Weekly Poll – Low Emission Zones Exemptions
Each week Disability Equality Scotland send out a poll question to our members on a topical issue. For the week beginning 30 August 2021, we asked a question about Low Emission Zone exemptions for Blue Badge holders. A Low Emission Zone is an area where only certain vehicles are allowed to enter, based on their emissions standards. Low Emission Zones are being introduced in Scotland’s four largest cities: Glasgow, Edinburgh, Aberdeen and Dundee, to help improve air quality and people’s health. As part of the Transport (Scotland) Act 2019 a number of national exemptions have been granted. This includes an exemption for Blue Badge holders whose vehicles are non-compliant.
Question 1. Do you think there needs to be a range of different options in place to allow Blue Badge holders to apply for a Low Emission Zone exemption?
- YES – 96% (90 respondents)
- NO – 4% (4 respondents)
Question 2. Please select all the formats that would suit your needs:
- Call Centre – 55% (52 respondents)
- Mobile App – 64% (60 respondents)
- Paper Copy – 63% (59 respondents)
- Text based SMS service – 61% (57 respondents)
- Website 81% (76 respondents)
- Other – 18% (17 respondents)
Of the 17 respondents who answered ‘Other’, 8 respondents suggested having a face-to-face option, which could be provided at a local council office. The were 5 respondents who indicated that the exemption could be identified through their existing Blue Badge. The remaining 4 respondents highlighted the need for having a range of accessible formats available on request, such as Easy Read and the ability to apply via email.
We provide verbatim comments where appropriate to illustrate strength of feeling or personal experience.
There was overwhelming consensus from respondents (96%) to ensure the application process for Low Emission Zone exemptions is available to Blue Badge holders in a variety of accessible formats. To achieve this, it is important to incorporate the principles of inclusive communication. This means ensuring the application is available to Blue Badge holders in a format that matches their communication strengths and preferences. The Equality Act 2010 requires service-providers to make reasonable changes to the way services are delivered. This includes a duty to provide information in an accessible format. At Disability Equality Scotland, we work in partnership with Sense Scotland to host the Inclusive Communication Hub: www.inclusivecommunication.scot, a website dedicated to inclusive communication guidance and resources.
“I think that there needs to be a wide range of different formats to suit the needs and abilities of disabled people to apply for Low Emissions Zone exemptions. While contacting a call centre might be fine for one person, it would not be suitable for someone who has a hearing impairment.”
“All means of communication must be open to Blue Badge holders.”
“All formats should be available to make it as accessible for everyone as possible. There’s no point only allowing certain ways to apply when it won’t fit everyone’s needs.”
A website for completing an exemption application was the format that was selected by the greatest number of respondents (81%). When developing a website, it is vital that it meets the Web Content Accessibility Guidelines (WCAG) 2.1 and is compatible with a range of devices and assistive technologies.
There was recognition of Blue Badge holders who are digitally excluded because they may lack digital skills or confidence to get online. Some people may have limited resources and money to pay for internet access or they are unable to use technology for other reasons, such as physical disabilities or cognitive impairment.
“Applying for an exemption needs to be available for all, not everyone is tech savvy. It needs to be accessible for all ages and disability requirements. Blind, deaf, and many other ways that would limit someone’s ability to apply for an exemption.”
“Not everyone is capable of digital registration, nor do they have family or friends to do it for them.”
“We are not all internet savvy, glued to a mobile full of apps. Different options are definitely needed.”
“Not all disabled people are able to use computers and I think there should be consideration of this. It doesn’t affect me personally, but I know others who would have issues.”
“I am able to access the internet at the moment but that’s not always been the case.”
When producing paper copies, a format that was selected by 63% of respondents, it is important that accessible information guidelines are followed to help reach as many people as possible. For example, it is beneficial to write in plain English with short and concise sentences of 25 words or less. Further guidance on how to produce accessible information can be found on the Disability Information Scotland website: www.disabilityscot.org.uk/making-information-accessible
It is also important to ensure that the paper copy of the application is available in several alternative information formats, such as audio, British Sign Language (BSL), Easy Read, large print, and plain text. At Disability Equality Scotland, we have a service to convert information into Easy Read, a format that is accessible for people with a learning disability. More information about our Easy Read service can be found on our website: www.easyread.scot
“As I am a registered Blue Badge holder and speaking for me and many likeminded people that don’t use a mobile phone, I would rather have a letter from Transport Scotland detailing the exemptions on low emissions.”
“I work on the helpline at Disability Information Scotland, and we take calls from people across Scotland who are having increasing difficulty getting Blue Badges renewed if they are either not able to access or use the online system. Some councils have been refusing paper copies of forms and this is a massive barrier for some.”
“If paper copies are available then we need Easy Read, large text, Braille etc.”
There were 52 respondents (55%), who selected call centre as a format that would suit their needs. This method may be suitable for people who are unable to complete an online application. However, a portion of respondents highlighted some of the factors to consider when implementing a helpline.
“Many disabled people have difficulty using phones and cannot press loads of numbers on a telephone keypad in order to get through to a human being. Their needs must be considered. Some organisations allow you to phone and say ‘assistance’ in order to get straight through to someone to whom they can talk.”
“It’s a nightmare getting understood over the phone.”
“The call centre option whilst it seems to be good could have unforeseen problems. 1. Will it be a freephone number? 2. Who would be operating the centre? 3. How much money would be spent on running this?”
Face to Face
Respondents had the opportunity to state a format that was not featured in the list of different options in question 2. In response, 8 of the 17 respondents suggested allowing Blue Badge holders to apply in person. One respondent stated why it would be important to have a face-to-face option available to people who would like assistance in completing the Low Emission Zone exemption form.
“As Blue Badge holders are all of different ages and of disabilities, there needs to be different ways to allow them to contact the transport office. I also feel that there should be a, room or small office, somewhere where people can actually go and register, as too often, an office is too far away from their home point. I fully understand that at this moment, it is only the 4 cities, but when it is rolled out everywhere, people should still be able to have someone, face to face to talk to about it.”
Integration with Blue Badge Scheme
There were general comments from respondents about the application process and how this could be streamlined with the existing Blue Badge scheme. Some respondents suggested that all existing Blue Badge holders should be automatically exempt from a Low Emission Zone, which would reduce the need to add another layer to the application process.
“Great, more forms! What will this cost? Again, we must carry the weight of all changes. Really rather fed up with oodles of more paperwork and endless red tape.”
“Why do we need to fill in more forms? Make it automatic. Those who don’t need an exemption won’t matter. Those who do will have even more stress added to their lives. Please show some sense and some kindness. Life’s hard enough.”
“The exemption should be incorporated into the Blue Badge with some sort of diagram on the badge that lets you get in and around without being a letter.”
“This seems to be yet another layer of bureaucracy. Surely being able to show a valid Blue Badge should be sufficient.”
“All Blue Badge holders should be exempt, and the badge used as identification rather than an additional option.”
“Why do we need to have yet another application system which will also have to be updated with car changes. Will it be a “free service” or just waiting for a charging system? I have not driven into any such city/zone in years but would feel the need to apply “just in case” such as for as a family hospital appointment. Why not simply make it part of the Blue Badge system?”
Some respondents stressed the need for clarification with regards to how the exemption will be applied to Blue Badge holders who will be using more than one vehicle.
“It needs to be extremely easy to change the vehicle registered and the time it is registered for because the Badge is issued to the person and the person may use the vehicles of many different friends and carers.”
“I hope this could be used in different cars because as you know Blue Badge holders may use alternate transport due to their disability i.e., visual impairment.”
“What about people with Blue Badges who are non-drivers and as a result might use a number of different vehicles?”
“Badge holder may travel in different cars so will this mean registering each time they/we are in a different car?”
One respondent questioned how the exemption would be implemented for people who use motorbikes.
“This also begs the question about disabled motorbike, motor trikes and the like, as currently these people are being discriminated against as you cannot reasonably attach a Blue Badge to those types of vehicles. But a method of registering the vehicles details on a central database would save money and hassle by those members of the public as it will be searchable for details even if it’s not for zone exemption.”
An overwhelming majority of respondents believed that the Low Emission Zone exemption application for Blue Badge holders must be available in a variety of accessible formats. This will ensure that applications embed inclusive communication principles and are available in a format that matches the communication strengths and preferences of each individual. There was recognition that not all Blue Badge holders will be able to access an online application, due to factors related to digital exclusion. This includes lacking digital skills or confidence to get online, as well as limited resources and money to pay for devices or internet access. Respondents highlighted the importance of having a paper version of the application, which is also available in a variety of different accessible information formats, such as Braille, Easy Read, large text and plain text. A call centre was identified as another alternative for people who face digital exclusion, as well as the ability to complete a face-to-face application. A number of respondents believed that Low Emission Zone exemptions must align very closely with the existing Blue Badge application process.