5.1
Transport providers made a significant and valuable contribution to the Inquiry process. In general, many of the submissions from transport providers were characterised by a tension between information about a number of improvements, either actual or proposed, made to the accessibility of public land transport services, and evidence of the barriers to further progress in providing the accessible journey. Nervousness about costs associated with improved accessibility was openly discussed.
5.2
Transport providers are particularly vulnerable to complaints of discrimination. Evidence before the Inquiry revealed the extent to which operators on their own can and should address the issues that give rise to complaints, and the extent to which effective action requires the involvement of others.
5.3
Transport providers were involved throughout the Inquiry process. As part of the research and consultation phase of the Inquiry, the Commission conducted focus groups with bus drivers and taxi drivers, and sought the views of representatives of the Amalgamated Workers Union and the Tramways Union. A number of transport providers made submissions to the Inquiry process and hearings. Following the hearings, at which seven providers made oral submissions, there were further discussions with some providers, and further information was sought from them.
5.4
The transport providers who had made submissions to the Inquiry were given the opportunity to comment on the draft recommendations, and feedback was received from some providers. Follow up meetings and presentations were held with the Bus & Coach Association and Toll NZ.
5.5
The Inquiry heard from the two major professional organisations, the Bus & Coach Association and the New Zealand Taxi Federation, which provided significant input throughout the process. The Bus & Coach Association represents 460 operators and 165 associate members. The New Zealand Taxi Federation represents 68 approved taxi organisations that in turn have 3,500 individual taxi operators within their ranks.
5.6
In addition, eight submissions were received from transport operators/providers and two came from community transport service providers. Despite this involvement, it is acknowledged that many other operators/companies did not engage with the Inquiry process individually, including some who were referred to and/or criticised in other submissions.
5.7
Transport providers expressed support for the ‘accessible journey’ concept:
“We support the focus on the ‘accessible journey’ and acknowledge that unless the footpaths, bus stops, railway stations, terminals, interchanges and so on are accessible for disabled people, there will be barriers to mobility. We want to work with city and regional councils to overcome these barriers, so far as they are within our control.” (Bus & Coach Association)
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5.8
This chapter focuses on the perspectives of transport providers/operators. Their submissions highlighted the advances in accessibility that are being made by operators, as well as the issues and challenges that confront them.
5.9
Considerable progress, particularly in the main centres, has already been made in replacing bus fleets with all super low floor (SLF) buses. These investments represent a very significant commitment to accessibility. For example, Stagecoach New Zealand reported that 49 percent of its bus fleet is SLF; a further 177 buses will be replaced in the next three years, and the urban fleet will be fully accessible by 2014.
5.10 The Bus & Coach Association told the Inquiry that:
“Since 1994 when the initial complaint against Stagecoach’s purchase of 80 single-step urban buses was laid, the bus industry has developed a protocol regarding investment in SLF accessible buses, and has followed it since. Since 1995 we have built more than 1,566 buses for an investment of $344 million.”
5.11 Mana Coach Services Ltd in the Wellington region reported that 42 percent of its urban fleet of 125 vehicles is SLF, with wheelchair facilities with a further 15 planned for purchase in the next three years:
“We have three regular wheelchair customers across our network of urban services and cater for their needs on a daily basis. In addition, as needs are bought to our attention we work with the customers to provide accessibility if practical to do so.” (Mana Coach Services)
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5.12 Stagecoach New Zealand reflected the views of several transport providers when it noted that, “this was done voluntarily and without the need for legislation”, and that there was a lack of justification for regulations “compelling us to do what we are already doing voluntarily”.
5.13 An increasing number of urban bus routes are being advertised as being serviced by SLF buses, either full-time or between particular hours. Examples were given to the Inquiry of routes in Auckland, Christchurch, Wellington and Dunedin in this category.
5.14 Stagecoach New Zealand told the Inquiry that a number of their routes were fully SLF at off-peak times, but were not advertised or promoted as such. One reason for not advertising appeared to be a reluctance to create an expectation of total accessibility, which could not be guaranteed to be met 100 percent of the time – for example, if for some reason, the SLF buses had to be taken off that service or were unavailable. While Stagecoach’s reasoning is understandable, it also highlights how uncertain accessible transport can be, and helps explain why, for many disabled people, it is too unreliable to be used.
5.15 Stagecoach New Zealand also advised the Inquiry of research undertaken as part of a proposal to make Wainuiomata bus services fully wheelchair accessible. Working in collaboration with local authorities and DPA in the Hutt Valley area, Stagecoach New Zealand carried out an evaluation of the bus routes to determine the infrastructure improvements that would be required to achieve this goal. The exercise identified many of the obstacles that commonly impede disabled people’s ability to travel. Problems highlighted included:
- kerb height
- pavements not wide enough to accommodate ramp use
- rough or damaged pavements
- bus stops covered with grass
- no pedestrian crossings adjacent to major bus stops or terminal
- obstructions such as trees at bus stops
- parked cars hindering the use of bus stops – where bus stops were not of sufficient length, or the placement of parking spaces did not allow adequate room for buses to enter and exit the bus stop easily.
5.16 Some operators have, upon request, arranged to ensure that accessible vehicles are available for disabled people who are regular users of particular services/routes:
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“I have been able to use the Newlands buses to get to work because the company was willing to schedule one of their low-floor buses on the route that passes my home at the same time every morning. The company has indicated that once they get more low-floor buses, they will consider scheduling one at the time I come home from work. I understand that Newlands has been similarly responsive in accommodating other passengers with disabilities.” (Alison Riseborough)
5.17 The Inquiry was told of some successful collaborative efforts between transport operators and disability organisations:
“The Blind Foundation co-ordinate with us to bring members of the community to our depots to familiarise themselves with our fleet if a new member moves to the area. We provide vehicles for them so that they can work with members to gain confidence in the accessibility issues, purchasing tickets, etc. this has proved a most worthwhile and successful relationship.
“In addition, many members of the local community live in local IHC facilities. Most use our services and purchase our ‘contactless’ smartcard ticket. This is usually done at our depot with the assistance of their caregiver and assistance is giv[en] in identifying boarding stops and destinations. We use this information to assist driving staff to identify people and put them in a position to better assist their customers as required. The majority of our staff live locally and we see this as an asset in helping their community when using public transport.” (Mana Coach Services)
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5.18 However, consultation with disabled people about transport provision, such as designing new premises, deciding on services, routes or timetables, and infrastructure, is negligible overall, and orientation and familiarity programmes for disabled people are the exception rather than the rule.
5.19 The Inquiry heard that funding and engineering constraints restricted the ability to improve some aspects of the accessibility of rail transport. However, notwithstanding these constraints, there have been some improvements made to facilities and services.
5.20 Toll NZ drew attention to the extent to which improvements in information provided to all passengers have assisted disabled people. Specifically, they instanced better platform indicators at Wellington, improved announcements, PA systems on trains and training to use them, and use of cell phone advice of disruption. They also mentioned Tranz Metro Wellington timetables available by voice via Greater Wellington’s Ridewell service, and on the internet, as well as in leaflet form and postings at stations; internet booking for Tranz Scenic; and on-board passenger information displays introduced to Auckland vehicles (while they were still operated by Toll).
5.21 Toll NZ also described the greater potential for accessibility offered by the 1980 Ganz Mavag electric multiple unit, compared with the English Electric unit:
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“The 1980s Ganz Mavag [electric multiple units] have wider doors than the English Electric units, and more space for wheelchairs. They have an on-board portable ramp so wheelchair users can gain access, along with tip-up seats to provide space for wheelchairs, and safety belt restraints. The current ramp is quite heavy, and a new ramp designed for newly refurbished Auckland trains will also be introduced in Wellington. This ramp is wider, lighter, stronger, and more flexible in accommodating a range of wheelchair types.” (Toll NZ)
5.22 As well as existing programmes and initiatives, some operators highlighted relatively small improvements that they have already made or could implement, to make their services more accessible for disabled people. For example, Toll NZ said:
“We note that the Consultation Report contains several comments about issues where relatively small improvements could greatly assist people with disabilities, particularly those other than movement impairments. We could do better on some matters, and will investigate how we can improve our service in the following ways:
- providing written advice as detailed as that on the PA in the event of disruptions, along with advice by cell phone update
- regular repeats of cancellation or replacement information
- earlier announcements of platform allocations and changes
- accessibility of ticket selling windows
- on-board announcements of station stops
- large print, up to date timetables at stations
- training, especially in recognition of disabilities, and enhancing the ability to treat people normally.” (Toll NZ)
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5.23 Some suggestions by other submitters were put to transport providers who made oral submissions to the Inquiry. Providers were generally open to investigating these proposals further. One example included fitting taxis with a Braille/raised print card, placed in a standard position (say, between front seats or on inside of doors) displaying the cab number, company contact details, etc., to provide greater security for blind and vision impaired passengers. Another involved establishing a modest, flat rate charge for loading wheelchairs in WATs, so that passengers are not put to greater costs when drivers take longer to perform this task.
5.24 Of all the issues canvassed by the Inquiry, compulsory driver training met with the greatest degree of consensus from disabled people and transport providers.
5.25 The New Zealand Taxi Federation has developed, in conjunction with disabled people, a very useful and comprehensive training package, and was supportive of the idea of mandatory training for all taxi drivers:
“We contend that all taxi drivers should be trained in the skills and knowledge required to provide a high standard of service to people with special needs as part of the ‘Passenger Endorsement’ to their driving licence. There is an NZQA Unit Standard, ‘1748: Demonstrate skills required to assist passengers with special needs’ that we consider all taxi drivers should be required to meet. Surely knowing how to assist people with special needs is as important as knowing how to get to where they want to go to.” (New Zealand Taxi Federation, Wellington Branch)
5.26 Bus operators acknowledged the importance of good customer service and driver training, both to the overall operation of their business, and to improving accessibility for disabled people.
“While we currently provide training for our staff we have recognised that this is an area we can improve on. We have been working on developing training for all drivers to update their skills in this area. We have already been actively consulting with the representatives from the various interested organisations and will be producing a new training module for all our staff once all submissions have been received back.” (Stagecoach New Zealand)
“The National Certificate in Large PSV Driving has an elective unit standard, number 1748, ‘provide assistance to passengers with special needs’. …We are working with the Industry Training Organisation to incorporate the major urban bus operators’ own training programmes into the National Certificate system.” (Bus & Coach Association)
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5.27 Bus operators called for acknowledgement by regional councils and the Ministry of Education, in their contract tendering processes, of operators with good training programmes:
“[I]f training is to be genuinely effective, regional councils must give a clear preference to operators who have drivers with their National Certificate. Currently, training is a cost which can go unrecognised in the competitive tendering process.” (Bus & Coach Association)
“Our company is committed to on-going training for our staff and believes that we are providing good service to our customers in this area. We see this as a valuable benefit we offer that we hope will be acknowledged when we come to tender for services with our local regional council.” (Mana Coach Services)
5.28 Two levels of training were identified as important. First, technical training in the operation of the vehicle and equipment – including reducing ‘rough driving’, pulling in close to the kerb, and training in operating wheelchair ramps, etc. Secondly, training on customer service was essential, including awareness and understanding of disabled people’s needs.
5.29 Citibus Newton advised that while “drivers have been trained to assist boarding by using the vehicle kneeling and ramp facilities if required”, they acknowledged that staff awareness and understanding of the needs of disabled passengers needed improvement.
5.30 Bus operators also maintained that there were limits to the level of service/assistance that drivers could or should be expected to provide:
“We must consider what we can practically expect a bus driver to do to assist passengers. We need to take into account the varying physical capabilities of drivers; cultural issues, the security of the bus and the appropriateness of physical contact between drivers and passengers. We are aware of our responsibilities to our staff under the Health and Safety Act and that we cannot expect staff to carry out any activity that is likely to cause them harm. This is particularly relevant when dealing with passengers in wheelchairs. We have already had incidents where drivers have suffered back injuries while assisting wheelchair passengers.” (Stagecoach New Zealand)
5.31 InterCity Coachlines reported that all its drivers undertake training in dealing with passengers requiring special assistance. When InterCity is advised of the need for special assistance in advance, the passenger list provided to the driver will include notes regarding special assistance that may be required. Difficulties arise, however, for people who are physically immobile and must be carried on or off the coach. InterCity noted that OSH guidelines require that drivers not be required to lift heavy weights (usually regarded as weights over 25kg).
5.32 Citibus Newton argued that some of the expectations of the level of assistance that bus drivers could provide were unreasonable, and some were also precluded by safety considerations:
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“The difficulty that we experience has developed from the expectation that because there is a vehicle that can carry wheelchairs, that the wheelchair user has a right to have their travel needs accommodated. Often this is to the detriment of the health of the driver or the operational needs of the service on which many regular travellers rely. Driver assistance for wheelchair users to get on and off buses has resulted in an increase in on-the-job back problems being reported. There is a reluctance to help independent wheelchair users who are not prepared to help themselves.” (Citibus Newton)
5.33 While considerable progress has been made by the transport industry in recent years, the submissions made to the Inquiry by transport providers outlined the remaining barriers they see to a totally accessible journey, and some of the reasons that they believe account for greater accessibility not being achieved.
5.34 Of chief concern to transport providers were:
- The need for integration and coordination between the various parties involved in public transport provision, to ensure that all parts of the ‘accessible journey’ function effectively. Breakdowns at other points of the ‘accessible journey’, particularly in relation to infrastructure, were highlighted.
- Funding/cost issues.
- Costs associated with upgrading conveyances and premises to meet any accessibility standards.
- Availability of funding for WAT replacement/upgrades.
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- Maintaining the commercial viability of their services and level of service to passengers across the board.
- Practical/engineering constraints, particularly in regard to long distance coaches and trains.
5.35 Almost all transport providers highlighted the crucial inter-relationship between the standard of infrastructure and the ability of transport operators to provide an accessible service. The concerns expressed by Dunedin’s Citibus Newton were shared by Wellington’s Stagecoach operators, and indeed by the industry nationwide:
“The whole journey concept has highlighted some issues with the location and accessibility of bus stops in Dunedin. The placement of kerb protrusions and their relative position, the enforcement of parking restrictions, the placement of street furniture (seats, timetables stands, lamp posts, etc) all make the use of ramps and kneeling devices difficult. The expectation of a short step from the bus to the kerb is often unable to be met because of this. The variability of kerb heights in the suburbs, the road camber and the gradient all add to our difficulties in providing a service that is without unreasonable barriers.” (Citibus Newton)
5.36 The Bus & Coach Association succinctly and comprehensively listed the issues:
“We share disabled people’s concerns about:
- the state of the footpath;
- whether the stop is accessible;
- ill-maintained and ill-sited bus stops which have hazards such as trees, bins, etc blocking the bus door;
- whether the information provided at the stop can be used by everyone;
- whether illegally-parked cars prevent the bus from stopping so the ramp (if fitted) can be used;
- whether the route designed by the regional council enables people to get to their destination with a minimum of changes;
- whether there is a service at all; or
- whether the transport terminal is genuinely accessible.
The industry is happy to help regional and city councils solve these problems. A national infrastructure standard may well be an appropriate response.” (Bus & Coach Association)
5.37 Rail operators identified as a major issue the direct impact on freight rail services of any design changes to rail infrastructure, in particular platforms, aimed at achieving accessible boarding of passenger trains.