MACS Response to the Performance Framework for Airline Accessibility Consultation – July 2023
Introduction
What is your name?
Name: Hilary Stubbs
Do your views officially represent those of an organisation?
Yes, I am authorised to submit feedback on behalf of an organisation
If Yes, please specify the name of your organisation.
Organisation: Transport Scotland Mobility and Access Committee
Which of the following best describes you or the group you represent?
Charity or disability organisation
Please specify if 'Other' if selected:
We are a non-departmental board advising the Ministers and officials at Scottish Government on matters relating the disabled travellers
Can we publish your response?
Yes
Do you agree we should introduce an Airlines Accessibility Framework?
Yes
Please set out reasons for your answer:
Disabled passengers need to know what to expect from an airline, airlines need to know what standards they need to meet.
The framework is essential for the industry so that they can meet the Equality Act and the PSD requirements as well as industry specific regulation
Website accessibility and the provision of essential information
Are the proposed criteria to achieve a ‘Good’ and ‘Very Good’ assessment level in relation to website accessibility and the provision of essential information appropriate?
No
If you think the CAA should consider setting the standards at a different level please explain your rationale:
The standard should be Very Good only. Anything less affects inclusive communication and may lead to some people being able to access information in the format they need. Having essential information readily available to passengers is essential in making an informed decision before making a booking and in journey planning.
Do you agree that airlines' websites and applications conforming to the latest Web Content Accessibility Guidelines (currently WCAG 2.1) is best practice?
Agree
Are there any examples that you would highlight of good practice for website accessibility either in the aviation sector or elsewhere which would be more appropriate?
Do the criteria adequately take into account commercial considerations for airlines?
Yes
If no, please explain your rationale:
Disabled passenger's have the same rights as non-disabled passengers, so airlines should provide equality of services irrespective of costs.
Do the essential information requirements sufficiently meet the needs of disabled passengers?
No
If you think it would be helpful to require any additional information, possibly to achieve a ‘Very Good’ rating, please set out your rationale:
The standard to achieve should be no less than Very Good for the reasons previously given. Only if the standard is set at Very Good will it be sufficient.
For formats to accessible information should be provided as standard using text, audio (equipped with subtitles and/or sign language interpretation) and/or electronic means to be accessible to all. Accessible formats include, but are not limited to, large print, Braille version, easy-to-read version, audio format such as tapes or CDs, video format like DVDs, and electronic format. This level of information needs to be routinely available to prevent exclusion of people with protected characteristic.
Would generic information on passenger rights regarding accessibility be useful to supplement information provided by individual carriers?
Yes
Requesting assistance and pre-notification
Are the proposed criteria to achieve a ‘Good’ and ‘Very Good’ assessment level in relation to requesting assistance and pre-notification appropriate?
Yes
If you think the CAA should consider setting the standards at a different level please explain your rationale:
Though the standard should be set at the Very Good descriptors to achieve a Good rating and the addition of appropriate freephone telephone answering standards enabling a Very Good rating.
We have concerns about the use of codes which classify disabled travellers needs. Code should only be used if accompanied by a full, clear description. The proposals make no reference to airlines who provide lifeline medical flights such as those to the Scottish islands. Passengers on these flights are often discharged from hospital at short notice and the relevant airlines and their service providers need to have contingency plans to cope with these passengers. (Edinburgh and Glasgow do have this in place on an informal basis but it needs to be more formalised.)
Are there additional actions which the CAA could require of airlines to further improve pre-notification levels?
Yes
If you think there are additional actions which the CAA could require, please explain your rationale:
Telephone answering standards for a freephone contact should be added to measure how long people are waiting to talk to someone about their needs.
Access and medical clearance
Are the proposed criteria to achieve a ‘Good’ and ‘Very Good’ assessment level in relation to access and medical clearance appropriate?
Yes
If you think the CAA should consider setting the standards at a different level please explain your rationale:
Is there anything additional that the CAA should consider to allow people to be confident they will not be denied boarding because of their disability or reduced mobility?
Yes
If you do think there is more that CAA should consider please explain your rationale:
Where a passenger may need inflight assistance or care a companion or carer should be allowed to travel free of cost if they can provide this level of support. This should also be part of the achievement of a Very Good rating.
Do you agree with the criteria set out by IATA under Resolution 700? Agree What could be additional criteria?:
Although I would add that there should be no additional financial outlay to disabled passengers if arrangements for flying with an alternative airline or re-routing are required. This should also include the passengers accompanying this person.
Accompanying persons
Are the proposed criteria to achieve a ‘Good’ and ‘Very Good’ assessment level in relation to accompanying persons appropriate?
No
If you think the CAA should consider setting the standards at a different level please explain your rationale:
The description of the requirements for a Very Good rating should be met to achieve a good rating.
Clear guidance is needed if an accompanying person is to be given a reduced fare. We are concerned that this benefit may be misused and someone claim they need assistance when they don't purely to access a free journey.
Do you have any comments on airline policies on the need for accompanying persons for passengers who are not self-reliant?
Yes
Comments on airline policies on the need for accompanying persons for passengers who are not self-reliant:
On most occasions the person accompanying the disabled passenger will have a better understanding of their needs and what works best for them including in emergency situations. This can assist with the efficiency of dealing with issues and critically ensure the disabled passenger receives person centred care.
The person accompanying a disabled person must have access to the necessary equipment to move the disabled person.
As such, accompanying person should receive free or heavily discounted travel.
It may also be inappropriate or stressful to ask another passenger, not known to the individual to undertake this role i.e. safety assistants
Checking-in
Is the proposed criterion to achieve a ‘Good’ assessment level in relation to checking in appropriate?
No
If you think the CAA should consider more criteria what should they be?:
Disabled passengers should be able to use mobility equipment and other special equipment, eg CPAC machines through the airport and until boarding. This is essential in the event of a flight delay where the disabled person's needs vary over a period of several hours.
Boarding and disembarking
Are the proposed criteria to achieve a ‘Good’ assessment level in relation to boarding and disembarking appropriate?
No
If you think the CAA should consider more criteria what should they be?:
There should also be a maximum time disabled passengers wait to disembark as part if the Gold standard i.e. no more than 15 minutes after other passengers.
Reference should also be made to receiving and returning personal mobility equipment which the traveller used to access the plane and needs to disembark.
Onboard facilities
Are the proposed criteria to achieve a ‘Good’ and ‘Very Good’ assessment level in relation to seating appropriate?
No
If you think the CAA should consider setting the standards at a different level please explain your rationale:
The criteria proposed for Very Good should the requirements to achieve Good.
Having moveable armrests (for aircraft with 30 or more seats) on all of the aisle aisle seats and specified distance/route to toilet facilities should be added to achieve Very Good ratings.
Seat reservation charges should be waivered for the disabled passenger and their companion.
Access to toilets
Are the proposed criteria to achieve a ‘Good’ and ‘Very Good’ assessment level in relation to access to toilet facilities appropriate?
Yes
If you think the CAA should consider setting the standards at a different level please explain your rationale:
It should be noted that access to a toilet washing facilities during a flight is a basic human right.
Many disabled people become really anxious regarding how they will access toilets during their flight with many travelling in discomfort and others opting to use in-dwelling catheters with leg bags to minimise the risk of urinalysis incontinence. Having to take these actions are not dignified or person centred and as such it is imperative that a Very Good rating is achieved in this area.
Storage of manual wheelchairs onboard
Is the proposed criterion to achieve a ‘Very Good’ assessment level in relation to the storage of manual wheelchairs onboard appropriate?
No
If you think the CAA should consider more criteria what should they be?:
The criteria of “storage of at least one vertically folding personal wheelchair not exceeding ISO dimensions” is not adequate. Given the increasing percentage of the population who identify as disabled, with a high proportion due to reduced mobility, there needs to be more capacity than 1 space.
Also many active wheelchairs fold horizontally and as such are wider when folded. This also needs to be taken into consideration.
Does the criterion adequately consider commercial considerations for airlines?
Yes
If no, please include your rationale:
But it appears heavily based on commercial considerations and not in meeting the needs of disabled passengers.
Carriage of mobility and medical equipment
Are the proposed criteria to achieve a ‘Good’ and ‘Very Good’ assessment level in relation to the carriage of mobility and medical equipment appropriate?
No
If you think the CAA should consider setting the standards at a different level please explain your rationale:
The standards to achieve a Good rating should include those proposed under Very Good.
For Very Good - “ airlines do not arbitrarily set limits on the number of mobility items it can carry per aircraft for commercial or practical reasons’ - should be added.
Does the criterion adequately consider commercial considerations for airlines?
Yes
If no, please include your rationale:
It would appear more so than passenger needs.
Do you agree that IATA’s ‘Guidance on the transport of mobility aids’ provides an appropriate level of guidance on safe transport of mobility aids?
No
If no, please include your rationale:
It needs to be consistent across airlines to prevent passenger confusion. Training is an essential part of delivering this service.
Has the CAA correctly identified the current issues regarding onboard facilities?
Yes
If no, please include your rationale:
Disabled passengers who need a reliable electric supply to support their equipment should be advised and seated appropriately. This is for equipment such as an electric CPAC machine (breathing aid)
Are there additional issues which should be considered?
Yes
If yes, please set out any additional issues that should be considered here:
A policy for the replacement and full reimbursement of any equipment damaged during the journey, including contingency arrangements for the disabled passenger should their vital mobility equipment be damaged. This should be at market value not the current levels.
There should also be a monitoring and evaluation process to evidence the percentage of equipment being refused and/or damaged with a target of zero damage given the impact on the disabled person independence and quality of life should their vital equipment be damaged.
Are the proposals practical and appropriate?
No
If no, please include your rationale:
The proposals don’t go far enough. See comments under additional issues to be considered.
Assistance dogs
Do you agree with the definition of 'recognised assistance dog'?
No
If no, please include your rationale:
The specified list I think this could include ‘buddy dogs’ which are trained by Guide Dogs. While they aren’t guide dogs they do receive some level of training from Guide Dogs trainers.
Do you agree with the proposed documentation required to be accepted for travel?
No
If no, please include your rationale:
I don’t believe people with visible disabilities accompanied by their dogs should have to produce written medical letters confirming their disability. While I haven’t flown with my guide dog since 2010 I have never been asked to provide documentation confirming that I am blind. I don’t think this should be
required especially if the person travelling has documentation from Assistance Dogs UK or its equivalent confirming that the dog is a certified and therefore trained assistance dog.
Are there any other types of assistance dogs or other training standards that the CAA should consider adding to the list?
Yes
If yes, please set add details of types or training standards that you think the CAA should consider:
Buddy dogs, trained by Guide Dogs for the blind.
Are the proposed criteria to achieve a ‘Good’ and assessment level in relation to assistance dogs appropriate?
No
If you think the CAA should consider more criteria what should they be?:
No not in my view because they are only requiring airlines to provide an extra seat on planes to accommodate dogs for free on safety grounds and not for reasons of comfort. My view is that even when the dog is small, there still isn’t enough space for a dog and their owner to share the floor space for even short flights, never mind long hall ones. The amount of leg room/ floor space is now so cramped there is barely room for bags to be placed beneath the seat in front and dogs simply would not fit, especially larger ones. I would also argue that requiring a owner and their dog to share the same seat space would comprise a safety issue as in an emergency the presence of the dog would prevent the owner from vacating their seat quickly or from accessing life jackets which are usually located underneath the seat, because the dog would need in the way and would need to move. In my experience UK airlines have always provided me with an extra seat free of charge, although these experiences are dated. Back then it wasn’t always easy to find out how to advise the airline when booking that I was being accompanied by a guide dog nor was it easy to request the additional seat, however my requests were never refused. If the CAA aren’t legally able to oblige airlines then they should influence them and in my view a ‘very good’ award would be awarded to airlines that provide additional seats for assistance dogs and state that this is their policy to do so. My recent May 2023 flying experiences, travelling on my own without my dog, were miserable, and confirm airlines are maximising profit over any other consideration.
Training
Do you agree that ECAC guidance is sufficiently extensive to help ensure adequate training?
No
If not, what else should be included?:
The Guidance should identify which staff must be trained and the frequency of refresher training.
Are there any examples of enhanced training programmes in other sectors that may be relevant to aviation?:
NorthLink Ferries disability awareness training programme, which includes the training being developed and delivered by people with lived experience of being disabled.
Is the proposed criterion to achieve a ‘Good’ assessment level in relation to training appropriate?
Yes
Should the CAA consider more criteria? If so, what criteria?:
For very good - disability awareness training should be refreshed annually and have lived experience trainers.
Assistance during flight disruption
Is the proposed criterion to achieve a ‘Good’ assessment level in relation to assistance during flight disruption appropriate?
Yes
If you think the CAA should consider setting the standards at a different level please explain your rationale:
Each disabled passenger should have an ‘assistance during disruption plan’, which has considered their individual needs in advance to assist with resilience planning.
Provision should include the disabled travellers companion, access to any medication that was checked in in baggage, access to mobility aids which may be in baggage and consideration of dietary requirements, e.g. diabetic travellers.
Complaint handling
Are the proposed criteria to achieve a ‘Good’ and ‘Very Good’ assessment level in relation to complaint handling appropriate?
No
If you think the CAA should consider setting the standards at a different level please explain your rationale:
The criteria listed to achieve a Very Good rating should determine a Good rating.
To achieve a Very Good rating timeframes for the investigation and targets for successful resolution should be added and made transparent.
Compensation for lost, delayed, and damaged mobility equipment
Are the proposed criteria to achieve a ‘Good’ assessment level in relation to delayed, lost or damaged mobility equipment appropriate?
No
If you think the CAA should consider setting the standards at a different level please explain your rationale:
It should be an implicit criteria that passengers need to make a special declaration of interest, under Article 22(2) of the Montreal Convention or under Article 22(2) of the Warsaw Convention, including an explanation of why this would be a beneficial act for the individual.
It is not acceptable and many passengers do not know, until too late, that reimbursement for damage or loss to equipment does not often cover the full cost of repair or replacement.
Carriers should consider arrangements, which will provide compensation that fully covers the cost to the passenger. Whatever the policy of the airline this should be stated on its website.
Do you have views on airlines reporting incidents of lost, delayed and damaged mobility equipment?
Yes
Views on airlines reporting incidents of lost, delayed and damaged mobility equipment:
There also needs to be a contract in place with mobility equipment providers to ensure the passenger/disabled person is not left without mobility equipment and to take the onus and responsibility away from the individual to source a solution at a very distressing time, when they have already lost their independence if mobility equipment is damaged or lost. The airline needs to take more accountability for this.
Definition of ratings and frequency of review
Is the proposed method to calculate the overall rating appropriate?
No
If you think the CAA should consider an alternative approach please explain your rationale:
In terms of the descriptors below, this in effect means that in 30% of occasions thus targets has not been met. In our opinion this is not acceptable and the target should be set at between 85-90% to drive more robust compliance toward the target. 30% non compliance should not be deemed a good level if service for disabled passengers.
“We propose for the initial publication of this guidance 70% of criteria be met at a ‘very good’ level for an overall rating of ‘very good’ to be achieved. We propose to review this threshold, and consider additional criteria, in due course. Where an airline fails to achieve a ‘Good’ rating in 70% of the criteria, in each sub-section set out above, it is the CAA’s view that it would be appropriate to rate them as either ‘Needs Improvement’ or ‘Poor’”.
Are the proposed criteria to achieve a ‘Needs Improvement’ and ‘Poor’ appropriate?
No
If you think the CAA should consider an alternative approach please explain your rationale:
There should be a system in place to identify actions needed if this level remains the same for more than 1 year.
Is the approach set out about the frequency of reviews appropriate?
Yes
If you disagree, please explain your rationale:
General comments
Do you have any other comments on the issues set out in this consultation?
Yes
Please use this space to add any comments you would like to share:
We believe that there should be guidance set out on how a wheelchair or other mobility aid is carried beyond the requirement that it is hand loaded. There should be proper restraining straps in use to secure the aid in a designated area in the hold. There should be protection from knocks and damage.
Provision should be made for the toileting of assistance dogs immediately prior to boarding and immediately on arrival at the destination. These areas should also be accessible if a flight is delayed.
Please use this space to add any general comments you would like to share:
Transport Scotland's Mobility and Access Committee (MACS) welcome the proposals in this document and are delighted to be asked to respond to the consultation as a stakeholder group.