Proposed Provision of Bus and Coach Services Legislative Competence Order (LCO)

Response from the Guide Dogs for the Blind Association

Prepared by Andrea Gordon
Policy Manager, Wales
Tel. 01792 702796
Mob 07974 205177
Email andrea.gordon@guidedogs.org.uk

The Guide Dogs for the Blind Association
Building 3, Eastern Business Park
Off Wern Fawr Lane
St Mellons
Cardiff
CF3 5EA

Website: www.guidedogs.org.uk

Introduction

Guide Dogs are the UK’s largest single provider of mobility and other rehabilitation training for blind and partially sighted people. Each year, we help thousands of visually impaired clients to negotiate public transport, either with a guide dog or long cane.

Our vision is for a world in which all people who are blind and partially sighted enjoy the same rights, opportunities and responsibilities as everyone else. We help blind and partially sighted people to achieve independence and mobility through the provision of guide dogs and rehabilitation services - yet this independence is limited by the environment in which visually impaired people must live. As such, we campaign for equal access to transport and the built environment, shops and services, health and social care.

The Guide Dogs for the Blind Association (Guide Dogs), welcomes the chance to respond to the Proposed Provision of Bus and Coach Services Legislative Competence Order (LCO) Consultation Paper.

Consultation questions

1. Do you agree with the principle that legislative competence for "the provision of bus and coach services” in Wales should be conferred on the National Assembly for Wales?

Guide Dogs support the principle that legislative competence for the provision of bus and coach services in Wales should be conferred on the Welsh Assembly Government. We are encouraged by the Welsh Assembly Government’s commitment to disabled people in the form of unrestricted concessionary bus travel, and we would hope that this signals a willingness to take into account other initiatives to make bus travel easier and less intimidating. We are campaigning nationally for the introduction of audio/visual information on all buses and coaches, and if Wales could be first in the UK to make this available to people with sight loss and other disabled people, independent travel would be more inviting and safer. We also believe that such technology benefits many other bus users, especially on unfamiliar routes.

In the "Functionality and the Needs of Blind and Partially Sighted Adults in Wales” report, published by Guide Dogs in September 2007, our research showed that 27% of visually impaired people in Wales find buses very difficult to use. The main reason for this was not being able to tell when the desired destination had been reached, so that a visually impaired passenger could alight at a totally unfamiliar stop. It is not surprising, therefore, that 70% of visually impaired people in Wales never go out alone, and that many of our respondents specifically mentioned how hard it is to use buses independently.

2. If you agree with the principle, do you think that the wording of the proposed legislative competence order is correct, or do you think it is too broad or too narrow?

Schedule 7 of the Government of Wales Act 2006, sets out the legislative competence that the National Assembly would have following a referendum supporting the commencement of Assembly Act provisions.

Subject 10 is Highways and Transport. This is defined as:-

Highways, including bridges and tunnels. Street works, traffic management and regulation. Transport facilities and services.

Exceptions to Subject 10 include the following:-

Regulation of use of motor vehicles and trailers on roads, their construction and equipment and conditions under which they may be so used, apart from regulation of use of vehicles carrying animals for purpose of protecting human, animal or plant health, animal welfare or the environment.

Driver licensing
Drivers’ hours
Public service vehicle operator licensing

With regard to Public Service Vehicle Operating Licensing, Guide Dogs would wish to see a higher standard of Public Service Vehicle Accessibility Regulations (PSVAR). Given greater powers, the Welsh Assembly Government could require all operators to provide audio/visual announcements on scheduled buses and coaches, We would also urge the Welsh Assembly Government to make Disability Awareness Training for drivers and other bus operating staff, a mandatory requirement. This training should be structured on a pan disability approach and such training should be developed with the involvement of disability organisations in Wales.

3. Do you think that the National Assembly for Wales should be given competence over some or all of the exceptions listed above in relation to the provision of bus and coach services in Wales?

Please see our answer to question 2

4. What are your views on the main objective of the proposed LCO which is to introduce a bus franchising system in Wales?

Guide Dogs would agree that "the current deregulated system does not protect the interests of local people and local government does not have sufficient tools to ensure bus companies are providing the safe, clean, modern and regular services required.” We would in fact suggest that current levels of service disadvantage visually impaired people who rely on buses as their only means of local public transport. In Wales, the rural nature and spread of population means that anyone living more than a few miles away from a town has to wait a long time for a bus, often on isolated roads, and with the risk that it will be late, or fail to arrive at all. This makes accessing evening social events difficult and even dangerous, let alone the routine trips to get to work or go shopping. Introducing a "public service ethos” should mean that the needs of people with diverse access requirements are more likely to be taken into account, and that visually impaired people might not have to rely so often on friends and family for their help.

Furthermore, we would hope that such an ethos would ensure that those living in rural areas would be less disadvantaged, in terms of accessing scheduled bus services. The current deregulated system means that bus companies will withdraw non profit making services and unless local authorities step in to subsidise such services, people living in these areas are isolated.

5. What are your views on the use of the proposed LCO to provide the Assembly with the necessary powers to improve school transport safety?

We have no additional comments