European Disability Forum
EDF response to the
European Commission
Staff Working Paper :
Rights of Persons with Reduced
Mobility when Travelling by Air
DOC EDF 04/08 EN
June 2004
"States should recognise the rights of organisations of persons with disabilities to
represent persons with disabilities at national, regional and local levels. States
should also recognise the advisory role of organisations of persons with
disabilities in decision-making on disability matters."
Rule 18 of the United Nations Standard Rules on the Equalisation of
Opportunities for Persons with Disabilities
European Disability Forum
> > Forum Européen des Personnes Handicapées
rue du Commerce 39-41 — B-1000 Brussels
T +32-2-282.4600 F +32-2-282.4609 E [email protected] W www.edf-feph.org
E uropean D isability F orum
List of contents
1. Introduction ......................................................................................................... 3
2. General Remarks ................................................................................................ 4
3. Comments on the draft Regulation ................................................................... 5
4. Accessibility of Airports and Aircraft .............................................................. 13
5. Conclusion......................................................................................................... 14
ANNEX I: About EDF and other documentation ................................................. 15
DOC EDF 04/08 EN
EDF Response to the European Commission Staff Working Paper: Rights of
Persons with Reduced Mobility when Travelling by Air
The document is available in English, and on diskette or in large-print upon
demand from the EDF Secretariat, and on the EDF Website at:
http://www.edf-feph.org
© Copyright European Disability Forum 2004. This document may be quoted and
reproduced, provided the source is given.
EDF response - Staff Working Paper: Rights of Persons with Reduced Mobility when Travelling by Air
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1. Introduction
The European Disability Forum (EDF), the umbrella body of the European
disability movement, very much welcomes the European Commission Staff
Working Paper: Rights of Persons with Reduced Mobility When Travelling by Air,
issued in January 2004. This Paper represents the important work and
commitment the European Commission has shown over the years to develop
measures and initiatives to secure the rights of passengers with reduced mobility
(PRMs) in all modes of transport – particularly by in the field of air travel.
Disabled people have the same rights as other persons to freedom of movement
and freedom of choice. This applies to air travel as to all other areas of life.
Discrimination towards people with disabilities in air travel must be prohibited.
There are and have been a number of incidents where disabled persons have
experienced discrimination when travelling by air. Disabled persons have been
refused booking or refused carriage due to their disability. There have been
incidents where disabled persons have been charged for the assistance they
require or for the use of installations needed to facilitate access on the ground or
in the air. Disabled persons have experience poor levels of assistance and
infrastructural barriers in airports and on aircraft.
The proposals for a draft Regulation as presented in the Staff Working Paper
upholds two fundamental principles which EDF is pressing for:
 that disabled persons must not be refused booking or refused carriage
because of their disability; and
 that disabled persons must not be charged directly for the assistance they
require.
In this paper EDF elaborates upon its response to the European Commission
Staff Working Paper and identifies points on which EDF believes there should be
clarification or improvement.
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2. General Remarks
Following the consultation process of the European Commission begun in 2002,
a public hearing was held by the European Commission in March 2003 between
airlines, airports and consumer groups, at which EDF participated. All parties at
the Hearing, including the air industry, generally expressed a positive attitude
towards the need for European non-discrimination legislation where it concerned
disabled air travellers. Such legislation would clearly set down rules to prohibit
discrimination of disabled travellers; prohibit unjustified denied boarding of
disabled travellers; prohibit direct charging of disabled passengers for the
assistance they may require in the airport; and set down clear rules and
guidelines to define minimum standards for assistance on the ground and on
board the aircraft.
EDF strongly believes that certain matters relating to disabled air travellers or
travellers with reduced mobility cannot be addressed through voluntary
commitments and must be addressed through European legislation. This view
was shared by the European Commission and the air industry in general.
Some key issues EDF has identified:

EDF notes that unjustifiable reasons on grounds of safety and security are
used, on a regular basis, to discriminate against disabled air passengers and
deny disabled passengers the right to board an aircraft or to present
restrictions on seat allocation. In some cases, disabled passengers are even
required to sign a declaration that they will not trouble non-disabled
passengers. This practice is unjustifiable and discriminatory.

Many cases are reported to EDF of disabled passengers being provided with
inadequate assistance or of disabled passengers being left without any
assistance provision whatsoever.

Airlines should not be permitted to charge extra for assistance services
rendered to disabled people. EDF has noted that this is sometimes the case
among low cost airlines.

EDF regularly receives reports of damaged wheelchairs and damage to other
mobility equipment or assistive devices due to poor handling during transit.
Airlines must be made liable to refund disabled passengers the full cost of
loss or damage of such equipment which has been damaged or destroyed
during transport by the airline.
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3. Comments on the draft Regulation
Article 2 : Definition
The term "person with reduced mobility" has been widely used in European
Community and European Civil Aviation conference (ECAC) documents. Some
concerns have been raised by disability organisations that the term ‘persons with
reduced mobility’ is not sufficiently clear. There has been some concern that the
term does not, in an explicit-enough way, relate to those individuals who are
blind, partially sighted, deaf, hard of hearing, or those who have an intellectual
disability as such individuals do not necessarily experience limited "mobility"
when travelling.
Therefore, EDF stresses that the diversity of disability must be recognised in the
draft Regulation and that the term "person with reduced mobility" should be
interpreted broadly to include all disabled passengers whose orientation,
communication or mobility may be reduced when travelling by air.
EDF notes also that the term "intellectual deficiency" used in the draft Regulation
is inappropriate. EDF wishes to point out that in recent European Community
legislation there has been a clear move away from use of the term "deficiency" in
relation to disabled persons. EDF would encourage the European Commission
to work towards a consistency in its use of terms and definitions so that they are
as inclusive as possible. Both the Bus and Coaches Directive (2001/85/EC)1 and
the recent Proposal for a Regulation on International Passengers' Rights and
Obligations (COM (2004) 143 final)2 use the phrase "intellectual impairment"
rather than "deficiency". Furthermore the air passenger voluntary service
commitments of the airlines and airports also use the term ‘intellectual
impairment’ in their definition of persons with reduced mobility.
1 Directive 2001/85/EC (Bus and Coach Directive) relating to special provisions for vehicles used for the
carriage of passengers comprising more than eight seats in addition to the driver's seat; Official Journal L
042, 13/02/2002 P. 0001 – 0102, Annex I, 2.21: "Passenger with reduced" mobility means all people who
have difficulty when using public transport, such as disabled people (including people with sensory and
intellectual impairments, and wheelchair users), people with limb impairments, people of small stature,
people with heavy luggage, elderly people, pregnant women, people with shopping trolleys, and people with
children (including children seated in pushchairs);
2 Proposal for a regulation of the European Parliament and of the Council on International Rail Passengers’
Rights and Obligations, COM (2004) 143 final, Article 2.21: "person with reduced mobility" means any
person whose mobility is reduced due to physical, sensory or locomotory incapacity, to an intellectual
impairment, age, illness, or any other cause of disability when using transport and whose situation needs
special attention and the adaptation to a person’s need of the service made available to all passengers;
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Article 3 : Prevention of refusal of carriage
Disabled persons have a fundamental right to equality of access to air travel with
non-disabled persons. Air carriers, agents and tour operators must not
discriminate towards disabled passengers on the basis of their disability and
must provide equality of access.
EDF welcomes express recognition in the Commission’s Working Paper and
proposed Regulation on the right to board for disabled passengers. People
with disabilities and other passengers with reduced mobility must be protected
against discriminatory denied boarding which continues to take place all too
often. EDF supports Article 3(1) of the draft Regulation which prohibits refusal of
booking or boarding by air carriers on the grounds of reduced mobility.
However, EDF is greatly concerned that Article 3(4) provides that air carriers are
able to refuse to accept a reservation or to embark a person with reduced
mobility in order to meet requirements related to "safety, security, health, or
working conditions" and that these requirements can be based on national
legislation.
EDF is concerned about the substantial lack of transparency in the interpretation
of "requirements related to safety, security, health, or working conditions." This
lack of transparency seriously undermines the prohibition of denied boarding set
out in Article 3.
EDF is concerned that disability is frequently equated with "illness" and
that on this basis air carriers refuse to board disabled passengers. Disabled
people face situations of denied boarding on the basis of arbitrary and
unspecified health and safety grounds which are discriminatory. Such
unjustifiable and unspecified health and safety reasons are also used to impose
restrictions on seat allocation. Furthermore, different airlines exercise use of
health and safety to restrict the conditions of carriage of disabled passengers in
different and divergent ways which compounds the confusion and lack of
transparency in the implementation of health and safety rules by airlines.
EDF is concerned that national health and safety legislation could be used
to justify refusal of boarding, resulting in highly diverging reasons and cases of
denied boarding from between Member States. There is a risk that the same
airline may refuse to carry a disabled passenger in one country but not in
another. This is in direct contradiction with the principle of harmonisation at
Community level of rules protecting air passengers. It is also in contradiction of
the objective of a single market without barriers and of the fundamental principle
of free movement within the EU for all citizens.
EDF would like to see a streamlining and clarification of the diversity of
rules governing health and safety in air travel which are currently far from
transparent. EDF would favour EU harmonised rules in this area.
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EDF notes that the carriage of certified service dogs is subject to national
regulation as explained and confirmed by Annex 2 of the draft Regulation. EDF
would emphasise the need for consistency and transparency at the national level
of such restrictions. Passengers with disabilities need to have confidence in their
ability to travel by air across all Member States and so must be fully informed of
such national regulations. EDF also calls for guarantees within the main text of
Regulation that certified service dogs shall be carried in the cabin, free of charge.
EDF fully supports the obligation placed on air carriers to inform, in writing,
passengers who are refused carriage. Also for the air carriers to inform the
passenger concerned, in writing, of the reasons for that refusal of carriage. The
air carriers must also make publicly available the safety rules that apply to the
transport of persons with reduced mobility as well as any restrictions on the
carriage of persons with reduced mobility caused by the size of the aircraft or the
absence of cabin crew.
Article 9 foresees the possibility of making a complaint to a "competent body
designated by a Member State" about an alleged infringement of this Regulation
as well as requiring that Member States lay down sanctions for cases of
infringement. EDF urges the Commission to ensure that such competent bodies
will have the mandate to address cases of unjustified denied booking or boarding
on the basis of safety, security, health, or working conditions and that sanctions
can be imposed.
The need for disability awareness training of staff
EDF would also like to highlight the lack of awareness about disability which
exists among airline and airport staff. Misconceptions about disability frequently
lead to discriminatory denied boarding particularly in cases of group travel (for
example, EDF has received reports about staff suggesting there are security
concerns when several people who are deaf, blind or who have intellectual
disabilities travel together).
Appropriate training of staff is crucial and it can contribute significantly to better
understanding the needs of disabled passengers while ensuring their safety,
independence and dignity. EDF urges that the Regulation require comprehensive
staff training for those who provide assistance and services to disabled
passengers. One important element of any training scheme should be to
emphasise that assistance should be applied flexibly and adjust to the diversity
of disabilities and the needs of the individual disabled person.
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Article 4 : Right to assistance at airports
Notification requirement
EDF suggests that the notification requirement of a disabled passenger's need
for assistance of at least forty-eight hours before the published time of departure
of the flight is unnecessary. EDF notes there is a risk that certain disabled people
may be unnecessarily denied assistance by the existence of such a notification
requirement. Such a notification period should be limited only to those people
who require assistance that involves significant pre-planning.
For example, this would include passengers who need continuous support from
arrival at the airport entry point to the departure gate, or substantial assistance to
board the plane (e.g. a high-loader lift).
A notification period of forty-eight hours should not apply to those disabled
person who require less assistance. For example, deaf people who need help
with documentation at check-in and information about which departure gate to
use; or independent wheelchair users who only need their wheelchair placed in
the hold at the point at which they board the plane. EDF proposes that 24 hours
is a more reasonable period of time for such notification.
Flight booking
If pre-notification of assistance is required then it must be possible for disabled
people to easily communicate their assistance needs during the booking
process. This applies in particular when a booking is made on the internet.
Where booking is made by phone, it should be possible to provide all the
necessary information about the assistance required in the same call. This may
imply prompts in the booking systems used by travel and booking agents to allow
them to input the appropriate information.
Flight booking is not only made in person or on the phone. One of the reasons
for the decrease in air travel prices is the fact that passengers can book
themselves onto a flight and arrange payment via the internet. This type of
booking often causes problems for persons with disabilities.
Firstly, the booking websites of air carriers are not always designed to be
accessible to disabled people who cannot read print (e.g. blind or partially
sighted persons or persons with learning disabilities). As a consequence, such
persons cannot take advantage of reduced fares available to others and who,
therefore, experience economic discrimination.
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Secondly, disabled people who want to book over the internet are often expected
to make an additional phone call to give details of their assistance needs (this
may be costly and the hours may be limited). Web inaccessibility and extra cost
and inconvenience may result in discouraging passengers with disabilities to
travel with those particular air carriers.
EDF urges that the Regulation require that air carrier and affiliated booking
agencies ensure their internet booking sites to be fully accessible, ie that these
internet booking sites must comply with the Web Accessibility Initiative (WAI)
guidelines. In addition to the measures suggested for phone-booking, the
Regulation should also ensure that it is possible to register notification of the
need for assistance by internet. Certain airlines already implement detailed
assistance-booking options on the internet.
Article 5 : Responsibility for assistance at airports
EDF welcomes the clear and strong commitment in the Staff Working Paper to
the fundamental principle that passengers with disabilities should not be directly
charged for assistance.
EDF supports the scheme set out in Article 5 of the draft Regulation whereby
costs of the assistance, to be provided free of charge to persons with reduced
mobility, shall be shared among the air carriers using an airport; directly in
proportion to the total number of passengers carried to and from that airport in
the preceding year.
EDF recognises a number of advantages in the proposal to centralise provision
of assistance within airports by assigning responsibility for the service to
managing bodies of airports. Such an approach would ease seamless travel for
disabled travellers as provision of assistance would no longer start from the point
of check-in but from the point of set-down. In order to resolve the cost issue,
assistance to PRMs should be considered as part of the general running
costs of the airport.
Ultimately, EDF advocates for provision of assistance that contributes to
seamless travel for disabled passengers who begin their journey at the entrance
to the airport (or airport car park, bus stop, or railway station) and who may
require assistance with, for example, flight check-in, security clearance, passport
control, customs control, baggage retrieval, locating the departure gate or
making a transfer to another flight (perhaps even to a different terminal).
EDF considers that a centralised charging system must require the
participation of ALL carriers and that any possibility for carriers to opt out
of the centralise charging scheme and, thereby, not pay the central charge
would lead to a deterioration in the overall quality of service for disabled
persons to be supported by the scheme. The advantage of a centralised
charging scheme is that it will provide a quality of the service towards disabled
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passengers guaranteed at certain standard which ALL carriers must subscribe
to. EDF believes that any possibility for airlines to opt out of the scheme would
severely water down the central scheme and lead to its deterioration which will
have negative consequences for disabled passengers.
In relation to Article 5(4), EDF welcomes the setting of quality standards which
will contribute to ensuring a reliable and high level of assistance to passengers
with disabilities. EDF supports requirement in the draft Regulation that such
quality standards are to be set by the managing body of the airport only after
consultation with organisations representing passengers with reduced mobility
and airport users. EDF is concerned that in cases where an Airport Users
Committee does not exist, such consultation might not be structured or
transparent.
It is extremely important that, in the setting of quality standards, internationally
recognised policies and codes of conduct – in particular the European Civil
Aviation Conference (ECAC) guidance Document 30, Section 5 "Facilitation of
the transport of persons with reduced mobility" including its relevant Annexes –
be fully taken into consideration.
EDF would like to see the section on quality standards further elaborated to
more clearly address the issue of monitoring and reporting. Relevant and
detailed performance indicators should be used for regular performance
monitoring by independent competent persons and organisations. In addition,
performance reports of each airport should be permanently and prominently
displayed in public areas of airports and on the internet.
A benchmarking system of both costs and services to stimulate competition and
quality improvements should be encouraged.
A uniformity of quality standards should be ensured within all airports and
Member States. This will ensure that disabled passengers throughout Europe
can count on high quality standards of assistance, and such uniformity will
contribute to the objective of harmonisation of air passengers rights within the
European Community.
Article 6 : Assistance by air carriers
Accompanying person
EDF would like to highlight the fact that “safety requirements” have often been
used as a justification for requiring a disabled passenger to travel with an
accompanying person. EDF believes that this is only necessary in certain
exceptional cases and urges that the Regulation require that air carriers be
required to provide written justification when the airline requires that a passenger
with a disability must travel accompanied.
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EDF further submits that, in cases where an air carrier requires that a passenger
with a disability must travel accompanied by a second person, and in line with
the principle of no direct charging for assistance, the accompanying person
should travel free of charge or at least have a significant reduction in fare.
Annex 1 : Assistance at airports
Assistance
EDF urges that Annex 1 must represent a minimum level of service and that
assistance provided should be based on the expressed needs of individual
passengers with disabilities. EDF notes there is a diversity of disability and that
different individuals will require differing degrees of assistance. An openness is
required, on the part of the person providing assistance, to communicate with the
disabled passenger to find out how best to assist.
EDF has documented many examples of passengers with disabilities who have
been obliged, against their will, to use assistance they do not need (e.g. a blind
passenger who needs assistance with way-finding being forced by an
assistance-provider to sit in a wheelchair rather than being guided to the
departure gate). This type of practice is unacceptable and the Regulation should
explicitly acknowledge that different passengers will require different types of
assistance. The overall objective must remain to assist the passenger while at
the same time respecting their independence and dignity.
Temporary replacement of damaged or lost mobility equipment
Annex 1 only provides for "temporary replacement of damaged or lost mobility
equipment." Experience illustrates that damage to mobility equipment will often
result in a disabled passenger incurring significant costs.
EDF urges that the Regulation provide that, in cases of damage to mobility
equipment, disabled passengers be compensated the full cost of loss or damage
of such equipment.
Accessibility of information needed to take flights
EDF underlines that accessible information is crucial for passengers who are
blind, partially sighted, deaf, hard of hearing or who have intellectual disability.
Architectural barriers within an airport or aircraft are easy to identify but
communication barriers are not so obvious. If adequate information is not made
available in visual as well as audible format, there is a risk that a passenger with
a disability could miss a flight because of a delay or gate-change.
Information and communication during the whole travel chain must be accessible
to all passengers with disabilities. This includes, for example, internet booking,
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information related to departure times and delays, and information and
documentation provided at check-in and ticket desks.
Information announcements should be complemented by display of the same
information on a monitor. Print material should be available in alternate format.
Telephones should be accessible and text phones and fax should be available to
the public within the airport.
With the centralised provision of assistance as proposed in the Staff Working
Paper, EDF underlines the need for airports to have Information Desks located
near airport entrance/access points to enable passengers with disabilities to
enquire about assistance upon arrival and to obtain necessary flight information.
Such Information Desks should have basic information about the airport
available in alternate format and should have a staff member who can
communicate with International Sign Language (ISL).
Annex 2 : Assistance on board aircraft
Certified dogs
As stated above, EDF objects to the carriage of certified service dogs being
subject to national regulations.
Mobility equipment
EDF is concerned that air carriers seek to limit the carriage of mobility
equipment, without justification in certain cases. In the interests of transparency
and to avoid unjustified denial of boarding, EDF urges that air carriers be
required to publicly, and in detail, outline any restrictions on the carriage of
mobility equipment.
Accessibility of information concerning flights
Air carriers are required to provide, free of charge, the assistance/services
specified in Annex 2 which includes the "communication of information
concerning a flight in accessible formats."
EDF underlines that the accessibility of information is crucial for those
passengers who are blind, partially sighted, deaf, hard of hearing or who have
intellectual disability.
EDF would like to emphasise that "information concerning a flight" should be
interpreted broadly within the Regulation to include, for example:providing all printed information (including safety brochures) in alternative
formats such as large print and Braille as well as ensuring that they are provided
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with pictorial content and plain language; providing a tactile map of the cabin;
ensuring that at least one crew member can communicate in basic international
sign language with passengers who use sign language; ensuring that all video
information during the flight has subtitles and signed PIP (picture in picture);
requiring that on-board alarms are active both visually and audibly.
Airlines should be encouraged to include sign language as one of the language
options for crew members to learn.
Seating
In Annex 2, the draft Regulation links seating arrangements for disabled
passengers to "safety requirements". EDF has noted an inconsistency among air
carriers in their restriction of seating of disabled passengers on board aircraft.
Certain airlines insist that passengers with disabilities sit in the window seat so
as not to block the evacuation of other passengers in an emergency situation.
Other airlines insist that passengers with disabilities sit only in the aisle seat to
simplify transfers from on-board wheelchairs. These practices are not only
arbitrary and inconsistent but are discriminatory. EDF urges that the Regulation
uphold the principle that passengers with disabilities should not be unreasonable
restricted in their choice of seating in the aircraft.
4. Accessibility of Airports and Aircraft
Accessibility of the built environment is a fundamental prerequisite to eliminating
discrimination. EDF is disappointed the draft Regulation does not address
accessibility of airports and aircraft.
Article 13 of the EC Treaty enables the Community to take initiatives to combat
discrimination on the grounds of disability. EDF sees Article 13 as the legal base
for any regulatory provision relating to the accessible built environment or
accessible design.
Many of the barriers disabled people face as air passengers can be easily
overcome by means of simple adaptation of existing airports. Airport and aircraft
design and layout can be made accessible to all through application of a Design
for All approach. Architectural and design-related barriers can be prevented in all
future construction. Actions taken to improve access to infrastructure, facilities
and aircraft must be undertaken in consultation with organisations representing
people with disabilities.
EDF urges that this Regulation includes an obligation for the managing bodies of
airports to ensure that new airports are planned, designed, constructed and
managed in such a way that air travel is facilitated for all passengers, and that
existing barriers are gradually eliminated.
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The poor design of aircraft means that currently, for a majority of airlines, aircraft
are not accessible. Accessibility features include, for example, toilets large
enough for an on-board wheelchair, tactile symbols in cabin design (including
seats and in toilets), high colour contrast interiors, or visual alarms.
EDF also urges that the Regulation include an obligation for air carriers to
purchase aircraft which meet accessibility standards.
5. Conclusion
The European Disability Forum welcomes the Staff Working Paper which
includes a draft proposal for a regulation on air passengers with reduced
mobility.
EDF calls on the EU institutions to support the approach of this draft Regulation
whilst, at the same time, taking on board the specific additional proposals
presented by EDF.
The most essential of EDF demands are:
 that disabled persons must not be charged directly for the assistance they
require;
 that disabled persons must not be refused booking or refused carriage
because of their disability;
 that health, safety and security reasons cannot be used as a means to
discriminate against disabled passengers.
 provision of a system that will provide seamless assistance for disabled air
passengers throughout all stages of the journey, from the point of setdown to the point of pick-up.
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ANNEX I: About EDF and other documentation
A.1
About the EDF
The European Disability Forum (EDF) is the European umbrella organisation
representing the interests of 50 million disabled citizens in Europe. EDF
membership includes national umbrella organisations of disabled people from all
EU/EEA countries, accession countries and other European countries, as well as
European NGOs representing the different types of disabilities. The mission of
the European Disability Forum is to ensure disabled people full access to
fundamental and human rights through their active involvement in policy
development and implementation in Europe.
A.2
Other relevant EDF documents:
EDF response to the Proposal for a Regulation establishing common rules on
compensation and assistance to air passengers in the event of denied boarding
and cancellation or long delay of flights (COM(2001)784 final) (DOC EDF 02-02
– April 2002)
EDF response to the European Commission consultation paper On Airlines’
Contracts with Passengers (DOC EDF 02-15 – October 2002)
A.3
Contact person at the EDF Secretariat:
Nora Bednarski, Policy Officer (T: +32-2-282.46.05 E-mail: [email protected])
More information about EDF is available on the EDF homepage at : www.edffeph.org Should you have any problems in accessing the documentation, please
contact the EDF Secretariat.
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