Komnas HAM, Indonesia UNCRPD Written Contribution
23. Komnas HAM noted that equitable access to public transports in major cities has been
well underway, with particular attention to the special capital city of Jakarta. Different
types of public transports in Jakarta have provided assistive services and priority seat
signs for people with disabilities.10 However, these disability-friendly services are yet to
be carried out in all regions throughout the country. Komnas HAM calls upon the
Indonesian government to issue a national-level regulation that require all public
transport services be disability-friendly.
24. Komnas HAM highly appreciates the use of priority signs for vulnerable groups and
persons with disabilities in different transportation services. However, the Commission
is against the use of such signs to perpetuate stigma and discrimination against persons
with disabilities.
25. Some reports received by Komnas HAM are related specifically to transportation
services in aviation.11 The reports indicated that discrimination against persons with
disabilities still exists in the provision of transportation services in the aviation industry.
Komnas HAM believes that flight safety instruction standards must also take into
account disability-friendly services.
26. Komnas HAM welcomes the establishment of regulations governing accessibility in
commercial buildings.12 However, strict adherence to these regulations are yet to be seen
with numerous buildings still not having disability-friendly access. It appears that
10
Komnas HAM appreciates that various public transports in the capital city have provided services and
mobility access for persons with disabilities. Priority seats have also been given for persons with
disabilities and other vulnerable groups (Komnas HAM 2019 Infrastructure Field Data).
11
Dwi Ariyani's case with Etihad is one of the cases reported to Komnas HAM. The report stated the
airline’s refusal to fly Ariyani due to the absence of a companion who would be available to assist in
emergency situation (Komnas HAM Data on Complaints).
12
Accessibility in buildings is stipulated in Law No. 8 of 2016. Prior to that, Indonesia has Law No. 28. of 2002
on Buildings. However, although it is mentioned that a building is required to provide accommodation, the law does
not provide specific provisions on what facilities need to be available to ensure such accommodation for people with
disabilities. The Regulation of the Public Works Minister Number 30/PRT/M/2006 on the Technical Guidelines on
Facilities and Accessibility in Buildings and Buildings’ Vicinity defines accessibility as the accommodation
provided to all, including people with disabilities and elderly, to realize equal opportunities in all aspects of life and
livelihoods. Article 4 of the regulation stipulates that (1) Technical requirements of facilities and accessibility in
buildings and buildings’ vicinity apply to: a. standard area size; b. pedestrian; c. tactile block; d. Parking area; e.
Doors; f. Ramps; g. Stairs; h. Elevators; i. Stairway elevators; j. Toilets; k. Showers; l. Sink; m. Telephone; n.
Control facility and equipment; o. Furnitures; p. Road signs and surface markings.
12