National Council on Disability 

An independent federal agency making recommendations to the President and Congress 

to enhance the quality of life for all Americans with 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 independent federal agency with 15 

members appointed by the President of the United States 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 disability, 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 important to recognize that many of the negative 

experiences of travelers with disabilities go beyond the typical hassles to which frequent 

travelers are accustomed, and constitute disability-based discrimination. Many of the 

issues could be remedied with customer service training of airlines personnel and their 

subcontractors. 

Though some progress has been made in the decade since enactment of the Air Carrier 

Access Act Amendments of 2000, primarily in the form of rule updates by the 

Department of Transportation, air travel remains a stressful undertaking for most people 

with disabilities. Airline personnel are not adequately trained on the accommodations 

required by the Air Carrier Access Act, and disability discrimination complaints have 

steadily increased. The heightened security concerns that pervade the entire air travel 

experience since 9/11 have exacerbated air travel difficulties 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 why discriminatory service in this 

important transportation sector persists. NCD recommended that Congress hold a 

hearing to examine the experiences of air travelers with disabilities, industry best 

practices, and enforcement activities by the U.S. Department of Transportation and 

develop corrective actions to make nondiscrimination in air travel a reality. 

 

The following are examples of the issues people with disabilities encounter when they 

fly. The list is by no means exhaustive, but includes frequent complaints by air travelers 

with disabilities. 
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• The lack of curb-side check in, common in some airports since 9/11, makes it 

difficult, if not impossible, for air travelers with disabilities to locate personnel to 

assist in getting from the airport entrance to a ticket counter. 

• Though DOT solicited comments on the accessibility of airport kiosks, airport 

kiosks are not accessible for people with disabilities. 

• Air carriers provide incentives in the form of discounts to travelers who use their 

websites to make reservations, but often do not make their websites accessible 

for people with disabilities, and personnel are often not aware that they should 

offer the same discount to travelers with disabilities 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 traveler’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 some 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 an animal relief area is 

located. 

• Though the ACAA requires that air carriers provide preboarding to passengers 

who self-identify as needing this service, the airline 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 no orientation value to a 

passenger who is blind or visually impaired. Airline personnel begin general 

boarding before the passenger who is blind or visually 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, and even when the bulkhead 

provides less room for a service animal than the seat 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 accessible for people who are 

deaf or hard-of-hearing. Information about gate changes, 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 physical 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 an airline seat. Some airline 

personnel count these as a carry on, even though they do not take up floor or 

overhead space. 

• There is confusion about what assistance will be provided to Personal Care 

Attendants when the attendant is assisting a passenger with a disability. 

• Though the ACAA requires that air carriers have available, upon request, at all 

times, a Complaint Resolutions Officer (CRO) to handle complaints of air 

travelers with disabilities in real time, passengers report that when they have 

requested the assistance of a CRO, air carrier personnel are not familiar with the 

term. 

Regrettably, an excerpt from NCD’s 1999 report, “Enforcing the Civil Rights of Air 

Travelers with Disabilities: Recommendations for the 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 effective communication 

of flight information, accessible seats, appropriate boarding assistance, 

and careful handling and stowage of their wheelchairs and other assistive 

devices. 

NCD appreciates the opportunity to provide this Statement for the Record, and would 

welcome the opportunity to work collaboratively with others to improve airline customer 

service for travelers with disabilities.