RNIB Comments to EDF on the 3d Railway Package, International Rail Passenger Rights and Obligations.

Where new text has been added to existing text it has been included between *...*.






General Introduction

Rail services, in all their respects should comply with the principles of social inclusion and access for all covering agreed standards of service delivery, passenger vehicle and infrastructure design, such as the COST 335 standards. This has to be a fundamental passenger right recognised in the 3d railway package.


Article 3

1. EDF COMMENT
(Article 3) This article on Travel Information only states 'information shall be provided in the most appropriate format', not clearly specifying that it shall be available in accessible formats.

RNIB COMMENT
An alternative text, (delete old text) :
"Travel information must be made available without delay or additional charge in alternative formats such as large print, braille, audio tape and/or electronically. This is so that blind and partially sighted people can plan their journeys before travelling. Travel information in all formats should be available 24 hours a day through an international free helpline."

(Blind and partially sighted people would be able to use this helpline to receive information about journey times, routes, station accessibility and as a means for requesting any personal assistance.)


2. EDF COMMENT
(Article 3) The information that must be provided, as set out in Annex I, makes no mention of accessibility on board the trains, or available assistance (at departure, transfer or arrival).

RNIB COMMENT
Annex 1 needs to be extended as follows :
"Accessibility and access conditions, *such as the availability of assistance for PRMs for every stage of their journey, including navigation through stations to other transport modes, and any route changes necessary.*"

3. There also needs to be a provision for information on accessibility during the journey.


Article 17

1. RNIB COMMENT
Article 17.1 : "Passengers shall be kept informed *through both visual and audible announcements* about the situation…"

2. EDF COMMENT
(Article 17 s.4) : particular attention to the needs of passengers with reduced mobility' is not strong enough - there must be a guarantee that any accommodation, transfer transport or alternate transport must be accessible and that there must also be provision of necessary assistance and communication in accessible formats.

RNIB COMMENT

Article 17.4 :

Agree with EDF comments. In addition it is especially important that blind or partially sighted travellers are provided with assistance in reaching hotels or the place where compensatory refreshments will be served.





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CHAPTER VI - Persons with Reduced Mobility

Article 27

EDF COMMENTS
Prohibition seems to be limited to issuing of ticket and making reservation rather than denied boarding, and furthermore, there is qualification that this shall only apply at 'main railway stations'. There should be no such qualifications.

RNIB COMMENT
The text should be changed to :
"A railway undertaking and/or a tour operator shall not refuse, on the grounds of a reduced mobility *or travel with an assistance dog*, to issue a ticket , *take a * reservation *or allow boarding * for an international service departing from *any* (delete "main") station."


Article 29

RNIB COMMENTS

1. All staff, whether at stations or on board trains, and those involved with design, should be trained by disabled people to understand the needs of those with mobility and sensory impairments as well as those with additional disabilities. However well-designed the rolling stock and stations are, there must always be staff available to give personal assistance. Many blind people travel alone often with luggage and/or a guide dog and need physical help. (This is no doubt equally the case for other disabled people.)

2. Staff should wear easy to recognise uniforms so that people with sight problems can identify them without problems.

3. Suggested changes to the existing text :
29.2. Amend the text as follows : "The station manager, shall designate points, *which through use of signage with strong colour contrast and tactile paving routes shall be easy for blind and partially sighted passengers to locate * within and outside the railway station. "


Article 30

EDF COMMENT
(Article 30) limits the requirement for assistance on board a train to cases where there has been 24 hours notice given, however, on the other hand station managers are nevertheless required to 'make all reasonable efforts' to provide assistance even when no notice is given.

RNIB COMMENT
Reference should also be made to 28-3 so that it is clear that it still applies that "all reasonable efforts" have to be made to provide assistance, even if 24 hour notice has not been given.


Article 33

EDF COMMENT
- (Article 33) Service quality standards in Annex IV should include : whether information provided is accessible, accessibility of trains and stations - (Article 33) report about railway undertakings service quality should be independent rather than published by railways themselves

RNIB COMMENT
Agree with EDF comment.





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ANNEX - How to Lessen the Problems Blind and Partially Sighted People Experience when Travelling by Rail

Design

All stations, including entrances and platforms, should be designed with features to help blind and partially sighted people according to principles of "design for all". Level entrances help all passengers, automatic doors help all passengers, information desks should be close to entrances and there should be a help button at the door or entrance of the station. Toilets should be located so they are easy to find and all doors should have a tactile letter or symbol to let blind people know the name of the room the door is opening into. Any seating should be easy to find and should be varied , some high, some low and some with arm rests. Lighting should be bright and should cover the whole station and platform with well lit signs. Lifts should be provided for those people who cannot use stairs or escalators. Lifts should have Braille and speech information. Stairs should have tactile markings at the top and bottom and handrails should go beyond the bottom and top step. All step edges should be marked in a coloured contrast. The gap between trains and the platform should be minimised and announcements should give an estimate of how big this is.

All rolling-stock should be designed with the needs of blind people being considered. The most important thing is to have clear on train announcements, information being given for every station, " The train will stop at…, the next station will be…., this station is."

There needs to be an external canvas barrier between carriages to stop people falling between the gaps between carriages having mistaken the space for a door.


Guide Dogs

Many blind people travel with a guide dog throughout Europe and facilities must be made available for the guide dog. There should be a Europe-wide free travel pass for all guide dogs, they should be allowed to travel on all parts of trains, including dining and sleeping compartments, a dog toilet area should be available at all railway stations. A seat with plenty of leg room and space for the dog to lie comfortably should be provided on all trains.

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