrians
have been given priority over vehicles. The opportunities to park
on-street are therefore reducing as the number of Badges on issue
and hence demand for parking increases. The demand for off-street
spaces will also increase as the number of Badges increases but
it is open to the operators of these spaces to devote more of
the total supply of spaces to use by Blue Badge holders.
23. The effect on local government administration
and costs will depend on various factors. As local traffic authority,
Councils have a duty to enforce parking regulations including
the validity of the use of Blue Badges. Increased activity on
this front will inevitably mean increased costs. However, there
should also be opportunities for more streamlined operations and
also increased income from fines for abuse.
24. In terms of the administration and issuing
of the Badge, much will depend on whether this role remains with
individual local authorities or is transferred to regional or
national organisations. We believe that collective means of administering
the Badge could be both more cost effective and give more rigorous
and consistent assessments. However, it is expected that there
would still be a need for local service points for applicants
who wished to call in on a personal basis and to facilitate assessments
where required. These could be centred on existing facilities
such as post offices.
25. Lastly, but by no means least, it is
vital to remember that the Blue Badge scheme is about delivering
a service to disabled people and the three parts to this question
need to be addressed in that light. The tests will be:
— whether increasing the number of
Badges on issue improves the quality of life for those people
who genuinely need it for personal mobility;
— whether local authorities and other
service providers monitor use and take appropriate steps to ensure
that the supply is adequate to meet the demand for parking; and
— whether any increased costs also
result in a significantly better quality of service for applicants.
CONCLUDING COMMENTS
26. As we have indicated above, the principal
concern of DPTAC is to ensure full accessibility for disabled
people. We believe that the Blue Badge still has the potential
to make a significant contribution towards these aims as part
of an overall menu of complementary measures. We appreciate that
some of the possible enhancements to the Blue Badge scheme may
require primary and others secondary legislation. We would, however,
expect that any measures that may come out these deliberations
will be pursued and implemented as soon as possible.
March 2008
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