European Year of People with Disabilities

EDF response to the  European Commission White Paper  European Transport Policy for 2010

"States should recognise the rights of organisations of persons with disabilities to represent persons with disabilities at national, regional and local levels. States should also recognise the advisory role of organisations of persons with disabilities in decision-making on disability matters."

Rule 18 of the United Nations Standard Rules on the Equalisation of  Opportunities for Persons with Disabilities




Doc EDF 01/11 – EDF response to the European Commission White Paper "European Transport Policy for 2010"


The document is available in English, and on diskette or in large-print upon demand from the EDF Secretariat, and when adopted will be published on the EDF Website at: http://www.edf-feph.org/ 

© Copyright European Disability Forum and Authors 2001. This document may be quoted and reproduced, provided the source is given

TABLE OF CONTENT

TABLE OF CONTENT 3

1 Introduction

Given that the White Paper on a Common Transport Policy presents the work programme of the European Commission in the field of transport for the next 10 years,  EDF is most disappointed at the limitedrecognition disabled people and people with reduced mobility are given in the White Paper.
In July 1999 EDF submitted to the European Commission its position paper on 'Access and mobility' in response to the call for comments of the CTP for the years 1998-2004.  However, the European Commission White Paper does not reflect the needs or concerns of disabled people or persons with reduced mobility presented by this EDF paper (1999 ).
The White Paper has given no recognition to the proposals and commitments presented in the recent European Commission communication on 'Towards a Barrier Free Europe for People with Disabilities ' and the subsequent European Parliament Resolution   which present a number of European initiatives and proposals for progressing access to transport for persons with disabilities and reduced mobility.   
2003 marks the European Year of persons with Disabilities during which time EDF would like to see the presentation by the European Commission of a specific EU Directive implementing the principle of equal treatment for persons with disabilities to cover all areas of EU competence including transport and access to goods and services.   In light of this, EDF would like to see concrete actions in the Common Transport Policy to breakdown access barriers faced by disabled persons who cannot use the transport system in Europe with any confidence at this time. 
EDF welcomes the fact that DG TREN are at present undertaking a number of initiatives to progress access for disabled people and persons with reduced mobility in the field of urban transport, air passenger rights, rail transport, maritime transport and bus and coach transport.  However, these initiatives and follow-up measures stemming from them are not referred to at all in the White Paper.
Disabled people make up 10% of the population in the European Union.   
Persons with reduced mobility include older people, parents with children and persons with heavy luggage can make up to 40% of the population.
An ageing population is increasing the need for transport policy to give much higher priority to the needs and interests of persons with reduced mobility and this should be reflected to a much higher degree in the White Paper.
The White Paper should recognise that the transport system is there to benefit society as a whole and therefore must be accessible to society as a whole.  It is totally unacceptable that a service which is in the general interest excludes certain groups in society be they disabled people, elderly people and other persons with reduced mobility, or other socially excluded persons.

2 Principal measures proposed in the White Paper

2.1 The rights and obligations of users

The White Paper includes a section devoted to 'recognising the rights and obligations of users' with a focus upon the issue of access to high-quality services and affordable prices.   
EDF is disappointed that there is no explicit mention of the access needs of persons with reduced mobility in this section given the importance of this problem for all transport users not just for disabled people.    
The White Paper refers to the air passenger rights charter as an example to be followed for other modes of transport.  The interests of persons with reduced mobility has been considered an important element in the work on air passenger rights, therefore, this should also be recognised by the White Paper.
While the development of voluntary commitments on passenger rights provides a means to build relations and communication between consumer groups and the transport industry there are specific issues faced by disabled people and persons with reduced mobility which can only be adequately addressed through legislation.  

Key issues for disabled transport users:

• Access to built environment / infrastructure and transport modes

• Access to information services  (particularly important for persons with sensory disabilities and learning disabilities)

• Service provision: disability awareness training of transportation staff (training on the needs of disabled people)

• Safety and security (including emergency evacuation procedures)

• Transparency of concessionary fares systems and assistance to disabled persons

• 

2.2 Developing high quality urban transport

The focus of the White Paper in the context of urban transport is on sustainable development.   Essential to sustainable development is the need to ensure that all members of society, including disabled persons/persons with reduced mobility and socially excluded persons, have full and equal access to an integrated urban transport system.  These problems were given attention in the Public Hearing on Urban Transport Living in Cities: the Transport Dimension" of 25-26 May 2000.  
However, the points made on access and social exclusion presented  at this event and in the report on the Hearing are not recognised in the White Paper.
EDF welcomes the fact that some reference has been given to persons with reduced mobility regarding the promotion of good practice in urban transport and fully supports the initiative of the urban transport division of the European Commission for a study to examine the accessibility of urban transport for persons with reduced mobility across the EU.  
However, while it is understood that responsibility for urban transport lies mainly with Member States and municipalities the White Paper should recognise the positive influence  the EU can have in breaking down barriers for disabled people in urban transport.  Notably, by including requirements on access for disabled people / persons with reduced mobility in the criteria it uses to allocate Community funding, in particular the Structural Funds including the European Regional Development Fund,  also in the research initiatives and by inserting requirements on access provisions for disabled people / persons with reduced mobility in criteria on EU legislation on public procurement and specific transport 
regulations.

2.3 Developing high quality rural transport

It must not be forgotten that rural areas are home for a quarter of the population and account for more than 80% of the territory of the EU.  Disabled persons and older persons living in peripheral areas are particularly isolated and neglected.    
For example, many rural stations are left unmanned which is a major problem for disabled persons reliant on assistance from station staff.   Public transport services are deteriorating in rural areas, therefore, disabled persons are reliant largely upon private motor transport, not always easily available to disabled persons, or taxi services which are more expensive. Therefore, access to rural transport systems must be given more attention in the work programme of the European Commission. 

 
2.4 Improving the road transport sector and Road Safety

EDF supports the attention the White Paper devotes to road safety which would help to prevent incidents of disability.
Attention must also be given to improving safety for disabled pedestrians who are particularly vulnerable to hazards on the road.  EDF calls on the European Commission to encourage discussion between Member States on how to improve design of the built environment which would improve safety for all as well as for disabled persons.  For example the installation of audible and tactile signals at pedestrian crossings,  removing high curbs, improving signage, improving the condition of pavement and road surfaces, stricter enforcement of traffic offences such as illegal parking which block pathways or disabled persons parking spaces.

2.5 Addressing access provision across all modes of Transport

2.5.1 Access to Road Transport

Access to road transportation notably buses and coaches, light rapid transport systems (trams and metro), taxis and the private car.  EDF urges the European Commission to continue to give attention to this issue in the legislative initiatives relating to respective transport modes.

2.5.2 Buses and Coaches

The EU "Bus and Coaches" Directive   has introduced important mandatory access provisions for persons with reduced mobility to urban buses.   However, EDF would like to see such terms extended to interurban buses and coaches.The COST 349 study on access to coaches and long distance buses in preparation will provide important proposals which must be considered by the European Commission in work it should do in this area.  With advances in research and development technical solutions are being found to address access requirements which must be recognised and promoted by the European Commission.

2.5.3 Private motorist

A number of important issues must be addressed in relation to the needs of private motorist with a disability.  The Council Recommendation on the parking card for people with disabilities  is an important initiative to facilitate travel for disabled motorists.  However, there is still confusion among disabled travellers regarding the differences in concessions for disabled motorists which operate across the Member States which create problems and should be addressed.
Other issues relate to: inadequate enforcement of parking restrictions, need for adequate financial support for disabled people to own and use a car given the cost of adaptations to vehicles and problems regarding the insufficient number of centres which provide services for adapted vehicles across the EU; the issue of driving licences, ensuring training and testing procedures are not discriminatory.  
Use of congestion charging will also have an important impact on disabled persons who are mostly low income and, currently, without easy access to public transport so reliant on the private motor car.  The application of such a system should include certain exemptions for disabled motorists and require a proportion of the revenue accrued from congestion charging to be used to improving access to public transport systems.

2.5.4 Taxis, metro and tram essential to an integrated transport system

Taxis, metro and tram are particularly important in an urban transport context and are central to an integrated transport.  EDF would like to see the European Commission develop initiatives on access to these transport modes.The European Commission funded a study on access to taxis which EDF welcomes and would be interested for the findings of the study to be used as a future basis for work in this field.   A major problem facing disabled persons is the negative attitudes of taxi drivers who refuse to serve disabled passengers or refuse transportation of guide dogs.   While disability awareness training can help improve such attitudes, punitive measures should be applied to drivers who discriminate against disabled persons.  

2.5.5 Revitalising the Railways

EDF is disappointed that insufficient priority is given to access for disabled passengers and passengers with reduced mobility with regard rail transport in the White Paper.The EU have recently adopted its Directive on Conventional Rail and Decisions regarding the technical specifications on interoperability relating to the High Speed Rail Directive.  These Directives refer to the COST 335   study on access for persons with reduced mobility which must be the essential guide in terms of implementation of this Railway infrastructure package.
Key issues for disabled people and persons with reduced mobility relate to inadequacy of access to railway stations, information of railway timetables, fares and tickets and other available services, inadequacy of access to rolling stock; safety and emergency procedures; staff training on needs of disabled people; issue of concessionary fares.
EDF would like clear and explicit recognition in the European Commission work programme on the importance of ensuring full and equal access for disabled people to rail transport in line with the recommendations of COST 335.
EDF wishes to see mandatory requirements at European level, on rail transport providers which will ensure full and equal access for disabled people to rail transport.

2.5.6 Air Transport

EDF has been an active member on the Task Force on Air Passenger Rights and is still actively involved in the European Civil Aviation Conference sub-group for persons with reduced mobility.   EDF has welcomed the opportunity to be directly involved in the consultation process regarding the drawing up of the air passenger rights charter, notably the separate section on the rights of persons with reduced mobility.
This work has been important in developing communication between the disability movement and the aviation industry which EDF has welcomed.
The voluntary commitments on air passenger rights has established a means whereby the aviation industry can improve its service for disabled people/persons with reduced mobility which is also welcome.  It is essential that EDF and representative disability organisations are fully involved in the monitoring process for the implementation of these voluntary commitments.
However, EDF considers that certain issues can only be dealt with in terms of legislation.  Notably;

• Denied Boarding

Disabled people face situations of denied boarding on the basis of arbitrary and unspecified health and safety grounds which can be discriminatory.  
There are incidents where unjustifiable security reasons are used to impose restrictions on seat allocation. In some cases, disabled passengers are even required to sign a declaration that they will not be any trouble to non-disabled passengers which is blatantly discriminatory and totally disrespectful.
EDF wishes to see much greater harmonisation of the diversity of rules governing health and safety in air travel which are currently far from transparent.   
EDF would favour EU legislation to clarify and harmonise rules in this area including rules on reasonable assistance and for rules governing "right to board" to be incorporated into conditions of carriage.  This would help to counter discrimination of disabled people who wish to travel by air.

• No direct charging for meeting the needs of persons with reduced mobility  including disabled passengers

As a fundamental principle, the cost of providing for the needs of persons with reduced mobility must not be passed directly to the person with reduced mobility.   
Airlines should not be permitted to make extra charges for services to assist disabled people which is still the case among some low cost airlines.  The European Disability Forum wishes to see EU legislation to prohibit this practice which allow airlines to discriminate against disabled people and deny boarding of disabled people.

2.5.7 Promoting transport by sea and inland waterway

Accessibility and security are the key issues for disabled people regarding maritime transport. Many EU and EEA member states are maritime countries where local and regional transport is often done by boat, either along the coast or on inland lakes and rivers. However,  transport facilities rarely consider the interests of  disabled persons and persons with reduced mobility.
For example, a survey produced by Norway (1995) on the accessibility for wheelchair users on the regional and local ferry transport routes showed that of 79 ferries only 3 were accessible for wheelchair users travelling alone and only 10 for manual wheelchair users travelling with an assistant.
EDF wishes to see improved Community legislation which would introduce mandatory access requirements for passenger vessels which would address both the access, safety and emergency evacuation needs of disabled persons and persons with reduced mobility.
This would correspond to the IMO Recommendation on design and operation of passenger ships to respond to elderly and disabled persons needs Provisions for disabled passengers in maritime transport must include, in particular:

• Accessible embarkation and on-board facilities for disabled people
  

• Safety and emergency procedures

2.5.8 Intermodality and Continuity of Journeys

For access to transport to be a reality for disabled people it is essential that it operates on the basis of a seamless journey.   It is important that the White Paper has recognised the need to improve travelling conditions and facilitation of modal transfers.   The major problem this represents for disabled people / persons with reduced mobility must be addressed by the Common Transport Policy.  Without the existence of seamless and accessible transport system disabled people do not have the confidence to travel and their freedom is restricted in a major way.
The principle of integrated and seamless travel for all, including disabled persons / persons with reduced mobility, must be fundamental to the development of the transportation system across Europe.  It must apply both a local and national level but also across the trans-national network system.
An integrated transport system, including integrated ticketing systems and information on interlinking connections, would facilitate travel for disabled people as it would for all travellers.
However,  seamless travel for disabled people requires particular consideration regarding:

• access to the built environment  (such as to  the train station, bus stop, airport)

• access to transport vehicles (buses, trains, coaches, taxis, airplanes)

• information provided in accessible formats relating to timetables and interlinking connections

Lack of access to travel information is a major problem for disabled persons. 
Difficulties exist with on-vehicle information for visually impaired and deaf/hard of hearing people.  This information should be provided in appropriate formats for all stages of the journey. This would mean, for example, the name of every station should be announced audibly and displayed visually, as a train progresses along its route.
Accessible information at railway stations, bus stations, bus stops etc varies from inadequate to non- existent.  There is also a need for real-time information on the status of particular journeys; if there are delays, disabled travellers are extremely vulnerable.

• Assistance to disabled travellers 

There is a need for clear information on, and coordination of, assistance provision for disabled people across the different transport modes.  Transport providers should also accept more responsibility for providing assistance to disabled travellers in cases of delays, cancellations or emergency situations.  At present it is only the airlines which provide any recognition for responsibility to disabled passengers in such situations.

• Need for reconciliation of the different concessionary fares systems:

 
establishing greater transparency regarding the diversity of systems operating across the different transport modes.   This is particularly important for disabled people who need to travel with a personal assistant which proves to be a very expensive business as two tickets have to be purchased for every trip.
At present many people have travel concessions that apply locally or nationally but no international concessions exist, for example, there are no international rail concessions for blind people.
Those passengers able to produce proof of disability should be able to purchase a ticket at the concession rate applicable in that country on demand.
Concessionary fares must be made available on all modes of transport, across local authority boundaries and at all hours of the day.  
Concessionary fares should also be available for door-to-door transport (e.g. dial-a ride and taxi community transport) where a person is unable to use mainstream public transport because of their disability.

• Problem of access to ticketing systems

Transport systems are moving increasingly towards a system of screen based, kiosk type ticketing and information services.  Such systems exclude visually impaired persons and therefore alternative means for ticket purchasing must always be possible. 

2.6 Consultation with representative disability organisations


EDF as the umbrella body representing the European disability movement,  positively welcomes the invitations it has received so far by different divisions of DG TREN in its consultation with stakeholder groups.
EDF would like to stress the fact that the disability movement is very diverse covering a range of different impairment groups with different needs (visual impairment, hearing impairment, learning disability, physical disability and mental health). 
It is essential that the European Commission and the Member States extend the involvement of representative disability organisations in the process of consultation with stakeholders across the mainstream of transport policy work.   
Consultation is particularly important in relation to design of transport infrastructure. The European Commission can play an important facilitation role in bringing consumer groups together with industry and service providers which must be developed in the coming months and years.

3 Conclusion

In conclusion, EDF is seeking to advance upon the commitments presented in the Commission communication 'Towards a Barrier Free Europe'.     Particularly in the lead up to 2003 the European Year for People with Disabilities, EDF will be campaigning for a disability specific EU Directive on non-discrimination which would address access to transport, goods and services among other things.
Disabled people have the right to travel with freedom and confidence and the European Common Transport Policy must give much greater emphasis on how transport policy must meet the needs of society as a whole including the needs of disabled persons and their families.
EDF has welcomed the way in which the Commission has consulted with us thus far on certain aspects of its work on transport but would like to develop these initiatives further in the months ahead.  
EDF regrets however that a similar consultation process was not applied in the drafting of this White Paper on Common Transport Policy.

ANNEX I: About the EDF and other documentation

A.1 About the EDF
The European Disability Forum (EDF) is a European umbrella organisation with 70 European NGOs and 17 National Councils from all of the EU as members. EDF represents the interests of 37 million disabled citizens in the EU. 
Our mission is to advance disabled people's human rights and promote equal opportunities in the EU Institutions and Member States in accordance with principles of non-discrimination.
A.2 Other relevant EDF documents:
EDF 01/5 "Civil Dialogue at EU level– A User's Guide" (2001/03 –EN) 
EDF 01/4  Civil Dialogue – Cementing Europe's Future (2001/03-EN) 
EDF 00/27 EDF Position Paper on the Bus and Coach Directive (2000-12 EN) 
EDF 00/26  EDF Response on the Commission proposal « Towards a Barrier Free Europe for people with disabilities » (COM(2000)284final) (2000/11) EN/FR) 
EDF 00/18 Accessible Access to Urban Areas- EDF contribution, Clean Urban Transport (2000-06 EN) 
EDF 00/2 EDF response on Air Passengers' Rights (2000-03 EN) 
EDF 99/7 Access and mobility for disabled people, an EDF response to EU CTP (1999-04 EN)
EDF 98/3 EDF Guide to the Amsterdam Treaty (1998-03  EN/FR/DE/ES)

A.3 Contact person at the EDF Secretariat:
Stefan Trömel, Director (T: +32-2-282.46.06 E-mail: director@edf-feph.org)  
Sophie Beaumont, EP and Policy Officer (T: +32-2-282.46.02 E-mail: ep@edf-feph.org)
More information about EDF is available on the EDF homepage at : www.edf-feph.org Should you have any problems in accessing the documentation, please contact the EDF Secretariat.
  EDF position paper 'Access and Mobility for Disabled People'  ref: 1999/7
  'Towards a Barrier free Europe for People with Disabilities' COM(2000)284 final  A5-0084/2001
  Council directive relating to special provisions for vehicles used for the carriage of passengers comprising more than eight seats in addition to the driver's seat, and amending Directives 70/156/EEC and 97/27/EC (C5-0278/2001 - 1997/0176(COD))

  OJ L 167, 12.6.1998
Passengers' Accessibility of Heavy Rail Systems; European Commission publication (1999) ref: ISBN 92-828-8223-3
European Disability Forum 2
Preliminary EDF draft response to the European Commission White Paper 
"European Transport Policy for 2010" - Doc EDF 01/11

European Disability Forum 


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