People With Disabilities ACT acknowledges the Ngunnawal People as the traditional owners of the land on which we work.

Copyright December 2015 People With Disabilities ACT Inc

This publication is copyright. Apart from use by those agencies for which it has been produced, not-for-profit associations and groups have permission to reproduce parts of this publication as long as the original meaning is retained and proper credit is given to People With Disabilities ACT. All other individuals and agencies seeking to reproduce material from this publication should obtain the permission of the Executive officer of People With Disabilities ACT.


Contact persons:

Robert Altamore

Executive Officer| PWD ACT |

Phone: 6286 4223

Craig Wallace

Access Campaign Manager



People With Disabilities ACT Inc. (PWD ACT Inc.) is a not for profit consumer run systemic advocacy organisation which represents the interests of people with disabilities in the ACT.   PWD ACT Inc. works to improve access to all amenities and to all forms of information and activities of the community. PWD ACT Inc. is a peak body which seeks to inform the community about disability issues. PWD ACT advocates from a human rights perspective and acknowledges the UN Convention on the Rights of People With Disabilities. The text of this Convention can be found at:

Articles 9, 19 and 20 of this Convention are especially relevant to this submission.

Craig Wallace and I were pleased to meet with Richard Watson and Brett Wildsmith of the Implementation Team on Tuesday 15 December. This submission reflects our discussions of the draft regulations.

Taxi Services – Minimum Service Standards

These Standards contain no reference to complaints handling and lost property. Even if these Standards are included in the Standards for Booking Systems, we think it would be useful both for drivers and passengers to have them reiterated in the Standards for Taxi Services.

These Standards also contain no references to the obligations of taxi operators and drivers with respect to assistance animals and especially dog guides under ACT and Commonwealth Disability Discrimination Laws. Given the high number of incidents reported both anecdotally and formally to discrimination law services and advocacy organisations of refusals of drivers to take passengers with dog guides or other assistance animals the Regulations should cross reference the obligations of operators and drivers to comply with this aspect of discrimination laws.

Independent Taxi Approval – Minimum Service Standards

The comments in relation to dog guides and assistive animals also apply to these Standards.

Hire Cars – Minimum Service Standards

The comments in relation to dog guides and assistive animals also apply to these Standards.

Ride Share Services – Minimum Service Standards

These Standards do not contain provisions relating to complaints handling and lost property. The explanation offered at the meeting is that these matters are dealt with in the Regulations relating to transport booking systems. On consideration PWD ACT does not see this as satisfactory. If the Standards for taxis and hire cars include these matters when they are also covered by the standards for bookings systems then the principles of equality of regulation burden would suggest that they should also be included in the ride share standards.

Standards relating to dog guides and assistive animals need to be included in the Ride Share Standards for the reasons given in our comments on this matter in the context of the Standards for taxis and hire cars.

WATS Services – Minim Service Standards

In the final paragraph of these regulations there is a reference to ‘restraining’ the Wheelchair and the passenger. In this context the use of the word ‘restraint’ is inappropriate. ‘Restraint’ is all too often used to infringe the human rights of people with disabilities in appropriate manners such as the restraint of children with autism in schools recently highlighted in a number of articles in the Canberra Times and other media. In this context the correct word to use is ‘secure’’ and the derivatives ‘securing’ and ‘secured.

Transport Booking Services

PWD ACT requests that these Standards mandate that the telephone and computer systems used by Transport Bookings Systems be accessible for all users. At our meeting we drew your attention to the long history of problems for people using the current voice response system operated by Canberra Elite Cabs. This system often breaks down and has a history of being poor at recognising people’s voices even people who have clear speaking voices. The system is especially difficult for people with speech and communication difficulties.

Other Matters

Driver Training

At our meeting we pointed out the advantages of disability awareness training being provided by people with disabilities and offered to assist both the Department and transport providers with this training. To follow this through, we suggest that the implementation team contact providers and potential providers to inform them of PWD ACT’s ability and willingness to assist them in their disability awareness training programs.

WATS Vehicles

At the meeting we mentioned that a major problem with the WATS service in Canberra was the type of vehicle being used to provide the service. The transit vans currently used accommodate the larger wheelchairs and scooters. However, they lack appropriate anchor points and often the person is seated in their chair over the engine. People in wheelchairs find these vans uncomfortable to ride in and many experience feelings of insecurity especially when an unskilled driver is breaking or cornering. In other states, there is a variety of vehicles used and the taragos and the sedans provide a much more comfortable and secure ride for wheelchair users. PWD ACT would like to see a variety of types of vehicles used for WATS services so that people could choose vehicles which provide them with a comfortable and secure ride.


There is a need for continuing discussion on these regulations and other matters raised in our submission. PWD ACT looks forward to these discussions in 2016.

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