The Paraplegic and Quadriplegic Association of Victoria

208 Wellington Street

Collingwood Victoria 3066

Phone: 03 9415 1200

Fax: 03 9415 1200

Email: theteam@paraquad.asn.au

SUBMISSION ON THE SUBJECT OF AN EXEMPTION APPLICATION BY THE VICTORIAN PUBLIC TRANSPORT CORPORATION (PTC)

AND OTHERS UNDER THE TRANSPORT PROVISIONS

OF THE DISABILITY DISCRIMINATION ACT

 

This submission will address some of the major points of argument in the application for exemption referred to above and will also advance other points relevant to this discussion.

  1. The applicants were involved in the development of the Standards for Disability Transport. Compromises have already been made by representatives of people with disabilities by agreeing to a 20 year period over which accessibility will be introduced. Why were these objections not raised at that time?
  2. As stated in the application, trams make up a large proportion of transport services. Delaying the introduction of accessible trams will perpetuate the considerable barriers to people with disabilities using public transport and the inequity which this involves. In addition, there are planned extensions of the tram service, for example, to Knox, Whittlesea and Box Hill creating an even more extensive tram network. There is no mention of these tramlines or of their planned accessibility in the application.
  3. The PTC promises that if the exemption is granted it will provide a fully accessible tram service in 35 years. Despite various concerted efforts by disability organisations in the past 10 years, including action over the light rail in St Kilda, very little has been done to make public transport accessible, though promises have been made by Ministers regarding trams. Given this history, one could feel doubtful about any commitment to provide accessible trams 35 years into the future. Eight new trams have been purchased in the past 10 years. None are accessible.
  4. The PTC states that hoists on trams would only offer benefits to people in wheelchairs (and no-one else) . They claim that only 1 per cent of the mobility impaired population would benefit from hoists. They need to consider the factor of the aging population, well documented, a phenomenon which will produce increasing numbers of people with mobility impairments who will need access to the public transport system. Hoists and rails would also benefit parents with pushers. Estimates of the percentage of people with mobility impairments in the population, including that made for the Regulation Impact Statement on the Draft Disability Standards for Accessible Public Transport are larger than 1 per cent (approximately 10 per cent). In addition the argument that hoisting people on to trams will hold up the transport system could be seen as discriminatory. Traffic snarls, parents with pushers and reluctant children, skylarking teenagers and elderly people can also slow down the progress of a tram. No-one is suggesting that they should be penalised or kept off trams.
  5. It is understood that representatives on Accessible Transport Consultative Council (a reference group to the Minister for Transport) spoke against this exemption when it was suggested.
  6. The argument for the retention of W class trams without alteration to provide access, may have some validity if there are plentiful other trams which are accessible on the same lines. However in Seattle in the USA, there are several Melbourne W class trams on a route similar to the city circle route. In this city, where access and disability rights are taken more seriously, access is provided to these trams via raised, ramped platforms, requiring no alteration to the outside of the tram and only minimal restraints on the inside. This demonstrates that ingenious alternatives may be found when the will is there to seek them. The exemption, if granted, would eliminate the need to seek other possible and perhaps less costly ways to make trams accessible. Perhaps other government schemes like ‘work for the dole’ could contribute work towards necessary alterations to trams. People with mobility impairments also come to Melbourne as tourists and may wish to use the W class trams.
  7. People with mobility impairments pay taxes and thus subsidize a public transport system which they are largely unable to use. They should have the same rights as other taxpayers to make use of the services they finance. Many people with disabilities have low incomes and cannot afford private vehicles or the inefficient, expensive and unreliable multi purpose taxi service, which is in itself a perpetuation of segregation. They are therefore among the people who most need to use public transport to allow them to be full members of the community with the same access to education, employment, recreation and the other social benefits that other citizens enjoy.
  8. They are instead threatened with further immobilisation and isolation by a government which appears to be sidelining their needs and rights in this matter. As the aged population increases, their lower income and possible mobility impairment will also increase their need to use public transport.
  9. There are questions here of equity and human rights. It seems to take a long time to shift the perception that people with disabilities can be segregated and excluded from services and social benefits that other people take for granted. We are still living with conditions which come from a time when disability was regarded as something that should be hidden and ignored. Surely it is time we emerged from this oppressive phase of history. Once the one-off changes are made the expense issues will subside, and to provide for the whole community instead of just one section of it will become the norm. It is a matter of priorities. For example, is a major sporting event more important than a long-term transport system, which caters to all types of people on all income levels? Which has the most potential for providing all community members with a decent and equitable life?
  10. In the application it is stated that the government will still provide some funding of the trams after privatisation. The government could therefore bear the cost of alterations to avoid upsetting the financial aims of the tram companies .
  11. We would like to suggest that the exemption not be granted and that a method of modifying some trams and gradually replacing others over a 20 year period be adopted in order to expedite the advent of full accessibility to trams. Other possible solutions to attaining this end at reasonable cost could be researched, including reviewing research which has already been done here in Melbourne, interstate and overseas.

Peter Prendergast

Chief Executive Officer 4 February, 1999