Accessibility Should Mean More Than Simply Getting into the Water

Everyone should be able to enjoy Port Macquarie's coastline.

People living with disability, older residents, people with reduced mobility, carers and families with young children all deserve safe, practical and dignified access to public recreation.

Protect Oxley Beach Port Macquarie strongly supports an accessible ocean pool for the community.

Our concern is whether Oxley Beach is the right location to deliver genuinely universal access.

Accessibility is not simply a question of whether a wheelchair user can eventually reach the pool.

It is about the entire journey:

How do you arrive?

Where can you park?

Can you safely get from the car to the entrance?

Can you travel along the pathway independently?

Can you reach toilets and change facilities?

Can you access the water?

And can you make the journey back out without unreasonable physical barriers?

At Oxley Beach, the steep natural topography, limited parking, constrained pedestrian network and busy Pacific Drive environment create significant challenges.

Are wheelchairs suitable for saltwater? Does not having a sutable wheelchair create disadvantage in accessing a Ocean Pool?

Standard wheelchairs are generally unsuitable for direct access to the Port Macquarie Ocean Pool because repeated exposure to salt water can damage components that are not designed for marine conditions, particularly through corrosion, while conventional wheelchair components may also be unsuitable for immersion. A purpose-built aquatic wheelchair should therefore use rustproof or highly corrosion-resistant materials, such as PVC or marine-grade stainless steel, together with water-resistant seating, suitable wheels and components designed for full salt-water immersion. Australian examples demonstrate these features: the Platypus aquatic wheelchair is rustproof and designed for full immersion in salt, chlorinated or fresh water, with a current listed price of $2,750, while specialised beach wheelchairs can cost $5,499.99 to $8,499.99, and one custom corrosion-resistant model averages approximately $11,000. For budgeting, approximately $3,000 for a dedicated aquatic/pool wheelchair is therefore a reasonable indicative purchase allowance based on the currently listed $2,750 example, although final cost will depend on required seating, support and access features.

What Does Australian Accessibility Law Require?

Accessibility is supported by a combination of Commonwealth legislation, the National Construction Code and Australian Standards.

The Disability Discrimination Act 1992 (Cth) makes it unlawful to discriminate against a person with disability in relation to access to premises and the use of facilities that the public is entitled to use.

The Disability (Access to Premises—Buildings) Standards 2010 establish requirements for accessible buildings and accessways and incorporate relevant requirements of AS 1428.1.

For aquatic facilities, the National Construction Code also contains specific provisions for accessible entry and exit from swimming pools. For example, the NCC's Specification 16 provides requirements for fixed or moveable pool access ramps, including a maximum 1:14 gradient, slip-resistant surfaces, handrails and kerbs.

These requirements are important.

But technical compliance is not necessarily the same thing as practical accessibility.

A facility can potentially be designed to meet minimum standards while still presenting significant challenges for some people because of its location, distance, terrain or surrounding infrastructure.

What Is the Maximum Wheelchair Ramp Gradient?

One of the most important accessibility considerations is the gradient of a ramp.

Under AS 1428.1, accessible ramps generally have a maximum 1:14 gradient, meaning that for every 1 metre of vertical rise, the ramp requires approximately 14 metres of horizontal travel.

That's a gradient of approximately 7.14%.

For ramps at the maximum 1:14 gradient, landings are required at intervals of no more than approximately 9 metres. Less steep ramps can have longer intervals, with requirements varying according to the gradient. Recent NSW access reports applying AS 1428.1 describe the relationship between gradient, ramp length and landing requirements.

A simplified example illustrates the significance:

Vertical rise

Approximate ramp length at 1:14 gradient*

0.5 m

7 m

1.0 m

14 m

2.0 m

28 m

3.0 m

42 m

4.0 m

56 m

*Approximate horizontal run before allowing for landings, circulation areas and other design requirements.

The important point is that 1:14 gradient is a maximum gradient, not a recommendation that every accessible path should be as steep as possible.

Where site conditions allow, a gentler gradient can make travel easier for many wheelchair users and people with limited mobility.

What About a 150-Metre Ramp at Oxley Beach?

The proposed feasibility design includes a sweeping access ramp of approximately 150 metres between the headland and the lower rock platform.

That distance is significant.

Even if the ramp can be engineered to comply with the relevant maximum gradients and landing requirements, a user could still face a lengthy journey down to the facility—and then the same journey back uphill after swimming.

For someone using a manual wheelchair, walking frame, crutches or another mobility aid, the physical effort involved can be substantial.

This is particularly important because accessibility standards are intended to facilitate access, but the physical reality of a site remains relevant to the user experience.

A 150-metre access route is very different from a level or gently graded pathway leading directly from nearby accessible parking.

The Difference Between Compliance and Genuine Accessibility

This distinction is central to the debate.

Imagine two ocean pools.

Facility A

A person parks close to the entrance, travels along a short, level pathway, accesses the amenities and reaches the pool with minimal assistance.

Facility B

A person parks some distance away, crosses a busy road, follows a long pathway, travels down a substantial ramp to the water and then has to make the entire journey uphill to return to their vehicle.

Both facilities might contain accessible features.

But the quality of the accessible experience is very different.

Universal design asks us to look at the entire journey rather than simply checking individual components against a compliance checklist.

Ramp Landings Are Essential

A common misconception is that an accessible ramp can simply be one long continuous slope.

It cannot.

AS 1428.1 requirements include landings and circulation areas. For a ramp at a 1:14 gradient, the maximum length between landings is generally 9 metres. Landings are also required at the top and bottom and where the ramp changes direction.

A typical accessible ramp also requires features such as:

• handrails

• kerbs or kerb rails

• slip-resistant surfaces

• appropriate landing areas

• appropriate clear widths

• suitable circulation space

• appropriate tactile indicators where required.

These are not optional decorative features.

They are important components of safe accessible design.

A Ramp Can Be Compliant and Still Be Difficult

This is particularly relevant at Oxley Beach.

The proposed access route is not simply a short ramp between two building levels.

It is a long coastal access route through a steep natural landscape.

The user experience could therefore be affected by:

• ramp length

• gradient

• number of landings

• fatigue

• weather

• wind

• sun exposure

• salt spray

• rain

• surface conditions

• wind-blown sand

• drainage

• maintenance

• the need to travel back uphill.

For some users, particularly those with limited upper-body strength or endurance, these factors can make a substantial difference.

Accessible Pathways Have Their Own Gradient Requirements

Not every accessible route is classified as a ramp.

AS 1428.1 distinguishes between different types of graded pedestrian pathways, with accessible walkways generally requiring gentler gradients than ramps.

NSW access documentation applying AS 1428.1 describes walkways as generally having between approximately 1:33 and 1:20 gradients, while ramps operate between approximately 1:20 and 1:14 gradients, subject to the applicable design provisions.

This distinction matters.

A gently graded pathway is considerably easier for many wheelchair users than a ramp operating continuously at the maximum permissible gradient.

The question for Oxley Beach is therefore not simply:

Can a compliant ramp be constructed?

It is:

Can the site provide a practical, comfortable and dignified accessible journey for a wide range of users?

Accessible Pool Entry Has Additional Requirements

Accessibility does not stop at the pool deck.

The pool itself must provide an accessible means of entering and exiting the water.

The National Construction Code's Specification 16 sets requirements for accessible water entry and exit from swimming pools. A fixed or moveable ramp, for example, must have a slip-resistant surface, a maximum 1:14 gradient, appropriate handrails and kerbs, and landings complying with AS 1428.1.

The NCC also provides for other accessible water-entry approaches, including zero-depth entry and other compliant arrangements depending on the facility design.

This means an accessible ocean pool requires careful consideration of both the route to the pool and the method of entering the water.

Accessibility Begins With Accessible Parking

A person using a wheelchair cannot benefit from an accessible pool if they cannot safely get to it.

Accessible parking is therefore a fundamental part of universal access.

The Disability (Access to Premises—Buildings) Standards contain requirements concerning accessible car parking, while AS 2890.6 provides detailed requirements for off-street accessible parking spaces.

At Oxley Beach, however, the challenge is the physical environment.

Pacific Drive occupies a constrained coastal headland above the beach.

Parking is already heavily used by:

• beach visitors

• local residents

• tourists

• schools

• sporting organisations

• community events

• visitors to surrounding facilities.

Creating accessible parking close to the proposed entrance requires more than simply painting an accessible symbol on the road.

The space must provide sufficient room for safe wheelchair transfers and access to the adjacent pedestrian route.

The Journey Across Pacific Drive

For some proposed parking areas, visitors would need to cross Pacific Drive to reach the Ocean Pool.

That raises a further accessibility issue.

A genuinely accessible path needs to be continuous.

It is not enough to provide an accessible parking space on one side of a road if the person using it must then negotiate an inconvenient, discontinuous or unsafe pedestrian route.

This is particularly important for:

• wheelchair users

• children

• older people

• people with vision impairment

• people using walking frames

• carers

• people using mobility scooters

• families carrying equipment.

Accessible design needs to consider the whole path of travel.

Accessibility and the Steep Topography of Oxley Beach

Oxley Beach is naturally steep.

The beach sits below Pacific Drive within a coastal amphitheatre.

That creates a fundamental site constraint.

To provide universal access from the road to the water, substantial infrastructure would be required to overcome the natural elevation change.

The question is whether it is better planning to:

engineer a difficult site to provide access, or

select a location where accessible access is naturally easier to achieve.

Protect Oxley Beach believes the second approach deserves serious consideration.

What Does Genuine Universal Access Look Like?

A truly inclusive ocean pool should allow people to experience the facility with as much independence as reasonably possible.

That means considering:

Before arrival

• accessible transport options

• accessible parking

• drop-off arrangements

• clear signage

• safe pedestrian connections.

Getting to the entrance

• continuous accessible paths

• appropriate gradients

• kerb ramps

• safe road crossings

• suitable surfaces

• adequate lighting and wayfinding.

At the facility

• accessible toilets

• accessible showers

• accessible change facilities

• appropriate seating

• shade and shelter

• space for carers and support workers

• accessible emergency arrangements.

At the pool

• accessible water entry

• suitable transfer arrangements

• aquatic wheelchairs where appropriate

• safe surfaces

• appropriate handrails

• adequate circulation space.

Returning home

• a safe and manageable route back to the vehicle or transport connection.

Accessibility is the entire journey—not just the final few metres.

Changing Places and Higher-Level Accessibility

For some people with disability, a standard accessible toilet is not enough.

A genuinely inclusive aquatic facility should consider whether Changing Places-style facilities are appropriate.

These facilities can provide additional space and specialised equipment for people who require assistance with personal care, including:

• adult-sized change tables

• ceiling hoists

• larger circulation areas

• appropriate sanitary facilities

• space for carers.

For a major community aquatic facility intended to serve people of all ages and abilities, these considerations should form part of the design discussion from the beginning.

The Coastal Environment Creates Additional Challenges

Accessibility infrastructure at Oxley Beach would also be exposed to the marine environment.

A long ramp and associated pathway could experience:

• salt spray

• wind

• rain

• sand

• algae

• marine moisture

• corrosion

• surface deterioration.

For wheelchair users, surface quality is particularly important.

A surface that is technically compliant when first constructed must remain safe and usable throughout its life.

That means maintenance is part of accessibility.

A poorly maintained accessible pathway is not genuinely accessible.

Accessibility and Emergency Evacuation

Another consideration is emergency access and evacuation.

If an emergency occurs at the lower section of the facility, people need to be able to leave safely.

This raises questions about:

• evacuation routes

• ramp capacity

• emergency assistance

• accessible refuge arrangements where relevant

• access for emergency services

• evacuation of people using wheelchairs or mobility aids.

A long, steep route between the beach and Pacific Drive needs to be considered not only as an everyday access route but also as part of the facility's emergency planning.

The Disability Discrimination Act Matters

The Disability Discrimination Act 1992 is an important part of the legal framework.

Section 23 addresses discrimination in relation to access to premises and facilities that members of the public are entitled to use. Section 24 also addresses the provision of goods, services and facilities.

This reinforces an important principle:

Public recreation should be designed so people with disability can participate equitably.

Protect Oxley Beach fully supports that principle.

Our argument is that achieving it should begin with choosing a site that makes accessibility easier, rather than relying on extensive engineering to overcome fundamental physical constraints.

Standards Are a Minimum — Good Design Should Aim Higher

Compliance with Australian Standards is essential.

But good universal design should aspire to more than simply meeting the minimum technical requirements.

A ramp that meets 1:14 gradient may be legally and technically compliant.

But if a person using a manual wheelchair finds the journey exhausting, exposed and difficult, the facility may still fall short of the broader goal of creating an inclusive community destination.

This is why site selection matters so much.

A good site can make accessibility easier.

A difficult site can make accessibility an engineering problem.

A Better Approach to Accessible Ocean Pool Design

Protect Oxley Beach believes Port Macquarie should pursue a tidal pool or ocean pool that is genuinely accessible.

That means considering locations where it is possible to provide:

• relatively level access

• accessible parking close to the facility

• continuous footpaths

• safe pedestrian connections

• shorter travel distances

• accessible amenities

• accessible water entry

• emergency access

• easy access for carers

• practical access for people using wheelchairs and mobility aids.

An accessible facility should not require people with disability to overcome unnecessary barriers simply because the site itself is difficult.

Accessibility Should Be Designed In — Not Engineered On

The community deserves an ocean pool that works for everyone.

That includes people who:

• use wheelchairs

• use mobility scooters

• use walking frames

• have limited mobility

• have vision or hearing impairments

• have reduced strength or endurance

• require assistance from carers

• are older

• are recovering from injury

• have young children.

Universal access should be considered from the moment a person decides to visit the facility until the moment they return home.

The Key Question for Oxley Beach

The question is not whether engineers can construct an accessible ramp at Oxley Beach.

They may be able to.

The more important question is:

Can Oxley Beach provide genuinely practical, dignified and universal access without requiring people with disability to navigate a long, steep, exposed and complex journey simply to reach the water?

Protect Oxley Beach believes this question deserves careful, independent consideration.

We Support an Accessible Tidal Pool/Ocean Pool

Protect Oxley Beach supports an ocean pool that can be enjoyed by the whole community.

We believe accessibility should be one of the starting points for selecting the location, rather than something added later to overcome site constraints.

A location with level terrain, convenient parking, safe pedestrian connections and simpler access infrastructure could potentially provide a better experience for people with disability while reducing the need for extensive engineering.

The goal should not simply be an ocean pool that is technically accessible.

The goal should be an ocean pool that is genuinely accessible, practical, comfortable, safe and welcoming for everyone.

That is what universal access should mean.

Frequently Asked Questions About Oxley Beach Ocean Pool Accessibility

What is the maximum gradient for an accessible ramp in Australia?

• For an accessible ramp under the relevant AS 1428.1 provisions, 1:14 gradient is generally the maximum gradient, meaning 1 metre of rise requires approximately 14 metres of horizontal travel. Maximum travel lengths between landings depend on the gradient; at 1:14, the commonly applied maximum is 9 metres.

Is a 1:14 gradient suitable for every wheelchair user?

• Not necessarily. A 1:14 gradient is a technical maximum, not an indication that every user will find that gradient easy. A person's strength, endurance, wheelchair type and other mobility factors can affect their ability to travel up a ramp.

How long is the proposed Oxley Beach access ramp?

• The feasibility concept referenced by Protect Oxley Beach proposes an access ramp of approximately 150 metres between the headland and the lower rock platform.

Does an accessible ramp need landings?

• Yes. Accessible ramp design under AS 1428.1 includes requirements for landings. At a 1:14 gradient, landings are generally required at maximum intervals of 9 metres, with additional requirements for the top, bottom and changes in direction.

Does the National Construction Code have specific requirements for accessible swimming pools?

• Yes. NCC Specification 16 sets requirements for accessible water entry and exit from swimming pools, including requirements for fixed or moveable ramps such as a maximum 1:14 gradient, slip-resistant surfaces, handrails, kerbs and landings.

Does accessibility only mean getting into the pool?

• No. Accessibility should consider the complete journey, including parking, pedestrian paths, road crossings, entrances, toilets, change rooms, pool access, emergency arrangements and the return journey.

Does the Disability Discrimination Act apply to public facilities?

• The Disability Discrimination Act 1992 prohibits discrimination on the basis of disability in areas including access to premises and the provision of goods, services and facilities.

Does Protect Oxley Beach oppose accessible recreation?

• No. Protect Oxley Beach strongly supports accessible recreation and an accessible ocean pool. Our concern is whether Oxley Beach is the most appropriate location to deliver genuine universal access.

Can a standard or motorised wheelchair go into salt water? 

• Wheelchairs are generally not suitable for the Port Macquarie ocean pool because standard manual wheelchairs—like those described in the Ottobock Start Series manual—are designed for dry, stable, hard surfaces, not wet, uneven, or submerged environments. Ocean pools involve saltwater exposure, slippery surfaces, wave action, and submerged ramps, all of which create safety risks including corrosion, tipping, loss of braking control, and instability. Only purpose‑built aquatic wheelchairs are engineered for safe use in water, whereas everyday wheelchairs cannot maintain traction, stability, or durability in ocean‑pool conditions.

Important Note About Accessibility Standards

Accessibility requirements can depend on the classification and design of a particular facility, the applicable provisions of the National Construction Code, the relevant version of AS 1428.1, site conditions and other applicable legislation and standards.

The gradient figures above are provided to explain the accessibility issues raised by the proposed site and should not be treated as a substitute for a formal access assessment by a suitably qualified access consultant.

For a major public aquatic facility, the final design should be independently assessed against all applicable Australian Standards, the NCC and disability access legislation.

Official References

Disability Discrimination Act 1992 — Federal Register of Legislation

Disability (Access to Premises—Buildings) Standards 2010 — Federal Register of Legislation

NCC Specification 16 — Accessible water entry/exit from swimming pools

NSW Health

Active Mobility Systems: Platypus Pool/Wet Area Wheelchair

Para Mobility Platypus Aquatic Pool Wheelchair 120kg - Bunnings Australia

Pelican & Platypus Aquatic Pool Wheelchairs

DaVinci Beach Wheelchair - Push Mobility