Member that reporting on measures taken in relation to any conditions attached to current exemptions have not been adequate. Having expressed a general view that the exemptions should not be granted All Aboard submitted comments on each of the individual applications on the assumption that the Commission would proceed with the application from ARA on behalf of its members. While All Aboard does not support some specific applications in general the network proposes that if the Commission were to grant any exemption it should be subject to the conditions attached to current exemptions, subject to a number of additional comments or proposals. All Aboard made a supplementary submission concerning what it sees as a significant conflict of interest arising from a cross-over in membership between the ARA and APTJC. All Aboard expressed concern that effectively a group of ARA members (state government transport bodies) are charged with providing advice to the Commission on the application for temporary exemptions by the ARA. Association of Consultants in Access Australia (ACAA) ACAA is a national membership-based professional association for people working to achieve accessibility of the built environment for people all. It is the peak national body for access consultancy in Australia. The ACAA submission does not comment on specific applications, but offers a view on the general approach that could be taken. ACAA proposes that rather than grant broad exemptions any non-compliance at specific locations should be itemised and be subject to the preparation of Alternative Building solution reports. These reports should document both the enduring non-compliances and the local management process by which equivalent access can be provided in the form of direct assistance or other means. People with Disability Australia (PWDA) PWDA is a leading national disability rights, advocacy and representative organisation of and for people with disability. PWDA notes that the current application mirrors earlier applications, but omits reporting responsibilities and reference to provisions such as direct assistance. PWDA states that a monitoring and reporting mechanism is essential for any exemptions granted and that most of the application cannot be supported unless there is such a mechanism as a condition. PWDA proposes that rather than the ARA continually making exemption applications its members should seek to comply with the prescriptive (deemed-to-satisfy) requirements of the Transport Standards and Premises Standards wherever possible. Where this is not possible PWDA proposes that ARA members should develop approaches to provide Equivalent access, including the use of direct
Member that reporting on measures taken in relation to any conditions attached to current exemptions have not been adequate. Having expressed a general view that the exemptions should not be granted All Aboard submitted comments on each of the individual applications on the assumption that the Commission would proceed with the application from ARA on behalf of its members. While All Aboard does not support some specific applications in general the network proposes that if the Commission were to grant any exemption it should be subject to the conditions attached to current exemptions, subject to a number of additional comments or proposals. All Aboard made a supplementary submission concerning what it sees as a significant conflict of interest arising from a cross-over in membership between the ARA and APTJC. All Aboard expressed concern that effectively a group of ARA members (state government transport bodies) are charged with providing advice to the Commission on the application for temporary exemptions by the ARA. Association of Consultants in Access Australia (ACAA) ACAA is a national membership-based professional association for people working to achieve accessibility of the built environment for people all. It is the peak national body for access consultancy in Australia. The ACAA submission does not comment on specific applications, but offers a view on the general approach that could be taken. ACAA proposes that rather than grant broad exemptions any non-compliance at specific locations should be itemised and be subject to the preparation of Alternative Building solution reports. These reports should document both the enduring non-compliances and the local management process by which equivalent access can be provided in the form of direct assistance or other means. People with Disability Australia (PWDA) PWDA is a leading national disability rights, advocacy and representative organisation of and for people with disability. PWDA notes that the current application mirrors earlier applications, but omits reporting responsibilities and reference to provisions such as direct assistance. PWDA states that a monitoring and reporting mechanism is essential for any exemptions granted and that most of the application cannot be supported unless there is such a mechanism as a condition. PWDA proposes that rather than the ARA continually making exemption applications its members should seek to comply with the prescriptive (deemed-to-satisfy) requirements of the Transport Standards and Premises Standards wherever possible. Where this is not possible PWDA proposes that ARA members should develop approaches to provide Equivalent access, including the use of direct
ARA%20temporary%20exemption%20report_0.docx