From: John Moxon 
Sent: Friday, 9 September 2005 8:33 AM
To: disabdis
Subject: ARA Transport Standards Exemption Application

Attachments: john.vcf

I would like to lodge opposition to the ARA application for an exemption from the DDA Accessible Transport Standards for the following reasons:

1.    The application does not set out how, at the expiry of the 
exemption, rail services will be in a better position to provide access for people with disability.  In fact the application makes it clear that the objective is to limit the level of access provided.

2.    If any provider is having difficulty meeting the Standards it can 
develop alternative solutions or can utilise the defence of unjustifiable hardship.

3.    The recommended changes are vast, complex and far reaching, affect 
all modes of transport and have not been considered by representatives of other transport modes (bus, taxi, etc), nor by people with disability.  There are many issues that will need careful examination.  
The appropriate time to do this is when the Standards are reviewed after five years of operation, as legislated.

4.   Codifying the guidelines (totally or in part) reduces the ability 
of providers to be innovative in their access solutions.

5.   Some of the recommended changes would create an unsafe environment 
(narrower boarding ramps, for example).

6.   This seems to be no more than a cynical exercise in avoiding 
responsibility.

Regards

John Moxon