November 14, 2025
To whom it may concern,
RE: Review of the Disability Discrimination Act (1992):
Disability rights linked to better access and voice in community broadcasting.
The review of the Disability Discrimination Act (1992) is of concern to community broadcasting because of the role the sector plays in creating connections in communities through giving a voice to the diverse social groups in Australian society. The sector includes over 500 community radio stations throughout Australia, with thousands of volunteers. Almost one quarter of Australian radio listeners choose community broadcasting for its recognition of local voices, issues and communities not given recognition in the mainstream media, including the 21.4% of Australians with disability (Australian Bureau of Statistics, 2024). This role as a public voice for communities is important for the rights of people with disability.
The community media sector embraces leadership in affecting attitude change through better representation and increasing participation of people with disability. The sector has not been free of poor attitudes towards people with disability and is working to change that. People with disability who volunteered and worked in community broadcasting had experiences of attitudinal barriers to their participation that sometimes reflect wider attitudes of Australian society. For instance, one participant recounted a high-profile musician making fun of his speech during an on-air interview, while others noted long delays and obstacles to their training to be permitted to be on-air, sensing their right to participate was conditional (Stewart, 2019. p.111-115). The sector has in recent years worked towards enhancing justice for people with disability as volunteers and participants through policy change and funding initiatives to increase access.
In 2024 the Community Broadcasting Association of Australia and the Community Broadcasting Foundation released a vision for the future of this volunteer-driven sector, Roadmap 2033, that recognises the need to increase accessibility and presence of people with disability in community radio. The sector provides many potential opportunities for people with disability to improve their skills, connection to the community, confidence, and voice in the public sphere. Inclusion of people with disability in community broadcasting provides a forum for the normalisation of voices with different life experiences to that people hear in the mainstream and allows for the voicing of the human rights issues that impact people with disability.
The recently updated Community Radio Broadcasting Codes of Practice also supports the human rights of Australians with disability through a commitment to “pursue the principles of democracy, access and equity, especially for people and issues not adequately represented in other media” to “promote the diverse identities of Australians and enrich the social and cultural fabric of Australian society” (2025, p.3.). This includes a change of language and sources of news that include “the voices of those with lived experience” (Code 5d), using “preferred terminology” (Code 7a) to accurately represent people we report on and providing opportunities for community information and participation. Our role in changing discriminatory attitudes is an important goal for the sector.
The issues paper for this review has important implications for the continued growth of volunteering and improving access to the community broadcasting sector. Some of the ways we see changes to the DDA could facilitate social inclusion of people in the community broadcasting sector and more widely include:
Attitude change can be facilitated by a change of the definition of disability
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Socially pervasive attitudes of deficit that impact acceptance of people with disability require change in many domains of society, the public sphere being a particularly important one. The Convention on the Rights of Persons with Disability (CRPD. 2006) encourages the “participation and positive portrayal of people with disability in the media” (Commonwealth of Australia, 2023. p.20). The Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability (2023) recognised the importance of the media as a location where attitude change must begin (Idle et al., 2020). Many of the people with disability who gave testimony to the Royal Commission noted the need for public visibility in the media to address discrimination, as silencing and invisibility produce the conditions for fear, dehumanisation and oppression. Idle et al.’s report into attitude change reported in the Final Report:
- “The most important interventions are those that create visibility of people with disability and contact between people with and without disability. Seeing people with disability in day-to-day environments can challenge expectations of where people with disability belong. This can ‘debunk’ prejudices, prompting reflection and challenging the underlying feelings and beliefs” (Commonwealth of Australia, 2023, p.20).
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Improving the definition of disability focusing on the social model and differences in human ways of being rather than deficit compared to a norm, will help shift attitudes towards a strength-based human rights model of disability as it begins to be used in public discourse. Attitudes are impacted by public discourse, important in the light of extremely
discriminatory attitudes entering the public sphere via US politics under the Trump administration. Improving the language that is used to describe disability will require changes to reporting of disability issues to also shift language. This is well underway in the community broadcasting sector, if not in the wider media landscape.
- Improving the characterisation of psychosocial disability and neurodiversity as difference, not disability. Rights movements emphasise difference and diversity in human ways of being, rather than ranking against a standard of normality. This is a trend we recognise in the diverse range of participants, community guests and content creators in community radio who do not always identify with the socially loaded term disabled (Stewart & Behan, 2025, in publication). A case-by-case basis is preferable to a blanket term that is not representative of the diverse identities of people with disability. Neither disability or impairment is scientifically justifiable, no reflect the lived experience of all people. A new definition of disability should include the nuances that people bring to disability as an identity, rather than simply a medical or physical state.
Intersectionality is required for fully understanding the lived experience of people with disability.
- Separate pieces of legislation for anti-discrimination fail to recognise intersectionality, possibly undermining rights and making complaints complex. Certainly, this is the experience of many of the authors of this submission and the community members they have spoken to during their radio production careers. People with disability are much more likely to experience, poverty, unemployment, less education and are more likely to be the victims of crime. Many First Nations people experience disability. A large proportion of the incarcerated are people with disability, many of them undiagnosed.
- Acts of law protecting people from discrimination and lack of access rely on the ideal complainant: an empowered, resourceful and economically supported person with the skills and motivation to follow through the complaint process. This focus on complaint-led enforcement instead is a barrier to justice for people with disability who have intersectional issues impacting them. In addition, resolution of discrimination often results in financial restitution without systemic change.
- A reversal from complaints-based enforcement to supporting increased accessibility would enhance accessibility compliance. This is important as the community broadcasting sector moves towards better inclusion. For instance, current legislation in Australia supporting the provision of accessible digital services for people who have differing cognitive or sensory needs applies in full only to government services through the Digital Inclusion Standard. Access to information impacts the capacity of people with disability to
be aware of the opportunities that might be available to them and to access information that might enable them to enter the public sphere through community broadcasting (Stewart & Price, 2025, in publication). Globally, there has been no improvement in web accessibility in the commercial sector over 15 years of the WebAIM Screen reader user survey (2024). This is unlikely to improve when there is no commitment from government to support digital accessibility financially, and legislation provides a loophole through ‘unreasonable hardship’ (Australian Government, 2024) that allows barriers to access to remain unchanged. Aiding accessibility as a positive duty is one of the final recommendations of the Disability Royal Commission 4.12 that says the Commonwealth should, “promote accessibility and universal design, and appropriate remedial action to existing infrastructure” (p.198).
- A similar reversal of duty to uphold human rights from the duty-bearer to the rights-holder exists in the burden of proof for complainants as noted in the issues paper (Recommendations 4.23 & 4.24). Grants, tax incentives, government supported training and other assistance to providers could shift the onus of enforcement back to the systemic changes that are needed, instead of on the rights bearers who are victims of discrimination.
About the authors of this submission:
The authors of this paper include community radio producers and co-producers of research on the accessibility and inclusion for people with disability in community broadcasting in Australia. Our team have diverse lived experiences of disability and long careers of volunteerism and casual work in the sector. Many of us collaborated to create an accessible mentoring and trainee program, Audio Ability, in 2022 to enhance the skills of new volunteers in the sector that has been popular and effective in increasing inclusion.
Sincerely,
redacted: s47F - personal privacy4ZZZ and Community Media Training Organisation.redacted: s47F - personal privacy, 4RPH and Community Media Training Organisation.redacted: s47F - personal privacy, Community Media Training Organisation.redacted: s47F - personal privacy, Radio Adelaide and Community Media Training Organisation.- Dr Kim Stewart, MSW, DCI, School of Psychology and Wellbeing, University of Southern Queensland.
- Professor
redacted: s47F - personal privacy, Discipline lead social work, School of Psychology and Wellbeing, University of Southern Queensland. - Association Professor
redacted: s47F - personal privacy, UniSQ. School of Psychology and Wellbeing, University of Southern Queensland.
References
Australian Bureau of Statistics. (2024). Disability, Ageing and Carers, Australia: Summary of Findings. https://www.abs.gov.au/statistics/health/disability/disability-ageing-and-carers-australia-summary-findings/latest-release
Australian Government (2024). Digital inclusion standard. www.digital.gov.au/policy/digital-experience/digital-inclusion-standard/dis-services-covered
Australian Government. (2025). Disability Discrimination Act 1992 Review. Issues Paper. https://consultations.ag.gov.au/rights-and-protections/dda-issues-paper/useruploads/dda-review-issues-paper.pdf
Community Broadcasting Association of Australia & Community Broadcasting Fund. (2024). Roadmap 2033. https://cbf.org.au/wp-content/uploads/2023/10/FINAL-Roadmap-2033-digital-for-printing.pdf
Community Broadcasting Association of Australia. (2025). Community Radio Broadcasting Codes of Practice. https://www.cbaa.org.au/community-broadcasting/codes#codes-of-practice-listing
Commonwealth of Australia. (2023). Executive summary, our vision for an inclusive Australian and recommendations. Royal Commission into violence, Abuse, Neglect and Exploitation of People with Disability. https://disability.royalcommission.gov.au/system/files/2023-11/Final%2520report%2520-%2520Executive%2520Summary%252C%2520Our%2520vision%2520for%2520an%2520inclusive%2520Australia%2520and%2520Recommendations.pdf
Idle, J., Giuntoli, G., Fisher, KR, Robinson, S., Purcal, C., Newman, C., Reedy, K. (2022). Research Report – Changing community attitudes to improve inclusion of people with disability. Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, https://disability.royalcommission.gov.au/publications/changing-community-attitudes-improve-inclusion-people-disability
Stewart, K., Spurgeon, C. & Edwards, N. (2019). “Media participation by people with disability and the relevance of Australian community broadcasting in the digital era.” 3CMedia. 9, pp. 44-63. https://eprints.qut.edu.au/133767/1/Media+participation+by+people+with+disability+and+the+relevance+of+Australian+community+broadcasting+in+the+digital+era.pdf
Stewart, K., & Spurgeon, C. (2020). “Researching media participation by listening to people with disability.” Media Culture and Society. 42 (6), pp. 969-986. https://doi.org/10.1177/0163443719890536
Stewart, Kim. & Behan, Annabelle. (2025). Critical disability theory: A framework for inclusive community radio in Australia. In Kate Saxton (ed.). Social Work for the Real World [Manuscript in preparation] Routledge.
Stewart, K., & Price, P. (2025). You can’t be what you can’t read: Website accessibility for people with disability in Australian community radio. Media International Australia, 0(0). https://doi.org/10.1177/1329878X251378272
WebAIM. (2024). Screen reader user survey #10. https://webaim.org/projects/screenreadersurvey10/
United Nations. (2006). Convention on the Rights of Persons with Disabilities. https://www.ohchr.org/en/instruments-mechanisms/instruments/convention-rights-persons-disabilities