VVI Pre-Budget Submission

28 AUG 2021

1. DPOs to be Funded

In line with the UN Convention on the Rights of People with Disabilities (e.g., General Comment 7, paras. 61, 62), the State is required to ring-fence core funding for Disabled Persons Organisations (also known as “Representative Organizations”), as well as providing project-related funding.

Note, DPOs are not disability service providers (DSPs) or advocacy organisations run for disabled people. In short, they are not the traditional brand-names of the “disability sector”.

2. Increase in Blind Persons Pension and Disability Allowance

According to the 2016 Census, at least 75% 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 are clearly too high for visually impaired people for this approach to be justifiable, generally, in their case. As equal Irish citizens, they deserve dignity of life and equal opportunity.

To mitigate against the current institutionalised disabling of people from their institutionalised unemployment and impoverishment, at the very least, the Blind Persons Pension and Disability Allowance need to be increased to meet the increased cost of living brought about by the disabling and impairments of their recipients.

For budgets to come, we would advise that universal basic income be considered for all people with a severe visual impairment 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).

Similarly, Blind Welfare Allowance would reflect the extra costs of living of independent visually impaired people, and be increased accordingly (cf. SVPJ report, 2017) which found that the extra costs due to visual impairment were around €70 per week, however, this is likely to be an underestimation given that the research relied on focus groups, which should be more biased towards the self-selection of relatively independent and mobile visually impaired people, and probably against those with most or recent sight-loss.

3. Equalisation of Blind Persons Pension with Disability Allowance

Currently, those on the Blind Persons Pension are at a disadvantage in several ways when compared with those on the Disability Allowance. For example:

  • Disability Allowance is payable from 16, but the Blind Persons Pension only from 18.
  • Capital disregard is €50,000 for the Disability Allowance, but only €20,000 for the Blind Persons Pension.
  • There are no disregards for partners or spouses on Blind Persons Pension, but some disregards for these regarding 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.

All of these anomalies are unjustifiable, and appeared to have accrued by neglect rather than design. The Blind Persons 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, but it is the fair and right thing to do.

3. 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.

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. Talking Books should be VAT-free

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 systemic impoverishment of visually impaired people.

6. Removal of VAT on dog-food for guide-dogs.

A guide dog is an aid to VIPs 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.

So, VAT should be removed from all purchases necessary for the maintenance of guide dogs, including dog-food.

7. TV license exemption to all visually impaired people – whether on welfare 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.

8. €2 tax on all Prescriptions for Medical Card Holders

When Fianna Fáil and the Green Party introduced this tax (€2.50 back then) in 2009, it was said to be a temporary measure necessary in the drastic economic circumstances that the State found itself in.

Eleven years on, and this regressive tax has only been reduced by 50c. Because this is a nasty little tax that hits the most vulnerable in society, it needs to be immediately removed, and removed completely. Many of our members are dependent on medicine related to their eye conditions, and this tax effectively taxes them on those eye conditions, or the prevention of those conditions getting any worse – which would be even more costly to the State.

As such, an affected person with a visual impairment on a social welfare payment will necessarily be poorer than their sighted comparitor as a result of this regressive tax. So, it is discriminatory as well as immoral.

9. VVI to be Closely Consulted

Apart from the above, no budget measures specifically relating to visually impaired people should be made without first closely consulting with Voice of Vision Impairment (as Ireland’s national DPO specifically focusing on visual impairment related issues).

Similarly, no budgetary changes should be made concerning disability in general without all national DPOs being closely consulted with.

10. Seed Funding for a National Universal Accessibility through Technology Scheme

As a basic step to using technology to empower visually impaired people in society, a national and universal scheme to provide access to all signage both digital and static, should be explored through consultations with VVI and other national DPOs. At last, technology has reached the point at which we can now implement affordably and easily those requirements, outlined in both the 2005 Disability Act (and the 2006 NDA Code of Practice), the Equal Status Acts, and most importantly of all, Article 9 of the CRPD.

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 include individual accessible technology grants from lottery funds, and a national assistive technology library where visually impaired people can test out devices.