Accessibility of Tram Services: Follow-up
Review snapshot
Has the Department of Transport and Planning implemented the action plan it developed to respond to the 10 recommendations in VAGO's 2020 audit Accessibility of Tram Services and improved compliance with accessibility standards?
Why we did this follow-up review
People with disability make up 17 per cent of Victoria’s population. People without disability can also have temporary or ongoing mobility restrictions that affect their ability to access tram services.
The state government is legally required to make public transport accessible in line with the Australian Disability Standards for Accessible Public Transport 2002 (DSAPT). Melbourne's tram network is a crucial public transport mode.
In our 2020 audit Accessibility of Tram Services, we found that tram services were not meeting the needs of passengers with mobility restrictions. We made 10 recommendations to the then Department of Transport about improving the network’s accessibility. It accepted 7 in full, 2 in principle and one in part.
We did this review to see if the Department of Transport and Planning (the department) improved the tram network's accessibility and implemented the action plan it developed in response to our 2020 recommendations.
We also assessed if the department’s planned actions addressed the risks identified in our 2020 recommendations.
Key background information
Source: VAGO.
What we concluded
There has been little improvement in tram network accessibility in the 5 years since our 2020 audit.
In 2023–24, only 18 per cent of tram services were accessible. This means they provided a low-floor tram at a level access stop. This is an increase of 3 percentage points since 2018–19.
The department did not meet the 2022 deadline for tram stop compliance legislated by the DSAPT. Based on current plans, the department will also miss the 2032 compliance deadline for low-floor trams. The department has not set a new deadline to deliver an accessible and DSAPT-compliant tram network and cannot forecast when it will be compliant.
Since our 2020 audit, the department has produced several tram plans and strategies that include a focus on accessibility. These do not include targets or timeframes and have not been funded.
Out of the department's 10 actions, it has completed 5, partially completed 3 and did not complete 2.
We also assessed if the department's actions addressed our 2020 audit recommendations. We found that most of them did not.
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1. Our key findings
What we examined
Our audit followed one line of enquiry:
1. Has the Department of Transport and Planning implemented the action plan it developed to respond to the 10 recommendations in VAGO's 2020 audit Accessibility of Tram Services and improved compliance with accessibility standards?
To answer these questions, we examined:
- the Department of Transport and Planning (previously the Department of Transport)
- Yarra Trams.
In January 2023, the Department of Transport and Planning replaced the Department of Transport. In this report we use ‘the department’ to refer to the department that was in place at the time.
This review is focused on accessibility for people with mobility restrictions. However, anyone's mobility may be temporarily restricted by an injury, or by travelling with a pram or luggage. Universal design principles recognise that accessible infrastructure benefits everyone.
Identifying what is working well
In our engagements we look for what is working well – not only areas for improvement.
Sharing positive outcomes allows other public agencies to learn from and adopt good practices. This is an important part of our commitment to better public services for Victorians.
Terms used in this report
Recommendations
At the end of an audit or review, we table a report in Parliament that outlines our findings and recommendations to agencies about how they can improve their performance.
We give agencies the opportunity to respond to our recommendations before we table our reports. We publish their responses in our reports. Agencies can accept each recommendation:
- in full
- in part
- in principle
- not at all.
When an agency accepts a recommendation in part, it specifies which part(s) of the recommendation it accepts. When an agency accepts a recommendation in principle, it proposes a different way of addressing the issues identified in the recommendation.
Actions
Along with their response to our recommendations, some agencies also provide an action plan that outlines how they will address each recommendation with target completion dates. Agencies report on progress against each action in our annual Responses to Performance Engagement Recommendations review.
Background information
Melbourne's tram network
Melbourne has the world’s largest tram network. The network covers 250 kilometres and has:
- 486 trams
- 1,628 tram stops
- 23 tram routes (not including the City Circle heritage tourist tram service).
The tram network connects Melbourne’s suburbs to the city. It mainly runs in mixed traffic alongside trucks, cars, pedestrians and cyclists.
The department is responsible for planning, building, operating and maintaining Victoria’s transport and planning system. It oversees the state's public transport operators, including Yarra Trams, and is responsible for providing accessible trams and tram stops.
Yarra Trams is Melbourne's tram network operator and manages day-to-day operations and maintenance.
Legislative requirements for accessibility
The Victorian Government is legally required to provide accessible public transport under:
- the Australian Disability Discrimination Act 1992
- the Victorian Equal Opportunity Act 2010.
The Australian Disability Standards for Accessible Public Transport 2002 (DSAPT) set 31 legally binding accessibility standards for bus, train, tram and ferry services and infrastructure. These standards cover all parts of a transport network including boarding and waiting areas, surfaces, doors and doorways, handrails and grabrails, information and lighting. Not all DSAPT standards apply to the tram network.
The Australian Human Rights Commission can grant temporary exemptions from the Disability Discrimination Act 1992 and DSAPT requirements. The Australian Human Rights Commission can decide whether to grant or reject exemptions, but exemptions are typically granted on the condition that the applicant makes and meets commitments to improve access within a reasonable period.
The Australian Human Rights Commission is responsible for disability discrimination complaints.
Tram network accessibility
From a practical perspective, the most basic requirement for a person with a mobility restriction to catch a tram is the combination of a level-access stop and a low-floor tram available when and where they want to travel.
Where we use the term 'accessible', we mean at a minimum having both a low-floor tram and a level-access stop. This is not always the same as being DSAPT-compliant, which is the government's legislative obligation to provide a network that meets all applicable DSAPT standards.
Figure 1: Components of an accessible tram service
Source: VAGO.
Our 2020 audit
In our 2020 audit we looked at whether tram services were meeting the accessibility needs of passengers with mobility restrictions. We found that:
- the tram network was not meeting the needs of passengers with mobility restrictions
- in 2018–19, only 15 per cent of tram services delivered a low-floor tram at a level-access stop
- the department had not met legislated DSAPT targets for tram infrastructure and could not comply by the 31 December 2022 deadline. It was also at risk of not meeting the 31 December 2032 DSAPT deadline for trams
- the department did not have a finalised strategy or a funded plan to achieve network-wide compliance with the Disability Discrimination Act 1992 and DSAPT. This meant it did not know when all tram services would be fully compliant.
Noncompliance posed a financial and reputational risk for the state due to possible legal rulings against it for not meeting legislative requirements.
What we found
This section focuses on our key findings from this review, which fall into 4 areas:
1. Tram network accessibility has only improved slightly since our 2020 audit.
2. The department cannot accurately measure network compliance with relevant standards.
3. The department's plans and strategies do not include targets or timeframes.
4. The department has improved the way it informs passengers about accessible services, but more work is needed.
We have refined the interactive dashboard we published with our 2020 report and updated the data to 2023–24. The updated dashboard uses the department’s actual tram service runtime data to provide a real-time wait time analysis. This data was not available in 2020. The dashboard is available on our website.
The full list of our 2020 audit recommendations, including the department's action plan, is available in Appendix D.
Consultation with agencies
When reaching our conclusions, we consulted with the audited agencies and considered their views.
You can read their full responses in Appendix A.
Key finding 1: Tram network accessibility has only improved slightly since our 2020 audit
As of March 2025, the department and Yarra Trams have delivered 15 more low-floor trams and 20 more level-access stops across the network since our 2020 audit. This includes 12 level-access stops added since 2023–24.
In 2023–24, 18 per cent of tram services offered a low-floor tram at a level-access stop compared to 15 per cent in 2018–19.
Figure 2: Tram accessibility
 Tram stops with level access |  Trams with low floors | |
|---|---|---|
| In April 2020 | 27% | 38% |
| In March 2025 | 29% | 41% |
| Improvement | 2 percentage points | 3 percentage points |
Source: VAGO, based on department and Yarra Trams data.
Delivery of level-access stops
The department's delivery of level-access stops has slowed since our 2020 audit.
Over the past 10 years, the department has built an average of 8.2 stops per year. This is down from an average of 13.2 stops built each year from 2010 to 2020.
The department's Tram Forward Program shows that, based on currently funded works, the rate of tram stop delivery will not speed up and may slow further over the next 5 years. The majority of network funding and effort will be directed toward the delivery and rollout of Next Generation Trams. In 2022, the Victorian Government invested $1.85 billion to design and deliver 100 Next Generation Trams and a dedicated tram maintenance and stabling facility in Maidstone.
Rollout of low-floor trams
Since our 2020 audit, the department has delivered 15 more low-floor E Class trams, with the 100th and final E Class tram entering service in October 2021.
While all of Melbourne's low-floor tram fleet offers level-access boarding and can be considered broadly accessible for people with mobility restrictions, the existing low-floor C Class, D Class and E Class trams do not fully comply with all relevant DSAPT standards. Next Generation Trams will be Melbourne’s first fully DSAPT-compliant tram model.
To have a fully low-floor tram fleet in service by the 2032 DSAPT milestone, the department needs to replace 286 high-floor trams with low-floor trams within 7 years. To be fully DSAPT compliant, the department would have to replace all trams with Next Generation Trams or another DSAPT-compliant tram model.
On current planning, the department will miss DSAPT’s 2032 deadline.
Wait times for low-floor trams
Users with mobility restrictions typically wait longer for a tram. Our 2020 audit found that in 2018–19, out of 23 routes only 11 were serviced by low-floor trams.
For 2023–24, we found:
- out of 23 routes, 12 were serviced by low-floor trams, which is an increase of one route
- of the 12 routes, 3 routes across the network were fully serviced by low-floor trams
- 9 routes were serviced by a mixture of high-floor and low-floor trams.
This means that a person with a mobility restriction who needs a low-floor tram often needs to wait longer than other passengers if the next scheduled service is a high-floor tram.
We analysed tram service data from 2023–24 and calculated the additional time a person with a mobility restriction requiring a low-floor tram would have waited for a service that met their needs. Passengers on routes 96, 86 and 11 did not need to wait longer for a low-floor tram. On route 72, 56 out of every 100 passengers who needed a low floor tram could not catch the first tram that arrived.
Figure 3: Additional wait time for a low-floor tram on all routes with low-floor trams
Source: VAGO, based on data from the department and Yarra Trams.
Figure 4: Additional wait time comparison between the best and worst performing routes
Source: VAGO, based on data from the department and Yarra Trams.
Key finding 2: The department cannot accurately measure network compliance with relevant standards
Our 2020 audit found that the department did not know when it would achieve full compliance with DSAPT because of limitations in the accuracy, completeness and reliability of its data.
Without being able to quantify the extent of the compliance gap between the current and desired network state, the department cannot make fully informed decisions about planning, prioritising and seeking funding for network upgrades. Based on this, we made 5 recommendations to the department about understanding and addressing the compliance gap.
This review found that the department has missed the 2022 deadline for tram stops and, based on current planning, it will miss the 2032 deadline for trams. Passengers who need accessible stops and trams are still excluded from most of the network.
The department has completed minor upgrades to its DSAPT compliance database for tram stops to address some of the issues we identified in 2020. The database still:
- does not capture data for all applicable DSAPT standards
- only captures DSAPT elements relevant to a stop’s current design (for example, an inaccessible kerbside stop that does not include a ramp is not recorded as needing one)
- does not capture compliance data for trams
- only gets reviewed and updated when a stop is upgraded.
Although the department uses the information currently recorded in its database to inform planning, it does not have a reliable source of information about total network compliance to inform upgrade works or monitor its progress. It cannot produce detailed costings based on the compliance gap and cannot forecast when it will be able to achieve a fully accessible network that meets DSAPT requirements.
Key finding 3: The department's plans and strategies do not include targets or timeframes
Our 2020 audit found the department did not have a clear strategy or plan for delivering accessible trams and tram stops. We made 4 recommendations to the department about planning for and delivering an accessible tram network that meets legislative requirements.
This review found that, 23 years after DSAPT was established, the department still does not have an overarching strategy for how it will deliver an accessible tram network that meets DSAPT requirements.
Tram Stop Rollout Strategy
The department finalised its Tram Stop Rollout Strategy in 2021. It provides:
- a comprehensive plan to upgrade tram stops, including standardised level-access stop designs
- a scalable delivery model
- a prioritisation framework for ranking planned upgrades.
However, the Tram Stop Rollout Strategy does not set a target date to achieve DSAPT compliance or set interim goals or timeframes. It includes a strategic framework outlining objectives and outcomes, but we did not see evidence showing how the department will measure and report on progress. It does not identify accountable business areas for each outcome.
Without specific goals, timeframes, accountable business areas, or funding for its implementation, the Tram Stop Rollout Strategy has not yet meaningfully accelerated the delivery of level-access tram stops or improved accessibility.
Tram Forward Program
The department has also developed other plans and strategies that address different elements of tram network infrastructure and accessibility. This includes the recent internal Tram Forward Program, which brings together the different tram sub-programs for the first time, including the Tram Stop Rollout Strategy. The Tram Forward Program is intended to ensure all areas of the department involved with tram investment are informed and contribute to the program, including future business cases development.
The Tram Forward Program does not establish overarching deadlines or a whole-of-program implementation strategy to achieve DSAPT compliance. It identifies a constrained fiscal environment as one of the main barriers to delivery.
Transport Accessibility Strategic Framework
The department released the Transport Accessibility Strategic Framework in October 2024. People with disability co designed the framework.
The framework sets out the approach the department will take to make public transport more accessible in Victoria. It provides guidance on prioritisation and considers accessibility more broadly than DSAPT compliance. It embeds accessibility considerations across asset planning, design and delivery for all modes of public transport.
The framework does not include funding commitments or set timeframes for achieving DSAPT compliance. However, it may help to support the state’s position in the event its compliance with DSAPT is challenged.
Key finding 4: The department has improved the way it informs passengers about accessible services, but more work is needed
Our 2020 audit found that the department's public information and mobile application (app) did not show accessible service patterns at chosen stops at a particular time or a specified day. Based on this, we made one recommendation to the department about informing the public about accessible tram services.
This review found that accessibility information is integrated into the Public Transport Victoria (PTV) app's journey planning features, but this information is not always timely, reliable or clearly presented.
The PTV app complied with the Victorian Government's minimum digital accessibility requirements at the time of its release. However, the department has not upgraded the PTV app in line with updated Web Content Accessibility Guidelines (WCAG). This means it no longer meets the government's minimum digital accessibility requirements. The department plans to address this in late 2025.
2. Actions' status
Status of the department's actions
In our 2020 audit Accessibility of Tram Services we made 10 recommendations to the then Department of Transport. It accepted 7 in full, 2 in principle and one in part.
The department has completed 5 actions and partially completed 3 actions since 2020. Two actions have not yet been completed.
Figure 5: Status of the recommendations from our 2020 audit
| Recommendation theme | Agency response | Did the department’s action plan address the issue? | Action status | ||
|---|---|---|---|---|---|
| 1 | Legal risk of noncompliance | Accepted | Partially | Complete | |
| 2 | Complete and accurate compliance data | Accepted in principle | No | On track (noting action is still in progress) | |
| 3 | Cost of achieving full compliance | Accepted in principle | No | Not complete | |
| 4 | Aligning DSAPT funding with renewal works | Accepted | No | Not complete | |
| 5 | Making travel planning app accessible | Accepted | Partially | Partially complete | |
| 6 | Cost–benefit analysis of full compliance | Accepted in part | No | Complete | |
| 7 | An overarching plan for DSAPT compliance | Accepted | No | Partially complete | |
| 8 | Prioritising stops for upgrades | Accepted | No | Complete | |
| 9 | Buying accessible trams | Accepted | Partially | Partially complete | |
| 10 | Building accessible stops | Accepted | Partially | Complete | |
Note: Actions in response to recommendation 2 are ongoing.
Source: VAGO.
Our 2020 recommendations, the department's action plan and our conclusions are listed in full in Appendix D.
3. Understanding the compliance gap
In our 2020 report we made 5 recommendations to the department about understanding the extent of work needed to deliver an accessible tram network and the legal risk associated with failing to meet legislative accessibility requirements.
In response to our recommendations, the department committed to completing 5 actions. It has since completed 3 of them.
Covered in this section:
- The department sought legal advice about failing to meet accessibility requirements
- The department made minor upgrades to its compliance database but cannot accurately measure network compliance
- The department cannot quantify the scope of work and cost to close the compliance gap
- The department considered the costs and benefits of improving accessibility
The department sought legal advice about failing to meet accessibility requirements
Action 1
In 2020, we recommended that the department seek comprehensive legal advice and explicitly advise the government on the implications of not meeting DSAPT and other legislative requirements. See Appendix D for the full recommendation.
The department accepted the recommendation and committed to implementing action 1.
| Action 1: Completed | |
|---|---|
Legal advice has been received and the Minister will be briefed in relation to this matter. Due 31 December 2020. | |
Legal advice and ministerial briefing
The department completed its planned action.
The department obtained legal advice in June and July 2020 in response to our audit findings.
The department briefed the Minister for Public Transport in February 2021. The brief contained a summary of the legal advice and did not recommend any action in response.
The legal advice was not comprehensive in nature. It related only to DSAPT obligations and did not consider other legislation that may have been relevant. Accordingly, the department’s action only partially addressed our 2020 recommendation.
The department has noted that its failure to meet DSAPT and other legislative obligations could increase the risk that people with disability make complaints to the Australian Human Rights Commission or Victorian Equal Opportunity and Human Rights Commission.
If a complaint is not successfully resolved, the person making the complaint may take legal action. If a court finds that unlawful discrimination has occurred, the state could be required to pay compensation and fix the issue. Legal action could also harm the state’s reputation.
Managing legal risks
The department’s planning and strategy documents show it acknowledges its noncompliance with DSAPT and is working with people with disability to develop and prioritise a response. These documents include the:
- Transport Accessibility Strategic Framework and its prioritisation method
- Tram Stop Rollout Strategy.
The documents are drafted in a way that does not commit government to defined outcomes.
By proactively engaging with people with disability and its Accessible Transport Advisory Committee, the department can identify and prioritise the issues that impact people with disability the most and build confidence in its response.
It also raises people with disability’s awareness about the department’s operating environment and the factors affecting progress, such as limited funding, to manage their expectations. This may reduce the likelihood of someone lodging a complaint.
The department made minor upgrades to its compliance database but cannot accurately measure network compliance
Action 2
It is important that the department measures and tracks its compliance against DSAPT requirements so it can:
- identify and prioritise tram network upgrades
- take advantage of emerging work programs.
Our 2020 audit found that the department did not know the full extent of its compliance with DSAPT because the accuracy, completeness and reliability of its data was limited.
In 2020, we made one recommendation to the department about upgrading its compliance database so that it could quantify the extent of noncompliance and plan to fix it.
The department accepted the recommendation in principle and committed to implementing action 2.
| Action 2: Completed | |
|---|---|
Enhancements to the reporting from the department’s DSAPT compliance database were initiated in early 2020 and are expected to be completed by the end of the calendar year. Whilst the database has limitations in capturing all of the accessibility features required by the current DSAPT, upgrades will be considered as a future enhancement of our compliance database to align with any changes to the current DSAPT that result from the current modernisation process underway. Due 31 December 2020. | |
Minor database upgrades
The department completed its planned action.
The department completed the planned enhancements to its DSAPT compliance database. It is now able to generate compliance reports for individual stops and can exclude decommissioned stops from reporting.
The department's DSAPT compliance database still has limitations that impact the completeness, accuracy and reliability of its data. This means the department’s action has not addressed our 2020 audit recommendation.
The department told us it will not do further upgrades until the Australian Government has concluded the ongoing DSAPT reform process.
In our 2024 Reponses to Performance Engagement Recommendations review the department extended the deadline to complete the action to 30 June 2025. The DSAPT reform process is ongoing, so this revised deadline has not been met.
The department’s compliance database
Due to its limitations, the database cannot be used to accurately assess the compliance gap for a stop, route, tram or the network. The department’s database still:
- does not capture data for all applicable DSAPT standards
- only captures DSAPT elements that are part of a stop’s current design (for example, an inaccessible kerbside stop that does not include a ramp is not recorded as needing one)
- does not capture compliance data for trams
- only gets reviewed and updated when a stop is upgraded.
This means the data in the department’s database is still not complete, accurate or reliable. The department cannot use this information to:
- develop detailed costings based on the compliance gap
- forecast when full network compliance will be achieved
- monitor progress towards full compliance.
The department uses the information currently recorded in the database to inform network planning. The department is also working on a prioritisation method for tram stop upgrades, which will be able to generate more accurate and up-to-date lists of stop upgrade opportunities.
Progress in DSAPT compliance
DSAPT requires that all stops be fully compliant by 31 December 2022. The information in Figure 6 shows how the department records its compliance levels, and the progress made since the 2020 audit.
Some data is missing given the limitations of the department's database.
Figure 6: Tram stop DSAPT compliance
| Standard | Does the department track this? | Compliance April 2020 (%) | Compliance March 2025 (%) | Change (percentage points) |
|---|---|---|---|---|
| 2 Access paths | In part | 63 | 66 | +3 |
| 3 Manoeuvring areas | In full | 93 | 90 | -3 |
| 4 Passing areas | In full | 74 | 76 | +2 |
| 5 Resting points | In part | 35 | 35 | 0 |
| 6 Ramps | In part | 6 | 14 | +8 |
| 7 Waiting areas | In part | 35 | 36 | +1 |
| 8 Boarding | In part | 54 | 58 | +4 |
| 9 Allocated space | In full | 61 | 63 | +2 |
| 10 Surfaces | In full | 86 | 86 | 0 |
| 11 Handrails and grabrails | In part | 22 | 28 | +6 |
| 12 Doorways and doors | Not applicable | Not applicable | Not applicable | Not applicable |
| 13 Lifts | In part | 0 | 0 | 0 |
| 14 Stairs | In part | 1 | 6 | +5 |
| 16 Symbols | In part | 97 | 97 | 0 |
| 17 Signs | In part | 16 | 20 | +4 |
| 18 Tactile ground surface indicators | In part | No data | 14 | Not applicable |
| 19 Alarms | Not applicable | Not applicable | Not applicable | Not applicable |
| 20 Lighting | Not tracked | No data | No data | No data |
| 21 Controls | Not tracked | No data | No data | No data |
| 22 Furniture and fitments | Not tracked | No data | No data | No data |
| 23 Street furniture | In part | 76 | 78 | +2 |
| 24 Gateways | Not tracked | No data | No data | No data |
| 25 Payment of fares | In part | 94 | 94 | 0 |
| 26 Hearing augmentation-listening systems | Not tracked | No data | No data | No data |
| 27 Information | Not tracked | No data | No data | No data |
Note: Where a standard is tracked in part, the percentage is calculated against the tracked components only. Change is calculated against standards already tracked in April 2020.
Source: VAGO, based on department information.
The department cannot quantify the scope of work and cost to close the compliance gap
Actions 3 and 4
To effectively plan for a fully accessible and DSAPT-compliant tram network, the department needs to know:
- how much of the network is currently noncompliant with DSAPT
- how much it will cost to upgrade or replace noncompliant tram stops and trams.
An effective plan would also allow the department to align funded DSAPT compliance upgrades with other planned works to maximise efficiency and minimise disruption to the community.
In 2020, we made 2 recommendations to the department about understanding the accessible infrastructure gap. The full recommendation is available in Appendix D.
The department accepted one recommendation in principle and one in full. It committed to implementing actions 3 and 4.
| Action 3: Not completed | |
|---|---|
A strategy to address existing, already identified, non-compliance will be included as part of the Tram Stop Rollout Strategy, however the identification of non-compliance not yet identified does not sit within this scope. Therefore, any further existing non-compliance will need to be identified as part of a separate process which will require funding. The Strategic Advisor and Design Advisor appointed as part of the Stop Rollout Strategy will be assessing the scope of technical engineering required to deliver DSAPT compliance across the whole network, and high-level estimates of the cost of implementation. The Tram Stop Rollout Strategy will provide an order of magnitude costs to complete network wide upgrades, based on different delivery approaches. However, detailed engineering assessment will not form part of the scope of this work. Engineering assessments will be completed as part of any funded development for tram stop upgrades to be delivered. Due 30 June 2022. | |
| Action 4: Not completed | |
|---|---|
Aligning accessibility upgrade works with planned, funded renewals is currently a process the Department has been improving. The Tram Stop Rollout Strategy will also consider how to best align these works. Due 30 June 2021. | |
Understanding compliance gaps
The department did not complete its planned actions.
Due to the limitations of its compliance database, the department cannot know the full extent of DSAPT noncompliance or the full scope and cost of work needed to fix it.
As a result, action 3 only committed to producing a strategy to address noncompliance the department already knew about. This did not address the issues our 2020 recommendation identified.
The Tram Stop Rollout Strategy
The Tram Stop Rollout Strategy is the department's internal strategy for delivering accessible tram stop infrastructure. It is not an overarching plan to achieve DSAPT compliance for the tram network and does not set any deadlines for achieving DSAPT compliance.
Technical review to inform costings
The department does not do detailed engineering assessments and cost estimates until a tram stop corridor is included in a business case.
The Tram Stop Rollout Strategy includes an overall estimate of capital and operating costs to implement the full strategy. It does not include an option that only addresses DSAPT compliance.
This means we did not see evidence the department assessed the scope of technical engineering required to make the whole tram network DSAPT compliant.
Enhanced renewals
Recommendation 4 intended to make sure that any funding allocated to increase DSAPT compliance could maximise value and minimise disruption by aligning it with other planned works.
The department did not provide any evidence of funding allocated only to increase DSAPT compliance.
Yarra Trams is required to have a franchise infrastructure management plan, which outlines how the department will maintain existing tram network infrastructure.
The department and Yarra Trams identify 'enhanced renewal' opportunities in which maintenance works required under the franchise infrastructure management plan are 'enhanced' to include DSAPT compliance and safety upgrades.
Completing accessibility and safety upgrades alongside maintenance reduces costs and service disruption. However, enhanced renewals can only be completed when opportunities arise. They cannot generate the scope or pace of change needed to deliver an accessible tram network that meets DSAPT requirements.
The department considered the costs and benefits of improving accessibility
Action 6
It is important that the department understands the costs and benefits of tram network upgrades to brief the government and inform future planning. This includes economic and social benefits.
Our 2020 audit found no evidence that the department had formally considered any potential social benefits that might accrue from a DSAPT-compliant tram infrastructure investment program.
In 2020, we made one recommendation to the department about understanding costs and benefits. The full recommendation is available in Appendix D.
The department partially accepted the recommendation and committed to implementing action 6.
| Action 6: Completed | |
|---|---|
While an extensive cost benefit analysis of all tram stops requiring upgrades is not currently in the scope of the Tram Stop Rollout Strategy, the Department acknowledges it has a legal obligation to provide accessibility across the tram network. Nevertheless, the Department is refining our current stop prioritisation framework to identify what stops on the network should be upgraded first and then continuing prioritisation, based on a range of factors. The Tram Stop Rollout Strategy will support determining any rationalisation requirements of existing tram stop locations. As part of Business Case submissions to the Government to fund the upgrade of network infrastructure to comply with DSAPT standards, the Department is required to include a cost benefit analysis that aligns with the Department of Treasury & Finance guidelines. The guidelines require the Department to demonstrate the impact of the investment on the safety of passengers/network, network performance, socioeconomic and environmental benefits. Ongoing. | |
Cost-benefit analysis
The department completed its planned action. It commissioned an economic outcomes report to feed into the future program business case for the unfunded Tram Stop Rollout Strategy. The economic outcomes report was not comprehensive and so it did not address our 2020 recommendation.
The approach included developing and testing methodology with the Department of Treasury and Finance.
The economic outcomes report includes:
- high-level cost–benefit analysis
- qualitative analysis of economic benefits
- exploration of social, environmental and wider economic benefits.
The report explicitly acknowledges that improving accessibility has the potential to generate significant economic benefits for the community. It identifies this as the basis of the investment case for upgrading the tram network.
The department lodged a successful bid in the 2022–23 state Budget cycle for funding to develop 4 tram stop corridors and received $5.5 million. Based on the evidence assessed, nothing came to our attention to suggest that the department did not use a cost–benefit analysis that aligned with Department of Treasury and Finance guidelines.
Rationalising tram stops
The Tram Stop Rollout Strategy includes a plan to rationalise tram stop locations by relocating stops to achieve more uniform spacing and removing some underused stops. This addressed the department’s action. The Tram Stop Rollout Strategy notes that stops’ close spacing is inefficient and creates challenges such as slow travel speeds and conflicts with other forms of transport. The Tram Stop Rollout Strategy recommends one of 4 actions for each stop:
- no action needed
- upgrade in place
- relocate and upgrade
- remove.
Any stop recommended for upgrading would be replaced by a DSAPT-compliant stop.
If the Tram Stop Rollout Strategy is delivered as written, around 25 per cent of stops across the network would be removed. The Tram Stop Rollout Strategy delivery has not yet been funded.
Any changes to the number or location of tram stops would be subject to consultation with the community and local councils.
The department’s plan did not include a full cost–benefit analysis and so it did not address our 2020 recommendation.
4. Planning for network-wide compliance
In our 2020 report we made 4 recommendations to the department about planning and delivering an accessible tram network that meets DSAPT requirements.
The department committed to completing 4 actions in response to our recommendations.
We found it has completed 2 actions. Two actions relating to the department's overarching plan and procurement of low-floor trams are still in progress.
Covered in this section:
- The department developed plans and strategies to address different network accessibility elements
- The department’s framework for prioritising network upgrades did not specifically consider people with mobility restrictions
- The department has not linked new low-floor tram procurement to stop upgrades
- The department developed standardised tram stop designs but has not yet streamlined delivery
The department developed plans and strategies to address different network accessibility elements
Action 7
Without a unified accessibility strategy for tram infrastructure and rolling stock, the department cannot know how or when it will be able to achieve compliance with DSAPT requirements.
Our 2020 audit found that the department did not have a clear and consistent strategy for delivering a DSAPT-compliant tram network.
We made one recommendation to the department about developing an overarching plan for the tram network that explicitly links to DSAPT compliance dates and accessibility outcomes. The full recommendation is available in Appendix D.
The department accepted the recommendation in full and committed to implementing action 7.
| Action 7: Partially completed | |
|---|---|
The Tram Stop Rollout Strategy will specify goals and timeframes within relevant areas of the Department and Yarra Trams. The prioritisation framework includes consideration of low-floor rolling stock on a given corridor in determining the level of priority of a given stop in being upgraded to provide level access. There are numerous considerations required when delivering rolling stock across the network including depot capacity and locations. In addition to accessibility, these considerations must be included in the timing and delivery of both rolling stock and of level-access tram stop upgrades. This is matched as far as possible and we are looking to improve on this further. We are currently engaging with a range of stakeholders on a Lessons Learned process, which will feed into the Tram Stop Rollout Strategy—this is the first step of our engagement with key stakeholders which will include councils and advocacy groups. Due 31 December 2021. | |
Planning and strategy documents
The department has partially completed its planned action.
Action 7 states that the Tram Stop Rollout Strategy will address the risks our 2020 audit recommendation sought to address by specifying goals, timeframes and the responsible areas of the department and Yarra Trams. It does not include this information.
It covers tram stop infrastructure but not trams or how to best allocate low-floor trams to maximise accessibility across the network. Without this, it is not a network-wide strategy.
Rather than producing one overarching plan to achieve an accessible and DSAPT-compliant tram network, since 2020 the department has developed several plans and strategies that address different elements of network accessibility. These plans still do not fully address the issues our 2020 audit identified or set deadlines for achieving accessibility.
Set up in January 2025, the department’s Tram Forward Program is a forum which brings together the program areas responsible for different tram network initiatives. Each initiative, such as the Tram Stop Rollout Strategy, forms a sub-program.
The Tram Forward Program creates a reference point for all sub-program areas to share information and create opportunities to streamline activities, such as the development of business cases for future funding. It is not a decision-making body. It does not set an overarching strategy or prioritise between the different sub-programs.
The department decided not to include defined outcomes or set deadlines for accessibility improvements in the Transport Accessibility Strategic Framework, at one point changing the strategy to a strategic framework to manage expectations.
The department was aware of some of the risks associated with this approach, including feedback on the draft strategic framework from consultations with people with accessibility needs that it did not deliver concrete actions or fund investment to meaningfully address DSAPT compliance.
We have concluded action 7 did not address the issues our 2020 recommendation identified.
| Documents include ... | from ... | which ... |
| the Tram Stop Rollout Strategy | 2021 | is the department's internal strategy for delivering accessible tram stop infrastructure. |
| the Made in Victoria for Victoria – Victorian Rolling Stock Strategy | 2022 | is a public document that outlines the Victorian Government's plan for future rolling stock (including trams). |
| Melbourne's Tram Plan | 2023 | is a public document describing the department's overarching strategy for the future of Melbourne's tram network at a high level. |
| the Transport Accessibility Strategic Framework | 2024 | is a public document outlining the department's approach to addressing accessibility gaps and improving transport experiences for everyone, in line with universal accessibility goals. |
| the Tram Forward Program | 2025 | brings all the department's current tram system initiatives together to share information and streamline the development of business cases. |
No target date for DSAPT compliance
The Tram Stop Rollout Strategy recognises that the department has a legislative obligation to provide an accessible tram network that meets Disability Discrimination Act 1992 and DSAPT requirements. It also acknowledges that the department will miss the 2022 DSAPT compliance deadline for tram stops.
It does not set a new timeline to achieve a fully DSAPT-compliant tram network.
Without a clear target date, the department cannot effectively plan network upgrades, allocate resources or track and report on progress. This also makes it difficult for the public to hold the government to account for its performance.
No set goals or timeframes
The Tram Stop Rollout Strategy does not set interim goals or timeframes for delivering tram stop upgrades. Without clear goals or timeframes to work towards, the department cannot effectively plan network upgrades, allocate resources or track and report on progress.
The Tram Stop Rollout Strategy included an example delivery scenario program showing how all tram stops across the network could potentially have been upgraded to level-access over a 10 year period to 2032.
Given that as of 2025 the government has not approved funding to deliver the Tram Stop Rollout Strategy, the example delivery scenario could no longer be achieved by 2032.
Lack of clear measures and accountabilities
The Tram Stop Rollout Strategy includes a strategic framework that sets out:
- an overarching vision statement
- 6 strategic objectives
- 15 outcomes, 2 of which relate to accessibility.
The outcomes are designed to be measurable so that the department can track its progress. But we did not see any evidence of how the department intends to measure or report on its outcomes.
The Tram Stop Rollout Strategy does not specify which business areas are accountable for each outcome. This makes it difficult to identify who in the department is responsible for ensuring the outcomes are achieved.
The Tram Stop Rollout Strategy has not been implemented
The Tram Stop Rollout Strategy has not meaningfully accelerated delivering level-access tram stops or improved accessibility outcomes. This is because it does not have:
- specific goals and timeframes
- identified accountable business areas
- funding for its implementation.
Some elements of the Tram Stop Rollout Strategy are designed to be flexible to allow the government to decide how to upgrade the remaining non-level-access tram stops based on funding availability and timing.
Other elements rely on a particular pace and scale of delivery to be implemented as planned.
For instance, the Tram Stop Rollout Strategy considered seeking state-level approval for the project as one entire program of works to streamline approval processes.
If the government does not approve funding for the project as one entire program of works, the state-level approval pathway cannot be implemented as proposed.
This means the department needs to seek separate approvals for each individual corridor or tram stop, which may slow delivery.
Scalable delivery framework
The Tram Stop Rollout Strategy introduces a scalable delivery model that groups stops into corridors and corridors into packages. Delivering a group of stops together means that design work, planning approvals, consultation and delivery can happen at the same time.
The Tram Stop Rollout Strategy shifts more of the responsibility for identifying and completing stop upgrades from Yarra Trams to the department. This allows the department to take a more strategic approach to network upgrades.
Yarra Trams still completes tram stop upgrade works on behalf of the department when needed.
In the scalable delivery model, the department is responsible for procuring and managing contractors to deliver packages.
The Tram Stop Rollout Strategy considered the suitability of various delivery models but did not include costings.
Figure 7: The department's corridor approach
Source: VAGO, based on information provided by the department.
Considering broader operational issues
The Tram Stop Rollout Strategy does not explicitly address the impact of depot and other operational limitations on the department and Yarra Trams’ ability to match level-access stops to low-floor trams.
The department allocates trams to routes through a separate process outlined in the Tram Cascade Plans. This process considers accessibility as one of 5 underpinning principles, alongside:
- capacity
- capital investment
- operational cost
- operational integration.
In July 2025, the department finalised its internal Tram Stabling and Maintenance Strategy. The strategy looks at the capacity of depots across the network to stable the new low floor trams. It shows that the planned Maidstone Depot development and Brunswick Depot upgrades will create sufficient stabling capacity to phase out all high-floor trams by 2034.
The planned rollout of new low–floor trams shows that they are mostly allocated to routes based on depot stabling capacity, not proportion of level-access stops on a given route.
Stakeholder consultation and user research
As set out in its action plan, the department sought stakeholder engagement at key times. This is reflected in the final Tram Stop Rollout Strategy.
The department consulted with its Accessible Transport Advisory Committee 4 times between October 2020 and November 2021.
The department did user research to understand how people use tram stops. This mostly involved:
- video-based interviews
- walk-throughs of tram stops
- online surveys
- focus groups.
The department also did observational research to validate user behaviour in a real-world context. The department adapted how it consulted with people with disability to be more accessible.
The department also held workshops with subject-matter experts and the Office of the Victorian Government Architect and made design changes in response to issues found during consultation.
The department’s framework for prioritising network upgrades did not specifically consider people with mobility restrictions
Action 8
It is not possible to upgrade all relevant tram stops at the same time without significant disruption. Therefore, the department needs to be able to identify which upgrades are the most important based on user and network needs.
Our 2020 audit found the department had developed a draft framework for prioritising tram stop upgrades. It used this framework on an ad hoc basis to help develop business cases rather than to explicitly advise the government with a priority list for level-access tram stop upgrades.
We made one recommendation to the department about enhancing its existing stop prioritisation framework. The full recommendation is available in Appendix D.
The department accepted the recommendation in full and committed to implementing action 8.
| Action 8: Completed | |
|---|---|
The existing tram stop prioritisation framework is undergoing updates as part of the Tram Stop Rollout Strategy. Additional refinement and updates of the prioritisation framework, including application to the entire tram network, will occur as part of finalising this strategy. Due 31 December 2021. | |
The prioritisation framework
The department has completed its planned action.
The department developed a prioritisation framework that assigns stops or corridors a score across 4 categories:
- movement
- place
- safety
- accessibility.
Scores for each category are weighted evenly but weighting can be adjusted to prioritise place, safety or accessibility. Each category is broken down into several criteria and scored on a scale from 10 (high priority) to zero (low priority).
| Under 'accessibility', the criteria 'low floor trams' assigns a score of … | to ... |
|---|---|
| 10 | a stop or corridor fully serviced by low-floor trams. |
| 5 | a stop or corridor partially serviced by low-floor trams. |
| 0 | a stop or corridor not serviced by low-floor trams. |
Other criteria scores and weighting considerations aside, this would rank a non-level stop serviced by low-floor trams higher than a non-level stop serviced by high-floor trams.
As one of up to 18 equally weighted sub-criteria, a high score is unlikely to have a significant impact on a stop or corridor's overall priority ranking.
The department considers a stop or corridor's ranking when making decisions about how to prioritise upgrades. A high ranking does not guarantee a stop or corridor will be upgraded sooner.
Considering passengers with mobility restrictions
The prioritisation framework considers several criteria within each category. For instance, it looks at:
- whether there are currently low-floor trams on the route
- whether there is a school nearby
- how many people currently use the stop per day.
The accessibility category adds 5 points to a stop's score for its proximity to each aged care facility, disability centre or specialist school.
While this identifies destinations that would expect to attract a higher-than-average number of people with disability, it does not consider the accessibility of the tram stops people would use to board the tram.
It also does not consider the possibility that a person with a mobility restriction may wish to use a tram to travel to a shopping centre, an art gallery, or to visit a family member.
Key issue: The prioritisation framework does not explicitly consider people with mobility restrictions
The prioritisation framework considers passenger numbers as a criterion under the ‘movement’ category. It uses the current number of passengers using a stop per day (ranging from 50–100 as low priority, to 18,000–20,000 as high priority). It also uses a forecast increase of passengers per stop per day (ranging from 25–50 as low priority, to 9,000–10,000 as a high priority).
The department has not provided any evidence showing that people who are currently excluded from the tram network due to a lack of accessibility have been considered as a specific cohort in these passenger numbers. This creates a risk that decisions to prioritise upgrades are made after only taking into account passengers who use the service now and do not consider people who would like to but cannot because the service is inaccessible for them.
Data not updated regularly
Our 2020 recommendation aimed to make sure the prioritisation framework:
- drew on accurate, current data
- was regularly reviewed and updated.
The prioritisation framework and list of prioritised corridors have not been updated since 2020. Based on this, the department’s action did not address the issues our 2020 recommendation identified.
Most data captured in the prioritisation framework is relatively static and easily tracked. Only passenger numbers and safety may be expected to change at short notice in response to external factors.
The department is in the process of updating the prioritisation framework and expects this work to be completed by the end of 2025.
The updated prioritisation framework will account for new data sources for passenger numbers through:
- automatic passenger counters on a significant proportion of the tram fleet
- government’s change to housing and suburban development though the Activity Centre Program.
Working well: The department's prioritisation method
As part of the Transport Accessibility Strategic Framework, the department is adapting its prioritisation method for the train network to the tram network.
The method ranks instances of DSAPT noncompliance based on how much they impact people with disability. It uses 5 impact ratings:
1. Safety critical: A serious safety risk
2. Absolute barrier: An absolute barrier to use for some people
3. High impact: Issues where the stop can be used, but it may require extraordinary levels of effort to do so
4. Medium impact: Issues where the stop can be used even though it might require significant effort
5. Minor impact: Issues where the stop is relatively easily used even though it does not technically meet required standards such as DSAPT.
Once the method has been adapted to trams, the department will be able to use it to identify the most impactful upgrades for people with disability.
The department has not linked new low-floor tram procurement to stop upgrades
Action 9
While level-access tram stops offer some individual benefits, a tram user with a mobility impairment requires both a low-floor tram and a level-access stop to get on or off a tram. This means matching delivery of level-access stops and low-floor trams is necessary to maximise the benefits of upgrades.
Our 2020 audit found that the department was at risk of not meeting the 31 December 2032 compliance date for trams.
We made one recommendation to the department about standardising tram vehicle requirements and linking procurement to stop upgrades. The full recommendation is available in Appendix D.
The department accepted the recommendation and committed to implementing action 9.
| Action 9: Partially completed | |
|---|---|
The Victorian Rolling Stock Strategy covers all rolling stock requirements across Victoria’s metropolitan, regional and tram networks. Whilst a tram-specific rolling stock plan is not in place, the Tram Stop Rollout Strategy will deliver the plan for the upgrade of the infrastructure. Rolling stock delivery and stop upgrades/improvements will be integrated and continues to be matched for timing of delivery as best as possible. There is already a high level of standardisation of rolling stock vehicles for the Melbourne tram network, and the Department, together with the franchisee, continues to review and update standards in line with changes to the network, operations, and industry best practice. As part of a rolling stock procurement there is extensive assessment of both existing international vehicle platforms in the market and market ability to deliver a vehicle that meets the Melbourne network’s requirements to ensure passengers receive the best possible performance and value for money outcomes. This is also in line with the State’s procurement policies and the Department’s due diligence requirements for any proposed new procurement. Due 31 December 2021. | |
Standardised tram vehicle requirements
The department has partially completed its planned action.
In 2022, the Victorian Government invested $1.85 billion to deliver 100 Next Generation Trams and a dedicated tram maintenance and stabling facility in Maidstone. Next Generation Trams is the name given to Melbourne’s next tram model. The first Next Generation Trams are expected to arrive on the Melbourne network for testing in 2025.
Next Generation Trams are considered the future of tram rolling stock for Melbourne's tram network. The Next Generation Trams design is fully DSAPT compliant.
The department reviewed and updated tram standards as part of the Next Generation Trams procurement. All DSAPT criteria for vehicles are specified requirements in the Next Generation Trams contract. The department and an independent party both then assess and verify compliance.
Matching low floor tram rollout and stop upgrades
The Tram Stop Rollout Strategy considers the need to match delivery of low-floor trams and level access stops. However, this is outweighed by existing network and depot limitations and other operational demands. The department’s action only partially addressed the issues our 2020 recommendation identified.
The Tram Forward Program is the department's internal program bringing together all current tram system initiatives. The Tram Forward Program acknowledges that the current program does not include an option to make sure rollout of low-floor trams is matched with level-access tram stops.
This means the deployment of first tranche of Next Generation Trams will happen on routes with limited level-access stops and will not materially improve accessibility until stops are upgraded. The department received funding to upgrade stops on the Droop Street corridor on route 82 in the 2025–26 State Budget.
The department developed standardised tram stop designs but has not yet streamlined delivery
Action 10
The department needs to deliver level-access tram stops rapidly to meet DSAPT requirements and improve accessibility for tram users.
Our 2020 audit found that the department did not have a standardised design approach for accessible tram stops, and delivery of level-access stops had slowed over the last decade.
We made one recommendation to the department about standardising design and streamlining delivery of level-access tram stops. The full recommendation is available in Appendix D.
The department accepted the recommendation and committed to implementing action 10.
| Action 10: Completed | |
|---|---|
The Tram Stop Rollout Strategy is undertaking workshops that will identify if any local planning approvals have had an impact to the process in previous projects and will consider any planning scheme amendments that may be appropriate. The Department undertakes extensive and broad stakeholder consultation for individual stops that are funded for development and subsequent delivery. The Tram Stop Rollout Strategy is developing level access design options which will include costings and timeframes to deliver each option. Options are being explored as part of the TSRS development for various delivery mechanisms including engaging with other delivery agencies on practices and process to provide cost and time effective solutions. Due 31 December 2021. | |
Impact of planning approvals
The department completed its planned action.
When developing the Tram Stop Rollout Strategy, the department carried out desktop analysis, case studies and a series of expert and stakeholder interviews to understand the impact of planning approval processes on its ability to deliver tram stop upgrades.
It did not consider how forecasting potential construction would allow earlier stakeholder consultation and planning. Based on this, the department’s action only partially addressed the issues our 2020 audit recommendation identified.
The Tram Stop Rollout Strategy considered but did not propose any planning scheme amendments based on this work. However, it identified an opportunity to streamline delivery through planning scheme changes introduced in 2021. This option has not been exercised to date.
Stakeholder consultation for funded upgrades
The department did community consultation to inform planning and development for the Thornbury, Fitzroy and Footscray corridor upgrades, which were funded in the 2022–23 state Budget. This involved engaging with the community and local businesses to work out preferred tram stop designs and locations.
The department is using the Thornbury, Fitzroy and Footscray corridor upgrades as a ‘pilot’ and intends to use a similar stakeholder consultation approach for future corridor upgrades. This shows a consistent consultation approach for tram stop upgrades completed as part of the Tram Stop Rollout Strategy.
Standardised level-access stop designs
The department developed a suite of 18 level-access tram stop designs that can be applied to suit a variety of road contexts. Seventeen out of the 18 designs fully comply with DSAPT requirements, while the remaining design is noncompliant on one standard.
These designs are also accompanied by a 'kit of parts' to simplify providing elements such as seating, lighting and shelter. The kit of parts also includes some elements needed to achieve DSAPT compliance, such as tactile ground surface indicators and passenger information displays.
Working well: The department developed standardised level-access stop designs
This work will enable the department to accelerate the delivery of level-access tram stops across the network by reducing the need for detailed design work each time a corridor is funded for delivery.
Estimated cost and timeframes
The Tram Stop Rollout Strategy contains high-level cost and time estimates, but these do not include specific costings and timeframes to deliver each option. This did not address the issues identified in our 2020 recommendation.
While the department developed an initial cost estimate based on a 9-year rollout period to 2030, this estimate can no longer be considered current or reliable given implementation delays.
Exploring delivery models
The department explored various delivery models for the Tram Stop Rollout Strategy. It carried out interviews and workshops with internal and external stakeholders from the department, Yarra Trams and the Major Transport Infrastructure Authority.
Based on this, the Tram Stop Rollout Strategy identified a shortlist of potential delivery models.
Tactical delivery approaches
Our 2020 audit found that the department had not yet explored using tactical delivery approaches or construction innovations such as modular or offsite fabrication. These could reduce costs and speed up installation of level-access tram stops.
As part of the Tram Stop Rollout Strategy development, the department explored using temporary or quick-build interventions to temporarily upgrade stops until more permanent infrastructure could be delivered.
The department developed a series of tactical tram stop designs to suit different road network configurations. None of the proposed designs offered level-access and none could not achieve DSAPT compliance. These designs have not been tested in a real-world setting.
5. Public information about accessible services
In our 2020 report we made one recommendation to the department about informing the public about accessible tram services.
The department committed to completing one action in response to our recommendation.
We found it has partially completed this action. The department still needs to improve the timeliness, reliability and clarity of information and make sure it complies with current minimum digital accessibility requirements.
Covered in this section:
The department focused on improving its PTV app accessibility instead of improving tram accessibility information
Action 5
Our 2020 audit found that the department and Yarra Trams' public information and apps (PTV Journey Planner and TramTRACKER) did not show accessible service patterns at chosen stops at a particular time or a specified day.
We made one recommendation to the department about providing public information on network accessibility, including by stop, route and scheduled service.
The department accepted the recommendation in full and committed to implementing action 5.
| Action 5: Partially completed | |
|---|---|
The Department of Transport’s digital journey planning tools are currently undergoing a major uplift. In late 2020, the fully accessible next generation PTV app will be released, granting our accessibility community access to the same journey planning features as our other customers, including real time travel and disruption information. Accessibility is and will continue to be shown within the limits of current operational data. Due 31 December 2020. | |
As our recommendation was made to the department, this review focused solely on the PTV app, which the department manages.
Accessibility of the Next Generation PTV app
The department has partially completed its planned action.
The department released the Next Generation PTV app in October 2020.
Prior to October 2020, digital accessibility features were offered in a separate app called PTV ScreenReader. PTV ScreenReader was an accessible, ‘light’ version of the legacy PTV app and was decommissioned in 2021.
The Next Generation PTV app was developed to integrate accessibility features and enable all customers to use the same app, regardless of digital accessibility requirements.
An accessible app versus an accessible journey
Our recommendation identified that passengers need to be able to identify accessible features when planning their journeys. These include:
- if a stop is level access or not
- if the scheduled tram is low floor or high floor.
This is important as passengers who need an accessible low-floor tram will typically wait longer for a tram than a passenger who can catch a high-floor tram.
Our recommendation did not talk about making sure the app itself was accessible, such as for people who rely on screen readers.
But the department's response focused on improvements to the accessibility of the app rather than the information available about accessible stops and trams. The means the action partially addressed the issues our 2020 audit recommendation identified.
Compliance with digital accessibility standards
The Web Content Accessibility Guidelines (WCAG) are a set of international standards that define how to make web content more accessible to people with disability.
The Next Generation PTV app complies with the WCAG 2.0 Level AA standard. At the time the app was released, this was the minimum accessibility requirement for Victorian Government content.
The Victorian Government’s minimum digital accessibility requirements have since been updated. It now requires that all government digital content and websites must, at a minimum, meet the current WCAG version Level AA. As of January 2025, this is WCAG 2.2.
The department provided a technical evaluation report and supporting documentation for the Next Generation PTV app. It showed that it meets 48 out of 50 WCAG 2.1 AA success criteria. This means it does not fully comply with the WCAG 2.1 AA standard and does not meet the government's current minimum WCAG 2.2 AA requirement.
The department has included the remaining 2 success criteria in a backlog for future development and plans to address these in late 2025.
Real-time travel and disruption information
The PTV app enables live vehicle tracking and provides real-time travel and disruption information. This allows users to view how far away a service is and receive timely information about service disruptions.
Information about accessible services
A person who needs to plan an accessible journey cannot rely on being able to catch the next tram that arrives or that the nearest stop is level. This means it is important that the department's PTV app shows if a scheduled service is low floor or not.
This allows tram users to avoid long wait times by timing their arrival at a level-access tram stop for when the next low-floor tram is due to depart.
In 2020 when the Next Generation PTV app was released and the department reported its action as complete, it was not possible to view if a tram was low floor or high floor. In July 2022, the department updated the app to allow users to view if an approaching tram is low floor and filter by accessible services.
While a low-floor tram is indicated by a blue wheelchair icon and accompanying text, a high-floor tram is only indicated by the lack of a wheelchair symbol (Figure 8).
Due to data limitations, a user still cannot view if a tram several hours into the future will be accessible or not. Because the PTV app does not use an icon or label to indicate a high-floor tram, app users cannot know if the accessibility information for a future service is blank because it will be a high-floor tram, or because the information is not available yet.
Figure 8: Screenshot from the PTV app
Notes: Screenshot taken on 16 September 2025 at 10.40 am. The user selected stop number 20 Coppin St/Bridge Rd in Richmond and viewed upcoming services towards North Balwyn.
Source: PTV app and VAGO.
Reliability of journey-planning features
Our testing showed that accessibility information is included in the PTV app's journey-planning features, but this information is not always reliable or clearly presented.
PTV app users can turn on an accessibility filter to display only low-floor trams and level-access stops. When used with the journey-planning feature, this allows app users to view services that are a combination of low-floor trams and level-access stops.
Information about if a scheduled tram is low floor cannot be viewed more than 2 hours into the future due to data limitations. This means a person with a mobility restriction cannot plan an accessible tram journey more than 2 hours in advance.
Our testing also identified several glitches in which the PTV app would sometimes display inaccessible trams or routes even when accessibility filters were turned on.
The department told us this is a known issue that occurs due to operational data constraints. The department plans to address the issue through improving data capability but did not provide a timeframe for when it would be resolved.
Working well: Information sharing with third-party apps
Since December 2023, the department has made real-time data for tram services openly available to third-party app developers. This allows third-party apps such as Google Maps and Apple Maps to provide more detailed and accurate journey-planning features.
In March 2025, the department made changes to its open data schedule dataset to provide more accurate information about tram services that terminate early.
These changes improve the accuracy of third-party journey-planning tools and give passengers more information to help plan a tram journey.
Appendix A: Submissions and comments
Download a PDF copy of Appendix A: Submissions and comments.
Appendix B: Abbreviations, acronyms and glossary
Download a PDF copy of Appendix B: Abbreviations, acronyms and glossary.
Appendix C: Review scope and method
Download a PDF copy of Appendix C: Review scope and method.
Appendix D: Recommendations and actions' status
Download a PDF copy of Appendix D: Recommendations and actions' status.
Appendix E: Data analytics methods and other technical information
Download a PDF copy of Appendix E: Data analytics methods and other technical information.
Download Appendix E: Data analytics methods and other technical information