Advocating for Universal Design Support from the World Bank
The following suggestions made by a disability NGO to the World Bank about its proposed Urban Transport Strategy are presented here for information and as a progress report on increasing the accessibility of transport systems around the world.
TO: Kenneth Gwilliam, Editor, World Bank Urban Transport Strategy Review, Washington DC
FROM: Thomas Rickert, Access Exchange International, San Francisco
COPIES TO WORLD BANK STAFF: As shown above
SUBJECT: Comments on Urban Transport Strategy Review
This is to communicate comments on behalf of Access Exchange International and to express our concern about the inadequate treatment of the accessibility needs of persons with disabilities in the recommendations of the Bank's draft Urban Transport Strategy Review posted this past Thursday, July 26, on your web page at http://www.worldbank.org/html/fpd/transport/
Our comments comprise
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a brief introduction,
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general comments supporting suggested wording to include in the World Bank's draft Urban Transport Strategy Review, and
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suggested wording to include in the review.
1. INTRODUCTION
Access Exchange International is an NGO founded in 1991 and based in San Francisco, USA, with the mission of promoting accessible transportation for persons with disabilities in the developing world, with special emphasis on the promotion of universal design of public transit vehicles and related infrastructure, as well as on planning and operational features which make public transport readily available to the full spectrum of disabled persons, most of whom are themselves low-income and, typically, marginalized from employment and other life activities due to their lack of mobility.
These comments are in response to a review of the draft document, "Cities on the Move: A World Bank Urban Transport Strategy Review," dated July 26, 2001. While having generally reviewed this document, we have reviewed with special care the Executive Summary, Chapter 3 on Urban Transport and Poverty Reduction, and Chapter 12 on How Can the Bank Contribute?
The suggested wordings in Section 3, below, take into account your indication that the draft will be put in final form this coming week of August 6-10. To accomodate this time frame, the suggested specific wordings have been prepared without benefit of more than brief consultations with colleagues in NGOs directed by persons with disabilities who may have additional concerns or may need to improve and modify these comments. Accordingly, these comments will be shared with some of these colleagues in the hope that they can in turn modify the comments where they fall short. If it appears likely that more time is required to properly incorporate our comments and those of disability agencies, then we suggest that the comment period be extended.
2. GENERAL COMMENTS
On the one hand, it does appear that some of the recommendations of the Bank's strategy review will have a positive impact on passengers with disabilities, including especially the likelihood that improvements in pedestrian infrastructure will help disabled persons to become more mobile. The emphasis on pedestrian and non-motorized travel is thus a plus from our viewpoint if it specifically acknowledges the concerns of persons with disabilities.
Another plus is the Bank's recognition that a new emphasis on safe operations is required, which should strengthen such fundamental practices as enforcement of requirements that transport vehicles pull to the curb at designated stops and remain stopped until disabled persons and seniors are positioned for their ride. However, specific treatment of these issues needs to occur. World Bank staff receiving these comments are referred to our editorial: "Privatization Without Regulation: A recipe for accidents and inaccessibility in developing nations," in our June 2001 Newsletter as well as to documents cited below.
However, the critically important recommendations found in Chapter 12 of this document fail to even mention the actual provision of transportation accessible to persons with disabilities. This is a profound failure on the Bank's part and I am deeply concerned to learn that the Bank's working paper from Finland, "Transport, Poverty and Disability in Developing Countries," has not yet been taken into consideration in the preparation of your recommendations.
Specific examples of our concern follow:
(2.1) In the Executive Summary the concerns of disabled persons -- which affect some 10% (UN data) to 12% (ECMT data) of the population -- are ignored, unless we consider the misleading remark on page xii that "Age and infirmity pose similar problems" (to those of gender), which ignores the fact that age and "infirmity" in fact impose mobility problems which are often quite different from those related to gender issues.
(2.2) Concerning Chapter 3 on Urban Transport and Poverty Reduction, the Bank should discuss the advantages of universal design and fails to do so. In Chapter 3, Paragraph 3.12 does address issues of physical disability and of the elderly. This brief statement is helpful in partially addressing some of the concerns facing this large population but the concepts introduced in this short paragraph are in any event ignored in the key chapter on "How Can the Bank Contribute."
(2.3) Encouragement for even the most elementary concepts of universal design are not found in the final recommendations (Chapter 12) on how the Bank can meet development challenges. This ignores significant global trends.
(2.3.1) At the regional level
The policies and activities of major institutions working at the regional level are not taken into account. The European Conference of Ministers of Transport is publicly and unequivocally committed to universal design of transportation systems as a requirement for financing (from western Europe) for projects in eastern and central Europe. Further, the Interamerican Development Bank has made good progress in this area through publications, roundtables, a seminar at its most recent annual meeting in Santiago, Chile, and already in movement toward practical implementation in, e.g., a transportation project in São Paulo. In addition, UN/ESCAP has made major strides in promoting universal design for transit systems in the Asia-Pacific region.
(2.3.2) At the national level
There is a growing body of legislation strongly supporting accessibility for disabled persons to public transport. Not only is this true of virtually every country in western Europe and North America, it is also true of Argentina, Brazil, Costa Rica, Japan, Australia, and other countries in Asia and Latin America. Projects are moving forward in countries where legislation has heretofor been "on the books" but not implemented. For example, South Africa is monitoring demonstration projects in three cities and agencies there plan to move forward with a national policy. In Mexico, national norms are now being proposed, following up a series of conferences. Singapore has acquired an initial fleet of ramped taxis.
(2.3.3) At the municipal level
We find significant trends toward accessible transportation in Latin American and Asian cities. The subway systems of the largest Latin American cities have already incorporated accessibility features in their newer stations in Buenos Aires, Rio de Janeiro, São Paulo, Mexico City, and Santiago, as well as universal design features making the Quito trolley and Bogotá's "Transmilenio" bus system accessible to persons with disabilities. More than a thousand low floor buses are in operation in Buenos Aires and smaller deployments are found elsewhere. São Paulo has a 100+ vehicle door-to-door system. In Asia, there is major progress in Japanese cities such as Tokyo and Osaka, in Kuala Lumpur (light rail), and Bangkok (Sky Train). Hong Kong has achieved a rail system largely accessible to disabled people along with a major commitment to accessible bus (1,000 low floor units in operation) and door-to-door services. Calcutta is considering access features on a subway extension.
Curitiba is consistently cited as an exemplary city in the Bank's document. However, the fact that what helps make Curitiba exemplary is a spectrum of good operational and universal design practices fails to inform the final recommendations.
None of this is happening in a corner and where is the World Bank? We would have hoped to have found the Bank, if not in a position of leadership, at least in a position of joining other institutions and agencies around the world in integrating its policies into what is clearly a global trend toward universal design.
3. SUGGESTED WORDING to be added to the Urban Transport Strategy Review
(3.1) MODIFY THE EXECUTIVE SUMMARY
These modifications should be considered as minimal, and would have been more ample if we had had more time to consider this document. At a minimum, we suggest the following:
(3.1.1) Non-motorized transport, currently on page ix: Reword paragraphs xv. or xvi. or add a separate paragraph to include the following:
"Pedestrian and non-motorized travel should also address the needs of local travel by wheelchair users and those using other mobility aids such as long canes used by blind persons and wheelchairs, walkers, canes, crutches etc. used by mobility-impaired persons. Pedestrian concerns also should address the need for proper written signage and other design features to address the concerns of those who are deaf, deafened, or hard of hearing."
(3.1.2) Paragraph xxix (current page xii): Reword or add a separate paragraph to include the following:
"A major category of potential passengers is composed of persons with mobility, sensory, or cognitive disabilities who are deprived of mobility due to architectural, operational, or attitudinal barriers which prevent them from using public transportation. Given the correlation between poverty and disability, and between aging and disability, this large group of persons -- often estimated as around 10% of the population -- is mainly low income. Adequate consideration should be given to the principles of universal design of transit vehicles and associated pedestrian infrastructure to maximize the use of public transportation by persons with disabilities."
(3.2) MODIFY CHAPTER 3 ON "URBAN TRANSPORT AND POVERTY REDUCTION"
As currently written, this Chapter fails to provide adequate documentation and background concerning the large proportion of urban low-income populations composed of persons with disabilities, including older persons with disabilities.
(3.2.1) Paragraph 3.12 (current page 28) is the only paragraph in this entire chapter which specifically addresses the needs of disabled persons. It should be amplified to include the issues and practices discussed in the Bank's working paper, "Transport, Poverty and Disability in Developing Countries," prepared by A. Meriläinen and R. Helaakoski of Finland and reviewed with additions by Access Exchange International. This working paper has been coordinated by Tom Hoopengardner of the Bank's Disability Group This document addresses the guiding principles of universal design, traffic safety issues in developing countries, and sectoral and policy issues, as well as technical concerns, public awareness, performance criteria, and financial issues. It concludes with a Bibliography and case studies from India, the Philippines, and Brazil.
The issues raised and treated by this Finnish working paper need to be summarized. Practical steps toward more inexpensive solutions to improve the accessibility of motorized transport need to be highlighted.
(3.2.2) Specifically, Chapter 3 needs to acknowledge that the needs of disabled persons must be fully incorporated into the Bank's otherwise helpful and encouraging treatment of non-motorized transport.
(3.2.3) The Conclusions of this chapter (Section G on current page 38) should include a modified statement that "The importance of walking and other non-motorized transport activities should be recognized both in infrastructure design and in traffic management, INCLUDING THE ADAPTATION OF PEDESTRIAN PATHWAYS TO THE NEEDS OF PERSONS WITH DISABILITIES AND OLDER PERSONS." (Suggested addition in CAPS) Note, in this connection, that the SUSTRAN Network, a leading advocate of non-motorized transport as well as public transport priority, integrates the concerns of persons with disabilities into its excellent guide, "Taking Steps: A Community Action Guide to People-Centred, Equitable and Sustainable Urban Transport." (Go to http://www.malaysiakini.com/sustran or e-mail Paul Barter at sustran@po.jaring.my or Dr. Bambang Susantono at csti@pelangi.or.id. SUSTRAN is only one of the NMT advocates which acknowledges that persons with disabilities are an integral part of the pedestrian/NMT constituency. Interamerican Development Bank publications also acknowledge this linkage and I am accordingly copying Charles Wright of the IDB with a copy of this e-mail.
(3.2.4) I suggest that a separate conclusion to Chapter 3 state that "The importance of incorporating universal design features into public transport modes should be recognized and encouraged, noting that such features benefit all passengers as well as eliminate barriers to mobility for passengers with disabilities."
(3.3) MODIFY THE RECOMMENDATIONS FOUND IN CHAPTER 12 (Meeting the Development Challenge: How Can the Bank Contribute)
Under "Developing the Response Further: The New Strategy," these additions are suggested for current pages 183-185:
(3.3.1) Under "Strengthening the Poverty Focus" (Section 12.11, current page 183)
(3.3.1.1) A statement should be added that "The Bank will emphasize the importance of incorporating universal design features to benefit persons with disabilities, both in public transport modes as well as in associated pedestrian infrastructure."
(3.3.1.2) In the same section, a statement should be added to the recommendation concerning safety that "safety issues relating to the use of public transportation by persons with disabilities should be given special consideration."
(3.4) Under "Private participation in the urban transport sector" (Section 12.13, current page 184) Modify to read "The Bank will only be involved in finance of vehicles where it contributes to a desirable reform, either in the introduction of cleaner technologies, MAJOR UNIVERSAL DESIGN FEATURES, or sustainable competitive supply arrangements." (Suggested addition is in CAPS)
(3.5) Under "Making transport safer" (Section 12.14, current page 185) modify to read "The Bank will require adequate safe provision for pedestrians and non-motorized, INCLUDING PERSONS WITH DISABILITIES, in all new road investment, rehabilitation and traffic management interventions." (Addition is in CAPS) Normally, we would assume that the interests of disabled persons would be automatically addressed under this recommendation, but the lack of recognition of disabled people as part of the larger cohort of pedestrians and NMT users does indicate a need to specifically include this community in this context.
(3.6) Under the sub-section "The Tools for the Job: Instruments, Processes and Procedures," these additions are suggested for current pages 186-189)
(3.6.1) Modify Section 12.20 concerning "high impact lending" to include highly defined demonstration projects to test innovative approaches toward the low-cost provision of accessible infrastructure and transportation for persons with disabilities. This especially makes sense given the Bank's relative lack of familiarity with this area, which, however, is highly developed in many regions (see our discussion under "General Comments," above). The concluding bold faced sentence in Section 12.20: "Transport safety and security has reached the proportion of a global pandemic which should be pressed on all possible occasions" is exactly on target. We do wish to note that it is precisely the global trends toward accessible transportation for disabled passengers which can lead governments and other stakeholders to revisit issues of safety and regulation. For example, driver training in safe operating practices should be specifically acknowledged as an important component of "high impact lending" and should address the preparation of training modules to assist drivers and firms employing drivers to understand safety issues and to adopt safe operating procedures.
(3.6.2) It is encouraging to note the statement under paragraph 12.25 (current page 188) that "It is . . . important that the urban transport/poverty nexus is better understood and that urban transport developments are increasingly linked both to general urban development activities and to other specific social sector developments." But it should be acknowledged that one of the "specific social sector developments" is the demonstrable global trend toward universal design and the inclusion of persons with disabilities as stakeholders whose concerns should be solicited and acknowledged along with the concerns of other stakeholders.
The above suggestions are not meant to be inclusive, but they address deficiencies which we have identified in the Bank's Urban Transport Strategy Review. Our suggestions are intended to amplify and indeed strengthen the many positive recommendations found in this Review.
It is certainly not too late to consider adding these concerns to the draft document at this critical juncture in which the Bank is re-examining its urban transport policies. It goes without saying that we are available to be of any assistance that we can provide.
Sincerely,
Thomas E. Rickert
Executive Director
Access Exchange International
112 San Pablo Avenue
San Francisco, California 94127
telephone (415) 661-6355
fax (415) 661-1543
globalride-sf@att.net
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