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Policy Papers
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?�
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