People With Disabilities ACT acknowledges the Ngunnawal People as the traditional owners of the land on which we work.
Copyright April 2015 People With Disabilities ACT Inc
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People With Disabilities ACT Inc, (PWD ACT,) is a not for profit consumer systemic advocacy organisation which represents the interests of people with disabilities in the ACT. Our commitment is to improve access to all amenities and to all forms of information and activities in the ACT community for people with disabilities. PWD ACT also works 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 http://www.hreoc.gov.au/disability_rights/convention.htm
Article 28 of this Convention, ‘Social Security and Living Standards’ is directly relevant to this submission. Articles: 19 Inclusion in Community, 20 Personal Mobility, 23 Home and Family, 25 Health, and 30 Culture and Recreation are also relevant.
PWD ACT does not address each question in the Discussion Paper. We have focussed on the areas of energy and water, motor vehicles and transport as these areas demonstrate most impact on our members.
We point out that people with disabilities in the ACT are disproportionately affected by social and economic disadvantage, have lower incomes than most ACT residents, experience higher rates of unemployment, have poorer health outcomes and lesser opportunities for economic and social participation. In relation to health outcomes we refer to the various reports of the Australian Institute of Health and Welfare’s on health services published since 2010 available from the Institute’s website. In relation to the disproportionate social and economic disadvantage experienced by women with disabilities we refer the Commission to the various submissions to the ACT Government made by Women With Disabilities ACT which are available from their website such as:
While we understand the practical need to target certain social assistance measures, we submit that this must be done within a context which recognises the entrenched economic social and cultural disadvantaged position of people with disabilities and the measures taken must not exacerbate this disadvantage and drive people with disabilities further into poverty and social exclusion. Further concession measures must support current ACT Government policies that promote the inclusion of people with disabilities in the ACT community such as Involve Canberra. We also refer to our submission to the 2016-2017 ACT Budget consultation available from our website http://www.pwdact.org.au/index.php/policyinfo/211-pwd-act-s-2015-16-act-budget-submission
Improving the Equity of Utility Concessions – Energy, Heating and Cooling
Changes to energy concessions must take into account the following realities. The ACT is an inland elevated area and as such has extremes of summer heat and winter cold. Accordingly energy costs in Canberra are high and the high costs of heating and cooling comprise a large proportion of living costs of people on low incomes many of whom are people with disabilities.
In addition, people with some disabilities and health conditions have temperature regulation issues and are more affected by extremes of heat and cold than the general community and incur higher costs in heating and cooling. Examples of people affected in this way are amputees, people with quadriplegia and people with Multiple Sclerosis. In this regard we refer the review to the Budget submission of MS Australia and to the article on this matter on page 12 of the Canberra times of Saturday 25 February 2012.
People with disability are also over-represented in the group of people experiencing long term unemployment and low incomes who need to access public and social housing. Some people live in older housing built to a lowest bid standard which lacks energy saving measures such as double glazing, full insulation or north facing housing.
PWD ACT submits that because there are disability specific factors which cause some persons to incur higher energy consumption for heating and cooling and thus a higher energy costs any changes to energy concessions must not further disadvantage these people. This matter is not addressed in the Discussion Paper and needs to be addressed in the implementation of any changes to the energy concession.
Improving the Equity of the Water and Sewage Concession
PWD ACT welcomes the extension of this concession to tenants given that people with disabilities are more likely to be tenants and constitute the majority of tenants of ACT Government housing.
In so far as the proposed change would reduce the concession for people who own their own home, this change would have to be implemented through an income test or tapir to prevent an unintended adverse effect on people with disabilities who own their own homes but who have low incomes.
The proposal to reduce the concession from 68% to 50% of the water and sewage charge also needs to be implemented with an income test or tapir or an offsetting benefit to avoid disadvantaging people with disabilities who own their own homes but who have a low income. This is an instance in which we agree with the ACTCOSS submission which points out that savings should be found from areas other than concessions given in recognition of social and economic disadvantage.
Improving the Equity of the General Rates Rebate
PWD ACT suggests that there is potential for the rates rebate system to be used to drive an increase in the stock of accessible and visitable housing if it included provision for a discount or rate rebate for properties owned by persons with disabilities which net relevant Australian Standards for accessibility to at least the Gold level. PWD ACT does not have the expertise or resources to do the economically modelling needed to provide the evidence basis for this proposal. We have sought ACT Government assistance to do this modelling without success. We believe that in the context of a concessions review and there is scope for the ACT Government to work with PWD ACT to economically model this proposal and scope the evidence base for the efficiency and effectiveness of this measure.
If the proposal to cease the grandfathering arrangements for persons who receive the Uncapped Concessions Scheme is adopted PWD ACT would prefer option 3 which is to freeze the current grandfathering arrangements for this concession for part pensioners which would see a freeze in general rates for uncapped recipient part pensioners at the 2015-2016 level and exclude those pensioners on the lowest incomes from the adverse effects of a change to the uncapped concession arrangements.
Improving Sustainability of the Motor Vehicle Registration Concession
PWD ACT supports ACT Government policies to promote the use of public transport and active transport options such as walking and cycling. However, we point out that for many people with disabilities public transport is often unavailable or inconvenient or at night is unsafe. Further, a person’s disabilities often makes active transport options impracticable. For many people with disabilities the motor vehicle is still the most practical and safe means of transport for people with disabilities. Accordingly, the ACT Government must be mindful of the effect of its charges for vehicle ownership on people with disabilities many of whom are also people with low incomes.
Some people with disabilities need to operate larger vehicles or vans to accommodate wheelchairs or other mobility equipment. These vehicles attract higher registration and third party insurance charges than the standard sedan car. We recommend that the ACT Government consider a concessional reduction to registration and third party insurance for vans used by people with disabilities for their daily transport. The current 100% concession for pensioners and DVA gold cardholders is a cost to ACT revenue estimated at between $265 and $483 per person.
However, we would suggest that this cost is more than offset by the economic and social contribution to the community which recipients of this concession make because they have the means of transport to travel to and from work and to and from family social, recreational and cultural activities. This concession is makes a substantial contribution to preventing social and economic isolation for concession recipients. These considerations more than justify retention of this concession. If the option to reduce this concession from 100% to 50% is implemented, this should be done over a 4 year period and the impact of the reduce concession should be carefully monitored. It is noted that ACT Registration costs are at the upper end of the scale when compared to other jurisdictions.
More Targeted Assistance for Part Pensioners
There are significant numbers of people with disabilities who have less than 20 hours paid work a week and receive a part pension. The proposal to reduce the levels of concessions available to these from the full concession to either 75% or 50%, especially for energy and utilities and water and sewage and transport, will substantially impact these people. As the Discussion Paper points out a reduction from full concession to 75% concession would reduce the average value of concessions paid to a person by $300 per year. However, the actual impact on an individual household would vary greatly depending on the number of concessions they currently access.
The Discussion contains estimates of the dollar impact per person or household of each of its suggested changes. It is understandable that no estimate of the benefit or detriment to a person, in dollar terms, of the cumulative effect of these changes can be given at this time because the Government’s intentions are not known. It is the cumulative effect of any changes which need to be monitored. The combined effect of a reduction in concessions for energy and utilities and water, transport and vehicle registration could be catastrophic for a low income person or household.
For this reason PWD ACT agrees with ACTCOSS’s recommendation that the ACT Government undertake further and more detailed data analysis that will more clearly explain how the risks of changes to concessions to low income households will be mitigated, before considering implementing any of the options outlined in the Paper.