Joint memorandum from the Joint Committee
for the Mobility of Blind and Partially Sighted People; The Joint
Committee for the Mobility of Disabled People; The Guide Dogs
for the Blind Association; RADAR; National Autistic Society; Disabled
Parents Network; Royal National Institute of the Blind (RNIB);
Arthritis Care; Mind; Restricted Growth Association; Parkinson's
Disease Society; Community Transport Association and Spinal Injuries
Association (TPT 24)
INTRODUCTION
Our organisations welcome the decision of the
Transport Select Committee to look into the issue of concessionary
fares.
The Government's Concessionary Bus Travel Bill
will ensure that from April 2008 free travel will be extended
to local off-peak bus travel across local authority boundaries
providing the bus stops at least every 15 miles. We welcome these
improvements but we believe that there is considerably more that
the Government needs to do to ensure that the mobility needs of
disabled people are addressed in concessionary travel. This could
be achieved by introducing:
— A requirement for free travel anytime.
— A requirement to provide free travel
on other modes of transport.
— A requirement for concessions to
apply to community transport services such as "dial-a-ride".
— A requirement to provide free travel
for a companion where the person's impairment means that they
can not access transport on their own.
— A definition of disability which
includes people with mental health difficulties.
We set out our reasons for these suggestions
below. As our coalition has come together to lobby on the Concessionary
Bus Travel Bill (the Bill) this submission only addresses questions
10 and 11 under the heading of "Concessionary fares-the right
strategy?".
THE NEED
FOR CONCESSIONARY
FARES
We believe that the free travel provided by
the Bill is necessary for disabled people for several reasons:
— It is often necessary, even on short
routes, for disabled people to use public transport either because
their mobility is restricted, the pedestrian environment is inaccessible
to them, or because they are concerned about personal security.
Travel costs can restrict that mobility.
— Blind, deafblind and partially sighted
people and people with movement-related conditions such as Parkinson's
disease are likely to have difficulty finding the correct change.
For deaf and hard of hearing people, free travel avoids the difficulty
of communicating with the driver or conductor.
— Where ticket machines are used, many
disabled people may have difficulties. For example, wheelchair
users may have difficulty because of the physical design and people
with learning disabilities may find such machines confusing.
Free travel also makes operational sense: it
contributes to reduced dwell times at stops with disabled people
simply showing their concessionary pass as they board.
TRANSPORT AND
ACCESS TO
EMPLOYMENT
Disabled people typically have lower incomes
due to their lack of employment opportunities and are more likely
to be socially excluded. According to the Government's "Disability
in Great Britain" report the incomes of disabled adults
are 20 to 30% lower than those of non-disabled people (these figures
included income from disability benefits). The ninth annual report
of indicators of poverty and social exclusion, Monitoring Poverty
and Social Exclusion in the UK 2006, issued in December 2006
by the New Policy Institute (funded by Joseph Rowntree) reported
that disabled people are twice as likely to be unemployed as non-disabled
people. According to the report 30% of disabled adults of working
age live on 60% of average income levels.
FREE TRAVEL
AT ANY
TIME
The restriction of concessionary travel during
morning peak periods has a severely detrimental effect on disabled
people travelling to work or looking for work. Research by RNIB
suggests that only 27% of blind and partially sighted people of
working age are in employment and where people are employed they
are more likely to be in lower paid jobs. Employment levels for
many other impairment groups are similar if not worse.
Restricting concessions to off-peak times also
affects disabled people travelling to early medical appointments,
benefit and other appointments, or to education and leisure activities
with an early start time. Many disabled people prefer to travel
to shops and town centres early in the day when they are quieter
and so more accessible.
As the Government has improved the minimum concessionary
fare scheme for older and disabled people, some local authorities
have cut back on local schemes that previously offered more than
the statutory minimum. For example, there has been pressure on
a number of schemes that provided free morning peak travel to
blind people but not to other older and disabled people. When
this issue came up in London, the Association of London Government
(ALG, now renamed London Councils) suggested levelling down but
following a major campaign by disabled people free travel was
extended to all disabled people in the morning peak hours. Our
organisations would support the national adoption of the London
approach, ie. free morning peak travel for all disabled people..
The scheme operating in Scotland already offers this level of
provision.
The Bill would also restrict free travel at
the other end of the day by limiting it to travel up to 11.00
pm. That limit is likely to effect the mobility of younger disabled
people in particular who want to go out for the evening with their
peers.
Other Support for Extra Transport Costs
It is widely believed that disabled people in
employment are able to obtain assistance with the costs of travelling
to and from work through the Department for Work and Pensions
Access to Work Scheme. In fact, the Scheme is only available to
those disabled people unable to use existing public transport
that operates between their home and their place of work, who
would therefore incur additional costs travel costs, for example,
in using taxis. The Scheme takes no account of the cost of public
transport.
While we are pleased that the Bill would not
prevent local authorities from continuing to offer more generous
concessions than the statutory minimum, we are concerned that
exercise of this discretion would effectively create a postcode
lottery for disabled people. Such lotteries are already evident,
for example to resolve a budget crisis Christchurch District Council
has removed the right for blind people to travel for free in the
morning peak despite the fact that the Dorset-wide County scheme
offers free morning peak-time travel to blind people. Guide Dogs,
RNIB and Warwickshire Association for the Blind worked without
success to try to reverse a decision by Stratford-on-Avon District
Council to remove free perk-time travel for visually impaired
people in the morning peak hours following the introduction of
free off-peak travel for all disabled people in April 2006.
For the Government to include morning peak-time
travel in the statutory minimum would be consistent with its commitment
to get more disabled people into work: a policy they are currently
promoting through their reform of Incapacity Benefit. Indeed the
New Policy Institute report cited above pointed to the lack of
access to paid work as the main reason for poverty amongst disabled
people.
There are no time restrictions on the schemes
which have been introduced in Wales and Scotland. Similarly there
are no time restrictions on using the Freedom pass in the morning
peak hours in London on buses, Underground and the DLR and this
has not caused difficulties despite the huge pressure on public
transport in the morning peak hours and late in the evening in
the capital city. However, if local authorities are to be able
to go on providing more than the statutory minimum the Government
must make sure that they are fully funded for the increases in
the statutory minimum concessionary fare schemes that are proposed
in the Bill.
The Government said in Grand Committee that
they were unable to support amendments to this effect because
it would cost £100 million. We appreciate the resources that
the Government is already committing to implementing the Bill.
However, we also note that when the ALG (now London Councils)
first began to consider the cost of allowing travel in the morning
peak for disabled people they also said that "It was so expensive
as to not be worth quantifying". However, after further investigation
and discussion with TfL the cost turned out to be a lot less than
originally thought and free travel has been available in London
24 hours a day since April 2003. The Government might also find
that the cost of this particular extension to the scheme would
be less than they originally thought.
Extending the Concessionary Fares scheme to
provide for free travel 24 hours a day would help disabled people
find and retain work and turn them from benefit claimants into
taxpayers. This would go some way to raising the £100 million
which the Government suggest that this measure would cost.
APPLYING THE
CONCESSIONS TO
OTHER MODES
OF TRANSPORT
In some areas concessionary fare passes can
be used in taxis, on community transport and other door-to-door
transport. This is particularly important in rural areas where
bus services may be infrequent or absent. Disabled people will
not benefit from having the concession if they have few or no
bus services on which to use it. In Scotland many ferry journeys
are also covered by the concessionary fares scheme in recognition
of the local transport services that ferries provide between the
Scottish Islands and the mainland. We would encourage the same
approach to be adopted for other services throughout the UK.
In urban areas concessions are also often available
to be used on local rail and light rail services. This is particularly
important where train and tram services are used as an alternative
to the bus for local journeys.
Certain groups of disabled people would also
benefit greatly from the application of the concessions to a wider
range of transport modes. People with autism, for example, prefer
to use door-to-door services because they often have difficulty
in judging road safety and can experience anxiety on scheduled
public transport services, especially where routes and timetables
frequently change. The restrictions on the eligibility for the
higher mobility rate of Disability Living Allowance means that
for some disabled people door to door transport is currently not
an option for them because of the additional costs associated
with its use.
Our organisations would encourage the extension
of the statutory minimum concessionary fare scheme to provide
for its application to a wider range of transport services.
Our organisations appreciate that the Government
are sympathetic to the sentiment of our proposed amendment in
this area but are unable to accept it because they believe that
it would cost £300 million. We are, however, encouraging
the Government to consider the cost-benefits of these changes
in terms of giving disabled people greater independence and allowing
more disabled people to work. Once these benefits are taken into
account to we believe that the economic case is much stronger.
USE ON
DOOR-TO-DOOR
TRANSPORT FOR
THOSE UNABLE
TO ACCESS
MAINSTREAM PUBLIC
TRANSPORT
An increasing number of services are operated
by accessible buses but it will be some time before all buses
are fully accessible. Having a concession for a service that you
cannot use is of no benefit to disabled people in areas where
fully accessible services are not yet available. Even where more
accessible vehicles are in use, they will never be a viable option
for some disabled people, even with assistance. Others may need
door-to-door transport to get to the nearest bus stop because
of the distances involved or the inaccessibility of the pedestrian
environment. For these reasons we believe that concessionary fares
should be made available on community transport and door-to-door
services.
Local authorities have discretion as to whether
to reimburse those providing community transport for accepting
concessions but a survey by the Community Transport Association
found that only a minority did so and of those most only reimbursed
half, rather than the full fare. We believe that this discriminates
against disabled people who rely on such services and is potentially
challengeable under the Disability Discrimination Act or the Human
Rights Act.
As with the more generous schemes, reimbursement
for community transport schemes is a postcode lottery. In Wiltshire,
for example, the County Council, West Wiltshire District Council
and Kennet District Council reimburse community minibus groups
for taking free passes on the eligible services they operate but
North Wiltshire District Council and Salisbury District Council
do not. Swindon Borough Council only provide disabled people with
£60 of free journeys per annum on community minibuses before
they have to pay for using the services.
Salisbury District Council have informed the
Community Transport Association that their concessionary fares
settlement from central government was insufficient to meet the
costs of reimbursing registered bus operators let alone community
transport operators. This affects two Salisbury-based community
minibus groups in particular -groups currently run services for
isolated people in Salisbury mainly to help them access local
shops, and both have to charge their concessionary pass holding
passengers for journeys which they would otherwise get free if
there was a registered bus route which served them.
At Grand Committee Stage cost was also cited
by the Government as the reason for rejecting an amendment to
extend the scheme to community transport. The Government also
pointed out that local authorities would continue to have the
discretion to provide concessionary fares on door to door transport
and that the legislation would allow for an extension in this
area at a latter date by Regulations.
At Report a further argument was offered that
such an amendment would effectively provide for buses to be replaced
by community transport in rural areas. We do not believe that
would be the effect. The purpose is to ensure that those disabled
people who because of their impairment could not access local
bus services, or who live in areas that are not served by bus
services, would be able to enjoy free travel on community transport
services in their area. As a safeguard the Secretary of State
could be required to issue guidance which could also address the
Government's concerns about the definition of community transport
for the purposes of concessionary fares legislation
TRAVELLING WITH
A COMPANION
Some disabled people need a companion to travel
with them on public transport. We would argue that concessions
should be available to allow a companion to travel free of charge,
where this is necessary to enable the disabled people to access
the service. This provision already applies under both the Welsh
scheme and the Dorset scheme.
Whilst we appreciate the Government's estimate
that this extension would cost £10 million we would point
out that as the proposed additional concession would only apply
to those who cannot access public transport without the support
of a companion, the number of people that would be brought into
the scheme is likely to be relatively small. The Government has
also pointed out that the term "companion" could be
open to abuse but we would be happy for an alternative term to
be used such as "personal assistant."
ADDING PEOPLE
WITH MENTAL
HEALTH DIFFICULTIES
TO THOSE
ELIGIBLE FOR
CONCESSIONARY FARES
The issue of the eligibility of people with
mental health difficulties remains a problem. Currently, people
with mental health issues who qualify for concessionary fares
do so by virtue of the fact that they would, if they applied,
be refused a driving licence under Part 3 of the Road Traffic
Act 1988 pursuant to section 92 of the Act. Section 92 of the
1988 Act refers to five categories of people who would be refused
a driving licence. The second of these are people with a "severe
mental disorder".
Eligibility for concessionary fares is one of
the major factors in determining an individual's chance of recovery
and re-integration into society. Severe mental ill health often
leads to social and physical isolation, discrimination and an
inability to play a full part in economic and community life.
Access to community centres, drop-in therapeutic communities,
counselling or self-help groups can be essential to recovery.
To access those services many people rely on public transport.
Research in the Report Focus on Mental Health, An Uphill Struggle:
Poverty and Mental Health (London, Mental Health Foundation 2001)
suggests that some people have not been able to get help from
mental health services because of their inability to pay for transport.
Even where they still hold a driving licence, poverty and a fluctuating
health condition may make driving impossible. The ability to travel
to education centres, to take up job opportunities and to access
community health and social care facilities is vital. The inability
to access these can lead to serious consequences for the individual.
These quotes from experiences reported to Mind
show the difficulties:
A service user writes from the Midlands: "Initially
I came up against a lot of aggravation when I applied for concessionary
fares. Now I hold a bus pass and come up against hostility with
a few bus drivers questioning my right to hold a pass".
One city Patient Council representative from
the West of England writes that "even where there is no
current problem in claiming in the city there are constant problem(s)
on buses of drivers' prejudice, eg `Why have you got a pass, you
don't look ill?'"
The evidence suggests that the definition is
causing a problem and for that reason we believe the Government
should act now to introduce a new definition to cover explicitly
people with mental health issues. Our suggested definition is
based on the definition used for the Scottish Concessionary fares
scheme.
In addition, a new definition could cover people
with a social and communication disability—such as those
with Asperger syndrome. Since most people with Asperger syndrome
do not have a learning disability, they may be excluded by a strict
interpretation of the definition in the Transport Act 2000. While
people with Asperger syndrome are not generally refused a driving
licence, they must notify DVLA of their condition and cases are
assessed on an individual basis; this may make car insurance unaffordable,
especially for young people. The difficulties experienced by some
people with Asperger syndrome in anticipating the actions of other
road users mean that some individuals choose not to drive.
Our organisations have welcomed the Government's
commitment to look at this issue and consult with its Concessionary
Fares Stakeholder Group. We believe that the consultation could
also usefully cover the issues of stigma faced by people with
mental health problems receiving concessionary fares (eg being
questioned because they do not "look disabled") and
how to maximise take up of concessionary fares amongst those people
with mental health difficulties who are entitled to them. The
recommendation of the Social Exclusion Unit's Report, Mental Health
and Social Exclusion was to consider the case for revisions to
the statutory guidance on giving concessionary fares to people
with mental health difficulties by the end of 2004. How has the
2004 recommendation been taken forward? We look forward to the
early completion of the new review which the Government have announced.
March 2007
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