26 April 2013 Disabilities Transport Access Secretariat Department of Infrastructure and Transport Dear Sir/Madam, Re: DSAPT 2012 Review We appreciate the opportunity to make a submission as part of the DSAPT 2012 Review. Our submission is based on experience of progress or inactivity evident in Brisbane and South East Queensland (the Gold Coast, Toowoomba, Sunshine Coast triangle), regional Queensland and some national observations. Yours sincerely, John Mayo General Manager – Community Development Spinal Injuries Association DSAPT 2012 Review Submission The following has a Queensland focus, though it touches upon national issues. 1. Has your accessibility to public transport improved since the commencement of the first Transport Standards review in 2007? How has your accessibility to conveyances (e.g. trains, buses and coaches, trams, ferries, wheelchair accessible taxis and aircraft) changed? Can you provide examples? Buses The percentage of low floor buses in the various fleets has increased. More than half of buses are low floor and accessible. These are not distributed uniformly in Queensland, as some operators are behind schedule. Direct Assistance Assistance from drivers in deploying the boarding ramp and of informing vision impaired passengers of their stop is generally good and is improving. Failures do occur on occasion. Movement of mobility aid in allocated space No safe and nationally uniform means of securing mobility aids in allocated spaces has been developed. Some operator specific solutions have been attempted but these all fail to meet the approval of other operators and fail to satisfy the travelling public. The insecurity of mobility aids when cornering, through round-a-bouts, braking and acceleration is a great disincentive to using low floor accessible buses. The DSAPT requirement in Part 9.11 has a 55% compliance requirement by December 31 2012. This target has not been met in Queensland and probably not nationally. 9.11 Movement of mobility aid in allocated space An allocated space must contain movement of a mobility aid towards the front or sides of a conveyance. Conveyances * Buses, except dedicated school buses * Trams * Light rail A nationally applicable solution for this failure to comply is urgently required. 2|Page Manoeuvring area Floor layout seems to be fixed in the pattern of an access path commencing at the front door and terminating at two allocated spaces immediately behind the wheel arches. This obliges a person using a mobility aid to turn it through 180 degrees to exit. This is quite difficult to achieve for some powered mobility aids. Some larger aids also struggle to turn into the spaces from the access path. Part 3.2 of DSAPT (below) requires a performance outcome where mobility aids must be able to enter, exit and manoeuvre in the bus. 3.2 Access for passengers in wheelchairs, etc (1) Passengers in wheelchairs or mobility aids must be able to enter and exit a conveyance and position their aids in the allocated space. (2) If this is not practicable, operators must provide equivalent access by direct assistance. Note See sections 33.3 to 33.6 in relation to equivalent access and direct assistance. Conveyances * Buses, except dedicated school buses * Ferries * Accessible rail cars * Accessible tram cars * Accessible light rail cars No dimensions are given to permit the required actions. Since the envelope of a bus’s width and length is strictly limited, an alternate layout where mobility aids enter by one door and exit by the other needs to be investigated. Rail Refurbishment of the Queensland Rail City Train fleet is ongoing, with most six car sets now having 12 allocated spaces. Assistance from guards and platform staff is adequate to good. The majority of City Train rail car sets have a compliant number of allocated spaces; however, the majority of allocated spaces are operationally unavailable. In a six car set, guards will deploy ramps only to the three allocated spaces in car 4. The nine spaces spread across cars 1, 3 and 6 (three per car) are not utilised. This is a QRail policy. Priority seating is present in cars 1, 3, 4 and 6 of a six car set but is not necessarily enforced. Passengers disinclined to surrender seats usually face nothing worse than censure via stares from other passengers. Ferries The Brisbane ferry fleet is undergoing a substantial refit that will give a high degree of accessibility. Deployable boarding ramps require further design consideration. It is acknowledged that the deployable boarding ramp must function in a dynamic environment, bridging between two moving surfaces – pontoon and vessel – and that this will influence its 3|Page profile. However, its design must first and foremost permit people with disabilities and others with diminished functionality to travel safely between ferry and pontoon. Assistance from deck hands and ticket sellers remains excellent, with direct assistance overcoming many access obstacles. The removal of obstacles will of course create a safer workplace for staff, through making direct assistance redundant. Taxis Wheelchair accessible taxi numbers remain static, whilst the population that needs them grows. As a result, accessing a wheelchair accessible taxi service during peak times is still more difficult than it is for standard taxis. Response time after a booking call still lags standard taxis at any hour. Assistance from drivers ranges from poor to excellent. With the introduction of the Amind maxi taxi modification, substantial progress has been made towards rolling out a fleet of universally accessible maxi taxis. Wheelchair users are increasingly indicating their preference to be located in the middle of maxi taxis near the centre of gravity to avoid the stressful, bumpy, sometimes hurtful ride when located in the rear tie down area due to the mathematics of side slip or slip angle that occur naturally when cornering. A continual complaint is that maxi taxi windows are not large enough for users in mobility devices to see out of, which is a poor experience compared to users seated in fixed seating who are able to visually experience the passing landscape and know what stage of the journey they are at. Compared to maxi taxis with two wheelchair spaces, modified MPV single wheelchair taxis receive less patronage by wheelchair and scooter users. Coaches Accessible coach numbers are static. Few coaches are accessible with at least one company, Murrays, admitting in the Federal Court to not having any accessible coaches (Haraksin versus Murrays Australia Limited, March 2013 FCA217). http://www.austlii.edu.au/cgibin/sinodisp/au/cases/cth/FCA/2013/217.html?stem=0&synonyms=0&query=title(haraks in%20) Courtesy coaches, such as those connecting airports to hotels, are uniformly inaccessible. These must be made DSAPT compliant, and if outside the current scope of DSAPT, must be brought within it. The social and economic impact on Australia’s tourism alone demands it. Aircraft Aircraft accessibility is static. The Jet Star two wheelchair policy is viewed as discriminatory, and therefore the Australian Human Rights Commission investigation into the effects of the policy is welcome. Assistance from staff is poor to excellent. Cabin wheelchairs are poorly designed and usually lack any heel / calf restraint. 4|Page Assistance animal policy varies between airlines, creating confusion. A nationally agreed assistance animal policy is needed. Complaint about airlines and airports by people with a disability is non stop. Trams / Light Rail Light rail is yet to be introduced in Southeast Qld but purportedly will be DSAPT compliant. How has your accessibility to information (e.g., maps, timetables, announcements, etc) changed? Can you provide examples? Audio announcements Service and next stop announcements vary between modes. Buses Some bus stations have next service announcements but most do not. No bus stops have audio announcements of next service. A limited number of buses are involved in a trial of next stop announcements. The effectiveness of these announcements has yet to be evaluated. Private industry is providing accessibility applications for smart phones. An example is Next Stop (http://nextstop.me/) which alerts passengers with vision impairments (and others) traveling on a bus that they are approaching the bus stop at which they intend to alight. This app is used successfully by a number of people who have vision impairments and should have been produced by Translink rather than an entrepreneur. As the product of an individual entrepreneur rather than a State or National authority, an innovative piece of work risks being isolated in its point of origin rather than being rolled out state-wide or nationally. Rail ‘Next Train Information’ consoles are ubiquitous in the Queensland Rail City Train network and generally reliable. Many platforms have next train arrival PA announcements, though these do not operate at all hours at every platform, making it an unpredictable service for customers to place reliance in. Platform staff are usually quite helpful, though very few stations are continuously staffed. New and refurbished trains have automated audio announcements of next stop and other service information, but some older trains rely on guards to make announcements. While some guards are quite good with announcement volume, punctuality and coherence, some are quite poor, which results in a service of unpredictable quality. 5|Page Ferries CityCat and City Ferry services announce next stop and in the case of CityCats either forward or aft boarding gate is also nominated. No announcements of next service are made or available on ferry terminals. A ‘Next Service Information’ console should be developed similar to that used by Queensland Rail. CityCats also feature audio induction loops for hearing aid users. Printed Information No real change in the quality or type of printed information has been noted. Text can be poorly contrasted with its background, and inappropriate font types can be employed. Large print copy is rarely provided. Electronic Information Timetables, and other information for bus, ferry and rail services, are available online at the Translink site. Frequently this material is in PDF format and not particularly accessible. A timetable for the Caboolture line serves as an example: http://jp.translink.com.au/travel-information/network-information/trains/caboolture While HTML timetables exist they are far from equivalent in scope to the PDF editions, requiring a degree of navigating between pages, and are somewhat difficult to locate on the Translink site. http://jp.translink.com.au/travel-information/network-information/trains/caboolture Translink are trialling a real time on-line / smartphone product called Trip Tracker, which gives arrival times of Blue City Glider and Clarks Logan City services at bus stops. If successful it will enable people waiting at bus stops to know the arrival time of their services at the stop at which they are waiting. How well this information functions for people using screen narration software is unknown. http://translink.com.au/about-translink/what-we-do/infrastructure-projects/triptracker Information on websites is not always accurate. For example, during the Australia Day 2013 floods all ferry services on the Brisbane River were cancelled. Despite no ferries running the Translink website continued to give “real time” updates on arrivals and departures at each ferry terminal. Had a person checked the timetable without first checking media news updates they would have been under the misapprehension that the ferries were in service. How has your accessibility to infrastructure immediate to boarding a conveyance changed? (e.g., any structure or facility that is used by passengers in conjunction with travelling on a public transport service). Can you provide examples? 6|Page Bus stops Bus stops are being upgraded steadily. However, upgrade will usually not make a bus stop DSAPT compliant. Factors such as road gradient, footpath crossfall, footpath width, location of underground services, above ground infrastructure, location of street trees, proximity to driveways, impracticability of stop relocation and lack of alternate sites in generally hilly suburbs will all prevent full compliance at a large proportion of bus stops. Rail stations Existing Queensland Rail City Train stations (Nambour, Gold Coast and Ipswich triangle) are either listed for upgrade, have already undergone upgrade or were constructed new to compliance. As such, the accessibility of the network is gradually improving. It remains to be seen whether the December 2017 deadline will be met. Bus stations All new bus stations constructed in the period have largely met DSAPT. New stations such as Stones Corner, Lutwyche, Kedron Brook have few issues with noncompliance. Existing stations also largely meet DSAPT. For people who have mobility or vision impairment, boarding buses at bus stations can be challenging at busy times. Several buses may pull in at random points at any time and the challenge is to identify and reach a bus before it departs. This is an issue facing all passengers, but for passengers who have vision or mobility difficulties it is often a deciding factor in discouraging use of bus stations. A boarding procedure that ensures that no passengers with disabilities are left behind needs to be developed by Translink. Ferry terminals Terminals are undergoing upgrades, but this has suffered setbacks following disastrous flooding in January 2011. While terminals are upgrading to compliance, their surroundings within the precinct often present accessibility challenges. It is critical that the precinct surrounding the ferry terminal is accessible to people with disabilities if they are to access the terminal from other transport modes. Topography is often a problem however, with short, steep escarpments between roads and riverbank creating an environment unfavourable for low-cost engineering work. Some of these accessibility challenges will be defended, possibly legitimately, as unjustifiable hardship cases. Others, particularly at busy terminals such as North Quay, would be harder to defend and could be overcome if sufficient funds were available for works. If this approach to connecting terminals to onshore facilities to a radius of at least 150 m is disregarded, many terminals will be DSAPT compliant, but isolated due to not being connected to shore based facilities by an accessible path of travel. Pontoon ramps can be quite steep at low tide. While they may fully comply with Part 6.5 they are not particularly accessible at gradients exceeding 1:14 over distances of >20 m. 6.5 Slope of ramps connected to pontoon wharves 7|Page The slope of a ramp connected to a pontoon wharf must comply with section 6.1 for at least 80% of the high and low tide levels listed in standard tide charts. Direct assistance could overcome the gradients, but without some guidance as to how this could be provided in a manner that is safe for passengers and staff it is unlikely to be provided. Airports Airports vary considerably in their accessibility. They frequently lack accessible drop off and pick up locations that are in proximity to the principal entrances. As per taxi ranks, no technical specification for an accessible pick up / set down facility is referenced in DSAPT. This omission needs to be rectified. As a policy, some airlines will leave customers with mobility impairment sitting in cabin aisle chairs for extended periods. We know of one woman who was left for four hours unattended. This is unacceptable as these customers lose all mobility and are not able to visit toilets, check luggage, obtain food or drink or any other normal activity. Access paths, circulation spaces, waiting areas and sanitary facilities vary in their compliance between and within airports. It is unclear if any significant effort to meet the DSAPT schedule of compliance is being made at airports. For example, at Brisbane airport the aerobridges are too steep and lack landings at compliant intervals. While this can be overcome through direct assistance, the different airlines’ policies vary on what will be provided. Compliant aerobridges will overcome the vagaries of airline direct assistance policy. Travellers with disability and diminished functionality who complain about their poor experiences almost universally report airlines and airports blaming each other for the problem experienced. What is urgently required by airlines and airports is recognition that the customer experience is from the airport kerb to the airline seat and vice versa. Tram light rail stops Tram stops are not yet constructed but are purported to be compliant when constructed. It remains to be seen how track flange-way gaps located in the access path to the tram stop will be addressed. It is an underlying assumption of the DSAPT that mobility aids can address horizontal gaps in an access path of up to 40 mm. If the track flange gap exceeds 40 mm it will challenge many mobility aid users. Taxi ranks Taxi ranks located at kerbside almost universally lack any means by which a mobility aid user, who must board or alight via the rear lift platform of the taxi, can negotiate the kerb. Lack of a safe connection between maxi taxi rear entrance and footpath places people using mobility aids in the unsafe situation of having to travel between the rear of the taxi and the footpath via the carriageway. A technical specification for taxi ranks is required similar to or an improvement on: http://www.brisbane.qld.gov.au/documents/building_development/subdivision_developm ent/ums%20265.pdf 8|Page What do you currently see as the greatest areas of need with regard to accessibility of public transport for people with disability? Can you provide specific examples? Transport network dysfunction While technical compliance, or the lack of it, is an issue for people with disability, it is not the critical issue. In the fullness of time, probably well after the compliance deadlines are past, most conveyances, infrastructure and premises will be as compliant as practicable. Unfortunately this will most likely involve protracted battles such as Haraksin versus Murrays Australia Ltd. Non-compliance will diminish in future however, and then cease to be an issue, as access and information solutions are developed, whether willingly or not. However, fully compliant conveyances, infrastructure and premises are only as useful as the systems, networks and landscapes of which they are a part permit them to be. Unless the pedestrian and transport connections between transport nodes are fully accessible, transport nodes risk being no more than accessible islands in an inaccessible ocean. Large areas of both urban and rural landscape currently feature these archipelagos of accessibility, with their scattered stops, stations and terminals embedded in a matrix of difficult access paths and poorly coordinated multimodal transport routes. Specific examples include: * compliant bus stops are sometimes built into grassy road verges that lack concrete footpaths, * ferry terminals are often isolated from access paths by unfavourable topography, * few rail stations or ferry terminals are the focus of bus feeder routes, * different modalities operated in isolation from each other with little attempt to coordinate timetables, * footpaths are poorly maintained in some jurisdictions, * Local authorities have not constructed concrete footpaths in road verges or have not constructed them to Australian Standards, * street crossing points lack kerb ramps or kerb ramps do not meet Australian Standards, * wayfinding cues for people with vision impairment are almost non-existent, * transport modality change required to complete journey where onward modality is not accessible. Unless timetables of intra and intermodal services coordinate, valuable time is wasted in waiting for the next service. Time is a valuable resource and its loss is a great disincentive to using public transport. 9|Page A concerted effort is required to ensure that wherever practicable, every front door is within range of an accessible entry point into the public transport system. Once in this system, travel and transport must be continuous, accessible and convenient. For example, intramodal changes between routes and services and intermodal transfers must be quickly and safely executed, using accessible paths of travel carried out in an easy and seamless manner. The password is ‘seamless connections”. Out-dated technical specifications The DSAPT primary referenced standards are all at least 12 years old, with the AS1428.2 being 21 years old. While some specifications, such as infrastructure dimensions, are unlikely to change over time, many do. In particular, references and specifications for wayfinding products and designs, electronic information and other information formats require updates. New technologies such as those that permit use of the near ubiquitous smart phones need to be incorporated into the DSAPT. For example, by using the ‘Next Stop’ app (http://nextstop.me/), people with vision impairments travelling on buses can be informed of their stop over their phones - provided that the bus is being tracked by GPS. A nationally coordinated strategy to ensure that conveyances, infrastructure and premises interact successfully with emerging technologies is required. A working group should be established to address technological changes that are applicable to DSAPT. 2. As a public transport user, are there areas of the Transport Standards where you consider that a more specific requirement for compliance would improve accessibility? The following sections of DSAPT require far more specific technical specifications or lack specifications entirely: * Mobility aid restraints in buses, trams, light rail; type of restraints and required restraint performance require specifications. * Next stop / next service announcements and displays, upgraded to contemporary specifications. * On conveyances; circulation / turning space dimensions, passing areas, access path surface texture / dimensions require technical / dimensional specification. * Taxi ranks, passenger set down / pick up zones to have specifications included. * Location and alignment of grab rails in allocated spaces have no specifications. 10 | P a g e * Design, operational requirements and placement of accessible controls (other than door controls) have few specifications or specifications impracticable for conveyances. * Clarification on the design of pontoon ramps and definition of which tidal ranges are involved (astronomical, neap, spring, mean?). * Vertical space above allocated spaces in conveyances other than taxis. * Minimum length of accessible toilet circulation area on a conveyance not specified. * Wayfinding signs for people with vision impairment have no specification. * Tactile Ground Surface Indicators lack technical specifications for layout at bus stations, bus stops and tram stops. * Specifications for emergency egress and emergency wayfinding require updating. * Lighting levels are often unrealistic and require greater clarity over which standards are to be met and under which circumstances. 3. To what extent do you feel that the requirements in the Transport Standards address all of the accessibility requirements for people with a disability? Are there gaps in the coverage of requirements? Wayfinding for people who have vision impairments The DSAPT dates from a time when wayfinding design for people with vision impairments was in its infancy. The science has matured somewhat and wayfinding needs to be covered comprehensively in the DSAPT. This must not be limited to TGSIs and Braille / tactile signs, though these have their place. Smart phone technologies need to be fully exploited with apps and information provided to allow passengers with vision impairments to determine that they are at the correct boarding point, moving along the correct path, within the vicinity of a service or information node, and so on. Taxi rank and passenger set down design The DSAPT contains no technical references for the design of taxi ranks. This is a major oversight and needs to be addressed. Wheelchair accessible taxis are usually accessed from the rear, so that a wheelchair user must be able to access the carriageway behind the vehicle. To accomplish this, the wheelchair user must either be able to negotiate the kerb or the rank has a kerbless design. Brisbane City Council does have specifications but these have no scope outside Brisbane and are limited to kerbside ranks: http://www.brisbane.qld.gov.au/documents/building_development/subdivision_developm ent/ums%20265.pdf 11 | P a g e Just as taxi ranks require technical specifications to allow boarding of wheelchair accessible taxis so the set down area for passengers using wheelchairs must also be included. Disembarking from most wheelchair accessible taxis will place the wheelchair user on the carriageway, often in designated passenger embarkation zones. To reach the footpath from the carriageway, the wheelchair user must either negotiate the kerb or the passenger pick up/set down zone must be of kerbless design. These passenger set down / pick up zones are as important to wheelchair accessible taxis passengers as are bus stops to accessible bus passengers. Any designated passenger pick up/set down zone must be considered a potential pick up or destination area for a wheelchair accessible taxi and therefore must be covered by DSAPT. Once again, the Brisbane City Council specification is the only one known. 4. Do you find that the current processes with regard to making a complaint or seeking information are sufficient or sufficiently responsive? Complaint has always proven time consuming, difficult and unpredictable. Many people will not make the huge commitment of lodging a complaint and seeing it through conciliation and possibly court. Complainants are simply worn down by the heavy artillery of big organisations defending their position rather than fixing the problem. When matters proceed to the Federal Court, the verdicts sometimes shake the confidence of a person with a disability, e.g. when a Court agrees the complainant has been discriminated against but they lose the case and are faced with the defendant’s costs (as well as their own)! The arduous process of lodging complaints is well covered in a media article: http://www.abc.net.au/rampup/articles/2013/02/28/3700346.htm While the public are put in the position of being the only DSAPT inspectors, and via their complaints the regulators, this situation will not change. A government or industry inspector / regulator with the power to compel compliance and issue fines is required. This might be achieved in either a co-regulation model or within the current jurisdictional framework. Human Rights are as important as workplace safety and so deserve equal funding for regulation and to ensure compliance with legislation. 5. As a body representing the views of people with a disability, do you have any specific responses or perspectives with regard to the issues raised in the questions above? The Exemption process can be divisive to the sector as submissions, often poorly or only partly informed, sometimes contradict each other. Conference and group discussion with sector representatives, either electronically or in person, would allow a considered consensus position to emerge. Better outcomes and more harmonious 12 | P a g e relations within the disability sector would result from the AHRC taking the facilitator role in group discussions over Exemption applications. It must also be recognised that since many of the sector representatives are employed either professionally or as volunteers they are time poor. They must therefore obtain approval to rearrange their diaries and must often seek funds to cover costs in order to participate in conferences and discussions. Some recognition of this by way of assistance and support would make their participation easier. 6. Other key issues you would like to see addressed? Performance criteria for Mobility Aids not in DSAPT Mobility aid suppliers frequently fail to inform purchasers of mobility aids of the dimensional and weight restrictions inherent in the DSAPT and listed as assumptions in the DSAPT Guidelines. People who purchase larger aids in all good faith are then surprised and disappointed when the aid will not fit or manoeuvre in a conveyance. Further, Department of Transport and Main Roads policy is that mobility aids exceeding to the dimensions of the footprint and with no restraint tie down points are not to be carried in maxi taxis. The performance requirements should be moved from the Guidelines and listed in the DSAPT. Aids supplied through programs such as the Queensland Medical Aids Subsidy Scheme and its equivalents in other jurisdictions should all be marked to indicate that they meet the performance requirements of DSAPT, and private suppliers confronted with disincentives for not confirming that the aid has the required performance to be operable in DSAPT compliant environments. Text of DSAPT encourages minimum compliance The DSAPT text and the text of the referenced Australian Standards fail to advocate for maximum practicable dimensions in conveyances, infrastructure and premises. Rather, they use terms such as “not less than 1200 mm” or similar. Under these circumstances the minimum dimensions permitted become the maximum provided, even when greater circulation space could be easily provided. For example allocated spaces are ‘defined’ in Part 9.1 at 1300 x 800 mm when they could be larger. The text reads “The minimum allocated space for a single wheelchair or similar mobility aid is 800 mm by 1300 mm.” It would be better to state preferred or optimum dimensions rather than the minimum permissible. The 1300 x 800 mm is the least possible provision before an allocated space becomes non compliant, and yet because it is quoted it becomes the default measurement for an allocated space. It would be better to state clearly that the greatest dimensions practicable should be provided with nothing less than 1300 x 800 mm permitted. This is only one of many instances where the text of the DSAPT should be promoting maximum practicable dimensions. 13 | P a g e Technological Changes The DSAPT is a product of the mid 1990s. It has entirely failed to remain current with the technological changes that have taken place within society and the economy. Smart phone apps, QR codes, GPS and other innovations were not in existence when the first draft of DSAPT was tabled. A report from Australian Communications and Media Authority (ACMA) gives a summary of the uptake of smartphone products. Smart phones and tablets: take-up and use in Australia Australian Communications and Media Authority (ACMA) 1 February 2013 Almost half of Australia’s adult population now own a smartphone. Take-up soared by 104 per cent to 8.67 million units over the 12 months to May 2012, according to research released today by the Australian Communications and Media Authority. The report also found that 9.2 million Australians went online via their mobile phone and 4.4 million accessed the internet using a tablet in the six months to May 2012. The number of mobile internet subscribers increased by 22 per cent to 22.1 million subscribers at June 2012. The report notes that continued rollout of mobile network upgrades, growth in 4G coverage and the increased use of WiFi hotspots are key drivers for the increase in smartphone ownership. In the June 2012 quarter, over two million Australians used a WiFi hotspot, 32 per cent up on the previous year. In addition, the huge range of apps available for smartphones and tablets has increased their ease of use and functionality. The number of applications downloaded by smartphone users increased by 85 per cent during 2011–12, with over 4.45 million smartphone users downloading an app during June 2012. http://apo.org.au/node/32808 The ubiquity and capabilities of the new technologies needs to be captured in DSAPT, which is currently rather out dated and limited in terms of its requirements for information, timetabling, wayfinding, service announcements and so on. 14 | P a g e