The Guide Dog Association of New South Wales and A.C.T. applaud the Commonwealth Government's commitment to protecting the rights of people who have a disability through the enactment of the Disability Discrimination Act 1992.

The major goal of the Guide Dog Association of New South Wales and A.C.T. is to provide mobility training for people who have a vision impairment or who are blind. The Association is the major provider of mobility training programs in New South Wales and A.C.T. One of the services provided by the Association is guide dog mobility training. People with a visual impairment are offered this form of training following a comprehensive assessment of their mobility needs.

The Association employs tertiary qualified Instructors to conduct assessments and training of its clients. Clients are carefully matched with dogs that have been through rigorous selection procedures, at various stages of their development, including Puppywalking and Training. Explicit criteria exist for dog selection and training and procedures are documented as part of the Association's ISO 2000 Quality Assurance System. These practices support our Duty of Care towards clients and protect the public from risk and unnecessary burden.

The Association welcomes the inclusion of Section 9.1(a) and 9.1(d) within the Disability Discrimination Act 1992. Section 9 clearly enshrines in legislation the access rights of people using a guide dog for the purpose of being independently mobile.

Having stated this, the Association has strong reservations concerning Section 9.1(c) and 9.1(f). The person and their guide dog function as a unit. Without the guide dog the person is denied mobility, orientation and access. In short, the guide dog has been trained with the client to alleviate the disability. The same does not necessarily apply to a person with an assistance animal. Such a person may well be able to access locations without being accompanied by their assistance animal. Further, the assistance animals may not be trained to travel and function in the full range of environments envisaged by the DDA.

 In this regard, this Association takes the position that people who claim access under Section 9(f) of the Disability Discrimination Act 1992 should be able to demonstrate a genuine need and also a level of training of the assistance animal comparable to that of guide dogs in order to accompany the person in public places. In order to implement the Act a person's disability needs confirmation as indeed does the training of the assistance animal to alleviate the disability. We would also point out that there are 30 000 Australian's each year who seek medical attention following dog attacks. This statistic alone suggests caution in widening access rights beyond those necessary to enable mobility.

 Therefore, this Association urges the commission to recommend the removal of the reference in section 9 of the DDA to animals other than guide dogs and hearing dogs. 

In the interim, the Association offers its assistance in examining the difficulties in developing criteria and assessment guidelines for the accreditation of assistance animals.