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RNIB response to the Department for Transport’s Transport Accessibility Action Plan

1. Introduction The Royal National Institute of Blind People (RNIB) promotes the interests of blind and partially sighted people and those at risk of sight loss, across the UK. We are led by a trustee board with over 80 per cent blind and partially sighted people. We have around 30,000 people in our RNIB Connect community, the vast majority of whom have sight loss. Our ambition is to change the world for those living with, and at risk of, sight loss. We take action to prevent avoidable sight loss, provide support and services to enable independence and campaign to create a fully inclusive society.

In this response you will find: Information about how we gathered our evidence and who we worked with A brief summary of our response Our response to your questions Our response to your actions A list of all of the recommendations we make (which can also be found

within the text)

2. Our evidence We have supplemented our extensive knowledge gained through transport policy and campaigns work by holding dedicated workshops and a survey in response to this consultation.

SurveyWe ran a short survey for three weeks in October and November which 636 blind and partially sighted people completed from across the UK (90 per cent of whom are based in England). A summary of our findings will be sent with this response. Where we do not provide source material as footnotes or state the source within the text, the statistics we quote will be from this piece of research.

WorkshopsWe held five workshops with blind and partially sighted people in London, Birmingham, Bristol, Manchester and Newcastle. Over 80 people attended our workshops.

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Quotes and examplesUnless otherwise stated the anonymous examples and quotes we use in this report are from our dedicated survey and workshops.

Working in partnershipWe have worked in partnership with other sight loss organisations to hold our workshops and promote our survey. We have held workshops in partnership with Thomas Pocklington Trust, Birmingham Sight Loss Council, Newcastle Vision Support and North East Action on Transport. We have also engaged with Guide Dogs as part of our response.

3. Summary3.1 What’s missing from the Action Plan? WalkingWe are disappointed that so little is included in this Action Plan in relation to walking and making walking easier for disabled people, and blind and partially sighted people in particular. We have included in our response detailed evidence of how street obstacles such as cars parked on pavements and A-boards continue to cause accidents and difficulties for pedestrians with sight loss. We also include evidence of how cycling infrastructure such as shared cycle routes and shared space in general are making parts of the country ‘no go’ areas for blind and partially sighted people. Walking and the rights of disabled pedestrians must be urgently considered not only in this action plan but more widely in guidance and regulations.

Electric vehiclesWe are also surprised to see the omission of electric vehicles from the Action Plan. As these vehicles can be silent, they pose a particular risk to people with sight loss. Although we wholeheartedly support cleaner vehicles to help the environment these vehicles need to be safe for our roads. As it is currently EU regulations which govern electric vehicles and the sound they make, it is essential that in light of Brexit the UK government introduces its own legislation that ensures manufacturers provide sensible noise options for these vehicles. We recommend that these vehicles produce a sound similar to other vehicles which cannot be switched off by the vehicle owner.

Recommendations:DfT must ensure that UK legislation makes all new electric vehicles have audible sounds which cannot be overridden or switched off by the driver;And older cars which are currently silent must have audible devices which cannot be switched off retrofitted.

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Local authorities must ensure that electric vehicle infrastructure does not become an obstacle for people with sight loss.

Driverless CarsIt is vital that the Automated and Driverless Vehicles Bill and related regulations, guidance and policies take into account blind and partially sighted people. If designed with the sight loss community in mind, driverless vehicles could bring independence to many. It is clear from our research and workshops that being unable to drive is the single biggest barrier to spontaneous transport that blind and partially sighted people face. Yet this technology could transform the lives of people with sight loss completely, but only if their use of these vehicles is planned from the start.

As pedestrians however, driverless vehicles pose a couple of risks: firstly that they are electric vehicles and so are currently silent (please see our response above in terms of silent vehicles); also, it is vital that the onboard computer systems are trialed with blind and partially sighted people, so that the vehicle’s sensors can respond to all kinds of pedestrians and pedestrians’ behaviour.

Recommendations:DfT and manufacturers must ensure that the sight loss community is involved in the development and testing of driverless vehicles.

3.2 Summary of our findingsThere are currently estimated to be more than 2 million people living in the UK with sight loss. This figure is set to double by 2050. Of the current 2 million, 360,000 are registered as either severely sight impaired or sight impaired (blind or partially sighted.) [1]

Access to transport is consistently cited as a top concern for blind and partially sighted people; forty percent of those we surveyed through our ‘My Voice’ survey in 2015 told us they were unable to make all of the journeys they wanted to. Over half told us that they needed support to get out of the house. [2]

We welcome that DfT are focusing on spontaneous travel as seventy nine per cent of people with sight loss told us that they could not travel whenever or wherever they liked. Not being able to rely on using a timetable and other transport information was one of the biggest barriers they faced, along with not being able to rely on ticket offices to be open and staffed.

We also welcome the interest from DfT in ticketing and ticket machines as only six percent of people with sight loss were able to use a ticket machine of 48

without difficulty. Over half said it was impossible for them to use a ticket machine, with thirty percent finding it difficult to use them. New, more accessible ways of providing tickets need to be developed as a priority.

Our survey and workshops have shown that blind and partially sighted people rely on transport staff for support and to enable them to travel. The way this assistance is provided and the understanding of the staff providing it is vital for it to work properly. With a trend of cutting staff from ticket offices being rolled out across the country, many passengers are concerned that they are not able to receive the level of support they need.

3.3 Our recommendationsThroughout our response we make recommendations in response to the evidence we have or the actions outlined in the action plan. All of the actions are contained in Annex One of this response. But here is a summary of the recommendations we make, which cut across themes within the action plan.

The DfT Accessibility Action Plan must be updated to include detailed sections on: Disabled pedestrians Cycling infrastructure and its impact on blind and partially sighted people The impact of shared space on disabled people Silent vehicles

All local authority, civil service and transport staff (bus, coach, taxi, rail, tram, maritime and air) must receive disability equality and awareness training. The training should include: Disabled people’s rights including reasonable adjustments (and relevant

policies such as concessionary passes and disabled person’s rail card where applicable)

How to guide a person with sight loss The different canes and their uses Guide dog policies (and pet passports for air and maritime staff) Understanding hidden impairments

DfT must urgently update both ‘Inclusive Mobility’ and tactile paving guidance, involving blind and partially sighted people in the process.

DfT must encourage transport providers, regulators and associations as well as local authorities to engage more meaningfully with disabled people, including blind and partially sighted people.

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DfT should introduce and support, through funding, universal all-day free travel for blind and partially sighted people across England; as it is in London and Scotland.

The Bus Services Act 2017 regulations should be introduced swiftly and include: Clarity that onboard information solutions mean audio and visual displays

on buses available to all Mandatory reporting on audio and visual announcement compliance on

buses by bus operators

‘Access for All’ funding must be increased by the Government and used to tackle: Tactile markings at stations Modifications to platforms where possible, to alleviate the gap between the

train and platform issue Providing audio solutions for navigation around accessible toilets

DfT, working with the Rail Delivery Group, should ensure that more stations offer ‘turn-up-and-go’, and that adequate staffing levels must are provided.

The rights of disabled air and maritime passengers need to be protected in UK law in anticipation of Brexit.

DfT should monitor guide dog refusal prosecutions. Guidance should be drafted by DfT for magistrates emphasising the

importance of fines as a deterrent Local authorities should be encouraged to prosecute when they receive a

complaint of guide dog refusals

4. Response to questions Question 1: Concessionary Bus PassWe have carried out considerable work in relation to the concessionary bus pass over the last decade, supporting blind and partially sighted people facing difficulties using them and challenging local authorities wishing to restrict their use. Fourteen per cent of calls relating to buses that we received to the RNIB ‘Campaigns Hotline’ in the last year related to difficulties with the concessionary bus pass. [3]

We completely support the concessionary bus pass and the independence it brings to blind and partially sighted people who rely on public transport. There are, however, problems with the way the bus pass is delivered by local authorities, which mean that people with sight loss are not able to benefit

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from the independence the pass brings. The issues most consistently raised by blind and partially sighted people with us are:

There is great inconsistency in the rules used by local authorities, which affect the times the pass can be used and the symbols used on the card

This means that neighbouring authorities that bus routes cut through often have different rules

Bus drivers and council staff are often unaware of the rules or confused by them - this leads to poor advice being given to customers

There is particular confusion and inconsistency in terms of companion bus passes and how they are issued, and their rules of use

We regularly receive complaints about bus drivers refusing bus passes when they should accept them - this leads to incidents of passengers being refused access to the bus and being left at the road side

Many local authorities over the last decade have made cuts to the usage policy for the pass meaning that it can only be used after 9:30am. We are opposed to this policy and have actively challenged local authorities who propose such changes. We have had some success in challenging restrictions but many local authorities now provide the minimum they are required to.

We have also worked with bus operators to increase awareness of the bus pass and its importance to blind and partially sighted people. We estimate that between 70 -80 per cent of the bus industry has now signed up to our Bus Charter [4], which includes pledging to ensure that bus drivers are aware of the relevant rules around concessionary bus passes. We still hear from bus operators that the information they receive from local authorities is not always clear and helpful.

The Government has targets around getting more disabled people into work and RNIB wants to see more blind and partially sighted people working and travelling independently, yet this policy undermines those goals. It is also a deterrent to spontaneous travel, which we expand upon in our response to question 8.

But even where councils have kept the all-day bus pass there is a real problem with bus services being cut, particularly early morning and later evening services, making it impossible for blind and partially sighted people to travel to work on public transport (which is the most cost-effective option for both the person and government, when the alternative is taxi travel either paid for privately or through Access To Work, or simply that a person with sight loss cannot work). Places most affected by these cuts to bus services are often rural where taxis are often in short supply (please see our response to action 5 on page 31). of 48

Recommendations: The Government should introduce universal, all-day, free travel for blind

and partially sighted people across England, as currently exists in London and Scotland

DfT should guide local authorities to provide clear, universal rules for concessionary passes, especially in relation to companion passes

Local authorities must be encouraged and guided to carry out better Equality Impact Assessments when planning to cut bus services - especially those running before 9:30am and after 4:30pm

Training must be provided to bus drivers and local authority staff in relation to the rules around concessionary bus passes

Question 2: Information regarding disabled people’s rights to flyingWe are concerned that if the EU regulations are not considered carefully before Brexit, and alternatives put in place, disabled people could lose their rights to air travel. It is vital that provisions against discrimination are added to UK law. In relation to this, the role of the Civil Aviation Authority (CAA) as enforcer must be strengthened. As the designated enforcement body, they are required to take measures necessary to ensure that the rights of disabled persons are respected. However, the CAA have informed us that they have no power to deal with individual complaints and that their powers only relate to “the collective interests of consumers”. This leaves a question mark over whether the UK has adequately enforced the regulation as it currently stands? Any new legislation must ensure that a proper enforcement body and/or powers are implemented.

In terms of the information available, it is on the whole easy to find via a Google search, or via airline and airport websites. Some websites provide slightly more comprehensive information than others. Similarly, some websites are easier to use and more accessible than others. It is, however, rather surprising that the Code of Practice on access to air travel is located in an archived part of the UK government website. This may give the wrong impression that the Code of Practice is out of date or no longer applicable.

There is, however, a lack of information in regards to traveling with a guide dog. This is of particular importance as we are aware of recent examples of guide dogs being forcibly removed from their owners when border officials are unsure about information held within the pet passport. The seizure of the dogs without notice can have a profound impact on a disabled person’s life and independent mobility, and it is not clear to RNIB that Border Control undertake any sort of risk assessment before quarantining the dog. In all of the cases that we are aware of, there was no risk to the public from the dog. It of 48

was usually a case of the paperwork having not been completed by the vet properly. Even where a slight risk exists, that needs to be weighed against the risk to a guide dog user of removal of the dog, and an informed decision made as to whether removal is necessary. It should always be a priority for guide dogs to be returned to their owners.

It is clear that the information for guide dog users is not adequate or accessible, and the DfT needs to give consideration to how this information (including information in the pet passport) can be improved and made accessible. There also needs to be a review of the use of these powers in respect of guide dogs by border control.

Our main concern is not about the information itself, but that the rights of disabled people outlined within the information are not adhered to by airports and airlines. When we receive complaints from blind and partially sighted people about air travel they tend to be in the following areas:

Difficulties in booking assistance Difficulties in actually locating assistance within airports Staff in general not being disability-aware or helpful The assistance being provided is not suitable - we hear of people with

sight loss being forced to use a wheelchair when they don't need to, or being left in a waiting area without any support to get refreshments or access shops and other services

Recommendations:DfT must ensure that: The rights of disabled air passengers need to be protected in UK law in

anticipation of Brexit Enforcement of disabled air passengers’ rights is strengthened and given

to a body that can enforce penalties on airlines Information relating to guide dog travel and the pet passport is

strengthened and made more accessible for guide dog owners Border staff are trained in how to respond to situations relating to guide

dogs, and in particular in carrying out risk assessments in relation to when it is and isn't acceptable to remove a guide dog from its owner.

Question 4: Issues relating to maritime travelWe have received no complaints in the last year relating to ferries and passenger boats like the Thames River Boat. We are however aware of complaints in relation to cruise ships and cruise providers. We have received complaints about people with sight loss being refused holidays on cruise ships, removed from cruises and being subject to eye tests or inspected by

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the captain of the ship to see if they are “fit to travel”; this is a clear breech of their rights and needs to be investigated and tackled.

As with aviation, we are concerned about the impact of Brexit as disabled people’s rights are currently in EU regulations. We want to ensure that blind and partially sighted people still receive the support they need when traveling by ferry, boat or cruise ship.

Recommendations: DfT needs to ensure that the rights of disabled air passengers need to be

protected in UK law in anticipation of Brexit The practices and policies of cruise ships and holiday operators need to be

investigated by DfT and or relevant government departments, and breeches in the rights of disabled people stopped.

Question 5: Onboard rail accessibility featuresOur survey found that blind and partially sighted people face many difficulties when using trains. Many spoke of the anxiety these difficulties cause them. Others said they only travel by train if someone else is able to accompany them. Others have been put off from travelling by train completely.

Audio AnnouncementsOur survey found that: 70 per cent said audio announcements are only sometimes available

onboard. 10 per cent said audio announcements were rarely available

“I often find that on more rural routes there are no audio announcements on the trains, this leads to me being very nervous between stops and having to ask fellow passengers at each stop to check that I don't miss my required destination.” - Survey respondent

It is vital that audio announcements are reliable as, unlike on a bus, passengers with sight loss cannot ask the driver to tell them when they reach their station.

Many told us that the sound level of audio announcements on trains is a big problem for them as they are often too low in sound level or the sound is garbled and distorted. Many older people have both hearing and sight loss which means that it is vital that these announcements are as clear as possible.

Lack of audio announcements are also a problem before boarding the train.46% said lack of audio announcements on station platforms was a problem. of 48

“There are a lot of unmanned stations, or stations only manned for a certain time period, navigating these is near impossible. Some of these stations also do not have audio announcements, which leaves me completely stranded; train travel is often not an option." - Survey respondent

Recommendations: We have requested that the Office of Rail and Road (ORR) include

complaints about audio announcements as part of their monitoring - we seek full confirmation that this has happened

Rail operators must undertake spot checks and mystery shopping of audio announcements to ensure they’re switched on and at a good sound level

Tactile paving on station platforms Blind and partially sighted people rely on tactile markings to indicate danger, whether that’s a flight of stairs, a road, or the edge of a platform. So when tactile markers are missing it can cause real danger for blind and partially sighted people. Many told us that they feel nervous whilst waiting on platforms generally because of the crowds and bustle.

A third of those who responded to our survey said that a lack of tactile paving on train platforms caused them difficulty when travelling by train.

Current ‘Inclusive Mobility’ guidance recommends tactile strips on platforms as well as the yellow line, but clearly there are still many platforms without tactile strips across the country. At our workshops we were told of recent incidents where passengers with sight loss had fallen on to the tracks due to a lack of tactile paving at the station edge.

Recommendations: London Underground are undertaking a tactile paving audit of all

underground stations and then installing tactile strips where they are missing - we recommend Network Rail and train operators do the same

Access for All funding must be increased and made available for tactile markings at stations

The gap between the platform and the train“On three occasions I have nearly slipped down between train and platform due to conductors ignoring me. The other side of the coin is that on a few occasions a conductor has been truly excellent. However, I now do not feel confident about using trains, particularly on local services so avoid them if possible.” - Survey respondent

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“I haven’t used the train after a really bad experience, where the gap between the train and the platform was so HUGE that my dog ended up falling between the platform and the train, it was terrifying.” - Survey respondent

Our survey found that nearly half (48 per cent) of respondents found the gap between the platform and train was a problem for them when travelling.

We are also aware of a number of blind and partially sighted people who have been injured by falling down the gap between the platform and train. We are also aware of a number of guide dogs who have been injured. Some rail companies provide ramps for passengers to use to board the train but at unmanned stations, where there is no guard on the train, this does not happen. Not all operators provide ramps for passengers with sight loss. Research carried out by DfT in 2005 contains the following passage in regards to injuries on the rail network:

“Incidents involving visually impaired passengers were significant; representing 2.6% of all incidents. Statistics provided by the Association of Train Operating Companies indicates that less than 1% of journeys are made by visually impaired people. Therefore, it would appear that they are at greater risk of having an accident.” [5]

It is unclear however what action was taken by DfT as a result of this research, as problems still persist.

Recommendations: The Rail Delivery Group (RDG), working with Network Rail, must

investigate ways to reduce injuries to blind and partially sighted people which relate to the gap between train and platform

Rail Operators must keep guards on trains so they can assist passengers when boarding and alighting at unmanned stations

Access for All funding from DfT should be increased so that Network Rail can make modifications to platforms where possible to alleviate this issue

Toilet facilities on trainsOur survey and workshops found that this was an important issue for blind and partially sighted people:

46 per cent had difficulty locating a toilet onboard a train 48 per cent had difficulties using the accessible toilet, such as finding the

lock

“The toilet door controls were nowhere to be found. My hands wandered all over the walls, around fittings, could not find any – despite announcements

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that the door was not locked - I used the toilet out of desperation.” - Survey respondent

“I once got locked into the toilet and couldn't find the buttons for opening the doors. I found a lever near the door. However, when I pulled it, I soon discovered it was the emergency stop lever. The Guard was great, but it wasn't a nice experience at the time.” – Survey respondent

A number of respondents said that they would deny themselves drinks when travelling, to reduce the need to use the toilet. It is unacceptable that disabled people have to deprive themselves like this. The main issue is that accessible toilets on trains are not consistent in design and so a person with sight loss cannot learn where the various features are, like door locks. At our focus groups a number of blind and partially sighted people spoke about how unhygienic it is to feel for door operating buttons. Many have to carry gloves and wipes because of this. Many said that toilet doors had opened on them unexpectedly. Yet there is a technical solution to this in the form of a device which can be fitted to toilets, which describes the location of key features to blind and partially sighted people.

This is not confined to onboard toilets as one of our survey respondents explained:

“I have had two horrible experiences when needing the toilet in unfamiliar stations, that now make me actively try to never need the toilet in such an unfamiliar station again. On both occasions I had passenger assistance escorting me off a train, and asked to go to the toilet, and was assured the accessible toilet was best. I am extremely uncomfortable that staff can and do open these toilet doors after I have locked them, if they believe I have taken too long in the toilet, or they hear some strange background noise as an indication I am finished and need the door opened for me. On both occasions the toilet door was opened while I was sitting on the toilet, and when I exclaimed for it to be closed, the door was only pushed to and not in fact locked again.”

Recommendation: Train operating companies must invest in audio description for their toilets

so that blind and partially sighted people can use them with ease and peace of mind

Other issues27 per cent of our survey respondents faced difficulties accessing onboard refreshment services like buffet cars. Although some spoke of good customer service where train staff brought them items from the buffet, others spoke of

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being left without refreshment. Many explained that if they left their seat there was no way for them to find it again, as seat numbering is so inaccessible.

In fact difficulty finding seats or seats being unavailable was the most frequently cited problem when respondents were asked to tell us about other difficulties they faced in the survey and at focus groups. Another issue was the accessibility of tickets which we tackle later in our response.

Recommendation: Rail operators should explore ways of making seat numbering more

accessible and introduce new accessible ways for passengers to locate their seat

Question 6: Transport providers understanding and disability awarenessThe main message from our survey and workshops is that blind and partially sighted people cannot rely on staff disability-awareness being good. There is inconsistency between staff even at the same station as to how helpful and disability aware they are. Although the majority found staff on the whole “helpful”, many said that the appropriateness of the help offered was often lacking. Many said that not knowing whether staff would be helpful caused them stress and anxiety when travelling. They could not travel with peace of mind.

Our survey findings: 21 per cent said staff were not helpful when travelling by train

Others said the issue was locating staff, with 46 per cent saying that rail staff weren't available to help when they needed them, though many suspected that staff were around but having sight loss meant that they couldn’t locate them. The issue here is the awareness of staff to approach a person with sight loss in an unobtrusive but helpful way.

At our recent workshops we heard the following:“I was guided completely inappropriately by a member of station staff. They just grabbed hold of the bottom of my cane whilst I had hold of the top and proceeded to pull me around by it!” – Survey respondent

“I was at a station using my cane when a guard yelled “Make way for the blind person!” at the other passengers. I won’t use my cane any more at stations because of this.” – Survey respondent

Conversely, we also heard examples of where staff were not just competent but made travelling a “joy” and “stress free.” This shows how important staff of 48

awareness and understanding is. It can make an enormous difference in a disabled person’s life.

“For me booked assistance is a brilliant service” - Survey respondent.

“Some staff are excellent whilst others seem to just run away from me!” - Survey respondent.

Many have excellent experiences with rail staff but most told us that this kind of service is never a guarantee.

An example of good practice that was often cited was turn-up-and-go on London Underground and Overground trains. Although not perfect, blind and partially sighted people who had used the service seemed to be happy with it. Many said it made travelling spontaneously a possibility for them where this service existed. It is important to note that many still turned up early to use the service, “just in case”, whilst others spoke of how the system can break down when being handed over to national rail services.

Recommendations: RDG to work with rail operators to ensure: All staff receive disability equality and awareness training Staff are made more visible and contactable at train stations and onboard

trains

Question 7: Levels of understanding of hidden impairments within transport industry.It is often wrongly assumed that all people with sight loss use a white cane or a guide dog. Many, however, don't use any aid or use a symbol cane only in certain circumstances, such as when in an unfamiliar place. More people are also using smart phones and navigation apps to get around, which are not obvious to others. Our survey found that: Around 20 per cent of blind and partially sighted people do not use a sight

related mobility aid. 16 per cent said they do not use any aids at all. A further 6 per cent said they used another form of mobility aid, such as

walking stick or wheelchair, which did not make their sight loss immediately obvious.

The experiences of people with sight loss who do not use mobility aids can be different to those who use a guide dog or cane, which is relevant to this question.

25 per cent of those who don’t use any aids identified as being blind (rather than partially sighted). So the lack of a mobility aid is not necessarily an indicator of the level of sight a person has.

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Those who do not use a cane or guide dog are less likely to have a disabled person’s rail card; 52% don’t (36 per cent don’t across the whole group). They were also more likely to raise signage and the visibility of departure boards as a problem at stations, with twice as many people raising this than in the whole group.

Through our survey and workshops we found that those who do not use aids are more likely to rely on other people to escort them on journeys, reporting that they have to build their journeys around others. This is also probably why fewer of them book assistance. At our workshops many spoke about station staff and bus drivers not realising they had sight loss and being questioned about why they were asking for help. Many reported that staff could be extremely unhelpful saying things like: “Just read the departure board” when they asked when the next train was; or saying “The number is on the front of the bus” when they ask a driver which bus it is.

Some chose to travel without an aid because they felt it drew unwanted attention as in the example we gave above where a train guard yelled “blind person coming through”.

Those who use white canes reported that it did not prevent ignorant behaviour from transport staff including: A Bus driver claiming he couldn’t see the white cane a passenger was

holding in front of him Staff just nodding or gesturing and not speaking, leading to other

passengers stepping in to explain Someone being told “Anyone can get a white cane, it doesn’t mean you’re

blind”

It is clear from these experiences that raising staff awareness of people with hidden impairments is a priority. Many at our workshops gave examples of good customer service outside of the transport industry, such as at John Lewis and M&S where staff seemed to be instinctively aware of how to offer and provide help regardless of whether a person is obviously disabled.

Recommendations:The Rail Delivery Group to ensure that: All transport staff receive training in hidden impairments and how to

provide help in a sensitive and accessible way They share learning from best practice customer service examples from

retail

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Question 8: Spontaneous travelIt is clear from our survey, workshops and campaigning work that spontaneous travel is something which few blind and partially sighted people can achieve. In fact at some workshops participants felt that it was an inevitable part of losing your sight; you give up your driving licence and you lose all of your independence and spontaneity. This is a terrible thing for anyone to experience. In some cases participants said they tried not to think about it because the difference between their choices and those of someone who can drive a car are just too great and upsetting. The consensus from the workshops is that being independent and being able to travel spontaneously is something which people with sight loss want very much indeed but currently rarely experience.

79 per cent of blind and partially sighted people cannot travel whenever and wherever they like.

Most of the evidence we supply in the rest of this response is about barriers which prevent people with sight loss from travelling spontaneously. But below is a summary of the barriers most commonly encountered by people with sight loss which prevent them from travelling when they want to (it is by no means an exhaustive list): Lack of accessible transport information Dangerous street obstacles and clutter on pavements A lack of safe crossing areas Tickets being inaccessible Ticket machines being inaccessible Ticket office closures reducing options to buy tickets in an accessible way Inaccessible transport infrastructure Inaccessible vehicles Lack of staff awareness Lack of staff Poor access at interchange sites

Our survey focused on some specific barriers to spontaneous travel and we found that: 68 per cent said timetables at stations and stops cannot be relied upon to

be accessible, so information has to be looked up in advance and journeys planned carefully.

66 per cent cannot rely on ticket offices being open and only 3 per cent can use a ticket machine without difficulties.

64 per cent cannot rely on staff being available to assist them. Half said they cannot rely on audio announcements being available.

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Just under half (49 per cent) have to prepare a walking route, taking into consideration safe crossing points for roads, before they can embark on a journey.

47 per cent have to make journeys around the availability of other people to assist them such as family members, friend or carers.

A workshop participant told us:“Everything takes longer when you have sight loss; It takes longer to make even a simple journey because it takes longer to walk using a cane or guide dog. It takes longer to navigate the streets including around street clutter. It takes longer because the quickest route doesn't have a pedestrian crossing so a 5 or 10 minute detour is taken so a road can be crossed safely. It takes longer to find the right bus stop. This means that simple journeys that others take for granted feel like army maneuvers for me.”

Another pointed out:“Even a service like turn up and go doesn't enable me to travel any quicker. I still turn up half an hour early just in case they don’t have any staff around. So a journey that takes someone half an hour takes me at least an hour.”

Increased impact of disruption and its effect on people with sight loss was raised as a barrier to traveling spontaneously. Train delays, route diversions on buses, and street disruption like road works, inconvenience everyone but they can make it impossible for blind and partially sighted people to travel. This is particularly because disruption is communicated poorly and in an inaccessible way to passengers with sight loss. Many said because of these kinds of disruption they would only travel when someone else can travel with them.

Some examples of this type of poorly explained disruption include: People set down off buses in strange neighbourhoods in the dark, not

knowing where they are because a bus has been diverted but they’ve not been told

Missing trains because platforms change at the last minute, or not being able to get to the other platform quickly enough

When there’s disruption, audio announcements stop and screens that can’t be read by most blind and partially sighted people are updated without audio announcements

Injuries due to street obstacles – 97 per cent of respondents to a survey in 2014 told us that they had collided with an obstacle in the last 3 months

The actual design of streets is another issue, and in particular cycling infrastructure; many people with sight loss cannot walk to places when they want to, or how they want to. Many have to plan longer routes to avoid these areas or will only walk when accompanied by another person. of 48

73 per cent of respondents to our survey said they were not confident sharing paths and spaces with bicycles.

Half avoid paths they have to share with bicycles if an alternative route is available.

27 per cent would always avoid a shared route, meaning their independence is being significantly hit if they have to avoid certain routes completely.

Recommendations for removing barriers to spontaneous travel: More accessible information needs to be provided at bus stops and

stations by local authorities RDG must ensure that more stations offer turn-up-and-go, and adequate

staffing levels must be provided Rail operators must provide more staff at stations including in ticket offices

and onboard trains Local authorities must prioritise improving the accessibility of street

infrastructure and remove clutter

Question 10: Passenger AssistMany blind and partially sighted people use passenger assist. From our survey we discovered that: 46 per cent said they found staff generally weren’t available to help at

stations if they didn't book. 64 per cent said that because they can’t rely on assistance being available

they have to book assistance in advance.

A third said that a reason they couldn’t travel when they wanted to was because passenger assistance they booked didn't turn up.

“’I’ve been left on the platform five times in the last six months at Birmingham New Street because assistance hasn’t turned up.” - Survey respondent

21 per cent said that staff who were available weren’t helpful.

“I have had a couple of train journeys recently where the assistance has worked very well. The rail operator managed a situation where a station was unmanned on my return journey that day by organising taxi transport to the next manned station. In recent months, I have requested a ramp for boarding and alighting from the train due to blindness and physical disabilities. However, on many occasions, ramps have not been available or the staff not trained to use them resulting in the constant need to explain why I need the ramp. There is a lack of awareness amongst many rail staff who, in the of 48

absence of their provision of a ramp, have insisted that I get off of the train without it which is unsafe for me and other passengers who offer to help.” - Survey respondent.

Please also see our response to Question 5 above.

It is important to stress that passenger assist, when it works, does support passengers to travel and many rely on assistance and find that largely the service is good. But many don't want to take the risk of assistance not turning up and so rely on friends or family to travel with them, which means their independence and spontaneity is severely restricted.

We welcome DfT’s commitment to the “reservation replacement project” which will lead to disabled people being able to book assistance when they book their ticket. Booking assistance was raised as an issue especially around booking complex journeys by our workshop participants. Our workshop participants also raised the following issues relating to assistance: It is often difficult to locate the assistance point within busy stations; they

are often poorly sign posted - it was suggested that blind and partially sighted people could be issued with a number they could call or text to indicate they had arrived at the station, and so be met by a member of staff rather than struggling to navigate around a station

Assistance often breaks down at points of interchange between one rail company and another - we heard examples of people being left on trains and missing connections because although one operator had provided assistance at the start of the journey, a different operator at an interchange station had not provided their side of the assistance

Please also see our response to levels of staff awareness Question 6 and earlier comments in relation to turn-up-and-go.

Some workshop attendees told us that they currently book assistance for help with problems in the station, which could be easily corrected. For example one workshop participant told us:“At one station I always have to book assistance because their platform audio announcements come so late I don’t have a chance to get to the platform in time. If the announcements were made earlier or there was a more accessible way for me to get that information accurately I wouldn’t need assistance.”

Some used apps that provide platform numbers which meant that they didn't have to book assistance at familiar stations. Many don’t have smart phones so this is not a solution which will help everyone.

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Recommendations:RDG must ensure that:

Rail staff receive disability-awareness training, including visual awareness and guiding training

Rail operators maintain staffing levels at stations that are adequate to meet the needs of disabled passengers

Quick wins need to be explored so that reliance on assistance can be reduced

Those who book assistance should be given a phone number they can call which gets them through to someone at the station, not in a call centre, on the day they are travelling

Question 11: TicketsOur survey shows that: Only 3 per cent can use a ticket vending machine without problems. 56 per cent say it is impossible for them to use a ticket machine, with 30

per cent finding it difficult.

Unsurprisingly then, only 4 per cent said they’d chose to buy a ticket from a vending machine if they were having to travel at short notice. 76 per cent would prefer to buy a ticket from a person in a ticket office and 20 per cent would prefer to buy the ticket onboard the train.

Clearly, buying tickets in person is the preferred method of buying tickets at short notice by blind and partially sighted people; yet, two thirds say they cannot rely on ticket offices being open and this prevents them from travelling when they want to.

Even when a person with sight loss buys a ticket they are not easily accessible. The accessibility of paper tickets has become a greater issue since the Rail Delivery Group issued a new ticket design two years ago, which currently is still being printed incorrectly from many ticket machines. This means that tickets which were accessible to a small number of people with partial sight are no longer accessible. In some cases, rail staff have difficulty reading and checking the tickets. Although RDG have discussed this issue with the sight loss sector, problems still persist. Our experience has been that operators blame RDG, whilst they blame operators, and nothing gets fixed.

Smart tickets on mobile phones can be accessible or made more accessible for people with sight loss, but not everyone has a smart phone. At our workshops many liked the idea of a top-up oyster type ticket which they can be in control of “topping up”, but many were worried this would not work with our current complicated rail ticketing system. of 48

Of those at our workshops who had used ticket machines, if with difficulty, many said that there were other problems with the machines such as: The types of tickets available are limited to the most expensive It is hard to add a rail card, extra passengers or select different ticket types

on the machines Many of the chip and pin devices on the machines do not have the

accessible bump on the number 5

By far the biggest problem cited about ticket machines after accessibility was that they are so frequently broken and out of service.

We also received regular complaints about the accessibility of rail operator and ticket buying websites. The inaccessibility of these websites limits blind and partially sighted people’s ticket buying choices even further.

Overwhelmingly, blind and partially sighted people want reassurance from a person when buying a ticket to make sure that they are buying the best ticket for their needs. There is a real fear that as new ticket technology is introduced, and ticket offices and staff are reduced, many people with sight loss will be excluded even further from rail travel and become less independent and more isolated.

Recommendations: DfT and Rail Deliver Group should explore a fully accessible and

consistent national system for ticketing Current issues with small print on tickets and the inconsistency in how

tickets are printed out needs to be addressed urgently by Rail Delivery Group and train operators - this has been a problem for two years and still many machines are issuing tickets which even rail staff find difficult to read

DfT needs to develop accessible vending machines The ORR needs to carry out an audit of train operating company websites

and penalise those which are not accessible

Question 12: Complaints and disputesAt our workshops blind and partially sighted people told us that they find complaining difficult, time consuming, confusing, frustrating and inaccessible. Most said that if they complained every time something went wrong with a journey they would spend all of their time complaining. This means that they generally only raise a complaint when it is very serious.

We have received a number of complaints that the delay and repay online form is not accessible for people who use screen readers. This cuts across all operators and is an industry wide issue. We have raised this with the Rail of 48

Delivery Group and train operators, but an accessible solution is yet to be provided.

Complaints procedures which used to be paper based, and so inaccessible, are now often online, which when provided on an accessible website can make it easier for those with smart phones and computers to complain, but many are on forms which are not accessible.

Our workshop participants told us that complaints relating to disability issues seem to not be well understood by customer service staff, or mainstream passenger organisations, and the wrong information is sometimes given out, leading to confusion and anxiety about travelling. An example of this from our workshop is as follows:

A customer complained that the ticket office was closed unexpectedly and they could not use the ticket machines. They were told that they should just book their tickets in advance from now on.

Complaint phone numbers are often advertised on posters and tickets that blind and partially sighted people can't see. Often the information requested by the transport operator like bus driver’s name or number, or the number of the carriage a passenger is travelling in, are not things someone with sight loss can see. We heard at our workshops how many have to ask fellow passengers to assist them in getting details of a vehicle or a member of staff, which can be embarrassing and difficult.

Many said that complaining on Twitter had become easier for those with smart phones but this is only a solution for a small number of people with sight loss.

Recommendations: Complaints processes must be made accessible and should be audited for

accessibility by the Office of Rail and Road Training in the Equality Act and passengers rights needs to be provided to

transport staff

Question 13: National Assitance CardThe consensus from our workshops was that for those who use a cane or guide dog the card was not needed as it should be clear that they have sight loss. Many felt that members of the public chose to ignore their cane or dog, but they felt those members of the public would equally ignore a card or badge.

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The 20 per cent or so of blind and partially sighted people who don’t use any visible mobility aids chose to do so for many reasons. But many said they chose to not advertise their sight loss and so would not want to use a badge or card.

We know that some people with sight loss do use cards and bus hailer type devices to indicate that they have sight loss, especially to bus drivers. In particular some older people who also used a walking stick, but not a white cane, were keen on the badge or card scheme.

Many suggested that general awareness raising campaigns from the DfT, transport providers and local authorities could help to encourage other passengers to be more considerate and kind to disabled and older passengers in general. Some mentioned a scheme in Brighton where passengers without disabilities were encouraged to wear a badge which said “Happy to give up my seat”. Although this sort of badge would not be seen by many people with sight loss, what they liked about the scheme was the emphasis being on all passengers to give up seats to anyone that looked like they needed it.

Recommendation: DfT, transport providers and local authorities should run a disability-

awareness campaign jointly highlighting issues like giving up seats for disabled passengers including those with sight loss

Question 15: Community TransportRNIB care homes’ experiences of using community transport services are mixed: some report high levels of satisfaction whilst others say it was unreliable and staff are not well trained and do not know how to guide passengers. From blind and partially sighted people we hear that there are inconsistencies across local authorities with some reporting good services, and others having difficulty using the services.

We are also aware that community transport services have been subject to cuts by local authorities in line with the wider cuts to funding within local authorities. It is important that these services are not cut; we therefore welcome Action 39 and the provision of guidance in relation to community transport.

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5. Our response to Actions Where we simply agree with an action or an action has been duplicated we have simply removed the action from the list, with the caveat that we believe that blind and partially sighted people need to be involved with the development and delivery of these actions.

Action 1: Inclusive Mobility and tactile paving guidancePlease see our separate response. RNIB’s Response to DfT’s Accessible Action Plan: (Accessible Streets and Shared Space), which we have submitted alongside this response.

Action 2: Shared SpacePlease see our separate response. RNIB’s Response to DfT’s Accessible Action Plan: Accessible Streets and Shared Space, which we have submitted alongside this response.

Action 3: Cycle Infrastructure Only 7 per cent of blind and partially sighted people said they were

confident using a path or pavement shared with bicycles. 73 per cent said they were not confident. 51 per cent would avoid a shared route with bicycles if an alternative was

available 27 per cent would always avoid a shared route with bicycles. We received 393 additional comments on bicycles, more than on the

subjects of rail and spontaneous travel. The 12th most used word within the comments was “scary”. One in five responses used words describing fear and danger. 10 per cent say they have had a collision with a cyclist. (Bear in mind that

we did not ask respondents to tell us about collisions so this figure is self-reporting without a prompt, other than “tell us about your experience”.) At our workshops we found that around a quarter of people asked said they had been involved in a collision with a bicycle, whist the majority said they had experienced near misses.

16 per cent mention the speed of cyclists being a problem.

“Sharing space with bicycles is dangerous and stressful; my balance is poor and cyclists rarely give me the space I personally need. Some cyclists expect pedestrians to leap out of their way, which I can't do safely due to the probability of falling over and the likelihood of actually moving into the cyclist’s path instead of out of it (this has happened). Bicycles are also often more or less silent and so it is difficult to know they are there. I almost had a bad accident on a shared space pavement a year or so ago. The pavement was not wide enough for both a bike and a pedestrian. The cyclist came up behind of 48

me quite fast and came past very close and my long cane bounced off one of the wheels.” - Survey respondent

Other problems mentioned were: Cyclists not using bells Shared cycle routes having no tactile and obvious delineation between

cyclist and pedestrian areas A perception that cycling on pavements, which are not designated shared

spaces, is becoming more prevalent Cyclists on the road going through red lights or failing to stop at zebra

crossings, so that conflicts and collisions are occurring on pedestrian crossings

It is clear from our research and workshops that blind and partially sighted people are being forced into conflict with cyclists more frequently since changes to the street environments including shared space and shared cycle routes. This is a situation which causes the majority of people with sight loss fear, anxiety and in many occasions has affected the journeys they make. Many told us that as well as avoiding routes, and so taking longer journeys, they rely more on other people to guide them, reducing their independence considerably.

We are extremely disappointed that the current Highways England strategy does not mention anything about people with sight loss and the effect cycling and cycling infrastructure has on them. In fact the strategy does not mention disabled people at all. The needs of disabled pedestrians needs to be a priority when local authorities are considering the need for, and impact of, cycling infrastructure. It is concerning that this Action Plan only considers the needs of disabled cyclists and not those of disabled pedestrians.

We also believe that there is a clear need for research into the behaviour and perceptions of blind and partially-sighted people when sharing routes with cyclists. We note that this was a recommendation of a literature review carried out by Phil Jones Associates on behalf of Sustrans in 2011.

Recommendations: DfT to draft guidance for local authorities on considerations they must pay

to the needs of disabled pedestrians in relation to the impact of cycling infrastructure

DfT to commission research into the behaviour and perceptions of blind and partially sighted people when sharing routes with cyclists, as recommended previously by Phil Jones Associates

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Action 4: Bus audio announcements We welcome this action and, alongside Guide Dogs and other sight loss organisations, we have been campaigning for audio announcements on buses. Audio announcements on buses make travelling easier and less stressful for people with sight loss.

It is important that the regulations are developed and enacted swiftly and that the timescales set out in them do not leave people with sight loss waiting for years for this technology to be introduced. We are aware of bus operators developing apps which track bus routes and announce stops, and although we welcome these apps if they are accessible, it is important to bear in mind that many older people and those with less money do not have access to smart phones; in addition, many people with sight loss find using them too difficult. So, in conclusion, any solution implemented by bus operators must be accessible to all passengers on the bus at any time.

Recommendations: That the regulations associated with the Bus Services Act 2017 are

developed swiftly by DfT, setting out a swift time-scale for A/V technology to be introduced

That onboard information is set out in the regulations as something all passengers can access and is not reliant on having a smart phone.

Action 5: Taxi and PHV licensing guidance In the last year around 14 per cent of the transport calls we received to our campaigns hotline were about taxis, with the majority being about guide dog refusals. It is important to bear in mind that for many guide dog users, Guide Dogs UK will be their choice to complain to, not RNIB.

We welcome this action. Again we want to see people with sight loss included in the development of this guidance. It is also vital that enforcement and monitoring of licensing authorities takes place. Research carried out by the journalist Sean Dilley in 2015 found that:

“337 licensing authorities responded to a freedom of information request as part of an investigation I ran into this issue. Over 18 months, 162 allegations of refusals to carry a guide or assistance dog were made, but only 17 drivers were prosecuted.” [6]

Enforcing the law should be a priority and more needs to be done to support guide dog users who wish to prosecute drivers. Local authorities must also do more to monitor and take action when complaints are raised with them. The

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DfT can do more to support local authorities in this area, as well as monitoring local authority compliance with their duties.

In addition to the lack of enforcement, one of the most concerning aspects in the prosecutions is the extremely low level of the compensation for victims. The current amounts being awarded by the Courts are derisory, especially given the impact that we know that guide dog refusals can have on an individual. The figures that are awarded can be contrasted with the amount that a guide dog user would receive if successful in the County Court where a service provider had refused them service because of their guide dog. The case of Purves v. Joydisc, which dates back to 2003, involved a refusal of a guide dog user at a bed and breakfast. The Court stated that £750 was the least that should be awarded for the very slightest injury to feelings, deserving of damages, caused by discrimination on the ground of disability. The Vento guidelines, which are used by the Courts and tribunal to determine levels of compensation have recently been updated to indicate that £800 is the very minimum that will be awarded in discrimination cases.

We were also somewhat concerned to see references to the work undertaken by Uber as a leader in this area as we are aware of very significant numbers of guide dog refusals by Uber drivers, and it should be noted that in the United States our sister organization, National Federation of the Blind, has been involved in a class action against the company which resulted in a comprehensive agreement which involved:

“Uber will require that existing and new drivers expressly confirm that they understand their legal obligations to transport riders with guide dogs or other service animals. Stricter enforcement policies -Uber will remove a driver from the platform upon a single complaint if Uber finds that the driver knowingly denied a person with a disability a ride because the person was traveling with a service animal. In addition, if Uber receives complaints that a driver denied a person a ride because of a service animal on more than one occasion, the driver will permanently be removed from the Uber platform regardless of the driver’s intent.Uber will also enhance its response system for complaints related to discrimination against guide-dog users, and will track detailed data on all allegations of such discrimination. Additionally, the National Federation of the Blind and its California affiliate will deploy testers over a multi-year period to evaluate Uber’s compliance with the settlement.” [7]

Clearly guide dog users should be able to request any Uber vehicle and not have to rely on drivers who have undertaken disability awareness training in order to be guaranteed carriage, as these may not always be available as quickly and may not be the cheapest option.”

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At our workshops other problems with taxis were raised, some of which we have covered in our response to your question on barriers to spontaneous travel. One of the biggest problems is the availability of taxis and their expense in rural areas. As bus routes continue to be cut, many people with sight loss are becoming more isolated. Taxis, if affordable and readily available, can enable blind and partially sighted people to live independent lives, but often outside of major towns and cities taxis have to be booked days in advance and their cost is prohibitive for regular use.

Recommendations: DfT should monitor guide dog refusal prosecutions DfT should draft guidance for magistrates emphasising the importance of

fines as a deterrent Local authorities should be encouraged to prosecute when they receive a

complaint of guide dog refusals

Action 8: Access for All fundingWe welcome the further roll-out of station access improvements but we are disappointed that the Access for All budget, after being cut in 2010, has not been increased since. Many blind and partially sighted people we spoke to at our workshops raised concerns that schemes like this focus on step-free access, which is of course an important aspect of accessibility, but it is not the only aspect of access. There are other access improvements which can be made which are often overlooked such as:

Tactile strips on station platforms Clearer signage Audio announcements Staffing levelsRNIB also welcomes the power of the ORR to take enforcement action against station providers who fail to meet current EU and UK accessibility standards. We are keen to learn more about this work and would seek further information regarding the amount of enforcement activity undertaken against providers who have, for example, failed to install tactile paving on platforms as required by Inclusive Mobility.

Recommendations: DfT should increase the Access for All budget DfT should ensure broader access improvements are rolled-out including

in Access for All funded projects

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Action 9 and 10: Accessible toiletsWe welcome this commitment but we direct DfT to our response to Question 5 in relation to making sure that accessible toilets are accessible for blind and partially sighted including having room for guide dogs, consistency with door lock placement and other features.

Action 12: Alternative journey optionsWe welcome any projects that assist disabled people, including blind and partially sighted people, to travel with more confidence, especially when there are unforeseen problems or general disruption. As we mention in our response to questions 5 and 8, blind and partially sighted people are detrimentally affected by disruption when travelling, whether this is through essential equipment being out-of-order, like audio announcements not working, or trains being delayed and cancelled. While passengers in general may be inconvenienced in these situations, for a disabled person this disruption can make travelling impossible or unreasonably difficult.

Recommendation: DfT and RDG work with people with sight loss and their organisations to

ensure that they consider the problems blind and partially sighted people face when things go wrong whilst travelling by train

Action 13: Stations Made EasyWe welcome any initiatives which make information on accessibility more widely available. Again, we recommend that you work with blind and partially sighted people and their organisations to ensure the information being shared is the most useful that it can be to people with sight loss. It is also vital that the information is accessible so that those who use magnification and voice software on computer devices can access the information. It is also important to bear in mind that although internet use by young disabled people is growing, it is still lower than among non-disabled young people. Internet use by disabled people is still lower across all age groups and is markedly different with the over-75s, with 50 per cent of non-disabled people over the age of 75 using the internet “recently”, whilst for disabled people it is only 34 per cent. [8] Considering that the majority of people with sight loss are over-60, there are many of them without internet access. For this reason, other ways of receiving accessible information about stations must be available, whether that’s over the phone or with things like tactile maps outside stations.

More also needs to be done to ensure that blind and partially sighted people know about Stations Made Easy and other access information. Train operating companies could do more to promote their services and pages like Stations Made Easy.

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We are however, concerned that the current information held by National Rail Enquiries is not up to date and reliable; for example, there is a category that says “Accessible ticket machines”, where many stations state that they have accessible ticket machines. No ticket machine that we are aware of on the UK rail network is completely accessible for people with sight loss. In fact only 4 per cent of blind and partially sighted people we surveyed said they could use a ticket machine without difficulty, and over half said that it was impossible to use a ticket machine. We assume that this category actually refers to the height of the ticket machine and whether it is accessible to wheelchair users. This needs to be made clear.

Recommendations: RDG should audit the information held about access on Stations Made

Easy Other ways of providing access information should be explored to ensure

no one is left out, including more tactile maps

Action 14: Disruption informationAgain, we welcome this action. As mentioned in our response to Action 12 and Questions 5 and 8, travel disruption has a disproportionately negative impact on blind and partially sighted people. Examples given to us at workshops by blind and partially sighted people are as follows: During disruption, a standard response by stations and train operating

companies is to advise passengers to look for information on departure boards, and announcements are switched off - this makes it impossible for blind and partially sighted people to follow what is happening

When train platforms are changed at short notice it is difficult and often impossible to get across to the platform in time without assistance, which is often not available in times of disruption

Just physically finding replacement buses is difficult when you have sight loss

If a person with sight loss is on a familiar journey they may not book assistance, but then if they are diverted or have to disembark at an unfamiliar station due to disruption they are left stranded, as they would need assistance at an unfamiliar station

Many told us that the fear of disruption itself was enough to prevent them from travelling alone by train.

So the earlier disruption can be identified, and blind and partially sighted people notified, the better, but there also needs to be a plan in place that provides support or assistance for that passenger.

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Recommendation: Build into this project a way of providing not only information but support,

assistance and advice for disabled passengers

Action 18: Train accessibility reporting. We welcome this and have raised with the ORR the importance of

including audio announcements within any such monitoring, and so would recommend the same for this.

Recommendation: The Bus Services Act 2017 regulations should include reporting on audio and visual announcement compliance on buses.

Action 22: Enforcement newsletterWe welcome this action and would like to see it rolled out to include enforcement of taxi guide dog refusal prosecutions and pavement obstructions like pavement parking and A-Boards.

Recommendation: DfT should produce enforcement newsletters in relation to guide dog taxi

refusals and pavement obstructions like A-boards and pavement parking

Action 23: Bus driver trainingWe welcome this, as the DfT is aware we have been campaigning for mandatory disability awareness training for bus drivers for some time now. We want to see blind and partially sighted people and their organisations involved in this work, as well as DPTAC and the bus industry.

RNIB has run a successful bus campaign over the last 5 years which has seen us hold over 70 ‘Swap With Me’ events across the UK. The Minister for Transport in 2013 launched our Bus Charter which set out 13 commitments bus operators can make to ensure bus travel is better for people with sight loss. Since then, the UK’s big 5 bus operators have signed up to our charter, and with many smaller regional operators also pledged to our charter we believe between 70 – 80 per cent of the UK bus industry is now signed up to our Charter.

Our experience working with the bus industry on these issues is invaluable for an initiative like this, and we gladly offer our expertise in this area to DfT.

Action 24: Rail staff trainingPlease see our response to questions 5,6,7,8,10,11 and 12.

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Recommendation:All rail staff must receive disability equality training.

Action 25: driver trainingAs this is now a legal requirement (since April 2017), we would expect DfT to do more to ensure that training is of a good standard, and to monitor that it is taking place and, where not, that enforcement happens. Many of the people who attended our workshops spoke of how taxi drivers were completely unaware of how to assist or even speak civilly to them. Although many had good experiences with taxi drivers the consensus was that many taxi drivers were not disability-aware, and in particular not aware of sight loss.

Recommendation: DfT sets out standards for disability awareness training for taxi drivers DfT monitors delivery of training and carries out enforcement work where it

is not taking place

Action 30: Disabled people’s rights and making complaintsWe welcome this action and welcome the introduction of the transport ombudsman, but believe the action should go further.

We received 247 calls to our Campaigns Hotline about transport rights in the first 6 months of this year, when we were not running any particularly active transport campaigns. Our experience is that although many blind and partially sighted people know they do have rights under the Equality Act 2010, they do not know practically how those rights apply. In fact, workshops we have held for this consultation and previous ones relating to buses have shown that blind and partially sighted people want more support in asserting their rights and understanding them.

Those who attended our workshops said that they often encounter contradictory advice from transport providers in regards to their rights. This is often in relation to not the Equality Act itself, but transport regulations. Some examples of poor advice or confusion we have come across are:

A national bus operator training staff in one region that it was “discriminatory” to ask a person with sight loss if they needed help

Guide dog users being told that the wheelchair space on a bus could not be used by a guide dog, and only wheelchair users

Rail staff insisting a person with a guide dog showed them their disabled persons rail card, even though it was inconvenient and difficult for them to do so

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Another guide dog user being told they don't need a disabled person’s rail card because they had a guide dog

Although lack of awareness from transport staff appears to be common, blind and partially sighted people tell us that they face severe difficulties when trying to complain. Some examples are as follows:

Pay and repay website is inaccessible to those who use screen readers - this seems to apply to all rail operators as they use the same web template

Bus operators advertise feedback phone numbers on posters and bus tickets that people with sight loss can’t read

When passengers do complain, they are asked for information that is impossible for them to see, such as the number of the train carriage they are in, the number or name of the member of staff, or the vehicle number

A lot of our work with bus operators who sign up to the Bus Charter has been around making complaints systems and policies more user-friendly for blind and partially sighted people.

Understanding your rights and being able to complain is useless if disabled people cannot challenge discrimination in the courts. We provide legal advice to blind and partially sighted people who have faced discrimination when using public transport and travelling, and have had success in a number of cases in the areas of:

Shared spaces Bypass bus stops Audio announcements on buses The gap between the train and the platform Rail passenger assistance failures Inaccessible transport websites Refusals on ferries

Unfortunately we do not have the resources to support all of the discrimination cases we hear about, and there are few other organisations in a position to support people with sight loss achieve justice. This situation has become considerably worse in the last 7 years, and we want to see the DfT and the UK government make it easier for disabled people to challenge discrimination.

We will be feeding in our views to the LASPO review on the availability of legal aid, and the potential deterrent of costs risks on an individual’s ability to seek redress.

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Recommendations: DfT and relevant transport bodies provide clearer accessible information

about disabled people’s rights when travelling DfT and ORR to audit transport providers complaints procedures to ensure

they are accessible and fit-for-purpose for disabled people

Action 32: Disabled Persons Rail CardWe welcome this action. Our survey discovered that: 35 per cent of respondents did not have a disabled person’s rail card Over a quarter of those who didn't have a disabled person’s rail card were

not aware of what it was. A further 10 per cent said they did not know how to apply for one.

For those who are partially sighted, the percentage of those who do not have a disabled person’s rail card was 45 per cent, and over a third were not aware of the card.

We were surprised by these figures and believe it demonstrates that much more can be done to promote the card. It is vital that any promotional materials are accessible to blind and partially sighted people, and we are keen to work with you to ensure that as many blind and partially sighted people know about the disabled person’s rail card as possible.

Recommendation: DfT, RDG and ORR work with RNIB to reach more blind and partially

sighted people Ensure any promotional materials are accessible to people with sight loss

Action 33: Travel TrainingWe welcome this action. The consensus from our workshops was that travel training and mentoring were not widely available. Those who had taken part in schemes, like the one run by Transport for London, had mixed opinions. Those who took part in the travel training said they found it useful and helpful at boosting their confidence. Whilst others said that the training only focused on limited journeys and couldn't take into account things like street obstacles and disruption, and it was these unforeseen problems that caused them the most difficulty.

But this type of travel training is not of much use to those still waiting for mobility training and general support when they either are diagnosed with sight loss or their level of vision changes. We know from our ‘State of the Nation: Eye Health 2016’ research that only 30 per cent of people say they are offered mobility training in the first year after being registered as blind or

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partially sighted. At our workshops, we heard how waiting for mobility training can be unreasonably long, and many felt that once they had their initial training they were “forgotten” or “abandoned”, and had to just get on with it. Others spoke of how when there were new developments in their area or their sight deteriorated they had to wait very long periods of time for extra training. Others had not received any mobility training for a very long time, especially those diagnosed with their eye condition when young.

Recommendation: Funding should be provided by DfT to develop travel training and mobility

training to be delivered locally, in a partnership between local authorities, transport authorities and providers.

Action 34-35: Losing your driving licence and Mobility CentresWe have grouped these questions to respond to them together.

At the workshops we held, people with sight loss spoke openly about what it was like being diagnosed and as a subsequence losing their driving licence. Everyone’s sight loss journey is different. Some have eye conditions which deteriorate slowly, giving them time to prepare for losing their ability to drive safety, whilst others may lose their sight quite quickly. One thing that the people we spoke with were clear about was how traumatic having their driving licence taken from them was. For some it symbolised a point of no return in the deterioration of their sight, whilst for others it was a sudden blow they hadn’t or couldn’t prepare for.

One participant spoke of how having his driving licence taken from him was like being given a diagnosis of cancer, he felt that his life was over because he would lose so much independence. He explained that it took a number of years to become independent using public transport. His experience is not unusual for those who lose their sight as adults. Participants were in agreement that it was an extremely traumatic thing to go through. They were also in agreement that currently there is not enough support for people losing their sight; many described how they were left to work out everything out for themselves.

Therefore, any service designed to support people going through the trauma of having their drivers licence taken from them needs to be sensitive and supportive. The consensus from workshop attendees was that Mobility Centres, as they currently exist, are not the place to help people who are unable to drive due to sight loss. Many felt it would be insensitive and uncomfortable to have to visit a Centre where the main focus is driving and cars. There was also concern that currently some of these Centres are

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situated in places not easy to get to by public transport, as they’re designed as somewhere you drive to.

What is clear is that people losing their sight want better support in all areas of coming to terms with their disability. This ranges from emotional to practical support. However, this support needs to be delivered somewhere that is accessible and in some cases will need to be delivered at or near the person’s home. The advice will also need to be long-term, as many described how long it took them to come to terms with their sight loss and gain confidence; it is not something that can be rushed. Many spoke of wanting support initially with simple tasks around the home and their local neighbourhood. Sometime later, they may want further support with making journeys and options to go further from home.

Recommendations: DfT must ensure that support and advice is provided to people with sight

loss when they lose their ability to drive safely Advice and support needs to be local, and either available at home or

easily reached by public transport - ideally for someone newly diagnosed, transport should be provided by the Centre providing advice

The place providing advice and support should not be at a Centre where other people are driving cars

The support and advice should not be a one-off session, but something available for as long as the person needs it as they move through their sight loss journey

Support should be both practical and emotional Wherever possible, blind and partially sighted people who have been

through similar experiences should provide at least some of the advice and support

Action 37: Mobility scooter trainingWe welcome this action. It is vital that this training takes into account those who use mobility scooters who also have some sight loss. Training centres need to be somewhere accessible to those who don’t drive and also include, where appropriate, using public transport.

Our survey and workshop also indicated that sharing a pavement with mobility scooters can be difficult for people with sight loss, in a similar way to sharing the pavement with cyclists is. So it is essential that any training includes a section on being aware of blind and partially sighted pedestrians.

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Recommendation: DfT must ensure that training includes awareness of blind and partially

sighted pedestrians and is accessible to those using mobility scooters who have partial sight

Action 39: Traffic Regulation Orders for pavement parkingWe welcome this action and have been campaigning alongside other sight loss organisations like Guide Dogs for improvements in legislation and regulations to tackle pavement parking.

In our 2014 ‘Who Put That There!’ survey, 71 per cent of respondents said that in the previous three months they had collided with a car parked on the pavement. Of those who had a collision on the street with a parked car, a third had been injured in some way.

It is also worth noting that parking on paving does not just affect blind and partially sighted people, but many other pedestrians too. In a survey we carried out in 2014 with people who do not have sight loss, 87 per cent said that in the last three months cars parked on pavements had caused them difficulties getting around; it was in fact the biggest difficulty cited. Many of those who responded were parents with small children or using buggies, older people with mobility impairments, and wheelchair users; however, many of those who had no obvious impairment still found cars parked on pavements a nuisance.

It is also important to bear in mind that vehicles parked on pavements cause damage to pavements, which can in turn cause pedestrian accidents and cost local authorities in maintenance.

Our campaigners have worked locally with police and local authorities on this issue with some success. They have used a range of tactics including Traffic Regulation Orders. We have found that TROs work most effectively when applied to a large area, like a whole town or a whole authority area, otherwise they can be time-consuming and bureaucratic to deploy. Consideration should also be given to the fact that TRO’s can lead to more street furniture/ obstacles, as signs are erected on streets. We would be happy to share our experience with DfT to assist with this work.

Recommendation DfT should bring in a ban on pavement parking across the whole of

England, as currently exists in London, and will soon exist in Scotland

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Action 40: Research into the experience of people with cognitive, behavioural and mental health impairmentsWe welcome this. Sight loss is often associated with neuro-diverse conditions like autism, and also with learning disabilities, and so should be considered along side these other hidden impairments within the research.

Recommendation: DfT should ensure that the impact of sight loss on neuro-diverse conditions

and learning disabilities is considered within this research

Action 41: Research into social and economic benefits of accessible transport for disabled peopleWe welcome this. It is vital that this research looks at the impact transport access has on employment levels. Research from Papworth Trust in 2016 found that a third of disabled people cited lack of accessible transport as a barrier to finding employment. It is clear from our work with blind and partially sighted people that they want to be able to travel more frequently and as independently as possible. Enabling them to do this will enable people with sight loss to live active lives, working and contributing to their local communities, as well as enjoying leisure activities.

It is important to address the problem of local transport cuts. It is no good having accessible buses and trains if they do not run at times which enable blind and partially sighted people to participate in society. Our workshops certainly highlighted problems with bus routes being cut, taxis not being available and too expensive, and even cuts in local train routes. One example given was that the trains running between Durham and Newcastle have recently been cut so that it is no longer possible for people to visit the theatre in Newcastle and get a train back to Durham afterwards.

Action 46: Learning from the Welsh governmentWe welcome this action in that it is always advisable to learn from other initiatives and share good practice. RNIB Wales, however, feels that these powers in Wales have had a limited practical impact on the lives of disabled people.

Action 47: Promoting awareness of the equality dutyAgain, we welcome this action. We have been concerned at the number of access panels, disability involvement groups, and access officer roles that have been lost or reduced in local authorities. In a Freedom of Information request we carried out in relation to streets in 2014, it was noticeable that those local authorities that had involvement mechanisms in place had greater

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awareness of their duties under the Equality Act. For example, of the local authorities that had evidence of involving disabled people in their work, 70 per cent said they measured the impact of planning decisions on disabled people, whilst the figure for local authorities as a whole was 49 per cent.

It is important that DfT and local authorities recognise that their responsibilities under the Equality Act do not end with compliance with the Equality Duty. The substantive provisions of the Equality Act apply and need to be considered particularly in relation to the anticipatory duty.

6. Conclusion and contact informationAlthough we are overall in favour of the actions within this action plan, there are many areas where the Department of Transport can go further. We are concerned that so many of the previous action plans have not been met, and the delays to Inclusive Mobility and tactile paving guidance in particular. We are concerned by the lack of involvement of disabled people in the actions as they are set out in this action plan. There are some serious omissions from this action plan, most notably addressing walking and the experiences of disabled pedestrians and silent cars.

Please contact:Dr Catherine DennisonSenior Manager Policy and Research RNIB Advocacy Team105 Judd StreetLondonWC1H 9NETel: 020 3829 2914Mob: 07711 187999Email: [email protected]

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Annex One: RecommendationsRecommendations are grouped by theme.

What’s missing from the Action Plan?The DfT Action Plan must be updated to include detailed sections on: Disabled pedestrians Cycling infrastructure and its impact on blind and partially sighted people The impact of shared space on disabled people Silent vehicles

Training Training for staffAll local authority, civil service and transport staff (bus, coach, taxi, rail, tram, maritime and air) must receive disability awareness training. The training should include: Disabled people’s rights including reasonable adjustments (and relevant

policies such as concessionary passes and disabled person’s rail card) How to guide a person with sight loss The different canes and their uses Guide dog policies (and pet passports for air and maritime staff) Understanding hidden impairments

Travel training Funding should be made available by DfT to develop travel training and mobility training for blind and partially sighted people, to be delivered locally in partnership between local authorities, disability organisations, transport authorities and providers.

Training for scooter usersDfT must ensure that any training includes awareness of blind and partially sighted pedestrians, and is accessible to those using mobility scooters who have partial sight.

Guidance DfT must update both Inclusive Mobility and tactile paving guidance urgently, involving blind and partially sighted people in the process.

DfT must ensure that the guidance is promoted extensively and it is monitored to encourage compliance.

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Research DfT must commission research on the impact that cycling infrastructure and shared space schemes have on blind and partially sighted people. The research must be from a ‘social model’ perspective, and people with sight loss must be involved.

DfT must ensure that the impact of sight loss on neuro-diverse conditions and learning disabilities are considered within the research considering the experiences of people with cognitive, behavioural and mental health impairments.

Travel informationTransport operators and local authorities must provide more accessible travel information, including timetables at stations and stops.

DfT, transport providers and local authorities should run a disability awareness campaign, jointly highlighting issues like giving up seats for disabled passengers including those with sight loss.

Bus Travel DfT should introduce, and support through funding, universal, all-day, free travel for blind and partially sighted people across England, as exists in London and Scotland.

Clear, universal rules for concessionary bus passes should be introduced, especially in relation to companion passes.

Local authorities must be encouraged and guided to carry out better Equality Impact Assessments when planning to cut bus services, especially those running before 9:30am and after 4:30pm.

Bus services ActThe Bus Services Act 2017 regulations should be introduced swiftly and include: Clarity that onboard information solutions mean audio and visual displays

on buses, available to all Mandatory reporting on audio and visual announcement compliance on

buses by bus operators

Rail Access for All fundingAccess for All funding must be increased and used to tackle:

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Tactile markings at stations Modifications to platforms where possible Consistency in accessible toilet layout

Audio announcements We have requested that the ORR include complaints about audio announcements as part of their monitoring. We seek full confirmation that this has happened.

Rail operators must undertake spot checks and mystery shopping of audio announcements, to ensure they’re switched on and at a good level.

Tactile pavingLondon Underground are undertaking a tactile audit of all underground stations and then installing tactile strips where they are missing. We recommend Network Rail and train operators do the same.

Gap between train and platformThe Rail Delivery Group (RDG) working with Network Rail must investigate ways to reduce injuries to blind and partially sighted people that relate to the gap between train and platform.

Rail Operators must keep guards on trains so they can assist passengers when boarding and alighting at unmanned stations.

Staffing Guards should remain on trains so they can assist passengers when boarding and alighting at unmanned stations.

Staff must be made more visible at train stations and onboard trains.

More staff should be available at stations, including in ticket offices and onboard trains, to assist disabled people.

Rail operators must ensure that staffing levels are adequate to meet the assistance needs of disabled passengers.

Onboard the trainTrain operating companies must invest in audio description for their toilets so that blind and partially sighted people can use them with ease and peace of mind.

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Rail operators should explore ways of making seat numbering more accessible and introduce new accessible ways of locating a seat.

Assistance and Turn Up and GoRDG must ensure that: Rail staff receive disability awareness training, including visual awareness

and guiding training Rail operators maintain staffing levels at stations that are adequate to

meet the needs of disabled passengers Quick wins are explored, to reduce reliance on assistance Those who book assistance are be given a phone number they can call

which gets them through to someone at the station, not in a call centre, on the day they are travelling

More stations offer turn-up-and-go, with adequate staffing levels provided

TicketsDfT and Rail Deliver Group should explore a fully accessible and consistent national system for ticketing.

Current issues with small print on tickets, and the inconsistency in how tickets are printed out, needs to be addressed urgently by Rail Delivery Group and train operators; this has been a problem for two years, and still many machines are issuing tickets which even rail staff find difficult to read.

DfT needs to develop accessible vending machines.

The Office of Rail and Road needs to carry out an audit of train operating company websites and penalise those which are not accessible.

Disabled Person’s Railcard DfT, RDG and ORR should work with RNIB to reach more blind and partially sighted people, and ensure any promotional materials are accessible to people with sight loss.

ComplaintsAll transport websites should be made accessible.

Complaints processes must be made accessible and should be audited for accessibility.

Better understanding about accessibility, discrimination and the Equality Act among staff dealing with complaints must be ensured.

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Rail Delivery Group DfT and RDG should work with people with sight loss and their organisations to ensure that they consider the problems blind and partially sighted people face when things go wrong whilst travelling by train.

RDG should audit the information held about access on Stations Made Easy. Other ways of providing access information should be explored to ensure no one is left out.

A way of providing not only information but support and advice for disabled passengers must be built into the Dynamic notifications on the Stations Made Easy project.

StreetsImproving the accessibility of street infrastructure must be a priority for local authorities removing clutter.

DfT should bring in a ban on pavement parking across the whole of England, as currently exists in London, and will soon exist in Scotland.

DfT should involve RNIB and other sight loss organisations in projects to learn from good practice examples of reducing pavement parking and street clutter from around the UK.

CyclingDfT should draft guidance for local authorities on considerations they must pay to the needs of disabled pedestrians in relation to the impact of cycling infrastructure.

DfT should commission research into the behaviour and perceptions of blind and partially sighted people when sharing routes with cyclists, as recommended previously by Phil Jones Associates.

WalkingA new section of the Action Plan must consider how walking can be made easier and more accessible to blind and partially sighted people.

Guidance should be provided to local authorities on how they can make their streets better for blind and partially sighted people.

Shared SpaceDfT should commence a moratorium on all new shared space schemes.

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DfT must urgently replace LTN1/11 with new guidance which reinforces universal accessibility standards involving blind and partially sighted people in the process

DfT must ensure kerbs and crossings are retrofitted to all shared space schemes.

See our supplementary report ‘RNIB response to the DfT Accessibility Action Plan: Accessible Streets and Shared Space’.

TaxisDfT should monitor guide dog refusal prosecutions.

Guidance should be drafted for magistrates emphasising the importance of fines as a deterrent.

Local authorities should be encouraged and supported to prosecute when they receive a complaint of guide dog refusals.

DfT should set out standards for disability awareness training for taxi drivers.

DfT should monitor delivery of training for taxi drivers and carry out enforcement work where it is not taking place.

Mobility Centres and Giving Up Driving Licence DfT must ensure that support and advice is provided to people with sight loss when they lose their ability to drive safely: Advice and support needs to be local and either available at home or

easily reached by public transport - ideally for someone newly diagnosed, transport should be provided by the centre providing advice.

The place providing advice and support should not be at a centre where other people are driving cars

The support and advice should not be a one-off session but something available for as long as person needs it, as they move through their sight loss journey

Support should be both practical and emotional Wherever possible, blind and partially sighted people who have been

through similar experiences should provide at least some of the advice and support

Training should include awareness of blind and partially sighted pedestrians, and be accessible to those using mobility scooters who have partial sight

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Aviation and maritime DfT must ensure that: The rights of disabled air and maritime passengers are protected in UK law

in anticipation of Brexit Enforcement of disabled air passengers’ rights are strengthened and given

to a body that can enforce penalties on airlines. Information relating to guide dog travel and the pet passport is

strengthened and made more accessible for guide dog owners Border staff are trained in how to respond to situations relating to guide

dogs, and in particular in carrying out risk assessments in relation to when it is and isn't acceptable to remove a guide dog from its owner

The practices and policies of cruise ships and holiday operators are investigated, and breeches in the rights of disabled people stopped.

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Endnotes

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1. https://help.rnib.org.uk/help/newly-diagnosed-registration/registering-sight-loss/statistics2. http://www.rnib.org.uk/knowledge-and-research-hub-research-reports-general-research/my-voice 3. Of 471 calls received between 1st October 2016 and 30th September 2017, 50% related to buses; it is important to note that we were running a major bus campaign for 6 months of that year.4. Ships (Regulation (EU) No 1177/2010 of the European Parliament and of the Council of 24 November 2010 concerning the rights of passengers when travelling by sea and inland waterway)5.http://webarchive.nationalarchives.gov.uk/20120925163540/http://www.dft.gov.uk/publications/rvar-significant-steps/6. https://www.theguardian.com/commentisfree/2017/jun/08/guide-dog-taxis-uber-illegal-drivers 7. http://dralegal.org/featured/groundbreaking-settlement-end-discrimination-blind-uber-riders-use-guide-dogs/ 8. https://www.ons.gov.uk/businessindustryandtrade/itandinternetindustry/ bulletins/internetusers/2017

https://www.ons.gov.uk/businessindustryandtrade/itandinternetindustry/bulletins/internetusers/2017

https://www.ons.gov.uk/businessindustryandtrade/itandinternetindustry/bulletins/internetusers/2017

http://dralegal.org/featured/groundbreaking-settlement-end-discrimination-blind-uber-riders-use-guide-dogs/

http://dralegal.org/featured/groundbreaking-settlement-end-discrimination-blind-uber-riders-use-guide-dogs/

https://www.theguardian.com/commentisfree/2017/jun/08/guide-dog-taxis-uber-illegal-drivers

https://www.theguardian.com/commentisfree/2017/jun/08/guide-dog-taxis-uber-illegal-drivers

http://www.rnib.org.uk/knowledge-and-research-hub-research-reports-general-research/my-voice

http://www.rnib.org.uk/knowledge-and-research-hub-research-reports-general-research/my-voice

https://help.rnib.org.uk/help/newly-diagnosed-registration/registering-sight-loss/statistics

https://help.rnib.org.uk/help/newly-diagnosed-registration/registering-sight-loss/statistics

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