ࡱ> "_ bjbjkk (:;\;\ϣ^^&&''''''8L'@(|'1(v2,H,(p,p,d.35$\ּ'j6B."d.j6j6ּ''p,p,R@R@R@j6d'p,'p,R@j6R@R@̧Pp,Z[&6L`^01#7#PP#'8d j6j6R@j6j6j6j6j6ּּ;j6j6j61j6j6j6j6#j6j6j6j6j6j6j6j6j6^> %:  SHAPE \* MERGEFORMAT  People with Disability Australia (PWDA) Submission on the Australasian Railway Association Exemption Application of 15 April 2015 17 July 2015 Contact Details Samantha French Advocacy Projects Manager People with Disability Australia (PWDA) Email:  HYPERLINK "mailto:samanthaf@pwd.org.au" samanthaf@pwd.org.au Phone: 02 9370 3100 Australian Business Number (ABN) 98 879 981 198 Table of Contents  TOC \o "1-3" 鱨վ People with Disability Australia 4 Forward: Access to transport as a human rights issue..4 Introducation 5 Group 1 Application for temporary exemptions from the Transport Standards  PAGEREF _Toc424890681 \h 6 2.1 Access paths Unhindered passage  PAGEREF _Toc424890682 \h 6 2.4 Access paths Minimum unobstructed width  PAGEREF _Toc424890683 \h 7 2.6 Access paths conveyances  PAGEREF _Toc424890684 \h 8 3.1 Circulation space for wheelchairs to turn in  PAGEREF _Toc424890685 \h 8 4.2 Passing areas - Two-way access paths and aerobridges  PAGEREF _Toc424890686 \h 9 5.1 Resting points - When resting points must be provided  PAGEREF _Toc424890687 \h 9 6.4 Slope of external boarding ramps  PAGEREF _Toc424890688 \h 9 8.2 Boarding - When boarding devices must be provided  PAGEREF _Toc424890689 \h 9 8.7 Boarding - Signals requesting use of boarding device  PAGEREF _Toc424890690 \h 10 11.2 Handrails and grabrails - Handrails to be provided on access paths  PAGEREF _Toc424890691 \h 10 12.2 Doorways and doors - Compliance with Australian Standard premises and infrastructure  PAGEREF _Toc424890692 \h 10 12.4 Clear opening of doorways  PAGEREF _Toc424890693 \h 11 14.3 Stairs - Compliance with Australian Standards conveyances  PAGEREF _Toc424890694 \h 11 15.2 Toilets - Location of accessible toilets  PAGEREF _Toc424890695 \h 11 15.3 Unisex accessible toilet ferries and accessible rail cars  PAGEREF _Toc424890696 \h 11 15.4 Toilets - Requirements for accessible toilets ferries and accessible rail cars  PAGEREF _Toc424890697 \h 11 17.5 Signs - Electronic notices  PAGEREF _Toc424890698 \h 12 18.1 Tactile ground surface indicators - Location  PAGEREF _Toc424890699 \h 12 20.1 Lighting - Illumination levels premises and infrastructure  PAGEREF _Toc424890700 \h 12 21.1 Controls - Compliance with Australian Standard premises and infrastructure  PAGEREF _Toc424890701 \h 12 26.2 Hearing augmentation listening systems - Public address systems conveyances  PAGEREF _Toc424890702 \h 13 27.3 Information - Size and format of printing  PAGEREF _Toc424890703 \h 13 28.1 Booked services - Notice of requirement for accessible travel  PAGEREF _Toc424890704 \h 13 28.2 Booked services - Period of notice of requirement for accessible travel  PAGEREF _Toc424890705 \h 13 Group 2 Application for temporary exemptions from the Transport Standards in relation to issues that were previously deferred  PAGEREF _Toc424890706 \h 14 11.2 Handrails and grabrails - Handrails to be provided on access paths  PAGEREF _Toc424890707 \h 14 21.2 Passenger operated devices for opening and closing doors  PAGEREF _Toc424890708 \h 14 21.3 Location of passenger operated controls for opening and locking doors  PAGEREF _Toc424890709 \h 14 Group 3 Application for temporary exemptions from the Premises Standards  PAGEREF _Toc424890710 \h 15 H2.2 (1) Access paths Unhindered passage  PAGEREF _Toc424890711 \h 15 H2.2 (3) Access ways  PAGEREF _Toc424890712 \h 15 H2.2 (6) Accessways  PAGEREF _Toc424890713 \h 15 H2.2 (7) Accessways  PAGEREF _Toc424890714 \h 15 H2.4 (2) Handrails and grabrails - Handrails to be provided on access paths  PAGEREF _Toc424890715 \h 15 H2.5 Doorways and doors - Compliance with Australian Standard premises and infrastructure  PAGEREF _Toc424890716 \h 16 H2.9 Toilets - Location of accessible toilets  PAGEREF _Toc424890717 \h 16 H2.11 Tactile ground surface indicators - Location  PAGEREF _Toc424890718 \h 16 H2.12 Lighting - Illumination levels premises and infrastructure  PAGEREF _Toc424890719 \h 16 H2.15 Controls - Compliance with Australian Standard premises and infrastructure  PAGEREF _Toc424890720 \h 16 Conclusion  PAGEREF _Toc424890721 \h 16 Regular reporting  PAGEREF _Toc424890722 \h 16 Direct assistance  PAGEREF _Toc424890723 \h 17 Multiple options for access paths and boarding  PAGEREF _Toc424890724 \h 17 Solutions rather than Exemptions  PAGEREF _Toc424890725 \h 17 National Code of Practice - Accessible Rail V1.00  PAGEREF _Toc424890726 \h 17  鱨վ People with Disability Australia People with Disability Australia (PWDA) is a leading national disability rights, advocacy and representative organisation of and for people with disability. We have a cross-disability focus representing the interests of people with all kinds of disability. Our primary membership is made up of people with disability and organisations primarily constituted by people with disability. We are a non-profit, non-government organisation. We are a member of the Australian Cross-Disability Alliance, which is funded by the Federal Government to promote, protect and advance the human rights and freedoms of people with disability in Australia by working collaboratively on areas of shared interest, purpose and strategic opportunity. We have a vision of a socially just, accessible and inclusive community, in which the human rights, citizenship, contribution, potential and diversity of all people with disability are respected and celebrated. Access to the built environment, including access to public transport conveyances, infrastructure and premises, is a key issue in achieving this vision. Forward: Access to public transport as a human rights issue Accessible public transport is a human rights issue, and many rights contained in the UN Convention on the Rights of Persons with Disabilities (CRPD) will not be realised until the important area of accessibility to transport is addressed. For example, a person with disability may face limited employment opportunities if they are unable to use the public transport system to travel to the workplace. On the fundamental issue of accessibility, the CRPD requires countries to identify and eliminate obstacles and barriers and ensure that people with disability can access their environment, transportation, public facilities and services, and information and communications technologies. The CRPD also acknowledges the importance of live assistance and intermediaries to facilitate accessibility. The National Disability Strategy (NDS) is the mechanism through which Australia delivers its commitments under the CRPD. NDS Outcome 1 Inclusive and Accessible Communities addresses access to the physical environment, transport, digital information, communication technologies, housing and principles of universal design. The NDS recognises the importance of: An accessible public, private and community transport system that is accessible for the whole community; Incorporating a universal design approach to services, programs, facilities; Removing access barriers, including through the adoption and monitoring of minimum accessibility standards for public transport and buildings; Communication and information systems that are accessible, reliable and responsive to people with disability, their families and carers. The NDS makes specific reference to the implementation of the Disability Standards for Accessible Public Transport (2002) as a key step to remove discrimination in providing public transport and to assist people with disability to fully participate in community life. Introduction People with Disability Australia (PWDA) is pleased to comment to the 鱨վ (AHRC) on the Application for Temporary Exemption by the Australasian Railway Association (ARA). The Exemption seeks temporary relief from various Clauses of the Disability Standards for Accessible Public Transport 2002 (DSAPT) and the Disability (Access to Premises-Buildings) Standards 2010 (Premises Standards). The commitment by ARA members to accessible rail networks rather than often-unachievable full compliance at a limited number of stations is acknowledged and welcome. That this approach is the disability sector's preference has of course been derived through broad consultation. This approach is also welcome and it is to be hoped that the priority of achieving an accessible network before eventually achieving full DSAPT and Premises Standards compliance continues. Wherever Equivalent Access or Unjustifiable Hardship solutions are employed in this process, they should be captured in the Rail Industry Safety and Standards Board's (RISSB) National Code of Practice - Accessible Rail V1.00 (CoP) to allow a nationally consistent approach. The current ARA Exemption Application largely mirrors earlier Exemption Applications, except that it omits reporting responsibilities and provision of direct assistance, among other omissions which are detailed in this submission. PWDA believes that a monitoring and reporting mechanism is essential for any exemptions granted. Without this mechanism as a condition most of the application cannot be supported. Several reporting models are available, but reporting regularly to the 鱨վ (AHRC) and the National Accessible Public Transport Advisory Committee (NAPTAC) would be well received by PWDA. The DSAPT permits the use of Direct Assistance to achieve Equivalent Access wherever the prescriptive requirements of the DSAPT cannot be met. The former Exemptions granted to ARA by AHRC featured reference to Direct Assistance as a means of compensating for lack of compliance during the Exemption period. Reference to Direct Assistance in the present application is limited, which diminishes the quality of service offered relative to previous Exemptions granted by AHRC. PWDA cannot support the Exemption Application unless all references to Direct Assistance are reinstated as per previously granted Exemptions. Many of the Exemptions sought are for features that by the ARA's admission have little prospect of being made compliant with the prescriptive (deemed-to-satisfy) requirements of either DSAPT or Premises Standards. Rather than seeking Exemption ad infinitum the ARA's members should seek solutions via Equivalent Access as per the provisions of the DSAPT (Clause 33.3) and Premises Standards (Section 3.2). Where an Equivalent access solution is not feasible Unjustifiable Hardship solutions become an option. Unjustifiable Hardship is, however, not an excuse to make little or no effort to improve non-compliant features, fixtures or facilities. Rather it involves improving the non-compliant asset to achieve maximum practicable accessibility and functionality given the constraints as per the requirements of DSAPT and the Premises Standards: "However, compliance is required to the maximum extent not involving unjustifiable hardship." Equivalent Access and Unjustifiable Hardship solutions should be developed and recorded systematically to allow rail industry-wide application and certainty for customers with disability. The first edition of the RISSBs CoP took the approach of spelling out Equivalent Access and Unjustifiable Hardship solutions for existing rail cars and infrastructure. At the time of publication in 2011 these were the best solutions available where full DSAPT compliance was not possible or practicable. The CoP is now dated. RISSB should be tasked with development of a second, contemporary edition of the Code that captures the Equivalent Access and Unjustifiable Hardship solutions derived by individual ARA members via consultation, research and development. This will allow a nationally consistent approach to accessible solutions, as per the intent of the original CoP. The RISSBs CoP Development Group must include AHRC and Disability Sector representation, with regular reporting on progress to the National Accessible Public Transport Advisory Committee (NAPTAC). Group 1 Application for Temporary Exemptions from the Transport Standards 2.1 Access paths unhindered passage The following should form the basis of permanent solutions based on future compliance, Equivalent Access or Unjustifiable Hardship rather than continually seeking five year Exemptions. Flange gaps The application is conditionally supported. It is acknowledged that no practicable solution to flange gaps on level crossings yet exists, and it may never exist. The crossings themselves are hazardous, despite the genuine efforts of the rail industry to make them as safe as possible. The use of pedestrian level crossings to access stations must be phased out as swiftly as possible as a matter of public safety, to be replaced by grade separated crossings. Therefore, in addition to reporting on progress on phase out to AHRC, each ARA member that has responsibility for stations that have pedestrian level crossings should within 12 months of the granting of any Exemption, submit to AHRC a Schedule of Works that details concrete milestones in the phase out and replacement of level crossings from the station access environment. Single entry / exit point and accessible primary travel path Single point entry / exit assumes a minimalist, worst-case scenario position. Entry and exit should be provided at the maximum number of locations practicable. It is acknowledged that not all entrances / exits can be practicably made accessible in the short to medium term, and some perhaps not even in the long term. This should not however confine access and egress to single points where multiple points could be practicably achieved. The Exemption Application should read along the lines of: "The maximum practicable number of station entrances / exits, and never less than one, shall be accessible." Similarly, primary access paths only to essential features should be regarded as the minimum, as crowds and circumstances can block single paths, denying access. The Exemption should be worded to require maximum practical provision of access paths to essential features, with a single path being the minimum permitted. In both instances, customers arriving at inaccessible entrances / exits should be directed by signs and other means to accessible entrances / exits. The access paths should also be clearly signed and otherwise indicated. 2.4 Access paths minimum unobstructed width The revised wording diminishes the ARA's commitment to maximizing the functionality of access paths where compliance cannot be practicably achieved. Therefore it cannot be fully supported. Further, a commitment from ARA members on the following should form the basis of permanent solutions based on future compliance, Equivalent Access or Unjustifiable Hardship rather than continually seeking five year Exemptions. Access path widths In the rationale for the exemption, much emphasis is placed on direct assistance to overcome access difficulties. While a valid approach at stations that are staffed 24/7 this strategy of direct assistance fails at the times that rail stations or tram stops are not staffed. Consequently, access paths on existing stations that are unstaffed or only periodically staffed must be trafficable by people with disability in the absence of any direct assistance. Bearing this in mind, the maximum number of access paths linking essential elements of a station must offer the maximum practicable width. Rail operators and providers must also commit to signage and other wayfinding methods that identify the access paths and alternate routes around obstructions. Tactile Ground Surface Indicators (TGSIs) intruding into access paths It is acknowledged that in some instances on existing stations and tram stops platform-edge TGSIs will intrude into access paths. These TGSIs are vital to the safety of customers who have vision impairments and their use cannot be compromised. However, reference to the relevant Australia Standard (AS1428.4.1-2009) will find that it states that TGSIs can disadvantage people who have mobility impairments. Intrusion into access paths must therefore be minimized to the greatest extent practicable. Rail operators and providers must commit to moving station furniture, structures etc. that compromise the width of the access path in the vicinity of TGSIs. 2.6 Access paths conveyances The Exemption sought removes the current responsibility of operators to inform their customers of on-board access path constraints and to directly assist their customers where necessary. It cannot be supported without ARA members committing to informing and assisting customers. The following should form the basis of permanent solutions based on future compliance, Equivalent Access or Unjustifiable Hardship rather than continually seeking five year Exemptions. Access path minimum width It is acknowledged that space within the envelope of a rail car is limited, particularly on narrow gauge systems. The expired Exemption placed some responsibility on ARA members to maximize access path width and to provide direct assistance where space was compromised. These conditions should also be included in the current Exemption application. Where practicable, stanchions, grabrails, seats and other features can be moved. An investigation of the feasibility of this and a report to AHRC with 12 months should still be required. Internal carriage stairs It is unlikely that an accessible solution to carriage stairs will be developed. Therefore all essential on-board services and facilities must be available at carriage entry level. A commitment to this should be stated in the Exemption Application. Single door access Customers may need to board at other than a single designated door if they are to alight at an access path on the destination station. For example, a station that has particularly severe access path constraints may not permit a customer to reach an exit from the door through which they boarded. In this instance the customer would need to board at a door that allowed them to alight at a point from which they could access the station exit. Multiple accessible doors are required to permit this. The Exemption application should propose a strategy to overcome this difficulty. 3.1 Circulation space for wheelchairs to turn in The wording of the current and proposed Exemption is minimalist. Rather than requesting that "a manoeuvring area in existing rail premises and existing rail infrastructure complying only with the lower end of the range of dimensions stated in AS1428.2 (1992) Clause 6.2 is permitted" the request should read "exceeds the lower end of the range of dimensions stated in AS1428.2 (1992) Clause 6.2 wherever practicable" or similar for the Exemption to be accepted. A commitment in the Exemption to move any re-locatable furniture and fixtures is also desired. Rather than continually seeking five year Exemptions ARA should formulate permanent solutions based on future compliance, Equivalent Access or Unjustifiable Hardship. 4.2 Passing areas - two-way access paths and aerobridges The Exemption application should retain the reporting requirement of the current Exemption for the Exemption to be accepted. By determining and reporting which locations depend upon the Exemption, rail operators and providers are in a position to assess which locations are amenable to future upgrade and which are not. It is likely that some access paths will not be practicably able to be brought to compliance. For these locations ARA's members should seek solutions that involve either Equivalent Access or Unjustifiable Hardship. 5.1 Resting points - when resting points must be provided As per comments on 4.2 Passing areas the reporting requirements should be retained for the Exemption to be accepted. These should form the basis of permanent solutions based on future compliance, Equivalent Access or Unjustifiable Hardship rather than continually seeking five year Exemptions. Solutions mentioned in C2 might be among those considered on a case-by-case basis in consultation with customers with disability, AHRC and the NAPTAC. 6.4 Slope of external boarding ramps The reporting arrangements, and the requirement to nominate site specific solutions, should be retained for the Exemption to be accepted. The reporting and research will inform the development of Schedules of Works for platform alterations that reduce boarding ramp gradients to 1:8 or gentler. It will also indicate where such work is impracticable and enable development of permanent solutions based Equivalent Access or Unjustifiable Hardship. These solutions can then be published, permitting customers to plan their travel arrangements accordingly. 8.2 Boarding - when boarding devices must be provided The minimalist Exemption proposed is not acceptable. It is essential that the conditions of the current Exemption be retained. Customers may need to board at other than a single designated door if they are to alight at an access path on the destination station. For example, a station that has particularly severe access path constraints may not permit a customer to reach an exit from the door through which they boarded. In this instance the customer would need to board at a door that allowed them to alight at a point from which they could access the station exit. Multiple accessible doors are required to permit this. Further, if the few allocated spaces associated with a single door are occupied, while those in other cars are vacant, the rail provider or operator fails to offer a truly accessible service. The DSAPT compliant proportion of allocated spaces to rail cars required on a commuter train is two per car. Only eight allocated spaces may be consolidated in a single car, meaning that at least two cars per eight car set will contain allocated spaces. In a four car set it is unlikely that eight allocated spaces will be associated with a single door. Where a unique feature such as an accessible on-board toilet is provided the probability of eight allocated spaces and the toilet being connected to each other and a single door by an access path is negligible. Reducing the access requirement to a single door makes the majority of allocated spaces and some unique features on a train redundant. The Exemption application should propose a strategy to overcome these difficulties. 8.7 Boarding - signals requesting use of boarding device The Exemption application is supported on the condition that rail operators and providers seek permanent solutions under Equivalent Access. Reports to AHRC and NAPTAC should be provided annually. 11.2 Handrails and Grabrails - handrails to be provided on access paths The Exemption application is supported on the condition that rail operators and providers seek permanent solutions under Equivalent Access and Unjustifiable Hardship, and that while rail operators or providers are exempted from the DSAPT Clause 11.2 obligation to place handrails on rail platforms in anticipation of public need, they consider their installation in response to publically expressed need. Requests are to be assessed on their merits and with regard to impact on other customers rather than simply deferred or refused. For example, handrails on rail platforms have the potential to provide support on platforms in instances where Unjustifiable Hardship prevents the installation of seats. ARA should assess potential solutions utilizing handrails on rail platforms as supports where seats are impracticable and report annually to AHRC and NAPTAC on developments in this area for the duration of the Exemption. 12.2 Doorways and doors - compliance with Australian Standard premises and infrastructure The Exemption application is supported on the condition that that all doors currently in service meet the Premises Standards maximum opening force of 20 N. Further, that the ARA's members pursue Equivalent Access that meet the performance requirements of DSAPT Clause 12.2, such as the solutions proposed in Sections C, C1 and C2 of the current application for Exemption. Solutions should be completed before the expiry of the Exemption, with annual reports on progress to AHRC and the APTNAC. 12.4 Clear opening of doorways The Exemption application is supported on the condition that ARA's members begin work on Equivalent Access and accessible and functional Unjustifiable Hardship solutions that meet the performance requirements of DSAPT Clause 12.4. Work on these solutions should be completed before the expiry of the Exemption, with annual reports on progress to the AHRC and APTNAC. 14.3 Stairs - compliance with Australian Standards conveyances The Exemption application is supported on the condition that ARA's members begin work on Equivalent Access and accessible and functional Unjustifiable Hardship solutions that meet the performance requirements of DSAPT Clause 14.3. Work on these solutions, such as that proposed for external stairs, should be completed before the expiry of the Exemption, with annual reports on progress to the AHRC and NAPTAC. 15.2 Toilets - location of accessible toilets The Exemption application is supported on the condition that ARA's members begin work on Equivalent Access and accessible and functional Unjustifiable Hardship solutions that meet the performance requirements of DSAPT Clause 15.2. Work on these solutions, such as the signage and website solutions quoted in the Exemption application, should be completed before the expiry of the Exemption, with annual reports on progress to the AHRC and NAPTAC. 15.3 Unisex accessible toilet ferries and accessible rail cars The Exemption application is supported on the condition that the conditions of the existing Exemption are maintained and that ARA's members begin work on Equivalent Access and accessible and functional Unjustifiable Hardship solutions that meet the performance requirements of DSAPT Clause 15.3. Work on these solutions, such as those quoted in Section C2 of the current application for Exemption, should be completed before the expiry of the Exemption, with annual reports on progress to the AHRC and NAPTAC. 15.4 Toilets - requirements for accessible toilets ferries and accessible rail cars No "Section B Temporary exemption sought:" was proposed for DSAPT Clause 15.4. Presumably ARA wishes to preserve and extend the current Exemption? If this is the case then the Exemption application is supported on the condition that the conditions of the existing Exemption are maintained and that ARA's members begin work on Equivalent Access and accessible and functional Unjustifiable Hardship solutions that meet the performance requirements of DSAPT Clause 15.4. Work on these solutions, such as those quoted in Sections C1 and C2 of the current application for Exemption, should be completed before the expiry of the Exemption, with annual reports on progress to the AHRC and NAPTAC. 17.5 Signs - electronic notices The Exemption application is supported on the condition that the reporting conditions of the existing Exemption are maintained and that ARA's members begin work on Equivalent Access and accessible and functional Unjustifiable Hardship solutions that meet the performance requirements of DSAPT Clause 17.5. Work on these solutions, such as the smartphone and alternate media solutions quoted in Sections C1 and C2 of the current application for Exemption, should be completed before the expiry of the Exemption, with annual reports on progress to include the NAPTAC. 18.1 Tactile ground surface indicators - location It is understood by PWDA that the location of TGSIs must necessarily vary station to station. The Exemption application is therefore supported on the condition that the reporting conditions of the existing Exemption are maintained and that ARA's members begin work on Equivalent Access and accessible and functional Unjustifiable Hardship solutions that meet the performance requirements of DSAPT Clause 17.5. Work on these solutions will involve station-by-station consultation with people with disability, particularly those who have vision and mobility disability and with access experts who advocate for customers with disability. Annual reports on progress should include the NAPTAC. 20.1 Lighting - illumination levels premises and infrastructure The Webb Report and its recommended illumination levels have been widely accepted by the disability sector in consultation and experience. Webb represents a solution in combination of Equivalent Access and Unjustifiable Hardship that have proven to be quite functional for customers with a disability and safely implementable by the ARA's members. Particularly welcome is the transition from yellow halide lighting to the 'white' lighting provided by CMH lighting. Exemption should not now be required unless failure to meet the original Exemption deadline for implementation, i.e. implementation of Webb Report illumination levels by December 31 2007, has not been achieved by some of ARA's members. It would be regrettable if this was the case almost eight years after the deadline, and as such no further Exemption could be justified. 21.1 Controls - compliance with Australian Standard premises and infrastructure The Exemption application is supported on the condition that that all doors currently in service meet the Premises Standards maximum opening force of 20 N. Further, that the ARA's members pursue Equivalent Access that meet the performance requirements of DSAPT Clause 21.1, such as the solutions proposed in Sections C, C1 and C2 of the current application for Exemption. Solutions should be completed before the expiry of the Exemption, with annual reports on progress to AHRC and the NAPTAC. 26.2 Hearing augmentation listening systems - public address systems conveyances The contemporary Passenger Information Displays (PIDs) have been widely accepted by the disability sector in consultation and experience. These units represent a solution in a combination of Equivalent Access and Unjustifiable Hardship and have proven to be quite functional for customers with a disability and practicably implementable by the ARA's members. Exemption should not now be required. Rather, each ARA member should provide a Schedule of Works to the AHRC and NAPTAC that details concrete milestones in the rollout and installation of PIDS. Progress reports on progress should be submitted annually to AHRC and the NAPTAC. 27.3 Information - size and format of printing The Exemption application is supported on the condition that the reporting conditions of the existing Exemption are maintained and that ARA's members begin work on Equivalent Access and accessible and functional Unjustifiable Hardship solutions that meet the performance requirements of DSAPT Clause 27.3. Work on these solutions, such as those quoted in Sections C1 and C2 of the current application for Exemption, should be completed before the expiry of the Exemption, with annual reports on progress to include the NAPTAC. 28.1 Booked services - notice of requirement for accessible travel No Exemption request detailed. 28.2 Booked services - period of notice of requirement for accessible travel It is accepted that in some circumstances customers with high support needs may need to give advanced notice of travel requirements to ARA members that provide booked services. It would however be onerous to place this requirement on the majority of customers with disability whose disability has no impact on the ARA members' provision of services. Therefore, the exemption application can only be supported if the ARA members begin a process that clearly informs potential customers with disability of who among them must give advanced notice of requirements for accessible travel and how far in advance they must contact the ARA member. Further, explanation of why the requirement for advance notice for booking is necessary should be provided in any published material relevant to bookings. For example, if seats need to be removed to accommodate wheelchairs then this will impact the seats available for other customers and would justify an advance notice of travel requirement on booked services. However, if the customers wheelchair was transported in a baggage car with the customer using standard seating then no advanced notice should be necessary as no seats would be removed. ARA's members should begin work on Equivalent Access and accessible and functional Unjustifiable Hardship solutions that meet the performance requirements of DSAPT Clause 28.2. Work on these solutions, such as those quoted in Section C1 of the current application for Exemption, should be completed before the expiry of the Exemption, with annual reports on progress to AHRC and NAPTAC. Group 2 Application for Temporary Exemptions from the Transport Standards in Relation to Issues that were Previously Deferred 11.2 Handrails and grabrails - handrails to be provided on access paths The Exemption application is not supported. ARA's members should seek permanent solutions under Equivalent Access and Unjustifiable Hardship. It is acknowledged that ARA's members cannot anticipate every instance where handrails would be of assistance, but they can determine general principles of location through consultation directly with people with disability and with access experts who advocate for them. For example, handrails on access paths to rail platforms have the potential to provide support in instances where Unjustifiable Hardship prevents the installation of seats. Further, ARA members can be informed of specific potential locations for handrails through public request. Requests can be assessed on their merits and with regard to impact on other customers rather than simply deferred or refused. The reservation expressed in the ARA Exemption application that poorly installed handrails could be hazardous to customers has no foundation. The DSAPT or the Disability Discrimination Act could in no way be interpreted as obliging ARA's members to put members of the public at risk in the cause of eliminating discrimination. 21.2 Passenger operated devices for opening and closing doors The Exemption application is supported on the condition that ARA's members seek permanent solutions under Equivalent Access and Unjustifiable Hardship. AHRC concerns that emergency evacuation for customers with a disability has not been fully considered are justified. The statement in Section C1 that "Most evacuations are orderly and carried out at the direction of guards, does not guarantee that all evacuations are orderly or supervised. The various emergency evacuation scenarios and the appropriate technical and policy responses require further research and disability sector consultation. AHRC and NAPTAC should be represented in this procedure. 21.3 Location of passenger operated controls for opening and locking doors The Exemption application is supported on the condition that ARA's members seek permanent solutions under Equivalent Access and unjustifiable Hardship. AHRC concern that controls will be accessible to customers with a disability has not been fully considered are justified. For example, not all of the ARA members' rail cars have either internal or external controls for carriage entrance doors as doors open automatically at each stop. The necessity for installing controls that externally may be too high or internally too close to corners is therefore unclear, since by the actual practice of some ARA members the requirement for customers to operate door controls would seem to be discretionary. The various scenarios possible in the location of customer operated door controls, or even their necessity, and the appropriate technical and policy responses, require further research and disability sector consultation. AHRC and NAPTAC should be represented in this procedure. Group 3 Application for temporary exemptions from the Premises Standards H2.2 (1) Access paths unhindered passage Comments relevant to H2.2(1) have been made previously regarding the Exemption clauses associated with DSAPT Clause 2.1 and are located in Group 1 of this submission and will not be repeated here. H2.2 (3) Access ways Comments relevant to H2.2(3) have been made previously regarding the Exemption clauses associated with DSAPT Clause 2.4 and are located in Group 1 of this submission and will not be repeated here. H2.2 (6) Access ways Comments relevant to H2.2(6) have been made previously regarding the Exemption clauses associated with DSAPT Clause 3.1 and are located in Group 1 of this submission and will not be repeated here. H2.2 (7) Access ways Comments relevant to H2.2(7) have been made previously regarding the Exemption clauses associated with DSAPT Clause 4.2 and are located in Group 1 of this submission and will not be repeated here. H2.4 (2) Handrails and grabrails - handrails to be provided on access paths Comments relevant to H2.4(2) have been made previously regarding the Exemption clauses associated with DSAPT Clause 11.2 and are located in Group 1 of this submission and will not be repeated here. H2.5 Doorways and doors - compliance with Australian Standard premises and infrastructure Comments relevant to H2.5 have been made previously regarding the Exemption clauses associated with DSAPT Clause 12.2 and are located in Group 1 of this submission and will not be repeated here. H2.9 Toilets - location of accessible toilets Comments relevant to H2.9 have been made previously regarding the Exemption clauses associated with DSAPT Clause 15.2 and are located in Group 1 of this submission and will not be repeated here. H2.11 Tactile ground surface indicators - location Comments relevant to H2.15 have been made previously regarding the Exemption clauses associated with DSAPT Clause 18.1 and are located in Group 1 of this submission and will not be repeated here. H2.12 Lighting - Illumination levels premises and infrastructure Comments relevant to H2.15 have been made previously regarding the Exemption clauses associated with DSAPT Clause 20.1 and are located in Group 1 of this submission and will not be repeated here. H2.15 Controls - compliance with Australian Standard premises and infrastructure Comments relevant to H2.15 have been made previously regarding the Exemption clauses associated with DSAPT Clause 21.1 and are located in Group 1 of this submission and will not be repeated here. Conclusion and Summary of Recommendations In summary, PWDA cannot support the ARA Application for Exemption from sections of the DSAPT and Premises Standards in its present form. While the application largely resembles the Exemption currently in force there is significant diminution of some obligations. Further there are areas that have not been addressed. These, as highlighted in this submission, must be amended for PWDA to support the Exemption Application. Regular reporting: The commitment to reporting on customer impact and on solution development must be maintained for the application to be supported. ARA must keep all stakeholders informed of the impact on customers of the Exemption, and work with customers, customers' advocates and other stakeholders to seek Equivalent Access and Unjustifiable Hardship solutions. Further, such information and communication must be in accessible formats. Direct assistance: Direct Assistance is a valid means of compensating for technical non-compliance. Unless all references to Direct Assistance are reinstatement as per the Exemption currently in force the application for Exemption cannot be supported. Multiple options for access paths and boarding: The Exemption Application cannot be supported without a commitment to providing multiple options for access to stations, access paths through stations and to boarding points wherever these can be practicably achieved. Unjustifiable Hardship solutions covering these are acceptable provided that "compliance is required to the maximum extent not involving Unjustifiable Hardship". Solutions rather than exemptions: ARA has sought extensions to its original Exemption without committing to solutions to the issues from which Exemption was sought. This is not the intention of Temporary Exemptions as expressed in the DSAPT and Premises Standards. Exemptions are granted to allow a degree of freedom from responsibilities while solutions are implemented or derived. ARA's members are to be commended for their work with the DDA or access reference groups but this is on a state-by-state rather than national basis. Therefore, none of the solutions derived are captured in the current Exemption Application. PWDA cannot accept extensions ad infinitum of Exemptions from DSAPT and the Premises Standards. Stakeholder agreed solutions are required and an ARA commitment to this must be provided or the current Exemption cannot be supported. National Code of Practice - Accessible Rail V1.00: The CoP developed by the RISSB is now dated. ARA must commit to resourcing RISSB to update the CoP as soon as possible for the Exemption Application to be supported. All stakeholders, including people with disability and their advocates, must be represented on the CoP's Development Group. The Code is the best medium for capturing and publishing nationally consistent Equivalent Access and Unjustifiable Hardship solutions that are both accessible and functional.  Australia ratified the UN Convention on the Rights of Persons with Disabilities in 2008. The full convention can be found here  HYPERLINK "http://www.un.org/disabilities/convention/conventionfull.shtml" http://www.un.org/disabilities/convention/conventionfull.shtml  Australian National Disability Strategy p. 43  HYPERLINK "http://www.dss.gov.au/our-responsibilities/disability-and-carers/publications-articles/policy-research/national-disability-strategy-2010-2020" http://www.dss.gov.au/our-responsibilities/disability-and-carers/publications-articles/policy-research/national-disability-strategy-2010-2020  DSAPT, Clause 33.7(2) and Premises Standard, Section 4.1(2).      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