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National Transport Authority consultation process on the Transport Strategy for the Greater Dublin Area: 2016 – 2035

January 2021


NCBI (National Council for the Blind of Ireland is Ireland’s national charity working for the rising number of people affected by blindness and vision impairment. At NCBI, we are working every day with people of all ages, from young babies to those reaching their 100th birthday. Most people we work with have some remaining vision, while only a small percentage are completely blind. Census 2016 figures show that there are currently 54,810 people with sight loss in Ireland and this number is rising [Source: Census (2016) Census 2016 Results: Profile 3 – An Age Profile of Ireland. Available at]. Last year, we offered support and services to approximately 8,000 people who are blind and vision impaired. Of this figure, 2,000 were new referrals to NCBI. The demands on our services are increasing as the population ages and the incidence of age-related sight loss escalates.

NCBI welcomes the opportunity to make a submission to the National Transport Authority in relation to its proposed Transport Strategy for the Greater Dublin Area, 2016 – 2035.

Public transport in a net-zero-emissions Ireland

NCBI of course understands and supports the need to protect the environment, and this includes using electric vehicles. We appreciate that the quiet engines of such vehicles also reduce “sound pollution.” However, people who have impaired vision rely on sound to judge whether it is safe to cross the road, when no accessible pedestrian crossings are available. For their safety, it is essential that additional sound is added to electric buses and cars, as well as to electric scooters, if new legislation permits their use on Irish roads.

In April 2014, the European Union agreed on its Regulation 540 / 2014 that all manufacturers must equip their electric and hybrid vehicles with an Acoustic Vehicle Alert System (AVAS). By 1 July 2021, all new vehicles must have an AVAS. Until silent vehicles have an AVAS to alert pedestrians of their presence, drivers of silent vehicles should be advised to drive with more care and caution, particularly in areas where there are pedestrians.

Improving urban and rural environments

Urban areas

Some years ago, mini coaches known as the “Imp” and the “Nipper” were made available within housing estates, to bring people to and from the bus stops used by the normal fleet of buses. This was really helpful. Restoration of this type of service would make life a lot easier for anyone living at some distance from a bus stop, who has impaired vision, and / or other disabilities.

Anyone who is older or has a disability in any way, such as having impaired vision, finds it more difficult to walk long distances, and to cross roads. Taking bus stops out of housing estates forces people to come to the nearest main road to catch a bus, which may be extremely difficult or impossible, for some people with disabilities. As a subsidised public service, Dublin Bus has a duty to provide for the least able members of society. “Nipper” and “Imp” buses did this very well indeed.

Rural areas

The United Nations Convention on the Rights of People with Disabilities, (UNCRPD) signed by Ireland, supports the right to travel independently. To say that Ireland supports the right of people with disabilities to travel independently, brings with it the responsibility to provide the means for them to do so.

In many rural areas, there is no public transport available. Most people who live in such areas need a car to get from A to B in their daily lives. People with impaired vision cannot drive, and are therefore dependent on family, friends, and neighbours to bring them wherever they need to go.

The provision of an accessible, reliable rural transport system would make it possible for people with impaired vision to travel independently, to connect with other people and services in their local area, to attend training courses, and to get to work.

If bus services connected towns and villages with train stations, it would enable people to extend their journey by train and travel further afield. This would be very beneficial to individuals who are blind and vision impaired, and people with other disabilities, especially those who live in remote areas.
It would also be very good for the environment, especially if electric buses were used with an Acoustic Vehicle Alert System for safety because many people in rural areas might give up their private cars if a reliable bus service were put in place. This would also cut down on emissions and help Ireland to meet its target.
It would obviously have to be a public service, provided by the State, as it is not likely to be a viable money-making business.

Impact of a changing age profile on transport planning

Many older people have excellent health, and have no impairment of either their mental, physical, or sensory abilities; but it is true that, as we age, very many of us do develop health problems such as heart disease, diabetes, dementia, and arthritis, as well as some mobility and sensory disabilities. This can make it difficult to use public transport, unless the transport is designed to accommodate users with a broad range of abilities and disabilities.

In the not-too-distant future, most of the population will be over 65 years of age, and there will be proportionately fewer younger people earning and paying tax, so that it will be more difficult for the Government to have enough money to provide services for those who need them. Therefore, it makes financial sense to maintain the independence and health of older people, by making it possible for them to travel independently, and to do as much as possible for themselves, for as long as possible.

The location of jobs, schools, and colleges

To avail of online training, a person must first learn how to use a computer, and that often means travelling to a physical school or college, where such training is provided. So even though online training is available, and many more people are using it because of the pandemic, there is still a need for public transport to places of learning.
Many jobs, too, cannot be done remotely, and require people to be physically present at the workplace.

Accessible information about transport services

Websites and apps are an integral part of our daily lives and that is no different for someone who is blind or vision impaired. Travel information, ticket booking, and timetables are all available online and on mobile apps. A person who is blind or vision impaired will use either magnification or screen reading software, but the website and app must be designed in such a way that it is compatible with these accessibility features.

The National Transport Authority and public transport operators must ensure that all its apps and websites comply with the new EU Web Accessibility Directive legislation being rolled out, which ensures that all websites and apps are accessible. NCBI can offer advice on accessibility standards as required.

NCBI also recommends that an accessible app and access guide be developed by public transport providers, to inform passengers of the accessibility features that they offer. TFL in London for example have developed a new accessible app to shows accessibility features at stations (see and Queensland Rail in Australia have also produced a station access guide which is available in hard copy and on their website (see – It is important that the hard copy of the guide be fully compliant with NCBI’s clear print guidelines. Clear print is a design approach that makes printed documents easier to read for everyone including people with low vision. NCBI are happy to advise further.

As well as provision of timetable information online, it should also be possible to get this information by simply phoning a number. This phone number should be well-advertised in ways that are accessible to people with vision impairments. Passengers could also this phone to ask for timetables, in the font size of their choice, to be posted to them. NCBI would be happy to advise further in the regard.

The future for ‘bricks-and-mortar’ retail – and what that means for the movement of people around cities and towns

Computer-literate people with good broadband in their area can shop online, and the pandemic is ensuring that more people are getting familiar with this alternative shopping method. It is therefore vital that online shopping sites are made accessible to customers who are blind and vision impaired because when the pandemic ends, many customers may not return to physical shopping and continue to shop online. NCBI would be happy to advise on ways to make online shopping accessible.

People using public transport to get to a shop or shopping area will need a cheap or free delivery service, especially when buying large goods, or large quantities of goods. Spacious lockers, in which to drop some items, while shopping for more, and from which home delivery could be ordered to bring all the goods home, is one possible solution.

If making these changes, or others, it is important that retailers understand the needs of customers with impaired vision, and other disabilities. It is as easy and cheap to provide accessible lockers, and set up an accessible delivery-request system, as to provide inaccessible goods and services. Many retailers do not understand the differences between accessible and inaccessible facilities and services. NCBI would be glad to provide advice at the procurement stage of goods and services. We would also be happy to provide disability and equality awareness training for owners, managers, and staff.

Outdoor seating used to be rare, in Ireland, because of our climate, but it has increased dramatically, first because of the indoor smoking ban, and then because of the pandemic. When tables and chairs are placed on footpaths, the space for pedestrians is reduced. Often, no barriers are placed around this furniture, or barriers which are not fit for purpose are used. Barriers around restaurant / café / pub seating must be designed and positioned in a way which makes it possible for people with impaired vision to pass safely. This also benefits other footpath users, especially wheelchair users, and parents with buggies and young children.

Luas Cross City – proposed new route to Finglas

The Luas Cross City route will be a very welcome development for people living and working in Finglas, and in the areas alongside the new route. The main concerns NCBI has with the Luas, in general, are:

  • Poor signage pointing to the presence of Luas stops, which in some places are not easy to find.
  • Not knowing where a tram is going, when it pulls up. People with impaired vision need to push the Help button to ask and find out. This was reluctantly accepted as a temporary solution, but that was several years ago and it is not acceptable as a permanent solution.
  • No audible signals to help people with impaired vision to cross tram lines safely and independently. The Railway Procurement Agency refuse to put accessible crossings in place, anywhere that pedestrians must cross tramlines. They have also removed the accessible crossing which was in situ at St. Stephen’s Green, when installing the extension to the Green Line called the Luas Cross City. This goes against both the equality legislation and the Disability Act 2005, as its deprived people with disabilities of a facility which had previously been available for their safety.Touchscreens for ticket purchasing are not accessible to people with sight loss because:
    a) they do not offer tactile or audible feedback and
    b) screens that are positioned in such a way where sunlight or streetlights shine directly onto them makes them very difficult to read even for people who have some useful vision.

NCBI is of the opinion that the tram’s destination must be announced audibly when it pulls up at a stop. If there are objections to this, perhaps an electronic tag could be carried by people with impaired vision, so that the audible announcement is only made when someone with such a tag is waiting at the stop. Alternatively, a port for headphones, backed up by technology to provide audible information at tram stops, and on train platforms, could be provided. Audible facilities of this kind are already available at ATMs provided by Ulster Bank. NCBI would be happy to discuss this further.


While NCBI supports the intention of the National Transport Authority to provide a better bus service, we have serious concerns about the proposal being put forward. Our main concerns are as follows:

  1. Island bus stops are unacceptable.
  2. The number of direct routes will be reduced, and it is unclear how interchange points will be laid out and structured, how long walking distances between bus stops at interchange points will be and how accessible the routes between bus stops will be.
  3. There is a lack of resources to train people with impaired vision to use new routes safely and independently.
  4. There is no information in the proposal about the availability of audio announcements.
  5. We have concerns about private companies following different procedures and standards to those met by Dublin Bus.
  6. We have concerns about communication between public transport users with impaired vision and the senior management of private bus companies.
    NCBI would be happy to discuss this further.

The on-going roll out of cycle tracks and greenways

The roll out of cycle tracks and greenways is very welcome if provision is made for the safety of pedestrians. It should include the provision of sufficient space for pedestrians, which segregated from the space used by cyclists by a change in level (that is, a kerb). Adequate and safely sited cycle parking facilities should also be provided wherever needed, so that cyclists do not attach their bikes to random poles, trees, fences or on the handrail of ramps needed by those who use a wheelchair.


Awareness training

People genuinely do their best to follow European or Irish regulations and laws but sometimes do not always fully understand the reasons behind them. They may then make mistakes which lead to a building, vehicle or service being less accessible than it could be. For this reason, NCBI would like an opportunity to provide Vision Impairment Awareness Training to decision-makers and the design team of the Metrolink before plans are finalised.

Disability and equality awareness training is also available from a consortium group. This is a team of experts in the fields of disability, some of whom have disabilities themselves, who provide specialist information and experiential training in mobility impairment including wheelchair use, vision impairment (this section provided by NCBI), deafness and being hard of hearing. Other experts can also be brought in to explain the needs of people with other disabilities, such as learning disabilities and autism.

This training would only take one day of the team’s time and could result in changes being made to the Metrolink plans, making it more accessible than it otherwise would be, and making costly and awkward retrofitting unnecessary.


NCBI has previously noted that when major changes are being made in public transport, the provision of good communication channels makes a huge difference to the smoothness of the implementation period. When Network Direct was implemented, great worry and distress was caused to many people, especially those with impaired vision, due for the most part to the lack of good communication; whereas when the Luas Cross City line was being installed, the Luas Information Office ensured that the process went as smoothly as possible by providing good communication with relevant stakeholders.

Vehicle design

Externally: Trams must be of a contrasting colour to their surrounding environment. It is vital that the visibility of the tram is considered, not just for people with low vision, but for the safety of everyone. If the tram is silent, additional sound needs to be added to the vehicle to make it safe, in areas where there are pedestrians – see above, under Public transport in a net-zero-emissions Ireland. It should also be fitted with a bell and a horn, like those used by the Luas.

Internally: As yellow handrails are in use in other public transport vehicles, it makes sense to use the same colour for the handrails in the Metrolink. The handrails should contrast strongly with the background against which they will be seen such as seats, walls, etc. and therefore yellow backgrounds are not acceptable.
The button to open and close the door of the tram should make a sound to help people with impaired vision to find it when it is ready to be pressed.

The buttons need to be sited between 900 and 1200mm above the tram floor and should be in strong contrast with the door. Ideally, the button itself should be strong yellow, like the handrails. If the door is not a dark colour, a black or other dark coloured band should surround the yellow button, to increase its visibility against the door.

Door opening buttons should provide audible, tactile, and visual confirmation that the button has worked as follows:

  • Audible: a beep should sound to confirm that the button has been activated.
  • Tactile: buttons should move in, and spring back out, when pressed.
  • Visual: the button should display a coloured light when pushed.

If lights are provided on or around the button to help people to find it, then the visual confirmation that it has been pressed could perhaps be a change in colour of the lights, or that the light switches off, before going back on again.

An emergency call button should be provided in carriages, with CCTV focused on it so that if someone presses it without good reason, or by accident, this will be seen.
NCBI would be happy to discuss this further.

DART expansion

As the DART network expands, money from the funding for this should be allocated towards the provision of:

  • reliable and accurate audible announcements on platforms, and
  • reliable and accurate audible announcements on trains.

NCBI has been requesting this for decades, and has received excuse after excuse, instead of a determined commitment from Irish Rail to ensure that this public service is made accessible. This is in defiance of equality legislation and the Disability Act 2005. Without reliable provision of audible announcements, the Irish rail system is not accessible. All public services are obliged by law to be accessible to everyone.

When expanding the DART service, it is important to ensure, at the procurement stage, that all new equipment is accessible for people with impaired vision, and other disabilities. It is important that during procurement stage, buyers remember that touchscreens are inaccessible for people with impaired vision. (see above, under “Luas Cross City”) and consider providing a port for customers’ own headphones, to allow them to access information in an audible way.

Further information
NCBI would welcome the opportunity to elaborate on the issues raised in this submission.

June Tinsley
Head of Advocacy and Communications
Whitworth Road
Dublin 9
01 8307033
087 9955076