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Policy Papers
The
Scottish Disability Equality Forum �(SDEF)
is an umbrella membership organisation open to all disability organisations or
any individual with any type of impairment and is funded by the Scottish
Executive.�
Every person, organisation and network
has an important role to play in ensuring the voices of people who are affected
by disability are heard in the new Scotland. The SDEF seeks to enable this.�
The Forum is presently seeking to restore a network of groups dealing
with access throughout Scotland to share expertise and add value to the work of
local groups.
The Scottish Disability Equality Forum
therefore welcomes the opportunity to comment on the above draft Regulations.
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Please let us say first of all that we
think this is a well-researched consultation paper, which covers most items of
concern.�� However, there are
still matters which we would like to highlight.
The draft regulations must be made specific to cover the
following
1.�����������������
Most important omission is there is no stated time-scale.�
This must be included in regulations.�
Planning should be able to be dealt with quickly.�
However we more concerned about implementation, monitoring and penalties
for non-compliance � the how and when.� Who
will oversee and monitor and enforce? � appears from P9 Section 3 � HM
Inspectorate.�� How soon will
they be able to set up to do this?�
2.�����������������
They will need to be specific and made such that it will not be cheaper
to break the law and pay a fine.
3.�����������
Additional resources must be identified and allocated for planning, but
more importantly implementing strategies.
Page 5 Accessibility Strategies.
Par. 2c Genuine
informed open choices must be given to parents and pupils which would benefit
each individual pupil whether in mainstream or �specialist schools� � not
being told this is best � for whom? and why?�
Mainstream must mean total inclusion within the school environment and
not special units on the same campus i.e. a school within a school, where all
the pupils do not have the opportunity of mixing.
If the explanatory notes and impact form
part of the official and enforceable document, then the following comments may
be superfluous.� If not the
regulations must be expanded to do so.
This would involve changes in school
management � movement of pupils within school, school outings and holidays,
and after school activities.
Page 6 Pre-school must be included
Impact.
P.10����
Special Educational needs and disability act 2001 in England and Wales
�unlawful to discriminate on grounds of disability.�
Emphasis again on planning � implementation, enforcement and their
timescale to support, necessary before planning means anything.
Agree there is only one option which
will work and that is option 3 and introduce primary legislation.�
This can then be enforceable and be enforced.�
This will also mean it will not be subservient to other complementary
legislation e.g. Building Regulations and Transport (as is the DDA itself, which
is secondary)
The needs of disabled parents should
also be catered for, to give them equal rights with other parents.�
In addition many schools are now community schools which are open to the
general public.
Page 11.�
Agree especially with travelling long distances.��
This is discriminatory as it means a longer and tiring day compared with
other children, and taking away from other local children.�
This means also specialist transport provision.
Page 12�
Glad to see mention of benefits of inclusion to all pupils and staff,
helping everyone to adapt and understand difficulties.�
This will form a good basis and better understanding in the future
throughout their lives.� This will
impact on disability awareness training and teacher training colleges and in
schools for all staff working there (not only teachers) e.g. secretaries, dinner
ladies etc.
P12.�
Higher achievement important element and should mean being better
equipped.� However, this opportunity
must be carried on beyond statutory educational age, as the higher expectations
will not reach full potential.
Costs.�
Private sector costs detailed.� Public
sector not costed � is this because it gets �lost� in the overall budget?� Is it intended that extra resources will be identified and
allocated especially for implementation or will this come of existing budgets,
which are already strained.� Concerned
this document only covers planning strategies.�
There will be costs of implementation and evaluation.
P13�
Some suggestion of how this could be done.
Do not accept� re-scheduling of classes and time tables unless whole class
is involved, and until all other avenues have been explored and discarded and
certainly never in a new school.� This
must never seen as the easy option.� The
individual child must never be made to feel different.�
This must not affect choice of subject e.g. in secondary school if the
only science labs or art rooms are upstairs.�
Stair lift is not acceptable unless it is a platform type as many people
cannot transfer themselves, and lifting is neither dignified, independent nor
safe for anyone.
Annex
A�
Agree except for timetabling see above.�
Safety must be taken into account e.g. practical subjects but not a
blanket ban (each individual pupil should be assessed on their own merits and
abilities).
Glad to learn that it has been
recognised that information will be made available in various forms e.g.
dyslexic pupil or parent.
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