MACS standard consultation response

The Mobility and Access Committee for Scotland (MACS) often receives requests to comment on proposed transport strategies, plans and policies, for example from councils, Regional Transport Partnerships (RTPs) and other public, private and third sector bodies. We always try to engage with major and national initiatives but as a non-departmental advisory public body with limited resources, we can’t usually respond to such requests at a local or regional level. We instead encourage organisations to involve local Disabled People’s Organisations (DPOs) and/or their local Access Panels. We hope however that this short guidance note will be a useful input for any organisations preparing transport strategies and plans.

The starting point for any new or revised policy is to understand the obligations under the Equality Act (2010), including the Public Sector Equality Duty. As disabled people are one of the ‘protected characteristics’ under the Act, you must consider the impact of the policy on disabled people (and others, for example; by age, sex, race, etcetera). If you are a public body, you will probably need to carry out an Equality Impact Assessment (EqIA). This can be combined with other assessments (for example, a Fairer Scotland Duty Assessment, Island Community Impact Assessments, Environmental Impacts Assessment, etcetera).

Whether or not you have a legal duty to carry out an EqIA, it is important to think about the impacts that the policy might have on disabled people in advance. It is essential to consult and involve disabled people and DPOs at this stage to uncover impacts presented specifically through lived experience. Their lived experience will help you identify and understand those impacts: talking to and engaging with disabled people (experts by experience) is probably the most important single thing that you need to do! This is not something that you should do as a one-off, but an iterative process. Engagement should continue throughout the development and each time a project is reviewed.

When consulting and engaging with disabled people, it is important to recognise that as individuals they may face a number of challenges and barriers from the built environment and from how services are designed and delivered. Even people with the same apparent disability - like sight loss or people who use a wheelchair - don’t all have the same needs either! Remember too that many disabilities are not visible or obvious - hidden disabilities. Learning disabilities, learning difficulties, chronic pain, mental health conditions, dementia, autism, breathing / heart conditions and neurodiversity are some common conditions that can be invisible.

It is important to ensure that you use inclusive communication methods - this means that you think about how easily people can understand your message and can give their feedback. Information should be in formats, that are accessible - some people prefer print, easy-read using infographics, some others prefer digital information. Often the most powerful way to communicate is person to person!

When thinking about the impacts of the policy, we would encourage you to take as broad a view as possible, and seek to understand the impacts from the disabled person’s point of view - a ‘person-centred’ approach. Most trips need to be ‘joined up’ - a walk to the bus stop, a taxi from the train station, etcetera. People often face barriers and challenges when moving from one travel mode or stage to the other. So for example, it will be more difficult for rail staff to assist a disabled passenger to get to the taxi rank if a taxi rank is moved further away from the train station.

Think about how the policy or service will operate in practice. The role of people is often just as important or more important than the design of physical structures and processes. Staff, well trained in customer care and disability awareness are essential to make many journeys accessible (see for example these Department of Transport resources). Disabled people may be travelling with carers; it is important to include carers needs and communicate with everyone involved in the ‘joined up’ journey. Above all, services must be designed around the people who use them and not the organisation’s needs.

For physical designs, some common issues or problems can include:

step-free access is needed for many people: but people who can’t see, need a way to orient themselves and tell them where they are safe (for example a kerb, or tactile paving);
remember that many disabled people are much more reliant on private cars for their mobility, as passenger or driver. So provision for access, drop-offs and parking must be considered carefully.
somewhere to sit is important for people who need to stop and rest frequently;
ramp lengths and gradients need to be realistic for self-propelling according to recognised standards;
toilets are also vital in many places – Changing Places toilets are the most accessible.

Consider what problems may arise - again from a person-centred perspective. How will the policy be carried out in practice? How will it impact on people? How will it be enforced? How can complaints or problems be dealt with as effectively and quickly as possible?

Think about how you will assess the success of the policy with regard to access and inclusion. How will this be measured? When should it be reviewed and what information would help you do this?

Finally, an important way of thinking is to embrace the ‘social model of disability’. This recognises that the access problems disabled people face aren’t caused by the impairments which they may have, but the failure to design places, processes, services and systems to take account of disabled people’s needs (building in barriers). By adopting an inclusive design approach, the outcome will not only be better for disabled people, but for everyone else too. Remember – disabled people most often have the solutions!

Appendix: About the Mobility and Access Committee for Scotland

The Mobility and Access Committee for Scotland (MACS) is a statutory advisory non-departmental public body. Within the founding legislation, Scottish Ministers have defined the overall aim for MACS as follows:

“MACS will consider such matters relating to the needs of disabled persons in connection with transport as the Committee think appropriate and give advice to Scottish Ministers”.

MACS Strategic Remit is:

To give Scottish Ministers advice on aspects of policy, legislation and

practice affecting the travel needs of disabled people.

To take account of the broad views and lived experiences of disabled people when giving advice.
To encourage awareness amongst disabled people in Scotland of developments, which affects their mobility, choices and opportunities.
To work closely with the Scottish Government (SG) and ensure our work programme complements.
The work being undertaken by the Inclusive Mobility and Transport Committee (IMTAC), the Disabled Persons Transport Advisory Committee (DPTAC), the Scottish Human Rights Commission (SHRC), the Equality and Human Rights Commission (EHRC) and other organisations, voluntary and statutory.
To promote the travel needs of disabled people with designers including transport planners and operators so that these are fully taken into account in the development of vehicles and infrastructure and delivery of services.
To monitor and evaluate the effectiveness of our work against the above aims and objectives in improving travel opportunities for disabled people in Scotland.