Made by Voice of Vision Impairment (30 Apr 2021)
1. Prioritisation of DPOs in Consultations
As a DPO under the Convention on the Rights of People with Disabilities, VVI needs to be prioritised in Dublin City Council’s (DCC) consultations on this proposal, and our concerns answered in detail, publicly as well as directly to us. Also, as a DPO, DCC needs to have sought our advice on this project from the concept stage of the plan. This, of course, did not happen.
By law, safety and rights come before perceived popularity.
Inaccessibility Issues Regarding the Proposal.
2. Inaccessible Information
The images in the proposal are not described, full stop, let alone adequately described for blind readers. This hampers our participation in the consultation process, and violates the EU Web Accessibility Directive (2016), and the Convention on the Rights of People with Disabilities (Article 4.3 as clarified by General Comment 7).
The delineation of the new pedestrianised spaces from the single remaining lane of traffic is unclear… i.e., we don’t actually know what it is because of the inaccessibility of the images; and also, it is likely to be inadequate, since a 125mm flat-facing kerb is required to segregate pedestrians from traffic – for safety of long cane users and guide-dog users, respectively.
4. Narrower Safe Footways
If the above point has not been catered for, then it means that blind pedestrians will be limited to a a very narrow safe space, if, indeed, they have any safe space remaining at all.
5. Vehicular Access
Many blind people rely on access by car – be it private transport, or taxi, and the reduction of road-space from three to one lanes means that such access will be more difficult.
For example, a blind person wishing to get a taxi to access the post office or the bank may not be set down close enough to where they need to go, putting them in harm’s way (given the above points 3 and 4).
6. Bus Diversion
The diversion of the 44 from Hume Street to Pembroke Street and Leeson Street will cause confusion and a lot of hard retraining.
7. Segregation of dining areas
The canvas/tarpaulin screens on steel poles are not fit for purpose when it comes to protecting long cane users, since the long cane is liable to snag in the gap between the canvas and the ground, and cause injury to the cane-user.
8. Partial Pedestrianisation
What is being proposed, of course, is partial pedestrianisation, depending on the time of day. This is confusing for the blind pedestrian, who will find the street safe to access in the current system, and find it dangerous in the semi-pedestrianised state (with one lane). This also means that they will be effectively excluded from the street during the peak dining hours. This has Human Rights ramifications, and is probably illegal.
Bollards are a hazard for long-cane users. Safer alternatives would have been proposed by VVI were we to have been consulted in time.
10.1. Encroachment of private business on public realm.
Apart from the worrying aspect of private enterprise being sponsored by the State to annex public realm, there are two related issues:
10.2. Where does the insurance liability lie, for example, if a long-cane-user injures themselves by being scalded by someone bringing a hot drink to the on-street dining area, or if they hurt themselves on the inadequate screens?
10.3. What is the plan to reclaim this public realm for the public once the supposed revitalisation stage is over?
11. Environmental Impact Statement
With such a large diversion of traffic from Stephen’s Green East, surely an Environmental Impact Statement is required? For instance, on Pembroke Street, Leeson Street, Ely Place, Merrion Square,
12. Bus Connects Presumption
Without prejudice to the foregoing, DCC’s final statement that Bus Connects will mean that there will be no buses on Merrion Row from 2024, anyway, presupposes the outcome of a democratic process of planning which has not yet been completed. It reflects wishful thinking, and a nod to the maxim that “if we define things as real, then they become real in their consequences.”