ࡱ> |~{g ObjbjVV r<r<FA~..84<%PPF> _%a%a%a%a%a%a%$'@*%y!^^@y!y!%.:h,(%$$$y!0_%$y!_%$$$ M'M"$$K%%0%$B+#B+$B+$\N$ *O%%$d%y!y!y!y!B+ : Our ref: 2011.05-Redline Federal Exemption Application Please quote on all correspondence 29 July 2011 David Mason Director Disability Rights Policy 鱨վ By e-mail: DavidMason@humanrights.gov.au Dear Mr Mason Submission in response to the Application by Tasmanias Own Redline for an exemption Thank you for the opportunity to provide the following submissions in respect of the application made by Tasmanias Own Redline for an exemption from the Disability Discrimination Act 1992 (Cth) (the DDA) and/or the Disability Standards for Accessible Public Transport 2002 (Cth) (the Public Transport Standards). Understanding of the application By way of clarification, I understand that the exemption is sought specifically in respect of the obligation under the Public Transport Standards set out in Standard 33.1: 33.1 Date for compliance with these Standards new conveyances, premises and infrastructure Operators and providers must comply with the specified sections of these Standards for all new premises, infrastructure and conveyances brought into use for public transport service on and from the date these Standards come into effect under section 31 of the Disability Discrimination Act 1992. The reason for this application appears to arise from the statement in the application letter that Redline has purchased in 2010 a number of new vehicles which are not fully DDA compliant and [Redline seeks] exemption to use these new vehicle on General Access services whilst still maintaining the 25% compliance over all services we operate. The new vehicles, if to be used for public transport purposes in 2010, should properly have been vehicles that comply with all of the relevant provisions of the Public Transport Standards. As such, the application appears to be an application for exemption under Part 33A of the Public Transport Standards. The basis of the application appears to be that it would be an unjustifiable hardship to require the company to comply with the Public Transport Standards: The request is based on the capital hardship that would be imposed on our Company requiring us to fit wheelchair lifts etc. to those vehicles purchased in 2010 that are used as support vehicles only for general access city to city services as low floor buses are not suitable for city-city services. It is not clear from the application whether the company is seeking exemption from specific obligations under the DDA and/or the Public Transport Standards, or from all of its obligations. This should be clarified as a matter of priority before determining the application. Redlines current situation and services On 22 June 2011, I met with Mr Sydes, State Manager, and the Michael Larissey, Managing Director, of Tasmanias own Redline and had the opportunity to view several of the different vehicles in the companys fleet. Of these vehicles, I was shown, among others, a vehicle that had a wheelchair lift enabling access for people with mobility impairments to the vehicle. I was also provided with some information on the range of general access services operated by the company and an indication of the provision of access on those services. I was informed that the company has vehicles operating on general access services, charter services and student-only services. In terms of general access services, I understand that the company operates services across four public transport corridors across the State: Burnie-Launceston-Hobart, Mole Creek-Deloraine-Launceston, Dodges Ferry-Sorrell-Hobart and Burnie-Smithton. These are all inter-urban public transport services, rather than metropolitan or urban public transport services. I also understand that the company assesses that it is achieving compliance with the relevant provisions of the Public Transport Standards in respect of 33% of servicesfor which the company should be commendedand anticipates meeting the timetabled requirement of compliance in respect of 55% by 31December 2012. The company representatives did indicate that DDA compliant buses are operated on the general access services and that a DDA-compliant vehicle is operated on each of the corridors. However, these accessible services do not appear to be publicised or timetabled and, as such, it is difficult to ascertain with any certainty when a person requiring accessible public transport could travel on the general access services. It would, in my view, be necessary and appropriate for the 鱨վ to seek clarification from the company on these matters before making its determination on the exemption application. It appears from my discussions with Mr Sydes and Mr Larrisey that the company is seeking to be able to use buses purchased for other purposes on its general access services where additional vehicles are needed or there is a problem with a scheduled vehicle. However, this may not accurately reflect the situation and it is one on which I believe the 鱨վ could usefully obtain more information before making its decision on the exemption application. Inter-urban public transport in Tasmania Tasmania has limited inter-urban public transport services with inter-urban public transport options limited to buses and taxis. Major service hubs are located in Hobart and Launceston in particular and many people need to travel to these two urban centres from rural and regional areas of Tasmania for a range of purposes including employment, health care, recreation and major events. For people with mobility impairments, access to public transport between the major urban hubs of Hobart and Launceston and to one or both of these hubs is of significant importance. As at June 2011, there were 61 wheelchair-accessible taxi (WAT) licences on issue in Tasmania. These have specific operating areas and are restricted to operating within, to or from the operating area specified for the particular licence. Of the 62 WAT licences, 42 are in the Hobart taxi area (which includes Dodges Ferry and Sorrell), 16 in the Launceston taxi area, one in the Devonport taxi area and one in the Huon Valley taxi area. This means that people who require wheelchair accessible transport who live outside the specified taxi areas are reliant either on private vehicles or on buses. Cost impact of limited inter-urban public transport As noted above, the only inter-urban public transport alternative to buses in Tasmania is taxis. At this time, the provision of WATs outside Hobart and Launceston is limited and the cost of travelling from Launceston to Hobart, for example, by taxi would be in the order of $350$400. By comparison, the published fare for travelling by Redline bus from Launceston to Hobart is $38.30 and the pensioner concession fare is $17.70. The Tasmanian Government does provide taxi fare concessions, but these are limited and do not offset the cost of a taxi fare when compared to a bus fare for the same trip: 3. Taxi Fare Concessions Taxi fare concessions entitle eligible members to: a 50% fare reduction when travelling in standard taxis, and is available only to persons meeting income and asset criteria for the issue of a Pensioner Concession Card, Health Care Card or a Commonwealth Seniors Health Card issued by Centrelink, and holders of a Pensioner Concession Card issued by Department of Veterans Affairs (DVA). The issue of a DVA Gold Card is not accepted as eligibility for taxi concessions, it is issued for rebates on medical treatment only and is not income and asset tested, or a 60% fare reduction when travelling in wheelchair-accessible taxis (for wheelchair reliant members of the Scheme only. Applicants who are wheelchair reliant are not required to submit a copy of a pensioner concession or health care card when applying for taxi concessions). A maximum concession of $25.00 per journey applies when using standard taxis, and a maximum concession of $30.00 applies for wheelchair reliant members when using a Wheelchair Accessible Taxi. Even with the maximum concession available, the difference in cost between travelling on a bus between Launceston and Hobart and a WAT would be in the order of $300$350. This is a significant cost burden on a person with disability. The purpose of the Public Transport Standards, the granting of exemptions and the issue of unjustifiable hardship The question of the availability of sufficient information to make a decision aside, there is a more fundamental issue of concern, that being whether the 鱨վ's exemption power under the DDA and/or Public Transport Standards is an appropriate tool to use to retrospectively address a clear failure of Redline to comply with its obligations under the Public Transport Standards by purchasing inaccessible buses and seeking to use those buses for public transport services. In effect, the 鱨վ is being asked to use its exemption power to endorse a claim of unjustifiable hardship rather than to offer protection from complaint on the basis that the applicant is making progressive moves to achieving compliance with the DDA and the Public Transport Standards. Of relevance to this point is the purpose of the Public Transport Standards and their relationship to the DDA. The Public Transport Standards were developed under section 31 of the DDA. It is my understanding that the capacity to make standards under section 31 of the DDA was included as a proactive compliance tool. The Public Transport Standards were developed over ten years of extensive consultations with industry, government and the disability sector, including involvement of the bus and coach sector through the industry body, the Australian Bus and Coach Association. The Public Transport Standards set out what operators are required to do in order to comply with their obligations as public transport service providers under the DDA. The breach of the Public Transport Standards indicated in the application letter is a breach of one of the few provisions that require immediate and ongoing compliance: the obligation in Standard 33.1 to purchase only DDA-compliant vehicles when purchasing new vehicles. Under the DDA and the Public Transport Standards, organisations that are in breach of the requirements may seek to rely on the defence of unjustifiable hardship. I note that the question of whether or not a defence properly applies is not a matter for the 鱨վ, but rather a matter to be determined by a court when considering a complaint alleging unlawful discrimination under the DDA by virtue of a failure to comply with the Public Transport Standards. That said, Standard 33.7 sets out the factors to be considered when determining whether or not compliance with a requirement in the Standards would impose unjustifiable hardship. Of potential relevance are paragraphs 33.7(a), (d), (h), (i) and (n), which are extracted below. 33.7 Exceptional casesunjustifiable hardship (3) In determining whether compliance with a requirement of these Standards would involve unjustifiable hardship, all relevant circumstances of the particular case are to be taken into account including the following: (a) any additional capital, operating or other costs, or loss of revenue, that would be directly incurred by, or reasonably likely to result from, compliance with the relevant requirement of these Standards; (d) the extent to which the service concerned is provided by or on behalf of a public authority for public purposes; (h) financial, staffing, technical, information and other resources reasonably available to a person or organisation required to comply with these Standards, including any grants, tax concessions, subsidies or other external assistance provided or available; (i) benefits reasonably likely to accrue from compliance with relevant requirements of these Standards, including benefits to people with disabilities, to other passengers or to other persons concerned, or detriment likely to result from noncompliance; (n) if a person or organisation concerned has given an action plan to the Commission under section 64 of the Disability Discrimination Act 1992 the terms of that action plan and any evidence regarding its implementation; These should, in my view, be applied to the effect of compliance at the relevant time. In this case, the relevant time would be at the time of purchasing the new buses in 2010. As such, the relevant question in respect of Standard 33.7(3)(a) in respect of the cost to Redline is not whether or not having to retrofit access features to the buses purchased in 2010 would impose an unjustifiable hardship, but rather whether or not purchasing DDA-compliant vehicles in 2010 would have imposed an additional cost burden on the purchase sufficient to impose an unjustifiable hardship. Redline has not provided information in its application as to the cost differential of purchasing DDA-compliant buses rather than non-compliant buses. In respect of Standard 33.7(3)(d), it is my understanding that the relevant services provided by Redline are provided under a contract with the Tasmanian Governments Transport Commission. As such, they are provided on behalf of a public authority for public purposes. In respect of Standard 33.7(3)(h), the Commissioner for Transport for Tasmania, David Peters has indicated in his submission to this process that Redline is providing services under a contract with the Tasmanian Government that includes, as an element of the remuneration, a capital payment linked to the bus capital value (BCV) [and that the] capital component [is] based on quotes from bus building companies for the supply of DSAPT-compliant vehicles. This appears to indicate that there is some financial assistance to achieve compliance. In respect of Standard 33.7(3)(i), I refer you to my comments above under Inter-urban public transport in Tasmania and Cost impact of limited inter-urban public transport. In respect of Standard 33.7(3)(n), I understand that the company does have an Action Plan and it has lodged this with the 鱨վ. I have not, however, been able to obtain a copy of that Action Plan, either from the Commissions website or from that of the company. As a result, I am unable to provide any comment on whether or not that Action Plan is relevant or is being implemented. I have concerns about the appropriateness of the 鱨վ to exercise its exemption powers to determine whether or not Redline could properly rely on the defence of unjustifiable hardship should a complaint be made against it. Nor is it appropriate for the Commission to exercise its power to grant an exemption to simply confirm the availability of this defence and thereby authorise non-compliance with the key compliance mechanism in the DDA: a standard made under section 31. Concluding remarks The level of detail provided in the application by Tasmanias Own Redline is, in my view, insufficient to determine whether or not the exemption should be granted. Unless the Commission has available to it details of how the current fleet of DDA-compliant buses is being utilised on the general access services, what information is available to the travelling public about the scheduling of those buses and what, if any, requirements there are on a person with disability seeking to travel on a DDA-compliant bus in relation to booking, etc. In considering whether or not the company should be granted an exemption on the basis of unjustifiable hardship, I note from the 鱨վs own guidance on the granting of exemptions: that the Commission has not been prepared to grant exemptions simply to certify that discrimination may continue, on the basis of unjustifiable hardship or other defences. While the approach of the 鱨վ has been to grant exemptions on condition that the applicant makes and meets commitments to improve access or opportunity within a reasonable period, there is insufficient detail in the application from the company to determine what, if anything, it is proposing to do to improve access or opportunity. Further, the limited information on current services and allocation of accessible vehicles to the general access services by the company, and the lack of publicly available information for passengers with disability mitigates against the granting of the exemption at this time. Yours sincerely [signed] Robin Banks Anti-Discrimination Commissioner     PAGE  PAGE - 2 - Office of the Anti-Discrimination Commissioner Celebrating Difference, Embracing Equality Level 1, 54 Victoria Street, Hobart GPO Box 197, Hobart, Tasmania, Australia, 7001 Telephone: [03] 6233 4841 Statewide: 1300 305 062 Facsimile: [03] 6233 5333 E-mail:  HYPERLINK "mailto:antidiscrimination@justice.tas.gov.au" antidiscrimination@justice.tas.gov.au Website:  HYPERLINK "http://www.antidiscrimination.tas.gov.au" www.antidiscrimination.tas.gov.au   Letter from P N Sydes, Tasmanias own Redline to Human Rights and Equal Opportunities Commission, 16 May 2011, 1.  Ibid.  Disability Standards for Accessible Public Transport 2002 (Cth) Sch 1, Pt 2, cll 2.4 and 2.5.  Letter from David Peters, Commissioner for Transport, to Robin Banks, Anti-Discrimination Commissioner, 1 June 2011. There is a licensed issued for Burnie, but it is not currently being operated.  Department of Infrastructure, Energy and Resources, Transport Access Scheme Information < HYPERLINK "http://www.transport.tas.gov.au/concession_information_and_forms" http://www.transport.tas.gov.au/concession_information_and_forms>.  Disability Discrimination Act 1992 (Cth) s11; Disability Standards for Accessible Public Transport 2002 (Cth)  Letter from David Peters, Commissioner for Transport, to David Mason, HREOC, June 2011, 1.  鱨վ, Exemptions under the Disability Discrimination Act (2011) < HYPERLINK "http://www.humanrights.gov.au/disability_rights/exemptions/exemptions.html" http://www.humanrights.gov.au/disability_rights/exemptions/exemptions.html>.  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