Submissions & observations

Submission by Voice of Vision Impairment on Part 8: Tralee Town Centre (Pavements). Phase 3

Who we are

Voice of Vision Impairment is a Disabled Persons Organisation (DPO) as set out under General Comment 7 of the Convention on the Rights of People with Disabilities.

This means that, since we are not a service-provider, and therefore have no conflict of interests, we should be prioritised in consultations regarding all matters relating to disability (GC7, para. 13). Indeed, DPOs are the only representative organisations in relation to disability (ibid., para. 10). Note that just about every matter relates to disability, including this Part 8.

Voice of Vision Impairment is the national DPO focusing on issues relating to visual impairment.

Inaccessible Information.

In violation of the EU Website Accessibility Directive (2016), the Disability Act (2005, Part 3), and Kerry County Council’s obligations under Public Sector Duty (Human Rights and Equality Act, 2014, S42), the information on this Part 3 is only partially accessible (i.e., significant parts are wholly inaccessible to blind and partially sighted users of screenreading technology).

In particular, there has been no attempt made at describing images, maps, overall project locations, markings layouts, and vehicle tracking.

Our Kerry representative, Barry O’Donnell, alerted Diarmuid Reilly (senior engineer) to these accessibility difficulties, but this made no difference.

The following observations are based on the incomplete information we have been given (in violation of our rights of equal access). Under the CRPD, the onus is on the Council to seek out our expert opinion at the concept stage of any design, rather than leave it up to us to struggle with inaccessible documentation when we’ve been alerted to the proposal by a member somewhere down the line.

The onus is also on Kerry Coco to provide detailed answers to our questions and issues (GC7, para. 23).

From what we can gather from the incomplete/inaccessible information, the following are among the proposals/consequences of the Part 3.

There are some pinch points on Bridge Lane (taxi rank, Citizens advice) and approaching Lower Rock Street (Kirby’s Brogue Inn).

We also understand the existing perimiter wall around the Garda Station will be removed (Currently this area has a footpath with

We understand a tactile guidance strip will be used to delineate between the road and the footpath.

Lower Castle Street (extending from the top of Denny Street) – narrowing of street to increase footpath widths, bicycle parking etc.

Shared Space

The major area of concern for VVI is shared space on the New Road (Garda Station) which deviates to the Island of Geese on the left and Bridge Lane (Taxi Rank, Citizens Advice Bureau) on the right. This area leads up to Lower Rock Street (Ray’s Loaded Lunches) passing the busy Rock Street Post Office en route.

There should be no shared space in areas where there is vehicular traffic. So, kerbs should be maintained, and, indeed, we recommend that these dished kerbs be raised to 125mm, but certainly, at no stage be allowed to go below 60mm (the minimum height for them to be recognised by a guide dog). Without adequate kerbs, guide dogs will walk out in front of traffic, including cyclists. For minimum heights for guide dog use, see report by Guide Dogs UK (2009, 2012).

Similarly, long-cane users need to have a safe zone where they know they will be safe from traffic (including cyclists). Our members cannot use eye contact to communicate with traffic, and especially with the increased useage of e-vehicles, it is more likely, with shared space, that blind or partially sighted people will step out in front of traffic (inadvertently).

For research into the dangers of shared space to blind and partially sighted pedestrians in an Irish context, see the TrinityHaus Report into Shared Surfaces (2011), and for Britain (in a very similar context), see the Holmes Report (2015).

Raised crossing points at Pedestrian and Zebra Crossings

Raised or level crossings cause Blind and partially sighted pedestrians to veer off course, potentially loose their balance (twist their ankle) etc as well as removing the dished paving cue.

Rumble strips which are used before roundabouts are very effective and could be used as an alternative to slow down traffic.

Bicycle parking

To reduce street clutter and eliminate unnecessary injury, we suggest bicycle parking stands be on the road (occupying former parking spaces) as Dublin City Council have done in St. Stephen’s Green, Hume Street etc.

Consideration should also be given to allocating a portion of town centre multi-storey car parks for secure bicycle parking. Dublin City Council have done this in Drury Street.

Pedestrian crossings

Tactile paving should extend the width of the path to the building line. Pedestrian crossing buildout (eliminating the need to use relief islands) are welcome as they will reduce the time needed to cross the

Phase 2 of part 8 urban realm upgrade works down Russell Street and Bridge Street are currently underway.

These are very narrow streets with pinch points.

As far as we know, a tactile guidance strip is being used to delineate between the footpath and the road.

The efficacy of tactile guidance strips are questionable even in their original setting, however, they are wholly inadequate as boundary markers. Where streets/roads are too narrow for wheelchair-accessible kerbed footways, in close consultation with DPOs (such as VVI), we recommend the use of high definition corduroy strips to delineate the carriageway from the footway.


VVI is recognised by the State (under international law), as a DPO. This means we get priority in consultations. An analogy is that of a 999 submissions thinking that a proposed bridge design is wonderful, but one, who happens to be the civil engineer, says it is dangerous, and is likely to collapse within six months etc. So, our perspectives are not to be aggregated, but treated with the seriousness given to us by law.

Shared space is wholly unsuitable for vulnerable pedestrians, and especially those who are blind or partially sighted. Visually impaired have rights of equal and safe access to their environment and community, and this right needs to be reflected in responsible planning that adheres to the principles of Universal Design. DMURS (2019, 28) says that pedestrians are top of the road-users’ hierarchy, but this doesn’t just mean giving pedestrians free reign everywhere. Responsible planning provides vulnerable pedestrians, in particular, with contiguous areas where they can feel as safe as houses.