ࡱ> ` 0&bjbj x0 P ooo8o$p,zp(pppprrryyyyyyy${hP~y rr"rrry ppyksksksr p pyksryksksrxT [ypp @ٸor^y8yy0zMy~s~[y~ [y$rrksrrrrryysXrrrzrrrr,,,BxoD,,,xo  L   Physical Disability Council of Australia Ltd (PDCA) P O Box 77 Northgate Qld 4013 07 3267 1057 07 3267 1057 HYPERLINK "mailto:pdca@pdca.org.au"pdca@pdca.org.au HYPERLINK "http://www.pdca.org.au/"www.pdca.org.au 9th September 2005 David Mason, Director Disability Rights Policy Human Rights and Equal Opportunity Commission, Sydney, Dear David, This submission is written in response to the application under section 55 of the Disability Discrimination Act(1992) from the Australasian Railway Association (ARA) on behalf of its members for a temporary exemption, for a period of 5 years, in relation to a number of provisions of the Disability Standards for Accessible Public Transport (DSAPT). The extent of the exemption is so vast that it will be necessary to consider the clauses of the application in an abbreviated manner in the introduction of this submission and a more detailed consideration of every clause of the application will be added as an attachment. To adequately deal with the application it will be better to have a face-to-face meeting. The submission is from the Physical Disability Council of Australia (PDCA) and we endorse the document and statements that have been prepared for the Australian Federation of Disability Organisations (AFDO) (attached) through an extensive consultation process and the document attached by John MacPherson of Brisbane. PDCA does not believe that the ARA understands the intent of the Standards and the process for decision making by the initial taskforce that developed the performance based Standards. The intent of the Accessible Public Transport Standards is to eliminate as far as possible discrimination against people with disabilities and to help make Public Transport accessible to all passengers including older Australians with mobility disabilities, parents with strollers and those with temporary disabilities. It is therefore irrelevant to be quoting percentages and numbers of people with disabilities when ARA are arguing for a reduction in the access provisions within the DSAPT. The inclusion of a compliant mobility aid in the Accessible Public Transport Standards is discriminatory for people with disabilities who need to meet their own individual and technical requirements and is more correctly left in the guidelines. The Accessible Public Transport Standards are performance based Standards that use Australian Standards to provide information to all stakeholders as well as a set of Guidelines to allow for the possibility of a variety of public transport solutions favourable to different locations. The Accessible Public Transport Standards were developed through a process of negotiation and consultation with all stakeholders and the final result was an agreed compromise that covered all aspects of public transport provision. It is not apparent that the ARA wants to adopt the Accessible Public Transport Standards as part of the rail industry code. It is more apparent that ARA wants to adopt a version of the Standards that is most suitable to the rail industry and not necessarily other modes of transport. It may not necessarily eliminate discrimination for people with disabilities. As well, the adoption of this new version of the Standards will only limit the opportunity for operators/providers in each State of Australia to arrive at favourable solutions. Services within the rail industry in each State vary widely. In this revised version of the Accessible Public Transport Standards by the ARA there are no new technical solutions offered that have been satisfactorily tested but rather a variation of the present Australian Standards(AS) to suit some rail operations. When the present AS does not suit the rail industry other Standards have been introduced. A more satisfactory solution to the technical problems sought by the rail industry would have been to have the AS revised rather than eliminating clauses from the AS that are referenced in these Accessible Public Transport Standards. The technical specifications needed for the rail industry could have been written into contracts between the Operators/Engineers/Manufacturers so that the new rolling stock etc was covered by a legal process. The safety of people with disabilities has been compromised by the rewriting of some clauses in this application for exemption. The lesser measurement for the width of a boarding ramp is dangerous for people in mobility aids, the removal of some handrails and grab rails in certain locations will disadvantage people with a vision impairment and the change in provision of public address systems could endanger people with a hearing device. It is doubtful if people with disabilities should be responsible for Occupational Health and Safety Issues (O, H & S) of Railway Employees. Operational constraints unique to rail transport have been tackled already in some localities. The nominated boarding place on a platform is not necessary in Western Australia where it is possible to board and alight from the conveyance at most points on the platform. The placement of TGSIs on a curved surface in infrastructure is a problem also faced by the Australian Bus and Coach Association with bus stations. At present it is not possible to pre-empt the process of the five- year review which may well be able to tackle some of the issues that are raised in this application for exemption. AFDO considers that there are other methods of resolving the issues faced by the ARA in relation to meeting the compliance schedule than this complex application for exemption. As already mentioned there is the possibility to tackle the AS so that minor clauses can be rectified and so that these changes to the minor clauses can be properly tested. Another scheme used by Bus and Coach operators is to mock up conveyances and have a wide variety of people with disabilities provide feedback about these situations. It was always envisaged that consultation with local groups of people with disabilities about the solutions to Accessible Public Transport would achieve the best result for the local conditions. By quoting overseas experience, it does not always provide the appropriate information for each Australian States conditions. Another method of resolving the issues faced by ARA could be that the rail industry publish a document that provides examples of best practice and give practical suggestions as to how technical solutions can be found. The cost of providing public transport is an enormous issue across all modes of transport and the cost of rolling stock will probably be greater than most. However there are provisions within the Accessible Public Transport Standards for the issues of costs to be sought. Equivalent Access, unjustifiable hardship and operator/direct assistance are some of the possibilities. The document attached by the ARA as the application for exemption from the clauses of the Accessible Public Transport that cannot be adopted in their current form does not highlight the clauses that do not require change but rather it highlights the exemptions from most of the clauses in the current Standards. (90 changes). The rewording of the clauses does not necessarily have the same intention as the original Standards and in fact may lessen the effect of the original Standard. The additional or altered information does not necessarily improve the clarity of the wording and may only improve the Standards for the rail industry. It is still only one sectors interpretation of clarity of the wording. The original Accessible Public Transport Standards were drafted 11 times to improve the clarity of expression. It would be necessary to consult with all stakeholders to arrive at the wording changes relevant to all sectors. The inclusion of extracts from the Guidelines within the Standards defeats the purpose of both the Standards and that of the Guidelines. The Standards are the provision of certainty for the stakeholders to be assured that Accessible Public Transport will occur. The Guidelines are the means of assistance needed to provide practical solutions in the many and varied settings for all modes of public transport. PDCA do not believe that the request by the ARA for exemption from relevant Standards listed in the document attached will effectively meet the needs of all stakeholders. The abbreviated form of the position that PDCA takes in relation to the proposed exemption is as follow: MEANINGS: (1.9X, 1.11AX, 1.11BX, 1.11CX, 1.15X, 1.18X, 1.18X, 1.19AX, 1.19X, 1.2, 1.23X ) 1.9X Access Paths: To add all these extra provisions to the access path terminology actually limits the opportunity to provide an accessible route for all passengers within all public transport premises, infrastructure or conveyances. 1.11AX Assistance Dog: New Clause The incorporation of clauses from the Guidelines into the Standards changes the original basis for the development of the Accessible Transport Standards from performance Standards where the best solution to each problem could be developed in the local conditions. HREOC recommendations should not be seen as Standards but only guidelines. 1.11BX Boarding Point. New Clause. This definition is superfluous and discriminatory because it is segregating people with a disability onto one place on the platform. 1.11CX Booked Services on Trains. 1.11DX Unbooked Services on Trains. New Clause. These services are the same for all passengers and do not need to be redefined for this document. 1.15X Disability Aid. New Clause. It is not necessary to define a disability aid as these standards are about Accessible Transport. Each disability aid is specific to an individual so can not be specified in an accessible Transport Standard. Accessible Public Transport also means access for strollers etc. and to begin defining every item that travels on a train would be unreasonable. There are already Australian Standards for disability Aids.eg. Heart pacemaker or hearing aid. 1.18X Infrastructure. This is an example of change in terminology in this exemption. It would be impossible for infrastructure to be limited to immediate boarding points because this does not allow for an access path. Extra provisions for rail could go in Guidelines. 1.18X Level crossings. New Clause. The inclusion of this new clause in the Accessible Transport Standards is rather premature as the Australian Standards for this definition has not been sorted out yet. 1.19AX Mobility Aid. New Clause. It is contradictory to say that 1.15X and 1.19AX are the same item. It should be one definition for each Aid(if at all necessary). The reason that the Guidelines has the dimensions of a mobility aid is that it is impossible to standardize a mobility aid. Once again there are already Standards for Mobility Aids. 1.19X Nominated Boarding Point. New Clause. A nominated Boarding Point creates segregation of people with disabilities and the emphasis of the Standards is to alleviate discrimination for people with disabilities. A nominated boarding point limits the provision of Accessible Public Transport eg WA has platforms where you can access an part of the suburban train. 1.2 Premises The extra provisions in this clause could be included in the guidelines or it would be necessary to provide explanation for all types of conveyances. The change from operator to provider may not assist all modes of transport. 1.23X Sleeping Berth. New Clause. The addition of this clause may not be suitable for other modes of transport. Eg ferries, coaches, airlines. 1.X Mobility Aids. New Clause. This new clause is one of those that most demonstrates the ARA does not understand the intent of the Standards. These Standards are about designing the built environment (conveyances, premises & infrastructure) so that it does not create barriers to passengers who need to use mobility aids. This clause does not take into account any studies or information about mobility aids. The inclusion of Guidelines into the Standards limits the opportunity for technical and innovative development. 1X.1 Design Criteria. Maximum size: There are Australian Standards already in place for the construction of mobility aids. This is only a recommendation for passengers wanting to travel on public transport and should remain in the Guidelines. Manoeuvrability: Passengers in Mobility aids that have difficulties manoeuvring in confined spaces would need to consult the guidelines to see if it is possible to access public transport. Mass: Passengers in mobility aids would need to be aware of weight constraints when tackling ramps on public transport for their safety. 1.X2 Performance Criteria. Braking: An effective braking system is too subjective to be placed in a Standards document. Anchoring: Rail operators would need to provide tethering for mobility aids to enforce the criteria for anchorage points. Stability: Passengers in mobility aids will have the same difficulty as other passengers in coping with the motion of public transport. Propulsion: The wording of this clause is not in conformity with other clauses in the Standards. It could be a recommendation in the Guidelines. Batteries: It would need to have the public transport regulations placed in the Standards rather than this reference. Wheels and Gaps: If there is an operator or other assistance this part of the clause is irrelevant. Ramps: This is not a passenger responsibility. Operation and Storage: The wording of this aspect of this clause is difficult to understand. Working Environment: The wording of this part of the clause is offensive as passengers and their mobility aids do not need to be operated. 1.X3 Orientation. This part of the clause is too broad (conveyances, premises and infrastructure) and could limit the access for people in mobility aids. It may be possible on conveyances because of the configuration of the conveyances. ACCESS PATHS: 2.1 Unhindered passage. The changes to this part of the clause may not suit all modes of public transport. A provider nominated unhindered passage may not make access appropriate for all passengers with disabilities. The provision of only one access path may not allow the best access for every situation. The inclusion of other Standards could lead to more complicated problems for operators in the provision of conveyances, premises and infrastructure. 2.2 Continuous accessibility. The detailing of the continuous accessibility makes this part of the clause more complicated and does not allow for the provision of a variety of solutions to access paths. 2.4 Minimum unobstructed width. The reduction of referencing in the Standards is only beneficial if it leads to more creative solutions to access problems but the AS referenced are particularly important because they contain specific information relevant to access for people with a disability. 2.4X. Minimum unobstructed width for railway platforms. New platforms. Existing stations and platforms. Site constraints preventing fully compliant paths of travel. Exiting platforms-exceptionally severe site restraints. Using platform edge warning TGSIs as part of the access path. Information to passengers. Moving footways. The inclusion once again of HREOC referencing is inappropriate because its information is only meant as guidelines. The underpinning of the Standards was that the Standards mostly applies to new conveyances etc or when upgrading occurs. The inclusion of another clause for railway platforms may be at odds with other modes of transport. 2.5 Poles and obstacles etc. The removal of information would need to be agreed on by all modes of transport. If testing was to be required for all aspects of the Standards much of the present and new clause would be found to be lacking. 2.6 Level Crossings. New Clause. The inclusion of this clause is pre-empting the adoption of the Level Crossing dimensions as an Australian Standard. 2.6 Access Paths-conveyances. The rewording of this clause only allows for the provisions of one access path for ALL people with a disability. People with sensory disabilities may prefer the use of stairs. The removal of parts of the clause and the insertion of guidelines does not benefit people with disabilities because it limits the options for achieving access. 2.8 Extent of Path. The details of this clause are too prescriptive and do not allow for alternative solutions to access paths. It may not suit other conveyances because this clause is across all conveyances. It is too prescriptive for only a few disabilities types. MANOEUVERING AREAS: 3.1 Circulation space for mobility aids to turn in. The removal of AS throughout the document is not consistent. The mobility aid clause should not be in the Standards but in the Guidelines. PASSING AREAS: 4.1 Minimum Width. The removal of this clause would remove on section of an AS that is relevant to people in mobility aids. It is a different part of AS than 4.2 4.2 Two-way access paths and aerobridges. This clause is a prime example of lessening the provision of access for passengers with disabilities and for the aged. A railway platform that is less than 1800 mm wide does not seem possible as this clause is only about access paths less than 1800mm. 4.3 Passing areas conveyances. The wording in this clause is confusing. It appears that only wheelchairs are allowed on ferries but mobility aids are on other conveyances. The change of wording is not positive. RESTING POINTS: 5.1 When resting points must be provided. The provision is more important now than ever because of an aging population. The removal of AS may cause problems with design requirements. RAMPS: 6.1 Ramps on Access Paths. The addition of AS is inconsistent with the general policy in this application of removal of AS because of referencing difficulties. The addition of these extra Standards could go in Guidelines as safety measures. 6.2 Boarding Ramps. The removal of the words must comply from this clause lessens the impact of the Standards. The removal of one AS and the addition of another AS is just as confusing as the interpretation of the original Clause of the Standards. 6.3 Allowable minimum width. The ramp surely should be consistent with the width of the doorway. These Accessible Public Transport Standards are about conveyances, premises and infrastructure and not about mobility aids. There are other Standards that the dimensions of a mobility aid need to be defined. BOARDING: 8.1 Boarding Points and kerbs. The provision of one nominated boarding point may lead to more segregation and discrimination. It would be better if the wording was left as it is to allow for technological development. In WA it has been possible to board a train from many points on the platform. 8.2 When boarding devices need to be provided. The removal of AS in this clause could cause safety issues. Will this change in this clause be applicable across all conveyances. 8.5 Width and surface of boarding devices. The removal of this clause from the Standards does not allow for every conveyances provisions. 8.6 Maximum load to be supported by boarding devices. The removal of signage may lead to confusion for passengers with a disability. 8.7 Signals requesting use of boarding device. This clause must remain because it is relevant to all conveyances- not just rail. 8.8 Notification by passenger of need for a boarding device. In this exemption clause there are only provisions for rail that are being stated and provisions for other conveyances are necessary before the clause needs to be changed. This clause wording complicates the process of notification for passengers with a disability. How would operator assistance be notified? If various positions are chosen how would the passenger with a disability know what the notification system is from one conveyance to another. ALLOCATED SPACE: 9.1 Minimum size for allocated space. The knee height of a mobility aid has nothing to do with the dimensions of an allocated space. AS should remain. Any may clause should be in the Guidelines. The manoeuvring of mobility aids does not need to be in this clause. 9.6 Number of allocated spaces to be provided rail, tram, light rail cars. Number for unbooked services. 1 (a)The number of spaces has always been 2 and any lack of seating lose has been taken up with flip-down seating. (b) The introduction of 110 seating and requirements will need to be negotiated. Number for booked services. 2. The strict nomination of number of spaces per car does not allow for future development with the aging population. 3.The congregation of spaces in one car will lead to more segregation of people with a disability. 4.It depends on the previous definition of a sleeping berth. 9.7 Consolidation of allocated spaces. People with disabilities vary in requirements for their mobility aids because of their different needs. It is not possible that one size fits all. 9.10 International symbol for accessibility to be displayed. The symbol of accessibility will indicate to users of flip-down seats that this space is used by people with a disability. Adding extra Australian Standards leads to confusion and what best suits operators rather than passengers. SURFACES 10.1.Compliance with Australian Standards. To remove infrastructure from this clause and make a new clause may be necessary for the interpretation of the operators of conveyances. 10.1X Compliance with Australian Standards(infrastructure) New Clause. The introduction of new clauses would need to go through a more detailed consultative process. HAND and GRAB RAILS 11.1 Compliance with Australian Standards - premises and infrastructure. The removal of luminance contrast details does not give enough guidelines for operators/providers and will lead to lack of uniformity. 11.2 Handrails to be provided on access paths. The removal of handrails in railway premises will severely inconvenience people with a vision impairment. Are these Standards written for people with a disability or the providers? 11.3 Handrails on steps. The removal of Australian Standards needs to be discussed with people with a vision impairment. 11.4 Hand rails above access paths. The placing of guidelines in the Standards actually limits the design possibilities. 11.5 Compliance with Australian Standards. The change in title of this clause and the removal of AS referencing is not consistent with document layout. Better design of rails would stop injury to all passengers. 11.6 Grab rail to be provided where fares are paid. The payment of fares has to occur in whatever form is necessary. The provision of counter tops should not be in this section and a counter top does not replace a rail. 11.7 Grab rails to be provided in allocated spaces. This exemption is not necessary. DOORS and DOORWAYS. 12.1 Doors on Access paths. 12.1 (3) is not necessary as this is the same situation on aircraft. Original wording was better. 12.2 Compliance with Australian Standards. This clause is only a rewording and the parenthesis should be retained to emphasis toilet door compliance. Weight activated doors and sensors. Consultation with people with a vision needs to be undertaken before this rewording is changed. Clear opening of doorways Toilet door ways need to be researched across all conveyances. Aircraft seem to manage. The removal of Australian Standards removes a benchmark for operators/manufacturers to begin application of Standards. LIFTS 13.1Compliance with Australian Standards- premises and infrastructure. The extra information about lifts would probably be better put in the guidelines. STAIRS 14.1 Stairs not to be sole means of access. The exclusion of one group in the Standards does not lead to the removal of discrimination. The phrase people with mobility impairment is best put in the guidelines. 14.3 Stairs on conveyances. This clause is only swapping one clause for another. More research needs to be done. TOILETS 15.1 Unisex accessible toilet premises and infrastructure. This information about gender specific toilets should be in guidelines. Often people with disabilities have different gender carers. Force of doors needs to be investigated. 15.2 Location of accessible toilets. Isnt the duplication of access paths nullifying the intention of other parts of the access path clause? Guidelines placed in the Standards will not allow for creative solutions to problems. 15.3 Accessible toilets ferries and trains. Compliant mobility aids is unnecessary word change. Accessible rail cars is needed to determine where the toilets are. 15.4 Requirements for accessible toilets ferries and accessible rail cars. Aircraft can provide a toilet so rail should be able to as well. Countrylink Sydney to Canberra has a accessible toilet that ARA could use as a model. It would be better to change AS for conveyances than to exempt trains. SYMBOLS 16.2 Compliance with AS2889.1 (1986) These extra Standards may not suit all modes of Transport. 16.3 Accessibilty symbols to include directional arrows. Consultation needs to be held with all stakeholders about these proposed changes. 16.5 Accessibilty symbols to be visible on all accessible doors. Exemption of symbols from internal doors will cause difficulties for people who are temporarily disabled and the aged. More consultation is needed. SIGNS 17.4 Destination signs need to be visible from boarding point. In some cases the boarding point is the whole length of the platform. A nominated boarding point is discriminatory. 17.5 Electronic Notices. The words 10 secs is removed from part 1 but not part 2 which does not lead to consistency. All stakeholders need input. 17.6 Raised lettering or symbols or use of Braille. It would be necessary to have wider consultation on this exemption as it relates to all conveyances, premises and infrastructure. TACTILE GROUND SURFACE INDICATORS 18.1 Location The substitution of one Standard by another brings more complication to these Accessible Public Transport Standards .Other modes of transport have managed to install TGSIs without an exemption. 18.2 Style and Dimension. Bus and coach stations have the same difficulties. Why should rail be exempt? The removal of AS will endanger people with disabilities safety. 18.4 Instalment at railway stations. The reduction of AS here would lead to safety issues. ALARMS 19.1 Emergency warning systems. All passengers would need warning in an emergency but people with a vision would need extra help. LIGHTING 20.1 Illumination levels premises and infrastructure. The chopping and changing of illumination levels Standards seems to be only pertinent to rail. Other modes have managed. CONTROLS 21.1 Compliance with Australian Standards premises and infrastructure. Is this the case with all doors in all situations or is it only relevant to transport situations? Surely the Australian Standards need to be changed rather than the Accessible Transport Standards. 21.3 Location of passenger-operated controls for opening and locking doors. This exemption relates to all conveyances other modes would need to be consulted. FURNITURE and FITMENTS 22.1 Tables, benches, counters etc. As the original clause was only related to premises and infrastructure it was appropriate. However the addition of conveyances needs to be treated separately. 22.5 Accessible sleeping berths trains. As stated previously the change in definition should not affect the number of sleeping berths available. The figures do not allow for an aging population. STREET FURNITURE 23.1 Seats. The specifications for street furniture are better to remain the same as in other domains than transport because most people expect a certain design. GATEWAYS 24.1Gateways and checkouts. The removal of Australian Standards would cause unreliability and uncertainty for passengers because an expectation from other domains. PAYMENT OF FARES 25.3 Vending machines There should be other alternatives if Braille lettering cannot be used rather than just removing the clause. The removal of AS does not lead to better design just accommodation of less features. 25.4 Circulation space in front of vending machines. The reduction of referencing of AS is not a useful policy when they are replaced with other Standards. It causes more difficulties and could produce a worse result. A uniform approach is better. HEARING AUGMENTATION LISTENING SYSTEMS 26.2 Public address systems conveyances. This clause has always been prefaced by if a public address system is installed . The removal of any information at present does not lead to later development. INFORMATION 27.1Access to information about transport services. Guidelines are not useful in the Standards because they limit future design and may not be applicable across all modes of transport. 27.2 Equivalent Access The placement of Guidelines in the Standards weakens the Standards and does not apply the full force of the Standards. 27.3 Size and format of printing The guidelines would be the best place for all the details of this clause. 27.4 Access to information about location The provision of equivalent access is inherent in the Standards and does not need to be restated here. Rewording is not necessary. BOOKED SERVICES 28.1 Notice of requirement for booked services. This change in clause is discriminatory. Information should stay in the guidelines. 28.2 Period of notice of requirement for booked services. With modern technology this information can be given at the same time as other passengers. 28.3 Location of carers, assistants and assistance animals. Rewording should be in line with expectation of people with disabilities. FOOD and DRINK SERVICES 29.1 Equal Access to food and drink services. Change of wording would need to be agreed by all stakeholders. BELONGINGS 30.1 Disability aids to be in addition to baggage allowance. These Standards are to remove discrimination for people with disabilities and to give them certainty of access to public transport. The Standards and guidelines are to assist operators to give that certainty and to provide suitable, dignified and safe access. There is no such animal as a compliant mobility aid. PRIORITY 31.1 Priority seating Any statements with may in them are best placed in the guidelines. PDCA would like to take this opportunity to thank HREOC for the opportunity to provide comments on the request for Exemption by the ARA. 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