Submission on the proposed Wellington Regional Public Transport Plan 2011-2021
Greater Wellington released a proposed Public Transport Plan 2011-2021 for consultation. The RNZFB's comments asked for accessibility issues and outcomes to be incorporated across all relevant objectives and policies, and suggested that development of all public transport initiatives should include wide consultation with disabled people and the disability sector to better understand experiences and requirements.
Introduction
This is the Royal New Zealand Foundation of the Blind’s submission on Greater Wellington's proposed Wellington Regional Public Transport Plan 2011-2021.
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 more than 11,500 blind and partially sighted members nationwide, including many who are deafblind. More than 900 of our members live in the Wellington region.
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. In the New Zealand Disability Survey 2006, more than 71,000 New Zealanders self-identified as having a vision impairment that could not be corrected by glasses.
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 - they are 'transport disadvantaged' as defined in the proposed Plan. In practice, blind and partially sighted people face barriers in using buses, trains and other public transport modes in New Zealand. The Association of Blind Citizens of New Zealand publication "Is this the right bus?"[1] outlines some of the barriers associated with different modes of public transport, and the solutions needed.
Improving accessibility for people with vision loss will benefit the whole community. The Human Rights Commission's Accessible Journey[2] 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.[3]
Proposed Wellington Regional Public Transport Plan 2011-2021
The RNZFB welcomes the opportunity to provide input to this proposed Regional Public Transport Plan, and congratulates Greater Wellington on recent accessibility initiatives in the area including braille bus stop numbers and audio real time signage.
Detailed comments on the Plan follow. In summary, the RNZFB's comments are:
- The RNZFB would like to see a specific focus area related to improving the accessibility of public transport for disabled passengers.
- The RNZFB would like to see accessibility issues and outcomes incorporated across all relevant objectives and policies.
- The RNZFB suggests that development of all public transport initiatives should include wide consultation with disabled people and the disability sector to better understand experiences and requirements.
Comments
The RNZFB welcomes the Plan's acknowledgement of 'transport disadvantaged' people including those with disabilities. Blind and partially sighted people are 'transport disadvantaged' as they can not drive a private car.
1 Focus areas
The proposed Plan includes consideration of disabled public transport passengers, but this is not adequately reflected in the focus areas.
Though the Plan's key strategic issues include "managing access and mobility issues", and outcomes include "Improved public transport accessibility for all, including the transport disadvantaged", there is no corresponding focus area that will ensure accessibility for disabled passengers is achieved in practice.
Improved accessibility may be implied within some of the other focus areas, but is not an inevitable part of progress and needs specific focus. For example, "continuing to improve the rail network" could include improving the accessibility of train services, or could simply mean acquiring more trains and operating a more frequent timetable. The Plan's focus areas should include a specific focus related to improving the accessibility of public transport for disabled passengers.
2. Policy framework
The proposed Plan includes a specific Objective to "improve accessibility for communities and groups whose needs are not met by the regular public transport system". The outcomes of this objective include improving the accessibility of public transport systems.
Though it is important that the plan focuses on the needs of people who can not use the regular public transport system, it is important to note that most people with accessibility requirements, including many blind and partially sighted people, do use the 'regular' public transport system. Rather than separating access requirements into a single Objective, the Plan should integrate accessibility into the design of transport systems. This could be reflected by including access-related Methods under relevant Policies. For example:
Policy | Method to improve access for blind and partially sighted people |
2.2: Ensure that connections between services are optimised to minimise transfer times and maximise transfer reliability | Include a requirement that transport interchanges are well designed for disabled pedestrians, compliant with both New Zealand Standard 4121 and RTS 14: Guidelines for Facilities for Blind and Vision-Impaired Pedestrians. |
3.1 Develop and maintain public transport timetables that are easy to understand and can be reliably delivered and depended on for all services | Include explicit requirements that timetables are made available in formats that are accessible to blind and partially sighted people. This may include accessible websites, text message services, large print, braille and audio. |
3.2 Ensure the provision of reliable information on the arrival and departure times of public transport services | Include explicit requirements for real-time information systems to be accessible. Wellington's recent development of accessible real-time bus signage is a great example of this. Further work could include audio announcements at stops indicating which bus is arriving. |
3.3 Ensure that public transport services deliver a high quality customer service experience | Ensure that requirements for ongoing customer service training includes disability awareness training, and specifically the needs of blind and partially sighted passengers, who have unique requirements. |
5.3 Advocate for improved personal safety and public transport road safety | Include the development of a policy on accessible environmental design for blind and partially sighted passengers. For example, Auckland Regional Council developed a 'Rail Station Upgrade Policy and Specification' with the input of the RNZFB that guides all rail station design in Auckland. |
6.1 Ensure the provision of public transport infrastructure suitable to its role and function within the layered service approach | As one of the measures of quality, include a requirement that stations and stops are designed to be accessible for disabled pedestrians, compliant with both New Zealand Standard 4121 and RTS 14: Guidelines for Facilities for Blind and Vision-Impaired Pedestrians. |
9.2 Provide relevant, accurate, easy to use information about the public transport network that customers can rely on. | Include a requirement that information is made available in formats that are accessible to blind and partially sighted people. This may include accessible websites, text message services, large print, braille and audio. |
Additional comments
Disabled people have lived experience of barriers to independent travel and should be involved in indentifying issues and developing effective solutions.
Within public transport planning, provision should be made for consulting with disabled people to better understand potential barriers and effective solutions. This should include nurturing links between disability advisory groups and operational staff within Greater Wellington, but should also include ensuring that any engagement with the community actively includes disabled communities.
Specifically, processes for consultation should include provision for communicating with blind and partially sighted people, to ensure that their informed perspectives can be heard. For example, consultation materials should be made available in accessible formats that blind and partially sighted people can read. This may include accessible websites or email, braille, audio and large print. The RNZFB would be pleased to advise greater Wellington on communications strategy for reaching blind and partially sighted people.
Further information
The Foundation 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
[1] Association of Blind Citizens of New Zealand Inc, Is This The Right Bus?: Public Transport - Trials and Tribulations of the Blind Traveller. Available online at http://www.abcnz.org.nz/download.php?filename=documents/Publications/Is%20this%20the%20Right%20Bus-Issue%202%20Accessible%20Public%20Transport.ABCNZ%20July09.doc
[2] Human Rights Commission, September 2005, The Accessible Journey: Report of the Inquiry into Accessible Public Land Transport. Available online at http://www.hrc.co.nz/report2/chapters/foreword.html
[3] For example Article 20, which requires States Parties to "[facilitate] the personal mobility of persons with disabilities in the manner and at the time of their choice, and at affordable cost".

