16 December 2020
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 being completely blind. Census 2016 figures show 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 www.cso.ie].
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.
We appreciate the opportunity to make a submission to the third round of public consultation on Core Bus Corridors (Bus Priority & Cycle Lanes/Tracks).
While NCBI supports the intention of the National Transport Authority to provide a better bus service, we have some serious concerns which we outline in our submission below.
Island bus stops
NCBI objects to the proposed new design of bus stops being proposed for the new bus corridors. NCBI is unable to support any form of cyclist prioritized bus stops or shared spaces as they significantly compromise the safety of individuals who are blind or vision impaired.
The new island bus stop design makes boarding and alighting from buses dangerous for people with vision impairments, who may neither see nor hear cyclists approaching. Therefore, this element of the Bus Connects plan is completely unacceptable to NCBI.
Cyclists still have the same three options as they had before which are to:
- stop and wait while passengers disembark and board at the stop;
- mount the footpath and cycle, which we do not recommend, or walk on the footpath behind the people boarding the bus and alighting from it; or
- overtake the bus on the outside.
This is exactly what cyclists do already and could continue to do. The only difference this design makes is to provide cyclists with a fourth option, which would be to simply cycle on through, between the footpath and the island, forcing people to wait while they do so.
So instead of cyclists having to wait, bus passengers will have to wait or risk stepping out in front of a bicycle, causing injuries to both pedestrian and cyclist, in the event of a collision. While it may not make a huge difference if only a couple of cyclists happen to be passing, it will make a very big difference if the numbers of cyclists keep increasing as they have been doing. In addition, electric scooters and bicycles who will also be utilizing these cycleways make the passage even more treacherous since the noise emitted from these is barely audible.
In the near future, there may be no break in the stream of cyclists passing between the footpath and an island bus stop, at peak times. Not only will this delay people who have alighted from their bus, and who need to cross to the footpath to continue their journey, it will also mean that people will not be able to get onto the bus, unless they are already on the island when the bus pulls in. If the bus driver waits for people to cross from the bus shelter to the island, to get onto the bus, and there is a long wait before there is a break in the stream of cyclists, then the bus service will be delayed. If the driver opts to stick to schedule and pull out, instead of waiting for passengers who cannot get across because of the cyclists passing between them and the bus, then people will be left behind at the bus stop. Neither option will result in the provision of a good, efficient transport system.
Bus Junction Layouts
NCBI supports the proposed typical junction layout where there is controlled crossings with audio tactile signals for pedestrians. This type of crossing provides a safe, controlled place for individuals who are blind or vision impaired to cross the road. They provide assurance that vehicles and bicycles have come to a standstill and the way is clear.
Bus Corridor Design
The NCBI approves of the bus corridor design. It does however seek confirmation from the National Transport Authority that the kerb will be a minimum height of 60mm and preferably higher in line with best practice.
Reduced number of direct routes
It is unclear in the Bus Connects proposals how interchange points will be laid out and structured. NCBI would like more detailed information. We would like confirmation of whether or not passengers with reduced mobility will be prioritized at interchange points to avoid it becoming a case of survival of the fittest at peak, busy times.
In addition, the National Transport Authority needs to recognise in its proposals that a short and easy walk between stops for someone with full vision is often much more difficult for someone who is blind or vision impaired. Many people with impaired vision also have other disabilities, which makes the extra distance more stressful and tiring than it would be for able-bodied people. Even where the distance between stops is quite short, the route could be inaccessible for people who are blind or vision impaired. There needs to be a firm assurance that at every interchange, the routes between one bus stop and another are fully accessible, and they will be maintained in good condition as a matter of priority, either by the National Transport Authority or by the Local Authority. This includes:
- no overhanging branches, or election posters mounted on poles with their corners projecting at face height;
- smooth, even surfaces underfoot;
- no vehicles or other obstacles blocking the footpath;
- detectable kerbs, and tactile paving in dished areas of kerbs at side roads;
- at busy roads, light-controlled pedestrian crossings with push button units and tactile and audible signals;
- Footpaths swept clear of leaves every day when necessary; and
- Where needed, provision of the correct tactile and visual guidance to help people with impaired vision to find their next bus stop.
Lack of training resources
Presently, there is one full-time and two part-time Travel Assistants under the Travel Assistance service, working from Dublin Bus, and paid by the National Transport Authority. NCBI has fewer than 5 trained and qualified Orientation and Mobility Instructors, working in the Dublin Area. Most of them are part-time, and all of them have other duties, such as Community Resource Work and Low Vision Assessments. None of them teach Orientation and Mobility full-time. The most up-to-date figures, from the 2016 Census, indicate there are over 15,000 people with impaired vision living in the four Local Authority areas of Dublin, and this figure is growing. See the table below:
|Blindness or a serious vision impairment||2011||2016|
If even 25% of people with vision impairment living in Dublin ask for training at the same time, it will simply not be possible for them all to get the training, with so few people trained and qualified to provide it. Therefore, it seems likely that large numbers of people with impaired vision will be unable to carry on their daily lives as normal, while waiting for training.
Of course, NCBI, and presumably the Dublin Bus Travel Assistants team, will prioritize the training of people who need to be able to get to work, or to schools and colleges. But even meeting the needs of the highest priority group will not be possible, simultaneously. Some of these high priority people will also have to wait in the event of wide scale changes to the bus network as envisaged under the Bus Connects proposals. With this in mind, NCBI is totally opposed to the entire bus network changing at once and should the network be changed it would need to be done on a phased basis.
Additional training to assist people who are blind or vision impaired to recognise the unique sounds of electric and hybrid vehicles in relation to the fleet upgrade is also pertinent. It is important to ensure public transport operators, including bus operators, provide appropriate supporting infrastructure at pick-up / drop-off points to facilitate the safe use by pedestrians who are blind or vision impaired. This is especially important for electric / hybrid buses networks.
Availability of Audio Announcements
NCBI would like to be able to assure people with impaired vision that the implementation of Bus Connects will not affect the availability of audio announcements. There is no mention of this in the Bus Connects proposal. NCBI would be grateful if the Bus Connects team could give us their guarantee that all buses including those run by Go Ahead and possibly other private companies will have audio announcements fully working, before, during and after the implementation of the proposal. Any disruption to the provision of audio announcements makes the bus service inaccessible for people with impaired vision.
Private bus companies
People who are blind or vision impaired would like to be sure that whatever bus they use, they are guaranteed the same standards of accessibility and customer service. Dublin Bus has consulted with NCBI to ensure the Disability Awareness Training given to their drivers is relevant, and of a high standard. However, it is essential that all transport operators in the network engage and apply the same standards as Dublin Bus.
Dublin Bus has User Group meetings, an Access Officer and can refer people to its Travel Assistance Service. They are easy to contact and are responsive to queries and concerns. A similar system and approach needs to be put in place with any private operators operating in the greater Dublin Network particularly if the network is to undergo major change.
The Wayfinding Campus
Bus Connects proposes that Botanic Rd will have segregated cycle tracks in both directions and no bus lane in the northbound direction due to how narrow the road is. South bound buses will have priority provision for 95% of the journey improving bus time and reliability. Due to the nature of the campus and the cohort of the user group-controlled priority pedestrianized access is critical. Also please consider the impact of any diversion of regional routes would have on those trying to access the campus.
We would be happy to discuss our submission in more detail.
Please contact June Tinsley, Head of Policy and Advocacy