Mr. Robbie Sinnott:

There is a bit of drilling in the background, so if there is any noise that is just the way life goes. I am sorry about it.

I represent Voice of Vision Impairment. I realise the metaphor of vision being used. I am equally happy with the term "visual impairment", which is possibly more appropriate. For the purposes of rhythm, we thought "Voice of Vision Impairment" was easier and better.

The first two speakers were eloquent. I hope we can complement them, in substance at least. I will try to provide lived experience and legal opinion and rights. A legal opinion was recently obtained by Voice of Vision Impairment. It concerns Article 4.3 of the Convention on the Rights of People with Disabilities, CRPD. Article 4 consists of general obligations. If we are dealing with Article 29, which is about political participation, people should first and foremost go to Article 4.3 because it is cross-cutting. It is explained by a 10,000 word document from the UN committee, known as general comment 7. Article 4.3 states that there shall be close consultation with representative organisations. The only representative organisations in terms of disability under the CRPD are disabled persons organisations, as our legal opinion shows. This is a complete change. Instead of service providers which, because of brand names, etc., are the traditional go to, the new experts are ourselves.

We need supports to manage this and make it work. A combination of reasons and things that are happening mean it is not working. There is State indifferent. Third parties such as disabled service providers and the disability industry are trying to colonise or otherwise appropriate the disabled persons organisations, DPO, space, and because they have traditionally done so they have been seen as the representative organisations, which they can no longer be.

A DPO is any organisation that is led, governed and directed by disabled people. A clear majority of its members have to be disabled. It has to be completely independent of the State and other NGOs, including service providers, and they have to be human rights-based and based on a social model which is compatible with the CRPD. Certain long-term supports are needed so that this sort of thing can happen. Such long-term supports would be, for instance, the registration of DPOs.

Deputy Wynne submitted a question to the Department of Children, Equality, Disability, Integration and Youth in July and found that the Department has no plan to register DPOs. How can it support something that it is not even registering? To our knowledge, there are six national DPOs at the moment.

A second support that is needed is the protection of DPO rights, which needs to be legislated for in terms of monitoring and remedy. Even that consultation process can be avoided if the Department is ignoring DPO rights. We have to remember this is cross-cutting. If there is only one thing anybody needs to know about the CRPD, it is Article 4.3 and general comment 7 which states that DPOs are at the heart of the CRPD. Without Article 4.3, the whole thing falls apart.

The State, in its interim report in December 2020, did not mention Article 4, let alone Article 4.3, at any stage. It made two references to DPOs. There are two elements of low-hanging fruit that we can deal with easily. A memo could go out to all Departments and quangos – there are about 600 quangos in the State - stating that DPOs need to be prioritised and distinguished in all consultations. That does not mean aggregated. The word "distinguished" means that there has to be separation. There is no point putting us under a deadline, making us queue and treating us as one out of a 1,000 organisations. We are the experts in an area of accessibility, and that has to be recognised. That is the first thing that could easily be done. Registration could be easily established as low-hanging fruit.

I am not reading anything. I do not remember something I was going to mention, but everything is in our submission. There are emergency problems at the moment.

In terms of emergency things we need to get done, the Department is currently working on something called the UN CRPD implementation plan, which will be the guidance for the disability steering group for next January. The problem is that, once more, it is not going near DPOs. It is dealing with what it calls the Disability Participation and Consultation Network, DPCN which, as our legal opinion shows, does not remotely comply with Article 4.3 of the CRPD. A tiny minority of its members are DPOs and it is controlled by non-DPOs. The DPCN says it is not a DPO space. This does just not wash. We see this as being an opportunity cost and distraction from the actual needs of DPOs in terms of rights.

The European Accessibility Act, a directive from 2019, has to be made law by June 2022. There has been no consultation with DPOs. This is very unhelpful. We submitted a question to the Department in July and that has been ignored.

On the transport front, the Minister for Transport recently said that local authorities will receive extra powers under e-scooter legislation in December. Streetscapes are disabling because they ignore the needs of people with visual impairments and all pedestrians. A pedestrian is vulnerable if he or she is put up against an articulated truck or a cyclist in a shared space because one side will come off much worse than the other in that situation. We are again being ignored. What the Minister is proposing flies in the face of the CRPD. We have contacted the Department and NTA regarding our worries about transport, and the Department in particular about the latest idea. It is a continuation of the practice of burying the voices of disabled people.

There is a perfect storm. The State is indifferent to DPOs while third parties are at a low level. We do not have the same branding as the NCBI or other service providers. We get zero funding from the State. That is something that has to be addressed. There are 55,000 blind people or people with severe visual impairment in the State, but they are unlikely to have heard of us. We do not have the same reach as other organisations. We have very limited social media skills because all of our members are visually impaired, most of them severely. There is a perfect storm against DPOs. The opposite needs to happen with some urgency.

Disabled persons organisations, DPOs, need to be involved in everything that this committee and the State are doing. They need to be at the heart of it.