Introduction

1.Disability Wales/Anabledd Cymru (DW) is the national association of disabled people’s organisations in Wales striving for the rights and equality of all disabled people, including for independent living. Our core role is to reflect the views of our members to Government with the aim of informing and influencing policy.

2.Disability Wales subscribes to the Social Model of Disability, by which we mean that “disability results from the interaction between persons with impairments and attitudinal and environmental barriers that hinders their full and effective participation in society on an equal basis with others” (UN Convention on the Rights of Disabled People). Disability Wales has been at the forefront of campaigning for disabled people in Wales to have the right to Independent Living.

3.Disability Wales welcomes this opportunity to respond to this inquiry on the Welsh Blue Badge Scheme. This response has been informed by the view and experiences of disabled people. In writing, this response we have consulted with disabled people through an online survey which received 136 responses and a focus group attended by disabled people.

Extending Eligibility Criteria

4.Our survey results showed a mixed response to whether the Blue Badge Scheme should be extended in Wales. 49 per cent of respondents to our survey thought that the current eligibility criteria for Blue Badges should be extended.  

“Include diagnosis of autism, I had to go in depth to explain how my daughter’s condition affects her mobility day to day and how we need the larger spaces etc. It’s annoying I had to get a letter off a specialist health visitor to back us”

5.We welcomed the extension to eligibility in 2014, which widened eligibility for people with autism and more recently the introduction of temporary blue badges. Our survey results suggest that public awareness of this extension is low. As many respondents were unaware that people with autism or mental health conditions could now be eligible for a Blue Badge.

6.Since the 2014 extension, many disabled people have lost automatic entitlement to their Blue Badge due to changes in the level of Personal independence Payment (PIP) that they receive. We would welcome a review of the eligibility criteria that helped clarify the entitlement of people with long term health conditions and / or impairments that may no longer be entitled to PIP.

“Currently we are unable to access activities and days out other families can. A blue badge would reduce the barriers and allow us to access more opportunities. This is the case across Wales but not? just our family”

7.Extending the eligibility of the Blue Badge scheme would allow more disabled people to easily access leisure, retail and work opportunities, reducing social isolation and loneliness. However, with more badges in circulation, the number of accessible parking bays would also need to increase.

The Practical Implementation and Consistency of the Blue Badge Scheme across Wales

“We were refused as my son is not physically disabled. They didn't consider that a disabled badge would make life less dangerous for me and him being able to park closer and having more room. He kicks and punches cars if they park too close and tends to not leave the car if we are too far away”

8.Many respondents without automatic entitlement to a Blue Badge experienced difficulties in applying for their badge. There appears to be a postcode lottery in Wales in relation to how discretionary applications are assessed across local authorities. This is particularly the case for people with autism.

“When my son was under 3 and a wheelchair user I was told there was no way I could have a blue badge without full mobility element of DLA which I could not apply for till he was three. This made life very difficult for us”

9.There seems to inconsistencies relating to the eligibility criteria set for Blue Badges and the information provided by local authorities.  Parents of disabled children have reported being told that their children were too young to receive a Blue Badge, despite having an impairment or health condition and being over the age of two.

10.We understand the need for discretion when assessing eligibility for people without automatic entitlement to a Blue Badge, However, the current inconsistencies across Wales in how applications are assessed is not working for some disabled people. We would like to see the guidance to local authorities in relation to assessments of discretionary badges strengthened. A review of the assessment process would ensure that assessments of discretionary badges are consistent across Wales.

11.We have also noticed inconsistencies in the way Blue Badges are renewed. Some of our members with long term health conditions and / or impairments are having to undergo a full assessment when renewing their Blue badges. In situations where an individual has a long-term progressive health condition or impairment, we would welcome the award of badges for a period longer than three years that reflects the fact that the condition will not improve. 

“I sent evidence needed using my smart phone. Took photos of PIP evidence and ID and emailed it to the council all using my phone. I didn’t have to attend the Council office like last time. It was a much easier process for me than trying to find time to get there and find accessible parking space. Difficult last time”

12.The majority of respondents to our survey applied for their Blue Badge in person at their local Council Offices (39 per cent). When asked how they would prefer to apply 63 per cent of respondents stated they would prefer to apply online.

13.Although the majority of respondents preferred online applications, it is important to note that many disabled people do not have access to the internet, therefore a range of applications options should be made available.

“They are well monitored in town etc. by traffic wardens but supermarkets etc. have a long way to go. Businesses need to monitor their spaces not just provide and then ignore”

14.76 per cent of respondents thought that Blue Badge spaces are not monitored well. Our members told us that they are often unable to park due to non-blue badge holders occupying accessible parking spaces.

15.We would like to see stronger enforcement levers used against drivers who park in accessible parking bays without displaying a blue badge.

16.47 per cent of respondents reported experiencing difficulties when parking with their Blue Badge. These difficulties range from problems in finding a space due to a lack of accessible parking bays, receiving abuse from members of the public when using their Blue Badge to park and non-badge holders taking up accessible parking bays.

17.Our survey respondents highlighted issues with the lack of accessible parking bays with extra space to allow easier wheelchair / mobility scooter access. One member who uses a mobility scooter explained that she did not necessarily require a parking space close to the building, but one with enough space for her to transfer easily from her scooter into the car, for example.  Clearer guidance on the amount and size of accessible parking bays should be made available to local authorities and organisations with car parking facilities. 

“Some people challenge me as I don't 'look' disabled - people still think it’s for wheelchair users”

18.We are concerned about the number of disabled people experiencing abuse from members of the public when using their Blue Badges. It is not acceptable that disabled people are being victimised for using a facility they are entitled to. We would like to see a public awareness campaign aimed at reducing discrimination towards disabled people. From our survey results we have noticed this abuse is particularly targeted at people with hidden impairments and health conditions. It is important that any public campaigns features a range of disabled people with varying impairments and health conditions.

The Support and Information That is Available to Blue Badge Applicants in Wales

“I was told I could apply. When I applied I was told no because my son wasn't physically disabled - so in fact I couldn't apply”

19.28 per cent of respondents to our survey felt that they did not have adequate access to information and advice when applying for their Blue Badge.

“I wish I had known earlier that I didn’t need a PIP decision to be eligible for one. I had been avoiding completing a PIP application as I knew how bad it would be, but was really struggling to walk, and to get out of the car in tight spaces. When the physiotherapist at the hospital said her medical report would be enough I could have cried”

20.Many respondents reported being told by their local authority that they were not eligible for a Blue Badge as they did not receive DLA or PIP. It is clear that incorrect advice and information is being offered to members of the public in relation to eligibility criteria.  Inconsistent information will prevent disabled people from applying for a Blue Badge and can contribute to loneliness and social isolation.  It is important that all advisors and assessors are aware of current eligibility criteria to ensure that prospective applicants receive the correct information and that assessments are completed correctly. Additionally, more needs to be done to raise awareness of eligibility criteria amongst the public.

“They didn't want to pay for BSL interpreter for interview. But email communication was eventually accepted as a way of application”

21.Our members highlighted a number of issues they faced when accessing information on the Blue Badge application process. Firstly, members with a vision impairment were not able to access digital information on the scheme because, a) the file format was not compatible to screen-reading software and, b) they did not have access to the internet where most information on the scheme is held. Secondly, members with learning difficulties were reliant on other people to interpret the information as easy-read versions were not readily available. Thirdly, disabled people asked to attend a face-to-face interview were not provided with appropriate communication support.

22.We would like to see information relating to Blue Badges made available in alternative formats. These should include; accessible digital versions (word format), easy-read, British Sign Language videos and printed accessible materials for people without internet access. Furthermore, it is not acceptable that disabled people are being refused access to communication support when asked to attend a face-to-face assessment. Under the Equality Act 2010 local authorities have a duty to provide reasonable adjustments which would include providing appropriate communication support and information in alternative formats.

Conclusion

23.Overall, the majority of respondents to our survey (80 per cent) were satisfied with their experience of applying for and using their Blue Badge in Wales.

24.There is a clear need for improvements to the scheme including; better access to accessible information and increased enforcement of parking bays. We would like to see improvements to the information provided to the public by Local Authorities in relation to eligibility criteria. In addition, clear guidance needs to be issued to Local Authorities to end the current postcode lottery system and ensure assessments are carried out consistently across Wales.

25.Lastly, we would encourage the launch of a public campaign to raise awareness of the Blue Badge Scheme and eligibility criteria, which may help increase applications and reduce abuse from members of the public towards Blue Badge holders.