Submission to the Fourth Review of the Transport Standards

PIAC made a submission to the 2022 Review of the Disability Standards for Accessible Public Transport 2002 (Cth) (Transport Standards).

Our submission reiterates many concerns from our submission to the Third Review, as the majority of issues we identified and our recommendations have not been addressed. These  include: 

• Reporting: requiring transport operators and providers to report and publish data on compliance with the Transport Standards;
• Compliance: funding the Australian Human Rights Commission (the Commission) to provide independent oversight of compliance with the Transport Standards; and 
• Enforcement: empowering the Commission to robustly enforce the Transport Standards, given the limitations of the current individual complaints-based system. 

We also refer to two specific transport areas – rideshare services and air travel – where we are aware action is urgently required to provide people with disability with equal access.

We have evaluated the issues and successes of existing frameworks in similar jurisdictions to recommend:

• Rideshare: amending the Transport Standards to explicitly include rideshare services, and to make both rideshare companies and drivers responsible for compliance, as has been done in the United States and the European Union with some success; and
• Air transport: co-designing with people with disability specific standards for air transport accessibility. We recommend the comprehensive framework in the United States should be a starting point for developing standards in Australia. 

Our submission received several endorsements from disability representative organisations and other legal centres concerned with eliminating disability discrimination.