Consultation on the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD): analysis of responses

4. Outcome 1 - Equal and inclusive access to the physical and cultural environment, transport and suitable, affordable housing

Sixteen commitments were included under outcome 1. Consultees were asked if they felt that these commitments would help the Scottish Government make progress towards Outcome 1.

Q3: Do you agree or disagree that the commitments (1-16) described at Section 2.1 will help the Scottish Government make progress towards outcome 1?

Sixty-nine consultees responded to this question. The majority of consultees who responded agreed that these commitments would help the Scottish Government make progress towards Outcome 1. Over three quarters (77%) agreed, 7% disagreed and 16% said that they neither agreed nor disagreed.

Q4: If you would like to make specific comments on any of the commitments intended to contribute to achieving outcome 1, please do so here. If not please skip to next question.

As table 4, below, shows, commitment 1 (transport accessibility) and commitment 16 (One Scotland awareness raising campaign) received the most comments (35 and 29 respectively).

Table 4: Number of comments for each of the Outcome 1 commitments

Commitment (Outcome 1)	No. of comments received
1. Transport accessibility	35
2. Design for Ageing	21
3. Raising awareness of accessible design	25
4. Homes which are more accessible	20
5. Accessible housing	25
6. A new help guide aimed at boosting accessible design	22
7. A new help guide to assist tourism businesses	19
8. A new help guide setting out key accessibility hints and tips	20
9. Access statement online tool builder	11
10. Widening access and increasing opportunities for disabled people to engage in culture, heritage and the arts	22
11. Recording and reporting of workforce diversity information	17
12. Improving access to the historic environment and collections relating to the historic environment	20
13. Disability Inclusion in Sport	23
14. Action plan to promote disabled people's participation in sport and physical activity	19
15. Sportscotland investments	17
16. One Scotland awareness raising campaign	29

Transport

1. Transport Accessibility - Transport Scotland has been engaging with Disabled People's Organisations, policy colleagues, transport providers and local government to discuss issues raised by disabled people on the accessibility of door to door journeys in Scotland. The issues will be taken forward in a Plan for Accessible Travel as agreed between all the above mentioned parties.

The engagement will continue and a steering group has been set up to agree, manage and monitor the plan. Setting up such a group which involves disabled people, was one of the key priorities for disabled people. (2016 on going)

Consultees commented on a range of themes relating to commitment 1, as can be seen in table 5, below. The most commonly mentioned theme was accessibility, which related not only to physical access, but also to other factors such as the cost of transport, and the need for inclusive communication. A large number of comments were also received relating to individual modes of transport, especially buses. Attitudinal barriers, both in terms of the attitudes of staff and members of the public, and the individual's confidence was another frequently commented on theme.

Table 5: themes identified for commitment 1

Theme/sub theme identified	Number of comments relating to this theme
Generally supportive	7
Importance of transport	6
Accessibility	44
Specific types of transport mentioned	46
Attitudinal barriers	22
Comments on the commitment and its implementation	18
Engagement	8
Children and young people	3
Other	2

Importance of transport

A number of consultees took the opportunity to reiterate the importance of transport to disabled people, and to stress that good access to transport is necessary for realising a number of rights and outcomes, such as accessing personal and social networks and accessing health and social care.

"Transport accessibility continues to be crucial to disabled people to achieve their rights to independent living. During our engagement events its importance was cited in terms of access to a social and family life, to education, work and/or even simply to leave the house. Without access to transport and travel, disabled people can be effectively imprisoned in their own homes (including residential care settings)."

Third sector / equality organisation - Inclusion Scotland

Accessibility

Accessibility of transport was a major area of concern, including physical access and wheelchair access to public transport and inclusive communication. Suggestions around inclusive communication included adopting universal signage, audio visual announcements, using British Sign Language ( BSL) and or/text information for D/deaf people, bus drivers announcing stops for blind people and better use of hearing induction loop systems in railway stations.

The cost of transport was also mentioned as something which could impede access to transport, and there were calls to increase concessionary travel schemes to include rail services and to extend the re-imbursement of concessionary travel fares to community transport providers.

Some consultees complained about the current requirement to book assistance for rail travel in advance as that denies them the ability to be spontaneous. It was noted that London Transport had removed this requirement. Improved access to information about transport was also raised.

"Improved transport accessibility is fundamental to improving opportunities for independent living, equality of access to services and all aspects of life for those with a disability and their carers."

Local government - Stirling Council

Availability

Linked to access was the concept of availability - transport going where people want to go at a time when they want to go. In particular a lack of services in rural areas was mentioned, and some consultees commented on the punctuality of public transport.

"Recent research conducted by Scottish Accessible Transport Alliance ( SATA) with its members in 2013 found that the main issues affecting disabled transport users in Scotland are availability and accessibility of public transport. Lack of consistency and poor attitudes (from taxi drivers and bus drivers) were also expressed, and differences in provision in rural and urban areas were noted as being a big problem for those living in rural areas."

Third sector / equality organisation - Inclusion Scotland

Specific types of transport mentioned

A large number of comments related to specific types of transport. Buses were the most commented on method of transport. Some consultees felt that although buses were meant to be disabled-friendly they often weren't accessible enough and cited poor attitudes of drivers and other passengers, as well as a lack of space for wheelchairs, and the fact that sometimes the wheelchair space is also the buggy space, which was seen as an uncomfortable trade off. One consultee, however did single out Lothian Buses buses as a positive example in terms of bus design and driver training.

"In our experience, the bus network provides one of the most commonly used forms of public transport, but is not always fully accessible for disabled people. Despite many buses being designed to be accessible, disabled people still report problems with driver attitudes or occupied wheelchair spaces which prevent them from accessing buses."

Third sector / equality organisation - Leonard Cheshire Disability

"Buses are now fitted out better for wheelchairs however, this seems to have to the detriment of children in buggies being able to access buses, due to a lack of space. There has to be better proposals put forward in order to allow more people who can't walk (including babies) to access buses. It will not have improved attitudes towards those with a disability by allowing this trade-off."

Third sector / equality organisation - Saving Down syndrome

There were calls to make taxis more accessible, both physically accessible and in terms of contacting them, for example ensure that they can be contacted by text as well as by phone.

It was suggested that more blue badge parking spaces should be made available and that these should be enforced. In addition it was suggested that blue badge charges were removed for people in poverty in order to be more accessible.

The pedestrian environment was also mentioned, with the need to improve the conditions of pavements and provide safe pedestrian crossings. Concerns were also raised about shared space initiatives, feeling that they posed a particular danger for disabled pedestrians.

"Shared spaces, where vehicles and pedestrians are mixed, are particularly dangerous for disabled pedestrians. There is a perception that drivers speed up once they become used to the new layout ( ILiS Interim Report)."

Third sector / equality organisation - Inclusion Scotland

Conditions at train stations, bus stations and bus stops were also mentioned as being in need of improvement. Specific comments included the need for adequate seating and lighting, the provision of accessible toilets, text displays of information, the use of hearing induction loops, lack of disabled parking and vehicle access around stations and the difficulty of physically getting around stations.

There was one mention of the Edinburgh trams - as an example of good physically accessible transport by a visually impaired person.

Attitudinal barriers

Negative attitudes and lack of training of bus and taxi drivers was mentioned, as was the poor attitude of some other passengers to disabled passengers. It was noted that bus drivers were sometimes unwilling to put down ramps, or allow disabled people extra time to get seated, whilst passengers were not always willing to give up seats for disabled people who needed them. Suggestions were made about the need for equality training for drivers, and that this could maybe be a requirement for getting public sector contracts. In addition, comments were made around disabled people's confidence in using public transport and the need to provide travel training, and also the issue of disabled people not feeling safe on public transport due concerns about hate crime.

"Respondents also felt that one of the main barriers to disabled people using transport services is attitudes; not only from staff and drivers, but from passengers as well."

Third sector / equality organisation - Scottish Disability Equality Forum

Comments on the commitment and its implementation

It was commented that there needed to be more detail about the commitment. The importance of monitoring and evaluation and reporting on progress was also mentioned, and it was felt that disabled people should be involved in this evaluation process.

It was felt that the Scottish Government should endorse and build on existing transport plans, such as the one by the Scottish Accessible Transport Alliance ( SATA).

It was suggested that the Scottish Government needed to work closely with private companies that provide public transport. It was also felt that any travel plan would need to be adequately resourced, and that this would require investment, particularly in rural areas.

It was commented that the Scottish Government's travel plan should be wider than just "accessibility" and should also include "mobility" and other barriers, and that it needed to include accessibility planning, and how far people are from services and facilities. One consultee described "mobility" as being the chain that needs to be in place for people to make a trip. It consists of information, confidence, getting to transport, getting on and off transport, affordability and going where people want it to go when they want it to go.

"Accessibility describes the ease with which a trip can be made but is only part of the equation for disabled people who wish to get around. Mobility is a wider issue and describes the making of a trip. There is a chain of passenger transport accessibility… People are mobile when all the links in the chain of accessibility are in place."

Third sector / equality organisation - Community Transport Association

Engagement

A recurring theme throughout responses to the consultation is the need for early and meaningful engagement with disabled people and disabled people's organisations ( DPOs) around proposed activities. A number of consultees were supportive of the idea of having a steering group which included disabled people. It was noted that the steering group should be as representative as possible, should engage with disabled people early on before any planned decisions were made, and that disabled people's role should continue throughout the process including monitoring and evaluation.

"The majority of respondents support the commitment to create a Plan for Accessible Travel and wish to see long-term engagement with disabled people in monitoring of the plan. Respondents felt that all too often transport providers do not effectively consult with disabled people at the earliest stages when commissioning services or infrastructure and this is the root of many access problems."

Third sector / equality organisation - Scottish Disability Equality Forum

Children and young people

A small number of comments referred to the specific needs of children and young people in relation to transport, these included a fear of bullying on public transport, and the suggestion of travel training for disabled young people to make them more confident using public transport. As with adults, it was mentioned that transport is often necessary for in order for children to access activities and social networks. It was also pointed out that due to their age, travel choices may be more limited for young people and that often they are dependent on their parents to transport them.

"This is an important area for disabled children and young people as transport accessibility opens up a world of opportunities. Disabled children and young people's fulfilment of rights and opportunities are often limited due to the localities they live in. The physical environment of the local community can also be a barrier for those with mobility issues. Many young disabled people also rely on their parents when transport is an issue, which can be restrictive as it will depend on their availability and willingness to get involved… A lack of suitable transport provision can lead to isolation for disabled children and young people."

Public Body - Children and Young People's Commissioner

Planning and Architecture

2. Design for Ageing - the Scottish Government will consider the scope for research into the impact of demographic change and an ageing population on design and planning and how this may also potentially positively affect disabled people. (2016)

A number of comments around commitment 2 said that consultees were generally supportive of the commitment. Some consultees commented on the specific needs of the elderly, whilst others urged inclusive planning which takes into account the needs of both disabled people and the elderly. Some consultees provided ideas for what the research might include, whilst others stressed the need for action. Table 6, below, shows the key themes arising from commitment 2.

Table 6: themes identified for commitment 2

Theme identified	Number of comments relating to this theme
Generally supportive	9
The research and following on from it	11
Needs of the elderly	10
The need for inclusive planning covering disability and aging	8
Inclusive communication	3
Dissatisfaction with current situation	2
Other	1

The research and following on from it

A number of consultees made comments relating to the research, including emphasising the need to engage with stakeholders including disabled people and DPOs. Some consultees made specific suggestions about what the research could include, such as: an audit of the immediate needs of current service users; cost implications; extending the scope to those under 65 who have degenerative conditions; inclusion of the needs of a wide range of equality groups; and taking a broader view than just accessibility which would include "prevention of isolation and loneliness, access to transport links, health and social care services, and the specific needs of people who have dementia and mental health problems" (Third sector/ equality organisation - Inclusion Scotland). The need for action following on from the research was also stressed, and it was felt that the commitment should include information on how the research recommendations would be taken forward, including the timescales for doing so.

Needs of the elderly

Some consultees made specific comments about the needs of the elderly, including sheltered accommodation; downsizing to smaller accommodation; specific adaptions; not being segregated from friends and family, but to be accommodated within their community; and the specific requirements of those with dementia. In addition the need to "future proof" Scotland's housing stock was also mentioned.

The need for inclusive planning covering disability and aging

A number of consultees highlighted the need for inclusive planning, which would cover the housing needs of both the elderly and disabled people of any age. However one consultee stressed that the needs of disabled people should not be subsumed within plans for the elderly, and that a specific commitment was required around the housing needs of the disabled.

"We agree with this approach which emphasises a focus on prevention in public service delivery. We thought it might be worth considering reframing this commitment to be more about "Design for Life" rather than limiting it to the factors of "ageing". It would then embrace all potential changes/transitions throughout the lifespan and support early intervention and prevention."

Public Body - Social Work, Dundee City Council

"However SDEF are keen to stress that the under-supply of housing suitable for disabled people with mobility impairments must be specifically addressed by the Scottish Government and not subsumed into the housing for an aging population agenda. Given the human rights implications for disabled people unable to access suitable housing in Scotland we need further commitments within the disability delivery plan on specific action to address the shortfall in accessible housing."

Third sector / equality organisation - Scottish Disability Equality Forum

Inclusive communication

The need for inclusive communication was mentioned by a few consultees. This included housing to meet the needs of hearing impaired and D/deaf people, (for example flashing light alerts), and also to support those with specific communication needs.

Dissatisfaction with current situation

A couple of consultees voiced their dissatisfaction with the current situation, and said that they did not believe that current housing was being built to meet the needs of the elderly and disabled.

Other

One other comment focused on the benefits of individualisation and stated that a "one size fits all" approach does not work.

3. Raising Awareness of Accessible Design - the Scottish Government runs the Scottish Awards for Quality in planning each year. The awards are in six categories and for the 2016 Awards, the judging criteria will be amended to promote good practice in accessible design in both buildings and the public realm. (2016)

A number of consultees were supportive of commitment 3, although some mentioned the limited value of an award. The need to engage with disabled people was mentioned, as was the need to address unseen disabilities and not just wheelchair access. The importance of knowledge, research and training was also highlighted. Table 7, below, shows the key themes identified.

Table 7: themes identified under commitment 3

Theme identified	Number of comments relating to this theme
Generally supportive	8
Engagement	7
Knowledge, research and training	7
The award - limitations and practical considerations	7
Address unseen disabilities, not just wheelchair access	6
Dissatisfaction with current design and planning situation	1
Other	11

 

Engagement

It was commented that there should be meaningful engagement with disabled people in establishing the award, including involving disabled people in setting the criteria for the award and judging it. In addition it was commented that more disabled people should be encouraged to consider entering architecture as a profession. This would help to ensure that accessibility issues were considered at the start of projects.

Knowledge, research and training

The importance of knowledge, research and training was highlighted, including the sharing of good practice in accessible design. The Scottish Disability Equality Forum shared information about work they are undertaking on a new inclusive design website which "aims to improve awareness and implementation of best practice in accessible design for planners, architects, and other building professionals." In addition there were calls for accessible design and inclusion training to be included as part of the training of architects, designers and planners.

The award - limitations and practical considerations

Whilst consultees were generally supportive of the idea of a design award, some also noted its limitations, feeling that an award alone would not be enough to help disabled people realise their rights. It was suggested that enforcement was required rather than an award. Another suggestion was that projects be required to meet certain accessibility standards if they were awarded public sector funding.

"Whilst many respondents agree that the award is a good idea, they are concerned that one award is insufficient to mainstream approaches to accessible design. 'This is not enough. Accessibility does not require awards just common sense, planning and legislation.'"

Third sector / equality organisation - Scottish Disability Equality Forum

Some practical considerations around the award were raised, including the need to promote the award widely amongst both professionals and disabled people, and the need for inclusive communication.

Address unseen disabilities, not just wheelchair access

Consultees felt that it was important that the award did not just focus on issues of physical access for wheelchair users, but that it was wider and considered those with hearing loss, communication needs and mental health problems, amongst others.

"Respondents were keen to point out that accessible design is not all about 'lifts and ramps' but should include a holistic approach to access for all disabled people, including those with mental health problems: 'accessibility can be due to sensory issues associated with autism and mental health and not just physical disabilities.'"

Third sector / equality organisation - Scottish Disability Equality Forum

Dissatisfaction with current design and planning situation

Concerns were raised about the current design and planning situation, and it was noted that it would take more than an award to rectify the situation.

"Some respondents also paint a picture of an unsupportive and bureaucratic planning system that does not take the access needs of disabled people into account and have suggested that it will take more than an award to tackle these issues."

Third sector / equality organisation - Scottish Disability Equality Forum

Building Standards

4. Homes which are more accessible - through engagement with house builders and local authority building standards verifiers, concessions for sites where development has become protracted will cease, and homes will be built to more recent standards and will be more accessible. (until 2016-17)

Whilst some consultees were broadly supportive of this commitment, there were some who were critical of it. A number of accessibility considerations to take into account were mentioned. Again the importance of engaging with expert stakeholders including disabled people was highlighted. Table 8, below, shows the key themes identified under commitment 4.

Table 8: themes identified under commitment 4

Theme identified	Number of comments relating to this theme
Generally supportive	4
Accessible Housing Needs	33
Engagement	4
Critical comments	6
Other	1

Accessible housing needs

Some consultees highlighted that there is a demand for many more accessible homes in Scotland

"In total an additional 230,000 adapted homes are needed. Research by Capability Scotland concluded that this lack of accessible housing was 'restricting disabled people's lives; having an impact on quality of life; and potentially leading to isolation, health problems and a lack of confidence/self-esteem'."

Third sector / equality organisation - Inclusion Scotland

It was emphasised that accessibility is wider than wheelchair access and includes meeting other needs, such as those of people with hearing or sight impairments, or those who require extra space and storage for specialist equipment. The importance of housing as part of the independent living agenda was also highlighted, as was the need to develop accessible housing in places where disabled people want to live, and where they can retain their connection to their communities.

A number of consultees mentioned the importance of building homes to "Lifetime Home Standards", where a home can meet a person's need throughout their life, requiring minimum adaptations to do so.

"To meet the universal design principle, building standards and planning consents should seek to ensure that new and refurbished housing should be designed to be accessible or require minimum possible adaptation, to meet current or future needs of disabled people. This is consistent with a lifetime homes approach."

Third sector / equality organisation - Inclusion Scotland

It was suggested that there was a need for targets around making new homes accessible.

Engagement

Engagement with disabled people and disabled people's organisations ( DPOs) was seen as crucial, including early engagement. There were calls for the establishment of an expert stakeholder group including disabled people.

"Sense Scotland's experience of working in partnership with housing providers is that a design approach which includes the provider and the disabled person results in more successful outcomes for supported people. The most suitable accommodation has involved tenants being part of the selection of design features, and having prospective landlords and architects who were open to adjusting designs in light of their input… Many design features do not need to cost more, if they are included at the outset."

Third sector / equality organisation - Sense Scotland

Critical comments

Concerns were raised about the need to improve standards in order to make it simpler to make adaptations. In addition there were concerns about proposals to modify building standards in new builds, as it was believed that this would make new build homes less accessible. In particular, concerns were raised around: reductions in space for the provision of a future shower or bath; reductions in space which would be incompatible with the use of larger powered wheelchairs; and reductions in the minimum locations for robust wall constructions for the fitting of grab rails.

"Capability Scotland receive up to one hundred enquiries to our advice service where disabled people are struggling to get the adaptation they require to live well in their own home and cannot move house because of a range of barriers. We therefore believe suitable building standards for new build housing as critical to creating the kind of housing stock that will meet the demographic challenges Scotland will face in the future. The suite of standards around accessibility therefore needs to be built upon and improved in order to future proof our housing stock."

Third sector / equality organisation - Capability Scotland

Some comments were made about the commitment itself. One consultee felt that commitment was unclear and required further clarification. Another suggested that the commitment should go further and do more to address the issue and impact of a lack of accessible housing. A third consultee did not think that the commitment would have much impact on developers in cases where development had become protracted.

"In light of the evidence that was presented by DPOs during the Scottish Government policy seminars, we are disappointed that these commitments are not stronger. In particular we are disappointed that there is no commitment to take action that will guarantee that new housing stock is accessible, that disabled people's housing needs will be properly assessed and that housing can be easily adapted when people become disabled."

Third sector / equality organisation - Equality Human Rights Commission and Scottish Human Rights Commission

Housing and Independent Living

5. Accessible Housing - the Scottish Government will consider in greater depth the issues raised by DPOs about the availability of accessible housing for disabled people within the existing planning system, and consider what further actions may be necessary. We will discuss with local authorities, social landlords, third sector organisations and other policy areas of the Scottish Government. (2016 ongoing)

Consultees highlighted the importance of accessible housing and how this linked with being able to realise other rights. The prevalent view, however, was that current housing did not meet disabled people's needs and that more needed to be done to address this housing shortage. Table 9, below, shows the key themes.

Table 9: themes identified under commitment 5

Theme identified	Number of comments relating to this theme
Generally supportive	7
Links between having/not having an accessible home and accessing other rights	9
Housing shortage/current housing supply not meeting disabled people's needs	23
Planning, regulations and new builds	10
Implementation	8
Adaptations	7
What is meant by accessibility	5
Other	8

Links between having/not having an accessible home and accessing other rights

It was noted that not having access to accessible housing could constrain disabled people's rights and negatively impact on their ability to participate in education, employment, social and recreational pursuits, and engage with health and social care. A lack of accessible housing could also result in delayed discharge from hospital.

"Without a user-friendly accessible house, access to employment, education or even social and recreational opportunities is made even more difficult for disabled people."

Third sector / equality organisation - Scottish Disability Equality Forum

In addition the importance of providing accessible housing to disabled people within their community where they can continue to have access to informal social networks was emphasised, and that disabled people should not be expected to leave their community in order to find accessible housing. Local amenities, such as access to transport links and shops, should be considered when building accessible homes.

"Social Work Scotland supports the intention to focus on the design of accessible housing- both in terms of increasing the availability of suitable accommodation for people with disabilities and also to avoid the situation where people have to move from communities where they live (and may receive informal support) following a deterioration in their physical abilities."

Representative body for professionals - Social Work Scotland Ltd

Housing shortage/current housing supply not meeting disabled people's needs

One of the most commonly mentioned concerns related to the current shortage of accessible housing and housing supply not currently meeting the needs of many disabled people. Third sector/equality organisations provided examples of difficulties that they were aware of their members experiencing. There were calls for this housing shortage to be addressed. It was suggested that the Scottish Government require local authorities to carry out an audit of current and prospective tenants and the housing available, in order to establish exactly what the shortfall is.

"Our most recent 1 in 4 Poll of over 500 disabled people showed that 75% of respondents felt that disabled people do not have equal access to suitable housing in Scotland, with the main barrier to accessing housing perceived as not enough new-build accessible housing. Other barriers included lack of specialist housing advice, not enough low cost housing, lack of private accessible rented property and disabled people finding it difficult to get help to adapt their home."

Third sector / equality organisation - Capability Scotland

"The Scottish Housing Conditions Survey showed that 62,000 households in Scotland require specially adapted baths or showers but do not have them. 8,000 households require, but lack, ramp access - 17,042 wheelchair users in Scotland lack appropriate accommodation."

Third sector / equality organisation - Inclusion Scotland

It was mentioned that disabled people do not have equal access to appropriate housing, and that accessible housing is required across all sectors. Disabled people may have fewer options available to buy or rent privately, nor is there enough suitable accommodation available in the social rented sector.

"Disabled people want to have the same rights as anyone else to choose where they live, including choice of tenure. However this is often constrained by the unavailability of suitably adapted housing. This can require disabled people to move outwith the community they wish to live in, or to seek social rented housing as there are no other options available - e.g. owner occupation."

Third sector / equality organisation - Inclusion Scotland

Planning, regulations and new builds

There was some discussion around new builds, with some consultees commenting that all new build homes should be built to an accessible standard, to avoid the need for costly adaptations later on. Others believed that there should be quotas or targets for the number of accessible new builds.

Implementation

A number of commitments were concerned with how to take this commitment forward. Engagement with disabled people and DPOs was highlighted as was the necessity for a national strategy. A couple of consultees highlighted concrete actions that they would like to see the Scottish Government take forward, including: cross-tenure grants to incentivise the building of houses with sufficient space for future adaptations; a pilot project around the development of wheelchair accessible housing; conducting a review of Housing to Varying Needs, around wheelchair size and technology used; support such as help to buy to improve disabled people's access to housing across tenures; and reviewing the new Housing Needs and Demand Assessment process, and comparing this to Local Authority future development plans to see if the needs of older and disabled people are being met. (Third sector / equality organisation - Scottish Disability Equality Forum and Capability Scotland)

Another consultee mentioned commitments that they would like to add under this heading, including a review of care homes and a review of support for families who care for a disabled person.

Adaptations

The importance of being able to adapt a home in order to stay in it was emphasised. It was noted that timely referral to an occupational therapist played an important role in this. In addition, the point was made that if a home which has previously been adapted becomes available it should be given to a disabled person, rather than those adaptations being removed and it being offered to someone else.

What is meant by accessibility

It was commented that accessibility can mean different things to different people and therefore needs to be defined. Some consultees mentioned that accessibility was about more than just wheelchair access, and the needs of hearing impaired and D/deaf people, and the support needs of people with learning disabilities in particular were highlighted by some consultees.

Other

Other comments referred to the lack of advice around housing, and the continuing need for the Scottish Government to mitigate the effects of the "bedroom tax", and its implications for disabled people who may need an extra room for a personal assistant to stay overnight or for storing equipment.

Tourism and Business

6. A new help guide aimed at boosting accessible design will be published creating a legacy for the 2016 Year of Innovation, Architecture & Design. Working in partnership with VisitScotland and architectural bodies, the guide will help architects design accessible buildings which fully meet the needs of disabled people.

Consultees were generally supportive of a new guide aimed at boosting accessible design, and some provided suggestions for what the guide should include. Others thought that something stronger than a guide was needed and called for enforcement. Engagement with relevant stakeholders and the need for more training around accessible design were also highlighted. Table 10, below, shows the key themes identified.

Table 10: themes identified under commitment 6

Theme identified	Number of comments relating to this theme
Generally supportive	10
Monitoring, accountability and enforcement	7
Engagement	6
What the guide should include	10
More training for professionals around inclusive design	4
Build on existing guides and resources	3
Critical comments	1
Other	2

What the guide should include

Some consultees provided suggestions for what the guide should include and how it should be communicated. It was suggested that both BSL and inclusive communication should be taken into account when developing and disseminating the guide. There was also a suggestion that the guide take cross-cutting issues such as transport into consideration, as well as a call for it to look into how historic buildings could be made more accessible, as well as new builds.

"It is important to consider travel and transport links with regard to accessible design. It would be of little use to disabled people if a museum or gallery was fully accessible if there were no ways of getting to it that were accessible and affordable, as well as decent accessible parking spaces."

Third sector / equality organisation - Inclusion Scotland

Monitoring, accountability and enforcement

Whilst a guide was generally seen as a step in the right direction, a number of consultees felt that this commitment should go further and introduce mandatory enforceable guidance around accessibility. It was stated that planners needed to be held accountable. It was also noted that it was unclear how uptake of this guidance would be monitored.

"Our respondents are supportive of this commitment but are concerned that a guide will not be enough to improve access. It was felt that mandatory guidance on accessible design needs to be made available to builders and architects when they are undergoing initial professional training and that disabled people need to be involved in the creation of this guidance."

Third sector / equality organisation - Scottish Disability Equality Forum

Engagement

It was regarded as important to engage with a wide range or relevant stakeholders, including disabled people, professionals and children and young people.

More training for professionals around inclusive design

There was a call for more training for professionals around inclusive design, including considering acoustics in public buildings for those who are D/deaf or hard of hearing. It was commented that the Design Council in England and Wales were conducting research on and were soon going to launch an e-module in inclusive design, and that it would be good for something similar to happen in Scotland.

"East Ayrshire Council would encourage Scottish Government to follow the lead from the legacy works since London 2012. There is a Built Environment Professional Education Board ( BEPE) which is working to encourage professional organisations and universities to educate individuals in the specialism which is inclusive design."

Local government - East Ayrshire Council

Build on existing guides and resources

It was noted that examples of good practice existed and that these should be built on. "Euan's Guide", a web based guide used by disabled people and the London 2012 Legacy work was mentioned.

Critical comment

One consultee questioned why such a guide was needed as architects already had enough guidance, and that the real issue was how to ensure that such guidance was acted upon.

Other

Other comments included a call for more detail on this commitment, and a comment around the importance of making day trips and holidays accessible for disabled people and their carers.

7. A new help guide to assist tourism businesses - to create more innovative and accessible websites will be provided, celebrating the 2016 Year of Innovation, Architecture and Design, helping businesses showcase their offer to disabled visitors.

Whilst consultees were generally supportive of the idea of a guide to assist tourism businesses to create more innovative and accessible websites, this also opened up discussion around disabled people's access to the internet more widely. The recurring themes of the need for inclusive communication and engaging with disabled people were raised. Table 11, below, shows the key themes identified.

Table 11: themes identified under commitment 7

Theme identified	Number of comments relating to this theme
Generally supportive	10
Scope of guide	5
Inclusive communication	3
Engagement	2
Access to internet	2
Other	4

Scope of guide

There was some discussion around the scope of the guide, including suggestions that it should be made mandatory in order to be effective. It was also commented that the guide's focus should be wider than just about physical access, whilst another consultee emphasised the importance of disabled changing places in order to allow disabled people full access.

"We were pleased to note the content around tourism and the encouragement that people with disability have rights to live a life the same as any other. It is hoped that this work will reflect more than just physical accessibility and encourage an awareness of people with a range of disabilities as potential valuable and valued customers."

Public Body - Social Work, Dundee City Council

Inclusive communication

The importance of inclusive communication was mentioned, including providing accessible guides and information in BSL, as well as accessible websites. "Euan's Guide" and Ireland's Tourist Information website were presented as being good examples of best practice.

"In terms of current online information provision Euan's Guide and Ireland's Tourist Information websites were considered to be best practice examples. One respondent stated that the guide would be particularly useful as a lot of Tourist Information and Travel Agent Websites are beginning to become extremely difficult for disabled people to use (particularly for Screen Reader Users)."

Third sector / equality organisation - Scottish Disability Equality Forum

Engagement

It was mentioned that disabled people should be involved in helping to develop the guidance.

Access to internet

It was highlighted that not all disabled people have access to, or are able to use the internet, and that more should be done to increase disabled people's access to the internet more generally. The need for off-line information for disabled people without internet access was also highlighted.

"Disabled people are generally supportive of making tourism websites as accessible as possible. It was agreed that some online information is broadly quite accessible, where disabled people have access to the internet in the first place - remembering that a significant proportion of disabled people do not have internet access due to various barriers."

Third sector / equality organisation - Inclusion Scotland

Other

Other comments included information from a Local Authority about what they are doing to make tourism more accessible, and a call for the guidance to recognise the role of disabled people as potential providers of tourism services, as well as consumers.

8. A new help guide setting out key accessibility hints and tips to meet the needs of disabled people attending events in 2015 and beyond will be provided to celebrate the 2015 Year of Food and Drink. The guide will focus on tourism businesses and visitor attractions. (2016)

Most of the comments around commitment 8 provided suggestions as to what the new help guide could usefully include. There were suggestions that the guide should be mandatory, and the importance of engaging with disabled people and DPOs was emphasised. Table 12, below, shows key themes identified.

Table 12: themes identified under commitment 8

Theme identified	Number of comments relating to this theme
Generally supportive	9
What the guide should include	16
Engagement	5

What the guide should include

The most common suggestions for what the guide should include were: support for those with sensory impairments and learning disabilities, including the provision of information in BSL, and the need for accessible toilets and accessible changing places. There was also a suggestion relating to support for holding communication inclusive events. There were also comments that the guide should be made mandatory.

"Leonard Cheshire Disability would like to emphasise that such a guide should include the accessibility requirements of people with sensory impairments and learning disabilities. For example: colour coding areas of public buildings would allow people with sight loss to better identify which area of a building they are in, and travel more easily as a result."

Third sector / equality organisation - Leonard Cheshire Disability

Engagement

Once again, it was felt that disabled people themselves and DPOs were best placed to inform this work, and should be involved. Inclusion Scotland mentioned an Accessible Engagement Handbook which they were in the process of developing and which they would be happy for Visit Scotland to draw upon.

9. Access Statement online Tool Builder - a refresh of the current tool will be undertaken to re-design a more IT-based version that enables tourism businesses to build online and maximise the use of modern technology. This will support both the consumer and the tourism/events industries and boost the 2016 Year of innovation, Architecture & Design as part of the wider Accessible Tourism project.

There were relatively few comments around commitment 9. Most consultees indicated that they were broadly supportive of this commitment, and some comments provided suggestions around the design, implementation and monitoring of the access statement online tool builder. Table 13, below, shows the key themes identified.

Table 13: themes identified under commitment 9

Theme identified	Number of comments relating to this theme
Generally supportive	8
Design, implementation and monitoring	6
Other	1

Design, implementation and monitoring

Comments around design, implementation and monitoring, included comments about the need for inclusive communication, including providing information in BSL, and the need to monitor implementation.

Culture

10. Widening access and increasing opportunities for disabled people to engage in culture and heritage and the arts - Creative Scotland is undertaking a wide ranging review of equalities, diversity and inclusion in the arts, screen and creative industries. The findings of this review will be used to inform all areas of Creative Scotland's work. It complements significant programmes which are helping more people, including disabled people take part in the arts, as professional artists and performers, participants or audience members. (2016)

There was a wide range of comments under commitment 10, and the importance of inclusive communication and engagement was emphasised. Table 14, below, shows the key themes identified.

Table 14: themes identified under commitment 10

Theme identified	Number of comments relating to this theme
Generally supportive	10
Inclusive communication	6
The disability arts scene and disability in mainstream culture	5
Accessible facilities needed	5
Engagement	4
Other	11

Generally supportive

Consultees were generally supportive of this commitment, and felt that increased access to culture, heritage and the arts could enhance the lives of disabled people.

"This commitment is greatly welcomed by respondents as the following response shows: 'In Scotland we have come a long way in the recent past in making venues and events more accessible, although some venues are still a nightmare to negotiate. As a person who loves music, film, theatre, art galleries and museums, disabled people should be encouraged to become involved in the arts as it enriches their lives.'"

Third sector / equality organisation - Scottish Disability Equality Forum

Inclusive communication

Inclusive communication was seen as essential and there was a call for an audit of the "communication inclusion" of cultural opportunities against "Good Communication Support Principles" or Principles of Inclusive Communication. It was also mentioned that D/deaf professionals should be involved in giving guided tours and talks in BSL, and that there should be increased use of braille - for example in relation to CD music lists.

The disability arts scene and disability in mainstream culture

It was noted that a disability arts scene exists in Scotland and that more should be done to promote it. It was also mentioned that mainstream culture does not adequately take disability into account. There was a call for more disabled role models, for example, in films and on TV. There were also concerns expressed that where disability is mainstreamed disabled people need to maintain control over how disability is portrayed in order to avoid tokenism, or non-disabled people playing disabled parts. It was felt that Creative Scotland needed to hold outreach events which are accessible and inclusive for disabled people. Further, it was suggested that Creative Scotland could support outreach projects whereby disabled performances / actors go into schools to help reduce stigma and promote disability rights amongst young people.

"There is also a need to promote and support the vibrant disability arts scene that exists in Scotland. On International day of Disabled People (3rd December) in 2015, we were pleased to see Creative Scotland's website feature an article about Disability Arts in Scotland; we agree that increased publicity of this pride in our arts scene should be a prominent feature included in the review."

Third sector / equality organisation - Inclusion Scotland

"We should also be talking about seizing such an opportunity to create inspirational role models for disabled children and young people. Children growing up today will see many more disabled people in key roles e.g. TV. films etc. This has to be seen as a positive in terms of increasing inclusion."

Public Body - Children and Young People's Commissioner

Accessible facilities and staff training

The need for improved access to facilities was highlighted, as was the need to train staff around accessibility.

"Respondents felt that accessibility requirements need to increase, for example, the need for more accessible parking, more wheelchair transfer seats and the provision of accessible transport to get to venues."

Third sector / equality organisation - Scottish Disability Equality Forum

Engagement

The need for appropriate engagement was highlighted. It was thought that in addition to engaging with disabled people, engagement with children and young people was also required, as was engagement with specialist groups in order to facilitate access for those who may be the most excluded, such as those with profound and multiple learning disabilities ( PMLD). One local authority highlighted the work that it had done in partnership with disabled people to widen access to culture.

"In Aberdeen, the Lemon Tree and Arts Centre work positively proactively with people from the protected characteristics groups and are inclusive in their approach. His Majesty's Theatre ( HMT) has a sign language interpreter, providing access for people with hearing impairments. Disabled people have also been involved in the refurbishment of Aberdeen Art Gallery and Music Hall and the Maritime Museum is currently working with the Equalities Team and community groups so that projects/ events/ exhibitions are more inclusive."

Local government - Aberdeen City Council (2 Equalities Team)

"This requires working with specialist organisations in order to ensure that the most excluded people within society - e.g. people with profound and multiple learning disabilities ( PMLD) are also able to access and engage in their culture, heritage and the arts. It is possible but takes expertise and planning and education of staff and the communities. Consideration also has [to] ensure that accessibility is available at a cognitive, sensory as well as physical level."

Academic or Research Institute - PAMIS

Other

Other comments made included the need for transport links to facilitate access to culture and the fact that cost can be a barrier to participation.

11. Recording and reporting of workforce diversity information - a project is being undertaken to improve the recording and reporting of workforce diversity information to improve the evidence base and measure the success of policies. A new Non Departmental Public Body called Historic Environment Scotland ( HES) will take over the responsibilities of Historic Scotland and the Royal Commission on Ancient and Historic Monuments of Scotland on 1 October 2015. (2017)

Whilst consultees were generally supportive of this commitment, there were calls to widen it out to include other workforces, not just culture. A number of comments revolved around the practicalities of collecting this information. Table 15, below, shows the key themes identified.

Table 15: themes identified under commitment 11

Theme identified	Number of comments relating to this theme
Generally supportive	9
Who should be included	8
The practicalities of collecting this information	7
Critical comments	1
Other	3

Who should be included

There was some discussion around who should be included in such statistics, with calls for volunteers and interns to be included. In addition a number of consultees strongly believed that this commitment should be extended to the wider workforce in Scotland, and not just be restricted to culture.

"We would welcome data recording to improve evidence collected and to measure the successes of policies. However we would call on the Scottish Government to extend this to ensure similar efforts are afforded to the wider workforce in Scotland."

Third sector / equality organisation - HIV Scotland & NAT (National AIDS Trust)

The practicalities of collecting this information

Some questions were raised around collecting this data, in particular who would collect it and what it would be used for. It was thought that reporting should tie in with existing mechanisms used, and that employers would benefit from training and awareness raising around collecting this information. The importance of using this information to learn and improve was also noted.

"Respondents called for clarity around how this information would be used and why it is of importance in terms of shaping services and the impacts on funding."

Third sector / equality organisation - Scottish Disability Equality Forum

Critical comment

Whilst supportive of the commitment, one consultee did say that they were sceptical that this information would be thoroughly and honestly recorded.

Other

Other comments included suggestions for how to encourage more disabled people to work in culture, such as stating in job adverts that applications from disabled people are welcomed, and opportunities for D/deaf people to provide sign language tours for D/deaf visitors.

12. Improving access to the historic environment and collections relating to the historic environment - including improving access to HES buildings and monuments and improving online access to its collections, services and outreach and community engagement programmes. (2016-19)

Consultees were generally supportive of this commitment. There was an acknowledgement that making historical buildings accessible is not a cheap or easy process, and in some cases may not be possible. Therefore there was support to explore alternative ways of making them accessible, such as the use of virtual access tours of building. Table 16, below, shows the key themes identified.

Table 16: themes identified under commitment 12

Theme identified	Number of comments relating to this theme
Generally supportive	10
Explore alternative, e.g. virtual access to buildings which can't be altered	6
Engagement	4
Build on current good practice	3
Implementation	2
Other	8

Explore alternative, e.g. virtual access to buildings which can't be altered

Consultees appreciated the challenges of adapting historic buildings to make them accessible and acknowledged that this might not always be possible. As such, the use of innovation and technology to improve access, such as through virtual tours, or online access to collections were suggested as appropriate alternatives. One consultee, however, did emphasise the need to try and improve physical access and said that online access should not become a substitute for physical access. Other positive examples of making the historic environment more accessible included: descriptive hand-held guides in galleries and museums; tactile paintings; visual cues; captioning and BSL guides.

"This commitment is very much welcomed by respondents. There was recognition from online respondents and road show participants that historic sites and old and/or listed buildings cannot always be made fully accessible to disabled people… Virtual reality tours were found to be particularly effective in these cases."

Third sector / equality organisation - Scottish Disability Equality Forum

"On-line access to collections would help, but it is important that the on-line world doesn't become an alternative to physical access, and this includes being made to feel welcome."

Third sector / equality organisation - Sense Scotland

Engagement

The importance of consulting with disabled people and utilising the expertise of specialist organisations was highlighted.

Build on current good practice

Consultees noted current good practice that already existed to help make the historical environment more accessible. It was seen as important to review and share that good practice. It was also mentioned that it would be helpful to publish case studies of properties which had been adapted but kept their character.

"Disabled people we consulted noted some good practice, such as descriptive hand-held guides in many galleries and museums, and availability of tactile paintings (available from the Living Paintings Trust); visual cues, captioning and BSL guides. We therefore advocate a review of current and international good practice with recommendations for promoting further roll-out, widening access and mainstreaming such practices."

Third sector / equality organisation - Inclusion Scotland

Implementation

The importance of sufficient funding and improving the use of inclusive communication was also noted by consultees.

Other

Other comments included emphasising that cost can be a barrier in accessing the historical environment, and the importance of transport to access the historical environment. A couple of consultees also took this opportunity to express their dissatisfaction with current access to historical buildings.

Sport and Physical Activity

13. Disability Inclusion in Sport - disabled people will have greater opportunities to participate in sport as funding of £6 million has been committed towards a new parasport facility in Inverclyde. (opens in 2016)

Whilst there was support for this commitment, there were also a number of criticisms, including that a new para sport facility in Inverclyde would not benefit the majority of disabled people in Scotland, and that investment throughout Scotland was needed, including making local facilities more accessible. Table 17, below, shows the key themes identified.

Table 17: themes identified under commitment 13

Theme identified	Number of comments relating to this theme
Generally supportive	9
Critical comments - Geographical disadvantage	8
Physical access needs and training and attitude of sporting workforce	6
Support disabled people to access sporting facilities and participate	4
Engagement	2
Inclusive communication	2
Other	10

Critical comments - Geographical disadvantage

Central to this commitment was the development of a new para sport facility in Inverclyde. It was stated that one centre in the central belt of Scotland was not sufficient and would not benefit the many disabled people in Scotland who wanted to participate in sport. Instead, investment was wanted in sports centres throughout Scotland to benefit more people, including making existing local sports centres more accessible to disabled people. It was also suggested that an outreach programme was required to allow people from outwith the area to benefit from the new para sport facility.

"The location of the Centre will not be suitable to some potential users, and development of smaller - scale local facilities must follow in the wake of this development in order to provide a wide range of opportunities."

Individual

"The development of opportunities to participate in sport will benefit the health and wellbeing of people we support. While parasport centres will be beneficial, it is important that staff and facilities in local sports centres and clubs are welcoming and accessible. Disabled people should be able to access the same sports locations as their non-disabled friends and family members."

Third sector / equality organization - Sense Scotland

"The provision of one Parasport Centre in Inverclyde was felt to be woefully inadequate in improve disability inclusion in sport in Scotland. 'It will not support those in the Grampian areas and north of Scotland. Much of these sporting provisions are found within the central belt already. There needs to be a wider program and access opportunities throughout Scotland'."

Third sector / equality organization - Scottish Disability Equality Forum

Physical access needs and training and attitude of sporting workforce

There was a call for local sports centres to be made more accessible. Specific access needs mentioned the need for accessible toilets and changing facilities and the need for more adaptive equipment within the centres.

"Even where sport and leisure venues are accessible respondents suggested a need for more adaptive equipment so that disabled people could better engage with facilities and activities once they are through the door."

Third sector / equality organisation - Scottish Disability Equality Forum

As well as physical access needs, there was a call for staff who work in sport to have better training and awareness around disability, and for them to be friendly and welcoming.

Support disabled people to access sporting facilities and participate

It was commented that participating in sport is not just about accessible facilities, but also providing support for disabled people to help them access those facilities. In particular, it was mentioned that young disabled people might require extra support to access sports as they are often reliant on their parents to take them, but that participation in sport might not be given high priority. It was also mentioned that people with learning disabilities might require additional support to access sporting facilities.

"Disabled children and young people tell us that they are often reliant on their parents to get them to venues, but that because of costs associated with bringing up a disabled child, sport is given lower priority and is often seen as luxury. Disabled children and young people still continue to experience difficulty accessing mainstream social and recreational' sport opportunities."

Public Body - Children and Young People's Commissioner

Engagement

It was commented that there needed to be engagement with a wide range of stakeholders, including DPOs, Health Boards and Local Authorities.

Inclusive communication

Inclusive communication and the need to provide communication and language support to help disabled people participate in sport were mentioned.

Other

Amongst the other comments received, a couple of consultees felt that there should be more funding for D/deaf athletes to participate in sporting competitions, and the importance of transport links for accessing sporting facilities was mentioned. There was a call to widely publicise any programme to include disabled people in sport in order to boost uptake.

14. An Action Plan for disabled people - In our commitment to equality, the Scottish Government and Sportscotland will work with disabled people to develop an action plan on existing initiatives to promote disabled people's participation at all levels of sport and physical activity. (2016-19)

Consultees were generally supportive of this commitment, although they also outlined current barriers to and dissatisfaction with disabled people's access to sport. The need for engagement and inclusive communication was highlighted. Table 18, below, lists the key themes identified.

Table 18: themes identified under commitment 14

Theme identified	Number of comments relating to this theme
Generally supportive	13
Barriers to, and current dissatisfaction with disabled people's access to sport	13
Positive examples	4
Engagement	3
Inclusive communication	1
Those who were critical	3
Other	5

Generally supportive

A number of consultees commented that they were supportive of this commitment as access to sport was seen as important for disabled people, both in terms of the impact it would have on them personally, but also in terms of inclusion within society.

"This commitment is welcomed by respondents, sport was felt to be very important to disabled people as it 'encourages team work, confidence building and provides exercise for people who may be very sedentary, which in turn will increase health and well-being'."

Third sector / equality organisation - Scottish Disability Equality Forum

"Promoting disabled people's participation in sport and physical is an essential action point to ensure that disabled people are not excluded within an important cultural element of Scottish society."

Third sector / equality organisation - HIV Scotland & NAT (National AIDS Trust)

Barriers to, and current dissatisfaction with, disabled people's access to sport

A number of consultees mentioned barriers that exist which make it harder for disabled people to access sport, and some reflected on their dissatisfaction with current facilities.

Amongst the barriers raised was a need for increased funding and support to make sport inclusive for all, and in particular it was noted that D/deaf sports people are disadvantaged at both mainstream and para events, "neither of which accommodate their communication needs" (Third sector / equality group - Inclusion Scotland). It was also noted that people with certain disabilities, such as profound multiple learning disabilities ( PMLD) may require more support than others, whilst another consultee felt that adequate support for those with autism was not currently being provided.

Other barriers mentioned included: the cost of participating in sport or accessing sporting facilities; the times that such facilities are available; and a lack of suitable changing facilities. In addition, it was noted that more could be done to make mainstream facilities more accessible, such as support or technology to help visually impaired people use gym equipment unaided. The ban on people with HIV participating in certain sports, such as boxing, was also noted as a barrier. The need for adequate numbers of staff, who are well trained was also noted.

"The availability of high quality training opportunities for sports coaches is key to ensuring these activities are inclusive and NDCS recommends the Scottish Government reference a commitment to ensuring teachers and coaches have access to training on the specific needs of disabled children and young people."

Third sector / equality organisation - National Deaf Children's Society

Positive examples

A number of consultees provided positive examples, and hoped that lessons could be learned from them. These included the activity of a local authority with a Legacy Plan which "contains specific actions in relation to promotion and development of disability sport" (Local government - East Ayrshire Council), the Me2 initiative with the National Children's Deaf Society, the Try Rugby programme with the Scottish Rugby Union and the Glasgow 2012 Commonwealth Games.

" NDCS has worked with a range of sports clubs and organisations as part of the NDCS Me2 initiative. The Me2 pledge is about making clubs and organisations activities deaf friendly and fully accessible to deaf children. The vision is for young deaf people to be able to participate on equal terms with their hearing peers across a wide range of activities."

Third sector / equality organisation - National Deaf Children's Society

"Road show participants were keen to stress that the Glasgow Commonwealth Games provided a great example of disability inclusion which in turn promoted a positive public message about disability so important to challenging negative attitudes and stereotyping."

Third sector / equality organisation - Scottish Disability Equality Forum

Engagement

The need for engagement was highlighted, and it was suggested that in addition to engaging with disabled people more generally, children and young people should also be involved in the process.

Critical comments

Those consultees who were critical of the commitment mentioned that it would only benefit a minority of disabled people. There were also concerns that disability inclusion in sports is not already being promoted, and a belief that whilst promotion was a positive step, more needed to be done in terms of investing resources to support disabled people to participate.

Other

Amongst other comments made, was a call for more detail on the commitment, along with a question on why it was limited to existing activity. It was also noted that this commitment was cross-cutting and should link in with other policy initiatives including the National Conversation on a Healthier Scotland, and again the importance of transport links to access sport was highlighted.

15. sportscotland - the national agency for Sport will ensure that the needs of disabled people and athletes are addressed through investment to Scottish Disability Sport, Active Schools Network, the 2016 Rio Olympic Games, the 2018 Pyeongchang Winter Olympics and Gold Coast Commonwealth Games.

Consultees were generally supportive of this commitment, and a number of comments were made about what would be required in order to make it work in practice. Table 19, below, outlines the key themes identified.

Table 19: themes identified under commitment 15

Theme identified	Number of comments relating to this theme
Generally supportive	6
Implementation	8
Critical comments	4
Other	2

Implementation

A number of suggestions were made about what would be required in order for this commitment to work in practice. These included the need for local level access to sport; cooperation between different bodies, such as local authorities and health boards; the necessity of inclusive communication; improved funding for disabled sport; and the need to train the sporting workforce.

The importance of addressing access to sport at all levels, not just elite, was also mentioned. It was observed that more investment was required in sport for disabled children to increase their participation beyond the two hours a week PE provided at school. It was also noted that disabled people needed access to view and participate in sports in order to feel more "invested" in Commonwealth and Olympic Games.

"More investment needs to be made into local level accessible sports and fitness activities that include access to Paralympic sports. As mentioned above, if disabled people cannot get access to sports (viewing and participating) they are less likely to be themselves invested in these games. With that in mind, investment in coaching, as well as accessible travel and transport, would improve Scottish para teams' chances of winning medals and promoting para-sports, and we therefore support this initiative"

Third sector / equality organisation - Inclusion Scotland

Critical comments

Some commented that the commitment was too vague, whilst others believed that it was more important to invest money in other areas to improve disabled people's lives before focusing on sport. Another consultee believed that such support should already be in place.

"While we acknowledge that there is real benefit in Sports we feel that an appropriate income and equal life chances overall are critical to promoting equality and are a necessary precursor to sport developments for people with a disability."

Public Body - Social Work, Dundee City Council

Other

Amongst the other comments one council outlined how they are currently using Sportscotland funding to improve inclusion in sport.

"The Council utilises sportscotland funding to support local delivery of national programmes such as Active Schools and Community Sports Hubs. This is utilised in inclusive provision and in particular within Active Schools we have a specific coordinator to support the development of disability activities within our special schools and support unit."

Local government - East Ayrshire Council

Awareness-raising campaign

16. A future phase of the One Scotland Campaign will focus on raising awareness of the barriers that disabled people face in society (2017).

Consultees were generally supportive of this commitment, but there were also comments that barriers needed to be tackled, not just raised, and that education and training would be a better approach than an awareness campaign. Most comments contained suggestions about what the campaign could include and how it could be delivered. Table 20, below, highlights the key themes identified.

Table 20: themes identified under commitment 16

Theme identified	Number of comments relating to this theme
Generally supportive	10
What the campaign could include and how it could be delivered	20
Engagement	8
Need to deal with the barriers as well as raise awareness of them	7
Education and training better than awareness raising campaign	5
More clarity required on commitment	3

Generally Supportive

Amongst consultees who were supportive of this commitment, the importance of attitudes towards disability and the existence of attitudinal barriers for disabled people were highlighted.

"We undertook a consultation with 1000 disabled people to determine what barriers still existed for those we support. Almost 40% of respondents saw that attitudinal barriers are their greatest concern. Capability Scotland would therefore welcome potential involvement in a national campaign similar to the 'See Me' campaign to tackle these barriers and promote disability equality."

Third sector / equality organisation - Capability Scotland

"Environmental change is critical but insufficient without fundamental cultural and attitudinal shift and therefore we also strongly support commitment 16. We hope this will not just be a short term public awareness campaign; rather we believe this should be a long term programme of education built into all educational curricula from pre-school to higher education including professional training for those working across health, education, sports, building, planning, culture and tourism etc."

Third sector / equality organisation - Independent Living Fund Scotland

What the campaign could include and how it could be delivered

A number of consultees highlighted the importance of the campaign covering a wide range of disabilities, especially those which are "unseen" or might not immediately be obvious, such as mental health conditions, autism, learning disabilities, sensory impairments and communication support needs.

"Disability is a complex subject particularly for those who look 'normal' but may have sensory and mental issues.....these are the people whom our modern society don't make allowances".

Individual

It was felt that there was a specific need to target employers and raise awareness about removing barriers to allow disabled people better access to employment.

"It was suggested that, rather than just awareness raising, the Government could also start a campaign that would inform other organisations, businesses and other employers about what they can do to break down the barriers disabled face accessing work. 'Please, whilst showing barriers, also show how easy it can be to remove these barriers and what a great difference removal of barriers can make to disabled people's lives.'"

Third sector / equality organisation - Scottish Disability Equality Forum

It was also suggested that the campaign should promote positive messages about disabled people and their contribution to society and aim to end stigma and hate crime directed towards disabled people. There were also suggestions around very specific issues such as the impact of honour crime and forced marriage on disabled people.

"They also asked for an awareness raising campaign to highlight disabled people's positive contribution to Scottish society; this would be wholeheartedly supported. This is because disabled people's experience of discrimination has been rising in response to the UK government's negative welfare cuts campaign work; and the mainstream media's consistently negative stories about so-called benefit 'cheats' and 'scroungers'. Quote: "I've been spat on, shouted at, pushed, bullied." There is a plethora of evidence on the impacts and rise of disability hate crime which do not require to be reiterated here and a real sense of fear amongst disabled people that we consulted."

Third sector / equality organisation - Inclusion Scotland

In terms of how the campaign is delivered, it was suggested that schools should be involved and that mixed media be used to reach the widest possible audience. It was also suggested that the campaign should be connected with national days, such as Human Rights Day or the International Day of Disabled People to raise the profile of the campaign.

Engagement

The need for engagement was highlighted, and it was stated that disabled people, DPOs and children and young people should be involved in co-producing the campaign from the start.

"We welcome the One Scotland campaign to draw awareness of the barriers disabled people face in society. In the future phase of the campaign that is referenced, disabled people should have meaningful opportunities to participate and shape the direction of the campaign. Disabled people have direct experience of these barriers and steps must be taken to ensure that it is their experiences which shape and inform the campaign."

Third sector / equality organisation - HIV Scotland & NAT (National AIDS Trust)

Need to deal with the barriers as well as raise awareness of them

Whilst awareness-raising was recognised as being a good thing, action to tackle the barriers would be even better.

"This campaign not only needs to raise awareness of the barriers but must create an expectation that people across Scotland need to work together to remove the barriers."

Public Body - Social Work, Dundee City Council

Education and training better than awareness raising campaign

Some respondents believed that longer term education and training opportunities would be more effective than an awareness raising campaign, and emphasised that such education should start with young children and be on-going.

"Inclusion Scotland has long been asking for disability awareness and equality to be taught as part of the mainstream curriculum, as a preventative measure to educating young non-disabled people and children not to use words related to disability in disparaging ways to bully others, and who may even grow up to commit hate crimes against members of their community. Disabled people contributing to the ILiS Interim Report of Scotland's Disabled People's Summit 2015 echoed these views."

Third sector / equality organization - Inclusion Scotland

More clarity required on commitment

It was commented that the commitment was a little vague and that more information was required, including more clarity around how it would be taken forward.

Q5: Are there any additional commitments and/or ways that you would strengthen the Outcome 1 commitments that you have not already mentioned in any comments above?

Forty-two consultees responded to this question. Where a comment related to a specific commitment, it was themed as part of the response to that commitment, rather than as part of question 5.

A range of comments were received in response to question 5. These included general comments about the commitments, as well as specific additions that consultees would like to see covered by the Outcome 1 commitments. Table 21, below, shows the key themes identified at question 5.

Table 21: themes identified under question 5

Theme identified	Number of comments relating to this theme
Supportive of this outcome	2
General comments	9
Commitments to add/areas to focus more on	17
Engagement	3
Models of disability	2
Other	6

General comments

A range of general comments were made, including the need for the commitments to be firm with specific targets to be achieved by set dates, and for these commitments to constitute legal rights. There was a comment that housing and transport were key, and should be tackled before sport and culture, as appropriate housing and access to transport are prerequisites to participation in sport and culture. It was also commented that the commitments did not go sufficiently far to help disabled people realise their rights under the UNCRPD. It was stated that various UN conventions on human rights, such as the UN Convention on the Rights of the Child ( UNCRC) and the UNCRPD, should not be considered and implemented in isolation, but as part of a cohesive whole. There was also a suggestion about how to better organise commitments in relation to the UNCRDP.

"The UN treaties should not be viewed in silos but rather in a way which reflects that the UNCRPD recognises the specific vulnerabilities of and difficulties facing disabled children and young people, and offers added protections in addition to their rights as enshrined in the UNCRC."

Third sector / equality organization - Together (Scottish Alliance for Children's Rights)

"Identifying the issues that are preventing disabled people from enjoying their rights under each UNCRPD article and then identifying the commitments to address these issues under each article would, in our view, provide a clearer demonstration of how the Government is implementing the UNCRPD."

Third sector / equality organization - Equality Human Rights Commission and Scottish Human Rights Commission

Commitments to add/areas to focus more on

Consultees also made suggestions for general themes or specific commitments that they would like to see added under commitment one.

It was stated that there was not sufficient focus on children and young people or on early year's policies.

"In order to strengthen the outcome 1 commitments for disabled children and young people, a Child Rights and Wellbeing Impact Assessment ( CRWIA) should be used to predict, monitor, strengthen or if necessary, avoid, the impact of each commitment on disabled children and young people. This would help to identify where further commitments are necessary, or existing commitments should be amended, in order to fulfil the government's obligations under the UNCRPD for disabled children and young people."

Third sector / equality organisation - Together (Scottish Alliance for Children's Rights)

"The final point I wish to make is the need to improve and transform our approach to children in their earliest years - from pre-birth through to their entry into formal education. This is a priority for my office, yet there is little mention of the early years in the document as a whole, and one which cuts across all four outcomes."

Public Body - Children and Young People's Commissioner

It was believed that insufficient attention was given to mental health, learning disabilities and dementia.

"As per our response to Q2, we are disappointed by the lack of any detailed commitments with regard to mental health, learning disability and dementia. In particular, we would like to see clear commitments to ensuring that the rights in Article 19 to living independently in the community are protected in relation to learning disability and dementia. We are concerned that funding pressures in social care will result in greater use of institutional care, and the advances in independent living seen for some in the last 20 years will be undermined."

Public Body - Mental Welfare Commission for Scotland

The College of Occupational Therapists suggested the inclusion of a specific commitment, "improve access to occupational therapy assessment to facilitate timely adaptations" as adaptations to a house can help older or disabled people to continue to live independently in their own homes, however the waiting lists for occupational therapy assessments to facilitate this vary across Scotland and can be lengthy.

There was a call for additional commitments for public service providers, including all public sector bodies, to require them to assess the accessibility needs of all groups of disabled people, and for public sector staff to be trained on disability and how they can help remove barriers for disabled people.

"A commitment should also be made to train all public sector staff on disability and how they can contribute to removing barriers to inclusion and participation (highlighting different issues which may arise for different types of disability)."

Academic or Research Institute - Centre for Mental Health and Incapacity Law, Rights and Policy - Edinburgh Napier University

Other more general suggestions included: capacity building for disabled people, including children and young people; providing more detail around affordable

housing; including the term "leisure" with culture and sport; the importance of supporting social interaction and friendships, especially in people with learning disabilities; the importance of disabled people's right to privacy; the importance of disabled people knowing their rights and having access to information; and legislating for accessible changing places.

Engagement

The need to engage with disabled people and their carers and families was emphasised, in order to take into account their experience and knowledge.

"Look at the knowledge, experience and value of disabled groups and access panels and use their strengths in areas which involve disability related decisions."

Individual

"We can only keep stressing that if the desired outcomes are to benefit those who have disabilities then it has to be guaranteed that those people will be part of the process at all levels."

Third sector / equality organisation - Saving Down syndrome

Models of disability

A couple of comments were made relating to the way disability was portrayed, or the model of disability which was used. Whilst one consultee commented that they supported the social model of disability used, another commented that they would have preferred a more assets-based definition, which focuses on what people can do, rather than what they cannot.

"We are particularly supportive of a social model of disability that prioritizes environmental changes to ensure disabled people are able to be active citizens in their own community."

Third sector / equality organisation - Independent Living Fund Scotland

"There needs to be recognition that we are all different and have differing abilities. As a society we tend to focus on a person's disability rather than their ability. I believe we need to shift the focus and emphasis - ability and not disability."

Individual

Other

Additional comments included: examples from local authorities about what they were currently doing to work towards Outcome 1, with one local authority highlighting the work it was doing to include disabled people from ethnic minorities, including refugees; and a comment about the conflict between human rights, including the right of the unborn child and pre-natal screening for foetal abnormalities.