LOCAL GOVERNMENT NSW

Our ref: R94/0186  Out- 21431
Further contact: Margaret  Kay or Richard Connors

26 April 2013

Disabilities Transport Access Secretariat
Transport Access Section
Road Safety and Transport Access Branch Department of Infrastructure  and Transport GPO Box 594
CANBERRA   ACT  2601

Dear Secretariat

2012 Review of the Disability Standards for Accessible Public Transport 2002 (Transport
Standards)

Local Government NSW (LGNSW) welcomes the opportunity to provide a response to the
2012 Review of the Disability Standards for Accessible Public Transport 2002 (Transport
Standards) Issues Paper.

Local Government NSW is the peak body for NSW Local Government,  representing  all the 152
NSW general-purpose councils, the special-purpose  county councils and the NSW Aboriginal Land Council. Local Government NSW is a credible, professional organisation representing Local Government and facilitating the development of an effective community-based  system of Local Government in NSW. (LGNSW's predecessors were the Local Government and Shires Associations of NSW.)

Our response to the Issues Paper is framed by the following resolution from the 2011 NSW Local Government Association conference:

That the Local Government Association calls upon the Australian Government to provide funding and resourcein order to modify existing and/or establish new infrastructure  to assist local councils with their obligations under the Disability Discrimination Act to comply with the Disability Standards for Accessible Public Transport requirements so that the necessary infrastructure can be transformed to me the required standards.

As Local Government in NSW is required to comply with the standards in the provision of accessible bus stops and taxi infrastructure, our response will address the questions in Section A of the paper- questions for operators, providers and their representative organisations.

1.  Have you been able to meet the 2007 Transport Standards legislated targets?  If not, can you elaborate on the reasons for not being able to meet these targets?

2.   Have you been able to meet the 2012 Transport Standards legislated targets?  If not, can you elaborate on the reasons for not being able to meet these targets?

LOCAL GOVERNMENT NSW
GPO BOX 7003 SYDNEY NSW 2001
L8, 28 MARGARET ST SYDNEY NSW 2000
T 02 9242 4000  F 02 9242 4111
LGNSW.ORG.AU LGNSW@LGNSW.ORG.AU
ABN 49 853 913 882

LGNSW has no definitive data on the number of bus stops across NSW which have been modified to meet the 2007 or 2012 standards. In order to develop an evidence base by which
to understand the extent of compliance, we would support a nationally coordinated collection of data. This would establish an overall picture of the size of the infrastructure task facing Local Government, its progress in the implementation of the Transport Standards, and the sector's ability to adequately fund these requirements.

Sources independent from Local Government, including the NSW Bus and Coach Association, have given some sense of the scale of the accessible infrastructure issue in NSW. For example there are approximately 7,200 regular bus routes in greater metropolitan Sydney, and possibly another 1,000 routes in rural and regional areas of NSW. Within these routes there are over
37,200 individual bus stops in Sydney alone, and estimates of another 10,000 bus stops outside
of Sydney. It is also worth noting that these estimates exclude the hail and ride stops which are common especially in rural and regional areas of NSW.

These numbers, while indicative only, illustrate the scale of the infrastructure issue facing councils in NSW.

3.  Are there requirements that have proven to be impractical or difficult to implement? If
so, please specify.

LGNSW is concerned that the introduction of the Transport Standards was not accompanied with any additional resources for implementation, nor was there a process to allow the full impact or cost-shifting implications on Local Government to be fully assessed.  The scale and cost of implemen.tation of the accessible transport standards may be beyond the capability of Local Government.

Councils in NSW already face a massive task in funding and maintaining existing assets. The ongoing sustainability of funding streams to support infrastructure commitments is a priority for Local Government. Research conducted for the 2006 Local Government Inquiry in NSW suggest that  councils in  NSW face  an infrastructure renewal backlog of $6.3 billion,  and  an annual renewal gap of $600 million, mainly to address the problem of roads and transport related infrastructure reaching the end of their economic life and replacement and maintenance being beyond their capacity. (Source: Independent Inquiry into the Financial Sustainability of NSW Local Government, 2006).  This funding gap has been confirmed by a recently released NSW Treasury Corporation (TCorp) report on the assessment of the financial sustainability of NSW councils, which shows that the infrastructure backlog had grown to $7.2 million as at 2012.

The   2007   Review   of   the   Disability   Standards  for  Accessible   Public   Transport  2002 recommended that Commonwealth, State and Territory governments provide funding for projects in regional and rural regions where Local Governments are unable to resource upgrades of public transport infrastructure (Recommendation 7).    LGNSW notes that the Australian Government's response to this recommendation was essentially that the provision of funding is a matter for each state government to consider. We suggest that, until there is a commitment from the NSW and Australian governments to adequately resource Local Government to address the infrastructure burden of the Standards, it is unlikely that the targets will be met.

Under the 2006 Inter-Governmental Agreement (IGA) with the Federal Government on cost shifting, an agreement was reached that Local Government would be compensated for any additional work it has to perform on behalf of, or to meet the requirements of other levels of government.  The  2013  Inter-Governmental Agreement  (IGA)·  with  the  NSW  Government contains a similar clause. The introduction of the Transport Standards in 2002 was not accompanied with any additional resources to implement the requirements in the legislation, nor was there a process to allow the full impact on Local Government to be fully assessed.

4.   Can you provide detail on any initiatives and action you have undertaken, not currently detailed under the Transport Standards or other legislative requirements,  in relation to removing discrimination against people with disabilities?

Local  Government  in  NSW  actively plans  for  the  provision  of  accessible  infrastructure,  for example within their comprehensive accessibility and/or pedestrian and mobility planning frameworks. The Integrated Planning and Reporting framework allows for the inclusion of accessible infrastructure and related issues in the context of councils' overall strategic planning and asset management systems.

The Standards establish specific requirements for access to transport serVices such as establishing the space allocation requirements for wheelchairs on buses and trains, lift and ramp access at railway stations and bus/rail interchanges, and access to transport service information. In addition to these responsibilities passengers must also have the capacity to use a mass transit system.   This  is  where  Local  Government plays  a  major  role  integrating  accessible  public transport   services  with   the   provision  of  accessible   bus  stops,  footpaths   and   kerbside infrastructure to create accessible and liveable communities.  Without appropriate funding to address the compliance targets supporting the Transport Standards, councils may be unable to resource the required works in the target timeframes.

Thank you for the opportunity to comment on the issues paper. Should you require further information on our response, please contact Richard Connors, Senior Policy Officer Roads and Transport on 9242 4073 or Richard.connors@lgnsw.org.au.

Yours sincerely

Noel
Director - Policy