May 31st, 2021
This is the submission on the Athenry Market Square Part 8 proposal from Voice of Vision Impairment (VVI), which is a Disabled Persons Organization (DPO) under the Convention on the Rights of People with Disabilities (CRPD).
We draw your attention to Article 4.3 of the CRPD, which obliges states parties to engage in close consultation with DPOs on designs and policies. Directly related to this is paragraph 23 of General Comment 7 of the CRPD, which obliges all “authorities” to give detailed and reasoned responses to DPO submissions.
VVI is the only national DPO in Ireland focusing on issues relating to visual impairment.
The images in the proposal were not adequately described for those of us with severe visual impairments (cf. EU Websites Accessibility Directive, 2016; European Accessibility Act, 2019; Disability Act, 2005, S28).
As such, visually impaired people, also through their national DPO, were denied the proper opportunity to engage in the consultation on an equal basis with their sighted comparitors.
VVI has concerns about the proposed pedestrianisation of Market Square. We note that there are two banks, an undertaker, a doctor’s surgery, and a chemist, on the square. In order to exercise their right of access to these businesses, many disabled people, especially those who are independent and relying on public transport (such as taxi), or private transport (including modified or adapted vehicles), need to be able to get as close as possible to their destinations in order to locate them safely.
For example, it is not much good to a blind passenger if a taxi-driver has to let him/her off outside the Square and tells them they have to fend for themselves.
Furthermore, we understand that there will be traffic access to the square by one street only, implying that the three other access streets are also to be pedestrianised. The same issue arises to businesses and dwelling places on these streets as well.
These measures would effectively exclude many disabled people from the centre of Athenry. As much as anyone else, disabled people have Human Rights of access to their community/environment (inter alia, cf. European Convention on Human Rights, Article 8, which links in to Article 14 (discrimination).
Article 9 of the CRPD also guarantees easy and safe access to our environment, as does the Arhus Convention (Environment Act, 2011).
No Shared Space Unless Wholly Unavoidable
According to UK Guide Dogs research through the University of London (2009), guide Dogs need a minimum of 60mm front-facing flat kerbs in order not to walk out in front of traffic. This needs to be maintained, even if occasional traffic is permitted in the Square. We recommend 125mm kerbs (as is standard in Northern Ireland since 2015).
We recommend footway widths of 2.5m in order to adequately cater for power wheelchairs passing each other. Where the surrounding streets are too narrow for this, we recommend a replacement of the narrow kerbs with a strongly defined corduroy tactile strip where the current kerbs are. This is not ideal for guide-dog users, as just stated, but is a compromise that would allow wheelchair users to access the buildings on these streets. Guide-dog handlers would have to navigate these four streets manually.