1. INTRODUCTION

  1.1 The National Federation of the Blind of the United Kingdom (NFB) is the largest campaigning organisation of blind, deafblind and partially sighted people in the United Kingdom.

  1.2 The Environment Committee of the National Federation are pleased to respond on all matters relating to access, mobility, transportation and the built environment as it affects blind, deafblind and partially sighted people.

  1.3 The National Federation would like to take this opportunity to congratulate the authors of this document upon their clarity and presentation.

  1.4 There are nearly 2 million blind, deafblind and partially sighted people known to organisations' representing visually impaired people. However, the true figure is much larger, many people deny that their sight is failing for fear of losing their employment; others have age-related problems where sight loss is but one of a series of afflictions. With an aging population, set by 2030 to outnumber the working population, these figures will grow to alarming proportions. Unless the nettle of provision of integrated transport and an accessible environment is grasped now; many elderly and disabled people will be condemned to social exclusion.

  1.5 "New Deal" attempts to address the problems, however, the safe and accessible solutions will prove very costly—cheaper options will lead to social exclusion.

2. A NEW DEAL FOR TRANSPORT

2.1 Better places to live

  Revision and strengthening of planning laws is essential. Stronger measures and financial incentives to reuse existing land within towns and cities must be encouraged and promoted. The use of green field sites creates pressures upon the local infrastructure which have led to an imbalance in general provision. The future designs of housing must reflect the needs to which the housing must be put. Peaceful and tranquil, easy to access areas for disabled and elderly people. Family units which can provide for growing families, to meet their needs within the built environment for example, close to schools. Construction of parks to provide "green lungs", leisure areas, tree-lined streets to improve air quality and amenities. The use of water to provide for cooling of air in the summer heat and interest features in winter.

2.2 Local transport plans

  Are but the building blocks to a national strategy, which must be the aim. The creation of new powers for local authorities must be properly funded. The commitment that the criteria of how local powers will be used is welcome. They should however complement a county-wide, regional and national strategy. Local transport plans should create an inclusive system of transport and be complementary one to another.

  2.2.1 The key for blind, deafblind and partially sighted people is better accessible information, coupled with physical assistance at all interchanges. Both buildings, vehicles and all interchanges should reflect fully the requirements of Part III of the Disability Discrimination Act 1995.

2.2.2 Introduction of tolls and charges

  Disabled drivers, those with an Orange/EU Badge and currently in receipt of a "free" tax disc should be permitted an exemption from all tolls and charges. This exemption, should also apply to vehicles used for the conveyance of disabled people. Even with accessible transport, not all disabled people will be able to use it. Special arrangements will have to be made for adequate disabled parking spaces close to town and city centres, so that disabled people can get from their car to do their shopping, business or leisure pursuits. A statutory requirement to provide such parking, may well be necessary. Tolls and charges can blight tourism; for example in the West Country the failure to continue with the road programme will reduce business prospects and drive away visitors, further worsening employment prospects within the region.

2.2.3 Rural areas—lack of transport services

  It will never be viable to run transport services in rural and out-of-town areas. Consequently, the car will remain the only option for many people. To prevent that use would be to socially exclude them. For blind, deafblind and partially sighted people this is also true. They often live in areas which have cheaper housing, because they rely upon benefits. Without car or taxi transport they would become prisoners, excluded from society.

  Special arrangements will be needed to help rural areas and out-of-town areas. This could be done by special tax discs, special tax exemptions for using environmentally friendly cars.

2.3 More and better buses

  There should be a Strategic Bus Authority (SBA) to oversee the national provision of bus transport and ensure a national coverage. This authority would also compliment the Strategic Rail Authority (SRA).

  2.3.1 The SBA could enforce higher standards both of provision and good practice, as well as oversee the introduction of the new style DDA accessible buses.

  2.3.2 Quality partnerships should not be unusual and co-operation between transport providers and local highway authorities should be encouraged in all areas. Placing Quality Partnerships on a statutory basis will ensure that the standards of requirement of provision of accessible vehicles are met and rapidly implemented. That a national standard of awareness training for staff is developed which will benefit not only disabled people but all the travelling public as well.

  2.3.3 The Disability Discrimination Act 1995 regulations for buses and coaches is one area which should not be relaxed for any reason. It will result in higher quality buses and this will benefit all the travelling public, not just the disabled.

  2.3.4 Concessionary fares for elderly and disabled people are essential. There is a strong link between aging and disability. However for younger disabled people the problems of affordability of public transport are still a major concern, as many are unemployed and totally reliant upon benefits. The DLA Mobility Allowance does not reflect the true costs of travel, even at a concessionary rate. The RNIB Needs Survey showed that only one in four blind people of working age was in employment.

  2.3.5 Quality Contracts should establish a criteria which would reflect best practice in the United Kingdom. The National Federation look forward to consultation on this criteria, to reflect passenger needs, especially for the blind, deafblind and partially sighted.

2.4 Better railway trains

  The new SRA will enable integration across the whole railway network, as well as promoting good practice and improved passenger and goods vehicles. The SRA can also assist in attracting inward investment in better designs of track, signalling and buildings, which will lead to a higher standard of public safety, punctuality and public confidence in the system. Likewise SRA could enforce the introduction of "affordable fares" more effectively upon train operating companies, which will be the key to greater public use.

2.4.1 Fares and ticketing

  The use of area or issue of travel cards brings many benefits to rail travellers, especially those who are blind, deafblind or partially sighted. The Disabled Persons Railcard offers many benefits to disabled people throughout the railway network, the exception, so far, being The Heathrow Express Link, which refuses to accept this card. The drawbacks with the Card are that it can only be purchased from the Centre at Newcastle, unlike other nationally accepted discount cards.

2.4.2 Physical interchanges between bus and rail

  Local Transport Plans should consider interchanges and the requirements of disabled people to use them. It would be useful to establish a national standard of requirements to meet disabled and elderly peoples needs—remember by 2030 the population of retired people will outnumber those in work by three to one. The National Federation would be happy to assist in the formulation of such standards.

2.4.3 Timetables, co-ordination and stability

  In requiring a standard electronic format for information, it must be understood, that such systems must be easily convertible into accessible formats both for the blind, deafblind and partially sighted.

2.4.4 Passenger information

  Clear, comprehensive and up to date information is essential for all. The blind, deafblind and partially sighted cannot generally access the current mediums of information so it is vital that they can receive it in an accessible medium for example lack of audible announcements at stations and on trains. These are simple to overcome, for the deaf the provision of soundloops would be a cheap and simple method of enabling many of them to access information.

  It should be possible to provide a national transport information service, which could be available as part of the new digital television revolution. The setting up of a National Special Needs Service would enable disabled people to obtain information on journeys and accessible routes and book their assistance. The loss of BR databases of station information has resulted in a fragmented system, with little hard information on access to and from station. An example of good practice has been Kent County Council's "Out and About" Guide for disabled people, which gives information about access to stations and bus transport in all of its local authority areas, together with information on specialist support and help services and taxis.

2.5 Better safety and security

  Many pedestrians, especially the blind, deafblind and partially sighted are intimidated by the close proximity of cyclists who have now been permitted to use footways, as segregated only by a white line or unsegregated shared facilities. Ensuring a physical separation between cyclist and pedestrians and cyclists and other road users should be the "norm".

  2.5.1 The reduction in staffing levels at Railway and bus stations has resulted in the general public failing to use these facilities out-of-hours. All Railway and Bus Stations should be patrolled. The physical presence of station and bus staff prevents crime and gives confidence to the public to use systems. It will also create new employment opportunities which is part of this Government's election manifesto.

  2.5.2 Improvements to the lighting and security of the built environment is essential. Areas which are well lit and patrolled have found reductions in crime and vandalism.

2.6 Better Taxis

  The National Federation welcomes the proposed new Regulations under the DDA 1995 which will make all taxis accessible to all disabled people. However, the National Federation are concerned to ensure that the excuse that a guide dog is an "unclean animal", will not be grounds for refusal to carry a blind or deafblind person. In many areas of the country taxi companies are run by muslims or employ muslim drivers and this has proved a major obstacle.

  2.6.1 The vast majority of blind and deafblind people use a taxi on a regular basis to get around. Police Crime Prevention advice has encouraged this because it is door-to-door, safe and secure. Blind people are considered a "soft target" for the opportunist thief, because they are not aware of what is around them.

  2.6.2 A recent survey of our membership found that well over 65 per cent use taxis on a regular basis as the main source of transport. One hundred per cent indicated that if they could afford the cost, they would always use a taxi. Since the introduction of shared facilities for cycles, 80 per cent have begun to use taxis because they fear an accident with pedal cyclists on the footway. Ninety per cent admit that they find the cost of a taxi exceeds their mobility budget and benefits should reflect fully the true costs of daily travel by taxi.

  2.6.3 In many Scandinavian countries, according to a recent European Blind Union Survey (EBU) give blind, deafblind people between £3,200 and £5,000 a year tax free to pay for taxi fares to keep them off the footways. In the United Kingdom the average return taxi fare is £10, thus blind and deafblind people would need £5,200 per annum to cover such costs.

3. A MORE INCLUSIVE SOCIETY

  The Disability Discrimination Act 1995 has pointed the way. The implications of Part III of the DDA 1995 have as yet to be fully appreciated by Government and Local Authorities, as well as Transport Providers. The reality is that:

—  all future planning decisions must take full account of the needs of all disabled people;

—  all local authority and national cycle strategies must take full account of Part III of the DDA and of the NDC letter relating to "footways being facilities"; to ensure absolute safety and segregation for blind, deafblind and partially sighted people from all forms of vehicular traffic on the footway (including cycles, skate boards and roller blades);

—  making the built environment and all facilities totally accessible to all disabled people.

  If this is not achieved, whatever the cost, then disabled people will remain socially excluded. The ripple effect of this failure will contribute to a colossal increase in social security benefits, social service support and health service costs.

4. EVERYONE DOING THEIR BIT

  The National Federation welcomes the idea of partnerships and individual responsibility and will contribute to such consultations provided and the outcomes continue to benefit all disabled people. The National Federation expects results and a very swift implementation of Part III of the DDA by all Local Authorities. It expects additional and proper levels of funding. It would be willing to assist Government as a watchdog.

5. SUSTAINABLE TRANSPORT

5.1 Better Health

  Most blind, deafblind and partially sighted people would prefer to walk, if they could. Exercise is beneficial to good health and for those living alone, association with others is essential for good mental health. Any policy which reduces this ability would be seen as discriminatory, leading to social exclusion and placing greater, rather than lesser costs upon the State.

5.2 More jobs and a stronger economy

  The National Federation see this as an opportunity to reverse the trend to destaff railway stations and to reduce the overall staffing levels on buses. By increasing enforcement officers, police, construction of new DDA bus, train and taxi vehicles and making the built environment accessible will in itself create many new job opportunities.

5.3 Silent vehicles

  Blind, deafblind and partially sighted people are concerned at reports of electrically powered vehicles, solar cars, silent gas vehicles, pedal cycles. All such vehicles are silent and would be difficult for visually impaired people to detect. It will be necessary for such vehicles to have a "buzz" which is easily detectable from other traffic noise to indicate their approach.

5.4 Pedestrian environment

  Illustrated by the National Federation's video "Get Streetwise!", which can be obtained from our Head Office and lasts for 11 minutes, it is a must to see what problems the blind, deafblind and partially sighted face when walking on our pavements. The slogan "Pavements are for People!" says it all. Pedestrians and cyclists do not mix! When sighted people become concerned it is time to act. The National Federation have supplied with this response Press Cuttings covering a range of accidents "on the footway" from a fatal to confrontation.

  5.4.1 Within the Cycle Strategy, no mention is made of the effects of the Governments Walking Policy, or Part III of the Disability Discrimination Act 1995 (DDA1995)—the Governments intention to challenge policies which contribute to "social exclusion". The use of "shared facilities", in any form, will contribute to "social exclusion" of disabled people, especially the blind; as well as elderly people who will "fear" to go out.

  5.4.2 The Environment Committee of the National Federation of the Blind of the United Kingdom (NFB), have compiled from newspaper cuttings and information supplied by its membership, statistics relating to accidents between cyclists and pedestrians on the footway.

  The following, which covers England only, deals with the period from January 1996 to date:

Fatal accidents—1 (Tyler case Southend)

Serious accidents—426 (those that require hospital treatment)

Non serious/incidents—860 (these range from near misses to knocks)

  These figures form the "tip of the iceberg". Based upon them the National Federation have called for national statistics to be kept by the police and DETR. Existing criteria for Safety Audits are flawed, without accurate statistics, they are based upon misleading assumptions.

  5.4.3 Sussex Police Authority in a July 1998 statement, listed the third most serious public concern, as "confrontation with pedal cyclists riding on the footway". The public need to have a safe environment to walk in, "pavements are for people to walk" not to cycle upon. Cycles are vehicles and should be segregated from pedestrians at all times.

  5.4.4 After the case of R v Garner (Worthing) many Crown Court Judges are currently critical of the way in which advice has been given by DETR to Highway Authorities. They view "unsegregated pavement shared facilities" as "inherently dangerous, especially for the blind." They are also concerned, that by using part of the footway to create a cycle track, the DETR and the Local Highway Authorities are sending out the "wrong message" to cyclists about riding on the footway.

  5.4.5 Section 329 of the Highways Act 1980, gives a single definition of a cycle track; it can be either a separate highway or part of a highway. There is no distinction between those constructed from new and those converted from all or part of the footway. This definition needs to be redefined more accurately. It is confusing and has led to many incorrect and dangerous assumptions by Highway Authorities. This is the real cause of the problem and one that needs to be put right at a national level.

  5.4.6 The "broadbrush" nature of the DETR Advice Notes has merely led to further costly confusion.

5.4.7 Amendments to Road Traffic Law

  The police, through the Traffic Committee of ACPO have indicated that they are unwilling to get involved in policing cycle tracks, until such time as they are given additional funding and the law is amended in various areas to bring in:

—  Licensing of all cycles.[6]

—  3rd Party Insurance for all cyclists.

—  The offence of failing to stop and report accidents must be extended to include cyclists.

  5.4.8 Our concern is that a decision resulting from the several civil actions, currently pending, may make the use of such "shared facilities" illegal. With all the resulting problems and cost for local highway authorities, of removing them, DETR are aware that the National Organisations representing blind people, may well bring a "friendly action", under the DDA1995, to establish in Law the validity of Part III as it affects "shared facilities". What is at stake, is legally what is considered to be "reasonable".

  5.4.9 The outcome of the recent Public Enquiry in Coventry, gives a lead. Local Highway Authorities, as a result of this ruling, must ensure that blind, deafblind and partially sighted people are not placed in "confrontation with cyclists and are safeguarded".

  5.4.10 The use of pavement "shared facilities" as described in Local Transport Note 2/86, either "segregated by a delineator strip" or "unsegregated", were seen as presenting a danger to blind, deafblind and partially sighted people. DETR are currently reviewing this Note.

  5.4.11 The Raj Kumar letter sent by the National Disability Council, was in response to a question relating to a definition of "a pavement, footway or footpath; being a `facility' designed to segregate pedestrians from other forms of vehicular traffic" and confirmed that a pavement, footway or footpath, was indeed a facility under Part III of the DDA1995.

  5.4.12 The Shared Facilities Policy of the Joint Committee for Blind and Partially Sighted People of the United Kingdom (JCMB) has been amended. It now contains a Resolution which is supported by all its constituent organisations calling for the abolition of "shared facilities". This document and its Resolution can be obtained from the Joint Mobility Unit, RNIB 224 Great Portland Street, London WIN 6AA.

  5.4.13 The Pedestrians Association and the Non Motorised Policy Group, which includes Sustrans', are now calling for the removal of "shared facilities". Sustrans' has produced several leaflets relating to the relationships between pedestrians and cyclists and cyclists and disabled people. However, they are misleading and do not fully reflect the implications of Part III of the DDA1995, because Sustrans' does not agree with them and views the Act as a serious threat to the National Cycle Network.

  5.4.14 There are over 8 million disabled people in the UK, who have difficulty getting about. 0.5 million are in wheelchairs. The RNIB's Needs Survey currently states that there are in excess of 1.6 million visually impaired people, known to the RNIB and other Service Providers. However, a more realistic figure would be in excess of 2 million blind, deafblind and partially sighted people suffering from age related problems who do not bother to include "blindness" within their list of problems—they all deserve a safe pedestrian environment.

  5.4.15 Many blind, deafblind and partially people are now "fearful" to go out alone. Some who have been involved in accidents with cyclists on the footway, now refuse to go out, because they are traumatised. The cost of keeping single blind people in their own homes is £10,000 per annum, plus additional support costs borne by local and national health bodies. Such policies can be easily proved to contribute to "social exclusion".

  5.4.16 The vast majority of blind, deafblind and partially sighted people and for that matter disabled and elderly people in general would prefer to be able to walk/move safely and freely on the footway, without fear of being "brushed" by cyclists. Cyclists do not stop for pedestrians or get off their cycles, they normally "push on" through. With the predicted increase in pedestrians using footways this is a real hazard.

6. TECHNOLOGY TAKING THE STRAIN

  Whilst new technological advances can help, the National Federation feel that many simple improvements can be just as, if not more, cost effective. Many organisations "for" blind people will be offering and promoting the use of technology, which they are prepared to sell to transport providers. For example RNIB "REACT", which is a wayfinding scheme. Many blind, deafblind and partially sighted people could not afford to purchase or rent the controllers, let alone be able to use them. The fatal flaw is that there is no substitute for physical assistance, to carry bags, answer questions or ensure that you are put in the right carriage/train or on the right bus. Advice should be taken from organisations "of" disabled people—the consumers—on what technology is appropriate rather than waste scant resources on expensive gadgets which we don't need.

7. MAKING A DIFFERENCE: THROUGH A RANGE OF TARGETS

  The National Federation welcomes the Integrated Transport Commission who will oversee and monitor the new indicators to see how its policies and programmes are affecting different groups. The National Federation would like to see an indicator relating to Mobility Training of blind, deafblind and partially sighted people included. Likewise an indicator for abolition of pavement shared facilities and construction of new footways in rural areas.

8. MAKING IT EASIER TO WALK

  The National Federation welcomes the proposals to make it easier to walk and proposals set out for increasing the priority to be given to walking. Likewise the removal of street furniture and clutter, such as "A" Boards. There is a "conflict of interest" for local authorities, between the profits generated by the sale of licences for such footway use and the needs to provide a safe accessible environment for all. This area needs to be looked at closely. The need for safety provisions relating to extensions to shops, restaurants, cafes needs to be considered. A blind person blundering into a crowded seating area outside a restaurant can easily cause a fatal accident, as well as injure themselves. All extension sites should be fenced in and local authorities given powers to enforce such prudent safety measures.

  8.1 Local Authorities should be encouraged to make all existing pedestrian crossings both audible and tactile. Also to introduce tactile guidance and information on all pedestrian areas.

  8.2 The effects of Part III of the DDA1995 must be fully enforced as a footway, footpath, pavement and pedestrian area is now deemed a "facility" and must be made fully accessible and safe to all disabled people, including the blind.

  8.3 The National Walking Strategy presents an opportunity to return pavements to pedestrians and to encourage all Local Authorities to construct footways where they currently do not exist.

9. MAKING IT EASIER TO CYCLE

  The National Federation and the RNIB are both very concerned that by allowing cyclists to share footways, the wrong message has been sent out to cyclists. They seek to ensure that such shared facilities will be abolished. This is particularly important in relation to safe routes to school, where many inexperienced school children could be the cause of very serious accidents and by advocating the use of pavements the Government is aiding and abetting the commission of an offence, which sets a very poor example to young people.

  9.1 By constructing dedicated cycleways in the carriageway, which segregate both pedestrians and other motor vehicles from cyclists. The design of these cycleways should be sufficiently wide to permit overtaking and the use by tricycles. This latter vehicle seems currently to have escaped the planners, but in reality will become more common as time and other policies within the White Paper begin to take effect.

10. MAKING IT HAPPEN—THE COMMISSION FOR INTEGRATED TRANSPORT

  10.1 The National Federation welcomes the new Commission and expects it to represent the needs of all passengers including disabled passengers, in addition it would expect representation on the Commission from the Disabled Persons Transport Advisory Committee and of organisations "of" Disabled People.

  10.2 The National Federation looks forward to establishing good relations with the Commission and hopes that they will permit them to consult with them and advise them on matters affecting blind, deafblind and partially sighted people.

11. FUNDING OF TRANSPORT

  11.1 Clearly transport will require funding from the tax payer to make it affordable for all. However, local businesses may wish to join in a partnership with local transport providers to enable workers to travel, shoppers to access town shopping centres and enjoy leisure amenities. Footwear manufacturers could sponsor awards for good pedestrian design. The need for dial-a-ride and similar community services will reduce as buses become more accessible and the funding can be moved to compliment the drive for more accessible public transport.

12. REDUCING SOCIAL EXCLUSION

  12.1 For blind, deafblind and partially sighted people, the barriers to walking created by Cycle Policy is an example of a Policy directly excluding disabled people. Not being able to access information about buses and trains further contributes to exclusion. The failure of local authorities to properly consult with or provide material in accessible media is yet another example of exclusion.

  12.2 There is need for statutory compliance by all local authorities to meet all disabled peoples needs and provision. The excuse that they cannot afford the cost should be subject to punitive fines on the authority concerned. Only by such measures will disabled and elderly people see change within their community and cease to be excluded. Experience has shown that there is no other option to force change.

13. BETTER ENFORCEMENT

  Unless the suggestions set out in paragraph 5.4.7 are implemented it will be difficult to enforce many of the protections that pedestrians are now seeking. The National Federation are aware that many offences which impact upon blind, deafblind and partially sighted people are considered minor by police . . . this attitude needs to be changed.

14. WORKING TO ACHIEVE THE NEW DEAL

  The National Federation is prepared to work both with Government, Local Government and the transport providers to achieve the objectives of New Deal.