The submission to the Draft Report considers that report from the perspective of how access to air travel would be effected by the recommendations contained in the Draft Report. Comments are focussed on the general quality of the analysis of the Draft Report, particularly the adequacy of the information sources, level of analysis and whether the evidence, support the recommendations in the Draft Report.
The submission concludes that the analysis and lack of independent evaluation of the claims of those making submissions and quoted as evidence in the Draft Report is disappointing. There is a lack a coherent application of methodologies for the analysis and selection of material on which ACG bases the recommendations. Since the basis on which the recommendations are made in the Draft Report is not fully substantiated, it follows that many of the conclusions fail to answer the concerns raised by people with disabilities who experience problems accessing air and other travel.