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Technical Review Recommendations for the Draft Disability Standards for Accessible Transport - August 2002

Regulation Impact Statement

Publication date: August 2002

Author: The Allen Consulting Group Pty Ltd

Executive Summary

In April 1999, the Australian Transport Council (ATC) considered a Regulation Impact Statement (RIS) on the draft Disability Standards for Accessible Public Transport (the “Standards”). At this meeting, Ministers agreed to finalise the Standards following some minor recommended alterations.

The Commonwealth Government also agreed to temporarily exclude from the Standards several unresolved technical issues as identified in the RIS pending further investigation to ensure a practical solution for each identified area. The Department of Transport and Regional Services (DOTARS) was tasked with undertaking a Technical Review of the Standards. In the course of the review a number of other technical issues were identified and re-examined. A draft report of the Technical Review has been completed and was released for public comment on 27 May 2002. The objective of this RIS is to assess the recommendations of the Technical Review.

In the scheme of things, the issues raised in the 1999 RIS that were considered by the Technical Review were of a minor technical nature. In the main, concerns related to the need to adapt requirements in the Standards based on Australian Standards that were designed for buildings to public transport conveyances. In most cases, there was a need for relatively minor changes to adapt the standards so that they could be practically applied in a transport context. Against this background, this RIS could be seen as an addendum to the more comprehensive 1999 RIS and it should be read in conjunction with the earlier RIS and the Technical Review report in order to put it in its broader context. This is particularly relevant to the assessment of costs and benefits in this RIS, which is based on the technical changes to the original standards.

Given that the Standards have already been formulated, it is appropriate that the recommendations of the Technical Review be assessed against the original Standards on which the 1999 RIS was conducted rather than the current situation in which disability standards are not in place. In terms of the assessment of costs and benefits, this means that a recommendation that makes the Standards less stringent would reduce the cost of complying with the Standards and hence be recorded as a benefit. On the other hand, if a change reduced the accessibility to transport for people with disabilities, this would be recorded as a cost.

An assessment of implementing the Standards under circumstances where no standards exist was the subject of the 1999 RIS and, even then, the impact of all the Standards as a package was assessed rather than a detailed assessment of the impact of introducing individual standards. To assess the impact of each clause considered in the Technical Review against the ‘no Standards’ case would require a detailed and costly study that would be out of proportion with the magnitude of the Technical Review’s recommendations relative to the full Disability Standards for Accessible Public Transport. Indeed, such an approach would require a level of assessment that was not even carried out in the original 1999 RIS.

It is difficult to assess the net benefits of policy change when some impacts can be quantified and others cannot. That aside, a rudimentary quantification of impacts has been undertaken where possible to give an indication of the order of magnitude of impact. In these instances, a conservative approach has been taken to estimating cost savings to avoid the risk of overestimation. On this basis, it was estimated that implementing the recommendations of the Technical Review would reduce compliance costs by a minimum of around $60 million. While this estimate is indicative only, it provides a ballpark indication of the potential scale of the benefits of implementing the recommendations of the Technical Review. For example, in its submission to the draft RIS, Queensland Transport stated that it was, “generally supportive of the assumptions and the cost estimates outlined in the RIS document and endorse the potential benefits contained therein”.  However, it is still arguable that this is an underestimate of the potential cost savings arising from the recommendations of the Technical Review.

It is not possible to quantify the impact of the proposed changes on the accessibility to transport for people with disabilities. In these circumstances, only a qualitative assessment of the impact is possible. In most cases, it was assessed that the proposed changes would have a negligible, if any, impact on accessibility. In a few cases, where the likely impact was greater, only a relatively small number of people with disabilities would potentially be affected...