Home-to-School travel policy: VGSN response

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The recent consultation about RBG’s new Home to School Transport policy closes Friday 18 July, and there’s still time to register your views, by visiting:
https://consultations.greenwich.gov.uk/kms/dmart.aspx?PageType=item&DMartId=770&NoIP=1.
We’ve published the response by the Voluntary Group for Special Needs (VGSN) groups in Greenwich to the proposals. If you support these views you can either respond to the the proposals with a web link to this article, or copy and paste into your letter. Please do make your voice heard on this very important issue for our children.

Member Groups of VGSN
Voluntary Group for Special Needs
Greenwich Mencap
Greenwich Parent Voice
Greenwich Down’s Group
DISC Deaf is Special Children
SAFE Social Arts for Education
National Deaf Children’s Society
Royal London Society for the Blind
Greenwich National Autistic Society
Greenwich Association of the Disabled
Greenwich Toy and Leisure Library Association
Dyslexia Association of Bexley, Bromley, Greenwich and Lewisham
SHINE Spina Bifida and Hydrocephalus Information, Networking, Equality

The Members of the VGSN feel the following amendments should be made to the policy:

1. Overall the policy seems to be based on limiting transport as much as possible.

The best practice for both pupils, parents and the RBG is for as many children / young people as possible to be able to travel safely and independently. The policy should ensure that children and young people are supported to learn to travel independently e.g. through travel training ,where safe and appropriate. Where pupils do need home to school transport, this should be provided for them via a clear and straightforward process with the minimum stress to families and as little need of the appeal process as possible. This is explained in the Department for Education draft Home to School Travel and Transport Guidance:

Publication of general arrangements and policies
Local authorities must publish general arrangements and policies in respect of home to school travel and transport for children of compulsory school age. This information should be clear, easy to understand and provide full information on the travel and transport arrangements. It should explain statutory transport provision and that provided on a discretionary basis. It should also set out clearly how parents can hold local authorities to account through their appeals processes. Local authorities should ideally integrate their Sustainable Modes of School Travel strategies into these policy statements, and publish them together.

Sustainable school travel
Section 508A of the Act places a general duty on local authorities to promote the use of sustainable travel and transport. The duty applies to children and young people of compulsory school age and sixth-form age who travel to receive education or training in a local authority’s area. The duty relates to journeys to and from institutions where education or training is delivered.
There are five main elements to the duty which local authorities must undertake:
• an assessment of the travel and transport needs of children, and young people within the authority’s area;
• an audit of the sustainable travel and transport infrastructure within the authority’s area that may be used when travelling to and from, or between schools/institutions;
• a strategy to develop the sustainable travel and transport infrastructure within the authority so that the travel and transport needs of children and young people are better catered for;
• the promotion of sustainable travel and transport modes on the journey to, from, and between schools and other institutions; and
• publication of Sustainable Modes of Travel Strategy.
• The Act defines sustainable modes of travel as those that the local authority considers may improve the physical well-being of those who use them, the environmental well-being of all or part of the local authority’s area, or a combination of the two.

2. The application form for applying for travel assistance both transport and travel training should be attached as an appendix to the policy

3. There should be a link to a phone number or the website for support and advice from a professional within the Royal Borough of Greenwich; this should be accessible for all parents including those with hearing or visual impairments. There should also be information about Independent Parental Special Education Advice (http://www.ipsea.org.uk/ Tel 0800 018 4016)

4. There needs to be a more accessible parent-friendly version of the policy especially for disadvantaged families and families where English is an additional language, Easy Read etc. The parent -friendly version needs to be clear about eligibility criteria stating clearly who is eligible as well as who is not eligible and that following successful appeals the eligibility criteria are amended accordingly to reduce the need for future appeals.

5. RBG should attach as an appendix to the policy the equality impact assessment that demonstrates that the Transport Policy is not disadvantaging disabled pupils.

Bedfordshire County Council v Dixon-Wilkinson [2009] EWCA Civ 678 (09 July 2009), clarified the need for LAs to ensure that their transport arrangements (in that case a taxi for a disabled pupil) did not disadvantage disabled pupils. Lord Aikens said: With regard to “disabled pupils”, the council, as the local education authority, is obliged to take such steps as are reasonable for it to have to take to ensure that, in discharging its section 508B “transport” function, such “disabled pupils” are not placed at a “substantial disadvantage” in comparison with pupils who are not disabled: section 28G(2)(b) of the 1995 Act.
[IPSEA]

6. A review of those who do and do not access travel assistance is needed to establish if those who are eligible receive transport. This needs to be linked to obligations under the Equality Act to ensure that disabled pupils are not unfairly disadvantaged. We would like to see how the duties under the Equality Act are met under this policy.

7. In section 4.1.3 the policy states: RBG will also consider promoting independent travel and travel training.

• The policy needs to provide more information about these schemes and how families can access this support , for example , eligibility criteria and an application form.

• The travel training scheme needs to provide assessments that pupils are safe to travel alone and regular reviews of how pupils are managing. The scheme also needs to be flexible enough to cater for all needs for example:
o Those that need travel training over several months / years
o Those whose needs change and at times need travel training and at other times need home to school transport
o That all pupils eligible for home to school transport are also offered travel training where safe

• One example is the Titan Travel Training Scheme for children in transition from primary to secondary school used by the Royal Borough of Greenwich Autism Outreach Team. An additional best practice example is included in the draft Department for Education draft Home to School Travel and Transport Guidance :

Coventry City Council case study

Impact/savings achieved
As a result of this initiative and tighter control and work to secure efficiencies in the operation of the home to school travel assistance programme the Council made £326k savings in 2011/12. The savings made in 2012/13 equated to £374k which includes the reductions in expenditure on home to school escorts. The total reduction over the 2 years is a 19% fall in expenditure.

Details of the new approach
Successful work has been undertaken to provide independent travel training for secondary aged pupils and the provision of personal transport budgets to the parents of pupils in special schools. This has enabled young people to become more independent and given them valuable skills for life, as well as securing a reduction in spending for the Council.

How was the change made?
Impower Consultancy was commissioned to identify potential efficiencies. Focus groups of parents of pupils with SEN or disabilities were formed to seek views and identify new ways of working. Two key work streams were then established to take forward the provision of Independent Travel Training and Personal Transport Budgets (PTBs).
Two travel trainers now focus their work on school aged pupils, to help them improve their independence skills. This also reduces the number of adults needing training in subsequent years.
The Council also developed a scheme to offer PTBs to parents. The funding was high enough to incentivise parents, while being low enough to deliver savings for the Council. This was piloted in one school initially and then rolled out across all the special schools.

Advice for other LAs implementing the change
Special school headteachers are fully involved in this initiative and they help identify suitable young people to undertake training.
Contacting parents by telephone was resource intensive, but very positive in terms of fully explaining the benefits and options. PTBs are voluntary, tailored and non-prescriptive. The attendance and punctuality of pupils with a PTB is monitored. Beyond this there is no prescription and parents are not asked to account for expenditure.

• The VGSN are more than willing to be involved in the planning of the travel training scheme

• The VGSN would like to see the number of appeals , both successful and unsuccessful published and monitored to ensure that every effort is made to reduce the need for appeals.

• Reliance on the appeals process for getting transport disadvantages those who lack the skills and support to appeal and particularly those with English as an additional language.

8. Section 4.2.2 states that: wherever possible RBG expects parents / carers of children and young people with a SEN statement to make arrangements for their child to attend school in the same way as for parents/ carers of children without a statement, as this is an important factor in developing the child or young person’s independence, social and life skills.

According to legal advice from Maxwell Gillott solicitors this paragraph is misleading , as it suggests that parents should take children with SEN to school if they can. This does not have any legal basis as the legal duty to provide transport for an eligible child (referred to in paragraph 4.2.1) exists irrespective of parents’ means and therefore RBG should provide transport in these situations regardless of whether the parent has the means to take themselves.

9. The heading of section 4 and also the text of section 4.2.2 need to include all pupils with special needs or disability and not just those with statements.

10. Section 5.1.1 states that: travel assistance will only be provided for the beginning and end of the school day or / at the beginning and end of the week / term in the case of boarding schools.

According to legal advice from Maxwell Gillott: while the law does not define how much transport should be provided for children at boarding schools, the provision should be reasonable. In many cases this would be at the beginning and end of a week or term but there needs to be flexibility taking into account the child’s needs.

11. Section 5.1.4 under ‘Transport vehicles’ states that: Each route will be planned on the basis of school start and finish times and the shortest route possible for all children and young people travelling on a particular vehicle.

The policy should reflect the Department for Education draft Home to School Travel and Transport Guidance on suitability of arrangements:

As a general guide, transport arrangements should not require a child to make several changes on public transport resulting in an unreasonably long journey time. Best practice suggests that the maximum each way length of journey for a child of primary school age to be 45 minutes and for secondary school age 75 minutes, but these should be regarded as the maximum. For children with SEN and/or disabilities a shorter journey time is usually more appropriate.

Consideration should also be given to the walking distance required in order to access public transport. The maximum distances will depend on a range of circumstances, including the age of the child, their individual needs and the nature of the routes they are expected to walk to the pick up or set down points and should be combined with the transport time when considering the overall duration of a journey. For arrangements to be suitable, they must also be reasonably safe and stress free, to enable the child to arrive at school in a state that is conducive to study.

The VGSN feel that is particularly important that the journey should be safe and stress free to enable the child to arrive at school in a state that is conducive to study.

12. Regarding section 7, the policy should reflect the Department for Education draft Home to School Travel and Transport Guidance particularly regarding the need for an independent appeals process.

13. Section 8.12 states that where a child or young person’s individual circumstances have changed, which results in either the child or young person no longer being eligible for support or being assessed as not requiring such support the parent / carer will be given a week’s notice before support is ceased.

The VGSN strongly feel that a week’s notice is not sufficient and will cause many families high levels of stress and disruption. The VGSN feel that normally a term’s notice should be given with flexibility for exceptional circumstances particularly when parents need to request flexible working to accommodate the change.

For families where transport is reviewed on a termly basis , stress and anxiety can be very high and where transport is withdrawn travel training should be provided before the transport is withdrawn.

14. Section 8.1.3 states that: RBG expects children and young people to behave appropriately on transport and must ensure health and safety of all passengers and staff is maintained. Any behavioural issues whilst on transport will be dealt with by RBG in conjunction with the child or young person’s school. Transport will be suspended whilst an investigation is undertaken. In such circumstances, it will remain the responsibility of the parent / carer to ensure the child or young person attends school in the interim period.

According to legal advice from Maxwell Gillott this is reasonable, provided reasonable adjustments have been made to take into account the child’s disability. But RBG still has a duty to provide transport and / or education. If this has happened, RBG need to make special arrangements, either in relation to transport or by way of something like home tuition on a temporary basis with a view to the child returning to school as soon as possible.

The VGSN welcome all opportunities to discuss our feedback.

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