- 1. Introduction
- 2. State’s Legal Obligations regarding resourcing of DPOs
- 3. Funding Related to Disability-specific Services
- 3.1. Additional Funding for Disability Service Providers
- 3.2. Specific Services and Accountability (context and ask)
- 4. Cost of Visual Impairment
- 4.1. Costs vs. Basic Income
- 4.2. Basic Income Based On Average Industrial Wage
- 4.3. Non-Contributory Pension
- 4.4. Anomalies Between Different Payments to Disabled People
- Capital Disregards
- Other Anomalies Regarding Rates and Circumstances
- Ages of Eligibility of Benefits
- Asks (4.4):
- 4.5. State Benefits as Taxable Income
- 4.6. Blind Welfare Allowance (BWA)
- 4.7. Accessible Application Processes for State Benefits and Awards
- 5. Mobility & Environment
- 5.1. Free Public Transport
- 5.2. Active Modes of Transport
- 5.3. Consultation on Sustainable Development Goals
- 5.4. Visually Impaired Passengers.
- 5.5. Accessibility as a Precondition for Public Transport Licensing
- 5.6. Removal of VAT on dog-food for guide-dogs.
- 6. Housing and Independent Living
- 6.1. Needs of Visually Impaired People in being Allocated Housing
- 6.2. General DPO Prioritisation in Consultations
- 6.3. Housing-Related Data
- 6.4. Minimum of 2-bed Allocations for Visually Impaired Individuals
- 6.5. Homelessness
- 6.6. Home Supports
- 6.7. Caution Regarding Individualised/Personalised Budgeting Strategy
- 7. Health
- 7.1. Accessible Health Services
- 7.2. The Medical Card
- 7.3. Medical Prescription
- 7.4. Public Eye-Care Services
- 8. Education & Culture
- 8.1. Habilitation and Rehabilitation
- 8.2. Accessible Educational Texts
- 8.3. Third Level Education Supports
- 8.4. Talking Books should be VAT-free
- 8.5. TV license exemption to all visually impaired people – whether in receipt of State benefits or not.
- 9. Assistive Technology Scheme
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).
- 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.
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).
VVI policy on braille documents
4. Cost of Visual Impairment
4.1. Costs vs. Basic Income
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.
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.
- 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.
- 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
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.
- 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.
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.
- 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)
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:
5. Mobility & Environment
5.1. Free Public Transport
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.
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.
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.
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.
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.
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).
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.
- 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.
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.
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.
- That Housing allocation for visually impaired individuals allows them a minimum of 2-bedroom dwellings.
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.
- 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):
VVI position on home support services
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.
- 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.
6.7. Caution Regarding Individualised/Personalised Budgeting Strategy
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.
That nothing be done regarding a change of funding strategy to personalised budgets without prior close consultation and active involvement of DPOs (including VVI).
7.1. 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.
- 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
VVI accessible communication
7.2. The Medical Card
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.
- 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.
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.
- 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.
- all publications which are subsidised by the State must be compliant with VVI’s Accessible Communications Policy
- and in particular with the production of accessible Microsoft Word versions of texts.
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.
- 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.
- 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.