Submission on Hawke's Bay draft Regional Council Regional Public Transportation Plan 2011-2014

Hawke's Bay Regional Council asked for public comment on a Draft Hawke's Bay Regional Land Transport Strategy. The RNZFB's submission commented on the need for accessible public transport systems, accessible technology and transport staff training in disability awareness.

Introduction

This is the Royal New Zealand Foundation of the Blind’s submission on the Hawke's Bay Regional Council's draft Regional Public Transport Plan 2011-2014.

Royal New Zealand Foundation of the Blind

The Royal New Zealand Foundation of the Blind (the RNZFB) is New Zealand’s main provider of sight loss services to blind and partially sighted people. The RNZFB's vision is empowering and supporting blind and partially sighted New Zealanders to ensure that they have the same opportunities and choices as everyone else.

The RNZFB advises government, business and the community on inclusive standards to ensure that blind and partially sighted people can participate and contribute equitably. The RNZFB also provides its members with the adaptive skills they need to lead independent lives. One of the core services provided is training in orientation and mobility skills so that members can travel independently.

The RNZFB has around 570 blind and partially sighted members living in the Hawke's Bay region, and more than 11,500 members nationwide, including many who are deafblind. The recommendations made in this submission will also benefit members of the community who have vision loss but do not meet the Foundation's eligibility criteria. Recent research[1] indicates that in 2009, 125,000 New Zealanders over the age of 40 had sight loss which prevented them from being eligible for a driver's license.

Accessible public transport

Providing reliable, accessible public transport options is vital for blind and partially sighted people, who often rely on public transport to get around as they can not drive. In terms of the discussion document, they are 'transport disadvantaged'.

In practice, blind and partially sighted people face barriers in using buses in New Zealand. The Association of Blind Citizens of New Zealand publication "Is this the right bus?"[2] outlines some of these barriers and the solutions needed.

Improving accessibility for people with vision loss will benefit the whole community. The Human Rights Commission's Accessible Journey[3] inquiry found that:

"all the changes that make public land transport more accessible for disabled people also improve access for non-disabled people, and therefore contribute directly to increased use of public transport."

The legal mandate for improving accessibility was strengthened by New Zealand's recent ratification of the UN Convention for the Rights of Persons with Disabilities.[4]

Comments on discussion document

12. Which groups of people do you consider to be transport disadvantaged, where are they located and what are their key access needs?

Blind and partially sighted people are 'transport disadvantaged', as they are unable to drive a car. Apart from walking, public transport may be the only option available. The RNZFB's members are located across the Hawke's Bay region, including in Hastings, Napier, Wairoa and the rural areas surrounding them.

Many blind and partially sighted people can and do use public bus services, but they often face barriers in accessing these services on an equitable basis with other residents.Specific accessibility requirements for blind and partially sighted travellers include:

• audible information about stops.
• timetable information in accessible formats.
• stations/stops designed to be accessible to blind and partially sighted pedestrians, compliant with both New Zealand Standard 4121 and RTS 14: Guidelines for Facilities for Blind and Vision-Impaired Pedestrians.
• clear audible and visual ways of identifying vehicles.
• staff awareness of how to accommodate blind, partially sighted and deafblind people, reinforced through mandatory training.
• affordable fares.
• adequate and equitable access to the Total Mobility scheme.

The Association of Blind Citizens publication Is This The Right Bus? details these requirements more specifically.

13. What provisions should be made to address their transport needs?

The following comments relate specifically to the draft Regional Public Transport Plan.

Standard, accessible design of buses. We note the comment on page 7 of the draft Plan that in 2009 all buses (with the exception of the Commuter Express services) were required to be wheelchair accessible. The RNZFB supports the move to implement the NZ Transport Agency guideline on the Requirements for urban buses in New Zealand to ensure basic accessibility considerations are addressed for all Hawke's Bay Regional Council buses. Standard design of features makes bus travel more predictable for blind and partially sighted passengers, increasing their confidence and encouraging patronage.

Design for blind and partially sighted passengers. Those who are blind, partially sighted or deafblind may benefit from wheelchair access to buses, but people with sight loss have unique requirements to facilitate their safe and independent use of public transport. These include adequate light levels (at stops and onboard), audible onboard announcements, clear internal and external signage, accessible bus stop identification, accessible bus stop design, accessible priority seating, contrasting furnishings and accessible ticketing systems.

As noted on page 8, the recent inclusion of braille bus stop signage will make buses more identifiable to blind and partially sighted passengers. The RNZFB has published accessible signage guidelines which outline best practice design advice for signage that everybody can read and understand, whether they read using sight or touch[5].

Accessible bus stop design. The RNZFB suggests that inclusive design principles should be adopted. We recommend following ARTA’s (now Auckland Transport) Bus Stop Infrastructure Guidelines (until NZTA has developed national guidelines) and liaising with the RNZFB to ensure the design meets the requirements of our members with appropriate visual, tactile and auditory clues and information. This would assist the Regional Council to meet the requirements within this draft plan of:

3.1 Buses (page 11) ensuring “better provision of information and facilities for those who are sight impaired, including providing blind markings at key bus-stops.”

Point 7 in the Customer policy table on page 16,

Point 6 under Information availability in the table on page 18,

Point 4 under the experience bus stops, timetables information on page 20.

Accessible technology. Looking Forward, on page 21, proposes investigating new technology to provide a better service the ability to load funds via the internet onto smart cards. The RNZFB submits that where new technology is used, it should be designed to be accessible to blind and partially sighted people. Websites, software and other technology can be designed to be accessible to blind and partially sighted people. Often, accessibility does not cost any more than less accessible solutions, but requires a consideration of access needs through the design process, reference to appropriate standards and consultation with blind and partially sighted users. Access to timetables, real time scheduling and bus stop locations through technology can be of huge benefit to blind and partially sighted passengers, who may have no other way of accessing this information independently.

Staff training in disability awareness. Bus drivers are a key part of ensuring that blind and partially sighted passengers can travel with independence and dignity. The RNZFB submits that bus drivers should have consistent, professional training in how to provide service to customers with an impairment. This training should be developed and conducted in conjunction with disability professionals, and should specifically include the needs of blind and partially sighted passengers.

15. Does your organisation believe there should be a discounted fare for people with an impairment or disability?

Yes, consistent with discounts provided across the rest of the country for people who are transport disadvantaged. For those who are unable to drive, having equitable and affordable access to public transport is an important part of ensuring that they can live independently.

16. What impairments/disabilities should qualify the passenger for a discounted fare and how would this be monitored?

People who are blind and partially sighted are transport disadvantaged because of their impairment, and should be eligible for a discount to ensure that they are able to participate in the community on an equitable basis.

The RNZFB's membership card would be a good method of proving the identity of a member for the purposes of establishing eligibility for a discount. Not all RNZFB members are eligible for a Community Services Card.

17. What is your organisation's definition of impairment or disability?

The RNZFB follows the definitions of disability and impairment provided in the New Zealand Disability Strategy - that is, the social model of disability:

Disability is not something individuals have. What individuals have are impairments. They may be physical, sensory, neurological, psychiatric, intellectual or other impairments.

Disability is the process which happens when one group of people create barriers by designing a world only for their way of living, taking no account of the impairments other people have. ...

Disability relates to the interaction between the person with the impairment and the environment. [6]

The RNZFB's membership criteria are based on medical measurement of impairment by an optometrist or ophthalmologist. The criteria are

• Adults: In the opinion of a registered ophthalmologist or optometrist the person's visual acuity does not exceed 6/24 in the better eye with corrective lenses, or there are serious limitations in the field of vision generally not greater than 20 degrees in the widest diameter.
• Children and young adults: Children and young adults must also have a referral from an ophthalmologist or optometrist. All children and young adults (21 years of age and under) who are currently registered with Visual Resource Centres regardless of their degree of vision loss may apply to become a RNZFB member.

Further information

The RNZFB would welcome opportunities to provide more information if required. Please direct any questions to:

Moira Clunie
Insights, Policy & Advocacy Manager
Telephone: +64 9 355 6938
Email: mclunie@rnzfb.org.nz

Royal New Zealand Foundation of the Blind
Private Bag 99941
Newmarket
Auckland