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RESPONSE TO CARRYING OF GUIDE AND HEARING DOGS IN TAXIS REGULATIONS - DECEMBER 2001

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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One of the main drawbacks of this piece of legislation (as with the previous one regarding carrying people with mobility problems) is that enforcement will be almost impossible. Taxi driving is the type of industry which employs many casual drivers, which makes regulations very difficult to enforce

Any regulation is only as good as its enforcement is practical.

Another difficulty is caused by the fact DDA excludes private hire vehicles.The fact that, apart from the cities, a large proportion of the taxis are actually private hire and thus the regulations will not be mandatory is unfair on people in these areas.�� We admit that this has been recognised in paragraph 4 of the guidelines, but we have learned from experience that the use of discretionary powers leads to all sorts of anomalies and interpretations, increasing difficulties in enforcing.

Types of dog

Guide dogs are accepted by the population at large as a special type of dog which is strictly trained through a long established training scheme. They are seen as a necessity to aid their owners to get around out of doors. However, the tasks carried out by hearing and assistance dogs are useful within the domestic situation, but are not in the same category outside.In addition we are not aware of the same nationally recognised training schemes.We feel therefore that there will be little difference between them and a well trained pet dog, and this could be lead to conflict.

There is reference to purpose built vehicles with screens. However, because of the previous legislation to allow those with mobility problems to travel with ease � there is a growing number of taxis which are the people carrier type, with no screens.

Guidelines

Paragraph. 12

We feel as GP/Consultant should already hold records of long term conditions, these sources should be used.Special medical would only provide a �snapshot in time� and not be a fair test, where a variable condition exists.

Par. 13

Must include reason for exemption

Par. 17

Time period must be stated and not be indefinite as medical treatments could improve the prognosis.

Par 18

The most logical thing is for Badge being for applicant�s use with photograph, which would parallel Blue Permit for disabled drivers.However, this again has been proved almost impossible to ensure against abuse

Include an obligation on both parties to disclose when a dog is involved, when a taxi or private hire vehicle is ordered by telephone.This would avoid a situation arising where a vehicle is sent whose driver can�t take the passenger.

Impact

This appears to be an open charter to apply for increased fares.The grounds for any application for increases must be scrutinised vigorously, before Licensing Authority allows them.

Are exemptions only on medical grounds?Emphasis seems to be placed on allergies relating to breathing problems, but there could be dangers for someone with a blood disorder, for example, if they were to be scratched or bitten(accidentally).What about a genuine fear of dogs?What would the position be where a taxi was ordered as �shared� and the other party had an allergy to dogs?How would this place the driver?What would be the position of damage done and mess caused by dogs?

Questions contained in your letter.

1.����������������� Prefer six months for implementation so that there would be fewer excuses of not being able to get it processed in time.

2.����������������� Regulatory Impact assessment � feel assessment is optimistic.It is impossible to accurately forecast numbers which will be granted exemption, but no doubt there will be a lot more applications, than grants.�� This could raise the costs and slow down the process.�� Are there any figures available of how many people have these dogs and use, or likely to use, taxis?This will also having a bearing on costs.

3.����������������� Draft guidance notes we feel cover what is required.

4.����������������� What happens about carrying dogs in Public transport vehicles, or transport provided by Local Authorities?�


Scottish Disability Equality Forum

Working together for the disability movement

SDEF is a recognised Scottish charity no. SC031893

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