Introduction

Total Mobility is an indispensable enabler of independent living for New Zealanders who are blind, deafblind, or low vision. Blind Low Vision NZ (BLVNZ) is extremely concerned that the proposals to “strengthen” the scheme will weaken it for those who need it the most.
The proposals to “strengthen” the scheme will only reduce fiscal liability on the New Zealand Government whilst further weakening the poorer outcomes experienced by New Zealanders who are blind, deafblind or low vision. BLVNZ’s Integrated Data Infrastructure (IDI) research Shining a Light on Blindness revealed that people who are blind or visually impaired are behind the average Kiwi in every outcome measured.
BLVNZ’s position is that the proposals weaken the scheme because the savings from the subsidy reduction are being shifted to fund public transport. This is when the scheme’s purpose is to provide transport options for people who cannot use public transport some or all of the time. The logic behind the changes to the scheme and the proposals are inconsistent.

Furthermore, our position is that trip caps will limit the ability of people who are blind or low vision to go about their daily lives, and further reduce community participation and their sense of dignity and independence.

The Total Mobility scheme makes the New Zealand transport system accessible to people who are blind or low vision. Our transport system is largely built around the road network and motor vehicle travel. Being blind, deafblind, or low vision means you are unable to drive so you are unable to access the country’s primary way of independently getting around. The Total Mobility scheme makes independent private vehicle travel a possibility through taxi services.

Taxis provide point-to-point transport for people who are blind or low vision that enables their independence. Drivers often provide assistance by helping their passengers find the entrance and reception of their destination. This is important as many public buildings in New Zealand lack an accessible route between their main entrance and the pedestrian network.

Many people who are blind or low vision use a mix of public transport and Total Mobility as only part of their journey may be accessible to them. Any future changes to the Total Mobility scheme should not remove flexibility and independence. The flexibility of being able to use the accessible public transport subsidy and the Total Mobility scheme ultimately reduces the cost of the Total Mobility scheme. It allows people who are blind or low vision to use the public transport journey where it is accessible and point-to-point travel through the Total Mobility scheme where it is not.

Both reducing the subsidy, and limiting the amount of trips blind, deafblind, and low vision people can take will further disadvantage people who have a material impairment that limits their participation in a society that was not built with them in mind. In New Zealand, accessibility is an afterthought, but mostly, accessibility is not thought about at all.

About Blind Low Vision NZ

Blind Low Vision NZ is the operating name of the Royal New Zealand Foundation of the Blind. Our organisation was founded in 1890 and has been serving New Zealanders who are blind, deafblind or low vision for over 135 years. We are motivated as a ‘for purpose’ organisation guided by our mission, values, and strategic plan.

Blind Low Vision NZ exists to empower our approximately 16,000 clients who are blind, deafblind, or low vision to live the life they choose. We estimate that 193,000 New Zealanders live with vision loss [1,2], and expect that number to grow to 225,000 by 2028 [3]. Some common eye conditions include Age-related Macular Degeneration, Diabetic Retinopathy, Glaucoma and Cataracts.

Blind Low Vision NZ is New Zealand’s leading provider of vision rehabilitation services. The services we provide are as follows:

• Orientation and Mobility Services
• Community and Support
• Guide Dog Services
• Library Services
• Accessible Formats Service
• Daily Living Skills
• Adaptive Technology
• Vision Store
• Sport and Leisure
• Emotional Support
• Employment and Youth Transition
• Deafblind Services
• Children’s Services
• Support Grants

These services ensure that everyone in our community has the support they need to thrive.

About the People we Serve

In 2025, BLVNZ commissioned Shining a Light on Blindness[4], a piece of IDI research to identify and describe some of the challenges faced by people with visual impairment in their everyday lives. The indicators chosen to assess outcomes for people cover a broad scope and identify areas where people with visual impairment could be disadvantaged compared to those with no visual impairment.[5]

People with severe visual impairment is the term chosen to define those identified in the IDI data as receiving support and services related to their vision or have a hospital diagnosis of blindness or severe visual impairment. People with other visual impairment includes those who have self-reported seeing difficulties.

Almost 2.2% of the population has some kind of visual impairment

The rate of vision loss identified in IDI data is 0.16% for severe visual impairment and 2.0% for other visual impairment.

The disability rate for visual impairment increases for older people and can lead to shortened lives

The median age for people with severe visual impairment is 57 and for people with other visual impairment, 58. This is compared to 38, the median age for the general population with no visual impairment.

People can and do live for many years with visual impairment. The median age at death for people with severe visual impairment is 71 years, nine years lower than that for people with no visual impairment. Whilst some people are born with blindness and visual impairment that will last a lifetime, others acquire a visual impairment through disease, injury or ageing. The median age for onset of visual impairment is 44 years for people with severe visual impairment and 54 years for people with other visual impairment.

A study of the working age population with visual impairment

To provide balance to the population studied in this research, the outcomes for the cohort of 15 to 64-year-olds have been analysed. In 2023, there were over 4,600 people aged 15 to 64 living with severe visual impairment and over 57,800 living with other visual impairment.

Demographic information, along with socio-economic indicators are described for this working age population. Where comparisons are made for the severe and other visual impairment populations, to those with no visual impairment, the data is often presented for the calendar year 2023 or a trend for five years from 2019 to 2023.

People with blindness and visual impairment live in areas of the highest socio-economic deprivation and face multiple challenges with inequity in housing

Over half of the percentage of people with severe visual impairments and 45% of those with other visual impairments, live in areas with the most socio-economic deprivation. Compared to 29% of those with no visual impairments.

People with severe visual impairments are half as likely to own their own home compared to those with no visual impairments. They are also seven times more likely to live in social housing than someone with no visual impairment and are at least three times more likely to live in emergency housing than those with no visual impairment.

People with blindness and visual impairment use health services differently

People with severe visual impairments are over four times more likely to have two or more hospitalisation events per year, compared to someone with no visual impairments. People with visual impairments access secondary mental health services at a greater rate than those with no visual impairments. For those with severe visual impairments the rate is 2.5 times higher, and for those with other visual impairments the rate is almost double.

People with blindness and visual impairment are more likely to have a diagnosis of diabetes or live with other disabilities than someone with no visual impairment

Whilst it is difficult to determine from administrative data whether a person was born with visual impairment, it is possible to determine whether they are living with multiple functional disabilities or have other medical conditions.

Over 25% of people with severe visual impairment and over 10% of people with other visual impairment had a diagnosis of diabetes and were dispensed hypoglycaemic medication or attended diabetic outpatient clinics.

Having visual impairment increases the likelihood of other self-reported difficulties, with those with a severe visual impairment being 16 times more likely to report difficulties with communication, 17 times more likely to report difficulties with mobility and 25 times more likely to report difficulties with self-care than those with no visual impairment.

People with blindness and visual impairment face disadvantage in gaining any qualifications and progressing further through the education system

People with severe visual impairments are four times more likely to have no qualifications than people with no visual impairment, and 2.5 times less likely to have a bachelor’s degree or above than those with no visual impairment.

People with blindness and visual impairment face disadvantage through finding employment, low income, and benefit dependence

As well as a higher rate of disadvantage in education there is also a higher rate of disadvantage in areas of employment, income, and benefit dependence.

Only 25% of people with severe visual impairment are employed in a position that is registered and recorded by the Inland Revenue Department; the gap in this employment rate between those with severe visual impairment and no visual impairment is widening. People with severe visual impairment are over five times as likely, and those with other visual impairment are over twice as likely, to receive a tier one MSD benefit compared to those with no visual impairment.

The individual calendar year gross income for 86% of people with severe visual impairment is $60,000 or under, compared to 59% of those with other visual impairments, and 49% of those with no visual impairments.

This research finds that the working age population in New Zealand who live with blindness and visual impairment experience deficits across all socio-economic outcomes.

Barriers to Public Transport Access for People who are Blind, Deafblind or Low Vision

This section outlines some of the barriers people who are blind, deafblind, or low vision face to access public transport. The public transport journey is still largely inaccessible to blind and low vision users where it exists.

Requirement to Signal: Many public transport providers require passengers to signal or hail a bus to indicate they want to board. However, if you are unable to see a bus you cannot signal it to stop. Some regions manage this better, providing guidance to drivers to stop for people who are standing or seated at the stop on a single bus route, or stopping for people who use a white cane or assistance dog. However, this is regularly ignored by the driver and leads to distressing situations when a bus is missed as they can be on an irregular route, miss a connection, or an important appointment.

Driver training: Many drivers show little awareness of the needs of people who are blind or low vision. There is a need for nationally consistent training programmes with content approved by relevant organisations about accessibility knowledge. This should be ongoing training and not only at the beginning of a driver’s career.

Bad experiences: When a person has had a bad experience, they may not be comfortable with using a bus again regardless of any action taken by the transport authority to address the issue or any orientation and mobility support they may receive.

Route planning: People who are blind or low vision need to wait for input from Service Providers to receive training for independent travel training including route planning, orientation to environments and mobility training to familiarise themselves with their public transport route.

Footpath to building entrance: New Zealand’s built environment lacks dedicated pedestrian access from the footpath to the main entrance to many of its public buildings. There is no provision in the building code (e.g. NZS 4121) to provide a pedestrian access route or continuous accessible path of travel from the foot path to the main entrance. Pedestrians are required to walk through vehicle entrances and walk over gardens or lawns. This situation renders private vehicles or taxis the only accessible way that people who are blind or low vision can access the main entrance of their destination.

Uncontrolled road crossings: During the trip uncontrolled road crossings that cannot be achieved safely and independently are a barrier to public transport. This may mean one direction of travel is undertaken by bus and the other by taxi or both directions by taxi.

Distance to Bus Stops: Bus stops can be a distance from the person’s residence or destination that they are physically unable to travel.

Busy and complex environments: Complex or changing environments where hazards on the footpath are difficult to navigate to and from bus stops. Busy footpaths can lead to bumping into people or canes being stepped on and broken. Areas of building work can mean items are blocking the pathway and/or access to pedestrian priority crossings, and no means are in place to assist a pedestrian to navigate the changed path. Alternative temporary routes may exclude pedestrian priority to cross roads. These works can be scheduled for long periods and the environments may change daily.

Temporary Bus Stops: Changing the position of the bus stops to a temporary location for the start or end of the journey. For some people getting off a bus at a location away from their regular stop can be disorienting if they are not familiar with that location.

Safety: Perceived/or real feelings of being unsafe at bus stops – particularly early in the morning or later in the evening.

Public Perception: Perceived/or real perception of being seen as a vulnerable person. Embarrassment at manoeuvring a mobility device on and off the bus – time taken and narrow spaces to move through to the accessible space/priority seating.

Multiple bus routes: Determining the correct bus approaching and not missing a bus that passes when the first bus stops.

Multiple platforms: Where the drivers can pull in behind another bus, then leave without going to the head of the stop to check for passengers who have a vision impairment and are unable to see the arrival of the bus and navigate the footpath to get to the correct bus.

Boarding: Bus drivers not consistently pulling into the kerb to reduce the stepping distance.

Head of Stop: Bus drivers not pulling up at the directional tactile ground surface indicators at head of stop, requiring the person with a vision impairment to hear the bus arrive and then locate the door.

Bus kneeling: Bus drivers not kneeling buses even on request.

Ramps: Bus drivers not pulling out the ramp for wheelchairs or walking frames for those struggling with the steps.

Knowledge of Stops: Bus drivers lacking knowledge of their routes when requested to advise when a specific stop is reached.

Driver communication: Communication with drivers when English is not the primary language for either the customer or the driver.

Priority seating: People sit in the priority area on the bus who do not need it and are not asked to move by drivers or do not move without being asked. This can mean a person who is blind or low vision needing to stand or to navigate steps to be seated.

Locating a Seat: Being unable to locate a vacant seat without assistance.

Guide dog teams being refused and harassed:

Guide dog teams are regularly harassed by other users without the driver intervening. Security staff are not always around or able to be identified for assistance. Many drivers have no awareness that assistance dogs are allowed to access public transport and that they are not a pet.

Journey Planning: Accessing detailed route information for journey planning. Tools can be inaccessible or require high skills to use.

Inaccessible Apps: Some public transport journey apps are not accessible or cost to purchase without advertisements. Free apps can be loaded with ads changing the screen.

Digital Divide: Not everyone has a smart phone or can afford the data to continually use during transportation. Not all smart phone users are able to learn the skills to use their phones for journey planning or following the route while on the bus.

Onboard stop notification: Being unable to determine when the required stop is next. Lack of auditory and/or visual information on board. Where screens are provided, they may change in the display between stops, removing the ability to read and follow the journey. Next stop audio announcements are only available in some regions, and where they are available, they are regularly turned off by drivers.

Time taken to get to destinations: In many instances what might be a 15 minute journey by car can be a one hour plus journey by bus for our clients.

Electric Busses: Current electric bus design means there is less seating at the front behind the driver. Locating an available seat in the lower sections can be an issue during peak hours. Electric busses are not fitted with AVAS Acoustic Vehicle Alerting Systems and are near impossible to hear when trying to cross a road or find a bus.

Bus Layout: Differing internal bus layouts that can cause difficulties in locating seating.

Bus Interchanges: Non-dedicated platforms for bus routes requiring travel to the bus as the position is announced. Insufficient tactile, auditory or visual information to locate the bus platform required.

The list of barriers detailed above are only some of the obstacles remaining to make public transport accessible for people who are blind or low vision.

Section by Section Response to the Proposals

Part 1: Clarifying Total Mobility’s purpose and introducing requirements to make assessment fairer and more consistent

Proposal 1: Set a clear purpose statement

BLVNZ position: conditional support, with clarification

Blind Low Vision NZ supports clarifying the purpose of Total Mobility and broadly agrees with the proposed statement:

• “to provide subsidised mobility services to disabled people who are unable to access public transport because of an impairment, to support them to live their lives.”

However, BLVNZ recommends that the purpose explicitly recognises functional access to transport, not just impairment.

BLVNZ’s IDI research Shining a Light on Blindness shows that people with severe visual impairment experience entrenched disadvantage across employment, income, health, and other wellbeing outcomes. Transport barriers are a key contributor to this disadvantage, particularly where public transport is technically available but functionally inaccessible due to navigation, safety, and discrimination barriers (see barriers listed in the above section, Barriers to Public Transport Access for People who are Blind, Deafblind or Low Vision).

A purpose statement grounded in functional access would:

• better reflect the experience of people who are blind or low vision,
• support the importance of Total Mobility to people who are blind or low vision,
• support more consistent assessments,
• align with the social model of disability already used in the discussion document.

Proposal 2: Make the Total Mobility assessment fairer and more consistent

Proposal 2A: Introduce evidence requirements

BLVNZ position: Qualified support

BLVNZ supports consistency in assessment but cautions against evidence requirements that increase cost, delay, or administrative burden for people with permanent vision impairment.

BLVNZ’s research shows that the median duration of visual impairment is approximately 30 years, and many people live with vision loss for most of their adult life. For these individuals, impairment is stable, well-documented, and unlikely to change.

BLVNZ recommends:

• no reassessments for people with permanent conditions that are stable and do not change, or that will continue to degrade.
• accepting existing clinical documentation without repeated certification,
• recognising assessments from specialist vision services,
• avoiding requirements that duplicate evidence already held by government agencies.

Evidence requirements should improve consistency without creating new barriers to access.

Proposal 2B: Introduce periodic reassessments

BLVNZ position: Do not support

BLVNZ does not support routine reassessment for people with permanent or lifelong vision impairment.

While BLVNZ agrees that eligibility should be based on functional ability rather than diagnosis, its research shows that people with severe visual impairment experience earlier mortality and sustained disadvantage, not improvement over time.

Periodic reassessment risks:

• unnecessary stress and uncertainty,
• reduced scheme confidence,
• administrative cost without proportional benefit.

BLVNZ recommends long-term or indefinite eligibility for permanent vision impairment, with reassessment only where a material change in circumstances is identified.

Part 2: Introducing more targeted support allocations for Total Mobility

Proposal 3: Introduce caps on trips based on level of need and circumstances

BLVNZ position: Do not support trip caps

BLVNZ does not support introducing trip caps, whether flat or targeted. Introducing caps contradicts why the scheme was started. In 1981 disabled people started the scheme to allow safe and dignified travel. The scheme was created because independent travel was not available to people with disabilities. The UN Convention of the Rights of Persons with Disabilities Article 20 sets out that State parties will ensure personal mobility with the greatest possible independence for persons with disabilities.[6] Limiting the travel of a person with a disability can be viewed as a breach of our obligations under the Convention.

BLVNZ’s research shows that people with severe visual impairment:

• have low employment rates (approximately 26%),
• are over five times more likely to receive a main benefit,
• 60 percent have annual incomes between $20,000 – $40,000.[7]

This indicates high transport need and low income.

Trip caps would neither uphold their human dignity nor empower their independence. In fact, trip caps would force people to ration essential travel, including:

• employment and job-seeking,
• medical and rehabilitation appointments,
• daily living activities, and
• social connection, which is critical for mental wellbeing.

BLVNZ is particularly concerned that purpose-based allocations would:

• reduce flexibility,
• increase administrative complexity,
• penalise people whose lives do not fit neatly into predefined categories.

If targeting is pursued, BLVNZ recommends it be achieved through eligibility and subsidy settings, not caps on use. Trip caps are the wrong solution to the wrong problem.

Proposal 4: Incentivise providers to provide more wheelchair accessible vehicle trips

BLVNZ position: Support

BLVNZ supports stronger incentives for accessible vehicles and notes that accessibility must be understood broadly.

While wheelchair accessibility is critical, BLVNZ emphasises that for blind and low-vision users accessibility also includes:

• reliable pick-up and drop-off practices,
• driver disability awareness,
• clear verbal communication, and
• safe navigation at trip endpoints.
• the use of braille taxi numbers on the front passenger door,
• accessible electronic payment terminals

Improving vehicle supply should be accompanied by service quality standards to ensure trips are usable, safe, and dignified for all disabled people.

Part 3: Promoting innovation in how Total Mobility is delivered

Proposal 5: Enable new Total Mobility service providers to enter the scheme

BLVNZ position: Conditional support

BLVNZ supports expanding the range of providers where this improves availability, accessibility, and choice.

However, its research shows that blind and low-vision people face barriers with:

• app-only booking systems,
• visual verification processes,
• inconsistent driver practices,
• guide dogs being refused access.

The rideshare business model means that the platform holder cannot directly influence a driver the same way a direct employment arrangement can. For example, in lobbying Uber about the consistent and persistent refusal of guide dogs in vehicles, Uber advised that they are trying to find ways to ensure drivers don’t break Uber’s policy or the law. We have many examples of riders being refused four times because of the guide dog, or simply driving away refusing the ride, or telling the rider to order an Uber pet. We acknowledge that Uber is trialling a new system, but it is people who are blind, deafblind, or low vision who pay the price.

BLVNZ recommends that any new providers be required to:

• offer non-app booking and payment options,
• meet accessibility and training standards,
• be subject to clear accountability mechanisms.

We do not want to see more rideshare drivers pulling up on the opposite side of the road yelling at someone who is blind to cross the road to them.

Innovation should reduce barriers, not shift risk onto users.

Proposal 6: Introduce a national public transport concession for people with disabilities

BLVNZ position: Support, as complementary to Total Mobility

BLVNZ supports a national public transport concession to improve consistency and affordability.

However, BLVNZ’s research shows that living in urban areas does not guarantee transport accessibility for people with visual impairment. Navigation, safety, and communication barriers persist even where services exist (see barriers listed in the above section, Barriers to Public Transport Access for People who are Blind, Deafblind or Low Vision).

A public transport concession must therefore be:

• additional to Total Mobility, not a substitute for it,
• implemented alongside continued investment in accessible infrastructure.

Overall conclusion

Blind Low Vision NZ supports strengthening the Total Mobility scheme where reforms:

• improve consistency,
• protect affordability,
• reflect functional need,
• preserve flexibility.

BLVNZ’s research demonstrates that blind and low-vision New Zealanders face long-term structural disadvantage and limited transport alternatives. Total Mobility is essential infrastructure for participation, not discretionary assistance.

Reforms must therefore prioritise access and dignity alongside financial sustainability.

[1] Thornley SJ, Gordon K, Shelton C, Marshall R. The prevalence of visual impairment: a capture-recapture study in three urban regions of New Zealand. Available at: https://blindlowvision.org.nz/news/new-study-vision-rehabilitation-new-zealand/
[2] Original numbers were obtained from: New Zealand Disability Survey 2013. Available at: https://www.stats.govt.nz/information-releases/disability-survey-2013 .
[3] Moore, David; Rippon, Rebecca; and Niemi, Malin. Vision Rehabilitation in New Zealand. 27 February 2019. Sapere Research Group. Page 14, Section 4.4.
[4] Blind Low Vision NZ, Shining a Light on Blindness: An Analysis of outcomes for Working Age New Zealanders who are Blind or Visually Impaired. Released 27 February 2026. https://blindlowvision.org.nz/shining-a-light-on-blindness/
[5] Administrative data in the Stats NZ Integrated Data Infrastructure (IDI) can be used to identify people who are blind or have visual impairment and compare their outcomes to people without visual impairment. Caution needs to be applied when assessing absolute numbers of people as the administrative data will not be able to identify everyone with visual impairment. Some groups of people are less likely to be identified in the data as they are less likely to seek support, use services or complete the Census.
[6] https://www.un.org/development/desa/disabilities/convention-on-the-rights-of-persons-with-disabilities/article-20-personal-mobility.html
[7] Blind Low Vision NZ, Shining a Light on Blindness, pages 46-51.