Aviation Access Forum (AAF)—Record of Outcomes—26 February 2014
|Date:||Wednesday 26 February 2014|
|Venue:||Qantas Meeting Rooms, Terminal 3, Sydney Airport|
|Attendees:||Australian Human Rights Commission
National Disability Services/The Royal Society for the Blind (by phone)
Physical Disability Australia
Regional Express (REX)
Board of Airline Representatives Australia (BARA)
Regional Aviation Association of Australia (RAAA)
Civil Aviation Safety Authority (CASA)
Department of Social Services (by phone)
Department of Infrastructure and Regional Development (DIRD)
Australian Airports Association
Australian Federation of Disability Organisations
Deafness Forum of Australia
National Council on Intellectual Disability
Key Discussion Items
Agenda Item 1
Welcome, acceptance of draft agenda
The Chair welcomed members and several guests to the meeting in relation to Agenda Item 4 covering the carriage of assistance animals. The draft agenda was agreed by members.
Last meeting of the Aviation Access Working Group—Outcomes and Action Items
The former members of the Aviation Access Working Group (AAWG) endorsed the record of outcomes of the final 8 May 2013 meeting of the AAWG.
It was noted that most action items had been completed, while Action Items 6/14 and 11/14 would be discussed at this meeting.
In relation to Action Item 1/14, Virgin Australia advised that the rationale behind removing moveable walkways at Melbourne and Sydney airports was related to congestion issues. Virgin Australia advised passengers can access a buggy service if they require assistance travelling within the terminal.
In relation to Action Item 2/14, Virgin Australia advised they are currently working through a number of issues identified in their recent disability services review.
Virgin Australia has recruited an additional staff member to assist with driving improvements in policies and processes to enhance services for passengers with disabilities.
A public announcement about Virgin Australia's objectives relating to disability services will be made once the review process has been finalised and the Virgin Australia's Disability Access Facilitation Plan will be updated this year.
In relation to Action Items 5/14 and 6/14, the Department will follow up these action items with the AAA out of session, as a representative from the AAA was unable to attend the meeting.
Action 1: The Department to seek advice from the AAA about relief areas for assistance animals at airports and whether the AAA has raised kerbside access issues with its members.
In relation to Action Item 8/14, Qantas advised that it is unable to provide safety information through iPads because the use of electronic equipment is not permitted during safety demonstrations. Qantas advised that audio announcements and individual briefings are provided by cabin crew when required. The AFDO was unable to attend the meeting and the Department agreed to seek feedback from the AFDO about their assessment of the “eSSENTIAL accessibility” software provided by Qantas to customers out of session.
Action 2: AFDO to provide Qantas with feedback regarding the “eSSENTIAL accessiblility” software.
In relation to Action Item 9/14, the Chair informed the AAF that the Austroads Registration and Licensing Task Force had instituted a project to determine a nationally agreed framework which provides for the safe interaction of motorised mobility devices (MMDs) in road and road related environments.
The increasing need to identify MMDs that can be used on public transport conveyances is one of a number of drivers for change in this area.
The project is being managed by the Queensland Department of Transport and Main Roads and it is envisaged that work on the project will continue through the year, with the Department updating the AAF as appropriate.
In relation to Action Item 12/14, Rex advised that the airline was unable to obtain any training material on the manual handling of passengers with mobility limitations by airline staff.
Rex found that passenger facilitators provided by the passenger to assist with transfer between aisle wheelchairs and aircraft seats are generally only available at one airport (either the destination or arrival airport). REX advised that the airline has altered its policy to allow free travel for companions who assist a passenger transfer between aisle wheelchairs and aircraft seats.
Agenda item 2: Establishment of the Aviation Access Forum (AAF)
Members agreed to the AAF's terms of reference.
In essence the AAF's role will be to provide advice to the Australian Government on policy, operational and administrative issues associated with disability access to airline and airport services and to act as a conduit for information to be exchanged between Forum members to help further improve disability access to air travel.
The AAF Chair will formally report outcomes of the meetings to the Minister for Infrastructure and Regional Development.
The Department will update its website to include the Forum's terms of reference and membership.
Action 3: The Department to update the aviation access page on its website to reflect the new Forum's terms of reference and membership.
Agenda Item 3: Airline Two Wheelchair Policy
The Department advised that it expected to release the airline two wheelchair policy paper for public comment by the end of March 2014. All submissions to the policy paper will be published on the Department's website unless otherwise requested by the author.
REX and the RAAA advised a one size fits all approach to motorised mobility devices (MMDs) is not appropriate in the aviation sector due to differences in aircraft sizes and capacity. The Department advised that submissions to the two wheelchair policy Issues Paper from airlines and disability groups all recognised that weight and size limitations of different aircraft affected the carriage of wheelchairs between different airlines.
Regional operators informed the AAF that they would like to specify the weight and size dimensions of the MMDs they are able to carry in their Disability Access Facilitation Plans, however there is concern this may result in claims of discrimination under the Disability Discrimination Act 1992. The Australian Human Rights Commission agreed to provide the AAF advice on this issue.
Under their operational model, Jetstar advised they do not believe it is possible to carry more than two passengers requiring the use of passenger lifting devices on a single flight. Jetstar informed the AAF that there is no available equipment that is quicker than the passenger lifting devices currently used by Jetstar and aerobridges are not available at most airports.
Jetstar also advised that if passengers can establish that they do not require the use of a passenger lifting device, Jetstar will attempt to accommodate the passenger on the flight provided seats are available. Jetstar also advised that if a passenger can establish that they do not require assistance to board the aircraft (for example, they do not require the use of facilities such as a passenger lifting device), then they would not require a wheelchair SSR and the policy is not intended to apply to them. Jetstar also advised its booking processes ensure passengers travelling with wheelchairs are notified immediately if they are unable to take their preferred flight due to the policy.
Action 4: AAF members to provide comments on the Department's policy paper on the airline two wheelchair policies.
Action 5: The Australian Human Rights Commission to advise the AAF on any potential implications of specifying mobility device weight and size limitations in Disability Access Facilitation Plans.
Agenda Item 4: Carriage of Assistance Animals
The AAF was informed that CASA has delayed the finalisation of Civil Aviation Safety Regulation Part 91, a small provision of which (Part 91.130) covers the carriage of assistance animals in the aircraft cabin. This delay is partly due to the current independent aviation safety regulation review established by the Government which is due to report by 31 May 2014.
CASA also advised that it is developing an accompanying advisory circular; however recent developments to the draft regulations have delayed the distribution of an updated advisory circular to the Forum.
Members were reminded that the new regulations will place responsibilities on the passenger and the aircraft operator in relation to the carriage of assistance animals in the aircraft cabin. This approach is consistent with aviation safety regulations more generally.
The purpose of CASA's advisory circular will be to provide guidance on the types of evidence that should be acceptable by airline operators when making a determination about whether to permit an assistance animal in the cabin of an aircraft.
The option of accepting identification cards which permit an assistance animal to travel on a state or territory public transport system was discussed. Members expressed concern about the different requirements underlying each state and territory scheme but acknowledged that there was no national standard and in the absence of this, airline and disability sector organisations should get together to agree on an aviation industry standard which could be outlined in CASA's advisory circular.
Airline representatives proposed the advisory circular should include the following requirements:
- The animal must alleviate the effects of the passengers disability during the flight (i.e. there must be a reason for the animal to be in the cabin of the aircraft); and
- Evidence of a public access test which demonstrates the animal meets appropriate standards of behaviour and hygiene.
Some members suggested that the Queensland legislative requirements provide a good model for the aviation sector to adopt, however it was noted that the Queensland legislation requires the assistance animal to demonstrate three specific physical support tasks, which are not achievable for all psychiatric support animals.
CASA reminded members that public access tests are not available in all states and territories. The content and requirements of public access tests can also vary. Members also noted the lack of consistency regarding the training and qualifications of persons conducting public access tests.
The Chair emphasised the need for an outcome where the same assistance animal would have the same assessment outcome irrespective of whether it flew with Qantas, Jetstar, Virgin Australia or Tiger.
CASA, in consultation with AAF members, agreed to develop a minimum standard that would be considered acceptable by the aviation industry, developed in consultation with assistance animal organisations.
Concern was raised regarding the use of the term ‘assistance animal’ as opposed to ‘assistance dog”. The group was advised the term assistance animal is preferred as this is consistent with the terminology used in the Disability Discrimination Act 1992 and allows for any future developments regarding the training of animals other than dogs.
Members were reminded CASA's primary concern is safety and whether the animal is a potential risk to the safe operation of the aircraft and all passengers and crew on board.
Action 6: CASA to distribute the draft Civil Aviation Safety Regulation Part 91.130 to AAF members.
Action 7: CASA, in consultation with the AAF, to finalise an aviation industry standard for the carriage of assistance animals which would be contained in an advisory circular on the carriage of assistance animals.
Agenda Item 5: Airline Code Sharing/Overseas Airports/Passenger Priority procedures
Members noted the Department's advice on current code sharing and passenger priority practices for passengers with a disability in events such as flight cancellations or overbooking.
The airlines outlined avenues for retaining information relating to the special needs of passengers with disabilities, including using existing frequent flyer programs, stressing that the retention of this information is only possible with the passenger's permission, and many passengers do not want their personal information retained by airlines.
Members also discussed possibilities for collecting data on the numbers of passengers with disability that travel by air. It was noted the data currently held by airlines was not complete as it does not capture passengers who could travel independently despite their disabilities or who are being assisted by a friend or relative.
Agenda Item 6: Review of Disability Access Facilitation Plans (DAFPs)
The AAF supported the Department carrying out a review of the disability access facilitation plan initiative including obtaining feedback about the effectiveness and progress of the plans from the disability sector and airline/airport operators. The objective of the process will be to facilitate feedback on how plans are operating and make practical suggestions for improving the initiative.
AAF members agreed to provide comments on the draft feedback form to the AAF secretariat and assist with distributing the form to their members and organisations.
Action 8: AAF members to provide comment on the DAFP feedback form developed by the Department.
Action 9: The Department, in consultation with AAF members, to distribute the feedback from to airline/airport operators and disability sector organisations for comment as part of the Department's review of the Disability Access Facilitation Plan initiative.
Agenda Item 7: Review of the Disability Standards for Accessible Public Transport
The Chair advised members that the Department is currently preparing the draft report of the review of the Disability Standards for Accessible Public Transport. It is envisaged that the final report and the Government's response to the report will be released later this year.
Action 10: The Department to update members when the draft Review of the Disability Standards for Accessible Public Transport is available for public comment.
Agenda Item 8: Other Business
The Department sought information about seating allocations for people with mobility limitations and whether passengers can secure a window seat if they request one.
Jetstar advised that a person with mobility limitations will be allocated an entire row of seats when possible. If the flight is full, the passenger with a disability will be boarded last to avoid having the passenger disrupted by other passengers having to move across them to be seated.
Qantas advised that if the passenger requires the use of an eagle lifter, they will automatically be seated in an aisle seat on the right side of the plane, as the eagle lifter only swings one way.
Both airlines advised that if the passenger does not require assistance to transfer between the aisle wheelchair and aircraft, the passenger they can be seated in the window seat at their request.
The Chair thanked all members and guests for attending this meeting, noting that several members and guests had attended at their own organisation's cost. The Chair indicated advice would be provided to members in due course on a date for the next meeting in the second half of the year.