Draft Policy Paper - Airline Two Wheelchair Policies April 2014
Contents OVERVIEW... 3 SUBMISSIONS TO THE ISSUES PAPER... 4 Disability Community... 4 Airline Operations... 6 FLEXIBILITY WITH THE TWO WHEELCHAIR POLICY... 8 PROPOSED WAY FORWARD... 10 2 Policy Paper- Airline Two Wheelchair Policies
1: Overview Members of the disability community have expressed concern about the two wheelchair policies adopted by some Australian domestic airlines (Virgin, Tiger and Jetstar), the effect of which is to not allow more than two passengers requiring the use of wheelchairs on a single flight. While those policies may be expressed in different terms by airlines, for ease of reference they are referred to as the airline two wheelchair policies. For the purposes of this paper the term wheelchair is taken to include manual or electric wheelchairs, and electric scooters. On 3 June 2013, the former Department of Infrastructure and Transport publicly released an Issues Paper about the airline two wheelchair polices. The aim of the paper was to gather information about the policy from the airlines concerned and impacts associated with the policy for affected passengers. The Issues Paper recognised that many disability groups would like to see the policies and their practice ceased but acknowledged that the aviation industry had set out a number of economic, operational and safety reasons underpinning the adoption of the policies, particularly in relation to low cost domestic carriers. The Paper also noted overseas practice while recognising that direct comparisons are impacted by a number of factors including the size of airline operations, the operational/business model of airlines and the infrastructure available at airports. Submissions to the Issues Paper were received in July and August 2013. The Department received seventeen submissions in total including thirteen from the disability community and four from the aviation sector. After consideration of these submissions, the Department has prepared this Policy Paper as a suggested way forward to help alleviate the effects of the policy on passengers with mobility restrictions, but without creating unjustifiable operational and economic hardship for the airlines. In effect, the Department proposes that the Australian domestic airlines, which currently have a two wheelchair policy, update their Disability Access Facilitation Plans and operating practices to: not have a limit of two wheelchairs per flight but rather advise passengers there are operational circumstances where the airline may not be able to carry more than two passengers requiring wheelchair assistance; emphasise the importance of passengers requiring wheelchair assistance to contact airlines as early as possible before their preferred flight to check the airline can provide appropriate assistance; and ensure airline booking processes prompt passengers to provide the airlines with information about their mobility assistance requirements and notify passengers as early as possible if the airline is unable to carry the passenger requiring wheelchair assistance on their preferred flight, and offering these passengers alternative flight arrangements. Policy Paper- Airline Two Wheelchair Policies 3
2: Submissions to the Issues Paper 2.1: Disability Community Summary The impacts of the two wheelchair policy on passengers requiring mobility assistance can vary. Some examples provided in submissions to the Issues Paper include the additional costs of alternative flights and extra accommodation requirements if required to fly a day (or more) earlier than intended, the inconvenience of missing events such as conferences, family occasions and sporting activities when flying earlier is not a viable option, and the emotional effects associated with perceived discrimination. The effects of the policy can be exacerbated when passengers are travelling to and from remote locations without regular air transport services, or when there are groups of passengers that require assistance travelling to the same location, for example to a disability-related conference. While members of the disability community disagree with the two wheelchair policy, there is recognition by that community that airlines are confronted with operational and safety restrictions that cannot always be overcome. This is particularly recognised in terms of the operations of smaller aircraft and at regional airports. Therefore some submissions identified a number of issues associated with the policy that, if addressed by airlines, could help minimise its impacts on passengers who require mobility assistance. Areas for improvement (a) Early notification that the preferred flight is unavailable A number of submissions raised concerns about insufficient notification by airlines at the booking stage that the passengers preferred flight is unable to accommodate any further passengers requiring assistance. Submissions claimed that despite booking many months in advance, on occasions some passengers were informed they were unable to travel on their booked flight on arrival at the airport. It was suggested that if airlines are to maintain some form of two wheelchair policy, they should ensure passengers are informed at the booking stage if their preferred flight is not available. One Australian domestic airline requires passengers travelling with wheelchairs to make reservations by phone. However, if a passenger is not aware of this requirement they may make an on-line booking for their preferred flight without providing the airline with information about their special needs requirements and without knowing whether the two wheelchair limit has already been reached. If the online booking system cannot be improved to accommodate the needs of passengers requiring wheelchair assistance, it should be made clear in the online booking process that the passenger must contact the airline call centre for assistance with their reservation. This will ensure 4 Policy Paper- Airline Two Wheelchair Policies
airlines are given sufficient notification of the passenger s requirements and provide passengers with greater certainty about their journey. (b) Clarity about the scope of the policies and recognition of varying degrees of mobility restriction Some submissions raised concerns about the scope of the policies claiming the definition or classification of wheelchair assistance is often unclear. It is uncertain whether a passenger requiring minimal assistance, for example a passenger who requires assistance moving through the terminal from the check-in counter to the boarding gate, but who can make their own way onto the aircraft and into their assigned seat, is included in the two wheelchair quota. This type of passenger could be travelling with or without a personal wheelchair, or with another mobility aid such as a walking frame or crutches. It was also suggested in some submissions that airlines should consider the passenger s level of disability when determining whether the airline is able to accommodate the passenger on a flight. For example, airlines may be able to allow three or four passengers travelling with lightweight manual wheelchairs and/or passengers requiring minimal assistance who are able to assist with their own transfer to and from an aircraft seat. These passengers will require far less assistance compared to passengers who use a larger mobility device, such as an electric scooter, or require assistance from airline staff to transfer from their mobility device to their aircraft seat. (c) Disability related events and conferences It was evident in submissions that a key impact of the policy was that groups of passengers who require wheelchair assistance are unable to travel together. Disability related events and conferences (such as the Disability Care conferences) may require multiple passengers with wheelchairs to travel to a designated location at a particular time, however the two wheelchair policy does not accommodate for these scenarios. In these circumstances, airlines should consider whether it is possible to specifically cater for such events when sufficient notification is provided through measures such as scheduling additional staff and arranging additional equipment for a particular flight (e.g. airline/airport wheelchairs). Comparisons to Overseas airlines Some submissions compared arrangements in Australia with arrangements overseas. The United States, Canada and European Union have regulations regarding an air carrier s ability to limit the number of passengers with disability that can travel per flight. As a result, most carriers in these jurisdictions, including low cost carriers, do not impose a wheelchair limit. Some submissions contended that Australian s major air routes are no different to other air routes around the world, and if operators in international jurisdictions can operate without a limit, then Australian operators can do the same. However while the policy settings in these overseas jurisdictions aim to ensure passengers with a disability receive unlimited services, there are provisions which recognise that safety and operational factors may limit access to wheelchairs on some flights and at some destinations and that this does occur. Policy Paper- Airline Two Wheelchair Policies 5
2.2 Airline Operations Summary Australia s airline operators, who adopt a two wheelchair policy, set out a number of economic, operational and safety reasons justifying its use. One airline states that while the two wheelchair policy may cause inconveniences for some passengers, overall the policy successfully meets demand. The airline stated that in the financial year 2012/2013, there were 46,797 passengers requesting wheelchair assistance, which amounts to approximately 0.542 passengers per flight. The airline indicates that the policy is therefore appropriate and reasonable. However, it should be noted that the same airline also recognises that the volume of passengers requiring wheelchair assistance is significantly increasing. The airline also pointed out that it invests a significant amount of resources for assisting passengers with mobility restrictions. This includes additional costs associated with transporting passenger s personal wheelchairs, purchasing equipment such as aisle and airport wheelchairs, employing extra staff to assist passengers form check-in to their aircraft seat and training staff to safely assist passengers in a dignified and appropriate manner. A range of alternatives are also offered to passengers if they are unable to take their preferred flight due to the two wheelchair policy including moving passengers to an earlier or later flight or re-routing passengers to their intended destination. In summary, the airlines see unlimited wheelchair assistance as incompatible to: - the operations of low cost, quick turnaround aircraft services; - the operations of smaller regional airlines; and - airports, where size and safety limitations associated with the carriage of multiple or larger mobility devices require limits on how many passengers requiring assistance can be carried. Reasons for the airline two wheelchair polices (a) Restricted turnaround times Submissions covering low cost carriers advised that they are able to offer low fares due to high aircraft utilisation, short turnaround times and other streamlined operational arrangements. These include a more limited specific assistance service, for example using the slide board and cloth method of transfer of passengers with a disability instead of eagle lifters used by some full service airlines at some capital city airports. Generally, the turnaround time for low cost carriers is 30 or 40 minutes depending on the nature of the particular aircraft and its passenger capacity. In this time, airline crew are required to assist passengers arriving at their destination to disembark the aircraft, and assist passengers leaving the airport to board the aircraft. Some submissions pointed out that this means there are potentially four passengers requiring wheelchair assistance in each flight turnaround period (i.e two arriving and two departing passengers). 6 Policy Paper- Airline Two Wheelchair Policies
Airlines indicated that passengers who need wheelchair assistance generally require a significant amount of additional support compared to other passengers, such as passengers with vision and hearing impairments and passengers travelling with assistance animals. Assistance may include transferring the passenger from their mobility aid to their assigned aircraft seat and loading the passenger s personal wheelchair into the cargo hold. Through a time motion study, one airline found that the time taken to board passengers requiring differing levels of wheelchair assistance is between 9 and 17 minutes and for disembarking between 6 and 9 minutes. According to some airline operators, accommodating more than two passengers requiring wheelchair assistance per flight will require an increase in aircraft turnaround times and adversely affect their operating cost models. Airlines indicated that increasing turnaround times would ultimately reduce the number of flights an airline is able to operate per day potentially leading to higher airfares for all passengers and adversely affecting airline employment. (b) Scheduling implications and delays Flight schedules are planned well in advance. Airlines have indicated that limiting the number of passengers requiring wheelchair assistance means airlines can better plan the types of services which will be required of crew on any given flight thereby minimising potential delays. According to airline submissions, making provision to assist more than two passengers requiring wheelchair assistance would escalate delays. Delays affect all passengers on that flight, and are likely to affect passengers on subsequent flights due to the domino effect which could be made worse by factors such as airport curfews, cancellations due to crew exceeding maximum allowable operating hours and airport congestion. Delays can result in financial implications for airlines including additional labour costs and ground handling costs, additional fuel costs if the airline decides to speed up the aircraft in flight to make up time and the costs of overnighting crew if airport curfews are missed. Delays can also have adverse effects for customer perceptions of a particular airline s performance. (c) Aircraft utilisation issues and airport infrastructure requirements Airlines can have a variety of aircraft models with varying cargo hold capacities and weight limitations. A large electric scooter may simply be unable to fit through a small cargo hold door. Smaller aircraft have strict weight restrictions and the weight must be evenly distributed for the safe operation of the aircraft. The weight of some electric scooters may mean operators are unable to meet these important safety requirements if they were accepted on board. Smaller aircraft generally have one aisle, while some larger aircraft have two. An additional aisle allows multiple passengers requiring mobility assistance to board the aircraft and transfer to their seat at the same time. However, larger aircraft are generally reserved for long haul flights, including international flights. Airlines generally aim to provide the appropriate aircraft size for each route depending on demand and airport infrastructure. Policy Paper- Airline Two Wheelchair Policies 7
Many regional airports do not have the demand, runway capacity and terminal infrastructure to support larger aircraft. Airlines suggested that many regional airports have limited facilities for loading passengers with a disability and attempts to cater for more than two passengers could result in costly investment and increased airport charges for airlines in locations where returns are already marginal. (d) Ground crew and cabin crew resources Submissions indicate that if more than two passengers requiring wheelchair assistance per flight were accepted, additional ground crew would be required to load additional wheelchairs into and out of the aircraft cargo hold. Extra equipment (such as aisle wheelchairs) would also be required to accommodate more guests needing mobility assistance per flight. Additional cabin crew and staff may also be required to carry out duties such as assisting with transfers to and from aisle wheelchairs and aircraft seats, obtaining dangerous goods approval for mobility aid batteries, conducting individual safety briefings and perform responsibilities in the unlikely event of an emergency. Additional cabin crew staff would result in lost seats to fare paying passengers because they would be required for crew. (e) Impacts to other passengers All passengers are subject to limitations in terms of baggage allowances. Changes to two wheelchair policies may further limit the size and weight of luggage that can be carried per passenger per flight, as the space in the cargo hold would be taken up by wheelchairs. The airlines argue that removing two wheelchair policies can increase aircraft turnaround times which may result in reduced flight options and higher airfares for all passengers. (f) Freight commitments Some airlines have agreements with transport companies for the provision of freight services. Changes to two wheelchair policies may mean airlines are unable to meet freight commitments because cargo space has been taken up by additional wheelchairs. This has the potential to expose airlines to financial penalties for failing to meet their service contract which may ultimately result in increased passenger fares to ensure operating costs are covered. 3: Flexibility with the two wheelchair policy While there are valid commercial and operational reasons for airlines imposing restrictions on the amount of assistance they can offer for each flight, there also appear to be opportunities for reducing the operation and impact of two wheelchair policies. One airline with a two wheelchair policy has indicated that they already seek to accommodate more than two passengers who require special assistance per flight when operational and safety requirements permit. The airline advised the limit of two is simply a trigger for the airlines booking system to request the intervention of an airline staff member to make an assessment about whether the flight can accommodate the passenger s needs. 8 Policy Paper- Airline Two Wheelchair Policies
In all circumstances where this has occurred, the airline has been able to carry the third passenger requiring wheelchair assistance. In the interests of clarity, this should be highlighted in their Disability Access Facilitation Plan. The International Air Transport Association (IATA) has developed a classification system for identifying passengers requiring wheelchair assistance which some airlines have referenced in their submissions and adopted in their Disability Access Facilitation Plans. If airlines choose to maintain a wheelchair limit, they could consider using IATA s classification system to clarify which passengers are subject to the restriction. However, it should be noted that IATA s definition is silent about whether the passenger is travelling with or without a personal wheelchair. The classification system is outlined below: WCHR wheelchair ramp Passenger can ascend/descend steps and make own way to/from cabin seat, but require wheelchair assistance for distances to/from aircraft (for example, between check-in and the gate). WCHS wheelchair step Passenger cannot ascend/decent steps, but is able to make own way to/from cabin seat; requires wheelchair for distance to/from aircraft and check-in lounge and must be carried up/down steps. WCHS wheelchair cabin Passenger completely immobile. Requires wheelchair to/from aircraft and check-in and must be carried up/down steps and to/from cabin seat. Using IATA s classification system, airlines could limit the number of WCHS and WCHC passengers travelling per flight, but accept an unlimited number of WCHR passengers as there would be a limited impact on boarding times. An arrangement such as this would provide greater flexibility and ensure a larger number of passengers who require minimal wheelchair assistance are able to board their preferred flight. However, one airline in its submission did address the suggestion of creating a more flexible policy using IATA s classification system (as suggested above) by stating it is not practical or feasible for a range of reasons including: there are already delays caused by accommodating two passengers requiring wheelchair assistance; there is little difference between the times taken to assist passengers with varying levels of disability; a complex, flexible practice creates more opportunity for service errors, customer complaints and delays; passengers do not always properly self-identify the level of assistance they require when making their reservation; and a flexible arrangement would incur additional administrative costs. Policy Paper- Airline Two Wheelchair Policies 9
4: Proposed way forward While acknowledging that an unlimited number of passengers requiring assistance is not practical for the operations of airlines, there is an opportunity to enable the carriage of more than two passengers requiring wheelchair assistance when operational circumstances allow if this is assisted by better planning by the passenger and the airline. This is particularly the case given there appear only a small number of times when the requirements for the carriage of more than two passengers requiring wheelchair assistance on the same flight does occur. One low cost airline has already confirmed that there is flexibility in the application of the policy now. Further, by improving the booking process, it may be possible to alleviate some of the effects of the policy on passengers with mobility restrictions, without creating unjustifiable hardship for airlines. The following are suggestions for improving current arrangements: (a) Adopt a more flexible approach to the implementation of the policy Submissions from the disability community highlighted the inflexible nature of the airline two wheelchair policies and called for airlines to consider the varying levels of disability and assistance required by passengers when making a determination about whether a passenger can be accommodated on a flight. While acknowledging that an unlimited number of passengers requiring wheelchair assistance can have adverse operational impacts, airlines should review the absolute limit of two and consider a passenger s request for a particular flight by taking into account the following: the extent of the passengers disability and the level of assistance to be provided by the airline; whether the passenger is travelling with a personal wheelchair to be loaded into the aircraft; the size and weight of the passengers personal wheelchair as small manual foldable wheelchairs will be easier to load and unload compared to electric scooters (which may also be accompanied by a spare battery that will need dangerous goods approval); the nature of assistance required for passengers already booked on the flight; the airport infrastructure available at the departure and arrival airports; and the type of aircraft allocated to the passengers preferred flight. These considerations in making an assessment should be included in Disability Access Facilitation Plans (DAFP s) as follows: There are limits to the number of passengers requiring wheelchair assistance which the airline can carry on a particular flight. In deciding how many passengers requiring wheelchair assistance the airline is able to carry on a particular flight, the airline will take into consideration the following: 10 Policy Paper- Airline Two Wheelchair Policies
The extent of the passengers disability and the level of assistance they require from airline staff; Whether the passenger is travelling with a personal wheelchair and if so the nature of that wheelchair; and The level of assistance required for any other passengers already booked on the flight. In a normal operating environment, the airline can generally accept up to two passengers requiring wheelchair assistance; however this may be more or less depending on the operational and safety requirements of the particular flight. (b) Improve the booking process In some submissions it was suggested that passengers are not always given sufficient notification that their preferred flight is unavailable due to two wheelchair policy restrictions. This may be because some online booking systems do not allow passengers to provide information about their special requirements. Airlines should review their booking processes for passengers with mobility restrictions (particularly online bookings systems) and update their DAFP s to ensure passengers requiring wheelchair assistance: contact airlines as early as possible before their preferred flight to check the airline can provide appropriate assistance; are prompted to provide the airline with information about their mobility assistance requirements when booking; and are notified as early as possible if they are unable to take their preferred flight and offering the passenger alternative flight arrangements. (c) Amend the guidance material on the carriage of mobility aids The Aviation Access Forum should also update the guidance material on the carriage of mobility aids to address issues raised in submissions and reflect best practice in this area. The updated version could include the following: notification should be provided at the booking stage if passengers are unable to take their preferred flight due to limits on the number of passengers requiring wheelchair assistance; and factors airlines should take into account when determining whether a passenger requiring wheelchair assistance can be carried on a particular flight. Policy Paper- Airline Two Wheelchair Policies 11