Submission to the Department of Infrastructure, Transport Regional Development, Communications, Sport & the Arts
20 November 2025
Public transport provides an essential connection for people with disability to education, work, healthcare, essential services and the community. The Disability Standards for Accessible Public Transport 2002 (Transport Standards) were introduced to provide certainty to operators and providers of public transport services about their responsibilities under the Disability Discrimination Act 1992.
In the 23 years since, public transport technology and usage has changed, so the standards need updating. Of the 5 identified reform areas, based on the expertise available to us, PWDA contributed to three working groups: Removable Gangways (reform area 42), Point-to-point Transport (reform area 3), and Reporting (reform area 1). Our peer Disability Representative Organisations (DROs) contributed to the other 2 areas: Braille (reform areas 15 and 16), Hearing augmentation (reform areas 9 and 10).
Transport systems, their infrastructure and interdependencies are complex and technical. This work required many hours of reading, detailed engagement, discussion, reflection, and at times compromise. PWDA would like to acknowledge the hard work, dedication and commitment of people with disability who shared their lived experience of accessing public transport, and their recommendations for changes that would improve accessibility for everyone.
We support the work done at parts 1-31 of the Draft – Disability Standards for Accessible Public Transport Guidelines 2025 to articulate how the standards should be applied. Where problems arise is when the obligation to comply is limited, optional or pushed to the distant future. The evidence over 23 years is that making transport accessibility requirements optional, or providing excuses for non-compliance, entrenches the exclusion of people with disability.
Recommendations
Based on our evaluation of reforms, and our experience of the co-design process involved in the Disability Aviation Standards we make the following recommendations
- Recommendation 1 – Accelerate straightforward changes
- Recommendation 2 – Regulate identified safety issues rather than making them optional
- Recommendation 3 – Co-design solutions with people with disability
- Recommendation 4 – Regulate and audit identified issues to achieve compliance
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