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.
- 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?
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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?
- 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 .
- 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