Review of the Disability Standards for Accessible Public Transport



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RIS analysis of Dedicated School Bus exclusions option


Supporting analysis to Review of the Disability Standards for Accessible Public Transport




October 2009

Report to Australian Government Department of Infrastructure, Transport, Regional Development and Local Government



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© The Allen Consulting Group 2009

Contents



  1. The nature and extent of the problem

    1. The Disability Standards for Accessible Public Transport

The introduction of the Commonwealth’s Disability Discrimination Act 1992 (the DDA) represented a fundamental shift in the treatment of people with disability in Australia. The DDA diverged from the traditional medical model of disability, instead adopting a new approach premised on an individual’s right to engage in meaningful social and economic experiences. Section 3 of the DDA states that the objects of the Act are:

  1. to eliminate, as far as possible, discrimination against persons on the ground of disability in the areas of:

  1. work, accommodation, education, access to premises, clubs, sport; and

  2. the provision of goods, facilities, services and land; and

  3. existing laws; and

  4. the administration of Commonwealth laws and programs; and

  1. to ensure, as far as practicable, that persons with disabilities have the same rights to equality before the law as the rest of the community; and

  2. to promote recognition and acceptance within the community of the principle that persons with disabilities have the same fundamental rights as the rest of the community’.

While the DDA makes discrimination on the grounds of disability unlawful it does not:

  • specify the ways in which compliance can be tested, or the means by which parties assure compliance with the DDA; or

  • provide clarification on the specific matters relating to the requirements of the DDA (except where an exemption is provided by the Australian Human Rights Commission [AHRC] or there is a determination by a court).

In response to these issues, the Australian Government sought to develop Disability Standards under the DDA in the areas of education, access to premises, public transport and employment. The Disability Standards for Accessible Public Transport (Transport Standards) were the first Disability Standards to be introduced when they were passed into law on 23 October 2002.

Scope of the Transport Standards



The Disability Standards for Accessible Public Transport establish minimum accessibility requirements for the providers and operators of ‘public transport conveyances, infrastructure and premises’. They include a wide range of requirements for: access paths; manoeuvring areas; ramps and boarding devices; allocated spaces; doorways; controls; symbols; signs; waiting areas; boarding points; allocated spaces; surfaces; hand and grab rails; doorways and doors; lifts; stairs; toilets; Tactile Ground Surface Indicators (TGSIs); alarms; lighting; controls; furniture and fittings; street furniture; gateways; payment of fares; hearing augmentation listening systems; information provision; booked services; food and drink services; belongings; and priority arrangements (Attorney General’s Department, 2006).

The Transport Standards set out requirements for providers and operators that apply to the following modes of transport or ‘conveyances’

  • aircraft

  • buses or coaches

  • ferries

  • taxis

  • trains, trams, light rail, monorails, rack railways and

  • any other rolling stock, vehicle or vessel classified as public transport within its jurisdiction by regulation or administrative action of any Government in Australia.

The Transport Standards themselves are not structured around modes of transport, but apply to each mode in a particular way (allowing for the nature of the mode and what needs to be done to provide accessibility).

Some transport services, such as school bus services and limousines and hire cars, were excluded from some, or all Parts of the Transport Standards during the implementation phase, in response to particular cost or technical concerns. The AHRC has the power to grant temporary exemptions from the DDA and the Transport Standards on application. These temporary exemptions allow providers a specified period of time to address particular problems with meeting the requirements in the Transport Standards.

Treatment of dedicated school bus services in the Transport Standards



A dedicated school bus service is defined in the Transport Standards as a service that operates to transport primary or secondary students to or from school or for other school purposes (Part 1.13). These services are excluded from 26 parts of the Transport Standards, as detailed in .

Exclusions from the Transport Standards for dedicated school buses

Transport Standards Part

Notes

3.2 Access for passengers in wheelchairs

Requires that passengers in mobility aids must be able to enter and exit a conveyance and position their aids in allocated spaces

6.2 Boarding ramps

Specifies that a boarding ramp must comply with the relevant Australian Standard

6.3 Minimum allowable width (ramps)

-

6.4 Slope of external boarding ramps

Specifies the slope of boarding ramps, for both assisted and unassisted access

8.2 When boarding devices must be provided

-

8.3 Use of boarding devices

Specifies that the boarding device must be provided at all designated stops

8.4 Hail-and-ride services

Specifies the use of boarding devices for Hail-and-ride services

8.5 Width and surface of boarding devices

-

8.6 Maximum load to be supported by boarding device

-

8.7 Signals requesting use of boarding device

-

8.8 Notification by passenger of need for boarding device

-

9.1 Minimum size for allocated space

-

9.4 Number of allocated spaces to be provided – buses

-

9.7 Consolidation of allocated space

Suggests that allocated spaces should be consolidated

9.9 Use of allocated space for other purposes

Specifies that allocated spaces can be used for other purposes

9.11 Movement of mobility aid in allocated space

Specifies that an allocated space must contain movement of a mobility aid towards the front or sides of a conveyance

10.1 Compliance with Australian Standard (surfaces)

Specifies the ground and floor surfaces on conveyances

11.3 Handrails on steps

-

11.4 Handrails above access paths

-

11.5 Compliance with Australian Standards (grabrails)

Specifies that grabrails must comply with the relevant Australian Standard

11.6 Grabrails to be provided where fares are to be paid

-

11.7 Grabrails to be provided in allocated spaces

-

12.1 Doors on access paths

Requires that any doors along an access path not present a barrier to independent travel

12.4 Clear opening of doorways

-

12.6 Automatic or power-assisted doors

-

14.1 Stairs not to be sole means of access

-

Source: Disability Standards for Accessible Public Transport Guidelines 2004 (No. 3), p. 49.

The exclusions set out in effectively mean that dedicated school buses are excluded from all physical access requirements in the Transport Standards. That is, dedicated school buses are not required to:

  • provide a boarding device for people using mobility aids;

  • provide handrails or grabrails;

  • provide any allocated spaces for people with mobility aids;

  • include appropriate surfaces; or

  • provide automatic or power-assisted doors, or have doorways of a specific width to assist people with mobility impairments.

lists those Parts of the Transport Standards that apply to dedicated school bus services.

The rationale behind the exclusions

The exclusion of dedicated school buses from physical access Parts of the Transport Standards was a response to the identified costs of these particular Parts, which require investment in low-floor buses or retro-fitting of coaches. While not a full exclusion, the remaining applicable Parts only provide a small degree of accessibility, primarily to those students with a vision impairment (through the requirements around signs, illumination and information). The exclusions remove any requirement that dedicated school buses are accessible for any student using a mobility device, or any student who has a mobility impairment which means that they cannot negotiate a series of stairs to enter and exit the bus (particularly as there is no requirement for handrails or grabrails).

The RIS for the proposed Transport Standards estimated that the costs of making dedicated school buses fully compliant with the Transport Standards would be $1265 million over 20 years (1998 prices) (Attorney-General’s Department, 1999), which would be incurred by a large number of small bus operators. These costs were deemed to be extremely high. It was further argued by school bus service operators that:

  • they are small business people, generally using older and often second-hand vehicles, turning them over less frequently;

  • there is little or no demand for accessible services, the cost is not warranted by the limited demand;

  • it is unlikely that there would be [an] accessible pathway between the bus stop and home so that improvements to buses would not be utilised; and

  • bus stops are generally unformed, sometimes merely the space required for the bus to pull over on the roadside (Attorney General’s Department, 1999).

It is also noted on the Attorney-General’s Department’s website that the reason for the exclusions for dedicated school buses were a response to problems associated with operating low floor buses on ‘difficult terrain’ (Attorney-General’s Department, 2006).

the Transport Standards that apply for dedicated school buses

Transport Standards Part

Notes

2.6 Access paths – conveyances

-

2.7 Minimum width between front wheel arches of bus

-

2.8 Extent of path

-

9.10 International symbol of accessibility to be displayed

Not applicable for buses without wheelchair accessibility

16.1 International symbol for accessibility and deafness

-

16.2 Compliance with AS2899.1 (1986)

-

16.3 Accessibility symbols to incorporate directional arrows




16.4 Accessibility symbol to be visible on accessible bus




17.1 Signs – height and illumination




17.3 Signs – location (conveyances)




17.4 Destination signs to be visible form boarding point

-

17.6 Raised lettering or symbols or use of Braille

-

19.1 Emergency warning systems




20.2 Illumination levels – conveyances

-

20.3 Dimming

-

21.2 Passenger-operated devices for opening and closing doors




21.3 Location of passenger-operated controls for opening and locking doors

-

21.4 Signal devices for conveyances that stop to request

-

25.1 Passengers to pay fares

Limited applicability

25.2 Fare payment and ticket validation systems

Limited applicability

25.3 Vending machines

Not applicable on school services

26.2 Public address systems – conveyances

Not applicable as address systems are not used

27.1 Access to information about transport services




27.2 Direct assistance to be provided




27.3 Size and format of printing




27.4 Access to information about location




29.1 Equal access to food and drink services

Not applicable as food and drink services are not provided on school services

31.1 Priority seating

Not applicable as school services do not have booked seating

31.2 Information to be provided about vacating priority seating

Not applicable as per 31.1



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