National Disability Authority Submission to theNational Transport Authority’sGreater Dublin AreaDraft Transport Strategy 2011-2030

April 2011

Introduction

The National Disability Authority (NDA) is the independent statutory advisory body to Government on issues of disability policy and practice and universal design. The statutory Centre for Excellence in Universal Design is part of the NDA. Universal design is defined in the Disability Act 2005 as the design of environments (including public transport) that can be accessed, used and understood by people regardless of their age, size, ability or disability, without the need for further adaptation.

The NDA estimates that there are at least 60,000 people in the greater Dublin area with a long-term disability that restricts their mobility. This figure doubles if people with equivalent functional difficulties who do not identify themselves as disabled are included. In addition there are people who may be experiencing a temporary disability. The NDA welcomes the positive measures included in the Strategy for people with reduced mobility.

The NDA looks forward to the opportunity, in due course, to contribute to the other plans that will follow on from the Draft Transport Strategy, the Implementation Plan and the Strategic Traffic Management Plan.

There are already a number of legal and policy commitments in place around accessibility for people with disabilities and others with restricted mobility:

  • the obligations under the Disability Act 2005 for public bodies to provide services that are accessible to people with disabilities and integrated with mainstream services; and to procure goods and services that are accessible to people with disabilities. See the related statutory Code of Practice on Accessibility of Public Services and Information provided by Public Bodies(2006);
  • the commitments in Transport 21 towards public transport that is accessible to people with reduced mobility - including people with physical, sight, and hearing disabilities, elderly people, people of small stature, and people with prams or luggage;
  • the obligations under the Equal Status Acts 2000 to 2004 to provide access to services for people with disabilities;
  • the EU technical specifications on the inter-operability of high speed and conventional rail systems, with regard to Accessibility for Persons with Reduced Mobility[1];
  • the provisions on mobility and accessibility set out in the UN Convention on the Rights of Persons with Disabilities[2], which Ireland has signed and is working to ratify;
  • the objectives set out in Transport for All.

The NDA welcomes the commitments in the Draft Strategy (Appendix A). There are, however, some gaps in the document that require attention. These suggested areas for action are supplemented by the information supplied in Appendix B

Travel Information

Everyone who uses public transport needs information to enable them to plantheir journey. Timetables, journey times, pricing information, the availability ofparticular facilities and last-minute updates should all be available in a rangeof formats, including visual and audible. Clear, concise, accurate and timelyinformation is crucial to people making journeys on all transport modes. Forpassengers with reduced mobility, quality information can be the differencebetween being able to make a journey or not. On-board information about each stop is critical for passengers with impaired sight or vision.

Information on the transportenvironment can be divided into three levels:

  • Level 1 information, such as urgentsafety information or immediate departures.
  • Level 2 information, such as generaltimetable information, information about connections and generalsafety information
  • Level 3 information, such as advertising.

It is important thatthese three levels of information are clearly distinguished. Essential information,particularly safety instructions, should be easy to find and should not beobscured by advertising.

It is important that public bodies, in trying to comply with their statutory obligations under section 9(1) of the Official Languages Act 2003 –and the accompanying regulations[3] – do not compromise on the size of the lettering on transport signs to the detriment of health and safety, or the accessibility of information to people with a vision impairment.

Timetable information

The information in timetables may be complex, but it should be presented visually in a clear and logical format so that it is easy for everyone to understand. The National Adult Literacy Agency[4]provides guidelines on its website on plain English writing. Timetables should be available inside transport terminals in an accessiblelocation.

Not everyone is able to read a written timetable (for example people with impaired vision), not everyone can hear a talking timetable (for example those with hearing impairments) and significant numbers of people, particularly older people, do not regularly use computers. So it is important to provide timetable information in a range of different ways to suit the needs of different users, for example in regular print, in large print, in audio format and on a computer website that is designed for compatibility with screenreader technology.

Talking timetables

Timetable and journey information should be available via a telephone service asan alternative for people who cannot read timetables or regularly get to a station or stop. The service should also beaccessible to people using a textphone. It should be available 24 hours aday, 365 days a year. Where a menu of ‘talking timetables’ is used, the sequenceof information should be logical and considered carefully so as not to frustrate orconfuse the people using it. Talking timetables cannot be used by many deaf orhard of hearing people, and should therefore be provided as a supplement to anoperator service, rather than be the sole source for obtaining information.

Integrated journey planners on the web

Operators should consider the use of integrated journey plannerson websites and maps. These offer the potential for detailed and precise journey details to be worked out before or during the trip. Information that is presentedvisually (such as on a map) should also be available in text format for people withvision impairments.

Many people, either through necessity or choice, require information about theavailability of particular facilities on a journey. People who use wheelchairs may wantto check that a destination station has step-free access and that a train has awheelchair-accessible toilet facility. Information should be readily available, as part of an integrated journey planner, to enable people to adequately prepare for their journey and to travel in comfortto their expected destination.

Journey pricing information

Journey pricing information should be available in advance to allow people to budget for their journey and to make the necessary arrangements for paymentupon arrival at the terminal. At the terminal, prices should be clearlydisplayed.

Pictorial signage

Use of accepted signs and symbols will benefit people with reading difficulties, intellectual disabilities. It also assistsforeign travellers who may not be confidentunderstanding or communicating using English or Irish.

Scheduling for connections

When transport services are scheduled, consideration should be given to the timeallowed between connecting services so that everybody has time to transfer fromone location to another. The time taken by someone with mobility difficulties, with small children, or encumbered by luggage to transfer from one mode to another should be factored-in in what are considered to be reasonable times to make a connection.

Door to door transport

For many people with disabilities, or older people, door-to-door transport is essential. Many people with disabilities and older people do not drive, and there are significant numbers of people who have difficulty in walking the distance it would be from their home to a bus stop or other public transport point.

Taxis

The Draft Strategy recognises the importance that taxis have in the lives of people with disabilities. They are a key form of door-to-door transport.

The number of accessible taxis has grown slightly in the last decade. However, many of the accessible vehicles are coming to the end of their useful life, and in today’s taxi market, there is a strong risk that this supply will be lost altogether. The proportion of accessible taxis has declined from 21% in 2000 to 6% in 2010. The NDA welcomes the commitment to achieve a 10% share by 2012 and feels this would be given further weight via a written, incremental percentage figure, covering a number of years, accompanying the above-mentioned commitment to have a share of the taxi fleet fully accessible.

The former Commission for Taxi Regulation (CTR) submitted a proposal for a grant scheme to incentivise the provision of wheelchair accessible taxis and hackneys, based on a target of 10% accessible taxi and hackney fleet. In today’s market where the returns to participants are affected by a high level of supply and the reduction in demand that comes with the recession, it is unlikely that taxi operators would choose a more expensive, accessible vehicle type when replacing their car if not incentivised to do so. The Minister for Transport referred the CTR proposal to the NTA for its consideration and decision.The NDA notes that there were funds available to the Commission, from levies paid by the taxi industry, which could be put towards such an incentive scheme – those funds are now under the direct control of the NTA. The NDA advises that it is timely to bring in such an incentive scheme.

Accessible taxis are largely designed with the wheelchair user in mind and most of those on the road today are adapted vans rather than purpose-built vehicles. They are, quite often,not easily used by other passengers with mobility problems, or by elderly people. In many cases it is the height of the taxi floor and/or the weight of the door that proves the major barrier. Consideration should be given to lowering the minimum height requirement before a step is required and to alter the design requirements for the door closing mechanism.[5]

Other door-to-door services

Many people use the services of accessible transport providers in small buses or minivans going from door-to-door. These providers give a good service yet remain operating under the device of unlicensed "travel clubs". The NDA advises that a modernisation of the licensing regime in the Road Transport Act 1932 would be important for this transport sector.

Engage with stakeholders around details of design

People have diverse needs and abilities as users or customers (as well as employees) of transport systems. It is necessary to consider design factors related to vision or hearing disabilities (such as providing tactile features, audio announcements, and the optimal acoustic quality of stations). Consider physiological factors beyond wheeled mobility (wheelchairs users) to include people with luggage, prams, walkers with limited endurance, issues related to fatigue, strength, balance and simply people of a much different size than most. Also consider cognitive and mental factors that relate to memory, concentration and comprehension, stress, literacy and people with limited English.

It is valuable to engage specifically with relevant stakeholders around the details of design of universal and accessible features of important infrastructure projects, the vehicles/rolling stock to be deployed along the route, the interface,the built environment and streetscapes at transport points and on the operation and maintenance of accessibility for people with reduced mobility. A universal design approach will be better informed by listening to the practical issues for stakeholders with disabilities, elderly people, and others with reduced mobility.

Co-location of transport services

The journey starts when you close the front door. In light of newly planned infrastructure, or the reorganisation of existing services, the location of transport buildings such as bus, coach and railway stationsshould be carefully considered in relation to the communities they serve andthe proximity of public buildings and services, shops and other local facilities.As journeys are often made by more than one mode of transport,it is beneficial if different modes of transport can be co-located, such as in atransport interchange which provides rail, bus and coach services. The convenientco-location of such facilities will promote public transport and have the addedbenefit of contributing toward a sustainable transport strategy. Where this cannotbe provided, bus and coach stations should be located as close as possible toother transport services.

In all terminals and transport buildings, facilities should be provided for a taxi service and to enable private cars to drop off and collect passengers close to the building entrance. At railway stations, motorway service areas, harbours and airports, car parking facilities should be provided, including proximate and prioritised parking for disabled car users and for parents with small children, older people and those who have difficulty walking short/medium distances.

Licensing Public Bus Passenger Services

Section 13 of the Public Transport Regulation Act 2009 allows for the attachment of conditions to the granting, amendment or renewal of a licence. Accessibility is mentioned in paragraph 13(2)(i) of the Act. The NDA advises that accessibility becomes a central requirement of any proposals for licensing of services, and in particular that accessibility should be a key criterion for any future proposals to contract out public transport routes.

Universal design of the built environment

The way we design our cities, neighbourhoods and streets, and our transport systems, are closely interlinked. A sustainable city is one which remains fit for purpose as the population ages, and where services and facilities are within easy reach, including those no longer able to walk for any distance.

The NDA promotes the principles of Universal Design – the design of places, spaces and facilities which can be used by everyone regardless of age, size, ability or disability.

NDA’s Building for Everyone guidance ( is being updated to reflect best modern practice and the universal design perspective. The NDA has developed specific guidance on

  • Design of the external environment
  • Incorporating universal design into physical planning

Given the considerable costs attached to infrastructure projects, making the built environment as easy to use as possible for the maximum amount of people makes financial sense. The building or space in question is future-proofed and the need for expensive and time-consuming retro-fitting is lessened.

Shared Space

Shared space, which normally involves the removal of, or reduced, demarcation betweenareas traditionally used by vehicles and pedestrians, has become an increasingly popular feature in our towns and cities. The approach is based on asserting the function ofstreets as spaces in order to improve quality of life, visual amenity, local economicperformance and environmental quality.

However, incorporating level surfaces as part of shared space schemes cancreate navigational difficulties for people with vision impairments and negativeperceptions of road safety among these users.

Each scheme should,therefore, be developed according to context and include features that allow peoplewith vision impairments to navigate effectively.

There may be a solution in the creation of ‘safe space’ within shared space schemes, equivalent to the traditionalfootway, usually located to the side of level surface streets. However, additionalinvestigations are required to establish the most appropriate way to demarcate this‘safe space’ from the shared area and allow users to cross the vehicle track.Planners should be mindful of these challenges presented by shared spaces andshould engage with representative organisations in considering such schemes.

Enforcement

With regard to the existing obstacles to be found in our urban areas, the NDA would welcome the consistent and rigorous application of the existing legislation in relation to vehicles[6]. Monies earned from the prescribed fines could supplement funds available to improve the measures already addressed in the draft Strategy and in this submission.

Appendix A

Commitments in 2030 Vision

The NDA welcomes the following commitments in the Draft Strategy:

  • Under the high level objective to build and strengthen communities, the objective to improve access for disadvantaged people (including physical access for mobility impaired people)
  • The Strategy needs toensure transport facilities are designed withthe needs of people with disabilities in mind
  • Integration of public transport (better travelinformation, simplified fares and ticketing,improved interchange including park andride, better access for cyclists, easier accessto public transport for mobility impaired anddisabled people)
  • The requirements of disabled people as pedestrians,public transport users and motorists should also befully taken into account.
  • The elements of local level planning which are of particular importance for theStrategy include:The needs of disabled and mobility impaired people
  • Crossing points need to be safe and easy to use,especially for mobility impaired and disabledpeople. Pedestrian islands, where provided, need tobe large enough to cater for adults with children and those in wheelchairs.
  • The Authority will prepare and issue design guidelines for bus stopping areas, to ensure a consistent standard and high quality approach in the provision of bus-stopping facilities.
  • All bus fleet vehicles on services procured by the Authoritywill be fully wheelchair accessible
  • The Authority will seek the provision of high quality rail stations and tram stops, including: Stops, stations and trains that are fully accessible by mobility impaired and disabled people
  • The Authority will seek:An appropriate quality taxi vehicle fleet,with a share of the fleet being wheelchairaccessible to serve established needs; andthe establishment and monitoring ofappropriate taxi vehicle standards, as part ofthe taxi licensing system
  • There will be a continuing role for communitytransport over the Strategy period, to providetransport services to schoolchildren, the elderly,mobility impaired and others, especially in ruralareas. Opportunities for efficiency savings inservice provision, by creating partnerships acrossthe health, education and community sector,should be availed of to ensure these services areretained or expanded.
  • There is alsoa need to determine adequate overall kerb-spaceallocations for special uses in Designated Towns andDesignated Districts, addressing disabled parking

Appendix B