The second five year review of the Disability Standards for Accessible Public Transport has been announced. The due date for submissions has been extended to Friday 31 May 2013.
On Tuesday 16 April 2013, the Disability Advocacy Resource Unit (DARU), convened a forum to assist disability advocacy organisations and people with disabilities to prepare submissions in response to the review.
Visit the Review website for submission details and dates for upcoming public consultations:
This is a summary of the key points made at the forum with relevant documents and links provided below.
Presenters at the forum:
Policy and Programs Manager at VCOSS, All Aboard facilitator
Llewellyn opened the forum by giving us an overview of the Disability Discrimination Act (DDA) and the Transport Standards.
The DDA is commonwealth legislation which came into effect in 1992. It aims to reduce discrimination against people with a disability. A subordinate piece of law is the Disability Standards for Accessible Public Transport. These standards set out basic criteria for what accessible public transport should look like.
The Transport Standards must be reviewed every five years. The first review was done in 2007. The Government response to the review was released in 2011. Not a great deal of changes have been put in place since then.
It is important to note that the Transport Standards are a set of technical guidelines. They are just a benchmark. They say things like a person should know where they are on a journey at any given time. The Transport Standards cover air travel, trains and trams, buses and boats.
Sometimes, there are overlapping responsibilities between state and territory governments, and the commonwealth government. Some service providers say that making changes will cost too much so they apply for exemptions from the Transport Standards. This means they don’t have to do what the Transport Standards say.
The 2007 review report made 15 recommendations. The Government agreed in principle with the recommendations but not much has happened since the report was released.
When considering your submission, you may want to take the following things into account:
- The 2007 review says that school and community buses are exempt from the Transport Standards. We think that all buses should be included. Children with a disability should have the same access to bus travel as other children.
- Do you think the transport Standards are effective?
- At the moment the only way things can change is if a complaint is made.
- What happens when milestones aren’t reached? What level of accountability should there be?
- How should the Transport Standards be enforced?
National Policy Officer at Blind Citizens Australia, and one of two consumer representatives on the Australian Public Transport National Advisory Committee
Jessica shared ways of how advocates could be more strategic in their submission and highlighted areas of concern that everyone was encouraged to include.
It’s important to focus on three or four critical issues that impact on your membership. Make sure these issues go beyond the individual, for example, the inaccessibility of one bus stop will not be picked up by the review of the Standards however signage and access to information at a bus interchange, are more likely to be considered.
Examples Jessica provided for her particular cohort included access to information compliance with information provision and acceptance of dog guides in taxis,
It is really powerful to include quotes that provide a personal experiences and/or case studies.
If you cannot make your own submission, look at joint submission by providing a supporting letter or contributing some other way.
Attending a public hearing is really important. If there are a lot of people with disabilities present then points can be made much more strongly and clarification can be sought on the spot.
Have a look at the recommendations made in 2007 and emphasise what has and hasn’t been adopted. Many recommendations haven’t progressed very far.
Key critical concerns that Jessica highlighted include:
- Wheelchair accessible trans (WAT) timelines
- School bus and community transport exemption
- Effectiveness of the complaints mechanism – this is critical that this appears in all of our submissions. The onus cannot be on one individual to make a complaint.
- DSAPT is not linked with funding.
- Include new barriers, Innovations and developments and gaps in coverage
Your submission should be questioning enforceability of the standards and enforceability of recommendations that come out of the report.
Project Officer and Advocate from Youth Disability Advocacy Services
Bec talked specifically around the issues faced by young people with disabilities and public transport.
Young people with a disability are often using, or would like to use, public transport at all hours of the day and night to attend education institutions, to socialise or to get to casual work. Lack of services/accessible services at off-peak times, combined with the inaccessibility of trams makes living life and getting around difficult.
Tram accessibility is a huge issue (including piecemeal accessibility/or accessibility that is not actually useable. Lots of young people with disabilities want to live in the city but many areas of the city are not accessible by trains. Compounded with the lack of tram inaccessibility, the choices of where young people can live, work and socialise is seriously impacted.
The Standards are inaccessible – they are not widely known about and not easily understood. Young people cannot make systems accountable if they can’t access or don’t know about the tools to do so. They need to be broken down so they can be understood, well publicised and available in alternative formats.
The complaints system is ineffective and disempowering. Service providers feel like they can’t be touched.
Stations need to be made as safe as possible. People with disabilities are some of the more vulnerable public transport users generally, let alone at night, when young people want to travel.
Public transport gives able-bodied young people the opportunity to get around without licences and/or in a way that is less costly. It is unjust and discriminatory that young people with disabilities can’t access the system to the same extent.
Not having buses covered in the standards impacts on the inclusion and capacity for young people with disabilities to access education. This has a whole range of life-implications for them.
Youth Disability Advocacy Services steering group member
Jarad provided a personal account of his experience negotiating the complaints system.
The questions from the Issues Paper, Section C: For disability sector and public views, was used to trigger discussion in small groups.
“Questions for people with a disability, their representative organisations and the community generally:
- Has your accessibility to public transport improved since the commencement of the first Transport Standards review in 2007?
- As a public transport user, are there areas of the Transport Standards where you consider that a more specific requirement for compliance would improve accessibility?
- To what extent do you feel that the requirements in the Transport Standards address all of the accessibility requirements for people with a disability? Are there gaps in the coverage of requirements?
- Do you find that the current processes with regard to making a complaint or seeking information are sufficient or sufficiently responsive?
- As a body representing the views of people with a disability, do you have any specific responses or perspectives with regard to the issues raised in the questions above?
- Other key issues you would like to see addressed?”
DSAPT Review website (off-site)Review Terms of Reference (RTF)Review Issues Paper (RTF)Review 2007 Final Report (DOC)The Standards_2002 (html)