VVI is disappointed at the lack of disability-proofing of, or contained in, the Planning & Development Bill approved by the cabinet in early October. Our reasons are set out below. We have sent this, in letter and submission forms, respectively, to the relevant Ministers, their opposition counterparts, and to the Joint Committee on Housing and Local Government.
We are Voice of Vision Impairment (VVI), Ireland’s Disabled Persons’ Representative Organisation (DPRO) under the Convention on the Rights of People with Disabilities (CRPD), specialising in advancing the rights and needs of blind and partially sighted people. DPROs are the only ‘representative’ organisations regarding disability, as per Article 4 (3) of the CRPD, meeting the following criteria:
to avoid conflict of interest, DPROs are not disability service-providers (General Comment 7 (GC7), para. 13);
DPROs are Human Rights organisations and rooted in the CRPD (GC7, para. 11);
DPROs are led, directed, run, and specifically staffed by disabled people (ibid.);
a clear majority of their members (i.e., not service-users) are disabled (ibid.);
Ireland ratified the CRPD in 2018, and so, is supposed to be bound by it, as international law.
Article 4 of the CRPD consists of “General Obligations” which are cross-cutting of everything else contained in the Convention.
Article 4 (1 a-e), effectively means that policies (and by extension, legislation) should be disability-proofed and be compatible with implementation of the CRPD.
Article 4 (3) is the only part of the CRPD explicitly dealing with consultation, and this obliges ‘close consultation with and active involvement of DPROs in all matters relating to disability’ (i.e., including the disability-proofing just mentioned. Details on how this should be done are contained in the UN Committee’s clarification of Articles 4 (3) and 33 (3) – General Comment No. 7 (GC7) – published in November, 2018. This includes prioritising the opinions and views of DPROs in such consultations (GC7, para. 23), and having DPRO-only consultative spaces at all levels and branches of government (GC7, para. 49). DPROs should be proactively approached for continuous (not one-time) engagement in a consultation (GC7, para. 28).
2. The Planning & Development Bill.
Ireland has agreed, in the CRPD, to make the built environment accessible (CRPD, Article 9 (1), and GC2), by utilising the principles of universal design (Article 2).
The last Planning & Development Act (2000) had effectively no disability-proofing of it or in it, and as such, our members face an avalanche of disablist planning. This disablement through design means that we find ourselves increasingly excluded from our environments, such as in the proliferation of open plazas and spaces to be shared between pedestrians and cyclists.
Our nightmarish lived experience is, no doubt, mirrored in the experience of other vulnerable pedestrians and those who must depend on four-wheeled vehicles (such as many in their 80s and 90s, etc.).
Currently, plans must have an Environmental Impact Assessment which rightly looks at the affect a development might have on a particular type of snail, for example, but there is no equivalent to see the impact that a plan might have on our safety or accessibility to a local area or amenity; or even on our safe and accessible travel from our homes to the local shop etc.
The increasing isolation of our members, who find themselves more and more restricted in terms of movement, or confined to visiting fewer and fewer areas, is leading to increasing isolation, and deterioration in physical and mental health. These are the hidden, but very real, social costs of Active Travel plans, in particular, which more-often-than-not, actually put an end to our long-time reliance on Active Travel by making places inaccessible to us as visually impaired people.
In 2013, the National Disability Authority published detailed guidelines on what a “Disability Impact Assessment” should look like; but this was pre-CRPD ratification and so is missing vital structures as set out in General Comment 7.
This advice, to our knowledge, has never been acted on in any plan.
Dublin City Council has been having trials in disability-proofing on certain projects (since 2022), and is finding the experience so useful that it plans to make it corporate policy in the near future. It is a win win, since planners know where to go to find out what they need to do to make their plan workable for as many as possible. Dublin City Council is basing its plans on compliance with consultation obligations in the CRPD (Article 4 (3) and GC7).
3. Golden Opportunity.
This Planning & Development Bill is a golden opportunity for the State to implement key aspects of the CRPD in a way that is immediately practical and discernible by all, while also massively improving the life chances and life quality of visually impaired people, and others, throughout the country.
We were disappointed to find that the awareness-raising by the focal point of the CRPD in Ireland (the Dept. of Children, Equality, Disability etc. (DCEDIY), is so poor that those who drafted the Planning and Development Bill were not aware of their obligations or to the once-in-a-generation opportunity to fix what is very much broken in terms of safe and accessible built environments for a growing population of older and disabled people.
It is not too late to add revisions that protect our Human Rights (along the lines of Ireland’s obligations under the CRPD), to include:
where plans require an Environmental Impact Assessment or Statement, they must also require an Accessibility Impact Assessment statement;
Accessibility Impact Assessments must comply with Article 4 (3), as clarified by General Comment 7 of the CRPD), including:
systematically approaching all national and relevant local DPROs for their close consultation and active involvement;
for planning authorities to develop agreed procedure with each DPRO for general application;
continuous, rather than one-time engagement with each DPRO;
for DPRO-only consultations except where advised otherwise by a relevant DPRO;
for DPROs to be involved from the concept stage of all relevant plans;
prioritisation of views and opinions of all DPROs in such consultations, with prioritisation of national DPROs in terms of over-arching principles.
realistic timeframes for consultations;
proper resourcing and capacity-building of DPROs to facilitate our meaningful participation in consultations on accessibility impact assessments;
an independent review body, such as an Oireachtas Commission, to monitor Article 4 (3) compliance in planning;
making Article 4 (3) compliance a prerequisite for all public realm plans (GC7, paras. 65-6);
facilitating the taking of class actions by DPROs against disablist planning decisions and decisions that are not otherwise CRPD-compliant;
regular review and monitoring of the efficacy of DPRO engagement with a view to strengthening and supporting where identified as needed;
other provisions to be worked out through close consultation and active involvement of DPROs.
By way of resourcing materials, VVI has published a number of relevant documents:
We are always available for close consultation and active involvement regarding this specific legislation, and the State’s obligations to DPROs and our Human Rights, in general.
Funding of Disability Service-Providers to be Conditional on their respect for Articles 4 (3) and 33 (3) of the CRPD.
For a Cost of Visual Impairment Allowance of €214 per week, per person, in line with Indecon Cost of Disability Report, and this allowance to be for all visually impaired people, non-means-tested, non-taxable, and in addition to all core benefits (5.1).
for core basic incomes to keep up with inflation, and for anomalies between such payments to be ironed out (5.2-6).
for information and application services to be accessible (5.7).
free public transport at point of use for all (6.1).
For streetscapes to be disability-proofed by DPROs as a precondition (6.2-3).
for the same incentives to own private vehicles to be available for visually impaired people as for wheelchair-users (6.5).
removal of VAT on guide-dog related costs.
for funding to be made available so that there are no visually impaired people homeless (7.5).
an end to all prescription charges for those on medical card (8.3).
for accessible educational texts (9.3)
for funding of an Assistive Technology Scheme for visually impaired people to access the latest technology in a way they can afford.
2. Introduction.
We are Voice of Vision Impairment (VVI). VVI is Ireland’s Disabled Persons’ Representative Organisation (DPRO) with specific regard to the Human Rights of visually impaired people.
According to the UN Committee on the Convention on the Rights of People with Disabilities (CRPD), A DPRO must have Human Rights campaigning at its core, must have a clear majority of its members with the particular impairment for the respective constituency being represented (visually impaired people in our case), and must be led, directed, and run specifically by such people.
The UN committee overseeing the CRPD notes that DPROs should have our views and opinions prioritised, in decision-making processes affecting disabled people, over all other civil society organisations, and especially over disability service providers (such as those funded under Sections 38 and 39 of the Health Act, 2004), since the latter may have a “conflict of interest” in trying to be service-provider and advocate at the same time (cf. CRPD, General Comment 7 (GC7), paras. 13, 14, 23, 56, 57 etc.).
As mentioned below in more detail, the State has, up until now, ignored its legal obligations towards DPROs, including those of supports and resourcing. As such, because of our relatively low resources and zero supports from the State or otherwise, VVI may not be able to produce submissions to the glossy standards of disability service providers. For example, we are relatively short on costings when it comes to our proposals, often due to the state-funded documentation being totally inaccessible to those of us using screenreading technology.
Our desiderata, below, are principles either directly mentioned in the CRPD, or as fitted by us to the Irish context of the lived experience of visually impaired people – an approach which prioritises the voice of the least resourced and least supported individuals, and which is a sum of the pooled experience and collective expertise of our members.
Note on Language:
We use “visually impaired” or “vision impaired” to describe people who are blind or partially sighted, respectively.
We say “disabled people” – with “disabled” being a verb, not an adjective – to highlight that while people may be born with impairments and diversities, “disability” is a social construct, meaning that people are disabled by bad design, planning, and attitudes, mostly caused by insufficient knowledge. This “disabled people” language is in line with the social model of disability embraced by the CRPD.
3. State’s Legal Obligations regarding resourcing of DPROs.
As part of the State’s obligations under Article 4 (3) of the CRPD, which took immediate effect in 2018 (cf. General Comment 7, para. 28), The UN Committee says that the State should ringfence core institutional funding for DPROs (ibid., para. 61 (d)), while ensuring DPROs are autonomous in deciding their advocacy agenda, despite the funding received (ibid., 61 (e).
Since, in Ireland, there is a strong historical legacy and tradition of non-DPROs (and in particular disability service providers) colonising the “representative” space, real representation (through DPROs) is in a fledgling state, and is operating in hostile territory. Since all of our representatives are themselves disabled, and since all our workers, including representatives, are volunteers, it is imperative that we receive appropriate supports from the State in our empowerment and capacity-building (ibid., paras. 13, 39.
To paraphrase the UN Committee: ‘The barriers faced by disabled people in accessing inclusive education compromise their opportunities and undermine their capacities to be involved in public decision-making, which, in turn, have an impact on the institutional capacities of their organizations. The barriers in accessing public transport, the lack of reasonable accommodation, and low or insufficient income and unemployment among disabled people also restrict the capacity of such persons to engage in civil society activities.’ (ibid., para. 59).
Asks (3):
That the DCEDIY set up a register of DPROs (ibid., paras. 44, 61, 94 (t)), along the lines set out by the UN Committee (ibid., paras. 10-14).
Genuine DPROs should then receive core institutional funding and regular information and other supports by the State in accessing all types of funding. Also, other supports may be required from the State by DPROs which don’t involve funding, and these should be determined through close consultation and active involvement of DPROs (ibid., paras. 60, 61, 80, 94 (b).
One source of funding suggested by the UN Committee is the national lottery (ibid., para. 64).
A policy and legislative framework is required to embed DPROs into decision-making processes, at all levels within the State (cf. ibid., paras. 94 (b, e, f, etc.), and this includes DPRO-only spaces at all branches and levels of government (ibid., para. 49).
Building Consultation with DPROs into Budgeting of all Statutory Bodies should be an earnest objective, but for this to be comprehensive, our capacity-building is a prerequisite.
4. Funding Related to Disability-specific Services.
4.1. Additional Funding for Disability Service Providers.
The Dep. Of Health’s Disability Capacity Review (July, 2021), shows the massive extent to which the State currently relies on charities to provide core and essential services to disabled people. Not only is this outsourcing of responsibilities by the State to private NGOs less amenable to accountability, transparency, and scrutiny – in contrast to services directly provided by the State – for example, through integrated Universal Design –on a very basic level, Human Rights should not be dependent on charity.
Ask (4.1): At a minimum, any additional State funding of disability services needs to be disability-proofed by DPROs (see Article 4 (3) of the CRPD as clarified by General Comment 7); and Public Sector Equality Duty in the Human Rights Commission Act (2014, S42).
Such disability-proofing must have as a precondition of State funding to disability service providers that they are not directly or indirectly interfering with the representative rights of DPROs, for example, as set out in the CRPD (see General Comment 7, para. 51).
In other words, State funds must never be allowed to be spent on anything that directly or indirectly undermines the capacity of DPROs. This includes, for example, any facilitation and funding of advocacy by disability service providers (paying the lobbyist), and ensuring that all State funded operations that inform visually impaired people about disability service providers must also inform them about their DPROs, and facilitate their joining of DPROs.
Funding of Section 38 and 39 service-providers should also be contingent on such organisations closely consulting and actively involving the relevant DPROs in their own work (GC7, para. 14).
4.2. Specific Services and Accountability (context and ask).
Braille as an Example: There are three providers of braille transcription services in the country, and public authorities generally pay for these services when they receive requests from citizens looking for materials in braille.
Such service-provision must meet the requirements of the end-user, and not be dictated by the service-provider. For example, a coalition of braille transcription service providers, in 2013, decided that they would suddenly change from producing all documents in Standard English Braille to producing all documents in Unified English Braille. There is only two clicks of a mouse in the production software interface between the two. This wholesale and steadfast change seriously discommodes most visually impaired people who have learnt braille before 2014, and is discriminatory.
Where contracts exist with these contractors, they must be regularly reviewed with close consultation and active involvement of the relevant DPRO(s), and in particular with VVI (cf. VVI’s Policy on Accessible Communications, Section 5).
In December, 2021, the long-awaited INDECON report into the cost of disability (commissioned by the State), was finally published. The cost of disability to those who have a severe vision impairment (i.e., who are blind), was said to be between €9,805 – €10,565 per annum.
It is important to note here that much of what was being measured was the extra costs of being disabled by lack of universal design – i.e., being disabled by disablist planning, design, and other decision-making.
Even forgetting for a moment the inflation which has hit the country since the publication of the INDECON Report, we believe these costings to be a massive underestimation for two reasons:
i). The INDECON Report did not factor in that blind people are fifteen times more likely to be without paid employment than their sighted comparitor. Being unemployed due to institutionalised discrimination not only has a clear negative impact on income, but has concomitant knock-on effects which were not covered in the report. In other words, being “unemployed” is a cost in itself.
ii). the methodology of the research inadvertently, but necessarily, excludes visually impaired people with the least resources and supports – i.e., those with the highest disability costs. For example, the quantitative side of the research was based on online surveys, which necessarily exclude visually impaired people on the other side of the digital divide (which is common, for example, when people lose their sight), as well as for those who do not have adequate internet access.
Since publication of the Indecon report, annual inflation has been about 7%, so the headline figures can be presumed to have similarly increased in the meantime.For visually impaired people, the yearly cost of visual impairment could, therefore, be set at a conservative baseline of €10,800-€11,500, or to round it off, €214 per week.
The extra cost ofvbeing disabled by society because of our visual impairments is universal – i.e., borne by those on all income levels. A precondition of our equality in society is that our socio-economic disadvantage be addressed.
Some visually impaired people are currently in receippt of the Blind Welfare Allowance (BWA), which is €66.70 per week on the individual rate. A reformed BWA could become the vehicle for a Cost of Disability Allowance for visually impaired people.
Ask (5.1).
That a Cost of Disability Allowance of €214 per week be paid to all people with a severe visual impairment (i.e., those of us with 6/60 or less in sight measurement – in line with Ireland’s definition of ‘legally blind’); and that this payment be non-taxable and non-means-tested, applying to visually impaired people of all ages, equally.
5.2. Core Basic Payments.
As mentioned above, according to the 2016 Census, at least 76% of those with a severe visual impairment in the relevant age-brackets are not in paid employment. Whereas Welfare payments are generally kept low as an incentive for the recipients to seek paid employment, the institutionalised and practical barriers to paid employment are clearly too high for visually impaired people for this approach to be justifiable. As equal Irish citizens, we deserve dignity of life and equal opportunity.
Inflation: The blind tax allowance was reduced in 2010 from €1830 to 1650 and it has stayed there since. Clearly, this is not keeping up with inflation. Prices have been rising on an annual basis since April, 2021, with annual inflation rates of 5% or over, since November, 2021 (cso.ie). While annual inflation stood at 9.1% inAugust, , 2022, and effectively 10.8% for the most socio-economically disadvantaged, as of July, 2022 (Social Justice Ireland), core disability benefits only went up by 4.3% in the last budget (i.e., considering that the increases were not implemented until January 1st, 2023). Disabled people on non-contributory pensions got a meagre core increase of 4.9%, which was well behind inflation.
While disabled people under the age of 66 received one-off payments of €908, and the fuel allowance was raised by 32%, – as well as the €600 universal credits – these helped with energy costs during a time of exceptionally high energy inflation, but did not impact on general inflation hits to disabled people.
The annual inflation rate for August 2023 stood at 6.3%, but for those most socio-economically disadvantaged, this rate was estimated to be at
Asks (5.2): to mitigate against the current institutionalised disabling of people from our right to employment, and our consequent impoverishment; at the very least, core disability-related benefits need to be increased to meet the increased cost of living of their recipients. This also includes a reparation of their impoverishment in Budgets 2022 and 2023, as well as future-proofing against the expected continued inflation for 2024. In effect, this amounts to a minimum of 20% increase in Blind Pension and Disability Allowance. At a bare minimum, disability benefits should be brought to match the non-constributory State pension.
Likewise, the non-contributory Pension needs to keep pace with inflation, and similarly, a 20% rise is the minimum to make up for empoverishing budgets of the past two years.
5.3. Non-Contributory Pension.
Because of the inaccessibility of means-testing for most visually impaired people, the State’s forcing us to jump from Blind Pension or Disability Allowance to the Non-Contributory Pension as we reach 66 years of age poses a significant challenge, and one that relies on the help of third parties – which in turn compromises our security, as well as GDPR rights in conjunction with reasonable accommodation rights.
Also, forcing someone to do this based on a particular age cut-off point is surely discriminatory on the grounds of age, and quite unnecessary.
Ask (5.3):
That visually impaired people be allowed to continue collecting Blind Pension, Disability Allowance, or other disability-related core payments, for as long as they need, without having to shut that door and go through the threshold of the non-contributory pension process.
that the non-contributory pension rate be raised to meet minimum living standard requirements and to counter inflation.
5.4. Anomalies Between Different Payments to Disabled People Capital Disregards.
Currently, the basic capital disregard for anyone applying for or in receipt of the Disability Allowance is €50,000, counting to €70,000; but equivalent disregard for people in receipt of the Blind Pension or Non-Contributory Pension is €20,000 counting to €40,000.
Such an anomaly is unjustifiable, and appears to have arisen from oversight. Furthermore, it is at least indirect discrimination on the grounds of disability, given the practical difficulties confronting anyone in receipt of the Blind Pension if they wish to opt to collect Disability Allowance instead.
None of these capital disregards have taken account of inflation since they were introduced.
Another disablist anomaly can be illustrated in the scenario where a parent has exercised responsible duty by ensuring that a visually impaired child receives an equal share of the estate in their will. Indeed, the parent might want to leave a greater proportion to the disabled child, according to cushion or alleviate their long-term needs (such as extra costs of living and less overall independence). As things stand, perhaps in most cases, such a bequest would mean that the visually impaired child would have to give up their State benefits until they have run through the capital left to them by their dutiful parent. This might be contrasted with a non-disabled sibling who is likely to be in employment, and can invest the capital and get the full benefit of it.
Other Anomalies Regarding Rates and Circumstances
There are no disregards for partners or spouses on Blind Persons Pension, but some disregards for these in relation to Disability Allowance.
While on Disability Allowance, full Medical Card entitlements are allowable up to an income of €427 per week, but with the Blind Persons Pension, no extra earnings income is permitted for a recipient to retain their Medical Card benefits.
Ages of Eligibility of Benefits
The number of recipients of the Blind Pension has decreased by 23.5% between 2015 and 2022, from €1,341 to €1,026 (Oireachtas.ie, PQ 84, 22.5.17). This can be explained by the relative advantages of the Disability Allowance, not just in terms of the capital disregard already mentioned, but also because the Disability Allowance is receivable from the age of 16, whereas the Blind Pension is eligible from the age of 18.
This anomaly, whether or not a result of oversight, can only lead to the dwindling to zero of the number of recipients of the Blind Pension. The ESRI report (2018) based on the Quarterly Household Report returns of 2017, found that visually impaired people are ten times more likely to be on the receiving end of discrimination than any other disability (apart from psycho-social impairments, which are still behind visual impairment in this regard). As such, the retention of a specific core payment to cater for the needs of visually impaired people is advisable.
Asks (5.4):
that all capital and income disregards for visually impaired people in receipt of State benefits be changed to being uncapped or unlimited. This would cost the State nothing, but would alleviate life-long impoverishment of many visually impaired people. At the bare minimum, all such capital disregards should be equalised and substantially raised.
that all other anomalies that put visually impaired people in receipt of benefits other than the Disability Allowance be ironed out so that they are no longer discriminated against in this regard.
All of these anomalies are unjustifiable, and appear to have accrued by neglect rather than design. In particular, the Blind Pension should be put on a par with the Disability Allowance in all respects as soon as possible. Since there are only slightly more than a thousand people in receipt of the Blind Persons Pension, fixing these discrepancies should not be onerous.
that visually impaired people be eligible for the Blind Pension from the age of 16 (as with the Disability Allowance).
5.5. State Benefits as Taxable Income.
The Blind Pension and Disability Allowance, respectively, are classed as taxable forms of income, which effectively means that in many instances, increases in rates of such payments, as well as supplementary benefits such as Living Alone Allowance, and Household Benefits Package, are cancelled out by rent increases by Approved Housing Bodies and Local Authorities, which are calculated based on taxable income.
Ask (5.5): No disability-related payment should be a taxable income for visually impaired people.
5.6. Blind Welfare Allowance (BWA).
BWA is provided by the HSE to blind people living independently who are “unemployed”, at a current rate of €66.70 per week for a visually impaired individual, and €120 per week for a blind couple. The potential for BWA to be transformed to becoming a universal cost of visual impairment payment for all visually impaired people is mentioned in 4.1 above.
Currently, an eligibility component of the BWA is “a letter from the National Council for the blind of Ireland (NCBI)…NCBI is the national sight-loss organisation. They can confirm whether you meet the criteria to register as blind” (hse.ie).
However, as we understand it from the NCBI itself, the NCBI is in no position to confirm whether someone meets the criteria of being blind – this being an ophthalmological determination, and because there is no longer a “register” for blindness at the NCBI or anywhere else, for that matter.
Also, the designation of the NCBI as “Ireland’s national sight-loss organisation” is self-declared, and in violation of the CRPD, and does not belong on State-produced material, such as the HSE website (hse.ie).
Asks (5.6):
that Blind Welfare Allowance no longer be classed as taxable income, and not to be included as income in any means-testing. It is there to help counter the cost of disability, not as a luxury.
In the absence of any other compensatory mechanisms commensurate with the cost of visual impairment, the Blind Welfare Allowance should be increased to €214, in order to meet the costs of visual impairment and to help counter the inflationary situation the country finds itself in, and it should be available to all visually impaired citizens, without reservation or condition.
Any reference to the NCBI regarding Blind Welfare Allowance should be removed from the State’s information on eligibility criteria.
5.7. Accessible Application Processes for State Benefits and Awards.
As Visually impaired people, we have the right to independently access our entitlement to supports and services, including those relating to social protection (cf. CRPD, Article 9 (1). However, as mentioned earlier, application processes involve paperwork which is often not independently accessible to visually impaired people.
This means that not only do visually impaired people find it incredibly difficult to apply for their Welfare entitlements (as already mentioned), but they are also far less likely to avail of more specialist or one-off supports for the same reasons. Examples of such specialist or one-off application processes include:
Medical Card application and review/renewal
Reasonable Accommodation Fund
Back to Work Enterprise Allowance
Short-term Enterprise Allowance
VJT 61A (Revenue Commission’s form for tax-back on assistive or accessibility-related products regarding visual impairment).
Technical Aids Grant
Disabled Persons Grant Scheme
Housing Adaptations Grant
Mobility Aids Grant
SUSI (third level education grants)
Ask (5.7):
In close consultation and active involvement of VVI, all relevant public bodies to create a system based on Universal Design, which builds reasonable accommodations, as a default, into their regulations and standard operating procedures.
Also, many visually impaired people – especially where there has been recent sight-loss – will not be able to access information on what they are entitled to. Statutory bodies need to have incorporated into their budget a social work service that will let visually impaired people and other disabled people know what benefits they are entitled to, and to assist them in such applications with regard to that public body. This may be more efficient as a one-stop shop within the Department of Social Protection (DSP).
Public bodies should study our Accessible Communications Policy carefully, and embed the contents of this document in its structure and operating procedures: https://vvi.ie/our-policies/accessible-communications-policy/
The more that public transport fares are reduced to encourage the general public to use public transport, the less justifiable become the costs of ticketing and revenue protection on such services.
As things stand, ticketing is generally inaccessible to visually impaired people, and visually impaired people cannot independently identify revenue protection officers in a secure manner. Furthermore, some of our members have not been able to obtain the Public Services Card because they have found the application system to be inaccessible.
Ask (6.1): We recommend that public transport be free at the point of use for all passengers. This not only makes the entire public transport system much more accessible to visually impaired people, but makes it more accessible for everyone. The savings in ticketing, revenue protection, and time costs, should ensure that the overall cost to the commonwealth is decreased, and by the same measures, that the greater public good is being served through encouraging more environmentally sustainable modes of travel. This remedy will require much higher investment in public transport infrastructure to meet the extra demand.
6.2. Active Modes of Transport.
Very often, it is not safe for visually impaired people to cycle, and for obvious reasons, driving a car is not legally or morally possible. As such, we depend on “lifts” from friends and relations (especially if living in the country); on walking, where possible; and on public transport. Walking requires safe and accessible streetscapes; is limited in terms of distance; and can make it more difficult to find one’s destination (e.g., a first-time specialist’s appointment and No. 83 Main Street, etc.).
As such, cycling and walking (active modes) are not remotely adequate in journey completion for visually impaired people as compared to the general population.
Like you, we have a Human Right to access our community and environment on an equal basis with everyone else. This means that we must be able to access all areas, whether by blue badge private vehicles, taxi, or bus, etc. Anything else (e.g., pedestrianisation) necessarily constitutes a disablist planning zone.
Ask (6.2): As is our right as a DPRO under Articles 4 (3) and 9 (1) of the CRPD, we request that all funding on active Travel modes be contingent on accessibility audits that conform to Article 4 (3) of the CRPD – namely “close consultation and active involvement of…representative organisations” (i.e., DPROs).
A useful starting point is our Manual of Accessible Planning for Pedestrians (MAPP):
This precondition will have long term cost benefits, since it will facilitate the independence (economic and otherwise) of our ageing population, as well as fulfilling the State’s obligations to our DPRO members.
6.3. Consultation on Sustainable Development Goals.
The UN Committee points out that part of the States obligations to “closely consult and actively involve” DPROs (as per Article 4 (3) of the CRPD), relates to, for example, the UN Sustainable Development Goals (2030) (General Comment 7, paras. 9, 92, 94 (r)). So far, in Ireland, this obligation has been neglected or otherwise ignored, across this entire area, including the Climate Action Plan.
Ask (6.3): In line with the State’s obligations under Article 4 (3) of the CRPD, and with the Public Sector Duty (IHREC Act, 2014, S42), disability-proofing, through close consultation and active involvement of DPROs, needs to be a precondition of any funding related to the 2030 Sustainable Development Goals.
6.4. Visually Impaired Passengers.
The EU Parking Permit scheme for disabled drivers and passengers means that blind passengers (along with severely physically impaired passengers/drivers) have disabled parking rights. However, particularly in rural areas, where visually impaired people do not have adequate access to public transport, we are often totally reliant on being driven to doctors’ appointments, to community events, to work, etc. Unlike our sighted comparitors, we do not have the option of cycling. Similarly, in a household, where both parents would be able to co-ordinate school-runs etc., where one parent is visually impaired, the availability for work of the other partner is often compromised by having to make such school-runs or drop children off to bus-stops etc.
Ask (6.4): Visually impaired people have a comparatively restricted ability to engage in “active modes” of transport, and as such, it is an anomaly (and discrimination on the basis of disability) that we are not also eligible for the Disabled Drivers and Disabled Passengers Scheme, which provides a range of tax reliefs linked to the purchase and use of specially constructed or adapted vehicles by drivers and passengers with a disability. Visually impaired people may not need adapted vehicles, but the necessity of their being driven should be reflected in the same tax reliefs and toll exemptions, i.e., as set out in the Disabled Drivers and Disabled Passengers (Tax Concessions) Regulations 1994 (SI 353/1994) as amended.
6.5. Accessibility as a Precondition for Public Transport Licensing.
There has been a trend, in recent years, towards the further opening up of public transportation to private operators. It is essential that such licencing by the National Transport Authority (NTA) is dependent on accessibility to disabled people in general, and from our perspective, to visually impaired people.
Ask (6.5): That all future license-granting by the NTA to private operators be dependent on disability proofing in line with Article 4 (3) of the CRPD.
6.6. Removal of VAT on Guide-Dog Costs.
A guide dog is an aid to visually impaired people, both for independent living and mobility. As such, the costs of maintaining them should be vat exempted, as is the case for adaptive technology, which also can be seen as an aid to independent/living/mobility. Currently, users of guide-dogs must pay 23% VAT on everything necessary for the maintenance of the guide-dog (such as dog-food which is of prime quality for working dogs).
Ask (6.6): VAT should be removed from all purchases (including payment of services) necessary for the maintenance of guide dogs (both working and retired).
7.1. Needs of Visually Impaired People in being Allocated Housing.
Currently, there is no agreed standard as to what constitutes Universal Design in State-supported housing – notwithstanding an out-of-date paper by CEUD, in 2013). The prevailing ethos (e.g., DHLG, Disability Housing Strategy, 2022), concentrates on accessibility for wheelchair users (which, of course, in itself is essential). However, Universal Design must also take account of the needs of visually impaired tenants, and to that end, Article 4 (3) of the CRPD is once more a statutory obligation. In other words, it is an obligation under international law that the State prioritise DPROs, in general, regarding the compilation of a Universal Design standard, but that in particular, with regard to visual impairment, VVI is prioritised on all levels.
Also, the designation of Approved Housing Body status to any disability service provider in this respect, against the wishes of DPROs, is necessarily repugnant to the CRPD.
Ask (7.1):
That the Housing Agency “closely consult with and actively involve” VVI in a statutory minimum standard on “Universal Design” as applied to public and private housing, with regard to new builds, and state-subsidised retrofitting.
That no AHB status approval be given to any disability service provider without this first being agreed with the relevant DPROs. In this case, since VVI is the national DPRO concerning visual impairment, specifically, VVI must be closely consulted and actively involved, as well as our views and opinions prioritised, in such consideration.
7.2. General DPRO Prioritisation in Consultations.
Currently, there is no provision for prioritisation of the “views and opinions” of DPROs (General Comment 7, para. 23), nor distinction of DPROs (ibid., paras. 13-17) in the Disability Housing Strategy (2022-7).
As with section 2, above, it is an obligation on the State to make sure that DPROs are afforded those rights, including in what is often referred to as ‘stakeholders’ in the area of housing, and this must be remedied in order for Ireland to be compliant with its obligations under the CRPD (Article 4 (3) and 19). This will also involve an obligation for Local Authorities to capacity-build DPROs.
Ask (7.2): That the DHLG, Housing Agency, and Local Authorities have distinct and prioritised consultations with DPROs regarding housing and disability.
7.3. Housing-Related Data.
Currently, the DHLG have shoe-horned Deaf, Deaf-blind, hearing impaired, neurodiverse, and visually impaired people into the one category, i.e., “sensory impairment”, and even worse, the medical model language of “people with a sensory disability”.
Impairments in sight and hearing have totally different consequences. The impacts, apart from the general disabling by society, are chalk and cheese. Lumping these categories in together might be handy from a disinterested statistician’s perspective, but not where one is interested in the actual differences in housing take-up and subsequent results.
Ask (7.3): That the DHLG be required to separate its statistical categories according to the various types of sensory impairment (Deaf, hearing impaired, deaf-blind, and visually impaired), as well as a separate category for neurodiverse people. This will allow additional funding, where necessary, to be targeted, not only in usual housing services, but also in terms of homelessness services.
7.4. Minimum of 2-bed Allocations for Visually Impaired Individuals.
Many visually impaired individuals in public housing have no choice but to remain in hospital when recovering, thus, inadvertently “bedblocking”, since they live alone in 1-bedroom dwellings, and as such, cannot have full-time care from extended family, community, or professionals in their own home. Generally speaking, also, visually impaired people living alone may require more room to house assistive technology, guide-dogs, and more room to avoid trip-hazards, such as placement of clothes-dryers etc.
Ask (7.4):
That Housing allocation for visually impaired individuals allows them a minimum of 2-bedroom dwellings.
7.5. Homelessness.
Homelessness is a terrible situation at the best of times, but 26% of people suffering from homelessness are also disabled (ESRI-IHREC, Discrimination and Inequality in Housing in Ireland, 2018). This over-representation, as with other inequalities, is not coincidental.
Asks (7.5):
that visually impaired and other disabled people be fast-tracked out of homelessness as a priority.
that in close consultation with VVI, that homelessness authorities identify those homeless accommodation facilities which are most accessible to visually impaired people, and that placements be made, as priority, accordingly.
7.6. Home Supports.
Many people with a visual impairment require additional assistance with tasks that others might think as straightforward, such as cleaning of rooms, assistance in travelling, and even simple DIY tasks such as safely changing a lightbulb, the railing or re-railing of curtains, replacing a fuse in a plug, etc.
VVI has published a position paper on traditional home support services (December, 2021):
However, there are two areas which need more investment from the State in this regard: namely, personal assistance for visually impaired people; and the provision of tradesperson-related assistance.
In terms of personal assistance, visually impaired people may require assistance, such as in browsing in their local library, including more specialist possibilities such as the need for a personal assistant to be proficient in a second language, such as Irish. Such additional support requires more investment in personal assistance provided by the State. In terms of assistance to visually impaired people, in particular, remote personal assistance, such as that provided by AIRA, should be seen as an intrinsic option supported by the State, where preferred by the visually impaired person.
In terms of tradespeople, some tasks are more specialist. For example, the pressure on the water may be low, but a visually impaired person cannot access the interface on the boiler to raise it; or on some makes of washing-machine, the filter is at the back, and cannot easily be removed when required to be cleaned –causing a breakdown in the washing-machine.
Asks (7.6):
That more investment be made in PA hours for visually impaired people, including, where sought, remote PA services, such as those provided by AIRA.
that a system of State-subsidised trades in the home be organised with a view to providing solutions to emergency and daily needs of visually impaired and other disabled people.
In its prebudget submission (July, 2022, p.9), the Oireachtas Joint Committee on Disability Matters writes:
“The Committee believe that funding strategy needs to move to individualised funding and a needs-led system where an assessment of people’s needs would be undertaken to allow for direct resource allocation to meet the needs of each person. Those could be personal care needs, social inclusion needs, etc. The Government must implement the personal budgets pilot to enable a model of delivering disability supports as a personalised budget which has autonomy, independence, and community inclusion for people with disabilities at its core”.
We have concerns about this approach, from a visually impaired perspective. Apart from the bureaucratic costs in determining individual budgets, which can be arbitrary and be a fiasco, as with the PIPS in Britain, visually impaired people are often denied access to the so-called free market by virtue of the fact that advertising and availability of services is not communicated in a form accessible to us. Also, clearly, different parts of the country will have varying qualities and amounts of service-provision if things are left to the ‘free market’, and indeed, if a Regulator, down the line, is necessitated, things get even more bureaucratic in terms of wasted resources.
Ask (7.7): That nothing be done regarding a change of funding strategy to personalised budgets without prior close consultation and active involvement of DPROs (including VVI).
Throughout Ireland’s health service, there persists basic and universal inaccessibilities and disablist practice. For example, we often hear of hospitals complaining about ‘no-shows’ of outpatients for medical appointments; but it is our experience that accessible communications from hospitals to visually impaired patients (e.g., as per the Disability Act, S28), are the exception rather than the rule, and have to be fought for by the outpatient, on each and every occasion.
Similarly, medical staff rarely appear to have received adequate training in how to safely guide a visually impaired person or to understand other access needs.
In terms of systems, The systems set up for vaccination and antigen-testing for covid are intrinsically inaccessible to visually impaired people – with VVI’s offers to advise on our needs from the outset being effectively ignored by the HSE and Dept. of Health.
Ask (8.1):
Adequate funding must be identified for the adequate training and setting up of accessible communications systems by medical staff and institutions, as well as public authorities, themselves.
Context and ask: Given the extra costs of being visually impaired, often involving greater need to use health services, all visually impaired people should be eligible, by default and without means-testing, for a general services medical card.
Because restoration of lost vision is an infinitesimally rare occurrence, and because renewal processes are intrinsically inaccessible to many visually impaired people, visually impaired people should have indefinite entitlement to the medical card.
8.3. Medical Prescription.
Medical prescription charges of €1.50 are charged to medical card holders getting items on prescription from pharmacies. Such a tax is regressive, since it cuts at the poorest in society; and it is also cruel, since it penalises medical card holders for their reliance on essential medicines or medical products. This latter point also means that by its nature, the charge is disablist.
Prescriptions regarding medicines for long-term conditions are currently required to be renewed by the service-user every three to six months, creating much unnecessary bureaucracy, as well as unnecessary hassle for the person with the long-term condition.
Ask (8.2):
That all medical prescription charges be dropped for medical card holders (which would, effectively, be a return to the situation as it was in 2009 and before).
that prescription-renewal obligations for medicines pertaining to long-term conditions be got rid of. When the patient dies (and the prescription comes to an end), the pharmacy concerned can be required to refund the State the amount it has received from the State in lieu of the medicines acquired, but unused, for that particular prescription.
8.4. Public Eye-Care Services.
A VVI member has a congenital eye syndrome (microphthalmia), but was also diagnosed with cataracts in 2016. The pre-existing syndrome means that a cataracts operationis not a straightforward procedure, and requires very experienced and specialist consultants. However, he remains an outpatient at a regional hospital, and appears to have been forgotten about. In the meantime, the cataracts is embedding itself in his eyes, making it more difficult to successfully remove without bleeding, infection, or detached retina. The prognosis for him saving any sight is not good.
Ask (8.4): that Ireland’s Third World public system for eye clinics be properly resourced to meet the First World expectations of our ageing population. Such investment will necessarily save money in the long-run as it helps to prevent life-changing experiences of total loss of sight, and the distresses and need for support services which accompany that loss.
8.5. Basic Health Needs for All.
Our members find that if they are on the Medical Card, they may be charged by their local General Practitioner for basic blood tests. As such, many of our members are being discouraged from getting tested for conditions such as diabetes, or cancer etc.
Similarly, visually impaired people, especially those on medical card, find it difficult to access adequate dental care.
Asks (8.5):
that funding be made available so that all blood-tests of Medical Card holders are free of charge.
that there be close consultation with VVI in the provision of adequate dental care for visually impaired people.
In keeping with the concept of Universal Design (CRPD, Article 2), visually impaired children have a right to receive a full education that meets their practical needs (as well as academic needs), as an integrated part of the education system. This means that the State should be providing education of life skills specific to visually impaired children (such as mobility and orientation, as well as other practical skills such as use of assistive technology, braille, and summer courses such as cooking, for visually impaired children. Similarly, but separately, the same services should be provided, as a right, to adults who have lost their sight later in life.
Ask (9.1):
That for any visually impaired person in the education system, that visiting teachers (from the NCSE) be adequately trained in the provision of education involving life skills specific to visually impaired children and young adults; and that in terms of rehabilitation, that the State closely consult and actively involve VVI in the establishment of a State-run rehabilitation service, under the auspices of the DCEDIY.
since the most cost-efficient and accountable provision of such services are where they are functions of the State, where NGOs are currently providing such services to some extent, such provision should be seen as a transitional support while the State establishes its own standards in close consultation and active involvement of DPROs, and in particular, in this instance, with VVI.
9.2. Accessible Educational Texts.
We know anecdotally from third level institutions disability support units and from what data there is from AHEAD, that attendance at third level institutions by visually impaired students – and in particular, blind students – is the lowest of all disability constituencies (although, since there is nothing on deaf-blind participation, we would presume this to be very low indeed, if there is any participation at all).
From our own experiences in the education system (in all levels, up to FITAC Level 10), accessibility to even core texts is difficult, or non-existent. Often, where access to even core texts is provided, it does not happen in a timely manner, further disadvantaging the visually impaired student. Given this discrimination, which is intrinsic to Ireland’s education system, it is no wonder that there is such a relatively poor success rate among visually impaired students.
note also that Duxbury (the software currently used by all Irish service-providers in braille-production, works from Microsoft Word, and so, production of braille texts from materials is really only practical when an accessible Microsoft Word version is the transcription-to-braille source.
the “Copyright Library” status of Trinity College Dublin should be extended to the National Library of Ireland, and as such; all books published in Ireland be required to lodge an accessible Microsoft Word version, and a .pdf version, of the book with the NLI, so that visually impaired readers can access such materials on demand from their local library.
9.3. Third Level Education Supports.
In the United Kingdom, visually impaired third level students are guaranteed a minimum of 20 hours personal assistance supports, which is totally separate to their data processing (text) supports. This personal assistance not only means that lectures are more accessible to us, but also that we can go for lunch and participate more fully in college life.
In Ireland, standards of accessible text provision as well as of personal assistance hours vary from institution to institution, but personal assistance tends to be only provided for taught courses, which excludes many post-graduate courses.
Visually Impaired students in Third Level may require very specialist personal assistance, such as knowledge of a particular language other than English, or knowledge of STEM abbreviations and charts, etc. The current rates of PA-pay for Third Level education supports is quite close to the minimum wage, and so, is not generally compatible with particular specialist needs.
In Section 4, we have already mentioned the evidence of systemic impoverishment of visually impaired people in general, and visually impaired students are no different in this regard.
Apart from the extra costs by Third Level students, generally, such as living away from home, etc., visually impaired people incur additional costs related to Third Level education, such as extra need for taxi services, more dependence on eating-out facilities, etc. Furthermore, since courses are more likely than not to be inaccessible, the drop-out rate of visually impaired people can be expected, reasonably, to be much higher than the norm.
In short, the current SUSI criteria for funding looks at previous Third Level experience as a negative marker where courses have been dropped. In the case of visually impaired people, this is disablist, because it is blaming the victim.
Asks (9.3):
that Third Level supports be standardised, including the provision of a minimum of 20 PA hours per student (including for all postgraduates).
that educational support workers (i.e., personal assistants) be directly employed by third level institutions, which will afford a much higher level of pay for their work, and attracting Pas with higher skill-levels.
that visually impaired students not be penalised by previous third level attendance in the awarding of SUSI grants.
9.4. Talking Books should be VAT-free.
Ask and Reason: 21% VAT needs to be removed from talking books (to match print book counterparts). This helps to address the difficulties in educational and cultural access experienced by blind people, especially having lost their sight later in life, and recognises the barrier to purchasing talking books caused by the systematic impoverishment of visually impaired people.
9.5. TV license exemption to all visually impaired people – whether in receipt of State benefits or not.
De facto this is the case anyway, since An Post has been thwarted in the Courts for trying to chase down blind people who had not officially been exempted. But visually impaired people should not have to worry about such things.
This is a good time to remind the State that the vast majority of television programming in Ireland does not have Audio Description, and so is inadequately accessible to visually impaired viewers/audiences.
Asks (9.5):
for all visually impaired people to be entitled to a free tv license or to be exempt from the requirement to have a license.
for State broadcasters in particular to have a minimum audio description output of 30% in 2023.
for such broadcasters to have accessible interfaces on apps and websites.
10. Assistive Technology Scheme.
VVI calls for Seed Funding for an Assistive Technology Scheme which would act like a lending library, where visually impaired people could test out devices to see if they would be suitable as long-term purchases.
as a basic step to using technology to empower visually impaired people in society, this national scheme would also be engaged in research, such as into the practical application of accessible digital signage, in close consultation and active involvement of VVI and other national DPROs.
Whereas, before, such technology may have seemed too expensive and not universal enough for widespread application, this landscape is rapidly changing, and Ireland should be at the forefront of utilising such technology to improve the lives of visually impaired people.
Possibilities not only include a national assistive technology library where visually impaired people can test out devices, but also to be considered should be individual accessible technology grants from lottery funds.
Currently, grants are available for visually impaired people to obtain technology once they have been offered a paid position by a public or private body, but given the scandalous unemployment rate of visually impaired people, most of us will not be in a position to be well used to such technology, at present, until entering the work-place, causing a catch 22 scenario. In keeping with Articles 4 (1) and 9 (2) of the CRPD, communications technology as a Human Right, needs to be seriously addressed by Ireland with regard to visually impaired people of all ages.
1. What is A Disabled Persons Representative Organisation (DPRO)?
1.1. DPROs are specifically founded to defend and advance the Human Rights of Disabled People (United Nations Convention on the Human Rights of Persons with Disabilities (CRPD) General Comment 7 (GC7), para. 11).
1.2. DPROs cannot be Disability Service Providers or ally organisations (CRPD, GC7, Para. 13).
1.3. DPROs must be only led, run, directed, staffed, and mostly Membered by Disabled People, (CRPD, GC7, para. 11).
2. Who can be a member of a DPRO?
Primarily, any Disabled Person can be a member of a DPRO along the lines of the constituencies or impairments being represented by that DPRO.
DPROs can also be cross-impairment or intersectional, based on disability and other protected grounds of discrimination such as gender, marital status, family status, age, sexual orientation, race, religion and members of the Traveller Community (cf. CRPD, GC7, paras. 11-2).
3. Other (non-DPRO) Disability-Related Organisations.
3.1. Disability Service Providers.
Disability Service Providers are private Non-Governmental Organisations (NGOs) who provide services to Disabled People, meaning they may have a conflict of interests in claiming to ‘represent’ disabled people (CRPD, GC7, para. 13.
So, Disability Service Providers cannot be DPROs, and indeed, DPROs should be distinguished from disability service providers and all other civil society organisations in consideration of any matter relating to disability by a public or private body, so that DPROs are clearly prioritised in consultations etc. (ibid.), even to the extent that there should be DPRO-only consultations in every branch and level of government (CRPD, GC7, para. 49).
3.2. Disability Ally-Organisations.
Another type of non-DPRO with regards to Disability are ‘Ally Organisations’, i.e., disability-related organisations who do not provide disability-related services, but who don’t otherwise meet the criteria for being a DPRO: e.g., led, run, directed, staffed and mostly Membered by Disabled People, and who may not be specifically set-up to advance the Rights of Disabled People. An example of this would be a network of parents of disabled children, relatives of disabled adults, or carers for Disabled People.
4. What Else does CRPD say about DPROs?
4.1. The only Representative Organisations regarding Disability are DPROs (CRPD, GC7, Part II, Section A), and as such, DPROs should be the first port-of-call in all consultations regarding disability, and the views and opinions of DPROs should be Prioritised by Public Bodies when addressing anything in relation to Disability, CRPD, Paragraphs 13-4, 23, 56), even to the extent that there should be DPRO-only consultations at all branches and levels of government (CRPD, GC7, para. 49).
4.2. Everything done by Public and Private Bodies should be Disability-Proofed, through DPROs, as a precondition for any Policy, Design, Law, etc., and this needs to be enforceable (CRPD, GC7, paras. 65-6).
4.3. Research should never be mistaken for consultation with DPROs, but even where research is undertaken into disability-related matters, obligations to closely consult with and actively involve DPROs regarding the agenda, questions and other aspects of the research, apply just as much (CRPD, GC7, paras. 17, 54, 77). For example, focus groups are not consultation, and cannot replace consultation, but focus groups should be predicated on prior obligations to DPROs.
5. Are DPRO Rights currently recognised in Ireland?
No, they are not. Even Ireland’s “focal point” of the CRPD, the Department of Children, Equality, Disability, Integration and Youth (DCEDIY) appears to be unaware of its own Obligations in this regard and also its own obligations to make everyone aware of the need to prioritise DPOs in all disability-proofing and other disability-related considerations.
6. Who has the responsibility to protect the rights of DPROs?
DCEDIY and all Public Bodies, as well as the Irish Human Rights and Equality Commission (IHREC) have the official responsibility of ensuring the implementation of the CRPD in Ireland, which is predicated on Articles 4 (3) and 33 (3) of the CRPD, as explained by the UN Committee, General Comment No. 7.
7. Have DPROs currently any say in anything that affects disabled people in Ireland?
DPROs are, at best, aggregated and effectively marginalised in occasional tokenistic consultations; but more generally, are systematically ignored. Rather than being approached by public bodies in a systematic way (CRPD, GC7, para. 22), DRPOs usually have to spend precious time and resources trying to explain what a DPRO is – a difficult task when DCEDIY continues to ignore its awareness-raising obligations as “focal point” of the CRPD in Ireland.
8. Are DPROs currently funded by Ireland?
As per the CRPD, DPROS must be State-funded, including with core institutional funding, while maintaining complete independence (CRPD, GC7, para. 61. However, since Ireland’s ratification of the CRPD (2018), DPO-specific funding and other necessary special supports, have still not been provided by the State.
Language note.
The UN Committee tends to use the language of the medical model of disability, so that it refers to DPROs as “representative organisations of persons with disabilities,” or just “organizations of persons with disabilities”, as well as “their representative organizations.” Up until recently, in Ireland, DPROs have been known as Disabled Persons Organisations (DPOs).
For more detailed information, see detailed legal opinion on DPROs, commissioned by Voice of Vision Impairment (VVI).:
Submission by Voice of Vision Impairment Ireland (VVI) to the EU Commission
22nd December 2022
1. Introduction to VVI
VVI is Ireland’s Disabled Persons Organisation (DPO) specialising in the defence of and campaigning for the Human Rights of visually impaired people (i.e., people who are blind or partially sighted). DPOs is the general term used in Ireland for what the Convention on the Rights of People with Disabilities (CRPD) refers to as “representative organisations” (CRPD, Article 4 (3), or “organisations of people with disabilities (General Comment 7, passim.).
2. Need to Prioritise and Distinguish DPOs in Consultations
In accordance with the Convention on the Rights of People with Disabilities (CRPD), Articles 4 (3) and 33 3)), DPOs must be closely consulted and actively involved in disability-related matters, such as this consultation; and as clarified by the UN Committee, in General Comment No. 7 (GC7), DPOs should be prioritised, in terms of their views and opinions as well as being first port-of-call, over all other civil society organisations in such processes, and this includes prioritisation over disability service providers (DSPs) (cf. GC7, paras. 13, 14, 23, 56, etc.).
This also means that instead of being aggregated in consultations, DPOs must be distinguished from all other civil society organisations (ibid., paras. 13-5).
It also means that consultations are ongoing, and not one-off (ibid., para. 28).
In this particular process, it is our experience that DPOs such as VVI have been totally ignored, and everything has been done through the Disability Federation of Ireland (DFI), which is an umbrella-group controlled by the disability industry in Ireland, and is as far as one could get from being a DPO.
No doubt this has occurred as a result of DFI being Ireland’s representative to the European Disability Forum, something which also needs to be sorted out, since non-DPOs should not be representatives to the EDF.
See post-submission note at the end of this document regarding the EU Commission’s neglect of its obligations under Article 4 (3) of the CRPD in this consultative process.
3. Language – European Accessibility Card
Before looking at the concept and accessibility features, language and terminology should be examined.
According to the social model of disability, which is espoused by VVI, as well as most of the rest of the global DPO movement, disability is a negative social construct, and not characteristic intrinsic to the disabled person. When we speak of disabled people, we mean ‘disabled’ in the verbal sense: i.e., that we are being disabled by bad design, prejudice, neglect, lack of understanding etc., rather than ‘disabled being used as an adjectival identifier. In this way, disability is comparable to ageism, sexism, racism, homophobia, etc., which are other negative social constructs.
So, disability is not an identity, but rather, a negative condition of discrimination. Humanity has a diverse array of conditions and physical and sensory impairments, but what disables us are the obstacles preventing us from accessing the world on an equal basis to what are imagined to be ‘normal’ people.
So, while the title “European Disability Card” follows the medical model of using disability as an identifier, and strongly suggests that the negative social construct is intrinsic to us, it is not appropriate.
In keeping with the social model of disability, a far better title for the proposed scheme would be “the European Accessibility Card”. Only disabled people would be eligible to possess such a card, but the extra accessibility it provides would help to mitigate against the socially-created phenomenon of disability – i.e., the disabling of us on a consistent basis by policies and design etc.
However, to avoid confusion, for the rest of this submission, we use European Disability Card (or EDC).
4. The Concept
4.1. Shortage of Recognised Equivalences from country to country
It has been noted by one of our members that in the UK, Italy and elsewhere, “if you can produce a card to say you have a disability you get discounts or better seating in theatres, etc.” But in Ireland, he has encountered the phenomenon of ‘if you don’t have a wheelchair then you’re not disabled’.
Our members who do not use mobility aids such as long canes or guide dogs are more likely to encounter such discrimination. Even when we travel to the UK or Germany, for example, we have nothing to show in lieu of a disability card.
Another VVI member showed his Irish Dept. of Social Welfare Free Travel Companion Pass at an exhibition in Berlin, but was told that this wasn’t recognised. This VVI member also noted that the disability card in Germany also includes free travel. This member then showed his Disability Parking Permit which is issued by the Irish Wheelchair Association and valid for parking in the European Union, and this worked for a concession, since it was recognised as a pan-European document.
Incidentally, this same VVI member had difficulties getting a companion rail ticket free of charge in Germany, since, for validation reasons, “you are required to obtain it from the rail company in your own country […Irish Rail…] Irish Rail), however [Irish Rail] closed their British and European Rail offices some time ago and outsourced it to a company who don’t want to know you”.
As we understand it, under the European Rules, the person with the disability is supposed to get a free ticket for their companion when they purchase a ticket. He goes on to make the observation that “Clearly, some type of pan European document was needed and many people already have the disability parking permit. Under European Union freedom of movement rules, we should be able to move and reside in another EU country with the same benefits.”. The problem appears to be current lack of mutual recognition among EU States.
Notwithstanding the UK examples above, the non-transferability of equivalents among EU states is a problem which appears already to be in breach of EU legislation and treaties. While a single European Disability Card would help to circumvent such current obstacles, the fact that such obstacles exist at all should also be dealt with.
4.2. The complication of having specific service cards
A VVI member cites the Cinema Exhibit Association (CEA) card for disabled people still operating in Britain and Ireland, which grants free entry of a guide/companion, for example, to visually impaired people. This can be the difference between accessing or not accessing a central point of culture in our community.
Given that there is no common EU position on what constitutes vision impairment, let alone any other impairment or condition, should it be a case that the rules of a person’s own country apply?
4.4. Medium Term Measure
Ultimately, with proper implementation of universal design, the latter situation, at least, would be averted. As one of our members put it, “Having to go on to a register to get services because you have a disability, that’s discriminatory, like having to be registered blind…”.
So, it should be stressed that a European Disability Card is not an acceptance that the EU is diminishing, in any way, the obligations of universal design (CRPD, Art. 2), but rather, that it is about targeting interim supports and concessions in the public and private sphere, as a mitigation against the endemic institutionalised discrimination that currently exists, and which will take some time to melt.
5. Accessibility
5.1. Accessible Application Procedure
The following are necessary from a universal design perspective:
Application processes should be flexible in terms of communication types and easily and freely available to the applicant.
Multiple formats should be on offer, including combinations. For example, some people are happy using a combination of phone and email etc.
Any required documentation must be accessible by a visually impaired applicant. i.e., expecting a visually impaired person to source information from a third party when that third party refuses to provide said information in an accessible or useable format, the application process itself becomes inaccessible.
If photographic ID on the card is required, the process of obtaining and providing such ID should be independently accessible to visually impaired people.
5.2. The Physical Card
The card should contain Tactile and High Contrast Large Markings, and be distinctive from any other cards, so that even a sighted person could identify it by putting their hand in their pocket (i.e., without looking at the card).
5.3. Security
Since the card is likely to provide for concession rates, etc., is an item worth stealing. As such, the mechanisms by which a visually impaired person is expected to produce such a card should be very security-conscious. For example, a visually impaired person may not be in a position to positively identify the legitimacy of an official looking to examine such a card.
5.4. Virtual Card
For those who find it difficult to carry multiple cards, an app should exist whereby a disabled person can carry the European Disability Card on their smartphone. This could also be linked, via Bluetooth, so that neither the phone nor a card has to be openly displayed.
6. Scope
6.1. Free Travel
The card should cover free travel on public transport by sea, land and air. This would be analogous to the Free Travel Scheme in Ireland and the Disability Card in France, but using the best from both.
6.2. Accompaniment
A carer, or any other person accompanying a cardholder for the sake of assistance, should also benefit, equally.
6.3. Linkage to Social Services
The card should also include linkage to the EU 111 card or social services subject to EU data regulations.
6.4. Blue Badge and Equivalents
The card should be useable in the procurement of a ‘blue badge’ which allows for priority parking for disabled drivers and passengers.
Post-Submission Note
When making this submission through the online portal to the EU Commission, there was no option to declare that the submission was from a DPO. Instead, there was merely the options of “individual”, “NGO”, or “trade union”. As such, it appears that the EU Commission, in this consultation, ignores its obligations under the CRPD (cf. General Comment 7, para. 13), that DPOs be “distinguished” in consultations relating to disability. Beyond this, we can say that there is no evidence of the Commission implementing its obligation to “prioritise” DPOs in the consultation.
Furthermore, when making the submission as an NGO, the choices were:
Micro (1-9 employees) Small (10-39 employees) Medium (40-249 employees) Or Large (250 or more employees)
Since VVI continues to get zero supports from the State, we have zero paid employees. So, even though we are a very relevant and legitimate NGO (as a DPO), it appears that if we read “employees” as meaning ‘paid employees’, then we would be de facto barred from making a submission.
Since VVI has 16 unpaid reps (representatives), we have put this as our number of “employees”, even though they are employed in their task in a voluntary capacity. We have had no choice but to take this interpretation of “employed”, since otherwise the choices would have disabled us from making a submission.
We urge the EU Commission to up its game in terms of its obligatory compliance with Article 4 (3) of the CRPD, since on the evidence of this consultation, at least, it does not appear to be aware of those obligations.
In the Republic of Ireland, next stop announcements on buses were first introduced in 2012, and rolled out fleet wide on Dublin Bus services in 2014. Next stop announcements are also to be heard on Bus Éireann and Go-Ahead Ireland services. Such next-stop announcements are invaluable to visually impaired passengers, since before the introduction of these announcements, we had to ask Drivers to let us know when we reached our required stop, and often, the driver would forget – leading us on a magical mystery tour not of our choosing, and causing us to be very late for our appointments or discombobulated on eventual arrival at our destinations.
It should be remembered that if a visually impaired person inadvertently alights at the wrong stop, they are in immediate danger, since we may be totally unaware of our surroundings, and if we think that we are at our usual stop, when we are not, the probability of acidents greatly increases.
For over two years, now, as a result of the arrival of covid, windows have been left open for ventilation on both diesel and hybrid buses, making it very difficult and, at times, impossible for blind or partially sighted passengers to hear next stop announcements. Not surprisingly, this is causing us to miss our stops.
The sound of the diesel engine, artificial engine noise (AVAS) on hybrid buses; as well as the sound of the road surface, traffic, other passengers talking and, indeed, rain, significantly adds to the problem.
This is both an issue for passengers seated at the disability area on the right (as you board the bus), as well as those seated elsewhere on the bus.
A range of measures were introduced in April and May, 2020, following the outbreak of the covid-19 pandemic. These included blocking off seats to ensure social distancing, windows being left open for ventilation, and the wearing of face masks.
While covid-19 restrictions were largely lifted on February 28th, 2022, the legacy of windows being left open for ventilation is likely to continue for the foreseeable future.
The volume for audio announcements is fixed at a predefined level which Dublin Bus Drivers have no control over.
Also, our members have been told by Dublin Bus that if next-stop announcements are inaudible, that the driver will tell them their stop if they let the driver know in advance. This position is clearly untenable, since if such a system was workable in the first place (prior to the introduction of the announcements), then no announcements would be needed.
Photo (above) – ‘Keep Window Open – Coimád an Fhuinneog ar Oscailt’ signage on Dublin Bus.
1.2. Examples
Some examples of difficult to hear next stop audio announcements include:
Dublin Bus Route H1 (Diesel) short recording of next stop audio announcements mentioning the following stops: Strandville Avenue, Newcomen Bridge and Amiens Street.
Short recording of Dublin Bus Route 70 (Diesel) next stop audio announcements mentioning the following stops: Our Ladys Church, Kinvara Avenue, Ashtown Grove, Kempton, Ashtown Roundabout, Parkway Station and Peck’s Lane.
Short recording of Dublin Bus Route 37 (Hybrid) next stop audio announcements mentioning the following stops: Parklands, Castleknock Road, Oak Lawn and Castleknock.
2. Other Announcements Crowding Out Next Stop Announcements
2.1 Issues with information message announcements
Some information messages are causing next stop announcements to play late.
In addition to next stop announcements, Several other information messages currently play on Dublin Bus. These include:
a 30 second CCTV GDPR message;
an 11 second, “please hold the hand-rail” message; and
a 15 second “please stay behind the white line message”.
The messages are longer than they would be in English-only jurisdictions, since under the Official Languages Act (2004), messages are required to be in both English and Irish.
These play at random and the Driver has no control over them.
3. Added Imminent Threat of Return to Covid Messaging
Initially, the covid response was all about limiting the numbers of passengers on buses: in March, 2020, covid-19 restrictions set a 25% limit on the number of passengers permitted to use public transport. In the case of Dublin Bus, this amounted to a limit of just 17 passengers.
However, in May, 2020, A 37 second covid-19 message was introduced. This was problematic because, in certain scenarios, these covid announcements were causing next stop announcements to play late, particularly at off-peak times, where it took buses much quicker to get from stop to stop, reducing the amount of available time in the interim for other announcements to be made.
Dublin Bus Covid-19 message playing from May 2020 until February 2022.
The audio announcement system is not configured to allow for information messages to be interrupted by next stop announcements. This has a particularly adverse effect during off-peak times of 2 and sometimes 3 next stop announcements playing one after another. In contrast, it is not an issue at peak time, due to traffic and a steady flow of passengers boarding and alighting at most stops.
An additional 45 second ‘Covid-19 mask wearing exemption message’, rolled out on Bus Éireann City Services, was also due to be rolled out on Dublin Bus and Go-Ahead in early 2022. However, this did not occur, following the lifting of restrictions in February, 2022.
VVI first raised this issue with Dublin Bus over 2 years ago, and while the removal of the 37 second Covid-19 message in February, this year, effectively resolved the issue, the 30 second GDPR message is now playing more frequently, and again leading to situations where blind and partially sighted passengers are missing their stops. Again, this is particularly noticeable when travelling off-peak.
We requested Dublin Bus to either remove or shorten the message to something like ‘CCTV is operating on this bus – Tá CCTV i bhfeidhm ar an mbus seo’.
VVI has also alerted Bus Éireann to the difficulties caused by these information messages, which, again, are particularly noticeable during off-peak times, when there is light traffic and passengers are not boarding or alighting at every stop.
We raised this issue with the National Transport Authority, at a meeting, in July, 2022; and also at the Accessibility Consultative Committee of the Dept. of Transport on September 6th, 2022; but we have received no adequate response. The NTA said it would make sure that “essential” messages were prioritised, without making it clear that next stop announcements would be prioritised over all others.
With the winter approaching, we are concerned about a possible reintroduction of the Covid-19 message and, indeed, the mask wearing exemption message.
A combination of all these messages will cause mayhem for passengers who are visually impaired, particularly when travelling off-peak.
5. Simple Asks
Bearing in mind the requirements under EU Bus Regulations – including Regulation EU no. 181/2011 and s.i. no. 635/2020); as well as the new EU standards on passenger information (EN 17478): the safety of visually impaired passengers cannot be compromised by their missing essential stop information in a timely manner.
Accordingly, we request the following:
that volumes of announcements always be adequate, bearing in mind ambience noise; and
that next stop announcements be given full priority, in practice, in announcements on all bus routes, over any other announcements.
Since the 1980s, accessible automatic teller machines (ATMs), which allow customers to withdraw cash from their bank through a ‘hole in the wall’ at any time, have been a staple part of the banking experience for people throughout the world, including in Ireland. Despite the trends and pushes towards a cashless society, the ATM option is still taken for granted by the vast majority of people with accounts in the traditional banks.
In many developed countries of the world, this access has also been extended to visually impaired customers through audio (text-to-speech) feedback via headphones, i.e., through the provision of a working earphone jack on ATMs. However, in Ireland, this right of visually impaired people to access their own money on the same terms as their fully sighted comparitors has been very much the exception, and certainly not the rule.
Today, In the Republic of Ireland, only Ulster Bank has accessible ATMs. However, Ulster Bank is due to leave the Republic’s market in early 2023, leaving the country with no ATMs, whatsoever, accessible to visually impaired customers
Ulster Bank ATM, Main Street Blanchardstown
Photo (above) of Ulster Bank accessible ATM with headphone jack and text to speech (TTS) – Main Street, Blanchardstown, Dublin 15.
Two-minute audio clip using Ulster Bank accessible ATM
Ulster Bank describes its audio functionality on ATMs as follows:
“The ATM talk feature is available on all our ATMs when using the following services: Balance, Cash, Cash with receipt, Mini Statement, Emergency Cash.”
Ulster Bank
Information is heard through your own headphones once plugged into the ATM via the headphone jack. The number 5 key on the keypad must be pressed before you insert your card into the ATM to activate the audio function.
The screen will go blank keeping your details secure from others who may try to see your information when using the feature.
Full instructions are voiced to you at each stage of the transaction including how to use the service.
Positions of Other Banks, Recently and Today
In the past twenty years, in the South, other forays were made into the provision of accessible ATMs by other banks.
Danske Bank (Formerly National Irish Bank) had accessible ATMs with a headphone socket with text to speech functionality from 2005 until their closure in 2012. For example, many blind and partially sighted users recall using the atm on Dublin’s O’Connell Street.
Article from September 2005 discussing National Irish Bank’s six-month accessible atm pilot in Baggot Street, Dublin.
Allied Irish Bank (AIB) has a headphone jack on all its ATMs, however, text to speech functionality is not enabled on any of them. The AIB Branch in the Dundrum Shopping Centre (The Lab) had an accessible ATM with headphone jack and text-to-speech from 2012 until 2016.
In a query to AIB, in June 2017, regarding the national rollout of accessible ATMs, AIB said,
“We did have this on trial on the ATMs in the Lab and it worked well, however as this was only a trial it has not been in operation on the Lab ATMs for almost 12 months. At present we are not in a position to roll the solution out to all ATMs, but it is on our development plan. We plan to revisit this later in 2017 at which point we hope to have another upgrade completed that will enable us to progress the Talking ATM solution.”
AIB
But nothing happened. In August 2022, AIB stated
“There are no plans to upgrade them to include this on the ATM’s currently. All our ATMs have an adopted keypad that has a raised pip on the number 5 button. They also have new universal raised icons on the function keys for Enter, Clear and Cancel.”
AIB
It should be noted that while tactile interfaces are an accessibility prerequisite for visually impaired customers on all bank card machines (including ATMs and contactless payment facilities), without being able to ‘read’ what is on the screen, transactions for any customer would be virtually impossible. As such, without the text-to-speech function being enabled, visually impaired people are expected to be telepathic in order to know what options are being displayed on the screen; or in other words, the ATM, and their own money as cash, is inaccessible to us.
AIB ATM with headphone jack
Photo (above) of AIB ATM with headphone jack but no text to speech.
Bank of Ireland, told VVI, in August, 2022,
“At present there are no plans to introduce this service. We “At present there are no plans to introduce this service. We do however keep our service / functionality offering under ongoing review and Text to Speech has been added for consideration”.
Bank of Ireland
The Irish League of Credit Unions was contacted by VVI at the same time, and we still await a response.
KBC Bank Ireland told us that,
“KBC do not have any ATMs as we are a cashless bank, so unfortunately would not be able to advise you ATMs with this function”.
KBC Bank Ireland
Permanent TSB tell us
“ATM’s do not have a text to speech feature”.
Permanent TSB
The Situation in Britain and Northern Ireland
Mirroring AIB operations in the South, we are informed, regarding AIB Northern Ireland, that, “Our ATMs in NI do not provide speech guidance via a Headphone Jack”.
With regard to Barclays Bank, if you pop in your location online or by app, it’ll bring up all the branches and ATM’s in that area. You can then select ‘filter’ and “Internal or External with Audio” and this will narrow down all the accessible ATM’s in that area.
“Our ATMs do have an earphone jack with text to speech function to assist our customers with vision restrictions.”
Danske Bank (Norther Ireland)
Example locations in Belfast would be Lanyon Place Railway Station and Castlecourt Shopping Centre.
Halifax UK tell us that:
“You should be able to select the audio function at most of our ATMs. Just plug in your standard headphones to hear what’s on the screen. Some of our older cash machines don’t offer this yet, and we’re changing these. Ask someone in branch or give us a ring to find your nearest Talking ATM.”
Halifax UK
HSBC UK tell us:
“Yes, we have Talking ATMs. Talking ATMs are easy to use. Plug Yes, we have Talking ATMs. Talking ATMs are easy to use. Plug in your headphones and you’ll receive audio prompts rather than having to read the ATM screen.”
HSBC UK
How to access it: You just need your bank card, PIN and a standard pair of headphones (3.5mm jack).
“You can select the audio function (Talking ATMs) on our Cashpoints. Just plug in your standard headphones to hear what’s on the screen. Our older machines may not have this service, but we are working to update them.”
Lloyds, UK
Natwest UK tell us:
Our own brand ATMs do have the option with an earphone jack and can be used as follows.
You need to have a set of earphones which you plug into the ATM.
You will then hear instructions of how to use the machine and what to do to get started.
You need to activate the audio functionality by pressing the number 5 on the keypad before inserting your card.
The machine will voice out what you need to do and the options to press on the ATM keypad to make your choices.
The screen will go blank to provide you with privacy so none of your details are visible
The full details of this can be found on our website under Talking ATMs.
The earphone jack would be below the place to insert the card on the machine, to the right-hand side of the screen.
Santander UK tell us that they are “glad to advise that our machines do indeed have this functionality.”
The Situation in Germany
Commerzbank: Awaiting reply.
Deutsche Bank: Awaiting reply.
DKB tell us, “We do not offer this service”.
DZ Bank: Awaiting reply.
HypoVereinsbank – UniCredit tell us:
“Our ATMs do not have a earphone jack or TTS. But you can ask in the respective branch for a so-called blind foil incl. explanation via audio CD.”
HypoVereinsbank
Santander Deutschland: Awaiting reply.
Sparkasse Germany tell us:
“Most of our ATMs are equipped with an earphone jack and a text to speech. The number-pads also have braille.
Sparkasse Germany
European Accessibility Act (EAA)
In the Republic of Ireland, regulation and accountability should be on the way, according to the EU Directive known as the European Accessibility Act (DIR (EU) 2019/882), which means that all self-service terminals such as ATMs will have to be accessible to visually impaired people. But given Ireland’s record of doing the minimum required when it comes to transposition of rights-based international law, a worst-case scenario could see Ireland deferring of the compulsory installation of accessible ATMs until after June, 28th, 2025, and for inaccessible ATMs to be kept in operation until June 28th, 2045.
Ireland was obliged to have the EAA transposed to Irish law by June 28th, 2022, but when VVI last asked the Dept. of Children, Equality, Disability, Integration and Youth about its progress, on July 7th, this year, we were informed that there were some technical legal difficulties which had delayed its implementation.
As we’ve been doing since July, 2021, We reminded the Department that VVI (as a Disabled Persons Organisation, a.k.a., representative organisation, or “organization of people with disabilities”), needs to be closely consulted and actively involved in the transposition of the EAA (as per Article 29 (b) of the Act, and Article 4 (3) of the UN Convention on the Rights of People with Disabilities.
The Department has an abysmal record regarding its obligations under Article 4 (3) to closely consult with and actively involve VVI in such decision-making processes, let alone discharge its more general functions under the same Article, but we are hopeful that the State will begin to mend its ways and acknowledge VVI’s rights, as a representative collective, under international law.
Conclusion
As visually impaired people, we salute the best practice consistently employed by Ulster Bank, but it is a shameful commentary on attitudes to accessibility in the Republic that with the departure of Ulster Bank from the market, there will be no more accessible ATMs in the country. It can be seen by the above comparisons, in particular with the UK jurisdictions, that the Irish banking sector is a total laggard when it comes to accessible ATMs, and from the lived experience of our members, things do not improve much in other aspects of the banking service in the Republic, either.
Ulster Bank should never have been the odd-one-out in terms of ATM accessibility, in the first place. Light-touch regulation of the banks go back to Thatcherism in Britain and the North, and yet, this has not meant that the rights of visually impaired people have been neglected in terms of ATMs, at least. So, it is not credible that the Republic’s infamous light-touch regulation of the banking sector can be said to be the only reason for its abysmal record on accessible ATMs.
VVI expects its right to be prioritised (as a DPO), in consultations on the pending transposition of the European Accessibility Act, where, among other things, we would advise that the obligation of all operators in the banking services industry to provide accessible ATMs be given a much swifter timetable, especially in recognition of what we’ve had to put up with for the past forty years or so in this regard.
We are Voice of Vision Impairment (VVI). VVI is Ireland’s representative organisation with specific regard to the Human Rights of visually impaired people. In Ireland, organisations with this representative status (as per the Convention on the rights of People with Disabilities (CRPD), are more often known as Disabled Persons Organisations (DPOs).
A DPO must have Human Rights campaigning at its core, must have a clear majority of its members with the particular impairment for the respective constituency being represented (visually impaired people in our case), and must be led, directed, and run specifically by such people.
The UN committee overseeing the CRPD notes that DPOs should be prioritised, in decision-making processes affecting disabled people, over all other civil society organisations, and especially disability service providers (such as those funded under Sections 38 and 39 of the Health Act, 2004), since the latter may have a “conflict of interest” in trying to be service-provider and advocate at the same time (cf. CRPD General Comment 7, paras. 13, 14, 23, 56, 57 etc.).
As mentioned below in more detail, the State has, up until now, ignored its legal obligations towards DPOs, including those of supports and resourcing. As such, because of our relatively low resources and zero supports from the State or otherwise, VVI may not be able to produce submissions to the glossy standards of disability service providers. For example, we are relatively short on costings when it comes to our proposals, often due to the state-funded documentation being totally inaccessible to those of us using screen-reading technology.
Nonetheless, our “views and opinions” must be prioritised over all other civil society organisations by public authorities when it comes to disability (ibid., para. 23), and our desiderata, below, are principles either directly mentioned in the CRPD, or as fitted by us to the Irish context of the lived experience of visually impaired people – an approach which prioritises the voice of the least resourced and least supported individuals, and which is a sum of the pooled experience and collective expertise of our members.
Note on Language:
We use “visually impaired” or “vision impaired” to describe people who are blind or partially sighted, respectively. In this designation we are at one with the language of the CRPD. Our differentiation between “blind and partially sighted” (not blind and visually impaired), is at one with the language used by European Blind Union and the World Blind Union. However, first and foremost, this language reflects the prevailing opinion among our members.
We say “disabled people” – with “disabled” being a verb, not an adjective – to highlight that while people may be born with impairments and diversities, “disability” is a social construct, meaning that people are disabled by bad design, planning, and attitudes, mostly caused by insufficient knowledge. This “disabled people” language is in line with the social model of disability embraced by the CRPD.
2. State’s Legal Obligations regarding resourcing of DPOs
As part of the State’s obligations under Article 4 (3) of the CRPD, which took immediate effect in 2018 (cf. General Comment 7, para. 28), The UN Committee says that the State should ring-fence core institutional funding for DPOs (ibid., para. 61 (d)), while ensuring DPOs are autonomous in deciding their advocacy agenda, despite the funding received (ibid., 61 (e)).
Since, in Ireland, there is a strong historical legacy and tradition of non-DPOs (and in particular disability service providers) colonising the “representative” space, real representation (through DPOs) is in a fledgling state, and is operating in hostile territory. Since all of our representatives are themselves disabled, and since all our workers, including representatives, are volunteers, it is imperative that we receive appropriate supports from the State in our empowerment and capacity-building (ibid., paras. 13, 39.
To paraphrase the UN Committee: ‘The barriers faced by disabled people in accessing inclusive education compromise their opportunities and undermine their capacities to be involved in public decision-making, which, in turn, have an impact on the institutional capacities of their organizations. The barriers in accessing public transport, the lack of reasonable accommodation, and low or insufficient income and unemployment among disabled people also restrict the capacity of such persons to engage in civil society activities.’ (ibid., para. 59).
Asks (2):
That the DCEDIY set up a register of DPOs (ibid., paras. 44, 61, 94 (t)), along the lines set out by the UN Committee (ibid., paras. 10-14).
Genuine DPOs should then receive core institutional funding and regular information and other supports by the State in accessing all types of funding. Also, other supports may be required from the State by DPOs which don’t involve funding, and these should be determined through close consultation and active involvement of DPOs (ibid., paras. 60, 61, 80, 94 (b).
One source of funding suggested by the UN Committee is the national lottery (ibid., para. 64).
A policy and legislative framework is required to embed DPOs into decision-making processes, at all levels within the State (cf. ibid., paras. 94 (b, e, f, etc.).
Building Consultation with DPOs into Budgeting of all Statutory Bodies should be an earnest objective, but for this to be comprehensive, their capacity-building is a prerequisite.
3. Funding Related to Disability-specific Services
3.1. Additional Funding for Disability Service Providers
The Dept. Of Health’s Disability Capacity Review (July, 2021), shows the massive extent to which the State currently relies on charities to provide core and essential services to disabled people. Not only is this outsourcing of responsibilities by the State to private NGOs less amenable to accountability, transparency, and scrutiny – in contrast to services directly provided by the State – for example, through integrated Universal Design – but on a very basic level, Human Rights should not be dependent on charity.
Ask (3.1):
At a minimum, any additional State funding of disability services needs to be disability-proofed by DPOs (see Article 4 (3) of the CRPD as clarified by General Comment 7); and Public Sector Equality Duty in the Human Rights Commission Act (2014, S42).
Such disability-proofing must have as a precondition of State funding to disability service providers that they are not directly or indirectly interfering with the representative rights of DPOs, for example, as set out in the CRPD (see General Comment 7, para. 51).
In other words, State funds must never be allowed to be spent on anything that directly or indirectly undermines the capacity of DPOs. This includes, for example, any funding of advocacy by disability service providers (paying the lobbyist), and ensuring that all State funded operations that inform visually impaired people about disability service providers must also inform them about their DPOs, and facilitate their joining of DPOs.
3.2. Specific Services and Accountability (context and ask)
Braille as an Example:
There are three providers of braille transcription services in the country, and public authorities generally pay for these services when they receive requests from citizens looking for materials in braille.
Such service-provision must meet the requirements of the end-user, and not be dictated by the service-provider. For example, a coalition of braille transcription service providers, in 2013, decided that they would suddenly change from producing all documents in Standard English Braille to producing all documents in Unified English Braille. There is only two clicks of a mouse in the production software interface between the two. This wholesale and steadfast change seriously discommodes most visually impaired people who have learnt braille before 2014, and is discriminatory.
Where contracts exist with these contractors, they must be regularly reviewed with close consultation and active involvement of the relevant DPO(s), and in particular with VVI (cf. VVI’s Policy on Accessible Communications, Section 5).
In December, 2021, the long-awaited INDECON report into the cost of disability (commissioned by the State), was finally published. The cost of disability to those who have a severe vision impairment (i.e., who are blind), is said to be between €9,805 – 10,565 per annum.
Even forgetting for a moment the inflation which has hit the country since the publication of the INDECON Report, we believe these costings to be a massive underestimation for two reasons:
i). The INDECON Report did not factor in that blind people are fifteen times more likely to be without paid employment than their sighted comparitor. Being unemployed due to institutionalised discrimination not only has a clear negative impact on income, but has concomitant knock-on effects which were not covered in the report. In other words, being “unemployed” is a cost in itself.
ii). the methodology of the research inadvertently, but necessarily, excludes visually impaired people with the least resources and supports – i.e., those with the highest disability costs. For example, the quantitative side of the research was based on online surveys, which necessarily exclude visually impaired people on the other side of the digital divide (which is common, for example, when people lose their sight), as well as those who do not have adequate internet access.
As mentioned above, according to the 2016 Census, at least 76% of those with a severe visual impairment in the relevant age-brackets are not in paid employment. Whereas Welfare payments are generally kept low as an incentive for the recipients to seek paid employment, the institutionalised and practical barriers to paid employment are clearly too high for visually impaired people for this approach to be justifiable. As equal Irish citizens, we deserve dignity of life and equal opportunity.
Inflation
In October, 2221, when Budget ’22 was announced, inflation was at 5.6%. The 2.46% increases to Disability Allowance and Blind Pension did not even match this, and worse again, this increase did not take effect until nearly three months later, so that the increase effectively amounted to a mere 1.845%, an effective impoverishment of recipients.
As of August, 2022, the annual inflation rate stands at 9.1%. A Social Justice Ireland report (July, 2022), estimates that this rate is higher among poorer households, standing at 10.8%, since they spend a higher proportion of their incomes on energy and food. As per the INDECON Report (2021) and Census ‘16, visually impaired people come under the latter category.
Asks (4.1): to mitigate against the current institutionalised disabling of people from our right to employment, and our consequent impoverishment; at the very least, core disability-related benefits need to be increased to meet the increased cost of living of their recipients. This also includes a reparation of their impoverishment in Budget 2022, as well as future-proofing against the expected continued inflation for 2023. In effect, this amounts to a minimum of 20% increase in Blind Pension and Disability Allowance. At a bare minimum, disability benefits should be brought to match the non-contributory State pension.
4.2. Basic Income Based On Average Industrial Wage
Given the extraordinary relative impoverishment of disabled people set out in the INDECON Report, and the institutionalised high levels of unemployment among visually impaired people, in particular, shown in Census 2016, there is a clear need for a basic income for visually impaired people, at least, based on the average industrial wage (a system which has pertained for a very long time in Norway). This does not negate the right of visually impaired people to be employed in meaningful work that suits their interests and skills, but rather, it facilitates their pursuit of productive interests and capacity-building for such employment opportunities.
Furthermore, the process of means-testing for visually impaired people is very often inaccessible, meaning that we must rely on the charity of acquaintances to procure and send evidence of capital, income, and expenditure – which are often not obtainable in accessible formats.
Asks (4.2):
For budgets to come, we ask that basic income be considered for all visually impaired people, at least for as long as the unemployment rates are so high (i.e., for as long as there is clear institutionalised biases and practical issues with blind and partially sighted people being employed. Effectively, this means that all visually impaired people should have a minimum basic income at one with the average industrial wage.
In terms of a basic income for visually impaired people based on the average industrial wage, the simplest way of achieving this is through increases to the Blind Welfare Allowance (see 4.2 and 4.6 below).
As a minimum interim measure, disability-related payments by the State to visually impaired people should not be means-tested.
4.3. Non-Contributory Pension
Because of the inaccessibility of means-testing for most visually impaired people, the State’s forcing us to jump from Blind Pension or Disability Allowance to the Non-Contributory Pension as we reach 66 years of age poses a significant challenge, and one that relies on the help of third parties – which in turn compromises our security, as well as GDPR rights in conjunction with reasonable accommodation rights.
Also, forcing someone to do this based on a particular age cut-off point is surely discriminatory on the grounds of age, and completely unnecessary.
The rate of the non-contributory State pension, at €242 per week – although higher than that of the Disability Allowance or Blind Pension, etc., is still far short of that necessary for a minimum standard of living (MESL) as shown by the Vincentian Partnership for Social Justice (VPSJ) on an annual basis, and as with disability-related benefits, should be raised to meet such basic living requirements.
Ask (4.3):
That visually impaired people be allowed to continue collecting Blind Pension, Disability Allowance, or other disability-related core payments, for as long as they need, without having to shut that door and go through the threshold of the non-contributory pension process.
that the non-contributory pension rate be raised to meet minimum living standard requirements and to counter inflation.
4.4. Anomalies Between Different Payments to Disabled People
Capital Disregards
Currently, the basic capital disregard for anyone applying for or in receipt of the Disability Allowance is €50,000, counting to €70,000; but equivalent disregard for people in receipt of the Blind Pension or Non-Contributory Pension is €20,000 counting to €40,000.
Such an anomaly is unjustifiable, and appears to have arisen from oversight. Furthermore, it is at least indirect discrimination on the grounds of disability, given the practical difficulties confronting anyone in receipt of the Blind Pension if they wish to opt to collect Disability Allowance instead.
None of these capital disregards have taken account of inflation since they were introduced, an anomaly easiest fixed by removing the requirement for means-testing for such benefits.
Another disablist anomaly can be illustrated in the scenario where a parent has exercised responsible duty by ensuring that a visually impaired child receives an equal share of the estate in their will. Indeed, the parent might want to leave a greater proportion to the disabled child, according to cushion or alleviate their long-term needs (such as extra costs of living and less overall independence). As things stand, perhaps in most cases, such a bequest would mean that the visually impaired child would have to give up their State benefits until they have run through the capital left to them by their dutiful parent. This might be contrasted with a non-disabled sibling who is likely to be in employment, and can invest the capital and get the full benefit of it.
Other Anomalies Regarding Rates and Circumstances
There are no disregards for partners or spouses on Blind Persons Pension, but some disregards for these in relation to Disability Allowance
While on Disability Allowance, full Medical Card entitlements are allowable up to an income of €427 per week, but with the Blind Persons Pension, no extra earnings income is permitted for a recipient to retain their Medical Card benefits.
Ages of Eligibility of Benefits
The number of recipients of the Blind Pension has decreased by 23.5% between 2015 and 2022, from 1,341 to 1,026 (Oireachtas.ie, PQ 84, 22.5.17). This can be explained by the relative advantages of the Disability Allowance, not just in terms of the capital disregard already mentioned, but also because the Disability Allowance is receivable from the age of 16, whereas the Blind Pension is eligible from the age of 18.
This anomaly, whether or not a result of oversight, can only lead to the dwindling to zero of the number of recipients of the Blind Pension. The ESRI report (2018) based on the Quarterly Household Report returns of 2017, found that visually impaired people are ten times more likely to be on the receiving end of discrimination than any other disability (apart from psycho-social impairments, which are still behind visual impairment in this regard). As such, the retention of a specific core payment to cater for the needs of visually impaired people is advisable.
Asks (4.4):
that all capital and income disregards for visually impaired people in receipt of State benefits be changed to being uncapped or unlimited. This would cost the State nothing, but would alleviate life-long impoverishment of many visually impaired people. At the bare minimum, all such capital disregards should be equalised and substantially raised.
that all other anomalies that put visually impaired people in receipt of benefits other than the Disability Allowance be ironed out so that they are no longer discriminated against in this regard.
All of these anomalies are unjustifiable, and appear to have accrued by neglect rather than design. In particular, the Blind Pension should be put on a par with the Disability Allowance in all respects as soon as possible. Since there are only slightly more than a thousand people in receipt of the Blind Persons Pension, fixing these discrepancies should not be onerous.
that visually impaired people be eligible for the Blind Pension from the age of 16 (as with the Disability Allowance).
4.5. State Benefits as Taxable Income
The Blind Pension and Disability Allowance, respectively, are classed as taxable forms of income, which effectively means that in many instances, increases in rates of such payments, as well as supplementary benefits such as Living Alone Allowance, and Household Benefits Package, are cancelled out by rent increases by Approved Housing Bodies and Local Authorities, which are calculated based on taxable income.
Ask (4.5):
No disability-related payment should be a taxable income for visually impaired people.
4.6. Blind Welfare Allowance (BWA)
BWA is provided by the HSE to blind people living independently who are “unemployed”, at a current rate of €63 per week for a visually impaired individual, and €120 per week for a blind couple.
Currently, it appears that the Blind Welfare Allowance is seen as taxable income, at least by Local Authorities and Approved Housing Bodies, when calculating rent. Given the massive cost of living evidenced in the INDECON Report, and the tremendous impoverishment of visually impaired people as a consequence, it should be seen as unconscionable that what little cushion there is to ameliorate such costs be clawed back by other arms of the State or its agents.
The BWA is currently means-tested, but, since such a stipend should be based on the extra cost incurred as a result of visual impairment, it should apply to those of all incomes who are eligible in terms of being determined to be “blind”, or severely visually impaired; with a secondary non-means-testable rate for those who are partially sighted (e.g., as defined by the NHS).
Currently, an eligibility component of the BWA is “a letter from the National Council for the blind of Ireland (NCBI)…NCBI is the national sight-loss organisation. They can confirm whether you meet the criteria to register as blind” (hse.ie).
However, as we understand it from the NCBI itself, the NCBI is in no position to confirm whether someone meets the criteria of being blind – this being an ophthalmological determination, and because there is no longer a “register” for blindness at the NCBI or anywhere else, for that matter.
Also, the designation of the NCBI as “Ireland’s national sight-loss organisation” is self-declared, and in violation of the CRPD, and does not belong on State-produced material, such as the HSE website (hse.ie).
The BWA rate is €63 for a single person. This amounts to €3.276 per annum, not remotely covering the cost of disability incurred by visually impaired people receiving it, according to the INDECON Report measurements mentioned earlier.
Asks (4.6):
that Blind Welfare Allowance no longer be classed as taxable income, and not to be included as income in any means-testing. It is there to help counter the cost of disability, not as a luxury.
In the absence of any other compensatory mechanisms commensurate with the cost of visual impairment, the Blind Welfare Allowance must be increased four-fold in order to meet the costs of visual impairment and to help counter the inflationary situation the country finds itself in.
In the absence of other necessary supports, such as a basic income based on the average industrial wage, the Blind Welfare Allowance should be available to all visually impaired people, and not be means tested.
Any reference to the NCBI regarding Blind Welfare Allowance should be removed from the State’s information on eligibility criteria.
4.7. Accessible Application Processes for State Benefits and Awards
As Visually impaired people, we have the right to independently access our entitlement to supports and services, including those relating to social protection (cf. CRPD, Article 9 (1). However, as mentioned earlier, application processes involve paperwork which is often not independently accessible to visually impaired people.
This means that not only do visually impaired people find it incredibly difficult to apply for their Welfare entitlements (as already mentioned), but they are also far less likely to avail of more specialist or one-off supports for the same reasons. Examples of such specialist or one-off application processes include:
Medical Card application and review/renewal
Reasonable Accommodation Fund
Back to Work Enterprise Allowance
Short-term Enterprise Allowance
VJT 61A (Revenue Commission’s form for tax-back on assistive or accessibility-related products regarding visual impairment).
Technical Aids Grant
Disabled Persons Grant Scheme
Housing Adaptations Grant
Mobility Aids Grant
SUSI (third level education grants)
Ask (4.7):
In close consultation and active involvement of VVI, all relevant public bodies to create a system based on Universal Design, which builds reasonable accommodations, as a default, into their regulations and standard operating procedures.
Also, many visually impaired people – especially where there has been recent sight-loss – will not be able to access information on what they are entitled to. Statutory bodies need to have incorporated into their budget a social work service that will let visually impaired people and other disabled people know what benefits they are entitled to, and to assist them in such applications with regard to that public body. This may be more efficient as a one-stop shop within the Department of Social Protection (DSP).
The more that public transport fares are reduced to encourage the general public to use public transport, the less justifiable become the costs of ticketing and revenue protection on such services.
As things stand, ticketing is generally inaccessible to visually impaired people, and visually impaired people cannot independently identify revenue protection officers in a secure manner. Furthermore, some of our members have not been able to obtain the Public Services Card because they have found the application system to be inaccessible.
Ask (5.1):
We recommend that public transport be free at the point of use for all passengers. This not only makes the entire public transport system much more accessible to visually impaired people, but makes it more accessible for everyone. The savings in ticketing, revenue protection, and time costs, should ensure that the overall cost to the commonwealth is decreased, and by the same measures, that the greater public good is being served through encouraging more environmentally sustainable modes of travel. This remedy will require much higher investment in public transport infrastructure to meet the extra demand.
5.2. Active Modes of Transport
Very often, it is not safe for visually impaired people to cycle, and for obvious reasons, driving a car is not legally or morally possible. As such, we depend on “lifts” from friends and relations (especially if living in the country); on walking, where possible; and on public transport. Walking requires safe and accessible street-scapes; is limited in terms of distance; and can make it more difficult to find one’s destination (e.g., a first-time specialist’s appointment and No. 83 Main Street, etc.).
As such, cycling and walking (active modes) are not remotely adequate in journey completion for visually impaired people as compared to the general population.
Like you, we have a Human Right to access our community and environment on an equal basis with everyone else. This means that we must be able to access all areas, whether by blue badge private vehicles, taxi, or bus, etc. Anything else (e.g., pedestrianisation) necessarily constitutes a disablist planning zone.
Ask (5.2):
As is our right as a DPO under Articles 4 (3) and 9 (1) of the CRPD, we request that all funding on active Travel modes be contingent on accessibility audits that conform to Article 4 (3) of the CRPD – namely “close consultation and active involvement of…representative organisations” (i.e., DPOs).
A useful starting point is our Manual of Accessible Planning for Pedestrians (MAPP):
This precondition will have long term cost benefits, since it will facilitate the independence (economic and otherwise) of our ageing population, as well as fulfilling the State’s obligations to our DPO members.
5.3. Consultation on Sustainable Development Goals
The UN Committee points out that part of the States obligations to “closely consult and actively involve” DPOs (as per Article 4 (3) of the CRPD), relates to, for example, the UN Sustainable Development Goals (2030) (General Comment 7, paras. 9, 92, 94 (r)). So far, in Ireland, this obligation has been neglected or otherwise ignored, across this entire area, including the Climate Action Plan.
Ask (5.3):
In line with the State’s obligations under Article 4 (3) of the CRPD, and with the Public Sector Duty (IHREC Act, 2013, S42), disability-proofing, through close consultation and active involvement of DPOs, needs to be a precondition of any funding related to the 2030 Sustainable Development Goals.
5.4. Visually Impaired Passengers.
The EU Parking Permit scheme for disabled drivers and passengers means that blind passengers (along with severely physically impaired passengers/drivers) have disabled parking rights.
However, particularly in rural areas, where visually impaired people do not have adequate access to public transport, we are often totally reliant on being driven to doctors’ appointments, to community events, to work, etc. Unlike our sighted comparitors, we do not have the option of cycling. Similarly, in a household, where both parents would be able to co-ordinate school-runs etc., where one parent is visually impaired, the availability for work of the other partner is often compromised by having to make such school-runs or drop children off to bus-stops etc.
Ask (5.4):
Visually impaired people have a comparatively restricted ability to engage in “active modes” of transport, and as such, it is an anomaly (and discrimination on the basis of disability) that they are not also eligible for the Disabled Drivers and Disabled Passengers Scheme, which provides a range of tax reliefs linked to the purchase and use of specially constructed or adapted vehicles by drivers and passengers with a disability. Visually impaired people may not need adapted vehicles, but the necessity of their being driven should be reflected in the same tax reliefs and toll exemptions, i.e., as set out in the Disabled Drivers and Disabled Passengers (Tax Concessions) Regulations 1994 (SI 353/1994) as amended.
5.5. Accessibility as a Precondition for Public Transport Licensing
There has been a trend, in recent years, towards the further opening up of public transportation to private operators. It is essential that such licencing by the National Transport Authority (NTA) is dependent on accessibility to disabled people in general, and from our perspective, to visually impaired people.
Ask (5.5):
That all future license-granting by the NTA to private operators be dependent on disability proofing in line with Article 4 (3) of the CRPD.
5.6. Removal of VAT on dog-food for guide-dogs.
A guide dog is an aid to visually impaired people, both for independent living and mobility. As such, the costs of maintaining them should be vat exempted, as is the case for adaptive technology, which also can be seen as an aid to independent/living/mobility.
Currently, users of guide-dogs must pay 23% VAT on everything necessary for the maintenance of the guide-dog (such as dog-food which is of prime quality for working dogs).
Ask (5.6):
VAT should be removed from all purchases necessary for the maintenance of guide dogs (both working and retired).
6. Housing and Independent Living
6.1. Needs of Visually Impaired People in being Allocated Housing
Currently, there is no agreed standard as to what constitutes Universal Design in State-supported housing – notwithstanding an out-of-date paper by CEUD, in 2013). The prevailing ethos (e.g., DHLG, Disability Housing Strategy, 2022), concentrates on accessibility for wheelchair users (which, of course, in itself is essential). However, Universal Design must also take account of the needs of visually impaired tenants, and to that end, Article 4 (3) of the CRPD is once more a statutory obligation. In other words, it is an obligation under international law that the State prioritise DPOs, in general, regarding the compilation of a Universal Design standard, but that in particular, with regard to visual impairment, VVI is prioritised on all levels.
Also, the designation of Approved Housing Body status to any disability service provider in this respect, against the wishes of DPOs, is necessarily repugnant to the CRPD.
Ask (6.1):
That the Housing Agency “closely consult with and actively involve” VVI in a statutory minimum standard on “Universal Design” as applied to public and private housing, with regard to new builds, and state-subsidised retrofitting.
That no AHB status approval be given to any disability service provider without this first being agreed with the relevant DPOs. In this case, since VVI is the national DPO concerning visual impairment, specifically, VVI must be closely consulted and actively involved, as well as our views and opinions prioritised, in such consideration.
6.2. General DPO Prioritisation in Consultations
Currently, there is no provision for prioritisation of the “views and opinions” of DPOs (General Comment 7, para. 23), nor distinction of DPOs (ibid., paras. 13-17) in the Disability Housing Strategy (2022-7).
As with section 2, above, it is an obligation on the State to make sure that DPOs are afforded those rights, including in what is often referred to as ‘stakeholders’ in the area of housing, and this must be remedied in order for Ireland to be compliant with its obligations under the CRPD (Article 4 (3) and 19). This will also involve an obligation for Local Authorities to capacity-build DPOs.
Ask (6.2):
That the DHLG, Housing Agency, and Local Authorities have distinct and prioritised consultations with DPOs regarding housing and disability.
6.3. Housing-Related Data
Currently, the DHLG have shoe-horned Deaf, Deaf-blind, hearing impaired, neurodiverse, and visually impaired people into the one category, i.e., “sensory impairment”, and even worse, the medical model language of “people with a sensory disability”.
Impairments in sight and hearing have totally different consequences. The impacts, apart from the general disabling by society, are chalk and cheese. Lumping these categories in together might be handy from a disinterested statistician’s perspective, but not where one is interested in the actual differences in housing take-up and subsequent results.
Ask (6.3):
That the DHLG be required to separate its statistical categories according to the various types of sensory impairment (Deaf, hearing impaired, deaf-blind, and visually impaired), as well as a separate category for neurodiverse people. This will allow additional funding, where necessary, to be targeted, not only in usual housing services, but also in terms of homelessness services.
6.4. Minimum of 2-bed Allocations for Visually Impaired Individuals
Many visually impaired individuals in public housing have no choice but to remain in hospital when recovering, thus, inadvertently “bedblocking”, since they live alone in 1-bedroom dwellings, and as such, cannot have full-time care from extended family, community, or professionals in their own home. Generally speaking, also, visually impaired people living alone may require more room to house assistive technology, guide-dogs, and more room to avoid trip-hazards, such as placement of clothes-dryers etc.
Ask (6.4):
That Housing allocation for visually impaired individuals allows them a minimum of 2-bedroom dwellings.
6.5. Homelessness
Homelessness is a terrible situation at the best of times, but 26% of people suffering from homelessness are also disabled (ESRI-IHREC, Discrimination and Inequality in Housing in Ireland, 2018). This over-representation, as with other inequalities, is not coincidental.
Asks (6.5):
that visually impaired and other disabled people be fast-tracked out of homelessness as a priority.
that in close consultation with VVI, that homelessness authorities identify those homeless accommodation facilities which are most accessible to visually impaired people, and that placements be made, as priority, accordingly.
6.6. Home Supports
Many people with a visual impairment require additional assistance with tasks that others might think as straightforward, such as cleaning of rooms, assistance in travelling, and even simple DIY tasks such as safely changing a lightbulb, the railing or re-railing of curtains, replacing a fuse in a plug, etc.
VVI has published a position paper on traditional home support services (December, 2021):
However, there are two areas which need more investment from the State in this regard: namely, personal assistance for visually impaired people; and the provision of tradesperson-related assistance.
In terms of personal assistance, visually impaired people may require assistance, such as in browsing in their local library, including more specialist possibilities such as the need for a personal assistant to be proficient in a second language, such as Irish. Such additional support requires more investment in personal assistance provided by the State. In terms of assistance to visually impaired people, in particular, remote personal assistance, such as that provided by AIRA, should be seen as an intrinsic option supported by the State, where preferred by the visually impaired person.
In terms of tradespeople, some tasks are more specialist. For example, the pressure on the water may be low, but a visually impaired person cannot access the interface on the boiler to raise it; or on some makes of washing-machine, the filter is at the back, and cannot easily be removed when required to be cleaned –causing a breakdown in the washing-machine.
Asks (6.6):
That more investment be made in PA hours for visually impaired people, including, where sought, remote PA services, such as those provided by AIRA.
that a system of State-subsidised trades in the home be organised with a view to providing solutions to emergency and daily needs of visually impaired and other disabled people.
In its prebudget submission (July, 2022, p.9), the Oireachtas Joint Committee on Disability Matters writes:
“The Committee believe that funding strategy needs to move to individualised funding and a needs-led system where an assessment of people’s needs would be undertaken to allow for direct resource allocation to meet the needs of each person. Those could be personal care needs, social inclusion needs, etc. The Government must implement the personal budgets pilot to enable a model of delivering disability supports as a personalised budget which has autonomy, independence, and community inclusion for people with disabilities at its core”.
Oireachtas Joint Committee on Disability Matters (July 2022)
We have concerns about this approach, from a visually impaired perspective. Apart from the bureaucratic costs in determining individual budgets, which can be arbitrary and be a fiasco, as with the PIPS in Britain, visually impaired people are often denied access to the so-called free market by virtue of the fact that advertising and availability of services is not communicated in a form accessible to us. Also, clearly, different parts of the country will have varying qualities and amounts of service-provision if things are left to the ‘free market’, and indeed, if a Regulator, down the line, is necessitated, things get even more bureaucratic in terms of wasted resources.
Ask (6.7):
That nothing be done regarding a change of funding strategy to personalised budgets without prior close consultation and active involvement of DPOs (including VVI).
7. Health
7.1. Accessible Health Services
Throughout Ireland’s health service, there persists basic and universal inaccessibilities and disablist practice. For example, we often hear of hospitals complaining about ‘no-shows’ of outpatients for medical appointments; but it is our experience that accessible communications from hospitals to visually impaired patients (e.g., as per the Disability Act, S28), are the exception rather than the rule, and have to be fought for by the outpatient, on each and every occasion.
Similarly, medical staff rarely appear to have received adequate training in how to safely guide a visually impaired person or to understand other access needs.
In terms of systems, The systems set up for vaccination and antigen-testing for covid are intrinsically inaccessible to visually impaired people – with VVI’s offers to advise on our needs from the outset being effectively ignored by the HSE and Dept. of Health.
Ask (7.1):
Adequate funding must be identified for the adequate training and setting up of accessible communications systems by medical staff and institutions, as well as public authorities, themselves.
in all funding and contracts, a stipulation must be accessible services and communications: cf. VVI’s Accessible Communications Policy
Context and ask: Given the extra costs of being visually impaired, often involving greater need to use health services, all visually impaired people should be eligible, by default and without means-testing, for a general services medical card.
Because restoration of lost vision is an infinitesimally rare occurrence, and because renewal processes are intrinsically inaccessible to many visually impaired people, visually impaired people should have indefinite entitlement to the medical card.
7.3. Medical Prescription
Medical prescription charges of €1.50 are charged to medical card holders getting items on prescription from pharmacies. Such a tax is regressive, since it cuts at the poorest in society; and it is also cruel, since it penalises medical card holders for their reliance on essential medicines or medical products. This latter point also means that by its nature, the charge is disablist.
Prescriptions regarding medicines for long-term conditions are currently required to be renewed by the service-user every three to six months, creating much unnecessary bureaucracy, as well as unnecessary hassle for the person with the long-term condition.
Ask (7.2):
That all medical prescription charges be dropped for medical card holders (which would, effectively, be a return to the situation as it was in 2009 and before).
that prescription-renewal obligations for medicines pertaining to long-term conditions be got rid of. When the patient dies (and the prescription comes to an end), the pharmacy concerned can be required to refund the State the amount it has received from the State in lieu of the medicines acquired, but unused, for that particular prescription.
7.4. Public Eye-Care Services
A VVI member has a congenital eye syndrome (microphthalmia), but was also diagnosed with cataracts in 2016. The pre-existing syndrome means that a cataracts operationis not a straightforward procedure, and requires very experienced and specialist consultants. However, he remains an outpatient at a regional hospital, and appears to have been forgotten about. In the meantime, the cataracts is embedding itself in his eyes, making it more difficult to successfully remove without bleeding, infection, or detached retina. The prognosis for him saving any sight is not good.
Ask (7.4):
that Ireland’s Third World public system for eye clinics be properly resourced to meet the First World expectations of our ageing population. Such investment will necessarily save money in the long-run as it helps to prevent life-changing experiences of total loss of sight, and the distresses and need for support services which accompany that loss.
8. Education & Culture
8.1. Habilitation and Rehabilitation
In keeping with the concept of Universal Design (CRPD, Article 2), visually impaired children have a right to receive a full education that meets their practical needs (as well as academic needs), as an integrated part of the education system. This means that the State should be providing education of life skills specific to visually impaired children (such as mobility and orientation, as well as other practical skills such as use of assistive technology, braille, and summer courses such as cooking, for visually impaired children. Similarly, but separately, the same services should be provided, as a right, to adults who have lost their sight later in life.
Ask (8.1):
That for any visually impaired person in the education system, that visiting teachers (from the NCSE) be adequately trained in the provision of education involving life skills specific to visually impaired children and young adults; and that in terms of rehabilitation, that the State closely consult and actively involve VVI in the establishment of a State-run rehabilitation service, under the auspices of the DCEDIY.
since the most cost-efficient and accountable provision of such services are where they are functions of the State, where NGOs are currently providing such services to some extent, such provision should be seen as a transitional support while the State establishes its own standards in close consultation and active involvement of DPOs, and in particular, in this instance, with VVI.
8.2. Accessible Educational Texts
We know anecdotally from third level institutions disability support units and from what data there is from AHEAD, that attendance at third level institutions by visually impaired students – and in particular, blind students – is the lowest of all disability constituencies (although, since there is nothing on deaf-blind participation, we would presume this to be very low indeed, if there is any participation at all).
From our own experiences in the education system (in all levels, up to FITAC Level 10), accessibility to even core texts is difficult, or non-existent. Often, where access to even core texts is provided, it does not happen in a timely manner, further disadvantaging the visually impaired student. Given this discrimination, which is intrinsic to Ireland’s education system, it is no wonder that there is such a relatively poor success rate among visually impaired students.
Note also that Duxbury (the software currently used by all Irish service-providers in braille-production, works from Microsoft Word, and so, production of braille texts from materials is really only practical when an accessible Microsoft Word version is the transcription-to-braille source.
the “Copyright Library” status of Trinity College Dublin should be extended to the National Library of Ireland, and as such; all books published in Ireland be required to lodge an accessible Microsoft Word version, and a .pdf version, of the book with the NLI, so that visually impaired readers can access such materials on demand from their local library.
8.3. Third Level Education Supports
In the United Kingdom, visually impaired third level students are guaranteed a minimum of 20 hours personal assistance supports, which is totally separate to their data processing (text) supports. This personal assistance not only means that lectures are more accessible to us, but also that we can go for lunch and participate more fully in college life.
In Ireland, standards of accessible text provision as well as of personal assistance hours vary from institution to institution, but personal assistance tends to be only provided for taught courses, which excludes many post-graduate courses.
Visually Impaired students in Third Level may require very specialist personal assistance, such as knowledge of a particular language other than English, or knowledge of STEM abbreviations and charts, etc. The current rates of PA-pay for Third Level education supports is quite close to the minimum wage, and so, is not generally compatible with particular specialist needs.
In Section 4, we have already mentioned the evidence of systemic impoverishment of visually impaired people in general, and visually impaired students are no different in this regard.
Apart from the extra costs by Third Level students, generally, such as living away from home, etc., visually impaired people incur additional costs related to Third Level education, such as extra need for taxi services, more dependence on eating-out facilities, etc. Furthermore, since courses are more likely than not to be inaccessible, the drop-out rate of visually impaired people can be expected, reasonably, to be much higher than the norm.
In short, the current SUSI criteria for funding looks at previous Third Level experience as a negative marker where courses have been dropped. In the case of visually impaired people, this is disablist, because it is blaming the victim.
Asks (8.3):
that Third Level supports be standardised, including the provision of a minimum of 20 PA hours per student (including for all postgraduates).
that educational support workers (i.e., personal assistants) be directly employed by third level institutions, which will afford a much higher level of pay for their work, and attracting Pas with higher skill-levels.
that visually impaired students not be penalised by previous third level attendance in the awarding of SUSI grants.
8.4. Talking Books should be VAT-free
Ask and Reason: 21% VAT needs to be removed from talking books (to match print book counterparts). This helps to address the difficulties in educational and cultural access experienced by blind people, especially having lost their sight later in life, and recognises the barrier to purchasing talking books caused by the systematic impoverishment of visually impaired people.
8.5. TV license exemption to all visually impaired people – whether in receipt of State benefits or not.
De facto this is the case anyway, since An Post has been thwarted in the Courts for trying to chase down blind people who had not officially been exempted. But visually impaired people should not have to worry about such things.
This is a good time to remind the State that the vast majority of television programming in Ireland does not have Audio Description, and so is inadequately accessible to visually impaired viewers/audiences.
Asks (8.5):
for all visually impaired people to be entitled to a free tv license or to be exempt from the requirement to have a license.
for State broadcasters in particular to have a minimum audio description output of 30% in 2023.
for such broadcasters to have accessible interfaces on apps and websites.
9. Assistive Technology Scheme
VVI calls for Seed Funding for an Assistive Technology Scheme which would act like a lending library, where visually impaired people could test out devices to see if they would be suitable as long-term purchases.
as a basic step to using technology to empower visually impaired people in society, this national scheme would also be engaged in research, such as into the practical application of accessible digital signage, in close consultation and active involvement of VVI and other national DPOs.
Whereas, before, such technology may have seemed too expensive and not universal enough for widespread application, this landscape is rapidly changing, and Ireland should be at the forefront of utilising such technology to improve the lives of visually impaired people.
Possibilities not only include a national assistive technology library where visually impaired people can test out devices, but also to be considered should be individual accessible technology grants from lottery funds.
This week sees the NCBI’s (National Council for the Blind of Ireland) media “Clear Our Paths” campaign, and you may be wondering what VVI’s approach is to this issue and what differences, if any, are there between VVI and NCBI on it. Indeed, so dominant has the NCBI been in the advocacy space regarding visual impairment in Ireland, people might even be wondering why VVI should need to exist in the first place.
Unlike the NCBI, which is a disability service-provider, or “organisation for people with disabilities”, Voice of Vision Impairment is a ‘Disabled Persons Organisation’ (DPO), or “organisation of people with disabilities”, as defined by the UN Convention on the Rights of People with Disabilities (CRPD), which Ireland ratified in 2018.
This means that VVI is necessarily rooted in the CRPD, and that our core mission is the defence of and advocacy for Human Rights (of visually impaired people in our case), and that a clear majority of our members must be visually impaired. Note the difference between “members” and “service-users”. It also means that we must be led, directed, and solely run by visually impaired people.
According to the UN Committee on the CRPD, DPOs are the only representative organisations when it comes to anything to do with disability, and their opinions and views are to be prioritised in consultations regarding disability by the State, and ultimately by non-statutory bodies as well.
Legal Opininion Commissioned by VVI regarding DPOs (2021)
This exclusive representative role and prioritisation of DPOs is logical when one makes other comparisons: imagine Women’s Rights organisations being led by men, for example, or trades unions being led by employers, or Consumer Rights groups being led by retailers. This would clearly be unacceptable, and even scandalous, because of clear conflicts of interests. For the same reason, the disability industry, according to the CRPD, is not in a position to represent disabled people. This representative role, for obvious reasons, belongs to disabled people, themselves, through their DPOs.
While VVI depend on the lived experiences of our members to determine our detailed policies on issues, our general approach to issues, as a DPO, is necessarily determined by the CRPD, including adherence to the social model of disability (as opposed to the medical or charity model). The following is a brief explanation of how this works in practice, using the issue of clutter-free footways as an example.
Background to Clear Footway Campaigns.
“Make Way Day” began as a social media based campaign organised by the Disability Federation of Ireland (DFI) in September, 2017, and has become an annual event ever since. While the NCBI is a member of the DFI, it took a leaf from the DFI’s book, and began the annual “Clear Footpaths Campaign” as it was, back in November, 2017. Both media campaigns now appear to be a calendar fixture.
Charity PR versus DPO Rights.
Some might argue that at least these organisations are doing something about the issue, and something is better than nothing. However, there is no evidence that such campaigns have any lasting effects in terms of public behaviour; but it is very likely that they do have the longer-term effect of increasing brand-recognition of the DFI and NCBI, respectively, in the public’s mind. This explains the significant resources devoted to such major PR campaigns.
For example, the NCBI’s profile across the media over a full week, gives itself branding that advertising couldn’t buy, increases public donations, increases custom in its charity shops, and most importantly, increases its branding with decision-makers when it comes to State funding and the embedding of their consultative status in significant policy areas.
The bins and dog-poo are just as likely to be a problem a day after the campaign, but the publicity is literally priceless. The “Clear Our Paths” campaign has the advantage of having the tried-and-tested branding technique of storytelling built into it in the simplest and most naturally understood way, and uses blind people themselves as an alibi in this branding masterclass.
Part of the branding is the perception that the NCBI is populated by members, and that it is a ‘representative’, or even, ‘the‘ representative organisation for visually impaired people in Ireland. For example, when John Cooke, the interviewer on RTÉ’ Radio 1’s Drivetime, on August 15th, asks June Tinsley, Head of Communications at NCBI, “Has it been more challenging for your members and the people you represent…?”, she makes no effort to correct either trope (a stance which directly or indirectly undermines DPOs, and is thus in contempt of the CRPD (cf. General Comment 7, para. 51).
How the DPO Approach is Different.
VVI, as a DPO, is in its infancy, and Ireland has not yet acknowledged the superpowers bestowed on DPOs by the CRPD, as laid out by the UN Committee in General Comment 7. These powers include the reversal of projects (plans or policies, etc.), that have not been disability-proofed by DPOs (General Comment 7, para. 66).
These rights are only obtainable through DPOs – not disability service-providers – and in order to see them come to fruition, we must first ensure that the DPO space is not shut down through suffocation of the space by service-providers, and we must campaign for the full recognition of DPO rights – since the traditional vested interests in Ireland are more dedicated to a consolidation of the status quo than in any meaningful change.
And yet, as fledgling as we are, VVI is outperforming key disability service providers in terms of campaigning on accessible public spaces, as well as other areas. For example, one local authority (Dublin City Council), and one public transport provider (Irish Rail), have begun to put the obligation to prioritise the views and opinions of DPOs into practice, and are finding VVI’s website to be a useful resource as a baseline in Universal Design, as they closely consult with and actively involve us in their consultation processes.
With regard to clutter-freefootways etc., DPOs, being rooted in the social model of disability and in the principles of the CRPD, necessarily holds that safe travel in, and full access to, one’s own community is a Human Right that can only be realised by the adoption of Universal Design in planning and policies by public authorities. VVI’s solutions to most of the issues referred to in the DFI and NCBI campaigns can be found in our Manual of Accessible Planning for Pedestrians (MAPP), for example, in Section 13.
Policies, such as our MAPP, are constantly under review in order to remain relevant, and as such, we depend on the individual experiences of our members and pooled expertise of our decision-making core (i.e., our representatives) to make sure they are kept up-to-date.
So, excellent PR campaigns by service-providers will come and go, but if you are visually impaired (that is blind or partially sighted), come and join VVI and add to our strength. As a member, we will build your experiences on this or any other issue into our policy so that your individual difficulties can lead to permanent change for all.
Dr. Robert Sinnott, Co-ordinator, Voice of Vision Impairment E: info@vvi.ie T: 086-3989365
The VVI is Ireland’s national representative organisation for visually impaired people, specifically focusing on our rights and needs from a visually impaired perspective. In this, we are part of a wider movement of what are known as Disabled Persons Organisations (DPOs).
All VVI members and representatives have a visual impairment, and since we are not a service-provider, we use our expertise to represent the interests and needs of all visually impaired service-users.
We also very much welcome members who have other impairments as well as being partially sighted or blind, and our policies are very much influenced by the particular needs arising from combinations of visual impairment with other impairments. https://vvi.ie/https://dublincityppn.ie/
DART stands for Dublin Area Rapid Transit, and is the name given to overground urban and suburban rail service in the Greater Dublin Area.
VVI compiled this position paper in the Spring and early Summer of 2022 in response to Irish Rail’s consultation on a design for a new DART fleet.
This document is complementary to our other policy documents, in particular, our Accessible Communications Policy, and our Policy on Accessible Public Spaces
1. Interior
1.1. Consistency
There is a need for consistency from carriage to carriage. Also, there is a need for consistency vis-à-vis front and back carriages vs. the rest of the train. In other words, the layout should be identical in all carriages, no matter which way they are facing.
1.2. Priority Seating Signs
The current signage (embedded in the windows of commuter trains) announcing Priority seating for blind and pregnant people is very useful and needs to be replicated in the new fleet.
1.3. Handrails
Bright yellow handrails are essential – i.e., not green, blue, or any other colour. The standard on Dublin Bus, Luas, and currently on Irish Rail, is very good because yellow reflects light while also being very distinctive.
Photo (above) of yellow vertical handrails on Siemens 81xx Series DART.Photo (above) of yellow vertical and horizontal handrails on Tokyu Car 85xx Series DART.
The vertical handrail from the floor to the ceiling when one boards the train is very useful. This is like the Luas or Iarnród Éireann Diesel Commuter trains and essential for people to maintain their balance when no seating is available, and need to be easily visible to visually impaired people who have some sight.
Photo (above) of yellow vertical and horizontal handrails on CAF 29xxx Series DMU.Photo (above) of yellow vertical and horizontal handrails on Siemens Berlin U-Bahn train.Photo (above) of yellow vertical handrails on an Alstom Luas tram.
Vertical handrail attached to the ‘wall’ on either side of the door: We are very impressed with this as there is currently nothing to hold onto when boarding or exiting trains in Ireland, so this is very welcome. Because there is nothing to hold onto, currently, passengers have to lean against the door-jam.
Handrails on seating
These are handy for shuffling around the corner to the aisle; and work well to assist a passenger standing; and, of course, for other passengers to hold onto for balance while walking through the train. The thinner version is easier to grip for those with less hand muscle or dexterity. Also, the rails should protrude less into the aisle, in case of passenger collision and should also be present at the top of seats, allowing more passengers (e.g., from behind the seat) to have the potential for easy-to-reach holding.
In general, the more opportunities for holding onto a rail etc., the better. A blind person cannot see where such rails are, and so it cannot be presumed that we will know where to reach. The more options we have in our close vicinity, the better.
Photo (above) of seating loop handrail & vertical handrail to ceiling CAF 29xxx Series DMU.
1.4. Accessible Door Buttons
The door buttons need to be accessible: including raised high contrast print, as well as durable Standard English Braille. Currently, the braille “c” and “o” on commuter train door buttons and raised door open/close arrows is good practice.
Photo (above) of accessible door open and close buttons on CAF 29xxx Series DMU.
Regarding clarity of braille, we are very impressed with the definition of braille signage on the refurbished De Dietrich Enterprise train between Belfast and Dublin.
Photo (above) of braille signage for ‘Dryer’ on Enterprise De Dietrich cross border carriage.Photo (above) of braille signage for ‘emergency intercom’ on Enterprise De Dietrich carriage.
1.5. Accessible Help Buttons
Similarly, the help/intercom facility needs to have the same raised print and braille signage for visually impaired passengers.
Photo (above) of intercom with ‘SOS’ in raised print and braille on Iarnród Éireann/NI Railways Enterprise cross border refurbished De Dietrich carriage.
1.6. Accessible Carriage ID
On trains, the identification number for each respective carriage should be accessible on the back of every seat, beside every door, and on every toilet door. Accessible, in this respect, means raised print letters in high contrast, and Standard English Braille.
Photo (above) of Dublin Bus stop #1417 with raised numbers, braille and contrasting colours.
1.7. Questioning the Concept of “Family Seating”
It is proposed that there be designated “family seating” areas on carriages. The practicality of such a feature as a designated family area is questionable. Rather than being in the best planning tradition of envisaging normal or worst-case scenarios, it appears to be based on someone’s imaging of an ideal journey, perhaps on a lovely sunny Sunday afternoon etc. Even then, the idea that there would only be space for one family per carriage (with two bicycles only), appears to be tokenistic, at best.
The more area designations in a carriage, the more confusing for passengers, and all designations are likely to be weakened as a result. In particular, we’d be worried that the unnecessary and impractical family designation would reduce the priority seating for vulnerable passengers, and weaken the acceptance of such designated areas by passengers more generally.
Keeping designations as simple as possible (i.e., priority seating and wheelchair areas closest to the doors) means that consistency (1.1 above) is much more achievable and adoptable.
Also, with a family designation area, as currently planned, when the carriage is reversed on a return journey, a visually impaired person will not necessarily know which side is family, and which side is general. There is no need for such confusion.
A realistic practice Family-friendly approach is currently operating with the use of opposing seating as currently in place on the Dart and used (with table) on intercity and commuter trains.
1.8. Airplane style seating
As with commuter trains and inter-city trains, a mixture of airplane-style seating and opposing seating would retain the family-friendly element, while meaning that there is more seating for all passengers.
There is currently a proposal for a small shelf beside the window on the new DART fleet. The curved edges are useful, but there is the possibility of snagging for those unfamiliar with its presence. As such, we would propose a flip-up version as one alternative, or else, as on one of the diesel commuter trains, which has a cup holder for 2 cups just under the window, which doesn’t take up as much space.
Otherwise, if airport-style seating is mixed in with the opposing seats (as on current inter-city and commuter trains), the flip-up shelves at the back of seats (as currently used) would be viable.
Many passengers like to be able to put their elbow against the frame of the window to rest on their journey, and we would suggest that this feature be retained in any new designs.
1.9. Tip-up seats
Two tip-up seats at the wheelchair space close to the door is also best practice. From a balance perspective, finding a seat as soon as possible when you board a Dart is critical in case you are thrown when the train starts moving. We realise that there are planned to be 2 tip-up seats at the wheelchair area and are supportive of this.
1.10. Wheelchair Spaces
On ICR trains, such as those operating to Galway, Tralee, Rosslare etc, one carriage on each 4 carriage set has room for 2 wheelchairs (one left and one right). We propose that this system be designed for every carriage in the new DART design.
While wall mounted signage should work for designation of wheelchair spaces, other passengers often do not or cannot read it, and either park themselves or their luggage there. Accordingly, use of the Dublin Bus standard floor signage of a white wheelchair on a blue background should also be used to help to prevent any confusion, albeit with the use of carpet rather than smooth flooring (with Dublin Bus using the latter).
Photo (above) of disability and wheelchair area on TFI Alexander Dennis (ADL) hybrid bus.
It appears that on the new DART fleet, Alstom have some concerns about passengers congregating in this area who are only travelling 2 or 3 stops and thus blocking the flow for a wheelchair passenger to board. A useful mediation for this is found on Luas trams, where an announcement of ‘passengers, please move down the tram to allow other passengers to board’ helps with the onboard dispersal of passengers.
1.11. bicycle storage
Transport For London (TFL) does not allow bicycles on its trains because of risk of self-combustion. Clearly, the combustibility of e-bikes and e-scooters needs to be investigated before they are allowed onto passenger-trains.
Also, having space for two bicycles for each carriage appears to be more trouble than it’s worth. It reduces seating space and consistency standards, while only appearing to be tokenistic in terms of “active modes”. A specific holding space for multiple bicycles (even if only a dedicated 6-m long carriage) would be practical for lone cyclists and not interfere with other passengers.
1.12. USB ports for charging
The 2 USB ports between the 2 seats is a good location and ensures no wires going across the other passenger as it currently the case on Intercity ICR and Mark4 trains where the usb ports are in the wall of the train. The metal trunking covering these will ensure they won’t get damaged.
We recommend under-seat, rather than shoulder-height, positioning of the USB ports because it is easier to access, especially when one is seated, and one is less likely to be annoying another passenger in plugging and unplugging etc.
Photo (above) of USB and 3 pin plug charging point in wall on Rotem Hyundai 22xxx Series ICR.
1.13. Space under Seating
We are very impressed with the proposed ample storage for bags etc under the seating, as per model we reviewed in March (2022), at the Irish Rail Works in Inchicore. Such space is also good space for a guide-dog. From a visually impaired perspective, it’s all about keeping the aisles clear for all passengers and ensuring no-one stands on the dog etc.
The regular priority seating on ICR trains backs onto a luggage rack and are certainly a tight fit for a guide dog. Indeed, this means the guide-dog has to rest in the middle of the aisle, where passengers, including visually impaired passengers can step on them or trip over them.
2. Doors
2.1. Automatic Door-opening
In order for visually impaired people to independently locate the doors from the inside or outside, there needs to be automatic door opening for doors on the alighting side. This best practice is currently operating in London (since the 1980s), and in Berlin (since the start of Covid. Opening of some doors will not suffice, as many visually impaired passengers will not know whether they are standing on the platform near the front or the rear of a stationary train, and those on the inside may not know on which side of the carriage to get off (i.e., find the door opening button).
An arguments that automatic door-opening may be uncomfortable for on-board passengers is relatively frivolous, especially when contrasted with the right of visually impaired people to independently board trains as per universal design. The principle of Human Rights being more important than aesthetic convenience is paramount.
2.2. High Contrast Doors
There is a need for high contrast colouring of doors. The current proposal of grey doors on a white train does not meet this need. Best practice can be seen on the current commuter fleet, where white doors are contrasted with a dark green carriage.
Photo (above) of high contrast colouring of doors on CAF 29xxx series DMU.
2.3. Two-way bleeps, with distinctive closing sound
The proposed feature of bleeps to represent the open carriage door – and bleeps that can be heard from the outside and inside – is very welcome.
3. Miscellaneous
3.1. External Livery
The current external livery on commuter trains where the engine is yellow, and the train is dark green, is what we consider to be best practice.
Photo (above) of yellow Driver’s cab on Siemens 81xx and Tokyu Car 85xx Series DART.
3.2. Visual Display of PIS Signage
Visual display of public announcement systems should be in accordance with all EU Regulations and Directives.
3.3. Audio Announcements
At en route stations, the next station should be announced prior to arriving at, and on arrival at, that station. When the door is open, announcement should be made of the next stop and the final stop, and this announcement should be two-way, audible from the platform as well as from the train.
3.4. Positioning of Speakers
We note that speakers are planned for the roof. However, speakers are needed closer to the ear-level of passengers. In terms of fleet consistency, these could be at a priority seating or flip-up seat adjacent to a wheelchair dock.
At least, there should be an intercom beside the door and under the horizontal handrail in the wheelchair area between the tip up seats, as proposed. Of course this is coach c or carriage 3 but having intercoms on the right side of the 4 doors in each carriage is a valuable safety net to contact the Driver in the event of the next stop audio announcement system not working etc.
Photo (above) of intercom to the right of door on a 5xxx Series Alstom Luas tram.
3.5. Accessible Digital Signage
Without prejudice to any other measure indicated in this or other VVI position documents, the relevant statutory bodies should explore the use of accessible digital signage with regard to the new DART design, closely consulting and actively engaging with DPO’s (including their prioritisation and distinguishing in such consultations).
There are various possible mechanisms for accessible digital signage, including Navilens, which is dependent on a smartphone camera being able to decode physical tags which are strategically placed and which can make detailed information, including real-time updates, accessible to visually impaired and other people.
Photo (above) of test Navilens tag on glass panel facing down CAF 29xxx Series DMU.
Where relevant, the information provided by ADS must be realtime or otherwise adequately updated, as appropriate.
