Learning Disabilities, Autism and Neurodivergence Bill: consultation analysis

Section 12: Transport

Introduction

The consultation document outlined the challenges faced while travelling by people with disabilities, people with learning disabilities and neurodivergent people. There is currently an ambitious and wide-ranging programme of work underway to make improvements, however the consultation document suggested that specific issues for people with learning disabilities and neurodivergent people could be addressed through the LDAN Bill.

Two specific proposals were presented for discussion at this section:

• Proposal 1: National and Local Strategies - requiring Regional Transport Partnerships (RTPs) to state how the specific needs of people with learning disabilities and neurodivergent people are being considered and met through travel information systems and accessibility initiatives. Also requiring RTPs to detail how staff across different modes of transport are being trained in disability awareness, how that training incorporates neurodivergence and learning disabilities, and the uptake of this.
• Proposal 2: Mandatory Training - extending the requirement for consistent statutory training to transport staff in Scotland.

Main Findings

Overall, 352 respondents provided feedback at this section, with over half agreeing with both of the proposals. Where respondents only supported one proposal, there was greater support for mandatory training compared to developing national and local strategies. Only a few respondents explicitly stated they disagreed with either or both proposals.

Proposal 1: National and Local Strategies

While this proposal was largely supported, comments in relation to the development of national and local strategies were limited. Most respondents did not set out a preference for national or local strategies, instead supporting a combination of both. Where respondents did express a preference however, a national strategy or national guidance received greater support than local strategies alone. As noted at other parts of the consultation, respondents were concerned that local strategies, without any overarching framework, would result in variation across the country. It was felt that a national strategy would help to ensure a consistent quality of service and a more joined up transport system to support cross boundary travel.

A few respondents, however, stressed the need for localised issues to be recognised and addressed, i.e. for remote rural and island areas.

Again, similar caveats and recommendations were made as at other sections:

• Strategies needed to be co-designed with those with lived experience;
• Transport providers must be resourced and funded to implement the strategy;
• The strategy must be effective in delivering change, it should not become a tick-box exercise;
• Statutory requirements/duties are needed and would be a better way of achieving change; and
• Strategies should be reviewed regularly (e.g. every five years).

The main issue raised, however, was the importance of accountability and enforcement to ensure strategies and improvements are delivered on the ground. While respondents supported the use of strategies in principle, it was argued that robust mechanisms needed to be implemented to ensure these are delivered and effective:

“We need to see actions and feel the benefit of the strategies in daily life. There is a ‘enforcement gap’ - we believe that enforcement powers for [Proposals] 1 and 2 need to be included on the face of the Bill. Even if actions are mandatory, how do we make actions accountable? We need to remain conscious of the “implementation gap” and produce and use better information and data to evidence that policy outcomes are delivered, driving progress, reducing inequalities and for transport…” (Organisation for Other Disability/ Condition)

Only a handful of respondents explicitly stated that they disagreed with Proposal 1. Most gave no reason for this while one individual felt that strategies would be “costly and do nothing”.

Proposal 2: Mandatory Training

Mandatory training was the most supported of the two proposals presented, with several of those who supported both proposals also stating that mandatory training was the most important element.

Many respondents agreed that the transport system would benefit from specialist training regarding learning disabilities and neurodivergence. There were many comments regarding the current lack of awareness, understanding and support, as well as perceived rudeness from transport staff. The majority of these comments were directed towards bus drivers:

“With respect to mandatory training, this may help. Staff are often unsure how to help people and some are downright rude.” (Family/Friend)

It was felt that training should be provided to all those who come into contact with the public, including (but not limited to) drivers, conductors, ticketing staff, and booking staff. It was also suggested training needed to cover all transport sectors, including buses, trains, planes and ferries, with some respondents also suggesting that taxi and licensed private hire providers/drivers and the British Transport Police should be required to undertake mandatory training. Taxis were highlighted as being important for inclusion here due to the problems and barriers that many people with learning disabilities and neurodivergent people experience in accessing and using mainstream public transport options and their increased reliance on taxis. A few also cited examples of poor experiences with taxi providers as justification for this training need.

Again, however, it was stressed that people with lived experience should be actively involved in the development and delivery of training.

Only a few respondents explicitly disagreed with Proposal 2. They typically felt that training would not solve the problems in transport as the biggest issue was accessibility and suitability of the infrastructure (e.g. it was generally too overwhelming to use public transport). Others felt that training for all staff was unnecessary as those who need support will most likely be travelling with someone who can already provide this:

“Training won’t help. Public transport is just completely inaccessible to autistic people.” (Neurodivergent Individual)

Other Comments and Considerations

Consistent with other sector specific sections, much of the feedback from respondents focused more generally on the difficulties and barriers people with learning disabilities and neurodivergent people face when accessing and using transport services, and the negative impacts that result from inaccessible and unsuitable transport systems, including isolation and difficulties accessing education, work opportunities, and other services. Some also made wider or more practical suggestions around how to improve the system. As such, a wide range of other considerations were raised by respondents, with the most commonly discussed issued outlined below.

More Inclusive Communication

Respondents highlighted difficulties in accessing current information about public transport services and called for greater use of inclusive communication. In particular, it was felt there was a need for improved signage and timetabling information:

“We would urge that when developing the LDAN Bill there is a commitment to communicate in an accessible manner that considers the principles of Inclusive Communication. This includes awareness of communicating in a manner which matches the strengths and preferences of each individual, as well as the availability of information in a range of accessible formats, including Easy Read, a format that uses simple, jargon-free language, shorter sentences and supporting image. This should be applied across all forms of public transport.” (Organisation for Other Disability/Condition)

Accessibility Initiatives

Accessibility was raised as a primary concern for many respondents. Some mentioned that those using wheelchairs had difficulty with access, ramps and steps. Others raised the issues of noise, space, smell and light as having a direct impact on the experience of travel and public transport use for some individuals. Indeed, some respondents mentioned how distressing it can be to use public services when senses are overloaded by noise, smell, colours and light. Crowded buses and carriages, bright lights and loud spaces were all cited as barriers to travel.

It was suggested that if more trains and buses were available, providing a reliable service and transport in all areas, then individual services would not be so crowded and overwhelming for neurodivergent people. Some also called for quiet carriages and quiet spaces in waiting areas, while a few respondents suggested offering dedicated quiet services/times (similar to those offered by some supermarkets) in order to meet the needs of people with learning disabilities and neurodivergent people.

Much of the remaining discussion around accessibility focused more on physical disabilities, however, rather than being specific to people with learning disabilities and neurodivergent people. This highlights the co-morbidity issues flagged as important throughout the consultation responses, and the need for intersectional data and understanding.

A few respondents mentioned the additional needs of those who are visually impaired. They supported the use of ‘talking bus stops’ and ‘next stop’ announcements on buses.

Several respondents discussed the provision for wheelchairs on buses, and noted that although accessibility had been considered, more could be done in this respect. Respondents said that corridors should be wider and that there should be more adequate space for users of larger wheelchairs. Some also called for better wheelchair restraints on buses, while a few noted that it can still be difficult to access a bus when using a wheelchair.

The provision of toilets was raised by some respondents who suggested that there should be an increased availability of disabled toilets, that some are locked and keys must be obtained, and that some do not have ramps and are therefore inaccessible to wheelchair users. Others discussed the use of ‘standard’ toilets, and suggested that instructions should be made clearer and more accessible.

Travel Training

Some respondents suggested that offering ‘travel training’ to people with learning disabilities and neurodivergent people and their carers, friends/family, etc. might help to overcome some of the ‘simpler’ barriers to travel. In particular, it was felt this could provide people with the confidence to use public transport options:

“Travel training came up in a number of the interviews with parents. There were several examples of a young person receiving intensive travel training, typically provided by a third sector organisation. This had led to the young person having the confidence to negotiate public transport, typically the bus system, and contributed to some level of independence.” (Other Organisation)

Attitudes of the General Public

Abuse from other passengers on public transport services was highlighted by a number of respondents as a significant barrier to use. Respondents noted that fear of discrimination and abuse, and vulnerability to hate crimes resulted in a lack of confidence to travel on their own or on public transport.

As a result, it was felt that more education, awareness raising and training was required for the wider public to tackle stigma, discrimination and harassment (which was again an issue flagged elsewhere in the consultation responses).

Free or Subsidised Travel

Respondents highlighted that people with learning disabilities and neurodivergent people are less likely to hold driving licences or have access to private transport, and that they may also have an increased requirement to attend healthcare and other support based appointments. Therefore, it was argued that free or subsidised transport should be provided for all people with learning disabilities and neurodivergent people. This included extending current concessionary bus passes to include people with learning disabilities and neurodivergent people, providing similar concessionary travel options for train travel, and providing a card or travel pass system for taxis.

In relation to trains specifically, it was argued that these were more suited to some people’s needs, were more convenient for some, offered a faster mode of transport, and had destinations that were easier to recognise (i.e. train stations being more obvious than bus stops).

It was also suggested that carers and assisting family members should be offered discounted or free travel, which should be more available and easier to secure.

Review Application Systems for Concessionary Travel/Blue Badge

Both the concessionary bus pass and blue badge schemes were cited as being very beneficial to many. However, some respondents requested that the application systems for each of these be reviewed to be more inclusive of neurodivergent people, and to be awarded indefinitely for life-long, deteriorating conditions, to save pass/badge holders from having to go through the application process for renewals.

In relation to the blue badge scheme specifically, it was felt this focused too much on physical disabilities and needed to be more understanding and inclusive of other needs. Some also felt strongly that many of those who could benefit from this were unaware of if and how they could apply for it. It was suggested that significant improvements could be made in this area to increase awareness and accessibility.

Funding

Finally, as noted across many sections of the consultation, respondents highlighted the need for funding, both to deliver the proposals around strategies and training, and for any material changes/improvements. Some queried where the money and resources would come from to fund adaptations, training and strategic development in this area.