Aviation Access Forum (AAF)—Record of Outcomes—28 October 2014

Date: Tuesday 28 October 2014
Venue: Qantas Meeting Rooms, Terminal 3, Sydney Airport
Time: 9:30am—12:30pm
Attendees: Australian Federation of Disability Organisations (AFDO)
National Disability Services (the Royal Society for the Blind)
Physical Disability Australia
Deafness Forum of Australia
Inclusion Australia (National Council on Intellectual Disability)
Assistance Dogs Australia
Virgin Australia
Regional Express (REX)
Board of Airline Representatives Australia (BARA)
Australian Airports Association (AAA)
Regional Aviation Association of Australia (RAAA)
Civil Aviation Safety Authority (CASA)
Department of Infrastructure and Regional Development (the Department)—Chair
Apologies: Attorney-General's Department
Department of Social Services
Secretariat: The Department

Key Discussion Items

Agenda Item 1

Welcome, acceptance of draft agenda

The Chair welcomed members and the draft agenda was agreed.

Previous meeting of the Aviation Access Forum—Outcomes and Action Items

Members endorsed the record of outcomes for the 26 February 2014 meeting of the AAF incorporating amendments from Jetstar.  

It was noted that most action items had been completed or would be discussed at this meeting.

In relation to Action Item 1, the AAA confirmed kerbside access and relief areas for assistance animals were a matter for each individual airport operator. Passengers with concerns about a particular airport are encouraged to contact the airport directly and can copy in the AAF Secretariat.

In relation to Action Item 2, the AFDO provided Qantas with feedback about the “essential accessible” software available on Qantas's website. The AFDO advised Qantas that its website is generally accessible and questioned the need for additional software, especially as the additional software was incompatible with screen reading technology. When procuring software, the National Disability Services reminded airlines to ensure it meets priority three compliance with the Web Content Accessibility Guidelines (published by the Web Accessibility Initiative of the World Wide Web Consortium) to guarantee the best standards of accessibility.

Members discussed the methods passengers with a disability use to book flights. Airlines outlined a variety of options were available including the internet, phone and travel agent bookings.

AAF noted that a combination of methods may be used as customers will follow up an online booking with a phone call to ensure their needs were appropriately recorded, or the airline will contact a passenger who has made an online booking for further information.

Qantas advised most bookings are made on its website and the booking fee is waived for passengers with a disability booking via phone.  Virgin Australia informed the forum that their online booking system advises passengers with a disability when they need to contact the airline to complete their booking.

REX reminded members that it is extremely difficult to amend airline online booking systems, as airlines do not own the booking systems they use.

The AFDO informed members that bookings with a guide dog can take up to an hour, even when using the airlines' preferred booking method.  In addition AFDO noted that invoices do not always contain costs when booking with guide dogs, making it difficult to organise reimbursements.

The Deafness Forum advised that their members prefer face to face communication, especially if they have reading and writing difficulties.  Inclusion Australia informed members that people with intellectual disability will often ask support staff and carers to make bookings on their behalf.  In these circumstances it is easier to use online booking systems as support staff can talk the passenger through their options more easily.

BARA agreed to survey international airlines on booking practices for passengers with disability.

Action 1: BARA to survey its members on the booking practices of international airlines for passengers with disabilities and report to next AAF meeting.

In relation to Action Item 3, the Australian Human Rights Commission was unable to attend this meeting however provided written advice on the potential implications of specifying mobility device weight and size limitations in Disability Access Facilitation Plans (DAFP).

Action 2: Department to distribute advice provided by the Human Rights Commission regarding potential implications of specifying mobility device weight and size limitations in DAFPs.

In relation to Action Item 6, CASA advised that the regulatory reform programme including Civil Aviation Safety Regulation (CASR) Part 91, which included provisions covering assistance animals, had been delayed awaiting the Government's response to the Aviation Safety Regulation Review report. This response was currently scheduled to be made by the end of the year.

The latest draft of CASR Part 91 includes a broad list of factors for airlines to consider when determining whether to permit the carriage of an animal in the aircraft cabin.  CASA emphasised that its legislation required safety of the aircraft and passengers on board as the primary consideration in drafting the regulations, which they hoped would be finalised in 2015 and take effect in 2016.

AAF discussed the different types of accreditation of assistance animals, the lack of a national standard and differing evidence based approaches.  It was acknowledged CASA regulations cannot address all animal “accreditation” schemes as they continue to evolve and do not have a common public access test.

Virgin Australia queried why the draft regulations refer to assistance ‘animals’ and not assistance ‘dogs’. CASA noted that the term ‘assistance animal’ is consistent with the Disability Discrimination Act 1995 and allows the regulations to account for future developments in this field.  It also ensures other animals accredited overseas travelling to Australia will be permitted under the regulations.

Action 3: Department to distribute draft Civil Aviation Safety Regulation Part 91.130 and 91.131 regarding the carriage of animals to AAF for final comment.

In relation to Action Item 7, CASA advised it was working with airline operators and the Department to finalise an advisory circular on the carriage of assistance animals.

Action 4: CASA to distribute an updated advisory circular on the carriage of animals to AAF for comment once received.

Agenda item 2: Two wheelchair policy

The Chair informed members that the Department received a range of comments (17 in total) to the draft policy paper on the two wheelchair policies of some Australian airlines.

The paper encouraged airlines to adopt a more flexible approach in accommodating the number of passengers travelling with a wheelchair on aircraft, rather than imposing a strict limit of two.

Taking into account submissions received on the paper, the Chair advised that the Deputy Prime Minister has supported the non-regulatory approach advocated in the paper to update the relevant guidance advice on the Department's website to promote a more flexible policy.

The Department reminded members that airlines are not obliged to comply with this advice and ultimately a decision on the number of passengers travelling with wheelchairs was for each operator.

ParaQuad emphasised that airlines should not compromise a minimum level of service for passengers with disability just as they shouldn't compromise on safety.  ParaQuad suggested that an option is for airlines to charge passengers a modest amount for assistance.  While this is not ideal, ParaQuad advised this is preferred to having no service available.

Virgin Australia informed the AAF it has agreed to adopt the more flexible approach advocated by the Department's paper and this was reflected in Virgin Australia's new disability access policy on its website.

Tiger also confirmed that it does not limit the number of wheelchair passengers in practice and will update their Disability Access Facilitation Plan to reflect this position.

Jetstar informed members that it believes its current practice is appropriate and reasonable and amending the guidance advice could be misleading and create unrealistic passenger expectations.

The Chair advised the Department website would emphasise that the material is guidance only and passengers will need to refer to an airline's Disability Access Facilitation Plan to find information about the specific services provided by the airline they are travelling with.

Action 5: AAF members to provide the Department with final comments on proposed amendments to wheelchair guidance advice by 14 November 2014.

Action 6: The Department to update its website with the outcome of the Department's two wheelchair policy review, including updated guidance advice.

Agenda Item 3: Disability Access Facilitation Plan (DAFP) review

The Chair advised that the Department had received some very useful initial feedback about the current DAFP's as part of its on-line review.

Comments received included that many passengers with a disability are unaware of plans or find it hard to locate DAFPs on operator websites, some plans are overly wordy and unclear and require a high level of literacy, and differences between various airline and airport plans are confusing for some passengers.

Disability sector representatives raised the possibility of linking airline and airport DAFPs however members noted that multiple documents can be difficult for passengers, especially when travelling through multiple airports with different airlines.

Members explored the possibility of referring passengers to airline DAFPs during the booking stage or as part of ticketing information, however as REX had noted previously, this will not be possible in circumstances were the airline does not own the booking system.

BARA acknowledged they had attempted to get more international airlines to publish a DAFP and was happy to renew those efforts.

The Department noted that comments on the DAFP review would still be received over the next few weeks and then it would draft a review report for consideration at the next AAF meeting.

Airlines were also reminded about the importance of ensuring passengers were aware of differences in services provided to passengers with a disability when changing to an aircraft operated by an airline's code-share partner.

Action 7: BARA to continue to encourage international airlines to develop DAFPs.

Action 8: Department to prepare DAFP review report for consideration at the next AAF meeting.

Agenda Item 4: Transport Standards Review

The Department advised that the final report of the review of the Disability Standards for Accessible Public Transport and Government response to the report is expected to be released by the end of 2014.

Members were informed that overall comments to the draft report supported the one aviation specific recommendation arising from the review which calls for the Department, in close consultation with the AAF, to conduct a review of the Disability Access Facilitation Plan initiative by 30 June 2015.

Airlines expressed interest in recommendation 5 of the draft report for a national motorised mobility aid labelling scheme suggesting it could assist airlines more easily determine whether a mobility device can be carried on an aircraft.

Agenda Item 5: Other Business

Kerbside assistance

The Chair informed members that the Department has received representations from members of the disability community outlining the need to provide passengers assistance beyond the terminal building to nearby taxi ranks or parking locations.

Airlines advised that landside of the terminal doors is not considered the ‘workplace’ for occupational health and safety insurance purposes. However this may vary between terminals and airports.

AAF acknowledged that there may be some confusion among airline staff about what they can and cannot do, with passengers experiencing an inconsistent level of assistance between trips. Qantas and Virgin Australia agreed to provide follow-up advice on their policies and the reasons why staff may be unable to assist passengers beyond the terminal at the next AAF meeting.

AAF noted some airports provide kerbside assistance when requested including Canberra Airport.  The AAA agreed to clarify which airports provide this assistance, to what extent and the scope for extending this practice and provide a report at the next AAF meeting.

Representatives from the disability sector noted the expectations of passengers with a disability regarding the level of kerbside assistance they should be able to access may vary, depending for example on their level of disability.  The AFDO stressed the importance of providing kerbside assistance to passengers with vision impairment.

Action 9: Airlines to provide information about their policies regarding assisting passengers with a disability landside of terminal buildings.

Action 10: AAA to advise which Australian airports provide kerbside assistance, the nature and extent of that assistance and the scope to extend such assistance to other airports.

Wheelchair transfers

The Chair advised members that the Department has received correspondence about using the slide board and slide cloth transfer method between airline operator wheelchairs and passengers' personal wheelchairs. The concern that had been raised in this correspondence was that the height difference between the two chairs meant passengers require a high level of assistance to undertake the transfer as they often must work against gravity.

The AAF was informed about an online petition on Charge.org regarding this matter where it is suggested airlines provide a firm cushion to assist the transfer of passenger in these circumstances.

AAF members requested more information about how the use of a cushion could provide assistance noting that given airline wheelchairs were designed to match aircraft seating height then the cushion may in fact have an undesirable effect for that transfer process.

AAF members also noted that there are many different types of cushions used by people with wheelchairs depending on their individual needs, and one variety may not suit everyone's needs. The Department agreed to distribute the Change.org petition to members for their consideration and discussion at the next AAF meeting.

Action 11: Department to distribute link to Change.org petition regrading wheelchair transfers for consideration and discussion at the next AAF meeting.

Seating allocation

The Chair advised members that the Department had received correspondence from a concerned member of the public who felt uncomfortable climbing over a passenger with mobility restrictions sitting on the aisle seat during a flight.  The Chair asked airlines to inform members about their seating policies for passengers with a disability.

Airlines advised that where possible, the airline will block seats next to passengers with a disability to avoid this situation, unless the passenger is being accompanied by a carer who will be seated next to the passenger.  However this is not possible when the aircraft is fully booked.

Airlines will offer passengers with a disability the window seat if they are able to transfer from the aisle wheelchair to the window seat with limited assistance. Where wide body aircraft are used, airlines will seat passengers with mobility limitations in the middle aisle so that other passengers can exit using the alternative passageway.

Airport relief areas for assistance animals

The AFDO congratulated Brisbane Airport on initiatives catering for assistance animals including a dog relieving area, and recommend other airports introduce similar areas. The AAA agreed to pass these comments onto to the airport and other airport operators.

Security Screening

The AFDO commented about inconsistency in security screening processes for passengers travelling with assistance animals at different airports when travelling with the same airline (Qantas).

Action 12: AFDO to provide Qantas with detailed information about the locations and the security screening processes concerned. Qantas to examine this information and then advise the Department if the screening practices warrant further consideration by the Office of Transport Security in terms of current regulations and/or guidance material.