DDB 58 Joint Committee on Mobility of
Blind and Partially Sighted People
Draft Disability Discrimination Bill
Response On behalf of the Joint Committee
on Mobility of Blind and Partially Sighted People
1. Introduction
1.1 The Joint Committee on Mobility
of Blind and Partially Sighted People (JCMBPS) welcomes the opportunity
to comment on this draft bill. We have not commented on all the
contents of the draft bill but concentrated on particular areas
which fall within the remit of JCMBPS.
Comments will follow these headings:
- Introduction to JCMBPS
- The consultation process and availability
of consultation papers
- Transport Services
(clause 3)
- Public Sector:
Discrimination by public authorities (clause 4) including the
trigger for reasonable adjustments and anticipatory duty
- Public sector duties
- Councillors
- Discrimination in relation to
letting of premises
- Enforcement of the DDA
- Blue badges
- Timing
1.2 The Joint Committee on Mobility
of Blind and Partially Sighted People (JCMBPS)
JCMBPS is an independent body consisting
of representatives of the principle organisations of and for blind,
deafblind and partially sighted people with a specific interest
in access and mobility.
1.3 Figures from the 1999 DSS Research
report No.94 `Disability in Great Britain' indicate there are
now an estimated 1.97 million people with a significant sight
loss.
1.4 JCMBPS believes that blind, deafblind
and partially sighted people should be able to move around safely
and independently. This is currently often not the case and barriers
may be physical, operational or attitudinal.
1.5 The Joint Committee on Mobility
of Blind and Partially Sighted People works with Central and Local
Government, and the transport and built environment sectors, to
ensure that the requirements of blind, deafblind and partially
sighted people and other disabled people are understood and integrated.
2. Consultation Process
2.1 It has proved very difficult
to obtain copies of the draft bill in alternative accessible formats.
Some members of the JCMBPS require consultation papers in Braille
and some on tape in order to consider the papers and prepare a
response. By early January 2004 braille and tape versions of the
draft bill were in preparation but still not available and in
order to allow our members sufficient time to comment we had to
prepare our own Braille and tape versions. JCMBPS would express
strong concern about this situation, particularly given the subject
of the consultation, and urge the government to ensure that alternative
accessible formats of consultation papers are available at the
same time as print copies.
3. Transport Services
3.1 Clause 3 of the draft Bill provides
for the extension of the DDA to cover discrimination in relation
to the use of a means of transport. JCMBPS welcomes this. At present
section 19(5) DDA excludes anything consisting of the use of a
means of transport from Part III of the Act. Currently disabled
people have no right to use a bus, train or coach however accessible
it is. This was the subject of a recent consultation by the DfT
to which JCMBPS responded. A copy of this response is attached.
3.2 Access to transport is a crucial
part of daily life, and one that has been for so long difficult
or even denied completely to many disabled people. The Government
should set out the intended timetable for regulations to lift
the Part 3 exemption from transport operators as soon as possible.
JCMBPS urges the Government to bring in these regulations as soon
as possible.
3.3 The Government is not proposing
to lift the exemption on aviation or shipping yet, but to wait
to assess the impact of voluntary Codes of Practice before deciding
whether to extend the DDA to cover these services in line with
the Task Force recommendation. JCMBPS is aware of reviews being
undertaken by DfT, in which DPTAC are involved. We recommend that
early dates are set when voluntary compliance can be assessed
and that the government commits to early action if voluntary compliance
is not seen to be effective.
3.4 The full Bill is to include
an 'end date' by which all passenger rail vehicles should comply
with rail accessibility regulations in line with the Task Force
recommendation. Trains brought into service since 1 January 1999
must comply with the detailed technical standards set out in the
DDA Rail Vehicle Accessibility Regulations 1998. There is however
no requirement on any train brought into use before that time
to be accessible, or for accessibility to be improved, even when
it is refurbished.
3.5 JCMBPS has recently responded
to the DfT consultation on this, a copy of our response is attached.
JCMBPS concerns include:
- An end date by which all rail
vehicles should be accessible of 2017
- Clear guidance on refurbishment
accessibility improvement requirements to include visual and audible
passenger information
- There is particular concern
about slam door trains. The phasing out of these trains has been
put back, and members would stress the safety concerns where the
wrong door can be opened onto the track rather than platform.
Visually impaired people highlighted this concern in Travellers
Tales (RNIB 2002). Until these trains are taken out of service
an interim measure would be the fitting of centrally operated
door lock systems.
- Strong pro-active enforcement
procedures and adequate penalties for non compliance
- The opportunity should be taken
to review the current RVAR regulations, now 6 years old. There
are several features on trains where members consider the current
standards should be reviewed. Examples include the close and lock
buttons on accessible toilets which members find difficult to
locate and operate; the buttons to open doors between carriages
which are not consistently sited and therefore can be difficult
to locate; and the button to open the outer train door where members
report that when not sure which side of the train to exit they
can spend time pushing a button on the wrong door - an audible
sound to locate the button when door ready to open may help.
4. Public Sector: Discrimination by
public authorities
4.1 Clause 4 of the draft Bill makes
it unlawful for a public authority to discriminate against a disabled
person in carrying out its functions. JCMBPS welcomes this to
ensure clear application of the DDA in key areas such as the overseeing
of the highway, the conduct of elections and electoral registration.
JCMBPS has consistently called for this. The grey area of the
pedestrian environment has been a key concern.
4.2 JCMBPS considers that a well
designed and managed accessible pedestrian environment is vital
for disabled people, particularly blind, deafblind and partially
sighted people.
4.3 The RNIB has recently produced
'Travellors' Tales' (2002). Research involved qualitative surveys
of the experiences of visually impaired people and showed that
the poor condition of the pedestrian environment and poor access
to transport are major factors limiting the mobility and independence
of visually impaired people.
4.4 DPTAC, the government's advisory
committee on access in transport and the built environment, commissioned
a MORI survey into the attitudes of disabled people to public
transport (2002). The research findings show that the poor condition
of the pedestrian environment is the major cause of concern to
disabled people, and that disabled people did not consider that
those responsible for providing and operating public transport
and the pedestrian environment sufficiently understand their requirements.
4.5 It is important that this clause
provides the same level of protection and, so far as possible,
mirrors the approach contained in the DDA sections relating to
discrimination in relation to goods, facilities and services (ss19
-21). There will be many occasions in which aspects of the same
service may be covered in some respects by the general services
provision, and in other respects by this functions clause. In
other instances it may be unclear, without expert legal advice,
which provision applies.
4.6 We are concerned that on present
drafting the functions clause provides different, weaker, protection
than the services sections: in particular, it sets a very high
threshold for making reasonable adjustments, and fails to establish
an anticipatory duty. Under the Bill a reasonable adjustment is
required where an authority carries out a function and for a reason
related to the disabled person's disability the outcome of the
carrying out of the function is very much less favourable for
him than it is (or would be) for others to whom that reason does
not (or would not) apply. This creates a very high threshold
(there must be a "very much" less favourable outcome).
4.7 Currently, under Part 3 of the
DDA a service provider has to consider making a reasonable adjustment
if it is 'impossible or unreasonably difficult' for a disabled
person to access the service. This is a very high threshold. For
example, if a service provider sends a blind person a standard
print letter it is possible for a court to decide that if there
is a relative or friend who could read the letter, it is not impossible
or unreasonably difficult for the person to access the letter.
Thus a person's right to accessible information may not be guaranteed
under the current trigger.
4.8 JCMBPS recommends a harmonisation
of the triggers for reasonable adjustments. This would improve
clarity in a complex law. The DRC's legislative review proposed
a trigger of 'substantial disadvantage'. This has received support
and would help clarify the situation.
4.9 JCMBPS recommends that the wording
of the reasonable adjustments duty is amended so that it is framed
as an anticipatory duty owed to disabled persons. Service providers
are already under such a duty under Part 3 of the DDA.
4.10 Planning to make systems accessible
at an early stage always proves more cost-effective than having
to adapt them further down the line. Moreover failure to anticipate
the need for adjustments well in advance will mean that often
it will be too late to make an effective adjustment for a particular
disabled person.
4.11 JCMBPS is also concerned about
potential justifications for less favourable treatment. Proposed
s. 21D 3 allows less favourable treatment to be justified where
in the reasonable opinion of the public authority one of the specified
conditions applies. We are concerned that the reason for discrimination
can be based on wrongly held prejudices and stereotypes of disabled
people, and that, so long as such beliefs were viewed by the judge
as "reasonably" held, they could justify discrimination.
This 'subjective' standard appears to be especially inappropriate
in the carrying out of public functions. Disabled people need
to have confidence that where a public authority treats them less
favourably this is for an objectively legitimate reason.
5. Public Sector Duties
5.1 JCMBPS welcomes the inclusion of
a Disability Equality Duty for public authorities in line with
Task Force recommendations. This change will bring enormous benefits
to disabled people. All the evidence tells us it is impossible
to remove discrimination by relying solely on individuals one
by one taking legal cases to challenge acts of discrimination.
This, it is hoped, will tackle institutional discrimination and
lead to lasting cultural change.
5.2 It would be useful if the Government
set out its thinking on what specific duties it intends to apply
to which public bodies and confirm that there will be parity in
this respect with the RRAA, i.e. key public sector bodies will
be required to develop disability equality schemes (along the
lines of race equality schemes under the RRAA).
5.3 A Planning Bill is currently
going through Parliament. JCMBPS, along with other disability
organisations, has recommended that this Bill should be amended
to give a positive duty to Planning Authorities to promote social
inclusion. If amendments to the current Planning Bill are not
made we recommend that the Disability Bill considers the insertion
into the Planning Act of the duty to promote social inclusion.
6. Councillors
We recommend that the full Bill
extends DDA coverage to councillors and to all political office-holders.
7. Discrimination in relation to letting
of premises
7.1 We recommend that the full Bill
includes a provision prohibiting landlords from withholding consent
unreasonably from a disabled tenant or prospective tenant to make
changes to the physical features of the premises and explicit
provision to ensure management committees cannot unreasonably
refuse consent to disabled tenants to make adjustments to common
parts.
8. Enforcement of the DDA
8.1 In the report "Monitoring
the Disability Discrimination Act 1995" (DfEE 1999), which
looked at the type and number of claims brought under the Act
in the first few years of its implementation, the reasons highlighted
for such a small number of Part III claims being brought under
the Act included: formality and complexity of the court system;
judges' inexperience with the Act and low awareness of discrimination
issues; little or no disability awareness; and accessibility and
facilities in courts.
8.2 The difficulties in enforcing Part
III claims in the county court is supported by the findings contained
in the RNIB report "The Price of Justice" (RNIB, 2000):
the cost and complexity of bringing proceedings in the county
court are deterring disabled people who have experienced discrimination
from pursuing their claim. This deterrent effect upon applicants
is of concern not only because individuals may be deprived of
justice, but also because an absence of case law leaves many areas
of the law untested and unclear.
8.3 The DRC Legislative Review recommended
that Part III DDA cases should be enforced through employment
tribunals rather than through the Courts. JCMBPS urges the Government
to give consideration to this and other measures which may enable
the DDA to more effectively be enforced.
9. Blue Badges
9.1 JCMBPS recommends that the opportunity
is taken in the Disability Bill to consider the required legislative
changes to implement the accepted changes to Blue badge provisions.
10. Timing
10.1 JCMBPS urges the Government
to introduce the Bill proper before the end of this session -
ideally before the summer recess, and then use the new provisions
for carrying-over Bills. In this way the risk of the Bill falling
in the event of an early general election can be minimised.
10.2 It would also be useful to have
a draft timetable from the Government setting out when they aim
to implement the new duties, which duties they would wish to bring
into effect shortly after Royal Assent and how long a lead in
time they anticipate for more complex provisions and those requiring
detailed regulations. We would argue that all provisions - including
the transport regulations - should be in force and fully implemented
by the end of 2006 at the latest.
11 Conclusion
11.1 The Joint Committee on Mobility
of Blind and Partially Sighted People welcomes the opportunity
to comment and hopes that these comments are useful. We would
be pleased to provide further information on any of the points
raised in this response and/or to provide oral evidence to the
Committee.
Attached:
2 JCMBPS consultation responses referred
to in the above response -
- JCMBPS response to Department
for Transport Consultation on the Government's proposals to lift
the exemption for transport services from some of the civil rights
duties in Part III of the Disability Discrimination Act (February
2003)
- JCMBPS response to Disability
Discrimination Act 1995 Rail Vehicles: Consultation on the Government's
proposals to amend the rail provisions in Part V of the Disability
Discrimination Act (January 2004)
Carol Thomas
JCMBPS Secretariat.
Principal Policy and Research Officer,
JMU Access Partnership
Carol.Thomas@rnib.org.uk
Tel 020 7391 2002
Department for Transport Consultation
on the Government's proposals to lift the exemption for transport
services from some of the civil rights duties in Part III of the
Disability Discrimination Act
Response of the Joint Committee on
Mobility of Blind and Partially Sighted People
Introduction
1.1 The Joint Committee on Mobility
of Blind and Partially Sighted People (JCMBPS) welcomes the opportunity
to comment.
1.2 The Joint Committee is an
independent body consisting of representatives of all the principle
organisations of and for blind, deafblind and partially sighted
people with a specific interest in mobility.
1.5 Figures from the 1999 DSS Research
report No.94 `Disability in Great Britain' indicate there are
now an estimated 1.97 million people with a significant sight
loss.
1.6 The JCMBPS believes that blind,
deafblind and partially sighted people should be able to move
around safely and independently. This is currently often not the
case and barriers may be physical, operational or attitudinal.
1.7 RNIB's research "Lost Vision
- Older Visually Impaired People in the UK' found that 59% of
respondents in the study never go out alone due to difficulties
with moving about the pedestrian environment and in accessing
public transport, and frequently consider themselves to be isolated
and excluded as a consequence.
1.8 The RNIB has recently produced
'Travellors' Tales',(2002). Research involved qualitative surveys
of the experiences of visually impaired people and showed that
the poor condition of the pedestrian environment and poor access
to transport are major factors limiting the mobility and independence
of visually impaired people.
1.8 DPTAC, the government's advisory
committee on access in transport and the built environment, recently
commissioned a MORI survey into the attitudes of disabled people
to public transport. The research findings show that poor access
to transport and the poor condition of the pedestrian environment
were major causes of concern to disabled people, and that disabled
people did not consider that those responsible for providing and
operating public transport sufficiently understand their requirements.
1.9 The Joint Committee on Mobility
of Blind and Partially Sighted People works with Central and Local
Government, and the transport and built environment sectors, to
ensure that the requirements of blind, deafblind and partially
sighted people and other disabled people are understood and integrated.
Policy Statements produced by JCMBPSP include the topics of walking
strategies, local transport plans, concessionary fares, and taxis
and private hire vehicles.
2. General Issues
2.1 Transport is a particularly difficult
issue in terms of disabled people understanding their rights under
the DDA, and transport operators their duties, due to the division
between DDA duties relating to transport infrastructure, those
relating to transport services including information about services,
and duties relating to the vehicles. It is essential that the
guidance to be produced by the DRC clearly defines the rights
of disabled people, and requirements on operators, across the
whole spectrum of transport. The provision and process for complaint
and redress must also be made clear. This is a difficult issue
across the DDA requirements but is likely to be particularly fraught
with regard to transport services given the difficulty in ascertaining
who is responsible for the various parts of the service.
2.2 'Duty to provide a reasonable
alternative method of making the service accessible - not apply
where the service consists of the use of the vehicle.' (section
3.2) We recognise the difficulty with regard to the use of the
vehicle. However there is an overlap between the service consisting
of the use of the vehicle, and other aspects. For instance, where
passengers travelling by rail are transferred to continue the
journey by bus or another means of transport, this aspect of the
service should be covered and both the alternative means of continuing
the journey, and the assistance to transfer and information given
must be accessible. The lack of information as to what is happening
in problem situations is an issue of particular concern to members.
3. Guidance
3.1 We note the expectation that the
DRC should establish a project group involving central government
and industry representatives to produce the Code of Practice.
It is essential that this project group includes key credible
representatives of disability organisations. We would particularly
recommend JCMBPS, JCMD and DPTAC, and to include devolved areas,
MACS and the Access Committee for Wales. We also recommend that
the group should involve the professional sector specialising
in access issues through a not for profit access consultancy such
as JMU Access Partnership and a local authority access specialist
from the Access Association.
4. Answers to Questions highlighted
in section 2
4.1 Benefits
While these duties are introduced specifically
under the DDA it must be emphasised that improvement in access
will have far wider effects on the accessibility and attractiveness
of public transport for everyone.
4.2 Measures to complement these
proposals
The legislative requirements must be
accompanied by effective measures to raise awareness among disabled
people and the industry.
4.2.1 Disability awareness training
Disability awareness and equality training
must be of a credible standard and delivered by credible trainers.
This is an issue that the DRC has considered but we do not believe
the issue has yet been adequately addressed. Acceptance onto the
DRC register of trainers currently seems to depend on attendance
at a one day training course run by the DRC. This is not an adequate
safeguard for the credibility of this training. An effective accreditation,
monitoring and evaluation system is needed. We recommend that
an accreditation system along the lines of the National Register
of Access Consultants be established with government support.
Training must include coverage of practical
issues such as providing assistance to wheelchair users, sighted
guide training, communication and dealing with assistance dogs.
We are concerned that there may not
be sufficient quality trainers to satisfy the demand. This must
be addressed by the government working with the DRC, disability
organisations and training bodies.
4.2.2 Professional training
While the importance of training for
drivers and front line staff is clearly noted in the consultation
document there is also a requirement for access training of those
responsible for the management and operation of transport services.
This should include entry level training for new professionals
at undergraduate, graduate and other appropriate levels, as well
as CPD for current professionals. This is recognised in the European
Charters on access and training.
Research conducted on behalf of CEBE,
Centre for Education in the Built Environment, showed the poor
coverage of access issues in many university courses across the
range of transport and built environment subjects.
DPTAC has identified the shortage of
professionals skilled in integrating accessibility in transport
and the built environment as a major barrier in delivering Government
objectives for improved access. Research for DPTAC has revealed
the lack of training and resources on access for professionals
working in these areas. The Government should effectively support
DPTAC's initiatives by actively encouraging professional institutes
to set access knowledge and skills as central core requirements
for professional recognition and accreditation, and to follow
this through to university and other courses leading to professional
status.
4.2.3 Training for Disabled People
The Government and DRC must run an
effective awareness raising programme to ensure disabled people
are aware of their rights, redress and the improvements in public
transport accessibility.
Building the confidence of disabled
people who may not have used public transport, or may have had
a bad experience, will not be easy. Time and resources must be
set aside for this if we are to see an increase in use of public
transport by disabled people. This should involve the development
and implementation of an effective programme of 'travel training'
for disabled people.
JCMB is concerned at the lack of
available outdoor mobility training. GDBA research shows that
9 out of ten blind and partially sighted people have never received
any assistance, despite nearly all those who had saying it improved
their quality of life and independence.
4.2.4 Pedestrian Environment
The accessibility of the pedestrian
environment is currently a 'grey area' in terms of the DDA.
The MORI poll commissioned by DPTAC
into the attitudes of disabled people to public transport showed
that the pedestrian environment was the major concern, ahead of
other transport services. (2002)
The improvements to the accessibility
of public transport vehicles and infrastructure required under
the Disability Discrimination Act 1995, and the civil rights duties
outlined in this consultation, will be of limited value if disabled
people can not access services because of inaccessible pedestrian
links.
As the consultation document recognises,
journeys are made up of a number of links in a chain. If any
of the links in the travel chain present a barrier or risk of
personal safety then the whole journey may become impossible.
Public bodies should have a legal
duty to promote equality of disabled people. All statutory services
should be carried out in line with this duty, including highways
duties and services related to the pedestrian environment. JCMB
urges the Government to act on this, as recommended by the DRC.
4.2.5.1 Enforcement of regulations.
As noted above, transport services
are part of a wider chain of accessibility. Enforcement of regulations
relating to pavement parking and parking at bus stops would assist
in the provision of inclusive environments. If cars are parked
at bus stops and the bus cannot pull in, the service is not accessible
to disabled people. An easy answer to this would be a camera on
board the bus so that the licence number of the cars could be
recorded. This must be backed by fines and endorsement of licenses.
The practice of buses 'leapfrogging ahead' at bus stops also makes
it difficult for visually impaired people to locate the bus they
want.
4.3 Timescale
As the consultation document points
out, other aspects of transport services are already covered by
the DDA, further many transport operators already act as though
they were covered by these duties. It is clearly good practice
in terms of customer service. We therefore do not consider there
is any justification for a lead in time or any further delay in
giving disabled people their right of access to transport services.
We urge the Government to make rapid progress in the legislative
process. At the same time the awareness campaign about the new
rights and requirements should be developed and implemented by
the government and DRC, and the Code of Practice should be developed
so that a draft for consultation is ready as soon as possible
when the legislation is enacted. The awareness raising during
this period should provide sufficient lead in time for transport
operators to consider and plan for any changes required to provide
a 'reasonable' service.
4.4 Tourism and Leisure Sectors
It is difficult to understand why
the government does not propose that transport services in the
tourism and leisure sectors should be covered. Other aspects of
accessibility in these sectors are already covered including Part
3 duties.
Accessibility to tourism and leisure
activities is as important to disabled people as to non-disabled
people, and should not be regarded as less important than access
to employment, shopping, health facilities and so on.
The tourism sector has recognised
the economic necessity of providing an inclusive service and had
already taken this up before the DDA. Tourist board grants have
been conditional on access improvements since before the DDA introduction
in 1995. Similarly the health and wellbeing aspects of sport and
leisure activities meant accessibility initiatives in the leisure
industry were progressing before the DDA. It is an anomaly to
exclude transport services in these sectors.
Concerns that small scale transport
services in these sectors may fold if required to comply with
the DDA should take into account the fact that what is required
is reasonable provision and the economic as well as technical
constraints will be taken into account.
5. Specific transport services
5.1 Rail
A key issue is the requirement to book
24 hours ahead for assistance. There is a strong belief that all
disabled people should be able to travel when they wish to in
the same way as non disabled people. This is our preferred option,
however we recognise the practical issues. Whether it is decided
to keep the book ahead requirement or not, it is essential there
is absolute clarity about this. A system where disabled people
are sometimes required to book ahead and sometimes not will cause
great confusion and may result in severe consequences for disabled
people used to not having to book who travel to a different location
and find there is no assistance.
At present, even where disabled people
book ahead problems still arise and these can result in frightening
and dangerous situations. It is essential that assistance is reliable
and of good quality, and guaranteed. Failure to provide adequate
service should be penalised with appropriately severe penalties.
If the book ahead system is kept, there
should be a requirement to provide assistance to people who turn
up without booking in as much as it is possible to do so.
Flexibility must be built into the
system as people cannot always guarantee to arrive at a station
at a particular time, especially on the return journey.
We do not accept that it is not possible
to provide assistance at small stations with few staff or unstaffed.
Assistants can travel on board the train.
We are also concerned about the provision
of assistance on board a vehicle. Some disabled people may not
be able to access the catering service, or may require assistance
to carry a hot drink. How will disabled people request this service?
This is particularly an issue where it is difficult to find a
member of staff, even more difficult on crowded trains. This is
an issue for all disabled people but more so for blind, deafblind
and partially sighted people.
5.2 Buses and coaches
The provision of audible and visual
announcements is a major concern for Joint Committee members.
While this may be a feature of the vehicle, the operation of any
system, or the use of non technical provision such as the driver
calling the name of the stop is a service on board the bus and
should be addressed.
Members of the Joint Committee are
concerned about hail and ride buses. As visually impaired people
cannot see the bus approaching this service is not accessible.
5.3 Taxis
We are concerned at the continued delay
in the introduction of accessibility regulations for taxis. This
is now long overdue and we urge the government to make progress
here.
The training of taxi drivers must include
familiarity with assistance dogs.
One area of concern to visually impaired
people is the difficulty of knowing the correct cost, as the taxi
meter cannot be read. Talking meters have been researched. What
has the government done to progress this? The provision of a receipt
with taxi number recorded would help, as would the taxi number
in Braille, clear large print and tactile in the cab.
5.4 Private Hire Vehicles
We welcome the Private Hire Vehicles
(Carriage of Guide Dogs etc) Act 2002. We urge the government
to ensure there is no delay in producing the guidelines and implementing
this Act. As with taxis, the training of drivers must include
familiarity with assistance dogs.
5.5 Aviation
If the voluntary route is followed
we request clear deadline date for compliance with voluntary code
and introduction of legislative provisions if necessary.
Joint Committee members are concerned
at the practice of grouping disabled people as 'special needs
passengers' which can lead to delays and separation from other
companions.
5.6 Shipping
It is essential that the level of compliance
with DPTAC guidelines is effectively measured and monitored. A
clear deadline date must be set for compliance with voluntary
code and introduction of legislative provisions if necessary.
The carriage of guide dogs and other
assistance dogs on ferries is an issue of great concern and clear
instruction is needed to the operators on the requirements.
The impact on areas such as the Highlands
and Islands will be considerable in terms of implications for
operators and effect on disabled people of poor accessibility
because of the reliance on this form of transport. Resources should
be set aside specifically for those areas where this will have
major impact.
5.7 Breakdown services
The key issues here are information
and communication issues, particularly in the event of a breakdown.
6.0 Conclusion
Thank you for the opportunity to
comment on this consultation paper. We would appreciate feedback
on the issues in our response which will be taken forward, and
any aspects of our response that you have concerns about. Should
you require any further information or wish to discuss any aspect
of this response please do not hesitate to contact me.
Carol Thomas
Senior Policy Advisor, JMU Access Partnership
Secretariat, JCMBPS
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