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

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