Guide Dogs for the Blind Association and
the Joint Committee on the Mobility of Blind and Partially Sighted
People (BBS 10)
INTRODUCTION
Our organisations welcome both the Government's
consultation document on the above and the Transport Committee's
decision to conduct an inquiry in to the strategy consultation
document.
When preparing our written submission to the
Transport Committee with have restricted our comments to issues
in regard to blind and partially sighted people as these are the
groups of people our organisations represent. We are of the opinion
that some of the issues in the consultation document would be
more appropriately addressed by others.
POSSIBLE CHANGES
TO THE
ASSESSED ELIGIBILITY
CRITERIA
We continue to be frustrated at the continued
exclusion from the scheme of partially sighted people.
In order to be registered as blind or partially
sighted, a visually impaired person has to be seen by a consultant
ophthalmologist, who considers their eligibility in relation to
guidance issued by the Department of Health. Those who are registered
blind automatically qualify for a Blue Badge. This is currently
not the case for those registered as partially sighted.
There is, in practice, some overlap between
entitlement to registration as blind and partially sighted. Additionally,
registration does not take full account of a person's ability
to see in different lighting conditions. Some partially sighted
people are able to see relatively well in normal daylight conditions,
but are effectively totally blind at night. Others are able to
see reasonably well indoors, but are effectively totally blind
in bright sunlight or in conditions of glare. Consequently some
partially sighted people may be able to use public transport at
certain times, or under certain conditions, but not others. As
a result partially sighted people need to use a car for some or
all journeys, and the blue badge would assist their driver to
park close to the premises they wish to visit. Our organisations
that if the criteria for entitlement were extended to include
partially sighted people, this would help to prevent this particular
group of people from being socially excluded and isolated within
their own homes.
Almost 60% of older visually impaired people
never go out on their own because of difficulties encountered
when moving about the pedestrian environment or accessing public
transport. The most common form of transport used by blind and
partially sighted people is a car driven by a friend or relative.i
In the period 2005-06, the number of registered
partially sighted people in England was approximately 155,200
(ref: RNIB website).
It should also be noted that DPTAC (Disabled
Persons Transport Advisory Committee) recommended to the Government
in 2002 that partially sighted people should be included within
the scheme.
REDUCING THE
MINIMUM BADGE
ISSUE PERIOD
FROM THE
CURRENT THREE
YEARS
Our organisations believe that the minimum period
for entitlement for the blue badge should be 12 months as this
would be in line with the definition of disability under the Disability
Discrimination Act (DDA) in which the adverse effect on your ability
to carry out normal day-to-day activities must last, or be likely
to last, for at least 12 months.
Giving local authorities the power to 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).
We consider that this proposal would be difficult
to manage for local authorities and would cause confusion to those
entitled to a blue badge. For example, a person entitled to use
concessions under the scheme may travel to an area which they
are unfamiliar with. This could result in a blue badge user parking
illegally and being issued with a fixed penalty notice and possibly
having their vehicle removed by the local authority. Such confusion
already exists for many who drive in to the four London Boroughs
which are exempt from the National Blue Badge Scheme.
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)?
If the regulations that exempt the four central
London boroughs from the National Blue Badge scheme are to be
redrawn so as to coincide with the congestion charging then we
believe that it is essential that by registering for the Blue
Badge exemption from congestion charging, that disabled people
automatically receive the parking concessions available to holders
of the central London Disabled Parking Badge. We believe that
this would provide the right balance between the access needs
of disabled people and the ability of other drivers to park.
In 2002 the London Assembly Transport Committee
published a report called "Access Denied" which called
for careful consideration of the central London exemption for
the Blue Badge. In response the four Boroughs involved worked
together to have one scheme instead of four separate schemes.
To have one badge which was the central London exemption from
congestion charging and which allowed Blue Badge parking in central
London would be another step in the right direction and would
avoid the need for disabled people to potentially have to apply
for a Blue Badge, central London parking a badge and congestion
charging exemptions.
OTHER CONCESSIONS
ASSOCIATED WITH
A BLUE
BADGE
We strongly feel that the Government should
take this opportunity to put in place a national exemption for
all blue badge holders from any charges levied to vehicle users
as part of any current or future congestion charging or road toll
schemes. A significant majority of those who are entitled to a
blue badge are often on low incomes and the additional cost of
travelling through congestion charge zones or toll roads would
be a financial barrier to them.
There continues to be a high number of reports
from blue badge users in regard to the misuse of blue badge parking
bays within car parks in premises such as supermarkets and other
service providers. We feel that Government should be more proactive
in encouraging service providers to police the use of blue badge
parking bays to ensure they are used by those who are entitled
to use them. Staff should be given disability awareness training
which includes specific training on how the scheme works and who
it is for. An example of good practice is Asda supermarkets where
from January, 2008 ASDA announced it would be the first retailer
to fine drivers for the misuse of disabled and parent and child
parking bays in its car parks. All profits generated from the
fines will go to charity. According to Asda, when surveyed four
out of five of their customers said they believed rolling out
the scheme was the right thing to do. As a result of the scheme,
the number of free parking spaces increased by over 60% for disabled
drivers and parents with young children.
REFERENCE
i "Rights of Way" RNIB, 1999 and "Travellers"
Tales, RNIB 2002.
March 2008
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