Environment Audit CommitteeWritten evidence submitted by Mencap
Background
About learning disability—A learning disability is caused by the way the brain develops before, during or shortly after birth. It is always lifelong and affects someone’s intellectual and social development. It used to be called mental handicap but this term is outdated and offensive. Learning disability is NOT a mental illness. The term learning difficulty is often incorrectly used interchangeably with learning disability.
About profound and multiple learning disabilities (PMLD)1—Children and adults with profound and multiples learning disabilities (PMLD) have more than one disability, the most significant of which is a profound learning disability. All people who have PMLD will have great difficulty communicating and many people will also have additional sensory or physical disabilities, complex health needs or mental health difficulties. The combination of these needs and/or the lack of the right support may also affect behaviour. All children and adults with PMLD will need high levels of support with most aspects of daily life.
Short Summary
Transport is very important for everyone. We all need to get from place to place so we can do lots of things such as accessing public services.
Most people with a learning disability cannot drive and half of all families with a child with a disability do not have a car.
Consequently, people with a learning disability and PMLD need to use public transport so that they can have independence, choice and opportunity.
However, many people with a learning disability and PMLD often find public transport difficult to use with transport remaining one of the biggest factors in excluding people with a learning disability and PMLD from participating fully in public life and enjoying everything their locality has to offer.
Some key transport problems faced by people with a learning disability and PMLD are physical inaccessibility, lack of accessible travel information, the cost of transport, limited/reduced availability of public transport, concerns over safety, lack of confidence and a lack of disability awareness on the part of transport staff and other transport users.
Mencap believes that transport should be safe, affordable and accessible for people with a learning disability and PMLD.
Inaccessible transport runs the risk of making public services inaccessible for people with a learning disability and PMLD.
We believe that more needs to be done to ensure that public services are as accessible as possible by public transport in order to make it easier for people with a learning disability or PMLD to access such services.
Paragraph 1: How are the Government’s current transport policies affecting the accessibility of public services? Can people get to key services at reasonable cost, in reasonable time and with reasonable ease?
We have all experienced times where public transport is too costly, delayed/cancelled or subject to unforeseen disruptions that cause frustration and undermine access to services. However, barriers relating to cost, availability and ease of access are a far more common occurrence for disabled people, many of whom have specific access requirements, limited income/finances and can often be reliant on the support of others in order to access transport. Whilst the Government has taken steps to improve accessibility to public transport and, consequentially, public services, there is still room for further progress before transport or public services can be described as truly accessible from a physical, financial, social and informational stand point.
Some of the barriers people with a learning disability experience in accessing public services as a result of the Government’s current transport policies are:
local transport service provision is being cut in some areas reducing the availability of public transport as a means of accessing public services. This is a particular problem in rural areas where alternative means of transport may be less readily available.
Many people with a learning disability, particularly those with PMLD, need the support of at least one companion when using public transport. Whilst the person with a learning disability may be eligible for concessionary travel under current Government policies, their companion(s) would not be, leading to additional costs.
Whilst the Government introduced changes to the Blue Badge scheme in February 2011, Mencap was disappointed to learn that, contrary to initial proposals, the Government rejected recommendations to extend the eligibility criteria of the scheme to include those with serious cognitive or behavioural impairments. We hope that the proposal is reconsidered in the near future.
The Government removed concessionary coach fares scheme for older and disabled people on 1 November 2011. National Express have since introduced an alternative scheme, but this provides a lower level of discount and individuals have to pay £10 a year to receive the discount.
It is important that Government transport policies make public services, including healthcare, education, employment and leisure easier for people with a learning disability and PMLD rather than creating additional and avoidable barriers.
Paragraph 2: Are other policies (such as planning, education, health, welfare and work etc) affecting the accessibility of public services and the environment?
Other Government policies are also having a detrimental impact on the accessibility of public services and the environment for people with a learning disability and those with PMLD.
Whilst the Government has protected the local concessionary fares scheme for buses, it has made other policy decisions which jeopardise the transport concessions many disabled people, including people with a learning disability, rely upon. For example, changes to Disability Living Allowance and the introduction of Personal Independence Payment threaten to jeopardise the eligibility of people with a learning disability to other concessions, such as the Blue Badge scheme. Such changes would negatively impact the accessibility of public services for people with a learning disability.
Some health services are now introducing charging for Blue Badge holders. This is expected to have a negative impact on the accessibility of such services for individuals who rely on their Blue Badge as a means of accessing such services.
Some Local Authorities are removing free home-school transport provision in their area which is impacting on some children and young people with a learning disability who rely on this service to access education. This could undermine the ability of children and young people with a learning disability accessing education which could have a knock on effect for their future employment options.
We have serious concerns that the new assessment for Personal Independent Payment (PIP), including in relation to the mobility component, will result in fewer people with a learning disability receiving support. The reduced number of people set to receive PIP also stands to have a negative knock on effect in terms of individuals’ eligibility for other travel concessions including the Blue Badge scheme, where DLA/PIP acts as a “gateway” to other support. Consideration must be given to how people with a learning disability will be able to access transport to public services if they lose their eligibility for the Personal Independence Payment. The current consultation on blue badge eligibility under PIP must take into account the specific needs of people with a learning disability, who may not be affected by physical disability but who may be unable to use public transport and need to be able to travel in a private vehicle which can be parked close to their destination. For example, people with a learning disability and behaviour that challenges: they are likely to need careful support from the person supporting them to minimise potential environmental triggers. They may not be able to travel on public transport or walk more than a short distance from their car because of the noise of traffic could cause them real distress.
Over the last few months, Mencap has been contacted by a number of individuals from different local authority areas who have raised concern about their respective councils’ proposals to revise their policies on transport provision. The proposals see local authorities pulling back from providing transport to and from community care services, with individuals being asked to make their own arrangements, primarily through DLA mobility usage. This is a huge concern. Mencap believes it is unreasonable for a council to expect a disabled person to use his or her mobility allowance to offset its liability to provide services and further jeopardises the rights of disabled people to meet their personal mobility costs that enable them to get out and about in the community.
Paragraph 3: Do decisions on the location of public services adequately reflect the public transport that is in place to allow people to access them?
Ideally, public services, especially education and health services should be accessible by public transport. In other words, they should be close to a bus stop or station so that disabled people are able to access services with ease via public transport. Decisions on the location of public services should reflect the public transport that is in place but the location of such services illustrates that this is not always the case. Mencap believe that greater efforts need to be taken to guarantee that transport is available and accessible so that people with a learning disability are able to access public services with ease.
Paragraph 4: Are environmental impacts considered when planning where to build/position public services? eg if a hospital is built far away from public transport links, do you think planners consider the environmental impact of people using cars/taxis to access it? How significant do you think this is to deciding where public services should be?
Mencap are unaware of environmental impacts being a consideration when planning where to build/position public services. However, we think this is a consideration that should be given priority in planning the location of public services as it would not only have a positive impact on the environment by reducing unnecessary use of cars and taxis but also improve the accessibility to public services via public transport links.
Paragraph 5: The Government has asked that the accessibility of public services is considered when planning local transport links, do you think this is working? Do you think that the Department for Transport has taken forward the accessibility agenda?
We don’t have the necessary knowledge on this area to comment in detail. However, it is encouraging that the Government is promoting accessibility of public services as a consideration for those planning transport links. We would hope that this recommendation was taken on board by those planning transport links as public transport is often a lifeline for people with a learning disability in accessing public services and the better the transport links, the easier it is for people to access such services with confidence and ease. This is of particular importance with regard to accessing healthcare, education and employment services given their significance for people with a learning disability and PMLD.
Paragraph 6: How should you measure how accessible a public service is by public transport?
How accessible a public services is by public transport can only truly be measured via experience. A useful way of measuring access would involve getting people of varying abilities to travel a given route to test its accessibility. It is important to emphasise and remember that a form of public transport may be accessible for someone with one form of disability, but inaccessible for someone else. For example, someone with a visible disability, such as a wheelchair user, may find their access requirements are more commonly addressed whilst someone with a hidden disability, such as a learning disability, may continue to experience barriers, such as inaccessible information or attitudinal barriers. Accurately measuring accessibility is therefore complicated by the fact that people with different disabilities encounter different barriers to accessing public services by public transport at different times- there is no standard experience. It is important to also note that there are now a number of people with complex disabilities who require non-standard wheelchairs. For example, someone with PMLD and postural support needs may have a large wheelchair with a width of maybe 1m. Often doors and wheelchair spaces don’t accommodate wheelchairs of this size. Therefore one “wheelchair user” may be able to use public transport but another one may not.
Paragraph 7: When planning transport infrastructure, do you think the social and accessibility needs conflicts with environmental considerations?
Making public transport accessible for more disabled passengers could have a positive impact upon environmental factors as it could make disabled people less reliant on private means of transportation, such as taxis or personal cars and give them the confidence to access public transport, such as trains and buses, which are more environmentally sound.
Paragraph 8: Would a measure of the transport accessibility of key public services, in a similar manner as “fuel poverty”, be useful for policy-making? If so, how do you think it should be measured?
Introducing a measurement for the transport accessibility of key public services would be useful for policy making. However, we feel that how such a measurement would work would require careful consideration and research to guarantee it adequately captures the relevant information to allow for comparative measurements.
Paragraph 9: Do you think that having broadband networks and the internet is lessening the need for transport infrastructure to access public services?
Many people with a learning disability do not have access to broadband networks or the internet at home, or may lack the knowledge to utilise these resources effectively. Access to the virtual world does not equate to access in the real world.
7 September 2012
1 For more information about PMLD see www.pmldnetwork.org