How to write a submission for the Getting Nowhere campaign

What are submissions?

Submissions are opportunities to share your opinion on a specific project, plan, or design that the government intends to put in place in the future. They are an opportunity to share your voice and point out what isn’t accessible. Often people design things that they think are accessible but are not, so we need to tell them what isn’t safe!

This guide focuses on public transport infrastructure plans developed by local authorities and the National Transport Authority (NTA). The recommendations and decisions made in these plans have a significant impact on local communities in the future and it is important that these transport plans are designed accessibly for people with disabilities.

Submissions made by the public, on public plans and designs, are an important way to raise concerns and highlight accessibility issues that need to be addressed before plans and budgets are finalised and projects begin.

Your voice matters- there’s no wrong way to make a submission!

  • We’ve included a lot of information below to help you write a submission, but any input in any format helps! Send in a single sentence, captioned photos, or use our template!
  • Don’t be intimidated. There is no wrong way to write a submission.

Where to find submissions

  • The National Transport Authority (NTA) has a website that is updated with open and upcoming submissions. This is a great place to check for submissions: https://consult.nationaltransport.ie/en/browse
  • Check BusConnects website, and look for open consultations: https://busconnects.ie/
  • Check out IWA’s social media, where we post about open submissions

5 Steps Overview

  • Step 1
    Find the correct contact details for the public service provider you are complaining about.
  • Step 2
    Prepare your complaint to your public service provider and send it.
  • Step 3
    Wait for a reasonable response time from your public service provider.
  • Step 4
    Prepare your complaint for the Office of the Ombudsman. Assuming the public service does not resolve the problem - you can now complain to the Office of the Ombudsman.
  • Step 5
    Lodge your complaint directly with the Office of the Ombudsman.

5 Steps in detail

Step 1: Introduce yourself

Say your name, talk about who you are.

Include how the proposal is relevant to you.

  • Is it near where you live? Work? Frequent? What community do you represent? Is that community impacted by this proposal? Think about how this impacts you and include that in the introduction!
Example: My name is Aoife, and I live in Donnybrook, near Donnybrook road where a new project is being proposed. I have lost 90% of my sight over the past 10 years, which has meant that I have had difficulty going out in my local area. The new project proposal for donnybrook road would make it even more difficult for me to go out. The local area is becoming more inaccessible, instead of more accessible.

Step 2: Tell your story

If you have a story that is relevant to the issue you are experiencing, include it! Stories help illustrate to others how something is inaccessible in a concrete way.

An example could be “the proposed features in the donnybrook project are like other floating bus stops I have had to try and use in Dublin. At one of these floating bus stops, a cyclist came from the right and refused to stop for me as I crossed. Instead, the cyclist went around me and nearly collided with me.”

Step 3: Describe the inaccessible feature

Describe how the feature is inaccessible.

Example: “Without a crosswalk with a signal, I can’t safely cross to get to the bus because I can’t see or hear the cyclists coming or move fast enough to avoid incoming cycle traffic.”

Step 4: Include your ideal solution

Example: “The crosswalk in the new project should include a signal that has visuals and audio and requires the cycle to stop at the pedestrian crossing.”

TIPS:

Try to avoid vague statements:

Say what you don’t like, why you don’t like it, and what you’d like to see happen. This helps the people reviewing and summarising submissions to have a clear picture of what to tell the government.

Mention other sources:

Mentioning research helps support your submission. We encourage you to include our research, as the more that similar requests are repeated in submissions, the more weight the government will give it.

  • You can mention how ‘mandatory accessibility regulations’ that are in line with UN Convention on the Rights of Persons with Disabilities (UNCRPD) Article 9 and General Comment No. 2 are needed to establish better accessibility.
  • You can mention that Shared spaces are, “Generally not supported by people with a disability and is not recommended by IWA as a safe and inclusive design approach to the design of urban streetscapes,” according to the Irish Wheelchair Association, ‘Best Practices Access Guidelines: Designing Accessible Environments’

If you are unsure what to look for in a proposal that is inaccessible, here are some features our members have mentioned:

Shared space, or sometimes known as ‘pedestrian and cyclist zones’. This is defined as spaces wherein pedestrians and cyclists or e-scooters interact without any separation

image showing example of
Source: Dublin City Council
image showing wheelchair user trying to cross cycle lane at floating bus stop
Source: IWA

Floating bus islands without stopping mechanisms for cyclists. Floating bus islands are defined as bus islands where cycle lanes intersect the footpath and the bus stop and in doing so separate access to the bus stop from the footpath.

image showing wheelchair user and cyclist at intersecting cycle lane
Source: IWA
image showing intersecting cycle lane with no stop controls
Source: IWA

Disabled parking bays that are lined on both sides with live traffic (cycle or vehicle)

‘Zebra crossings’ or unmediated crossings. Unmediated crossings are defined as pedestrian crossings that do not have signals that audibly and visually indicate when cyclists must come to a stop to allow for pedestrian traffic, and therefore when pedestrians are safe to cross cycle lanes.

image showing example of zebra crossing on street
Source: National Cycle Manual, figure 4.109.

Step 5: Send your submission.

Where to submit: Send it directly through the website where you found the submission or contact the access officer to ask for them to help direct your submission. Access officers are a provision included in  The Disability Act (2005):

26 (2) Each head of a public body referred to in subsection (1) shall authorise at least one of his or her officers (referred to in this Act as “access officers”) to provide or arrange for and co-ordinate the provision of assistance and guidance to persons with disabilities in accessing its services.[1]

 What happens after you submit a submission?

  • The government body will review all submissions and comments and develop a report that tells the public how they are considering the feedback
  • Let us know! We want to document the number and type of complaints given so that we can emphasize this in our lobbying efforts.

 Need help getting started? Use our template.

Example:

[Introduce yourself, and what communities you are part of]

Article 9 of the UN Convention on the Rights of Persons, states that for persons with disabilities (UNCRPD) to live independently and fully participate in all aspects of life, they need to have access to accessible transportation, infrastructure, the built environment, information and communication processes and technologies.

I am writing because [insert proposal] is not accessible in the following ways [list ways].

  • In this section include:
    • Which features are inaccessible and how they are inaccessible to you
    • How the inaccessible features impact you
      • Does it make you not want to use the space? Does it make it harder for you to get around? Or to use public transportation?
    • Tell them how you want them to fix the issue.

I believe that these issues stem in part from the absence of mandatory accessibility regulations required by UNCRPD Article 9 and General Comment No. 2; these need to be in place to ensure the accessibility of public services, as is the responsibility of public entities according to the Disability Act 2006, Section 27. You can read more about the need for mandatory accessibility regulations on [insert IWA’s transport website].

Know your rights

  • You have the right to access government services, and the right to request reasonable accommodations where the information is not accessible to you.

UNCPRD’s Article 9.1(b) requires States to act to ensure information is accessible. The Equal Status Acts require that goods and services provide reasonable accommodations to those who would otherwise not be able to use those services. The Disability Act also requires organisations that provide services and information to accommodate the needs of people with disabilities.

If you need submission materials in another format, you can request accommodation.

  • How to request accommodations
    • Contact the department directly, or via an access officer to request materials be provided in a format accessible to you.
  • Key Contacts:

Resources used