Active Travel post-legislative scrutiny

March 2018

1.      I was Public Affairs Manager at RNIB Cymru from January 2015 –December 2017. I am writing to the committee as part of the recent inquiry into the Active Travel Act (Wales) 2013. I am writing in a personal capacity based on my experiences with the Act whilst working at the charity, but my comments should not be taken as a view of RNIB Cymru. I am also unable to share specifics about which local authorities contacted me as I no longer have access to this information.


2.      The Delivery guidance of the Active Travel Act (Wales) 2013 published in May 2014 was later updated and republished in October 2014. In this guidance, point 2.33 stated that “Local authorities should seek to establish a dialogue with organisations representing people with protected characteristics, as part of developing a clear understanding of local needs, circumstances and opportunities.” In this paragraph, RNIB Cymru was quoted as one of those organisations which should be consulted. The full list of organisations listed was: RNIB Cymru, Disability Wales, Guide Dogs Cymru, Diverse Cymru and the local access group. All but one of these groups is a national organisation.


3.      As a result, as many local authorities emailed RNIB Cymru and asked us to review their plans. As there are 22 local authorities in Wales, throughout 2015 my team received a vast number of requests for help and support.


4.      RNIB Cymru being quoted as one of the consultees in the guidance was something I welcomed in principle; however, the reality of this meant that local authorities were able to send out requests for help as a tick-box exercise. Whilst RNIB could provide general guidance on clear streets, local people are the only ones with the knowledge of the routes being proposed and the potential hindrances and opportunities. I replied to each local authority request for information, and put them in touch with their local blind or partially sighted societies and groups. For this I used the Wales Council for the Blind website, which holds this information for all of Wales. When writing back to the local authorities, I asked to hear more about the consultation with those groups once they had been undertaken. I did not hear back from the local authorities about those consultation exercises.


5.      My experience with this Act is similar to local interaction with the Acts such as the Social Services and Wellbeing (Wales) Act 2014, and the Wellbeing of Future Generations (Wales) Act 2015. During 2017, the Wales Vision Strategy Implementation Group invited civil servants from Welsh Government to speak about the Wellbeing of Future Generations (Wales) Act 2015. In this session, the civil servants told us that national charities and bodies such as RNIB Cymru should be in touch with all Public Service Boards to highlight issues in each area, as without our knowledge, those issues might be missed. I questioned these civil servants about this, as my team (made up of 2.25 Full Time Equivalent team members) also needed to engage with each Regional Partnership Boards to ensure that blind and partially sighted people were being included in population needs assessments and each local authority area for the Active Travel Act.


6.      It is therefore of grave concern that the success of all three Acts is beholden to the third sector, which has largely had the same funding issues as local authorities throughout this decade. Often, requests for information are sent to generic email addresses, with short deadlines, and due to workloads of organisations being far more wide-reaching than the work programmes of the Acts mentioned, it is likely that blind and partially sighted people are being forgotten, not consulted or worse off in some areas of Wales.


7.      Within the duties of the Act, local authorities are required to report on whom they have consulted with and that Welsh Ministers are able to turn down the plans based on this consultation if it is not detailed enough. All local authorities have dutifully reported on their plans and routes, but it is unclear from many of the plans online who they have consulted with or where certain comments came from. Welsh Ministers should exercise their powers to ensure that local authorities have consulted with local blind and partially sighted people and not just national disability bodies.



Emma Sands, former Public Affairs Manager, RNIB Cymru

28 March 2018