You will remember the blue badge consultation recently conducted by Bromley Council.  This is the text of Bromley Mencap’s response to Ben Stephens, Head of Parking Services, following feedback from our members.

Dear Mr Stephens

Charging Disabled Blue Badge Holders in Council car parks
Consultation period

Further to our letter of the 30th, we have now had the opportunity to consult our membership and hope the following comments assist the Committee with their deliberations.

Firstly we must express our disappointment at Bromley Mencap being initially overlooked as part of the consultation. As you know we only become aware of the consultation through a contact at Disability Voice who had received a formal letter from you. Bromley Mencap did not receive a letter inviting us to take part in the consultation and we are pleased that this was subsequently addressed and your deadline extended. We are the largest disability member led organisation in the borough with 1,500 members. Last year we merged with Bromley Scope and have a significant number of blue badge holders amongst our membership with whom we have widely consulted on your proposed charging policy.

Most members understood that “the purpose of the blue badge scheme is to reserve parking in convenient locations, rather than to be a discount scheme”. However they wanted to highlight the point that people with mobility issues often have no choice but to drive absolutely everywhere, and cannot avail themselves of cheaper ways of getting around such as public transport, park and ride schemes or walking. Non-disabled people who find that parking costs are too high can save money by choosing another option, but disabled people often have no other options, and will find these charges to be a huge financial burden.

Additionally, there was a degree of cynicism about the proposals and a strong suspicion that this was a poor attempt at disguising a revenue raising proposal, particularly when the Council is holding £51m in reserves.

Feedback

Set out below is a summary of the key points raised by members:

  1. Members did not feel that the consultation exercise was broad enough, given the range of individuals and groups affected
  2. Disabled people want and need accessible parking spaces. The reality is that they have no choice but to use their car. Council car parks often provide the most suitable locations for parking. Highway based bays are limited and not always in convenient locations
  3. As a disabled person, I take longer to park, get out of my vehicle and set up my wheelchair, lock the car etc. I don’t always have the benefit of a carer to support me. On the occasions I have to park on the street, the kerb causes me a problem and I am sure that sometimes my manoeuvring and the set up of my wheelchair is both a hazard to other drivers and pedestrians alike. I sometimes take over 30 minutes to get out of and back into my car. As part of my condition, I also need to visit the toilet frequently. This also adds significantly to the time I need to park. In short, if you introduce parking charges, the costs to me will be significant.
  4. People with disabilities tend to be the poorer, most disadvantaged members of society. The committee may not consider how ‘poor’ a person is to be a relevant factor, but people with disabilities are twice as likely to be unemployed or on low income (including those on benefits)
  5. Simply proving low level payment machines will not meet the broader access requirements. Fully accessible machines, that are low level, on flat surfaces, that are tactile, audible and can accept different payment methods will be costly, and may out-weigh the perceived benefit.
  6. Disabled people often have to make several short journeys to different locations within the Borough because they cannot just park in one place and walk to each location they need to go to. With the introduction of charges, they could find themselves paying to park several times in one day.
  7. Have you considered charging a flat annual fee to Blue Badge holders instead? This could be means tested and would eliminate the idea that the Blue Badge was some sort of parking discount scheme. It would give disabled people more freedom and flexibility to go out in their cars without worrying about the cost each time. It would also eliminate the need for more accessible payment meters. Alternatively, could you consider a system of parking tokens, similar to resident permit holder parking vouchers? These could be bought in books of 20, for example, and entitle the user to park for free on a specified day when used with their Blue Badge. This would remove the risk of people paying to park several times in one day, and would also remove the problems associated with physically having to go off and pay at a parking meter.
  8. It is high time you had an effective policy to stop misuse and abuse of blue badges. Far too many blue badges seem to have been issued to people with no vehicles, who pass them on to their family and neighbours, who then use them in the interim.
  9. The consultation document makes no reference to the national review of Blue Badge (Disabled Parking) Scheme that includes the increase the maximum cost of providing a blue badge from £2 to £10. The review also highlights that the average benefit for badge holders from having a badge (and not having to pay parking charges) is estimated to be £300 over the three years for which most badges are valid. If the main driver is about raising revenue, then why not simply raise the administration costs?

Summary

I hope you will consider the points above and take full account of the equality, practical and financial issues and implications for Blue Badge holders if you do introduce pay as you park charges. Ultimately non-disabled people have a choice to make each day about whether or not they want to use their cars, but for many disabled people there is simply no choice at all, and any charges for parking will seem to be taking advantage of a vulnerable group who have absolutely no alternative but to pay up – simply another tax on disability.

The consensus view was that targeting the small number of disabled blue badge holders was not the right approach. There was concern about the unintended consequences of the introduction of charges, including the increased volume of Blue Badge parking on the highways in and around the town centres in the Borough. Some of these roads are already congested enough, that disabled people may simply stop using the shops and facilities in the Borough and may not be properly integrated into the community. Lastly many feared that other parking providers who currently offer free parking to Blue Badge holders i.e. Hospitals and The Glades will follow suit.

The issue evoked strong reactions from respondents, with many feeling that once again the most vulnerable people in society were an easy target. Equally, many recognised the tight financial circumstances the Council was operating in, and said that their prime concern was the provision of suitable, accessible parking spaces. If charges were imposed, they must have sufficient time to purchase a ticket/return to their vehicle, from convenient and safe locations, from suitably adapted machines.

We have consulted Helen Dolphin – Director of Policy & Campaigns at Disabled Motoring (formerly Mobilise). Helen is a member of the British Parking Association and has written a paper on access issues in car parks. Disabled Motoring have also supported a number of successful legal challenges against standard charges being levied. As the result of these cases, authorities have adopted solutions whereby disabled parkers are given either a fixed free period e.g. 3 hours or 1 hour free and 1 hour charged. If Bromley goes ahead with the introduction of charges, we would ask you to consider adopting this approach. If you would like to contact Helen directly I would be happy to pass her details onto you.

Finally and most importantly, we believe the proposed charges are in breach of the Equalities Act 2010, specifically in relation to indirect discrimination. The introduction of the same charging regime as non disabled people will result in disabled people being charged more due to their additional time requirements. Has an Equality Impact Assessment been undertaken for this policy change and if so what was the outcome?

I hope the above is useful and please feel free to contact me if you require further information.

Yours sincerely

Malcolm Wood
Bromley Mencap