Attachment 1 ARA temporary exemption application 2015 Table of contents Scope of report 3 Introduction 3 References and documents considered 4 Overview of submissions 5 Broad questions raised in submissions 10 Consideration of each application – Group 1 16 2.1 Access paths – Unhindered passage – Part 1 16 2.1 Access paths – Unhindered passage – Part 2 18 2.4 Access paths – Minimum unobstructed width 22 2.6 Access paths – conveyances 26 3.1 Circulation space for wheelchairs to turn in 30 4.2 Passing areas - Two-way access paths and aerobridges 32 5.1 Resting points - When resting points must be provided 35 6.4 Slope of external boarding ramps 37 8.2 Boarding - When boarding devices must be provided 40 8.7 Boarding - Signals requesting use of boarding device 43 11.2 Handrails and grabrails - Handrails to be provided on access paths 45 12.2 Doorways and doors - Compliance with Australian Standard — premises and infrastructure 47 12.4 Clear opening of doorways 49 14.3 Stairs - Compliance with Australian Standards — conveyances 51 15.2 Toilets - Location of accessible toilets 53 15.3 Unisex accessible toilet — ferries and accessible rail cars 55 15.4 Toilets - Requirements for accessible toilets — ferries and accessible rail cars 57 17.5 Signs - Electronic notices 61 18.1 Tactile ground surface indicators - Location 63 20.1 Lighting - Illumination levels — premises and infrastructure 66 21.1 Controls - Compliance with Australian Standard — premises and infrastructure 68 26.2 Hearing augmentation – listening systems - Public address systems — conveyances 70 27.3 Information - Size and format of printing 74 28.1 Booked services - Notice of requirement for accessible travel 76 28.2 Booked services - Period of notice of requirement for accessible travel 76 Consideration of each application – Group 2 79 11.2 Handrails and grabrails - Handrails to be provided on access 79 21.2 Passenger operated devices for opening and closing doors 81 21.3 Location of passenger operated controls for opening and locking doors 83 Consideration of each application – Group 3 - Application for temporary exemptions from the Premises Standards 86
Member that reporting on measures taken in relation to any conditions attached to current exemptions have not been adequate. Having expressed a general view that the exemptions should not be granted All Aboard submitted comments on each of the individual applications on the assumption that the Commission would proceed with the application from ARA on behalf of its members. While All Aboard does not support some specific applications in general the network proposes that if the Commission were to grant any exemption it should be subject to the conditions attached to current exemptions, subject to a number of additional comments or proposals. All Aboard made a supplementary submission concerning what it sees as a significant conflict of interest arising from a cross-over in membership between the ARA and APTJC. All Aboard expressed concern that effectively a group of ARA members (state government transport bodies) are charged with providing advice to the Commission on the application for temporary exemptions by the ARA. Association of Consultants in Access Australia (ACAA) ACAA is a national membership-based professional association for people working to achieve accessibility of the built environment for people all. It is the peak national body for access consultancy in Australia. The ACAA submission does not comment on specific applications, but offers a view on the general approach that could be taken. ACAA proposes that rather than grant broad exemptions any non-compliance at specific locations should be itemised and be subject to the preparation of Alternative Building solution reports. These reports should document both the enduring non-compliances and the local management process by which equivalent access can be provided in the form of direct assistance or other means. People with Disability Australia (PWDA) PWDA is a leading national disability rights, advocacy and representative organisation of and for people with disability. PWDA notes that the current application mirrors earlier applications, but omits reporting responsibilities and reference to provisions such as direct assistance. PWDA states that a monitoring and reporting mechanism is essential for any exemptions granted and that most of the application cannot be supported unless there is such a mechanism as a condition. PWDA proposes that rather than the ARA continually making exemption applications its members should seek to comply with the prescriptive (deemed-to-satisfy) requirements of the Transport Standards and Premises Standards wherever possible. Where this is not possible PWDA proposes that ARA members should develop approaches to provide Equivalent access, including the use of direct