ISSUES RELATING TO THE TOTAL MOBILITY SCHEME

Introduction

7.1 The current Total Mobility scheme (TM) provides a subsidised taxi service to people with serious mobility constraints by way of taxi vouchers that provide a subsidy (usually 50 percent) on the normal taxi fare and funding assistance for the purchase and installation of wheelchair hoists in taxi vans known as wheelchair accessible taxis (WATs). There were approximately 39,000 TM users in 2002-2003, according to the Total Mobility 2003 survey by Transfund.[53]

7.2 The scheme is provided in all regions, but is usually limited to urban areas subject to a public transport regional rating levy. Regional councils usually operate and manage the scheme, except in Whangarei and Invercargill, where responsibility has been delegated to city councils, and in Marlborough, Nelson and Gisborne, where unitary authorities operate the scheme. Regional councils fund the scheme and are reimbursed by Land Transport NZ for 40 percent of their contribution to taxi fares, and 60 percent of the cost of fitting taxi vans with wheelchair hoists.

7.3 The provision of the scheme is consistent with the Land Transport Management Act 2003, which requires local authorities to consider the needs of transport disadvantaged people when preparing any land transport programme.

7.4 A review of TM has been under way since 2002, when the New Zealand Transport Strategy was released. This Inquiry took place prior to the second phase of the review by the Ministry of Transport, in partnership with Land Transport New Zealand.

7.5 This chapter looks at the issues identified by disabled people, outlines the perspective of transport providers, reports on the views of regional councils and describes some innovative approaches to the implementation of TM and to other community initiatives providing a door-to-door service for disabled people.

7.6 TM attracted both praise and criticism from disabled people in submissions to the Inquiry. The crucial contribution the scheme has made to their mobility was acknowledged by disabled people who appreciated the service and commended TM in their submissions. On the other hand, problems relating to availability, accessibility, affordability and acceptability were identified. Taxi organisations agreed with some of those concerns, and also identified others specific to their operations.

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7.7 In both submissions and subsequent meetings, some regional councils argued that the current funding base of the scheme was unsustainable in the future. They argued that prospects of significantly increased demand from an ageing population, and more equitable needs-based access to the scheme, would impose unacceptable rating burdens.

Issues for disabled people

7.8 A mixture of appreciation, frustration and anger characterised submissions from disabled people relating to TM. Some disabled people consider that it graphically symbolises their lack of access to full participation in society. This is despite the evidence of community goodwill and innovation in the operation of the scheme in different parts of the country, and the obvious commitment of many taxi drivers, who provide a valued and valuable service to clients.

7.9 The issues raised by disabled people cover availability, in particular of wheelchair accessible taxis (WATs) in certain places and at specific times of day; accessibility, given inconsistency of provision and information throughout New Zealand; acceptability, including driver behaviour and safety; and overall affordability.

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7.10 Advocates for disabled people highlighted the lack of integration of TM into transport planning, with the result that it has developed more as a social service than part of core public transport and the accessible journey. While regional councils operate TM advisory committees, often with disabled people’s participation, there appears to be little interaction between these committees and the overall planning and implementation of public transport policy.

Affordability

7.11 A total of 22 submitters made comments about the affordability of TM services from the perspective of disabled passengers. In general, their comments fell into two broad categories. The first was the unaffordability of a system of accessible public transport being based on taxi services and charges, even when a 50 percent subsidy is available in some circumstances. The vulnerability of TM services to taxi fare increases was noted by both funders and users, who had little control over price fluctuations. The second related to the extra costs associated with using TM over and above the taxi fare charge:

“There is also considerable cost associated with using mobility taxis, so even with the subsidies available, disabled people are faced with greater costs than non-disabled people, and are often doubly penalised due to reduced earning capacity or being reliant on welfare benefits – surely another form of discrimination for the disabled.” (Muscular Dystrophy Association of NZ)
“In addition we would identify the problems of extra costs being added onto use of Total Mobility. This has recently arisen in Wellington in terms of charging a “booking fee” of $10.00, and adding on an additional service charge of $2.00 to the user contribution when a TM voucher is used. DPA notes that Total Mobility has been the locus of a variety of additional revenue-generating mechanisms during its life, but notes that the burden of providing that extra revenue seems to devolve largely to the disabled users, who are least in a position to afford it.” (DPA National)

7.12 Proposed solutions to the perceived unaffordability of TM services varied. The main ones were:

7.13 A significant number of the submissions commenting on the unaffordability of TM were from organisations that represented a large number of people, or had consulted widely before making their submission:

“Many disabled people are being confined to their homes, unable to afford to use their taxi vouchers due to high cost even with the discount.” (DPA Dunedin)
“[F]or the person who has a disability/disorder that requires regular monitoring or treatment, the appointments can use up their allocation, leaving nothing for trips to the supermarket or to see friends, etc. The same applies for the person who has to use a maxi taxi at least twice every day if they wish to be gainfully employed or attend a centre of learning. There is also no leeway in this system for the ‘spontaneous’ outings that the able-bodied take for granted.” (Disability Information Service Inc, Dunedin)
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7.14 Submitters commented that the interaction between low income and the high cost of TM services increased the disadvantage many disabled people felt:

“Besides the limited availability and the high cost (relative to public buses) of Total Mobility in the Waikato region, there are many other deficiencies in the provision of the service. For example, the cost is an issue because of the low incomes typical of the disabled population. At 40 percent, disabled people have the highest unemployment rate of any significant minority group in New Zealand. Having to rely on the basic invalid’s benefit of $205.18 per week makes the cost of Total Mobility, at half a taxi fare, very expensive, with the consequence to disabled people of only being able to afford a minimal number of trips.” (NZCCS, Waikato)
“Financial hardship – relying on taxis all the time is costly, especially for those on benefits. To get to and from work for a week, it’s $34 per day without vouchers ($170 per week). My Total Mobility vouchers are meant to last me three months. With going to work, they last me three weeks.” (Donna-Rose MacKay)

7.15 For those in rural and provincial areas, the difficulties of accessing and using TM services are often compounded:

“The voucher system is a big step in the right direction, but in my case, if I used the service to travel from Feilding to Palmerston North (14 km) and return, the cost would be $80, which puts using the service out of all proportion.” (Darwin Vincent)
“Because of the increase in taxi fares I am not able to use taxis when I need them, as I cannot afford them … I am on an Invalid’s Benefit and I work voluntarily two days a week. There is no public transport in Blenheim and I am often unable to get taxis when I need them, as there are only two maxi taxi hoist vehicles in Blenheim … I have to use all my Total Mobility funding just to get me to my voluntary work, and I will be at least three months short of funding this year … My allocation does not even allow me to visit the doctor.” (David Clode)
“Cost is an important factor for anyone relying on public transport. A taxi once in a while or to allow a person to socialise and drink without driving, although expensive, is a safe option. If [some form of] public transport is your only means of transport for every day use the cost mounts up, even if you use the Total Mobility vouchers and have to pay only 50 percent. The average taxi fare in Blenheim is $20 one way – therefore a return trip could cost up to $40 or $20 if using Total Mobility vouchers – a lot of money for a lot of people.” (Nelson-Malborough Amputee Society Inc)

7.16 Use of the TM scheme and/or WATs may incur charges additional to those of an ordinary taxi fare:

“Cost of using a wheelchair accessible taxi is expensive even with the use of Total Mobility vouchers and the extra $4 loading discount (in Dunedin). These taxis, while receiving a loading fee, also have a higher per kilometre rate for wheelchair users compared to when the vans are being used to transport non-disabled passengers.” (DPA Dunedin)
“There are some systemic aspects relating to taxi fares that discriminate against wheelchair users:

7.17 Submitters proposed a number of possible solutions to the issue of the high cost of TM services. The Health and Disability Commissioner suggested that TM subsidies should depend on a person’s level of isolation:

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“One possible solution is to consider allocating needs-based funding for Total Mobility services, depending on the person’s level of isolation … [T]here may be some individuals who remain isolated because of limited finances and who need greater levels of funding. For example, in a situation where a person is unable to use [other forms of] public transport, has no other transport resources available through volunteer organisations or social contacts, and is unable to afford a subsidised taxi fare, needs-based funding would cover the full travel costs for one trip to a doctor each month and one trip to a support service each fortnight.” (Health & Disability Commissioner)

Availability , accessibility and acceptability

7.18 A total of 48 submitters made comments about the availability of TM services. These divided into two broad categories: the availability of TM services generally; and the availability of WATs as part of the overall TM service.

7.19 Submissions concerned with availability of TM services generally commented that:

7.20 About 90 percent of TM hires take place in standard taxi sedans, according to the NZ Taxi Federation. As one submitter said, the issue of wheelchair access and TM is not confined to WATs:

“Many wheelchair users can and do use the ordinary sedan taxis provided the doors are wide enough, there is room to stow the (manual) wheelchair and the driver will stow the wheelchair.” (Alison Riseborough)[54]

7.21 Submissions concerned with the availability of WATs commented on:

7.22 As a taxi-based service, TM is available only where there is a taxi operator – and even then, not in all cases. This leaves many disabled people in rural and provincial areas without access to any form of accessible public transport. If they are also unable to drive a private motor vehicle, they have little independent access to essential services such as health, employment, education, recreation and community contact:

“There are many restrictions on the provision of Total Mobility schemes in the Region. At present such schemes only operate in Hamilton (within the city boundaries only), Taupo and Tokoroa. There is no funding available for regional coverage at present” (Environment Waikato)
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7.23 Even if there is a taxi service available in the locality, TM subsidies do not extend beyond the urban rating boundaries:

“Total Mobility schemes are limited to within the city region – retirement villages and rest homes outside the city boundaries accommodate a significant number of older people – they are not able to use this form of transport, and are therefore reliant on highly variable and inconsistent transport from the facility or family and friends.” (Age Concern, Hamilton)
“Our New Plymouth clients have access to the Ironside disabled transport service, for which they receive a subsidy via the Council’s Total Mobility scheme. There is no such service in Hawera, and the Total Mobility subsidy does not go beyond Hawera. We have a number of clients from Patea, about twenty minutes south of Hawera, who wish to attend the Hawera centre. Their only option is to use a private taxi service, for which we have been offered a reduced rate. It is still well beyond the means of the clients. Advice from MSD/WINZ is that their only option is to utilize their DA allowance, or what is left of it in most cases. In other words these people are out on a limb.” (Taranaki Enterprises Inc.)
“Taxi vouchers cannot be used between towns, e.g. Waitara and New Plymouth – not even for medical visits; yet in larger cities, travel from one part of the city to another is further than from Waitara to New Plymouth. Someone in Auckland or Hamilton, etc, can go off to a social event the other side of town half price, but someone in Waitara has to pay double that to go the shorter distance into the doctor or hospital at New Plymouth.” (Judith Miller)

7.24 With capped budgets, the availability of TM subsidies are limited in a variety of ways, either by the authority running the scheme, or by an agency sub-contracted by the authority to administer the scheme. Restrictions are usually applied to the number of vouchers available; the maximum fare available per trip that will attract a subsidy; the purpose of the trip for which vouchers can be used; and the number of new clients or members. The Blenheim experience mirrors what the Inquiry heard from other parts of the country:

“Blenheim is receiving the maximum amount of Transit New Zealand Funding that is available, but this is no longer meeting the needs of the community. Over the past three years, both CCS and IHC have had problems with their Total Mobility funding and have ended up running large deficits. The system is no longer meeting the needs of their clients.
“Many agencies now give their clients individual restricted budgets that do not meet their needs. Most people’s budgets have been reduced over the past two years, and most agencies now have waiting lists of people wanting to get onto the scheme. There are a high number of elderly people living in Marlborough who need vouchers and have ended up going to agencies such as CCS for help, even though they do not fit the criteria. Some agencies have restricted the use of the vouchers to inside the Blenheim boundary, while other agencies have restricted their number of vouchers and where or when they can be used.” (Blenheim & Districts DPA)
“The system employed by the Regional Council, with emphasis apparently on saving money rather than working with the community to see that the budget is well spent, seems to discourage holders of the taxi vouchers from using the vouchers for social outings.” (Hawke’s Bay Disability Information Trust)

7.25 For those who are reliant on WATs for their only current access to public transport, the restrictions and limitations that apply to TM generally are exacerbated by the limitation on WAT availability:

“Another deficiency of the Total Mobility scheme is that at certain times of the day, wheelchair accessible taxi vans are difficult to get. It is well known to the disabled community that during school pick-up times, from 8:15am to 9: 15am and again in the afternoon from 2: 30 pm till 4:0 0pm, taxi vans with hoists for wheelchair users are very difficult if not impossible to access. Also despite … 24 hour coverage being contracted for by Environment Waikato, the realities of commercial practice mean that the availability of vans with hoists is severely limited after 6pm most nights. Traditionally, there has been limited demand for accessible Total Mobility vans by disabled people in the evening. Now that is changing, with many younger disabled people having more normal social lives, in which evening events are common. Unfortunately, if disabled people call an accessible Total Mobility van after 6pm, they often have a long wait because taxi companies are unwilling to have more than one van on at a time in off-peak hours.” (NZCCS Waikato)

7.26 By and large, WATs are operated by owner-operators, who often depend on Ministry of Education contracts to transport disabled children to and from school as their core income. It is well accepted in the taxi industry that vans used as ordinary taxis are not as popular with the general travelling public as sedan taxis. When not transporting disabled passengers, it can be difficult for WAT operators to supplement their income by taking non-disabled passengers. The New Zealand Taxi Federation noted that vans are often bypassed on taxi stands in favour of sedans:

“While WATs do ply for hire on stands and carry out radio hires, they are subject to consumer resistance. Some people cannot board the vehicles, others prefer a sedan, some do not like to be seen in a ‘Disabled Vehicle’.” (New Zealand Taxi Federation, Wellington Branch)
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7.27 The nature of transporting disabled passengers means that there are often more unchargeable kilometres going to a new job from the end of another job than would normally be the case. As owner operators, WAT drivers are subject to the same restrictions on driving hours as other drivers, as well as the normal requirements for time off, holidays, and reasonable working hours.

Issues for transport providers

7.28 Taxi organisations highlighted the basis for resourcing of the TM scheme as a major concern. Other issues they identified included the variable political will of regional councils, the high capital and running costs of wheelchair accessible taxis, and restrictions inherent in Ministry of Education contracts on WAT availability.

7.29 The New Zealand Taxi Federation echoed the views of a number of submitters, that national coordination and consistency of the TM scheme was lacking:

“Sadly, many … regions in our view have a minimalist and lip service approach to the provision of funding; in some cases the approach is particularly hard-nosed, with poor budgetary allocations, severely restricted use criteria, and low levels of subsidy.
“It is our opinion that there should be nationally uniform use conditions and subsidy levels, with disabled people being entitled as of right to the same conditions wherever they happen to live or travel to.” (New Zealand Taxi Federation)

7.30 WAT unavailability, particularly in the mornings and afternoons when school runs operated, is a major obstacle to wheelchair users’ travel. Taxi operators acknowledged the problem, but forcefully rejected “unfair” criticism of the taxi industry:

“During school terms WATs are always engaged on school runs for special needs school children, in fact if it wasn’t for the income earned from these runs, the WATs would not be economically viable and no service would exist.
“The situation is worse in smaller centres and rural communities where there is even less capacity spread over larger areas. The only way to rectify the situation and generate extra capacity is to have a very high level of subsidy; we think this should be seriously considered, particularly in smaller rural areas.” (New Zealand Taxi Federation)
“The economics of providing wheelchair accessible services are dependent upon the use of the service by schools providing education to children with disabilities, and institutions catering for the elderly. Without them the service would not be viable. It follows that at some times of the day services will be stretched.” (New Zealand Taxi Federation, Wellington Branch)

7.31 Another major concern of taxi operators was the cost associated with fitting out and running WATs. The New Zealand Taxi Federation contended that WAT fleets were overdue for replacement, and that the situation was deteriorating “because of restricted funds for fit out and conversions, or incomes that are insufficient to support the purchase of replacement vehicles”:

“[I]t must be remembered that taxi operators are self-employed people who provide a transport service in order to feed, house and clothe their families; none are rich. It follows that the service they provide has to be economically viable if it is to be sustained.” (New Zealand Taxi Federation, Wellington Branch)

7.32 At the request of the Commission, the New Zealand Taxi Federation updated an early survey of the condition of all WATs in New Zealand. Replies were received from 123 out of a possible 140 members with WATs. The Federation reported that “despite a recent push to upgrade and a temporarily boosted Transfund subsidy (last two years), the average vehicle age is 8.5 years and the average kilometres travelled per vehicle is 230 [thousand] km. There are still many vehicles in the 12 to 20 year age bracket, with between 400 and 800 [thousand] kms on the clock.”

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7.33 In a letter to the Inquiry, Executive Director Tim Reddish identified two reasons for the ageing fleet. The first related to the extent of regional council support, the second to fares being too low to fund replacement.[55] The Wellington branch of the Federation commended the Greater Wellington Regional Council for an approach which it said should apply nationally:

“At the inception of the TM system, the Taxi Federation undertook to provide the service at normal taxi fares if the installation of wheelchair hoists was subsidised. This agreement has been honoured by us, but until recently some regions have had difficulty in obtaining the required level of support from Councils. However, we have been fortunate in the Wellington region, where the Council has agreed to a planned approach to vehicle replacement.
“It is our contention that vehicle replacement and expansion has to be programmed if a safe and reliable service is to be maintained. We further contend that the financing of hoist purchase and installation should be done nationally so that we have consistency across the country.” (New Zealand Taxi Federation, Wellington Branch)

7.34 Bus operators also had comments about TM:

“[B]ecause of the restrictions on the [Total Mobility] coupons that are issued to eligible users, there is an inevitable push for more access to the main public transport option, buses. I believe that in this case then, there is a case for bus operators to be seen as being part of the Total Mobility scheme and therefore should be able to get some compensation to reward the extra time, effort and inconvenience involved in the carriage of wheelchairs in particular.” (Citibus Newton)

7.35 Citibus Newton also argued, however, that buses should not be expected to cater fully for passengers with significant mobility impairments, and that TM was the most appropriate option for those passengers, despite the higher cost:

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“While this may not be at the same price, I don’t believe that this should be an impediment to this scheme being used more extensively than it is at present.” (Citibus Newton)

Regional councils

7.36 Regional councils echoed some of the concerns held by disabled people and providers about the inconsistency of TM, as well as the importance of effective training and adherence to safety and service standards. Environment Waikato’s submission made recommendations on all these areas:

“Total Mobility schemes need to be uniform throughout the country. There would be advantages in having the scheme portable, so that a patron of a service in a particular area is able to travel to other areas and still use Total Mobility vouchers.
“In order for a taxi company to meet a service level agreement for Total Mobility, a certain level of training for its staff should be included. That training programme should be mandatory and enforceable. Consideration of including mandatory training for owner drivers needs to be considered by licensing authorities. This could be tied into OSH requirements. Emphasis on a positive attitude should be made and also that many people with disabilities require extra time and care. Training needs to cover hoist operation and the needs of the passenger.” (Environment Waikato)

7.37 While conceding the inadequacy of the present situation, an overriding concern for regional councils was the impact of the funding burden on ratepayers. Regional councils submitted that fare caps, geographical boundaries and other restrictions, which were criticised by a number of submitters to the Inquiry, have been necessary to prevent the costs of the scheme spiralling beyond their capacity to fund.

7.38 While acknowledging the validity of the need to ensure that TM is known and available to all those who are eligible for the service, regional councils have been reluctant to promote or advertise the scheme, given that increased patronage would place even greater pressure on the limited funding available, and would inevitably require rates increases.

7.39 The Inquiry was told of the strong perception, within councils and in communities, that TM is a social service that should be funded by central government, rather than at a regional level. It was asserted that TM in fact amounts to a form of indirect income supplement for its consumers – and that this is, more properly, a central government role. Regional councils strongly argued the point that a greater level of central government funding of TM would be pivotal to any efforts to improve the scheme.

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7.40 As for the steps that regional councils could take, there was a level of consensus that improving the overall accessibility (including availability, affordability, and acceptability) of other forms of public transport could reduce the demands on TM.

Innovation

7.41 Submissions to the Inquiry showed a number of innovative responses to implementing TM, or to supplementing a subsidised door-to-door service with other community responses.

7.42 For example, Southland Enterprises Inc (SEI) reported on “the success we have had in Invercargill when we worked in partnership with the Invercargill Passenger Transport and our consumers to provide an alternative to using the Total Mobility taxis for people travelling to and from our vocational centre”. Whereas TM was becoming increasingly difficult for SEI workers to access or afford, the introduction of a special bus service for workers had an array of benefits. There has been a boost to self-esteem and confidence, especially among those workers who had never travelled on public transport by themselves before. The financial benefits have also flowed on to the other TM users, because their agencies now have a greater share of the budget from the SEI savings.

7.43 In Invercargill, consumers and administrators of the TM scheme adapted and improved what had been an allocation system that was not efficient or cost effective, and was seen as being “neither fair nor empowering to users”:

“Three consultation workshops were held to find a solution to how best manage the capped budget in a way that was fair and equitable …The result is that the TMS is an allocation system determined by TMS users. Agencies and Rest Homes have appointed staff to verify new user allocation requests …Tickets are issued directly to the TMS user. Initially this was broken into short period allocations but now into the second year, data collected has enabled longer periods of allocation. Tickets are not able to be carried forward and all unused tickets are returned. This also helps the TMS user gain a true awareness of how often they are required. … [Invercargill City Council] has employed one person for 20 hours to administer the scheme, noting that this cost does not come from the TMS budget.” (DPA, Southland)

7.44 The inclusive process by which these improvements were made, and the proactive and collaborative approach taken, have meant that not only does the allocation service better meet the actual needs of users, but a sense of ownership of and enthusiasm for the project was readily apparent.

Conclusions

7.45 There was one constant theme across the range of submissions to the Inquiry on TM, and that was that the scheme had to change if it was to become available, accessible, affordable and acceptable. Disabled people want changes to improve equity of access, affordability, safety, portability and consistency. Taxi organisations want changes to funding to provide a higher level of subsidy for these vehicles; they want to move from a regionally based to a nationally consistent framework; and they want greater support for both the capital and the running costs of wheelchair accessible taxis, which they say are only marginally economic. Bus companies want the TM scheme integrated into public transport on competitive terms. Regional councils want a central government solution to the long-term sustainability of the TM scheme.

7.46 Despite a diversity of perspectives from users, providers and funders about the current provision of TM, there is a degree of common thinking about how the scheme can be reformed to improve access and mobility for disabled people.

7.47 As this report was finalised the Government announced a $9.49 million funding increase for the TM scheme increasing the total budget to $18.67 million. The new money will allow for improved services and a 60 percent increase in the number of users from 43,000 to 69,000 over the next three years. The Government’s share of funding will be boosted from 40 to 50 percent in the current year and to 60 percent in subsequent years provided local authorities do not reduce their contributions. The timing of the announcement as this report went to press means the impact of the funding announcement on the accessible journey could not be fully assessed.

7.48 The Total Mobility Scheme Review (the Review) report that followed the funding announcement in September 2005 makes a number of recommendations that are likely to have some effect on the recommendations made as a result of this Inquiry. The Review is organised around six key themes: the scheme purpose; eligibility; entitlement; assessment services; administration and issues for transport operators. However, the Review has not looked at some issues that were highlighted during the Inquiry such as the affordability of the scheme for passengers and appropriate training for drivers.

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7.49 In the limited time available to assess the recommendations from the Total Mobility Scheme Review this Inquiry endorses the following:

“The Total Mobility Scheme is to assist eligible people with impairments to access appropriate transport to enhance their community participation. This assistance is provided in the form of subsidised door-to-door transport services wherever Scheme transport providers operate”.

7.50 The Inquiry believes that the application of the definition of disability in the Human Rights Act 1993 to the TM scheme needs to be addressed. The definition of disability in the Human Rights Act is comprehensive, covering physical and sensory disabilities, people with experience of mental illness, people with anxiety disorders and people with intellectual disability. Submissions to the Inquiry suggest that some people with experience of mental illness and some people with intellectual disability are missing out on the benefits of the TM scheme in some areas. Not adopting the definition of disability in the Human Rights Act means this practice could continue. Adopting the definition will make it explicit who is eligible for the scheme. Failure to incorporate the definition could result in some disabled people being excluded from the scheme. Such exclusion could constitute unlawful discrimination. People, who meet the eligibility criteria, incorporating the Human Rights Act definition of disability, should not be expected to have to meet the further requirement that their impairment last or be expected to last for six months or more. The Human Rights Act makes no mention of a time qualification in relation to discrimination on the basis of disability.

7.51 The Inquiry believes there is a need for further consideration of the following issues: that the local authority determines the maximum subsidised fares for TM in negotiation with Land Transport New Zealand; and that the number of allocated subsidised trips be limited. While recognising that the TM scheme must operate within a budget the Inquiry is concerned about the possibility of limitations on disabled subsidised public transport users that are not placed on non-disabled subsidised public transport users. Further discussion is sought on these recommendations to ensure that the opportunities for inclusion for passengers who are dependent on TM for independent travel are not unduly restricted.

7.52 The Total Mobility Scheme Review and those aspects of the Accessible Public Land Transport Inquiry report dealing with TM have similar concerns, and highlight common issues, suggesting that a joint consideration of their content and recommendations would be useful. Further, the Total Mobility Scheme Review recognises the need to “ develop a wider public transport policy framework for improving access and mobility for all New Zealanders.” The recommendations of the Inquiry into Accessible Public Land Transport report provide this policy framework for disabled people and for all New Zealanders.