Accessible Transport Strategy 2025
Consultation Document - Response
15/11/2015
DART Partnership
Contents
About DART Partnership ............................................................................... 3
Contact Details ............................................................................................... 3
DART Response to the Accessible Transport Strategy 2025 ..................... 4
(1) Imagery .................................................................................................. 5
(2) Identification of Themes ....................................................................... 6
(3) Language & 'Community Transport' .................................................... 7
(4) Structure - Theme 2' ..........................................................................8-9
(5) Accessibility ................................................................................... 10-11
(6) Data, reliability, assumptions & omissions ................................. 12-13
(7) Flawed engagement to date ............................................................... 14
(8) Reference to Integrated Passenger Transport Project .................... 15
(9) Responses to specific questions in ATS 2025 ................................. 16
(10) Responses to action plans............................................................... 17
(11) Commitment to full public consultation.......................................... 18
Conclusion ................................................................................................ 19
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DART Partnership
About Down Armagh Rural Transport Partnership Ltd
As a company limited by guarantee and a registered charity, DART was
formed in 1999, as a multi-agency partnership, tasked with delivering a range
of community transport and training services throughout Craigavon &
Banbridge.
The DART Partnership is the only not-for–profit community transport operator
offering subsidised travel services to the voluntary sector and has become the
real focal point for individual, group and rural community transport
requirements within the Craigavon & Banbridge council areas.
DART operates a fleet of 11 accessible vehicles and provides the following
services: include:
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Group Hire (self-drive service)
Dial-A-Lift Service (DAL) – (pre-booked Door-to Door service)
Disability Action Transport Service (DATS) - (pre-booked Door-to Door
service)
Accredited MIDAS training & Elements of Driver CPC
DART’s transport services are operated by drivers fully trained to MIDAS
(Minibus Driver Awareness Scheme) standards.
The DART Partnership provides over 40,000 individual passenger trips per
year to eligible individuals utilising the Dial-A-Lift Service (DAL) and Disability
Action Transport Service (DATS) throughout the Craigavon & Banbridge
council areas.
DART’s transport, training and volunteering programs are actively involved in
delivering community transport solutions to issues including:
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Reducing rural isolation
Improving accessibility for the disabled
Facilitating social support networks
Providing access to services
Promoting volunteering & active communities
Contact Details
Any queries regarding this response should be directed to:
Ian Wilson
Director
DART Partnership
39 High Street
Lurgan, CRAIGAVON
Co.Armagh, BT668AH
Tel: 02838317810
Email: ian@dartpartnership.org.uk
Web: www.dartpartnership.com
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DART Partnership
DART Response to the Accessible Transport Strategy 2025
Introduction
The DART Partnership has considered the Accessible Transport Strategy 2025
consultation document and would recognise, as a key delivery agent for demand
responsive services across NI, that the implementation of the previous ATS
(2005–15) has led to significant improvements in accessibility across all modes
of transport including;
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Physical accessibility of vehicles, depots & infrastructure
Accessible information
Community transport services (including urban & rural demand
responsive / Door to door services)
Shop Mobility
Taxis & Private buses
Concessionary Fares
We recognise that the new ATS 2025 acknowledges these improvements and
has identified five themes for the new Strategy to further enhance and improve
accessibility.
As a key delivery agent in the accessible transport network, DART welcomes
the opportunity to influence the strategic direction of the Strategy over the
medium term through the public consultation process.
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DART Partnership
(1) Imagery
1.1
The ATS 2025 consultation document is replete with imagery which is largely
shot from within Translink's Central Station in Belfast.
This gives a largely urban-centric hue to the document - a theme which will be
revisited later in our response when considering the make-up of stakeholder
bodies which informed the ATS consultation document.
1.2
In a referenced survey in page 10 of the ATS 2025 consultation, Attitudes of
Disabled and Older People to Public Transport, November 2014 – January
2015, it is noted (page 12) that more than 43% of respondents to the survey
published on 23rd April 2015 were from a rural area. It is also noteworthy that
more respondents used 'DATS' & 'Community Transport Services' than
Translink rail services, however, most of the imagery is focused on trains and
station related infrastructure.
1.3
DART would recommend using imagery from rural areas which celebrates the
success of the demand responsive community transport providers in increasing
accessibility in remote and isolated areas where large urbanized transport
infrastructure does not exist. This would ensure that potential stakeholders who
are rural dwellers can at least identify with subsequent documentation on a
stylistic and visual level.
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DART Partnership
(2) Identification of Themes
2.1
Generally, the five themes outlined in pages 11& 12 of the ATS 2025 are
satisfactory as broad measures of strategic intent for 2015-2025.
However one of these themes, Theme 2, page 14, 'Improving accessibility of the
wider transport network' suffers from being vague, and poorly defined.
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DART Partnership
(3) Language & noted Omission of 'community transport'
3.1
There are real and substantive issues around the ambiguity of confusing and
inconsistent language especially in relation to Theme 2. 'Improving accessibility
of the wider transport network'.
Vague and undefined terms like, 'wider transport network', (pg,11), 'specialised
transport services', travel options', alternative forms of private or publicly funded
transport', (pg,12) are peppered throughout the Theme 2 section.
3.2
Why does there seem to be a deliberate attempt not to name 'community
transport' or identify successful, accessible and integrated schemes such as
Dial-A-Lift (DAL) or the Disability Action Transport Service (DATS)?
3.3
Indeed DART notes, in page 11 of the ATS 2025, that it's authors claim that the
inspiration for Scottish ATS 2015-2020 is based upon Northern Ireland's
previous ATS (2005-2015).
An examination of the Scottish ATS 2015-2020 has revealed that community
transport or Scotland's CTA (Community Transport Association) is mentioned no
fewer than ten times throughout their strategy with community transport
identified as a key strategic partner specifically linked to stated strategic
objectives throughout the Strategy.
3.4
In stark contrast to the Scottish ATS there seems to be no stated or specified
commitment to the development or sustainability of current publicly funded
community transport provision as a means of achieving an inclusive and
accessible transport system for Northern Ireland, anywhere in this consultation
document.
3.5
The language used to describe accessible transport services could be
considered to trivialise what are essential services for many disabled and older
people, suggesting that they are utilised for convenience rather than need.
3.6
The terminology used to refer to accessible transport services is unclear and
inconsistent. Throughout the consultation document and the supporting
documentation the Department refers to “specialised transport schemes”,
“supported transport programmes”, “publicly funded transport”, “other transport
services” and “the wider transport network”.
Do these terms mean community transport services such as DATS, and Dial-ALift, which ordinary stakeholders can readily identify with?
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DART Partnership
(4) Confusing Structure of Theme 2
4.1
As a corollary to the above section which identifies language and noted
omissions, it is significant and noteworthy that the structure of Theme 2 also
differs greatly to the structure of Themes 1, 3, 4 & 5.
Themes 1,3,4& 5 set out a number of aims which relate to the theme and
corresponding measureable targets – this is not evident within Theme 2.
E.g. Theme 1
Aim – maintaining and improving the accessibility of the transport fleet, including
working towards step free public transport vehicles
Measured by – monitoring the % of step free vehicles in the public transport
fleet.
E.g. Theme 3
Aim – promoting the benefits of the NI Concessionary Fares Scheme and
encouraging greater usage by pass holders
Measured by – the uptake of the half fare concession
E.g. Theme 4
Aim – examine new ways to provide information in different media or formats
Measured by – measuring usage of different media
4.2
In contrast to the SMART themes 1,3,4, listed above, Theme 2, (page 14) refers
to a vague aim of ‘continue to examine options to deliver integrated transport’,
which will be measured by ‘taking forward the Integrated Passenger Transport
Pilot’
This aim makes no sense within a Theme which sets out to ‘Improve the
accessibility of the wider transport network’ and the measuring progress on this
aim ‘taking forward the Integrated Passenger Transport Project’ is the most
vague and unidentifiable statement in the whole document.
This is due to the fact that the Integrated Passenger Transport Project (IPT)
remains a largely unknown DRD micro pilot focused on a small number of areas
in Mid-Ulster, for which there is a paucity of hard quantitative data in terms of
patronage and the actual benefits derived from the project.
4.3
DART are very surprised given the absence of any meaningful analysis to date,
that reference to the (IPT) has been included as a key objective without any
evaluation of its outputs or benefits in relation to integration of transport.
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DART Partnership
4.4
DART would recommend that reference to the Integrated Passenger Transport
Project (IPT) be removed from Theme 2 and a 'SMARTER' and more tangible
aim be included, such as:
Proposed Aim - maintaining and improving the accessibility of the transport fleet
within the wider transport network.
Measured by – the number or % of accessible vehicles within the wider
transport network.
Or,
Measured by – the number of older people and people with a disability who use
publicly funded community transport provision within the wider transport
network.
4.5
The benefit of including actual examples linked to current community transport
provision would be the utilization (as a benchmark of future measurement) of the
extensive data supporting the effectiveness of these measures, including, Social
Return on Investment (SROI) Study (2014) and CTA NI Stakeholder
Engagement Study (2015) both of which utilised large and diverse stakeholder
sample sizes of 300 and 500 respectively.
4.6
It is the contention of DART that the public should be given the opportunity to be
consulted on ideas on how to improve the accessibility and sustainability of the
current 'wider transport network' including current, tangible and measurable
publicly funded community transport provision.
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DART Partnership
(5) Accessibility
(5.1)
The consultation document is not easy to read – it references many other
documents which must be read in conjunction with it which may not be readily
available to some who would wish to or who are invited to respond to the
proposed ATS. This makes the process of consideration of the Strategy a lot
more work for the respondent and as a result can only invite ill-informed and
misguided responses.
We would draw attention to HM Government's Code of practice on Consultation
(2008) which states, Criterion (4) 'Consultation exercises should be designed to
be accessible to, and clearly targeted at, those people the exercise is intended
to reach'.
(5.2)
Again, without access to additional documentation/data it is fundamentally
impossible to respond effectively to the ATS 2025 document. The documents
required to respond effectively would include:
1. DRD NI (2014), The Options for Improved Integration of Publicly Funded
Transport Services - Integrated Passenger Transport Project.
2. SATA (2015), Accessible Transport Strategy and Action Plan for Scotland
2015-202
3. DRD NI (2014), Attitudes of Disabled and Older people to Public
Transport, November 2014-January 2015 - Stakeholder Report from DRD
ATS Focus Group Meetings.
4. IMTAC (2015), The Accessible Transport Strategy (ATS) 2025: Our views
on the vision, strategic priorities and how to measure success for a new
ATS.
5. OFMDFM (2012), A strategy to improve the lives of people with
disabilities' 2012-2015.
We would draw attention to HM Government's Code of practice on Consultation
(2008) which states, Criterion (4) ‘Consultation exercises should be designed to
be accessible to, and clearly targeted at, those people the exercise is intended
to reach'.
(5.3)
In addition DART's participation in recent consultations with a range of
stakeholders in October 2015 have revealed that the vast majority of potential
respondees will not be familiar with the Integrated Passenger Transport Project
(IPT), its aims and objectives; nor will they have any consideration of its success
to date and its future potential to inform any subsequent strategy.
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DART Partnership
(5.4)
DART remains deeply dissatisfied with the historic and current lack of
meaningful engagement with the Integrated Passenger Transport Project (IPT)
and we are therefore ill-equipped to inform our stakeholders about (IPT) with a
view to improving consultation responses with reference to the ATS 2025.
We would draw attention to HM Government's Code of practice on Consultation
(2008) which states, Criterion (4) ‘Consultation exercises should be designed to
be accessible to, and clearly targeted at, those people the exercise is intended
to reach'.
(5.5)
In general terms, the terminology used – particularly in reference to what users,
providers and other stakeholders refer to as ‘Community Transport’ – is unclear
and inconsistent.
(5.6)
Throughout the document – and in particular in Theme 2 - there are references
to ‘publically funded transport’ and ‘specialised transport schemes’.
Most respondents (particularly from the wider community & voluntary sector
organisations who use community transport services) will not know what these
terms refer to but would recognise the term ‘community transport’ – this
confusion will influence greatly the types of responses received from this key
stakeholder group.
(5.7)
Most of the questions within the response document are very leading – starting
with a very broad and general statement and asking if the respondent agrees or
not.
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DART Partnership
(6) DATA - Reliability, Assumptions & Omissions
6.1
Why is there no reference to the numbers of passenger trips made by disabled
individuals on accessible transport services such as Dial-A-Lift & the Disability
Action Transport Service?
Indeed there currently exists in the public domain a wide range of independent
qualitative and quantitative data on the usage and effectiveness of the above
services including:
1. Guage NI, (2014), The benefits of community transport in N.Ireland,
Social Return on Investment (SROI) Study.
2. Lloyds TSB/CTA NI, (2015), Stakeholder Engagement Study –
community transport in Northern Ireland.
Both of the above utilised large and diverse stakeholder sample sizes of 300
and 500 respectively.
6.2
In contrast to (6.1) above, we note the Department's continued reliance on
largely anecdotal data provided by IMTAC.
The consultation document makes reference, on page 7, to the IMTAC
publication “The Accessible Transport Strategy 2025: Our views on the vision,
strategic priorities and how to measure success for a new Accessible Transport
Strategy”.
The IMTAC document states “Rural and urban transport services funded by the
Department are important services used by relatively small numbers of disabled
and older people. We know from our work that some people are dissatisfied
with these services” –
What evidence can IMTAC or the DRD (NI) provide to quantify and substantiate
such statements?
6.3
DART's independently commissioned and available research is in complete
variance with IMTAC's statements and indeed a recent report on the findings of
a Northern Ireland wide stakeholder engagement program produced by
Lloyds/CTA NI in 2015. This report indicates a 96% approval rating with current
community transport provision, i.e. DAL & DATS.
A further study conducted by the DRD’s Sustainable Transport Branch,
referenced in page 10 of the ATS 2025, which involved significant stakeholder
engagement , notes, in (page 16), (Accessible Transport Strategy 2025 Stakeholder Engagement - Emerging Issues, Sustainable Transport Branch,
August 2015);
Rural Transport is recognised as a very important and necessary transport
scheme to prevent social exclusion and isolation in rural areas. From the
feedback in the focus groups it is widely used both in urban and rural areas and
it is noted that the drivers are excellent.
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DART Partnership
Approximately 92% of the vehicles used by Rural Community Transport
Partnerships are accessible.
Why is the above positive data not reflected in the ATS 2025 consultation
document to support and sustain existing community transport schemes (DAL &
DATS) which are delivering effective, integrated and accessible transport
solutions for disabled people across N.Ireland?
6.4
As a consequence of our findings (6.3) above, we would recommend that the
Department should critically examine the narrow range of data used to inform
this consultation document and consider a broader range of data concerning
community transport services which is currently available to DRD.
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DART Partnership
(7) Flawed Engagement to date
7.1
DART has long maintained that departmental consultation with community
transport providers has not been adequate in relation to the Integrated
Passenger Transport Project (ITP).
7.2
Indeed, we have stated after the previous (ITP) consultation process that we
have consistently felt that the current method of Departmental engagement is
highly selective, inaccessible and ineffective and at no point has the situation
improved – in fact we are at a point where a ATS strategy has been presented
without any pre-stakeholder engagement with DART - a major provider of
demand responsive services in the Craigavon & Banbridge currently delivering
over 25,000 individual demand responsive trips per annum.
(7.3)
It is of great concern to DART that the Department states that it does not intend
to undertake a full public consultation on the (revised) ATS 2025 or the new
action plan but will instead consult with those who have requested through this
consultation to be involved – this flies in the face of the focus on engagement
discussed throughout the document.
DART's unequivocal recommendation is that there must be a full public
consultation.
(7.4)
DART contends that an open and positive dialogue involving community
transport operators and users at all levels could lead to a better grasp of what a
future accessible and inclusive transport network might look like.
This dialogue could also be opened to the public rather than the limited, closed,
restricted and 'agenda led' exercises, held to date and coordinated by 'arms
length bodies' funded by the DRD.
DART feel that this current dialogue is predominantly a negative one.
(7.5)
We would also draw attention to the relatively short time-frame for this
consultation response which we feel is unacceptable - and would reference HM
Government's Code of practice on Consultation (2008) which states,
"Consultations should normally last for at least 12 weeks with consideration
given to longer timescales where feasible and sensible."
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DART Partnership
(8) Reference to Integrated Passenger Transport Project (ITP)
(8.1)
The proposed Strategy prematurely relies heavily upon the Integrated
Passenger Transport Pilot/Project but does not provide any information on the
context or content of this pilot, the providers involved; the passenger
demographic particularly in respect of disability; how it has addressed
accessibility nor its relevance to day to day transport users. There is no
definition provided as to what the Department mean by “Integrated Transport”
which is different from what the wider disability sector and the general public are
likely to associate with that term. There is also no information publicly available
on the success or otherwise of this pilot nor has it been approved by the
Northern Ireland Executive.
(8.2)
Therefore as in (4) and for the reasons outlined above we would contend that all
reference to the ITP should be removed from the consultation document.
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DART Partnership
(9) Responses to specific questions - pages 23-32
(9.1)
DART has answered NO to all questions since we believe the consultation
document is fundamentally flawed in terms of pre-document engagement,
structure, language, critical omissions and accessibility.
QUESTION
Since the launch of the ATS in 2005 do you
think the accessibility of the transport system
for older people and people with a disability
has improved?
Do you think there is a need for an ATS?
Our vision for a new ATS is to have a
transport network in NI that is inclusive &
accessible to all. Do you agree?
Theme 1 - Enhancing the accessibility of the
public transport network - do you agree with
this approach?
Theme 2 - Improving the accessibility of the
wider transport network - do you agree with
this approach?
Theme 3 - Enhancing the customer
experience - do you agree with this
approach?
Theme 4 - Enhancing the accessibility of
information - do you agree with this
approach?
Theme 5 - Working in collaboration with
partners and stakeholders - do you agree
with this approach?
RESPONSE
NO
NO
NO
NO
NO
NO
NO
NO
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DART Partnership
(10) Responses to action plans - pages 31 - specific actions.
1. Immediate and urgent 'meaningful' engagement from DRD with publicly
funded community transport providers to address issues raised in this
response along with a commitment to build a broader and more diverse
stakeholder representative grouping in future.
2. Immediate and urgent agreement from DRD for representation from
publicly funded community transport providers at all levels in respect of
the Integrated Passenger Transport Project.
3. An action plan to address accessibility issues for disabled people living in
remote and isolated rural areas where there is poor or insufficient public
transport infrastructure.
4. A commitment to consider the appropriateness of key strategic objectives
in relation to community transport, contained in the Accessible Transport
Strategy and Action Plan for Scotland with a view to implementing similar
measures in Northern Ireland.
5. An immediate undertaking by DRD to critically examine the data used to
date to inform the ATS 2025 consultation document in relation to
community transport provision, with a commitment to include relevant
data which supports the continued role of community transport in
improving accessibility of the transport network.
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DART Partnership
(11) Commitment to full public consultation
(11.1)
DART's recommendation is that there must be a full public consultation.
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DART Partnership
Conclusion
The Community Transport Network (NI) is concerned that DRD officials who are
involved in this process have a limited and narrow understanding of how
community transport delivers a wide range of effective, integrated and
accessible transport solutions across N.Ireland.
This fact that community transport has not been mentioned once throughout this
consultation document, whether by accident or design, further reinforces our
view.
For the reasons contained in our response DART would recommend that the
present consultation process and documentation be radically revised as we
believe it is not fit for purpose and contravenes important key criteria in relation
to good practice as contained in HM Government's Code of Practice on
Consultation (2008).
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