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Written evidence from the Guide Dogs for the Blind Association (SB LCO 3) Introduction The Guide Dogs for the Blind Association (Guide Dogs) welcomes the
opportunity to respond to this consultation.
Our vision is for a society in which blind and partially-sighted people
enjoy the same freedom of movement as everyone else, and our purpose is to
deliver the guide dog service and other mobility services, as well as breaking
down barriers - both physical and legal - to enable blind and partially-sighted
people to get around on their own. This
response is confined to the provision of concessionary fares in
1. What are your views on the general
principle that legislative competence in the areas identified in Matter 10.2 be
conferred on the National Assembly? We would support the conferring of legislative competence on the basis that the development of Measures would be subject to appropriate scrutiny, and that the concerns of blind and partially sighted people, and other vulnerable pedestrians would be taken into account. The impact of an increase in the cost of travel, when buses are often an essential link to shops, doctor's appointments, family and friends cannot be under estimated, and many blind and partially sighted people would have to restrict the number of journeys they make because of a cost they have not budgeted for in the past.
However, we would also seek reassurance that, as
stated, the aim would be to safeguard and hopefully improve the long term
sustainability of the concessionary travel scheme. There is much in this proposed Order which
points to a reduction in the flexibility and availability of the concessionary
pass, which is disappointing in view of the commitment to its continuation
reflected in the National Transport Plan for
With regard to the direct administration of the scheme by the Welsh Assembly Government, it is not clear as to how this would significantly impact on blind and partially sighted people as long as it is enhanced, or at least maintained in its present form. We would not wish to see the process for obtaining a concessionary pass become more complex, or less accessible to blind and partially sighted people, through the introduction of application forms or processes that are in any way inaccessible to them.
2. What are your views on the terms of the proposed Order? For example, are they too narrowly or too broadly drawn?
We believe that concessionary fares are essential for blind and partially sighted people and other vulnerable pedestrians for several reasons. It is often necessary, even on short routes, to use a bus either because the distance involved is too far to walk, the pedestrian environment is inaccessible to them or there is simply no other means of making the journey. They do not have independent access to their own vehicles and taxis
are prohibitively expensive. In many
areas of rural local bus is the only way to travel, and a once a week shopping trip may be the only link between a blind or partially sighted person and the community in which they live. Faced with so few options, blind and partially sighted people depend on buses much more than most, and so the proposed restriction to limit use of the pass within their own travel authority, or to areas very close by is concerning. With the closure of many local hospitals, and the fact that most people are employed in larger conurbations blind and partially sighted people who need to make essential journeys further afield will have to pay much more. It would be particularly disappointing for this restriction to the scheme to be introduced at this time; given that the UK Government extended the English minimum concessionary fares scheme to match the existing cross local authority boundary provision which the Welsh scheme has had since 2002.
For blind and partially sighted people, bus journeys require complex planning, particularly if alighting at one stop, locating and getting safely aboard another vehicle and being sure that it is stopping at the destination of choice. Currently, a proportion of buses
in visual information to passengers, but it is not consistently available and is not even an option outside of these major cities. Add to this the confidence required to maintain independence, negotiate the difficult pedestrian environment to and from the bus stop, and the threat, in these proposals, to remove free companion travel and the negative impact on blind and partially sighted people becomes very significant.
We are concerned to note the proposed limiting of the pass to off peak travel times, and making a charge for a carer or companion: It is clear from the changing demographics of Wales that this will affect a significant number of people who currently make good use of bus services, and who may rely on the help of a friend, family member or personal assistant to do so.
According to the local authority statistical returns for
The Wales Council for the Blind makes several supplementary comments of significance:
· As many as 60,000 persons or more who are eligible for registration do not appear on these records 90 % of the visually impaired population are over 65 and 75 % are over 75
With 47 % of blind and partially sighted
people in and a high proportion of that group being over 65, the value of the concessionary pass is easy to see. Reducing its scope or flexibility would significantly limit the independent safe mobility of blind and partially sighted people in
The current pilots of free rail travel on the Border Lands, distance coach service allows blind and partially sighted people to reach destinations which would otherwise be costly and very challenging. We would hope that in changing the way in which this scheme is administered, the Welsh Assembly Government would appreciate the value of this to blind and partially sighted people who wish to have the same safe independent access to destinations outside of their locality as anyone else.
Using trains obviously poses different challenges to buses, the particular dangers of stations, (of which 194 are
unmanned in a companion is sometimes essential to assist with finding the way from the bus to the train and vice versa. The National Transport Plan is committed to achieving sustainability and the
integration of transport modes in blind and partially sighted travellers, however, the complexity or unfamiliarity of the route can make the transition from one mode to the next impossible to accomplish independently. The transition between the bus and the train cannot be supported by the bus driver, or vice versa, and so the help of a companion becomes essential. Access to platforms, using ticket machines and the fear of being lost and unable to find help is a very real barrier, and the Advanced Passenger Reservation Service can only operate on manned stations. For all of these reasons being required to pay for a companion to facilitate safe travel would unfairly penalise blind and partially sighted people. Free rail travel on some journeys is a valuable asset in a rural environment where it may be impossible to make a longer journey by bus, and we would ask that the pilots are extended in line with the Welsh Assembly's commitment to improving the quality of life for all its citizens.
3 Do you have any additional comments relating to the proposed Order?
No further comment
4 Do you consider that the amendments to general exceptions to Matters, referred to on page 2 of the proposed Order and relating to field 10, would have implications for the effectiveness of any future proposed measures brought forward under Matter 10.2? If so, please explain why.
No further comment
January 2010 |