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The discussion paper entitled “Harmonisation of disability parking permit schemes in Australia”, recently released by the Department of Families, Housing, Community Services and Indigenous Affairs, has already come up for a fairly thorough take-down in Lauredhel’s previous post.
In some discussion with various people with disabilities from different states who currently held a permit, or had in the past, I began to wonder how the alleged ‘harmonisation’ of state-based schemes into a national one was taking place: was it simply a matter of selecting the most narrow existing scheme and applying it nation-wide, as the cynical part of me wondered. As it turns out, none of the existing schemes administered by the various states had eligibility criteria as narrow as the proposed scheme. My inner cynic, apparently, is not yet cynical enough.
Please compare the proposed new criteria to the eligibility criteria on existing schemes, excerpted below. It’s also worth noting that all states offer reciprocal recognition of other states’ permits (and some overseas permits), so while there are some small benefits to the idea of ‘harmonisation’, they mostly have to do with PWD (People With Disabilities) retaining access to permits if they move states, and the convenience of those administering the schemes.
These existing schemes usually have some kind of distance measure, which says something like ‘person’s impairment would be unduly affected by walking 50m/100m.’ When you compare the “harmonisation” proposal with that, something becomes clear: what they’re doing is mandating what kind of impairment you have, rather than assessing the effect of the combination of the impairment and the disabling context of distant or inaccessible parking. We’re moving away from an acknowledgement of the way that parking requirements can be disabling for particular people, whatever their type of impairment, and at reducing that disability by accommodations. We’re moving towards configuring particular people as ‘deserving’ based on an assessment of the type of their impairment or their dependency.
One of the major problems here is that it requires PWD to provide evidence of dependency. You have to prove that if you push yourself too hard, if you work beyond your known limits and ‘act’ like an able-bodied person, not only that you can’t do it but that you will need physical help from another person to walk. It makes dependence, again, the supposed essence of disability, and it attributes this to the individual, rather that seeing it as occurring at the intersection of ‘normal’ parking and impairment.
This new scheme would effectively shift us from regulations which deploy the social model of disability (by assessing the extent to which one is disabled by walking a distance which is involved in ‘normal’ parking) to regulations which deploy the medical model (by requiring that one’s impairment hit a certain physical standard, namely an inability to walk (at least sometimes) and a particular level of dependence). That shift is quite important for a couple of reasons, and it’s why I wouldn’t want anyone arguing that we can keep the proposed regs so long as they’re ‘generously’ interpreted. (And it’s worth noting that a ‘generous’ interpretation seems unlikely given the government’s agenda, outlined in their Q&A, which is to decrease the number of permit holders.)
First, the new regulation would focus on the individual as having the problem, rather than the way that we’ve set up parking. In other words, the shift from the social model to the medical model, which exonerates TAB and the exclusiveness of the world they’ve built.
Second, the more legislation that passes which involves a social model – namely the acknowledgement that we built the world in such a way as to disable those whose bodies don’t match a random standard – the more this way of thinking about disability actually has a chance. To wind back a system which is currently shaped by the social model of disability is a major problem in terms of the precedent it sets.
The other thing to keep in mind, of course, is that current regulations don’t have the same level of ‘questionable’ness or ‘arguable’ness, precisely because they test for how one is disabled by inaccessible parking, not for how dependent/unable to walk one is. In that respect, I think it’s pretty telling that we’re shifting to something ‘questionable’. Premising accessibility on how well one can argue the point privileges, of course, white, middle-class, educated people, without cognitive disabilities and with energy to spare, who tend to do better in the ‘persuasive’ stakes. And ‘questionable’ also places the decision-making power back into the hands of procedural institutions, shaped by the drive to ‘reduce numbers of permits’, who are unlikely to understand the social model, disability, or most importantly of all the extraordinary variation of impairments that term contains.
Here are the proposed and current eligibility criteria for accessible parking permits in Australia.
Proposed new requirements [Emphases are ours.]
Current State-by-Territory requirements.
NSW: (taken from Mobility Parking Scheme Application (Individuals) form avail. from RTA)
QLD: (taken from the Disability Parking Permit Scheme Application form, avail. from Qld Transport)
NT: All schemes are council-based. This example is taken from the Application for a Parking Permit for Disabled Persons with a Mobility Limitation as administered by Darwin City Council) However, this is “at the discretion of the council.” Not exactly a win for transparency.
Victoria: (taken from DCA Application Form from City of Melbourne)
SA: (taken from the transportSA website)
Short term parking permit scheme from Hobart City Council (as an example for the temporary arrangements offered by other Tasmanian cities) :
WA: (taken from ACROD Parking Program WA)