Moonee Valley City Council
Submission
Australian Government Review of the Disability Discrimination Act 1992
03 9243 8888 | 9 Kellaway Ave, Moonee Ponds VIC 3039 | City of mvcc.vic.gov.au Moonee Valley
Introduction
The City of Moonee Valley
The City of Moonee Valley comprises approximately 43 square kilometres of land, with around 67 per cent of the land area used for residential purposes. The municipality is bordered by the local government areas of Maribyrnong, Brimbank, Merri-bek and Melbourne and at its closest point, it is approximately 5 kilometres from Melbourne CBD.
Our community
Moonee Valley is a great place to live, work and play. Our neighbourhoods that allow residents, at all stages of life, to live locally and sustainably, accessing most of their needs close to home. We hold strong community connections which enable citizens and the environment to be healthy and resilient.
Moonee Valley has a population of around 126,500 residents or 55,115 households.
According to the 2021 census, 15% identify as having a disability, 15% of residents were carers (provided unpaid assistance to a person with a disability, health condition or due to old age), 6.1% of people in Moonee Valley reported needing help in their day-to-day lives due to disability (Community Profile, 2021), and 3% of Moonee Valley residents participate in the National Disability Insurance Scheme (NDIS, National Dataset 2025).
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Our work with people with disability
Moonee Valley City Council is committed to a more inclusive and accessible city, where everyone can access everything and feel empowered to do so. Two key initiatives that lead this work are the Moonee Valley Disability Advisory Committee (DAC) and the Disability Action Plan (DAP).
Moonee Valley Disability Advisory Committee (DAC)
The DAC provides a forum to consult with community members who live, work and volunteer in the local community, and seek specialist advice around disability. The DAC is comprised of a selection of people with disabilities, their family or carers, who represent a cross section of the local community and reside in different geographic locations across Moonee Valley. Local service organisations also participate in the DAC. The DAC provides pivotal insights into the development and implementation of Council’s Disability Action Plan.
Djanga-nhanyin nharrag-ayl
Our Identity is Powerful: Inclusive Moonee Valley (DAP 2024-2025)
The DAP 2024-2025 outlines 32 key actions to be implemented over 2 years (between January 2024 and December 2025) by Moonee Valley City Council. The DAP improves access and inclusion to everyday life while removing barriers. This includes providing information to the public on accessibility in Council buildings and the way that Council recruits staff, with the objective of removing barriers for people with disability, neurodivergent people, their families and carers to actively participate in civic life.
Council is currently preparing a DAP for 2025–2029. This new plan builds on and extends the actions of the first DAP, and has been integrated into the Council Plan to both elevate the importance and to ensure alignment with broader strategic priorities. It will incorporate actions from Djanga-nhanyin nharrag-ayl DAP 24-25 and identify new opportunities to enhance access and inclusion across the municipality.
Our submission draws on our experiences delivering Disability Action Plans for the City of Moonee Valley.
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Discussion paper response
41. Should there be minimum requirements for action plans (such as through guidelines) and what should the minimum requirements cover?
Minimum requirements for Disability Action Plans (DAPs), established through clear guidelines, could significantly improve the consistency and quality of these plans. By setting foundational standards, Councils would be better equipped to align their DAPs with human rights legislation and United Nations conventions, ensuring a more robust and accountable approach to disability inclusion. These requirements could also elevate the visibility and importance of DAPs. Further, alignment with the Australian Disability Strategy 2021-2031 and State/Territory plans could demonstrate the relationship between local, state and Commonwealth responsibilities for addressing inclusion. Additionally, incorporating community engagement principles would ensure that people with lived experience of disability and carers, are meaningfully involved in shaping policies that affect them.
While standardisation promotes quality assurance, it must be balanced with flexibility. Councils must be able to respond to the unique needs of their communities and develop place-based solutions. Success from our current DAP includes upgrading accessible parking across the municipality, improving community feedback processes for accessibility concerns, building staff capacity in inclusive practices within Family and Children’s Services, developing business cases for accessible leisure centre improvements including automatic doors and mobile pool hoists, and investigating an interactive public access map.
Introducing stringent minimum requirements could present challenges to this work. Developing high-quality DAPs demands dedicated, knowledgeable staff and sufficient resources. Currently, our DAPs are developed and managed by one EFT position who works very closely with community, to focus on local issues that are in alignment with the four pillars of the Inclusive Victoria: State Disability Plan 2022-2026.
A stringent compliance-based DAP model may require resource support to engage specialised staff. Interpreting legislative and regulatory frameworks demands a distinct skill set compared to our current model, which centres on translating community feedback into social policy and guiding staff across the organisation to implement inclusive practices. Without adequate support, there is a risk that the quality and relevance of DAPs could be compromised.
We see the value of the development and implementation of a consistent nation-wide reporting framework that focuses on the impact of local DAP initiatives have for people with disability. From our experience and benchmarking, we understand that
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similar themes are aspired to through the DAPs of Local Government Authorities. The review of the DDA offers an opportunity to clarify the ways in which DAPs can contribute to achieving the National aspirations of inclusion.
We believe the benefit of our current DAP process is the ability for our Disability Advisory Committee to have influence over the initiative’s development and delivery. Through this Committee, we ensure that outcomes from previous plans directly inform future planning cycles. We suggest that to preserve the integrity and community-driven nature of our current DAP process, any standards, review or rejection framework must explicitly recognise and support the role of community committees and emphasise the importance of developing initiatives that build on previous wins and community-led outcomes.
Lastly, navigating complex state and federal frameworks could complicate implementation of initiatives within DAPs, underscoring the need for practical, scalable guidelines that support rather than hinder progress. Increases to compliance would require clarity around the different levels of compliance.
Recommendations:
- Minimum requirements for DAPs should include meaningful community engagement.
- DAPs should be reported for public accountability across common themes for inclusion.
- DAPs should not specify specific actions that could limit place-based actions.
42. Should the Australian Human Rights Commission be able to reject action plans that fail to meet these requirements?
Empowering the Australian Human Rights Commission to reject DAPs that do not meet minimum standards could improve the overall quality and impact of these plans. It would introduce a layer of meaningful oversight, ensuring that plans are not only submitted but are also fit for purpose.
However, introducing a rejection mechanism could create new pressures for both Councils and the Commission. There’s a risk that the focus could shift from genuine inclusion to compliance-based outcomes. The process of revising and resubmitting plans may lead to delays in implementation, and smaller or under-resourced organisations might struggle to meet the standards without additional support. To avoid this, any rejection framework should be paired with capacity-building support, clear guidance, and a collaborative approach that encourages learning rather than penalisation. This would help ensure that the intent—meaningful disability inclusion—is not lost in the process.
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Recommendation: 4. Assessment of DAPs should be supported by transparent criteria, constructive feedback, and capacity-building resources.
43. Should there be a set period of time for which an action plan is valid?
Establishing a set validity period has the capacity to strengthen DAPs. Moonee Valley City Council has integrated our new DAP into our Council plan, to enhance holistic decision-making, accountability and greater organisational alignment that centres inclusion of people with disability. The review process of the Council plan ensures regular evaluations and elevates these reviews to corporate reporting frameworks, ensuring staff across the organisation recognise the importance of the work. These regular review cycles embed essential feedback loops into the planning process, reflecting a systems thinking approach of plan, act, do, review. This ensures that action plans remain dynamic and responsive and support continuous improvement.
We do not think it is necessary to limit the time period of DAPs to achieve these outcomes, but rather place emphasis on review processes. If a validity period was introduced, there would need to be flexibility mechanisms for integrated plans, new legislation, major service changes, or serious accessibility complaints.
Recommendation: 5. Prioritise the establishment of robust and regular review processes for DAPs rather than enforcing a fixed validity period.
44. Are there any other changes to the action plan process that you would recommend?
Recommendations: 6. Moonee Valley City Council recommends the following additional changes to the action plan process: - Accessible formats: Mandate accessible formats for published plans to ensure full participation by people with disabilities. Provide support to develop accessible engagement activities. - Community consultation: Formalise consultation processes, drawing on successful models to ensure consistent and meaningful engagement with people with lived experience, and considers the unique experiences of diverse groups of people with disability.
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- Flexibility mechanisms: Ensure the process allows for responsiveness to legislative changes, service redesigns, or serious accessibility complaints.
- Community voice: Protect and elevate the role of community committees and feedback loops from previous plans to ensure continuity and genuine inclusion.
- Common outcomes framework: develop and implement clear ways in which local DAPs contribute to the aspirations of inclusion through a consistent nation-wide reporting framework that focuses on and measures the impact of local DAP initiatives have for people with disability.
- Greater clarity on attitudinal barriers: provide greater clarity on local government’s role in addressing attitudinal barriers through DAPs, as outlined in Australian Disability Strategy.
45. How could compliance with and enforcement of the Disability Standards be improved?
The Disability Standards are a valuable tool which support Councils to understand their role in promoting equitable access and inclusion across services and infrastructure. However, with the introduction of the new positive duty, there is a need for greater clarity around roles and responsibilities in relation to the Standards.
The proposed shift from a reactive, complaints-based model, to a proactive compliance approach is welcomed. We anticipate these will include a significant change in practice for prioritising upgrades to community facilities and infrastructure, of which additional external funding opportunities will be required to achieve. Clear guidance is needed on how the Disability Standards will interact with any proposed minimum requirements for DAPs and positive duty, especially within the local government context. Councils need clarity on roles, responsibilities and prioritisation frameworks to ensure they can proactively meet compliance obligations within funding limitations, while continuing to deliver place-based, community-informed outcomes.
Recommendations: 7. Clear guidance and clarity on roles and responsibilities is required for Councils to understand the interaction between the proposed minimum requirements for DAPs, positive duty and Disability Standards. 8. Prioritised upgrades to community facilities and infrastructure will require additional external funding.
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46. Should the Disability Discrimination Act be amended to encourage relevant duty holders to self-report on their compliance with the Disability Standard(s) in disability action plans?
47. Could the Australian Human Rights Commission provide additional guidance to duty holders regarding how to self-report on the Disability Standards in disability action plans?
Encouraging duty holders to self-report on their compliance with the Disability Standards through DAPs could significantly strengthen transparency and accountability. It would support a shift from a reactive, complaints-based model to one of continuous monitoring and systemic improvement. Self-reporting would allow Councils to assess their progress proactively, share best practices, and identify areas for improvement, aligning with the intent of positive duty.
Focusing on the impact that local DAP initiatives have for people with disability could assist communities to see meaningful differences in their everyday lives and demonstrate practical connection to Disability Standards.
It should be noted that implementing such a requirement would introduce additional workload and resource demands, particularly for Councils that may not yet have systems in place to track and report compliance data. There is also a risk that reporting could become a superficial exercise, or increase legal exposure if non-compliance is documented without adequate context or support.
To mitigate these risks, the Australian Human Rights Commission must play a vital role by providing clear, practical guidance on how to self-report. This would help address knowledge gaps and allow officers to support knowledge acquisition at the executive and senior management levels. It could also reduce the administrative burden of developing reporting frameworks. It’s important that any guidance remains flexible enough to account for the diversity of Councils in terms of size, capacity, and community priorities.
Conclusion
Moonee Valley City Council thanks the Attorney-General’s Department for the opportunity to contribute to this important review. Our submission reflects our commitment to meaningful disability inclusion and our experience in developing community-driven DAPs.
We support reforms that strengthen accountability and consistency. The success depends not only on compliance frameworks, but on genuine community participation, adequate resourcing, and clear guidance that supports Councils in their proactive duties. We look forward to continued engagement in this reform process, to advance disability inclusion across all areas of Council operations and service deliver.
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Moonee Valley Language Line
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03 9243 8888 | 9 Kellaway Ave, Moonee Ponds VIC 3039 | City of mvcc.vic.gov.au | Moonee Valley