BIC Submission to the Reform of the Disability Standards for Accessible Public Transport – Phase 1

BIC provided responses to 100-plus questions in the following reform areas of the Transport Standards:
  • Staff Training and Communication
  • Mobility Aid Safety
  • Priority Seating
  • Allocated Spaces in Transit
  • Digital Information Screens
  • Website Accessibility
  • Communication during Service Disruption
  • Assistance Animal Toileting Facilities
  • Emergency Egress
  • Fit for Purpose Accessways
  • Wayfinding
  • Tactile Ground Surface Indicators
  • Provision of information in multiple forms.
The BIC also provided an over-arching executive statement. The Australian bus and coach sectors are one of the most highly regulated in the heavy vehicle industry. Generally, this regulation occurs via state-based transport legislation and operational contracts. As all route, and the vast majority of school and replacement bus operations are in one form or another contracted by the respective state governments, there are specific contract requirements that operators must comply with and hence some of the responses provided in the following are limited due to these existing contractual arrangements. For example:
  • the majority of new buses are purchased under government procurement contracts or contracts developed by large corporations and DDA compliance is part of that procurement process. Therefore, individual bus operators have limited control over bus specifications
  • most state jurisdictions either operate or are creating, centralised passenger information systems therefore, individual bus operators are just users of such systems and hence have limited control over the specifications of any such systems.
As all route, and the vast majority of school and replacement bus operations are in one form or another contracted by the respective state governments, the BAN believes that any proposed changes or additions to the DDA need to first recognise exiting state-based operational contract requirements in order to avoid duplicating existing requirements or introducing new requirements for the same subject matter. As an example, the RIS chapter 4 sets out proposed DDA additions in relation to staff training and communication, and as detailed in our response to this chapter, there are existing and detailed staff training and communication requirements at a state operational level and the existence of these need to be both recognised and considered. The BIC is active on the NATT Working Groups, and the subject matter contained within a number of the chapters in the RIS have been reviewed by these Working Groups. In these instances, the BIC has offered detailed response to the RIS questions that align with what has already been agreed via the Working Group processes.

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