The equality watchdog has warned that the proposed closure of nearly 1,000 rail ticket offices across England could breach both the Equality Act and the UN Convention on the Rights of Persons with Disabilities.
The Equality and Human Rights Commission (EHRC) said it remained “concerned” about the potential impact of the closures on disabled rail passengers, while there were “important questions” over whether they complied with equality laws and the UN convention.
In its response to a consultation on the closures, which ended last Friday (1 September), the EHRC warned that the closures could “increase the barriers to accessing rail travel for disabled and older people”.
It also warned that cuts to staffing could affect the safety of passengers, particularly disabled people, women, members of the LGBT community, and younger and older people.
The commission pointed out that because it was unclear how overall staffing figures would be affected by the proposals, those responding to the consultation “cannot know whether there will be sufficient staff available to meet the needs of those seeking assistance”. It said this was a “serious concern”.
The commission also said it was “essential” that the proposed changes did not increase barriers for disabled people who wanted to continue to enjoy “spontaneous” travel through “turn up and go” services.
Last month, Disability News Service reported how campaigners were warning that the right of disabled people to enjoy spontaneous travel on the rail network was under “serious threat” due to the proposed closures.
The commission said that spontaneous travel was “fundamental to ensuring disabled people can realise their right to independent living” under article 19 of the UN Convention on the Rights of Persons with Disabilities.
EHRC also warned in its consultation response that the arrangements made by train companies after any closures could be “confusing” for disabled and older passengers because of the possibility of “significant inconsistency in the provision of rail services” across the 13 train companies involved.
And it said it was “particularly disappointed” that the Department for Transport had yet to release an equality impact assessment of the proposals (see separate story).
It reminded both the government and the 13 train companies of their obligations under the Equality Act to consider the impact of the proposals on disabled people and other minority groups.
The watchdog welcomed the decision to extend the initial length of the consultation from 21 to 58 days, but it said it believed that this “still remains inadequate” for many disabled and older people and the organisations that represent them “to consider the possible impact of proposed changes and to raise their concerns”.
It has also been told that some of the consultation documents were inaccessible to some disabled people, while new documents were added during the consultation period, which “will have potentially further reduced the amount of time for some disabled people to consider and voice their concerns on these proposals”.
And it said that the complexity of the process – with 13 train operating companies submitting their own proposals – made it difficult to understand the wider impact of the closures, including how they would affect accessibility.
The commission said it believed the consultation period should have been closer to three months, rather than the two months eventually agreed by train companies.
If that was not possible, it said, “more could have been done to help rail travellers to understand the variable impact of 13 different proposals on their potential travel arrangements”.
EHRC said in its consultation response that the proposed changes “largely rely on digital technology to supplement the role of staffed ticket offices” alongside “roving staff”, but disabled and older people are more likely to experience digital exclusion.
This means disabled and older passengers “may experience additional barriers to planning journeys and buying tickets, such as significant delays when purchasing tickets if staff are occupied elsewhere or if they are travelling outside of staffed hours”.
It warned that any move by train companies towards “digital by default” service provision would not meet the “reasonable needs” of disabled people.
There were more than 680,000 responses to the consultation by the time it closed on Friday (1 September).
The train companies can then refer their proposals to transport secretary Mark Harper if they disagree with the conclusions of the two watchdogs.
Picture: The government office block where EHRC has its London headquarters. Picture by Google
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