Letter to the Scottish Executive - draft amendments to the Blue Badge Scheme

Lynne Duff
Scottish Executive
Enterprise, Transport & Lifelong Learning Department
Aviation, Ports & International Division
Victoria Quay
Edinburgh
EH6 6QQ

12th January 2007

Dear Sir/Madam,

Please accept our apologies for having missed the deadline for the consultation on The Disabled Persons (Badges for Motor Vehicles) (Scotland) (Amendment) Regulations 2006. This was due to staff illness. However, we would like to take this opportunity to put our views and concerns on this issue forward.

The draft amendment regulations introduce a new category of eligibility for people with a temporary mobility impairment which makes it impossible or unreasonably difficult for them to walk and which is likely to last for a period of at least 12 months. This will not make more people with dementia eligible for a Blue Badge because this only covers physical disabilities. We do not believe you have fully taken into account the fact that mobility can be impaired by the behavioural symptoms of dementia.

Dementia is the term given to a progressive decline of mental functions, such as memory and cognition. It can be caused by a range of degenerative neurological disorders, the most common of which is Alzheimer’s disease. People with dementia gradually lose their ability to carry out the activities of daily living. Among the many deficits caused by dementia, those which particularly impact on mobility include disorientation, confusion, lack of judgment, lack of perception of danger, poor reaction speed and perceptual problems.

Navigational skills decline, along with the ability to recognise surroundings, and people are likely to become disoriented, even in familiar places. People with dementia also become vulnerable to danger; for example, from road traffic because their judgment is impaired and they need close supervision to keep them safe. They may have a perception disorder called a ‘visual cliff’ which causes great difficulty negotiating even apparently straightforward terrain, because a change in surface colour may be perceived as a hole or a step, causing anxiety and potential falls. A significant proportion of people with dementia have gait abnormalities or diminished motor control, caused by dementia, which make walking difficult.

In the early stages of dementia, some people can continue to drive. However, beyond the early stages of the illness this becomes impossible and they rely on their carers to drive them. There are many reasons why the carers of people with dementia may need to park near their destination when driving someone with dementia.

• Some people with dementia may need to be dropped off at their destination because they have difficulty in walking or may experience panic, confusion and disorientation when having to walk through a large car park to reach their destination. However, many people with dementia wander, which means that they need constant supervision; thus, being dropped off whilst their carer parks the car is not a viable option. In addition, some people with dementia can become distressed and disorientated if separated from their carer when in unfamiliar surroundings.

• People with dementia are often unaware of the dangers of traffic; thus, are vulnerable as pedestrians in such situations. Being able to park as near to their destination as possible will reduce the amount of traffic they have to negotiate.

• People with dementia generally experience short-term memory loss; thus, being able to park near familiar surroundings and landmarks, such as outside a local shop, would be useful in helping them remember where they are. Additionally, unfamiliar environments can induce anxiety and aggression, which can be extremely difficult for carers to cope with.

• The dimensions of a normal car park space are not big enough to allow a car door to fully open. For many people with dementia this is necessary because they have difficulty remembering how to get in and out of a car and perceptual problems can make stepping out of a car difficult.

In addition to these behavioural symptoms, some people with dementia can have physical limitations that would be helped by being able to park near their destination.

• Some people with dementia have difficulty walking due to gait abnormalities, which are characterised by slowing and ataxia (a loss of the ability to coordinate muscular movement)(1). Thomas et al. (2002)(2) found that 11.8% of 900 people with Alzheimer's disease had severe gait impairment.

• Many people with dementia are frail, which impairs mobility. This can be due to dementia, age or a combination of the two factors (of the 64,000 people with dementia in Scotland, almost 62,500 are over the age of 65(3)).

• Due to diminished motor control or frailty, some people with dementia are prone to falling; having to walk a shorter distance reduces the risk of this.

• Some people with dementia can be incontinent; thus, parking near facilities is vital.

A long term consequence could be that a Blue Badge could allow someone with dementia to be cared for in their own home for longer. Being able to park near their destination could facilitate the carer taking the person with dementia with them on outings, for both practical and leisure purposes, and could increase the number of outings, potentially reducing social isolation. This also assists in the maintenance of the social and budgeting skills of the person with dementia and would reduce the stress that many carers experience when making such journeys.

Alzheimer Scotland is of the position that eligibility for parking concessions should be available to people with dementia on grounds wider than purely physical impairment. At present, issuing Blue Badges to people with dementia is at the local authority’s discretion and there is no right to an appeal if the badge is refused. This route has potential for inconsistent decision making. We are not requesting that everyone with dementia is automatically eligible for a Blue Badge. However, we strongly believe that the eligibility criteria should cover people who require supervision due to personal safety risks when left unattended and to those who require supervision and walking assistance due to behavioural issues or a combination of physical and psychological impairments. We urge you to take this into consideration and to incorporate the needs of people with dementia in this legislation.

Yours faithfully,

Kate Fearnley
Policy Director, Alzheimer Scotland

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1 Waite L M, Broe G A, Grayson D A & Creasey H (2000) Motor function and disability in the dementias. International Journal of Geriatric Psychiatry 15 (10) 897-903

2 Thomas V S, Vandenberg E V & Potter J F (2002) Non-neurological factors are implicated in impairments in gait and mobility amoung patients in a clinical dementia referral population. International Journal of Geriatric Psychiatry 17 (2) 128-133

3 http://www.alzscot.org/pages/statistics.htm