Transport CommitteeWritten evidence from the Chartered Institute of Logistics and Transport (CILT) (DAT 32)

1. The Chartered Institute of Logistics and Transport in the UK (“the Institute”) is a professional institution embracing all transport modes whose members are engaged in the provision of transport services for both passengers and freight, the management of logistics and the supply chain, transport planning, government and administration. We have no political affiliations and do not support any particular vested interests. Our principal concerns are that transport policies and procedures should be effective and efficient and based, as far as possible, on objective analysis of the issues and practical experience and that good practice should be widely disseminated and adopted.

2. The Institute has a specialist Accessibility and Inclusion Forum and a Public Policies Committee which considers the broad canvass of transport policy. This submission draws on contributions from all these sources.

Is it working?

3. Before one is able to assess whether legislation relating to transport for disabled people is “working”, it is necessary to understand what it is that the legislation is working to achieve. Whilst the most recent Government Accessibility Action Plan states that the Government’s aim is “to have a transport network where everyone can enjoy the same convenient, safe, affordable door to door journey experience when going about their day to day business”, and to focus on “increasing access to services and jobs”, there is much less clarity about how these goals are to be best-achieved and about how their achievement is to be measured. In general, it appears that the legislation focuses on achieving these goals via increasing the accessibility of the mainstream, conventional transport system. However, there is a powerful argument which says that this is only a part of what is required in order to provide meaningful mobility for disabled people, and that another important part of the answer is the provision of specialist services, such as demand-responsive door-to-door transport (or what is referred to in the US as “paratransit”). It appears to us that the legislation is potentially lacking in regard to these specialist services, and that this is a cause for concern.

4. If one assumes that the aim is to increase travel opportunities for disabled people via improving the accessibility of the transport system, we can readily identify a number of different ways in which progress towards achieving this might be measured. In general though, we believe that “hard” evidence is short in supply.

5. One set of measures might involve, for example, indicators of the accessibility of the system. There is data on the proportions of the bus and rail fleets that comply with the relevant accessibility regulations, and these show increasing proportions to be compliant. However, this is very much subject to geographical variation, particularly in relation to buses—with very high proportions of the bus fleet in London complying with the Accessibility Regulations and lower proportions elsewhere. Furthermore, an accessible vehicle is actually only as accessible as the fixed infrastructure and staff connected with it, and data on the accessibility of the fixed infrastructure and on the approach and attitudes of staff is much less available, and difficult to map on to the data on vehicles.

6. However, these sorts of measures don’t really tell us anything about the impact on people’s mobility. To properly understand whether the legislation is working or not, we need to find a measure of outcomes—how many more people can travel now as a result of the changes brought about by legislation. The decline in the percentage of disabled people experiencing difficulties in using public transport from 27% in 2005 to 22% in 2011, reported in the Government’s Accessibility Action Plan of December 2012, seems encouraging and could, on the face of it, be seen to be implying that public transport accessibility is improving. However, there may be a number of possible explanations of why fewer people are indicating that they are experiencing difficulties in accessing public transport: perhaps the make-up of the sample of respondents to the particular survey is changing over the course of time; perhaps the percentage of people trying’ to use public transport is changing over time; or perhaps peoples tolerance of “difficulties” is changing over time.

7. Likewise, the National Travel Survey (NTS) classifies those who indicate that they have difficulty going out on foot or using bus services as having mobility difficulties. The most recent data indicates that those with mobility difficulties aged 16–69 make approximately 25% fewer trips than those in the same age-group but without difficulties. Amongst those in the age-group 70+, the difference in trip numbers increases to over a third. It might be possible to infer something from trends in this data over time about how legislation is linked to such trends via its impact on the transport system, but again it is likely that the data is not sufficiently detailed and disaggregated to allow firm conclusions to be drawn from it. Another source of data could be trends in the use (or possibly take up) of pensioner and disabled persons concessionary passes, but once again our expectation is that any such trends would be open to various interpretations.

8. So whilst the indications from available data do seem encouraging, we believe that the currently available evidence is insufficient to permit firm conclusions on whether, and the extent to which, the legislation is “working”.

Is it sufficiently comprehensive?

9. We believe that the mix of legislation seems to be something of a patchwork, with different levels of coverage for different modes, and a mix of national and EU legislation. For example, vehicles, staff and fixed infrastructure are all treated rather differently from one another; bus and rail vehicles have associated accessibility regulations, whilst other transport vehicles do not. Aviation is, as we understand it, still largely not covered within the national legislation, though it is covered by EU law (as is rail).

10. The place of the pedestrian environment amongst all of this is rather unclear, despite its enormously important role as the beginning and endpoint of most journeys and the known difficulties which many disabled people encounter as pedestrians. The DFT’s own guidance on recommended walk distances for different categories of disabled people, set out in their “Inclusive Design” guidance document, indicates that the distances disabled people are typically able to walk are considerably less than what is assumed, for the purpose of designing a public transport system, about how far people will be prepared to walk to a bus stop or train station. Hence, failing to link up the features of the pedestrian environment with the features of the public transport system—as the legislation appears to fail to do—undermines the effectiveness of the legislation. Whilst there is this mis-match between recommended walk distances for disabled people and actual walk distances to public transport entry-points, there remains a strong argument for “door-to-door” (or “paratransit”) services and it appears to us that these services are largely absent from the current legal framework.

11. As well as the legislation specifically focused on transport and disabled people, elements of other transport-specific legislation and of other broader disability-related legislation also contribute to the patchwork. For example, we understand that the Law Commission’s current strategic review of taxi and private hire legislation has highlighted a number of disability-related concerns, and that the legislative changes to disability welfare payments are projected to have a number of transport-related implications.

12. Does this apparent patchwork demonstrate an inconsistency of approach (and, hence, a lack of comprehensiveness), or is it an approach that acknowledges the different contexts and requirements of different transport settings? For us, the key concern that results is that initiatives are not always joined up; ie there’s little point having a great accessible train if some of the stations served by it or the taxis available to get to/from the stations, etc are not.

How effectively is it enforced?

13. Our understanding is that enforcement responsibilities are divided between the EHRC, DFT and DCLG. In which case, we wonder if this division, of itself, is a bit of a problem, mitigating against a joined-up, comprehensive approach to enforcement. Also, with the EHRC having such a wide remit (extending far beyond the issue of disability) and, as we understand it, such a scaled back staff, its capacity is likely to be somewhat stretched. A passing knowledge of its activities gives the impression that they are not particularly active in the area of transport.

14. We believe that the Equality Impact Assessment, insofar as it serves to support the Equality Act, has a potentially useful role in the enforcement process. However, our impression is that the conduct of Equality Impact Assessments is very variable, and that they are often boiled down to being a “box-ticking” exercise, rather than a meaningful attempt to understand equality impacts of particular actions of relevant public bodies. With a heightened awareness of the usefulness of Equality Impact Assessments and more targeted guidance on how best to conduct them, we believe they could be much more effective than they are at present.

15. Two further aspects worth mentioning here are, firstly, the role of the Equality Duty as it relates to transport and, secondly, the role of procurement of transport services and infrastructure. We would not profess to be experts in these aspects, but with such significant components of the transport system being the responsibility of public bodies (whether that responsibility be to build, operate and maintain or to regulate), we would anticipate that the Equality Duty and procurement processes could have a significant impact in both highlighting legislative requirements and enforcement of access legislation in general.

The accessibility of information

16. We believe that accessibility of information is a major problem for quite a high proportion of elderly people. While many older and/or mobility impaired people have access to the internet or a computer, a reasonably high proportion don’t—and we believe that this will be a continuing problem for some time to come. For example, the Regional Partnership for Aberdeen and Aberdeenshire (NESTRANS) have recently undertaken some work on enabling people to get to health appointments, and they found that access to information was their biggest problem. They have now set up a staffed telephone information line to try to overcome this.

17. One area which we believe is often ignored is the role of libraries as an information source. For example, in East Cheshire all the local libraries have information about local bus and rail services, including all of the pocket rail timetables for all of the key routes—although, of course, to be able to access this information source (or even to know it is available) requires one to be able to access their library, which may itself be problematic.

18. It must also be acknowledged that, for disabled people, it is not only the usual information regarding times, service levels and fares that is important, but also information relating specifically to their accessibility concerns. Whilst this sort of detailed, specific information provision often seems to be lacking, there are some very good examples, such as the “Games Accessible Network” information source established for the 2012 Olympiad (though which has, since September 2012, been switched off) and “Describe-online”.

19. We believe that Social Workers and Rehabilitation Officers, as front-line staff working with disabled people, are important but often under-recognised information conduits. Not only can they serve as an information source for disabled people, advising them on specific mobility and travel issues, but they could also serve as important points of information about disabled people’s difficulties for planners and designers.

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

20. We strongly believe in the important role that staff play in providing passenger assistance, and the importance of effective training—training for staff and travel training for disabled people. This is why we decided last summer to organise a seminar focused on this subject, which is being held on 29 January at the offices of Transport For London. We would be happy for representatives of the Committee to participate in the seminar, and to provide the Committee with a report of this seminar in early February

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

21. As mentioned above, we believe that the “Games Accessible Network”, established as a network of accessible routes, with a detailed accompanying information provision, worked well during the period of the Olympics. Clearly a great deal of effort and thinking went into this initiative. If there is to be a lasting legacy from the Olympics for disabled people, one can readily imagine that a significant component of it would be based on developing this work further. It would be extremely interesting to speak to disabled people themselves about this, and to generate evidence based on the experience of the Games Accessible Network, before it fades from people’s memory.

22. It would be very interesting to talk to some of those operators involved to obtain a provider side perspective. For example, we believe Ealing CT worked with West Mids Ring and Ride to provide many of the minibuses used to provide the door to door services.

23. It would also be very interesting to compare, on the one hand, the rather bold claims made in the Olympics documentation about how many disabled people were expected to be attending the Olympics with, on the other hand, what it is possible to find out about the actual numbers of disabled people who did attend; and to understand the reasons behind any gap between the two figures.

24. As a note of caution, while there may well be some useful lessons for other Metropolitan areas, we wonder how transposable the lessons may be to less dense urban or rural areas.

January 2013

Prepared 13th September 2013