We have replied to NIR today and attached a copy of all your comments A full text of our email is set out below Dear Sir Re Dog Policy We refer to your email 3rd inst. and are pleased to note that you are reviewing your policy which requires Dogs to be carried in a dog carrier on trains, which is tantamount to a ban, particularly for pensioners and mobility impaired. We would urge you to undertake this review and bring your policy in this respect into line with that in the rest of UK without delay. We would in particular draw your attention to the following points :- Compliance with DDA and discrimination. 1 The policy is discriminatory in that it treats Dog owners in Northern Ireland less favourably than those in the rest of the UK 2 The policy is also discriminatory with respect to the Disabled, Passengers with particular needs and the aged since it imposes a restriction on such persons travelling with their pets that cannot be complied with by them in the same way as it can be complied with by an able bodied person. This constitutes direct and/or indirect discrimination. We would remind you that under DDA “The service provider may have to change a practice, policy or procedure which makes it impossible or unreasonably difficult for disabled people to use their services.” Clearly imposing a requirement that a dog must be carried in a dog carrier makers it “unreasonably difficult” for a disabled person to travel by train with their dog in the same way as an abled bodied member of the public can do . We have examined your Equality Impact assessments for the past few years and we can see no reference to such an assessment having been carried out in relation to the Dogs in a carrier policy. Please confirm if such an assessment has been carried out and forward a copy thereof. Please treat this request for a copy of such Equality Impact Assessment (EQIA) as a request under the Freedom of Information Act and forward within the 20 day period set forth therein. We would remind you that not all persons who are disabled have “Assistance Dogs” since the dog may be a companion dog and therefore would not qualify under the Assistance / Guide Dog exception. 3 We note your comments on Final EQIA/screening summary report September 2008 that “Older people are more likely to have limited mobility and that more than half of people aged 75+ are disabled. Older people may have to give up driving as their physical abilities decrease; for some this may mean using public transport on a regular basis for the first time in their lives” but as a result of your policy such people will not be able to travel by train with their dogs. This is unfair in that it excludes those who most require access to the service 4 Social obligation “public transport … should be a reasonable option for all members of society [including those with dogs] and a useful tool in combating social exclusion in respect of travel to employment, education, etc It is more likely that the disadvantaged will not have access to a car and thus your policy affects them to a greater extent by taking away their ability to travel with their dog on public transport. 5 Disability “The data analysis showed that high proportions of disabled people use public transport on a regular basis” Again those persons will not be able to travel with their dogs if they have to carry them in a dog carrier. Statutory Duty In “A New Start for Public Transport in Northern Ireland’.it was stated that one of the statutory aims of the Government in relation to public transport is to “ create an effective, efficient and sustainable public transport service that contributes to the Government’s mobility, environmental, social and economic objectives. The overall aims of the Public Transport Reform proposals are to deliver a public transport system that: supports the implementation of the Regional Transportation Strategy; provides safe, efficient and high quality public transport services; complies with EU regulations; encourages the greater use of public transport;” Since current estimates put the number of households owning dogs in NI at around 35% we fail to see how excluding in the region of 35% of potential users of trains contributes to the aim of encouraging the greater use of public transport .The policy is therefore in breach of NIR’s statutory duty to provide a service to all of the Northern Ireland public. Market Research We note that the only justification you were able to provide for this unfair and discriminatory policy was market research. We would remind you that you are not a private business whose only aim is to maximise profits but rather a heavily subsidised public transport provider whose main accountability is not to shareholders but to taxpayers thorough their elected officials. Market research is therefore not sufficient justification for excluding as many as 35% of these taxpayers, whose money is used to subsidise your operations, from full use of the services provided. In any event so that we may assess the validity of this “Market Research” referred to please provide the following (soft copies will be sufficient) 1 copy of the market research report, 2 when was it commissioned 3 was it independent 4 Provide full details of the questions asked, the size of the survey, the location and timing of the research. 5 Provide copies of the Minutes of meetings of the committee or board meetings at which the proposed policy was discussed and the decision taken to implement the policy and the dates thereof and whether the persons attending those meetings had the benefit of the results of the research forwarded to them in advance . Please treat requests 1-5 as a request under the Freedom of Information Act 2000 and forward within the 20 day period set forth therein. Since you are now reviewing your policy we are happy to assist with some “market research” of our own and attach hereto a schedule of comments posted to our Facebook page. We would urge you to consider them carefully during your deliberations Conclusion We await hearing from you without delay and trust that good sense will prevail and the policy re Dogs on NIR will be changed to bring it into line with that in the rest of the UK. Regards Dog Lovers NI comments RE NIR.doc comments RE NIR.doc 636K View Download
Posted on: Wed, 31 Jul 2013 11:52:17 +0000
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