Submission on 2020 Vision- Sustainable Travel and Transport
Mobility is the key to equal citizenship in a society which sets a high value on personal independence and freedom to move around. The adequate provision of an accessible sustainable public travel and transport service is one of the significant services that impact on the quality of all transport users, even to the most able-bodied, and issues relating to transport accessibility go far beyond the needs of people with disabilities. They impact on the transport needs of the entire population because most people, at some point in their lives, are likely to acquire a physical or other impairment or be impeded in some manner, that will make travelling difficult, if not impossible, on what one might call 'traditional' type transport vehicles. This is particularly the case as people advance through the ageing process. It is also the case that there is a high correlation between age and disability.
Accordingly, in addressing the issue of sustainable transport accessibility, the National Disability Authority uses the term "people with reduced mobility" in line with the definition contained in the Department of Transport's Sectoral Plan .
The Department is defining the term as follows:
"People with physical, sensory, learning or cognitive difficulties (whether permanent or temporary) and others whose access to traditionally constructed transport vehicles, services and infrastructures is limited, to a greater or lesser extent, on account of age, because of accompanying children or because they are carrying luggage or shopping or are otherwise impaired in their use of the transport system."
A major component to this is the adequate provision of an integrated accessible public transport service which enables older and ageing people and people with disabilities to fully participate in society.
Lack of access to public transport or if the mode of transport or the built and external environment is not accessible for people with reduced mobility, means that they are unable to leave their immediate environs without arranging for private transport or having to pay for a taxi. As a consequence, this leaves people with reduced mobility dependent on private vehicle use.
The lack of provision of an appropriate and adequate level of accessible public transport significantly diminishes the quality of life for people who are heavily dependent on it. This impacts on their ability to pursue education, attend training courses, work outside the home or live in the area of their choice. They cannot participate in social activities on the same basis as their non-disabled peers. They are prevented from going into the city to window-shop or browse. It also means that they can not take spontaneous action.
This can be particularly acute in rural areas of Ireland where no public transport service is available and where there is a need for further support in the development of innovative initiatives, within rural communities, to provide local accessible transport.
Public transport accessibility issues go beyond the needs of people with disabilities. They also involve the transport needs of the wider community, who at some time in their lives have some form of impairment which makes travelling difficult, if not impossible.
The concept of "Transport for All" is now generally accepted within the EU and the European Council of Ministers for Transport (ECMT). The Department of Transport has also embraced this concept and it is at centre of its sectoral plan on transport. Such a concept includes a broad proportion of the population and not just people with disabilities. Thus it removes the notion that "special" provision alone needs to be made for people with disabilities.
Accessibility to public transport modes enable people to access and avail of goods, services, employment and other activities.
It is within this context that NDA is making this submission and confines its comments to disability and sustainable travel and transport to the following specific areas which it sees as priorities for action between now and full implementation of the Vision in 2020.
The NDA broadly welcomes and supports the Vision as articulated in the public consultation document and notes in particular that one of the anticipated outcomes of this sustainable travel and transport vision will be "ease of access to public transport and other sustainable forms of travel will be improved for all citizens, irrespective of location and mobility needs".
The rationale underpinning such a vision from a disability perspective needs to take account of:
- The number of people with disabilities is growing in Ireland. With an ageing population, this number will increase over the next decades, so any future proofing needs to be cognisant of this;
- Everyone must have an opportunity for independent living and therefore development of a sustainable transport service must be barrier free;
- All travel and transport initiatives must be universally designed and public funding and procurement of transport services should be conditional on compliance with accessibility standards.
In order for this Vision to translate into a sustainable policy on public transport and travel, the policy needs to be applied not only within the Department of Transport but across other agencies and departments who operate and/or fund transport provision. In this context the lead role of the Department of Transport is critical.
The development of such a policy would include, inter alia:
- The adoption and implementation across all departments and agencies of a "transport for all" policy which currently underpins the Department of Transport's;
- The integration of sustainable transport and travel policy with other policies e.g. spatial planning; social inclusion policy etc;
- The coordination and integration of the provision of all public transport;
- The development of local integrated transport services including demand responsive and flexibly routed services;
- The need for research that supports the development of a sustainable and integrated accessible transport policy including
- data collection, analysis and evaluation of on all publicly funded accessible transport (e.g. voluntary bodies, HSE, schools transport etc);
- analysis of transport trends and current usage
The review of current legislation and regulation in order to facilitate the inclusion of other categories of vehicles and services as part of an integrated approach e.g. community transport services like Vantastic, ACTS etc. and thus provide better harmonisation and coordination within the broader transport legislative and regulatory framework.
Accessible streets, footpaths and pedestrian areas are a key element of most travel journeys and NDA acknowledges the importance of this as reflected in the Sectoral Plan of the Department of Environment, Heritage and Local Government. There are established standards for dishing footpaths and providing tactile paving at junctions. Audio traffic signals are another important element.
Significant work has also been advanced by the Local Government Services Management Board in the development of an integrated accessible roads and street design template. It is critical that work on agreeing the template be advanced immediately by the relevant parties, including the Department of Transport, so as to maximise the opportunity for creating an accessible environment for sustainable travel.
In prioritising which streets and footpaths should be tackled first, the NDA recommends a route approach that first targets routes to public facilities like transport stops and stations, key transport hubs like airports, ferry ports, harbours and taxi ranks, schools, churches, post offices, health services, banks and shops.
Footpaths and pedestrian areas that have been made accessible need to be well publicised to enable people plan their travel journeys. Accessible routes should be mapped, with on street guidance and with maps available locally with transport operators etc and on local council and transport websites and available as accessible information.
It is also important to maintain accessible pedestrian routes. Road repairs frequently turn streets and footpaths into an obstacle course, and typical marking of holes with plastic tape and/or mesh can be hazardous for people with vision impairment. A standard condition of road opening licences should be that accessible routes are maintained, roadworks are protected safely and roads and paths are reinstated flush with the remainder of the paved surface.
Such an approach would ensure the continuing maintenance of accessible environments which are an integral component of sustainable travel journeys for individuals.
As outlined in the discussion document 2020 Vision there are international examples to show that promoting changes in travel behaviour need to be accompanied by fiscal measures and disincentives and the discussion document outlines a number of measures like VRT, congestion charges etc that might be examined.
NDA acknowledges the complexity of bringing about such changes. However, such measures need to be examined within an Irish context and the potential impact on vulnerable groups like people with disabilities, those living in rural areas and those who do not in fact have any viable alternative but to use personal transport.
Changes in this area should be disability proofed in order to assess the impact such changes would have on people with disabilities. For example, recent changes in assessing VRT and Motor Tax from 2008 on the basis of CO2 emissions can have an impact on a person with a disability who requires an automated car because they do not have the use of certain limbs. A person in this situation has no viable alternative and therefore exemptions may need to apply.
Fiscal measures should also ensure that public transport is affordable. In this regards there should be review of the current schemes of support for transport costs for people with disabilities which are operated through the welfare/health systems, to enhance their ability to deliver real mobility to their target group. Such a review should examine issues like a payment of a travel to work allowance; the use of smart card technology being introduced in the Greater Dublin Area in 2009 to be used as credit by those eligible for "free travel passes" on other modes of community/public transport.
Priority fiscal measures should also be given to modes of public/community transport with links which interconnect with local travel services and which promote accessible public transport use.
Integrated Transport and Travel
In order to bring about more sustainable travel patterns towards shorter, less frequent and a modal shift to more sustainable public transport, it is important that people have better access to public transport services. In this regards the NDA would be broadly supportive of what is outlined in the discussion document on an integrated approach to the delivery of public transport services…"(which) should make it as easy and convenient as possible for people to use the public transport system. This has many dimensions, including ease of access, ease of transfer and interchange, integrated ticketing, real time passenger information and interchange with other transport modes".
In addition, NDA is of the view that such an approach needs to move beyond what is currently classified as "public transport" and needs to include other forms of community transport operators, small public service vehicles, rural transport operators. For this to happen a trial transport initiative should be considered in the short term. Such an initiative could be explored in an urban and a rural context which would involve inter alia
- local level practical research into the reorganisation and coordination at local level of paratransit services which should include all publicly funded transport services being provided by or for other public bodies
- local research on travel needs of local users in particular people with disabilities
- maximising the use of existing accessible transport and complementing it with door to door demand responsive flexibly routed local services
- extending "free travel passes" for use on other modes of community/public transport
- improving links and efficiencies in use of transport between residential areas and common destinations, work, schools, shops etc
- increasing convenience by greater frequency and reliability of local services.
Such an approach should be monitored and reviewed by the Department of Transport as the lead department with relevant stakeholders over a fixed time period. This would enable lessons learned to enhance future developments into other key transport developments such as the Dublin Transportation Authority and the 2020 Vision for Sustainable Travel and Transport.