Submission to Transport for NSW on the Disability Action Plan

CPSA's submission about the draft Disability Action Plan offering recommendations on how to make NSW's transport system more accessible for everyone, particularly older people and people with disability.

Download: Submission to Transport for NSW on the Disability Action Plan [Adobe Acrobat PDF - 436.55 KB]


Combined Pensioners and Superannuants Association of NSW Inc (CPSA) was founded in 1931 in response to pension cuts. CPSA is a non-profit, non-party-political membership association serving the interests of pensioners of all ages, superannuants and low-income retirees.

CPSA has 139 Branches and affiliated organisations with a combined membership of over 29,000 throughout NSW. CPSA serves the interests of its membership and broader constituency at the local, state and federal levels.

CPSA welcomes the opportunity to comment on the Disability Action Plan (DAP). The availability, accessibility and affordability of public transport are of major concern to our members and wider constituency.

An accessible, well integrated public transport system is a cornerstone for ensuring the social, physical and economic well-being of everyone in NSW.

In spite of this fundamental role played by transport, many people are unable to access and use the type of transport services that meet their needs. This is commonly referred to as transport disadvantage. Transport disadvantage is most keenly felt in rural and regional NSW as well as Sydney’s outer metropolitan areas. Particular groups, hopwever, are likely to experience this even in more populated and urbanised locations notably older people, people with disability and people with medical conditions.

Transport disadvantage can arise from

-          limited or no availability of public transport options;

-          reliance on expensive private transport because of poor or no public transport options;

-          unaffordable transport options,

-          transport services and/or infrastructure not being accessible to people with disability or other mobility impairments; and/or

-          a lack of access to private transport.

CPSA welcomes the specific reference in the DAP to ageing and the specific needs of older people with respect to transport accessibility and in particular the need for whole of journey accessibility and seamless transfers between modes of transport.

Public Transport in Urban Areas

Reforms to bus services in particular and public transport services generally have increasingly prioritised commuter services – peak hour services on weekdays directed to the Central Business District – at the expense of non-peak hour services and those that travel through residential areas. Bus services have been cut or modified in order to accommodate commuter-oriented transport, with the re-routing of buses along more major thoroughfares and the reduction in the number of bus stops across a number of areas in Sydney and other major population hubs. Similarly, train services are relatively irregular in off-peak periods and with only 22 per cent of City Rail stations deemed fully accessible, meeting the Disability Standards for Accessible Public Transport (2002), makes public transport travel impossible for many people with disability.

Apart from a reduction in bus stops and greater walking distances required to get to bus stops, there are a number of other concerns around infrastructure and accessibility. While improvements have been made with an increasing number of accessible train stations, still only 42.7 per cent of City Rail stations are deemed as ‘Easy Access’ (accessible for wheelchairs but not necessarily people with other disabilities). Other access issues include:

-          Few low-floor accessible buses in non-metropolitan areas;

-          Some routes having accessible services in one direction, but none on return journeys;

-          Some routes offering  only one accessible vehicle in the morning and one in the afternoon, limiting flexibility for passengers;

-          When accessible bus services break down they are often replaced by non-accessible buses;

-          Non-compliant bus stops and train stations prevent passengers with mobility impairments from using accessible services;

-          Stops that comply with access standards are not actually accessible– due to tree obstructions preventing buses from being able to come up to the curb, for example;

-          In many rural and regional areas, bus stops are on unsealed roads;

-          The height of bus stop platforms in rural and regional areas is inconsistent making it difficult to use bus ramps properly;

-          One section of a trip being accessible but the other not;

-          A lack of adequate information, particularly about routes and times of accessible services: the level of language used is often too complex for passengers, particularly those with limited English or intellectual disabilities;

-          Services that have been made more accessible for one disability may be at the detriment of another disability (for example, new trains have more space for wheelchair access but their quiet doors are to the detriment of visually impaired travellers). Similarly, new accessible red bus metro services are wheelchair accessible but the higher placement of stop buttons proves difficult for those with balance issues.

CPSA appreciates the recognition of many of these issues in the DAP. Yet many of the accessibility shortcomings identified in the DAP do not include a detailed outline of how these will be rectified. Acknowledging problems without positive steps to solve them does not add value to the transport system, particularly for people with mobility impairments.

CPSA condemns any proposal to reduce numbers of guards on trains, especially due to the negative impact on

-        Assisting people with disability on and off trains at unstaffed stations;

-        Safety to passengers (boarding and alighting) due to door closures;

-        Security (especially at night).

Recommendation 1:

Prototypes for new modes of transport, such as for bus fleets and train carriages undergo on-road testing, complete with passenger feedback, before full procurement.

Recommendation 2:

A system be introduced that enables an easy alert system to users advising them of breakdowns of accessibility measures, for example lift and escalator maintenance and breakdowns.

Recommendation 3:

Bus stops deemed compliant with access standards be regularly monitored in conjunction with local councils to ensure that they remain accessible.

Rural and regional areas

CPSA welcomes the commitment to improving the access to transport for people with disabilities and older people in rural areas. In particular, the continued employment of regional transport liaison officers in regional NSW to reduce the negative effects of transport disadvantage appears to be a step in the right direction. However, the specifics of what these positions will entail and how they will go about achieving this objective is not adequately outlined in the DAP.

Many people travelling to, from and between rural and regional areas rely on CountryLink services. However, many older people and people with disability find CountryLink services have declined.

Coach services have replaced a number of train services. Although coaches used by CountryLink exceed current Disability Standards for public transport benchmarks, (as most coaches have two wheelchair spaces), travelling by coach is considerably more difficult for people with mobility impairments or medical conditions as they are unable to move around as freely as they would be able to on a train. Passengers are also prohibited from eating or drinking on coaches and have limited or no access to on-board toilets. This can pose problems for people with medical conditions, such as diabetes. In addition, limited assistance is provided on board and when boarding or alighting. This not only applies to people who use wheelchairs but also those who use other mobility aids such as walkers, walking frames and sticks.

Services provided by CountryLink across NSW are quite limited in frequency and are poorly scheduled.  CountryLink services have a poor on-time running record. Since 2002, services have only met CountryLink’s on-time running record 37 per cent of the time. 

People travelling from rural and regional areas to Sydney for medical and other appointments typically find CountryLink services their only travel option. However, because of inconvenient timetabling, passengers must stay overnight in Sydney unnecessarily. Unnecessary overnight stays because of infrequent services as well as long travel times have a substantial financial impact on individuals because of the need to pay for accommodation. People travelling for health-related purposes may be eligible for reimbursement for some of their travel and accommodation costs through the Isolated Patients Travel and Accommodation Assistance Scheme (IPTAAS).However, the reimbursement under this scheme is small.

Apart from ‘on board’ issues, similar access difficulties as those identified in public bus services are present in CountryLink coach services. Walkways and footpaths to accessible bus stops are sometimes obstructed or footpaths damaged, and facilities at bus stops, such as toilets and cafeterias, are not always wheelchair accessible or open at night time.

Additional barriers within some rural areas include the fact that often the only means of transport into town is a school bus, which does not run during the school holiday breaks. CPSA would like to see buses be available on all business days throughout the year.

Recommendation 4:

Investment in CountryLink services needs to be increased. CountryLink is a vital means of transport for many living in rural and regional areas. Improving services will also make CountryLink an attractive means of travelling around NSW.

Community Transport

When considering improvements to the current public transport network it is important to also consider the role of community transport in meeting the transportation needs of older people and people with disability.

Community transport services are already stretched and unmet need is evident across the state. Meanwhile demand is increasing particularly due to population ageing and increasing complex needs. A continuing rationing of services is unsustainable. CPSA notes and has welcomed the additional $12million in funding over four years of a more flexible Community Transport Program. However, this funding needs to become recurrent beyond the initial four-year period. Furthermore, given the social, health and economic benefits of providing services to those who are unable to access mainstream public transport, cannot afford or cannot use private transport or who have no or limited public transport options in their vicinity, additional funding – particularly directed to NSW Health for non-emergency health-related transport – will be necessary with an ageing population and a growing population with more people with complex needs.

Given the fact that community transport is increasingly relied on to bridge the gap between demand and accessible public transport availability it is concerning that community transport vehicles are not required to be accessible unless they are providing services to the general public. This does not match up with the stipulation in the NSW HACC Community Transport Guidelines that it is not acceptable to refuse service based on the unavailability of an accessible vehicle. Community transport users are more likely to have mobility impairments when compared with the wider population of NSW so it is crucial that community transport vehicles are accessible and that community transport organisations are adequately funded to allow them to do so.

It should also be noted that the Community Transport Organisation and other organisations with an interest in community transport services have been calling for community transport to be included within the Passenger Transport Act. This will allow for a more cohesive approach with other transport methods and ensure that it can be adequately regulated. CPSA believes that this warrants serious consideration given the community’s need for a greater number of community transport services, a better integration of those services with mainstream public transport services as well as service types that fit in between both the community transport and public transport modes.

Recommendation 5:

Significant additional funding should be provided to Community Transport so that those who require such services find access timely, appropriate and affordable.

Recommendation 6:

Additional funding should be provided for non-emergency health related transport so that community transport services are better able to meet the needs of their client groups. Funding should also be sufficient to ensure that all newly purchased community transport vehicles are accessible.

Recommendation 7:

The NSW Government should investigate the inclusion of community transport within the Passenger Transport Act.

Demand Responsive Transport (DRT)

Currently, Sydney’s transport system is made up of a large public transport network of mainstream services – heavy rail, buses, ferries and a light rail service – supplemented by Community Transport initiatives specifically targeted towards certain demographics. As discussed above, community transport is a specialised service, which is only able to provide limited services. It also invariably comes at a considerably higher cost to the patron than would a mainstream service, generally $5 to $10 a return trip, more if the distance is further.

In between mainstream public transport services and community transport, there is a wide gap of unmet need. As alluded to earlier, with the streamlining of public transport services, this gap will only increase as community transport in its current form cannot meet additional demand. Unmet need exists as a result of the limited services provided by community transport and because people do not qualify for community transport. The Western Sydney Community Forum has termed this gap as the “360 metre gap”. This gap, which often turns out to be much bigger, refers to those who cannot access community transport “but find the distance to the nearest bus stop too difficult and are left without access to a service able to meet their needs”.[1]

With the streamlining of public transport services, “there has been an outcry from many older people who … (feel) this as social exclusion because their bus routes have changed and they can no longer access the services they once enjoyed”.[2] The public transport framework must therefore be flexible to meet the needs of various groups. Such solutions must be well-integrated with current services and must be flexible to ensure that they take into account demographic changes over time and are able to change, grow or contract as demand changes.

CPSA believes that the NSW Government should investigate a number of DRT options with key stakeholders such as the Community Transport Organisation, community transport providers and other transport providers as well as Local Governments and community organisations. DRT has the ability to significantly reduce the ‘360m gap’, ensuring everybody has access to appropriate transport services. A further advantage of introducing well integrated, designed and comprehensive DRT services is that community transport is relieved of much of its demand. Community transport providers would therefore be able to focus on maintaining and improving the independence of those who most need community transport.

DRT services are becoming commonplace around Europe and are also being utilised in other parts of the world. They can offer a combination of fixed route and demand responsive services, enabling passengers to be picked up and dropped off anywhere along or within the bus route or zone.  This has acute benefits for people, who are currently prohibited from taking buses due to the walking distances required from the stop to their home, for example.  A number of Dial-A-Ride services have been established in other states of Australia, including South Australia with RoamZone operating in six locations in metropolitan Adelaide and Melbourne with the Telebus network servicing five suburbs in the city’s east. Melbourne’s Telebus network offers a very comprehensive approach to integrating DRT into the public transport network and deserves close consideration.

Recommendation 8:

Transport for NSW investigate with key stakeholders Demand Responsive Transport programs designed to complement traditional forms of public transport and help relieve the strain placed on community transport services.

Barriers to Whole of Journey Accessibility

As noted in the DAP, people use multiple transport modes for their journey. As a result, a barrier at one mode can compromise the entire trip.

This goes beyond merely various timetables not matching up, resulting in a journey taking much longer than necessary. All modes of transport, including footpaths and roads, must be accessible.  User friendly transport is particularly important for older people, people with disabilities and their carers as it provides opportunities to engage with local communities. Commonly cited problems that deter older people or those with mobility issues from walking include uneven and/or narrow footpaths, inadequate lighting, inadequate shade and rest areas, inconvenient crossing locations, short pedestrian cycles at signal-controlled crossings and safety fears.

In NSW many neighbourhoods have been built without taking the diverse needs of older people and those with mobility difficulties into account. Statistics on pedestrian fatalities provide a bleak example of the consequences: while people aged 70 years and over represent 10 per cent of NSW residents, they account for one third of pedestrian fatalities.[3] Traffic light walk times need to be increased to allow for people who cannot cross quickly to make it safely across the street.

There is also a need for clear language on signs and voice-over announcements, particularly when a journey is disrupted or an alternative route is required to be taken.

Making cities and communities age-friendly is one of the most effective policy approaches for responding to demographic ageing. This involves working with older people to ensure that services are conveniently located and accessible and ensuring that footpaths, roads, buildings and other public spaces are easy to navigate. CPSA welcomes the strategies involving working with Local Governments outlined in the Plan. Yet CPSA would like to see more specific outlines about how this collaboration will take place.

There is a need to ensure the linking of accessible transport services to accessible locations, such as shopping centres and railway stations. Currently, there are situations where, particularly during track work, rail commuters are required to alight from the train at an inaccessible station and climb stairs to transfer to a bus. There is a lack of cohesion between modes and a policy of seamless travel should be adopted to ensure that all modes have accessibility integrated into all areas, and not be included as merely a separate policy. A seamless travel policy should include not only accessible vehicles and departure points but also accessible ticketing and ticket validation points as well as a barrier free pedestrian environment in order to remove current barriers to participation.

Recommendation 9:

When disruptions to travel occur, changes should be clearly outlined in simple language and necessary assistance given.

Recommendation 10:

When buses are required to replace trains due to breakdowns or track work, an accessible station as well as accessible buses should be used.

Disability Action Plan Review Periods

CPSA is concerned about the lack of detail and timeframes outlined in the Plan. While the DAP covers a period of five years from 2012 – 2017, the next review of the Disability Standards for Accessible Public Transport will be occurring sooner and it would be beneficial to tie the two reviews together. In fact, CPSA calls for a review period of one year for the DAP to ensure that it is on track and to outline the next steps to take place.

CPSA is concerned by the vague nature of many of the action items outlined in the plan and would like to see a more detailed outline of particular action items and how they will be tackled and funded.

Recommendation 11:

Annual public reporting on the progress of the DAP objectives take place.

Private Contracts

CPSA does not support the public-private partnership (PPP) model for delivering transport infrastructure or services. In transport, PPPs have led to perverse and negative policy outcomes.

CPSA is concerned that the Disability Action Plan will not apply to private contractors. While CPSA understands that contracts require compliance with the Transport Standards and to prepare a disability access plan themselves, this seems counter-productive. Given the extensive work that has gone into Transport for NSW’s Disability Action Plan it seems inefficient to require bus companies to compose yet another plan. This is particularly the case with small operators; approximately 50 per cent of rural and regional bus companies with commercial contracts have less than ten vehicles and to require them to be compile an extensive disability action plan may create ‘unjustifiable hardship’ and therefore not lead to accessible outcomes for transport users.

Recommendation 12:

Private bus operators and other contractors have it stipulated in their contacts that they must adhere to the aspects of Transport for NSW Disability Action Plan that apply to their service.

Taxi Services

It is disappointing that response time data for wheelchair accessible taxis is not available for areas outside of the Sydney, Newcastle, Wollongong and Central Coast areas. It is particularly problematic that compliance with the Standard are not met in these areas, where wheelchair accessible taxis are more widely available than in rural and regional areas. While CPSA notes the interest free loans available to country taxi operators to assist with the purchase of wheelchair accessible taxis, the disincentives for drivers to operate such taxis are not adequately addressed. Drivers are often reluctant to take passengers who require additional assistance in getting in and out of the vehicle due to the lack of revenue they receive while doing so as the metre is not running and the time taken to do so. The level of assistance given to passengers with limited mobility varies extensively between drivers, with some offering to support people with door-to-door assistance while others are reluctant to provide assistance when asked to allow passengers to enter and exit the vehicle.

Recommendation 13:

Mandatory driver training for all taxi drivers (not just those driving wheelchair accessible taxis) on disability awareness and how to appropriately and safely assist people when required. Penalties should be introduced for taxi drivers that do not act appropriately.

Taxi Transport Subsidy Scheme (TTSS)

CPSA’s Members and constituents place high importance on the value of the state’s public transport services. Access to the $2.50 excursion and other concession tickets by pensioners and seniors helps ensure public transport is affordable. Unfortunately, however, concessional fares are of little value to the many people who are eligible but unable to access services. 

The amount that the TTSS provides approved participants with per trip (half the fare to a maximum subsidy of $30) is to the disadvantage of people in rural, regional and outer metropolitan areas. People with disability and limited mobility not only find it more difficult to access taxi services in the first place, the length of trips to access essential services means that they are more likely to exceed the $60 cap per journey. They are also less likely to have other accessible transport options, including public and community transport, available to them. This creates social isolation and prevents people from being able to maintain their independence if required to rely on family members of friends to get around, if that in fact is an option.

Recommendation 14:

Taxi subsidies be set as a means-tested progressive percentage of the fare, with the cap being lifted for people living in rural, remote and outer metropolitan areas.

CPSA has been made aware of taxi drivers abusing the Taxi Transport Subsidy Scheme, charging users more than the metred fare and telling passengers that as their fare is subsidised they must agree to the inflated price. CPSA members have reported feeling intimidated and unable to dispute the amount added to their fare.

Recommendation 15:

Adequate checks to be put in place to ensure that taxi drivers are unable to charge users more than the metered fare or abuse the TTSS system.

Customer Service

CPSA welcomes the increased involvement of older people and people with disabilities in consultation about the barriers to transport they face. CPSA maintains that it is extremely important that the transport system looks to address the needs of individual people and their requirements rather than merely the structure of the transport network.

Public transport staff and their receptiveness to responding to the needs of older people and people with disability is of crucial importance to maintaining accessibility and travel experience of public transport for many users. This is particularly important given that the infrastructure currently provided in many areas requires people with disability to rely on staff in order to be able to access public transport.

It is disappointing that the limits of current physical infrastructure and information provision means that transport in many areas across the state is not independently accessible for many people. CPSA looks forward to a time when commuters with mobility impairments are able to travel independently without reliance on travel staff. Until such time that infrastructure is sufficiently upgraded to ensure independently accessible transport for most people, the human element provides too many opportunities for failure as noted in the Plan.

Sufficient relevant staff training in dealing with and meeting the needs of travellers with mobility issues is important and monitoring of staff dealings with individuals is also fundamental in ensuring training effectiveness.  CPSA welcomes the idea of mystery travellers to monitor this as well as satisfaction questionnaires enabling people to specify if they have a disability for data collection.  CPSA is however concerned that the indicator used for disability and age awareness training outlined in the DAP is merely number of staff who receive the training. This does not take into account whether staff take the training on board. Looking at the experiences of customers is more appropriate at being reflective of the effectiveness of the training.

Recommendation 16:

Effectiveness of staff training in improving the travel experience of older people and people with disabilities be examined, not just the number of people who undertake the training.

Travel Training

CPSA welcomes pilot travel training programs for people with recently acquired spinal cord injuries and older people who are no longer able to drive. Older people who have recently given up driving are often new public transport users and may have difficulty navigating the complex system.  Bus routes and timetabling can be daunting for people unfamiliar with the system and providing people with the basic skills required to use the public transport system in their local area instils confidence and allows people to remain independent and active once they have relinquished their driver’s license. Community Transport already has travel trainers in place and so their experience and expertise should be drawn upon.

Recommendation 17:

Transport for NSW works together with Community Transport for insight into best practice around travel training

Utilisation of new technology for access improvements

CPSA welcomes the integration of new technology to assist transport users in gaining accessible information. This has proven particularly useful for people with vision impairment, with the internet and smart phones facilitating much of this. However, people without access to the internet should not be excluded and basic tech options should still be made available. For example, large print timetabling and signage should be provided for people with low vision.

Recommendation 18:

New technologies that assist accessibility should be embraced but not at the expense of low tech options.

[1] Worrall, H. 2009. Discussion Paper: The problem of the ‘360m gap’, Western Sydney Community Forum.

[2] ibid.

[3] Roads and Maritime Services, Vulnerable Pedestrians, URL: (Accessed 24 April 2012).