Disabled Access to Transport

Written evidence from Merseytravel (DAT 20)

Context

0.1 Merseytravel is a public body comprising the Merseyside Integrated Transport Authority (ITA) and the Merseyside Passenger Transport Executive (PTE), acting together with the overall aim of providing an integrated transport network for Merseyside which is accessible to all.

0.2 Integrated Transport Authorities have a statutory requirement to produce Local Transport Plans (LTPs) as a result of the Local Transport Act 2008. Via the Local Transport Plan, the ITA is responsible for multimodal transport policy issues. However the Passenger Transport Executive (PTE) remains responsible for delivery of passenger transport, concessionary travel, ticketing and so forth, and as a result, works in partnership with the local authorities and other partners to deliver the LTP. The new Local Transport Plan and its associated documents came into force on the 1 April 2011 and form the transport policy framework for Merseyside.

0.3 The Local Transport Plan referred to above includes a specific goal of improving the accessibility of the transport network, and ensuring easy travel for disabled people. Merseytravel has an adopted Equality Scheme, setting out its approach to securing compliance with the Equality Act 2010 as a service commissioner and provider and as an employer.

0.4 Merseytravel has an established track record of promoting and designing infrastructure, services and facilities that are fully accessible to all sectors of society, as part of its corporate vision of delivering world class customer services. This has included pioneering work in trialling low floor buses in the early 1990s, the development of accessible bus boarding points, codes of practice on disability issues, access guides, accessible rail stations and audible announcements on board local electric train services, as examples. It also operates one of the most comprehensive travel schemes for disabled people in the country, in addition to the demand responsive Merseylink service, for people with the greatest mobility needs.

0.5 Merseytravel’s comments on the questions raised by the Committee are as follows.

Questions

1. The effectiveness of legislation relating to transport for disabled people: is it working? Is it sufficiently comprehensive? How effectively is it enforced?

1.1 Overall, Merseytravel considers that sufficient legislation exists in relation to transport and access for people with disabilities. The principal problem concerns the myriad of powers, and the fragmented nature of roles and responsibilities across different modes of transport and across networks. Road, rail, private hire vehicles, public buildings and the public highway / public realm are all subject to different regimes or differing timescales for compliance. This makes lines of accountability from a member of the public’s point of view ambiguous, especially when it comes to responsibility for enforcement.

1.2 For example, the Equality Act 2010 consolidates the legislation previously set out in the Disability Discrimination Act 1995 and the Disability Discrimination Act 2005 to increase access to transport services and infrastructure by disabled people.

1.3 Under the Rail Vehicle Accessibility Regulations 1998, all rail vehicles must be compliant and fully accessible by 1 January 2020, except for those which are specifically exempt under Order. The United Kingdom’s leadership in the area has now been recognised at a European level, and the European Commission has come forward with new standards for the accessibility of trains.

1.4 The Rail Vehicle Accessibility Regulations 1998 have now been superseded by European Directive 2008/164/EC which applies Europe-wide standards of rail accessibility. These were adopted by the UK on 1 July 2008. These new standards represent a step change in the accessibility of trains on mainland Europe. In 2010 the Rail Vehicle Accessibility (Non-Interoperable Rail System) Regulations 2010 came into force and brought light rail into line with other rail vehicles, including an end date for compliance of 1 January 2020. There is also an ongoing programme to refurbish rail stations to make them accessible for all.

1.5 Accessibility requirements for buses and coaches are set out in the Public Service Vehicles Accessibility Regulations 2000, as amended, that came into force on 30 August 2000. They require all buses and coaches, both old and new, to comply from 2017 for buses and from 2020 for coaches. There is a further question as to the extent to which disabled passengers can and should be assisted into a vehicle. There are also questions regarding accessibility of bus stations and terminals, which are largely the responsibility of local authorities in enforcement terms.

1.6 Accessibility of buildings and the street environment tends to be covered by the Town and Country Planning Act and the Building Regulations. Aviation and shipping are covered differently as well. Access champions also differ from mode to mode with various bodies such as Passenger Focus, CAA, Passenger Shipping Association, local authorities and transport authorities all having some remit on these issues.

1.7 As such, in terms of door-to-door journeys, there is a myriad of legislation covering accessibility, which can be confusing. There is no single regulator or accountable body for transport accessibility. The Disabled Persons Transport Advisory Committee (DPTAC) provided a valuable role as a ‘champion’ for disabled people previously, but Government now wishes to abolish this body. This is considered a retrograde step.

1.8 This complex legislative framework prevents the holistic implementation of access for all to buildings, streets and individual transport modes in a consistent way. As a result there is no single, coherent system or accountability across the door-to-door journey and standards often differ. The same is true of information and support that is provided by public and private sector bodies.

1.9 Finally, although there are significant moves due to the Equality Act 2010 legislation and related legislation to improve the accessibility of all modes of transport, to buildings and the general environment, there remains a lag between the introduction of legislation, and the delivery and mainstreaming of legislative requirements. This raises the importance of non-statutory codes of practice and best practice guidelines in the intervening period, with a view to legislative requirements being satisfied or exceeded, wherever possible.

2. The accessibility of information: including the provision of information about routes, connections, timetables, delays and service alterations, and fares

2.1 Legibility and information on accessibility of the transport network is crucial to enable disabled people to have the knowledge, confidence and support to use it. Unfortunately there are still gaps and weaknesses in provision currently. There is often a lack of universal, real time information across the network on the availability or running of accessible buses on a particular bus route at a particular time. This uncertainty can frequently discourage disabled users from the transport network. This can vary by franchise or by operator, as standards are rarely consistent or stipulated at a national level. This is not conducive to promoting more use of the public transport network by everyone.

2.2 Timetables can be difficult to navigate and there is a need to be creative when engaging with people who struggle to understand the network. This can include one-to-one support through travel advisors and travel ‘buddies’, but which are typically reliant on scarce revenue funding sources to sustain. The Traveline telephone helpline service is often the most accessible option, being easy to use, and personalised.

2.3 Increasing the use of web-based technology, and mobile web-based technology is a powerful way in which to make travel information available in alternative formats for people with a range of disabilities. Allied to this is the need for all service providers to make information available in a consistent format, and there is a role for government in co-ordinating such requirements.

2.4 In terms of service alterations, through correspondence with disabled transport users, Merseytravel is aware of serious difficulties arising when bus operators switch vehicles without adequate, or indeed, any warning. This can come as a result of emergencies such as vehicle failure, and where an alternative, accessible bus with a ramp or level access is not available. However, if an anticipated, accessible vehicle does not arrive, disabled passenger are left unable to board the vehicle and make a journey. This is a particular problem on services operated by smaller operators, who have smaller fleets and no back-up vehicles. Affected passengers have advised Merseytravel that the consequences of such changes could be resolved by a simple requirement for the transport industry to make information about service changes available to disabled customers in advance, or as soon as problems become known. This need not be costly or arduous, and could be in the form of a help line number, text message or a telephone ‘app’ which could inform disabled people (or else via bodies such as Merseytravel) of changes planned in the next 24 hours to bus fleets or routes which would affect a person’s ability to travel. This would at least allow alternative, informed arrangements to be made by passengers.

2.5 Bus services that are procured by Merseytravel must be accessible, as per the conditions of contract. Merseytravel can thus assure users of a minimum level of service and accessibility. On the commercial network, Merseytravel recognises the need for a consistent level of quality, as demonstrated by its commitment to Statutory Quality Partnerships, in partnership with the local authorities and bus operators, to commit all parties to high and consistent standards.

2.6 Looking at local action being taken to improve the accessibility of information, Merseytravel for example is currently working with the charity ‘Guide Dogs for the Blind’, who are developing a downloadable MP3 file which will audibly describe the layout of particular bus station on approach.

2.7 Access audits of transport interchanges such as bus stations, or road crossings are of great importance for many reasons, not least to help identify issues that need to be communicated or publicised to disabled passengers. The importance of regular audits needs to be promoted by government.

2.8 As noted in Q1, DDA legislation in 2017 will require bus companies to have compliant vehicles across their fleet and many operators are in the process of upgrading their fleets to accommodate this. However this is a phased process and for smaller companies, there is a lag in the intervening period. This can result in the practical problems outlined in the example above and which can render disabled people unable to travel or be disadvantaged, potentially at short notice. As such, the role of technology is considered critical, coupled with a requirement for transport operators to make information available in a consistent and timely way.

3. The provision of assistance by public transport staff and staff awareness of the needs of people with different disabilities

3.1 Staff attitudes and behaviour play a large part in passengers’ ability and willingness to travel. It is essential that transport staff are fully trained on equality and customer service to World Host standard (or equivalent) to deal with these issues. Good progress has been made in ensuring that transport staff have the appropriate disability equality awareness training to support disabled passengers and enable them to travel confidently and in comfort. Merseytravel, through its Merseylearn programme, has developed specialist training for bus operators and taxi operators. Such training also needs to be recognised by government as a core element of the licensing regime, and potentially, as part of the Public Service Vehicle (PSV) system. It is considered that knowledge of peoples’ differing needs and customer care is as important a skill as having the required competence to drive a PSV vehicle. To this end, Merseytravel recommends that the new system associated with Certificates of Professional Competence (CPC) for PSV licence holders should include specific training around disability awareness and also customer care.

3.2 The Secure Stations Scheme is designed to improve security standards at overground and underground rail stations for passengers and staff. While the Scheme is essentially about improving security at stations, it also encourages rail operators to work with partners to improve the whole journey experience for passengers, including disabled passengers. But there is no equivalent scheme for transport facilities for other transport modes.

3.3 Disabled people can suffer from harassment and hate crime and this is a barrier both to themselves as travellers and to their guardians who fear for their safety. Merseytravel is an active supporter of the Stop Hate campaign through its TravelSafe. Working in partnership with Merseyside Police, Liverpool, St Helens and Wirral Councils, and the Stop Hate charity, which provides 24 hour support and information to people affected by Hate Crime. The campaign will result in 800 buses and 200 poster sites carrying the Stop Hate UK branding across Merseyside. There will also be local awareness raising events across the region.

 3.4 Merseytravel administers a small travel training programme which seeks to enable people with various disabilities to access the public transport network and increase their life choices. Learning to use the network is a rite of passage undertaken by young people. However people with learning disabilities cannot always take this route, and need additional support to access public transport. One-to-one travel support of this nature needs to be acknowledged in government policy so that it is mainstreamed and properly resourced. In addition, the inability to fund such revenue-based initiatives locally thro ugh transport capital funds from the Department for Transport is a long-standing problem, which can result in training programmes and related initiatives being reliant on short-term or bid funds, making them, "stop-start" in nature.

4. What can be learnt from transport provision during the Paralympics and how can we build on its successes?

4.1 On the lessons learnt from the Olympics/Paralympics, then it is considered that the success lay in the fact that the Olympics were planned with accessible, sustainable transport as an integral component, aided by the identification of budgets, from the outset.

4.2 This highlights the importance of integrating land use planning, service planning and transport provision, so that accessibility is planned from the inception of a project or service, not as an add-on. This will ultimately result in better, more attractive, more useable developments that are accessible to all.

4.3 The Olympics/Paralympics was also an example of a site and destination designed with sustainable transport as its primary mode, rather than being designed solely with access by car in mind. It is often the case that developments built solely around the needs of the car exclude people travelling by other modes, including public transport. This can have a disproportionate effect on people with disabilities and who do not have access to a car or private transport. Such problems then lead to the need to retrofit costly access solutions to rectify a situation (e.g. supported bus services), which is usually more expensive than making accessibility a core requirement from the outset.

4.4 A further lesson from the Olympics/Paralympics was the integration of travel and venue ticketing and information, coupled with the dedicated bus and rail services that supplemented the conventional services. Equally, the availability of fleets of motorised buggies and people movers within the Olympic Park catered for the needs of people who were disabled, elderly or infirm.

4.5 The role of the "games makers" was significant in supporting access by people with disabilities (and equally without), by making information, travel advice and directions easily available at interchanges and arrival points. The "games makers" principle could equally be applied to other major events e.g. the Commonwealth Games in 2014 and on regular basis across the transport and tourism industries as a mainstream model of delivery. This needs to be addressed as one of the legacies from the Games and as one of the great successes of the 2012 Olympics and Paralympics in London. There is considered to be a role for "games maker"-style support at travel facilities (e.g. bus, coach and rail facilities) to support passengers with information and support, and provide a friendly welcoming, and reassuring presence.

4.6 Finally, the facilities that were designed and made freely available at the Olympic venues, such as toilets, seats, rest areas and water stations, need to be recognised as major successes and lessons that can be carried into the future. Such facilities are critical determinants for many disabled people and can make the difference between having the confidence to make a journey or not.

January 2013