Last week William Hague, the new Minister for Disabled People, went on a four-day 'fact-finding' trip to the United States to see how a new law to prevent discrimination against disabled people is working in practice.

He met people and organisations who had campaigned and eventually persuaded President George Bush to sign the Americans with Disabilities Act in July 1990. The ADA makes it illegal to discriminate against anyone with a disability and provides a right of access to employment, transport, telecommunications, public services and buildings.

Mr Hague's introduction to measures which could transform the lives of disabled people in the US came barely four months after Nicholas Scott, his predecessor, had helped to kill a Bill which would have given Britain's 6.5 million disabled people similar rights.

The British disability lobby is hoping that Mr Hague's visit will persuade him that anti-discrimination legislation is desirable, workable and - crucially, from the Treasury's point of view - affordable.

This year, disability has commanded unprecedented political attention. The Government misjudged public opinion by using tactics widely regarded as underhand to defeat a Bill which commanded all-party support, and since then it has been on the run over the issue. The outcry has raised the issue of how Britain treats disabled people in a way that had never happened before, triggering a debate about what sort of framework of rights disabled people should have, what will be affordable and who should foot the bill.

The Civil Rights (Disabled Persons) Bill was backed by the disability lobby and would have made it illegal to discriminate against disabled people in the same way that discrimination on grounds of race and sex are outlawed. The Government estimated that the cost to business would be prohibitive - pounds 17bn over five years.

Yet after the Bill's defeat in May the Department of Social Security hurriedly published a consultation document in July, with proposals which would provide a more limited range of rights costing a mere pounds 17.2 million. Interested groups have until 7 October to respond.

Even so, the Treasury continued to lobby hard against such proposals, and this month the Daily Telegraph disclosed that Treasury ministers were horrified by the costs that even these watered-down proposals would impose on businesses. This message was repeated the next day by Treasury press officers, who told the Independent that ministers were concerned about the 'burden on industry'.

The costs of providing improved rights for disabled people are difficult to quantify. Yet the consultation document did estimate that the cost to business and industry of complying with the proposals would be pounds 17.2 million - pounds 8m to implement anti-discrimination proposals at work and pounds 9.2m to create access for disabled people to shops, restaurants, cinemas and other public buildings.

While the Treasury insists that these costs would be prohibitive, the disability lobby has attacked the proposals as completely inadequate. So where does the truth lie?

One of the few things the Government and the disability lobby agree on is the need to bring more disabled people into work, reduce dependence on social security benefits and increase income tax revenues. Of the 6.5 million disabled people, 2 million are of working age - and of those an estimated 1,380,000, or 69 per cent, are unemployed.

But beyond agreement on this general point, the Government and disability campaigners disagree on how to achieve the goal of higher employment and a number of other issues. The consultation proposals exclude increased access to educational establishments and public transport, while disabled groups argue that improvements in these areas are essential so that people can improve their chances of qualifying for jobs and travelling to work.

Another disagreement concerns financial services. Many disabled people feel their insurance premiums are unfairly loaded without evidence that they are a greater risk. The Government proposes a voluntary code, whereas disability groups want insurance discrimination outlawed.

The Bill would have created a Disability Rights Commission with powers similar to those of the Commission for Racial Equality. The Government's plan is for an advisory body which would have no power to seek redress for discrimination.

The two camps are most polarised over access to shops, restaurants and cinemas. The Bill said that public places should be made accessible provided the costs did not impose undue hardship on the owner. The disability lobby says this does not mean that every little cafe and store would have to provide a wheelchair ramp or that every restaurant would have to produce menus in Braille.

The Government proposals contain a get-out clause which says that owners do not need to change their premises where 'existing physical barriers prevent access'.

The house builders' lobby has complained at the Government's proposals to make all new homes accessible, with doors wide enough to take wheelchairs. But the Government's document states that providing wider external and internal door 'is unlikely to involve significant expense'.

The time scale for enforcing compliance has also been modified so that industry will have longer to adjust. The Civil Rights Bill said that all measures had to be introduced within five years.

Roger Berry, who tabled the Bill, eventually accepted all 80 amendments - including one that the time scale should be extended to an unspecified period. Bert Massie, director of the Royal Association for Disability and Rehabilitation (Radar) now says that no one ever wanted to force companies to comply within five years, but this position enabled the Government to argue that the Bill was unworkable.

Analysis by Radar has since shown that the Government's initial pounds 17bn estimate of the cost of the Bill was inflated by double counting and the inclusion of estimates for converting buildings that had already been adapted. Radar concluded that the costs had been overstated by pounds 12bn.

The argument about the Bill has focused almost exclusively on the costs of compliance, without taking into account the benefits. First, there would be substantial savings for the Treasury. In Britain spending on disability benefits has risen from pounds 5bn in 1978-79 to pounds 17bn in 1993-94; and 2.66 per cent of Britain's GDP is spent on social security benefits and allowances for disabled people.

Disabled people are three times as likely to be out of work as non-disabled people of working age, according to the Office of Population Censuses and Surveys. Two million disabled adults are of working age and if just 500,850 of them were employed the Government would save almost pounds 5bn in social security spending and increased revenue from tax and national insurance, according to an analysis by the Rights Now Campaign and the Disability Alliance.

Their report, Accounting for Discrimination, also estimates that if more disabled people had jobs, consumer spending would increase by pounds 2,000 a year for each disabled person finding work, and that the untapped market for tourism by disabled people could be worth pounds 12bn. This type of increase would be reproduced in every sector that opened up its services to disabled people. For instance, the report quotes an estimate that accessible bus services would allow companies to benefit from a 3 per cent increase in the number of bus journeys.

Perhaps the best guide to the impact that the anti-discrimination measures could have comes from the US experience of the ADA, which suggests that most initial fears about unreasonable costs have not materialised.

The research was carried out by Victoria Scott, daughter of the former minister Nicholas Scott. She works for Radar and the all-party parliamentary disablement group which supported the Civil Rights Bill. In a report, Lessons from America, she concludes: 'Most companies are coming to terms with their compliance duties, overcoming initial intimidation, installing ramps, making accommodations and gaining customers as a result. It seems that once companies take the first step towards compliance they find it less traumatic, less expensive and more beneficial than they had anticipated.'

Her report claims that the National Federation of Small Business Owners says that 'contrary to expectations, the ADA has become a goldmine for small businesses, widening customer bases and opening up an untapped labour pool'. She says every opinion poll has shown business to be surprised at the cheapness of improving access, and 'not one example is available, even from those most vigorously opposed to the ADA, of a company being pushed into bankruptcy by complying'.

American businesses have been helped by a variety of tax incentives for ADA expenditure and the Clinton administration is examining ways of helping further. The British government is under pressure to follow suit. The Institute of Directors argues that anti-discrimination legislation is a a social measure which should be financed by taxpayers.

Even if the message from the US is not being heard by the Treasury, it seems to have have been listened to by some sections of British business. The Confederation of British Industry was worried about the potential costs of implementing the Bill but recognises the benefits of some legislation.

Robbie Gilbert, its director of employment affairs, said: 'We need a new and effective framework of law in this area which opens up opportunities for people with disabilities so that they can make the fuller contribution in the workplace and as consumers that they seek, and from which business can surely benefit; a sound framework which does not impose costs so great that job opportunities might be reduced across the board.'

(Photograph omitted)