## National Council on Disability

An independent federal agency making recommendation s to the President and Congress to enhance the quality of life for all Americans wi th disabilities and their families.

1331 F Street, NW ■ Suite 850 ■ Washington, DC 20004
202-272-2004 Voice ■ 202-272-2074 TTY ■ 202-272-2022 Fax ■ www.ncd.gov Statement for the Record

For the Advisory Committee for Aviation Consumer Protection , Office of the Secretary, U.S. Department of Transportation

August 7, 2012 Meeting on Airline Customer Service Issues

The National Council on Disability (NCD) is an inde pendent federal agency with 15 members appointed by the President of the United St ates and confirmed by the U.S. Senate. The purpose of NCD is to promote policies, programs, practices, and procedures that guarantee equal opportunity for all individuals with disabilities, regardless of the nature or significance of the dis ability, and to empower individuals with disabilities to achieve economic self-sufficiency, independent living, and inclusion and integration into all aspects of society.

NCD commends the Advisory Committee for soliciting input about customer service issues for people with disabilities. It is importa nt to recognize that many of the negative experiences of travelers with disabilities go beyon d the typical hassles to which frequent travelers are accustomed, and constitute disability -based discrimination. Many of the
issues could be remedied with customer service trai ning of airlines personnel and their
subcontractors.

Though some progress has been made in the decade si nce enactment of the Air Carrier Access Act Amendments of 2000, primarily in the for m of rule updates by the Department of Transportation, air travel remains a stressful undertaking for most people with disabilities. Airline personnel are not adequ ately trained on the accommodations required by the Air Carrier Access Act, and disabil ity discrimination complaints have steadily increased. The heightened security concer ns that pervade the entire air travel experience since 9/11 have exacerbated air travel d ifficulties for people with disabilities.

In NCD’s 2011 annual report to Congress, NCD stated that it is time to revisit the ACAA, and its regulations and enforcement, to determine w hy discriminatory service in this important transportation sector persists. NCD reco mmended that Congress hold a hearing to examine the experiences of air travelers with disabilities, industry best practices, and enforcement activities by the U.S. D epartment of Transportation and develop corrective actions to make nondiscriminatio n in air travel a reality.

The following are examples of the issues people wit h disabilities encounter when they fly. The list is by no means exhaustive, but inclu des frequent complaints by air travelers
with disabilities.

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• The lack of curb-side check in, common in some air ports since 9/11, makes it difficult, if not impossible, for air travelers wit h disabilities to locate personnel to assist in getting from the airport entrance to a ti cket counter.

• Though DOT solicited comments on the accessibility of airport kiosks, airport kiosks are not accessible for people with disabilit ies.

• Air carriers provide incentives in the form of dis counts to travelers who use their websites to make reservations, but often do not mak e their websites accessible for people with disabilities, and personnel are oft en not aware that they should
offer the same discount to travelers with disabilit ies who have to make reservations by telephone. DOT solicited comments about the accessibility of air carrier websites, but no rule has been issued.

• Airline personnel often communicate with the trave ler’s companions or escort instead of communicating with the traveler with the disability – even turning over important documents such as passports and boarding passes to someone other than the traveler with a disability.

• The subcontractors who provide the escort services are not trained in how to interact with a person with a disability, and it is often difficult to get the proper assistance due to language barriers. There are som e escorts who still insist that a visually impaired person sit in a wheelchair, for example, to get escort assistance. And, they are often unaware of where a n animal relief area is
located.

• Though the ACAA requires that air carriers provide preboarding to passengers who self-identify as needing this service, the airl ine personnel often forget the request and fail to provide the service. When the service is offered, it is typically announced over a public address system that is of n o orientation value to a passenger who is blind or visually impaired. Airli ne personnel begin general boarding before the passenger who is blind or visua lly impaired can determine
where to board.

• Flight attendants often insist that a person with a disability sit in the bulkhead, even when the passenger prefers a different seat, a nd even when the bulkhead provides less room for a service animal than the se at selected by the passenger.

• Flight attendants sometimes ask another passenger, possibly a stranger, to assist the passenger with a disability.

• Many airports do not have an animal relief area.

• Announcements made at the gate are typically not a ccessible for people who are deaf or hard-of-hearing. Information about gate ch anges, reasons for a flight delay, and calls for volunteers to be bumped when a flight is oversold, etc. is only provided audibly.

• Verbal in-flight announcements are not conveyed to people who are deaf or hardof-hearing.

• In-flight movies are typically not captioned.

• The most common complaint from people with physica l disabilities is that the airlines often damage their wheelchairs.

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• During layovers, airline personnel often refuse to bring a person’s customized wheelchair to passengers with mobility disabilities . Passengers needing a customized wheelchair are given airport wheelchairs , which the passenger may not be able to operate independently.

• Some people need special cushions for sitting in a n airline seat. Some airline personnel count these as a carry on, even though th ey do not take up floor or overhead space.

• There is confusion about what assistance will be p rovided to Personal Care Attendants when the attendant is assisting a passen ger with a disability.

• Though the ACAA requires that air carriers have av ailable, upon request, at all times, a Complaint Resolutions Officer (CRO) to han dle complaints of air travelers with disabilities in real time, passenger s report that when they have requested the assistance of a CRO, air carrier pers onnel are not familiar with the

term.

Regrettably, an excerpt from NCD’s 1999 report, “En forcing the Civil Rights of Air
Travelers with Disabilities: Recommendations for t he Department of Transportation and Congress” http://www.ncd.gov/policy/civil_rights , is as apt today as it was then:

When they fly, people with disabilities still face uncertainty about whether air carriers will provide accommodations such as ef fective communication of flight information, accessible seats, appropriat e boarding assistance, and careful handling and stowage of their wheelchai rs and other assistive
devices.

NCD appreciates the opportunity to provide this Sta tement for the Record, and would welcome the opportunity to work collaboratively wit h others to improve airline customer
service for travelers with disabilities.