Submission to the Ministry of Transport. April 2005.

This submission

The Foundation's submission has been informed by individual members of the Foundation who use Total Mobility (TM), by Foundation Community Committees, and by staff members who assist members to learn about and access the scheme in various parts of the country.

Importance of Total Mobility

Individual blind, deafblind, and vision-impaired people rely heavily on the Total Mobility scheme and are grateful for it. But they are frustrated when its various limitations hamper their ability to travel independently. This submission from the Foundation is made on behalf of a membership that values Total Mobility (where it is available) and believes that more eligible persons could benefit if the scheme were indeed expanded to improve its national adequacy, consistency, portability, sustainability, and coverage.

The Foundation has appreciated the dedication of the Ministry of Transport and Land Transport New Zealand staff charged with this phase of the Total Mobility review and applauds the efforts of the team to ensure that the consultation has been wide, thorough, and inclusive.

Scheme purpose

The Foundation believes there is value in reminding the community that Total Mobility exists so that people for whom a public transport journey would be inaccessible under certain circumstances can be active participants in society. The emphasis on "door-to-door transport" helpfully distinguishes TM from other transport services that are not whole journey solutions. Using the term "transport" (i.e. rather than "taxi") means that TM is defined by the mobility it gives an individual rather than by the type of vehicle involved. The Foundation's membership values TM as a transport solution that meets real needs at a practical level.

Language that is consistent with the New Zealand Disability Strategy and the New Zealand Transport Strategy is wholly appropriate in the purpose statement.

Local and central government partnership

The Foundation understands and accepts that TM will remain a partnership between local and central government, and that this review is directed primarily to those areas of the country in which TM currently operates. However, the right of people with impairments to participate in the community is no less important in rural areas and towns that are not at present covered by TM.

The Foundation is therefore hopeful that the Human Rights Commission inquiry into accessible land transport and further work by agencies responsible for public land transport at the national and regional levels will address the barriers to social participation still encountered by disabled people. See the New Zealand Disability Strategy actions 8.5, 8.6, and 8.7 and the New Zealand Action Plan for Human Rights, Priorities for Action 2005-2010.

Land Transport New Zealand should, in consultation with local authorities, develop a plan to extend the service throughout New Zealand. Foundation members living in Kaitaia, for example, cannot use TM on visits to Auckland because it is not provided by the Northland Regional Council to Kaitaia residents.

Eligibility criteria

The Foundation stresses that membership of the Royal New Zealand Foundation of the Blind must, on the basis of the criteria for that membership, entitle a person to use TM anywhere in New Zealand. Foundation membership is available to "a person who in the opinion of a registered ophthalmologist or optometrist has visual acuity not exceeding 6/24 in the better eye with corrective lenses, or serious limitations in the field of vision generally not greater than 20 degrees in the widest diameter." In practical terms, some or all public transport journeys will be impossible for a Foundation member to undertake independently.

Whole journey approach

The Foundation strongly supports the whole journey criteria. Even if individuals use public transport sometimes, it remains true that blind, deafblind, and vision-impaired people can face severe difficulties making a particular journey. Problems include inaccessible timetable and route information, the inability to see route information displayed on buses and trains, dangerous routes to and from buses and trains, and the practical difficulty of shifting from one bus or train or ferry to another mode of transport. Individuals may be disoriented and at risk when they try to use public transport in an unfamiliar environment, or when particular weather or lighting or falling darkness affects their limited sight. Rain can mean that a person with low vision experiences difficulty as though it were night. Glare can mean that a person who has little vision problem indoors becomes almost blind in bright sunlight.

Blind, deafblind and vision-impaired people cannot be bound to making only the familiar bus trip or travelling at only particular times of the day. For Foundation members, as long as they can afford their share of the cost of the fare, TM ensures some degree of freedom in choosing when and where to travel.

When they cannot use public transport for whatever reason (because of a sudden change in their vision or circumstances, or because that journey would always be impossible for that person), the blind, deafblind and vision-impaired traveller never has the choice of independently driving a private car. 

Eligibility for people who live even where TM does not operate, for children, people in residential care settings, and people with short-term impairment.

Social participation

Social participation is a right of every citizen, including all these groups. Blind, deafblind, and vision-impaired people should have the right to mobility wherever they are (see the New Zealand Disability Strategy objective 8). Just as a citizen can use utilities and amenities when visiting another city, so should anyone eligible and registered for TM be able to use the system whenever they are in an area in which it operates. Where it operates, TM represents an essential service.

The need to make journeys

Most people in a rural area need to go to an urban area for hospital and specialist services, and are already taxed with the task of getting transport to and from the town or city. It would greatly help them if they could use the available TM service whilst in the town. They would be able to get to appointments independently and complete any other business during the one visit.

Foundation members should be able to use TM when they visit urban centres. This would be a significant step forward for people who must visit cities for visits to specialists and hospitals, education, job interviews, and many other reasons. The cost of getting round a city can be substantially dearer than the cost of getting to it.

Financial modelling

The Foundation welcomes the Ministry's statement that it will undertake financial modelling for the possible improvements. The Foundation believes that modelling increased costs will prove that TM eligibility can be more consistently applied without the increase in local and central government spending on TM proving unsustainable. Also, system efficiencies can lower administration costs.

As individual needs vary so greatly, the Foundation believes it essential for TM to continue to allow eligible persons to travel with a support person if desired.

Standardised fare subsidy

Certainly the TM fare subsidy must be standardised in order to deliver national consistency. The Foundation does not believe that this or any other possible improvement should have the effect of spreading the existing TM spend more thinly, thereby substantially reducing the fare subsidy for some areas. We believe that financial modelling will show that the additional expenditure required to achieve a nationally consistent fare subsidy is affordable, if there are also system efficiencies.

Feedback from individual Foundation members has favoured a fare subsidy of 50%.

Geographic realities

The Foundation recognises that the TM scheme must take account of geographic realities. A major urban centre is very different from a small city in terms of the distances people need to travel to get to various facilities and venues. In Auckland, say, a taxi fare of $40 or $50 is not uncommon, whereas in a small town any community facility could be reached for $10 or $12. Moreover, not every TM region has a maximum subsidised fare. Developing a formula to set maximised subsidised fares should not deliver a substantially less adequate TM service for users in areas which do not at present have a maximum subsidised fare.

A maximum subsidised fare based on dollar values has the disadvantage that over time inflation erodes the distance that can be travelled for the maximum amount.

Distance-based approach to setting the maxium fare

The Foundation recommends a distance based approach be used for setting the maximum subsidised fare. Naturally the distance must be measured as the route a vehicle would actually take rather than as a crow would fly. The literature review being undertaken by the Ministry might suggest a means of modifying a distance based formula to account for people's need to get to key places such as shopping centres, airports, major sporting venues, educational facilities, and hospitals. For example, in Dunedin the airport is a considerable distance from the city, and in Napier/Hastings the only hospital is at Hastings. Perhaps maximum distances could be measured from a variety of key places within a region. So from Tauranga, for example, a traveller could use the TM subsidy to reach Katikati or Te Puke but not further afield.

In some regions, it may be possible to set the maximum journey at half the distance taken to travel from one end of the region to the other. That will not work everywhere. Whichever method is used to set the maximum in particular places, it is important that the process be transparent. Funding agencies (central government and regional and/or district councils) and a representative user group should jointly discuss and set the maximum for a region. It is essential that the maximum for each part of the country be openly communicated as part of the effort to publicise TM to all current and potential users. National consistency means that a TM user visiting another part of New Zealand must easily be able to know in advance how far may be travelled for the maximum subsidised fare in that place.

Remove minimum fares

Need is need. The Foundation strongly urges the review to recommend an end to minimum subsidised fares and any local surcharges on particular types of journey or vehicle on the grounds that they are inequitable.

Number of trips

There should be a nationally consistent method for deciding every user's entitlement to use TM. But using the language of "vouchers" locks in a less than ideal system for administering the scheme.

Some people rely on taxi travel to participate in work or education and should have the right to use the local TM scheme.

Not every region sets a limit on the number of TM journeys available to an individual. The Foundation believes that modest increases in TM funding by local and central government, more efficient and cheaper administration systems, retaining the user's contribution at 50% of the subsidised fare, and setting a maximum subsidised fare will together enable the removal of allocation limits. Financial modelling should reveal that.

Allocation limits should be abolished because they constrain TM artificially. If a local community through its regional authority undertakes to operate TM, the TM scheme should not be compromised.

Restrictions based on trip purpose are discriminatory. In accordance with the New Zealand Disability Strategy, disabled people have the right to live in and move round their chosen community and to participate in the economy, employment, and leisure activities. TM users use TM because they do not reliably have available other transport options that would cost them less. That reality should underpin the provision of the scheme.

Assessment

No financial or administrative barriers should discourage eligible persons from accessing TM. In the case of Foundation members, people will already have met the costs of visiting an optometrist or ophthalmologist for an eye diagnosis, and in many cases there will have been several visits to a doctor, specialist, low vision service, or hospital beforehand. An individual will have paid $150 or more. Qualifying to join the Foundation on the basis of its medical criteria for membership must be sufficient grounds for being able to use TM.

In some cases (e.g. for Foundation members) an assessment should not be required, and a confirmation of eligibility should suffice. Costs can be reduced by not requiring unnecessary assessments.

Note that not all Foundation members who live in TM areas are registered to use the scheme. The majority who are not registered for TM might not have heard of the scheme or might not need to travel independently by taxi or might not be able to afford their 50% of the subsidised fares. It does not follow that automatic registration of Foundation members for TM will lead to significantly increased use of the scheme.

Administration

National consistency is key. The administration scheme must be efficient and cost effective, and not place an undue administrative (and cost) burden upon agencies that undertake assessments. Currently it is far from easy for eligible individuals to obtain a clear picture of their entitlements under TM.

All participating authorities need to advertise information about their own schemes and those elsewhere in the country so that an eligible person can easily and knowledgeably use TM in other parts of New Zealand. This will mean uniformly including details in all council publications and web sites, explaining availability of the scheme in other areas, and providing customer service support to existing and potential users.

The Foundation believes that consideration should be given to developing a charter to be signed by participating councils and transport operators. Signatories would accept the responsibility to disseminate detailed and current information about TM, including complaints procedures. Complaints procedures need to be well advertised, easy for users (e.g. accessible to blind, deafblind and vision-impaired people), and adequately monitored. National guidelines around the receiving and handling of feedback (complaints, compliments, and suggestions) would strengthen community support for and appreciation of TM. A charter culture might helpfully provide a structure within which transport operators and TM user groups could share perspectives and explore the potential for service enhancements.

Accessible information

The Ministry can show leadership by funding or itself producing an overview of the scheme and by funding accessible formats for the use of people who cannot read standard print.

The Foundation will certainly advise on accessible information needs and costs. It is certain that TM information made accessible in, for example, audio form could meet the needs of individuals other than members of the Royal New Zealand Foundation of the Blind. These would include people with print disability, literacy difficulties, or English as a second language.

It would be very beneficial to users of TM if they could ring up the local authority responsible for TM and obtain a list of trips and amounts to present to Work and Income for disability allowance purposes. This would certainly assist those users who cannot read receipts and find it difficult to keep track of them.

The Foundation compliments the Auckland Regional Council and the Wellington Regional Council on making TM information easily available to users.

Transport operators

A problem encountered by many users is that within a fleet where swipe cards are in use, not all cars are fitted for TM. Often individual drivers refuse to handle TM or are not well trained to do so, and this can be troublesome to users or even traumatic for them.

The Foundation believes that a TM transport operator should be required to make 100% of its fleet TM compliant. All its drivers should be trained to handle TM and to meet the needs of disabled passengers.

Certainly, blind, deafblind, and vision-impaired travellers - while appreciative of TM where it is available - receive variable levels of service from taxi drivers.

Common problems

• Drivers have poor route knowledge. Passengers who are unable to see the environment cannot easily direct a driver who is unaware of route that should be taken and are likely to be charged more than the journey should have cost.
• Many drivers lack skills in guiding a blind or vision-impaired person. Drivers often do not know how to provide physical assistance in a safe and appropriate way.
• Many drivers for whom English is a second language have difficulty communicating verbally with passengers. This is especially stressful for people who cannot focus on the driver's face and gestures.
• Many drivers have difficulty in communicating effectively with people who cannot see where they are pointing or who cannot visualise directional information.
• When vouchers have to be filled in, blind, deafblind and vision-impaired passengers have no certainty that the details (including the fare amount) written on the voucher are accurate.
• Travellers can find it difficult to keep track of receipts.

The following comment from one Foundation member echoes the sentiments of many: "It's time for TM to move into the 21st century! ... A card that could be used in a seamless national scheme would avoid the numerous complaints I get from taxi drivers who have trouble reading the taxi vouchers and filling them in because of the coloured paper they are printed on. It would avoid the blind passenger having to sign the voucher for every trip."

Swipe card systems

• Cheaper to operate.
• Reduces the risk of fraud (including meter over-runs).
• Provides users and operators and funding agencies with certainty about the amount charged for a journey.
• Saves the users the difficulty of filling in bits of paper (if they can).
• Provides users with a convenient ID card (especially as TM users will often not hold a valid driver's licence).
• Encourages taxis to install swipe card readers useful for a whole range of commercial transactions.

In small towns, where taxi operators may not even have a PC, a swipe card system may genuinely prove a challenge for the local community of operators and users. However, the Foundation recommends at least considering the technology that makes TM convenient, safe and affordable to operate.

A subsidy for transport operators might be appropriate, although it is true that the cost of introducing service enhancements is one that innovative business will undertake when the benefits and potential are clear.

These systems could be successfully introduced only after consultation with users and amid a high level of confidence that people on limited incomes and passengers unable to see would not regard such an intelligent card as unaffordable or insecure.

Driver training

"Sighted guide" training is essential, and should be part of a TM transport operator's contractual or charter obligation. A degree of vision loss is a common experience within an ageing population. The training that would assist drivers to deliver a safe, efficient service to Foundation members would help them in their dealings with a variety of passengers.