An Bord Pleanala, 64 Marlborough Street, 1.

9th. August 2010

Center for Independent Living Carmichael House North Brunswick St Dublin 7

Case Reference: PL29S.NA0005 Closing Date: August 18th, 2010

Dear Sirs,

Enclosed please find submission in relation to Railway Order in respect of underground Electrified Heavy Railway from to , Dublin (DART Underground). Cheque in the amount €50.00 enclosed.

Yours sincerely,

______David Egan

Telephone: 01 873 0455 Mobile: 086 8226355 Email: [email protected] Website: www.dublincil.org

Issues Concerning accessibility for people with reduced mobility on

DART Underground

A Submission on behalf of the Center for Independent Living

The Center for Independent Living (CIL) offers the following views and observations in relation to the application for a Railway Order by Coras Iompair Eireann for an underground Electrified Heavy Railway from Inchicore to East Wall, Dublin (DART Underground).

CIL welcome this vital new piece of transport infrastructure which will link all of Dublin’s public transport systems including Red and Green lines, Mainline Rail at Heuston and Connolly Stations, the Dublin network, and the proposed Metro North.

CIL understand that all new stations on the proposed DART Underground will accommodate wheelchair users in line with relevant legislation and best practice guidelines both national and international.

CIL wishes An Bord Pleanala to take a view on the accessibility of the entire system, including the platform/carriage interface, in respect of wheelchair access. CIL are mindful that the rolling stock which Iarnrod Eireann propose to use in operations on DART Underground may not form part of the planning process.

However, the carriages interface with the station platforms, which do form part of the planning application, will be critical to wheelchair access. It is not possible to view rolling stock and platforms as separate entities in the context of wheelchair access as it is the interlocking nature of their relationship which will determine the accessibility of the system.

The European Community Directive 2008/164/EC, which came into effect on July 1st., 2008, applies to all rail systems in Ireland. The directive concerns the Persons with Reduced Mobility Technical Specifications for Interoperability (PRM TSI) on conventional and high speed rail systems.

TSI states that “a boarding aid shall be provided” and the Infrastructure Manager and the Railway Undertaking shall decide who is responsible “for provision of boarding aids” and to “ensure that the division of responsibility they agree is the most viable overall solution.” It is the case of this application that the Infrastructure Manager and the Railway Undertaking are a single entity.

It is therefore our opinion that the question of the “most viable overall solution” should form part of any decision by An Bord Pleanala.

CIL define wheelchair access, in the context of this submission, as the ability of the users of both manual and electric wheelchairs, to have unassisted access to every aspect of DART Underground. Unassisted access means moving freely within the entire system without the need to request manual assistance when boarding or disembarking DART Underground carriages (ie a roll-on/roll-off system as operated on LUAS).

CIL understands that there is currently no defined stepping distance between the proposed new platforms and DART rolling stock but that there is an aspiration on the part of the operating company (Iarnrod Eireann) to have a “stepping distance target of 20mm vertical and 50mm horizontal. These targets have not been verified as feasible, however, Iarnrod Eireann will endeavour to achieve them” (letter from Minister of Transport to Sean Connick TD, Feb 2010).

The stepping distance outlined above (56mm in total) will require that some wheelchair using passengers would have to request assistance from Iarnrod Eireann staff to deploy manual ramps for the purpose of boarding and disembarking rolling stock.

Such a deployment would render the DART Underground ineffective, inefficient, and a deterrent to potential passengers with disabilities.

The Central Statistics Office National Disability Survey 2006 found that difficulty getting on and off public transport was the reason 16% of disabled people did not use it. In a Department of Transport Survey of train users with disabilities (Sectoral Plan for Accessible Transport under the Disability Act 2005, Transport for All 2008 Edition) 95% of respondents stated that getting on and off trains was their biggest issue.

Deploying manual ramps in a busy underground station would be impractical. Wheelchair passengers could be left unassisted in carriages unable to disembark. This has happened occasionally on existing DART lines.

The cost to the already heavily subsidised operating company of providing assistance over the lifetime of the infrastructure would be prohibitive. The indirect cost of slowing the entire network to accommodate wheelchair passengers boarding and disembarking with the use of manual ramps and assistance would bring DART Underground into disrepute.

It was noted above that DART Underground will link with the network, the existing LUAS lines and the proposed Metro North. The Dublin Bus fleet will have one hundred percent unassisted access foe people with disabilities by 2012. Both LUAS Red and Green lines currently offer unassisted access to disabled passengers as will the proposed new LUAS lines.

It is proposed that Metro North will have access similar to the current LUAS system, unassisted. Transport Access for All, 2008 Edition, published by the Department of Transport, states “metro services will incorporated the most up to date accessibility provisions for people with mobility, sensory and cognitive impairments in line with those already provided on the LUAS network.”

This single piece of infrastructure which is intended to link all of the above unassisted accessible public transport systems will require that wheelchair users seek manual assistance. CIL believe that such a proposition is both unthinkable and untenable.

It is therefore our position that An Bord Pleanala should set as a condition for its approval of the CIE Railway Order application that the applicant demonstrate how they intend to achieve unassisted wheelchair access on the DART Underground using platform based solutions, or with carriage integrated automatic ramps.

In addition, Iarnrod Eireann should be required to state the stepping distance they intend to achieve between the carriage and platforms. In the absence of such a clear statement planning permission will be based on an aspiration.

The intention at present is to “endeavour to achieve” an overall stepping distance of 56mm. There is no guarantee that this stepping distance will be achieved. Indeed it is highly improbable that the carriage/platform interface will fall within a total 56mm tolerance at all interfaces.

Article 9 of the The United Nations Convention on the Rights of Persons with Disabilities (UNCRPWD) states that “to enable persons with disabilities to live independently and participate fully in all aspects of life, State Parties shall take appropriate measures to ensure to persons with disabilities access, on an equal basis with others, to the physical environment to transportation, to information and to communications.”

The Irish Government has signed the UNCRPWD and has signalled its intention to ratify the convention in 2010.

It is our view that requesting assistance to deploy a manual ramp falls outside of Article 9 of the UNCRPWD. This is particularly relevant when other more cost effective solutions are available which approximate more closely the right to “access on an equal basis with others”.

Platform based ramps are commonplace on heavy rail systems in Europe and have the advantage of being a relatively cheap way of eliminating any vertical gap. While this ensures access for some wheelchair users, it is not a catch-all solution as the horizontal gap may remain an issue for some users. However, platform based solutions do remove the requirement for assistance to deploy manual ramps. Trains will be obliged to stop in designated positions as set out in TSI.

Integrated electric or electro-hydraulic ramps offer a more complete solution responding to the problems of vertical gap, horizontal gap and platform variants.

It is our understanding at this point that no order has been placed for new rolling stock to operate in the DART Underground. The quantity of trains to be ordered will vary and could be anything between 100 and 400 carriages dependent on the expansion of the DART network. It is further our understanding that any new rolling stock will have at least one such electric ramp per train set.

However, DART Underground does not plan to exclude existing DART rolling stock from the new system. DART currently operate a fleet of 154 carriages. None of these carriages are fitted with electronic ramps and the operating company intends providing assistance to deploy manual ramps for use on existing rolling stock in DART Underground.

It is technically feasible to retrofit existing carriages with vertically mounted electronic ramps. Sub-floor ramps may not be technically feasible or cost effective.

A number of the existing train sets do not meet the specifications for operating in DART Underground. It is our understanding that as few as 80 vehicles of the current fleet will operate in DART underground. Carriages operate in configurations of two, four and six carriages per train set.

Given the requirement to fit only one electronic ramp per train set, the cost of retrofitting the existing fleet prior to DART Underground becoming operational in 2018 would be technically feasible and a cost effective solution. Such a retrofit could be built into a maintenance programme over a number of years which would not unduly impact on fleet availability.

CIL are of the view that, as a condition of planning, all DART rolling stock, including existing rolling stock, which will use the DART Underground system, will have at least one carriage per train set fitted with an electronic-hydraulic ramp for use by wheelchair users if required.