1. Introduction
The purpose of this
discussion paper is to raise issues
around parking difficulties faced by people with
physical disability. We suggest possible
solutions in the paper and welcome comments from
anyone interested in the topic.
2. Why is Accessible Parking
so Important?
Whatever view we may
take of the role (for good or ill) of cars in
modern times it is impossible to avoid this
simple truth: Our towns and cities have been
developed and planned on the assumption that
private car use is and will remain a dominant
transport form for the foreseeable
future.
All members of society
make use of cars for all kinds of purposes: to
go work, to shop, to transport children to
school, for social and recreation purposes.
People with disability are car users in the same
ways as the population as a whole. Indeed,
because of restrictions placed upon people with
disability by inaccessible public transport,
those of who drive may be even more dependent on
our cars than the population as a
whole.
People with disability
need accessible parking because the ability to
use a car - as a driver or a passenger - is
often essential and sometimes our only transport
option.
It is also true, however,
that people with physical disability have fewer
choices in moving about the community safely,
easily and independently than members of the
public generally. The limitations forced upon us
are a consequence of the low levels of
accessibility of public transport, particularly
trains and buses. These failings are made worse
by the expense and unreliability of wheelchair
accessible taxi services.
A few key statistics
illustrate the scale of the barriers that
prevent people with physical disability from
moving around New South Wales as freely as other
residents:
- 90% of railway
stations in NSW are not accessible to
wheelchair users currently and will not be
accessible for at least 9 years (and very
much longer in many cases).
- 60% of State owned
buses in NSW are not currently wheelchair
accessible.
- 80% of privately owned
buses in NSW are not currently wheelchair
accessible.
- 96% of taxis in NSW
are not currently wheelchair
accessible.
As a result of the
continuing failure of public transport to
facilitate equality of opportunity for people
with physical disability, we are forced into a
much greater reliance on private vehicles. For
example, an NRMA forum on parking in the Sydney
CBD found that 80% of people with mobility
difficulties have no alternative but to drive
(or be driven) because of restricted access to
other forms of transport.
This disproportionately
high reliance on private transport requires
planners and the public to accept the need for
two interdependent components of mobility
assistance for people with physical
disability.
- The availability of
flexible parking rights through mobility
parking permits.
- Convenient and
plentiful parking, with an ample and reliable
supply of parking spaces designated for the
sole use of mobility parking
permits.
3. SO …What's the
Problem?
Access to parking,
particularly in areas of high demand such as
places of employment, education, recreation and
shopping, has become increasingly problematic
for people with physical disability. The
problems arise in several ways:
- Sometimes there are
simply not enough parking spaces
available.
- Sometimes there are
insufficient numbers of available parking
spaces designated for exclusive use by
authorised mobility parking permit
holders.
- Often the system of
designated parking spaces is abused by
thoughtless or indifferent members of the
public who park without displaying the
authorised parking permit and exclude people
with physical disability.
The difficulties faced by
people with physical disability centre on two
main concerns:
- The provision and
misuse of mobility / disability parking
permits; and
- The inadequacy of the
provision and policing of designated
accessible parking spaces.
4. Mobility Parking
Permits
The mobility-parking
permit was first introduced to NSW in the early
70s. It is administered in NSW by the Roads and
Traffic Authority (RTA) and in other states by a
range of government departments or
instrumentalities. In Western Australia it is
issued by a non-government agency, ACROD.
There are three types
of mobility parking permit issued in
NSW:
- For people with
permanent disability who drive
themselves;
- For passengers who are
driven by someone else (for example a family
member, friend or worker with a
disability-related service provider);
and
- For people with
temporary mobility restrictions.
- For further details on
these permits Australia-wide see the following
web sites:
www.rta.nsw.gov.au/visit/mobilitypark_0301.pdf
www.melbourne.vic.gov.au/infopage
and follow the links
www.brisbane.qld.gov.au/council/
and follow the links to disability
services
www.accessibility.com.au/sydney/travel/parkperms.htm
www.islandnet.com.au
The NSW mobility-parking
permit is much valued by people with physical
disability (and others) with a genuine need for
the concessions it allows. The valuable support
it provides, by which we mean an accessible
parking space near popular and/or busy
locations, results, however, in abuse by people
who do not genuinely need the benefits built
into the system.
Over the duration of the
parking permit scheme in NSW there has been a
constant and substantial increase in the number
of people applying for and being granted
mobility parking permits. During that time the
original criteria for determining eligibility
have not changed.
PDCN accepts that the
increase in the number of mobility parking
permits is due (in part) to an increase in the
number of people with disability who genuinely
need access to designated parking because of
mobility difficulty. We recognise that with an
ageing population it is likely that the number
of genuine applicants will continue to increase
rather than decrease.
PDCN strongly believes,
however, that a significant proportion of the
increased number of mobility parking permits is
due to successful application for the concession
by people with no genuine need. In short, people
with no mobility difficulty are abusing the
system.
In attempting to find
reasons behind the escalating number of permits
issued, it seems clear that the mobility-parking
permit is a victim of its own success. As the
scheme has become better known, as the number of
locally based access committees has grown, as
designated parking spaces have become more
widespread in premium and desirable locations
and as the amount of free on-street parking
spaces has become scarcer (especially in CBD
areas) the demand for mobility parking permits
has multiplied.
The NRMA parking forum
"Breaking Down the Parking Barriers" conducted
in 1998 identified a number of problems related
to perceived greater availability of parking
permits and their abuse. These
included:
- Medical Practitioners
(mostly GPs) allocating mobility parking
permits to people who were not necessarily
eligible (it is not difficult to picture
over-worked doctors, short of time perhaps,
responding to emotional blackmail /
harassment by persistent patients who have no
real need for a mobility parking permit but
do have the tenacious self-interest to abuse
the system).
- Temporary permits
being abused by people long after recovery
from temporary impairment.
- Current permits for
passengers being misused by non-eligible
drivers when the permit holder is not
occupying the vehicle.
- Expired permits (both
driver and passenger types) being misused by
non-eligible drivers, sometimes even after
the original permit holder had
died.
- People without permits
misusing designated parking spaces, safe in
the knowledge that no truly effective
policing and / or enforcement mechanisms
operate in many locations.
- Stolen or forged
permits misused by non-eligible
drivers.
5. Making the Mobility
Parking Permit work Better for people with Genuine
Need
PDCN does not wish
to restrict access to a mobility-parking permit
by any applicant whose need is genuine. People
with real mobility difficulties need and welcome
the support and accessibility made possible by
the current scheme.
At PDCN we believe,
however, that if the current system is to
survive as a meaningful and valuable support to
living in the community, access to the benefits
of the mobility-parking permit must be more
clearly targeted on people with genuine need. In
short, we need to ensure that abuse of the
scheme is made more difficult.
In our view, a key point
at which the potential for abuse occurs comes
when a medical practitioner is asked to confirm
that an applicant is eligible for the parking
permit. The process of applying should become
more rigorous so as to deter bogus applicants
but not so off-putting as to deter genuine
applicants.
We invite comment,
therefore, on the range of proposals set out
below. The proposals cover three
areas:
1. Application
for a mobility parking permit
2. Issuing of mobility
parking permits
3. Prevention of
fraud
Our aim is to make it more
likely that only those people with genuine need
for a mobility parking permit can deemed
eligible to receive one.
Option 1: Remove
responsibility for assessing applicants from all
General Practitioners.
The current arrangements
generate conflict of interest. People intent on
abusing the system for assessing entitlement to
mobility parking permits can bring all kinds of
subtle (and not so subtle) pressure to bear on
local GPs who may be overworked, short of time
and simply too busy to give due thought and
consideration to a potentially fraudulent
application.
Option 2:
Designate one or more (a small number) of
medical practitioners (or other designated
person) in each local government area as
assessors of applications for mobility parking
permits.
The General Practitioner
(or other designated person) responsible for
assessing applicants should not be the medical
practitioner of the applicant. Applicants should
be required to seek authority for a parking
permit from a person not directly known to them
in relation to day-to-day medical and/or
community living support.
Option 3:
Applicants to renew current mobility parking
permits should be re-assessed at the point of
application.
As currently held mobility
parking permits expire, all existing holders
should be re-assessed using the new arrangements
set out above. Abuse occurs (in part) when
current mobility parking permits are misused or
abused by people who are not entitled to use
them. New applicants will be required to undergo
more rigorous application processes. Existing
holders should be required to undergo the same
process once, on the expiration of their current
permit.
Option 4:
Applicants should be charged an
administration fee
A small administration fee
($25 - $50) should be levied on applicants. The
fee would serve two purposes. Firstly, it would
make possible a self-financing application
process (practitioners designated to assess
applications would be paid to take on the work).
Secondly, applicants would be required to
consider the potential cost of applying. The fee
arrangement would allow discretion to waive the
fee for applicants for whom any additional
financial burden would create a
disincentive.
Option 5: Transfer
responsibility for issuing mobility parking
permits from the RTA to another
agency.
We seek comments on the
suggestion that the RTA may not be the most
appropriate body to issue mobility parking
permits. PDCN has no fixed view on this
question. In Western Australia the parking
permit is issued by a non-government
organisation. Overseas, in the UK for example,
local government issues mobility-parking
permits. There is clearly some benefit, however,
to the current arrangement, which allows a
driver with disability to conduct all vehicle
registration / parking authority business at one
location … the local RTA office.
Option 6:
Introduce an audit process similar to the
NSW Taxi Subsidy Scheme.
In NSW the current taxi
subsidy scheme has an effective monitoring and
auditing process. We favour the introduction of
a similar arrangement in relation to mobility
parking permits. Every year a randomly selected
small sample of practitioners responsible for
assessing applicants and holders of mobility
parking permits should be monitored to ensure
that applications are genuine and that
assessments are valid. Any abuse identified
through such an auditing process should be
subject to appropriate penalties, which would
include the removal of the right to assess
applications as well as financial
penalties.
Option 7: Redesign
the permit that must be displayed by legitimate
holders
The current, white-paper
permit is too easy to forge and / or misuse. A
range of suggestions has been made to make it
more difficult to abuse. These
include:
- Print the permit on
brightly coloured, thick card.
- Print the permit
using two colours.
- Do not print on
white card.
- Include a
photograph of the holder (fixed to the
reverse side)
- Include a
hologram.
- Choose one colour
for drivers, a second colour for
passengers.
We welcome comments on and
amendments or additions to the suggestions
above.
6. Provision and Policing of
Designated Parking Spaces
Even if every
mobility-parking permit issued to people were
issued to people with genuine need as a
consequence of mobility difficulty there would
still be some abuse of the designated parking
system. We must, therefore, address questions of
provision and policing of parking spaces as well
as applications and issuing of mobility parking
permits.
Before 1981, the United
Nations International Year of Disabled Persons
and the advent and growth of access committees,
designated parking for people with disability
was virtually non-existent. Twenty-one years
down the track, designated parking has spread
from shopping centres, airports, council
chambers to the streets, to places of recreation
and entertainment such as theatres and beach
fronts, parking stations and the like. They are
highly sought after because of their convenient
locations. The very fact that makes them
valuable to people with mobility problems
creates the potential for abuse.
Even with the growth in
the number of designated parking spaces over the
last 20 years, however, the growth of legitimate
demand has outstripped the supply of spaces.
This trend is likely to continue. As our
population profile changes and more of us live
longer in the community demand for accessible
parking will increase. In short, we need more
designated parking spaces as well as more
effective enforcement of parking
regulations.
At the NRMA forum
(mentioned above) a range of issues concerned
with parking spaces and policing
included:
- Accessible parking
must be integrated with public transport
services as a matter of equity.
- Appropriate design of
designated accessible parking spaces is
critical to independence and safety
especially where there is variation in the
kind of provision e.g. parallel, 90 or 45
degree parking.
- Off-street parking in
parking stations can pose access difficulties
when ceiling heights are too low, automatic
ticketing machines are unsuitably located,
the cost of spaces is
prohibitive.
- Signage for spaces is
poorly marked, inconsistent, lacking clarity
and visibility.
- Current penalties
especially in off street parking spaces e.g.
shopping centres are ineffective
deterrents.
- Enforcement of
regulations is lax or
non-existent.
- Policing of abuse of
mobility parking permits is poorly resourced,
not a priority or simply absent.
On street parking is now
better policed since responsibility for
monitoring has been passed over to local
councils. Nevertheless, a recent survey of
designated parking spaces in the Sydney CBD
conducted by Sydney City Council over one day in
July 2001 found:
- Only 57% of vehicles
displayed a mobility parking permit
(conversely 43% did not)
- Of those displaying a
permit, 22% stayed longer than 8 hours and
28% arrived before 9a.m.
- Of the 43% NOT
displaying a permit, 80% stayed under 15
minutes
- 18% of vehicles had a
driver or passenger with an obvious mobility
disability (conversely 82% did NOT have an
obvious disability)
- The length of stay
averaged 3.5 hours
PDCN invites feedback on
the proposals set out below, which are intended
to increase the availability of designated
parking spaces for legitimate holders of
mobility parking permits.
Option 8: Increase
the proportion of designated parking
spaces
We should double the
proportions of designated parking spaces
required by Building Code of Australia. The new
minimum requirements must be incorporated into
the draft standards on access to premises and
access to transport.
Option 9:
Financial incentives should be introduced
for operators of parking areas who exceed the
minimum requirement of the Australian
Standard.
Concessions and / or
incentives should be built into corporate tax
arrangements, land use fees, rates, etc where a
provider of designated accessible parking
exceeds the requirement of the Building
Code.
Proposal 10:
Penalties for abuse of designated parking
spaces should be high enough to be a real
deterrent.
The penalty for misusing a
parking permit or using a designated parking
space without proper authority should be no less
than $500 for the first offence.
Option 11: The
permit should be re-designed to be more easily
identified or more conspicuous by its
absence.
The design proposal made
above not only makes the permit more difficult
to forge; they also make policing more
effective. A more easily seen or conspicuously
absent permit allows policing agents to be more
certain in the conduct of their duty.
Option 12:
Training for enforcement officers in the
priority matter of cracking down on abuse of
designated parking.
Awareness of the issues
and commitment to a policy priority should be
incorporated into the training of parking
enforcement officers.
Option 13:
Policing of designated parking spaces on
private land (e.g. shopping malls, cinemas, etc)
should be transferred to local authority
enforcement officers.
In some areas, agreements
have been reach between the local government
authority and owners of private land on which
shopping malls and other 'public' facilities are
based to empower local authority enforcement
officer. These arrangements should become
standard practice throughout NSW.
Option 14: A
debate (with a clear deadline for completion)
should commence into the pros and cons of
introducing a two tiered parking scheme in
NSW.
The parking needs of
different people with disability vary. It is not
unusual for people with disability who use
wheelchairs or other mobility aids to need wider
parking spaces than other people with
disability. In some circumstances, however, it
may not be necessary for wider bays to be
immediately adjacent to the destination (in a
covered car park at a shopping mall, for
example, extra wider bays could be located at a
distance from the lifts while the much larger
number of narrow bays designated for the
majority of people with disability could be
close to the entrance). PDCN has no firm view on
this proposal and welcomes feedback.
PDCN welcomes comments about
and feedback on the ideas and proposals presented
in this discussion paper.
Comments should be sent by 16th August 2002
to
email
admin@pdcnsw.org.au
letter
PDCN, 3/184 Glebe Point Road, Glebe NSW 2037
fax 02 95562 4644
This discussion paper has
been prepared by the Transport Policy Group of the
Physical Disability Council of NSW and approved by
the Council's Management Committee on 22nd July
2002.
|
