Review of the Disability Access Facilitation Plan Initiative
The purpose of this review is to assess the current application of the Disability Access Facilitation Plan initiative with the aim of improving the overall effectiveness and accessibility of future plans.
Disability Access Facilitation Plans (DAFPs) serve as a communication tool between airline and airport operators and the travelling public on the availability and accessibility of services for passengers with a disability. The plans aim to cover the whole of journey experience from booking a ticket through to arriving at the intended destination.
Since their establishment in 2009, airline and airport operators have been encouraged to develop and publish DAFPs to provide the public with detailed information on the operator's individual approach to meeting the needs of passengers with disabilities.
The Department of Infrastructure and Regional Development (the Department), in consultation with disability and aviation industry representatives, has developed guidelines and templates to assist operators in preparing their plans. These documents are publically available on the Department's website.
There are currently 43 published DAFPs covering all major Australian airlines and capital city airports. The uptake of the initiative has been positive within the Australian domestic aviation sector but less consistent amongst international airlines operating to and from Australia, noting that these airlines may still have information available on disability access on their websites in a different form.
Given the DAFP initiative has been in operation for six years, the Department believes that it is timely to review the initiative with the aim of improving and refining the effectiveness and accessibility of the plans.
The Aviation Access Forum (AAF) agreed to support this review at its 26 February 2014 meeting.
This review is also consistent with Recommendation 7 of the draft Disability Standards for Accessible Public Transport 2002 (the Transport Standards) review report which was publicly released by the Department on 9 May 2014. Recommendation 7 tasks the Department, in close consultation with the AAF, to undertake a review of the DAFP initiative by 30 June 2015 with the aim of improving the overall effectiveness and accessibility of the plans.
Overview of Aviation Industry and Disability Sector Feedback
The Department, in consultation with the AAF, prepared two separate feedback forms for the aviation industry and disability sector. These feedback forms were available on the Department's website between 16 April 2014 and 31 October 2014.
The purpose of the feedback forms was to gain a broad range of views from a variety of stakeholders advising on their experience with the DAFP initiative including potential improvements and other considerations that should be incorporated into the plans.
The Department invited a wide variety of aviation industry members and disability sector representatives to complete the feedback forms.
The Department received a total of 46 responses, with 14 from the aviation industry and 32 from the disability sector.
The majority of responses received from the disability sector were from individuals but there were also submissions from representative organisations.
Overall, responses from both the aviation industry and disability sector supported the DAFP initiative and encouraged its future adoption and improvement.
Responses from the disability sector identified opportunities to refine the DAFP initiative. A re-occurring theme was the lack of awareness of the availability of DAFPs within the disability sector. Some responses indicated that the plans are overly complex and expressed frustration that information provided in the plans did often not match the services provided on the day of travel. Other responses suggested a broader consideration of the provision of services provided by the aviation industry is required.
The responses from the aviation industry showed the various approaches taken by different airline and airport operators in engaging with the public and disability sector. Responses also demonstrated how airline and airport operators implement the services stated in their DAFPs on the ground through mechanisms such as staff training in disability awareness and incorporating the DAFPs into internal policies, procedures and manuals.
A summary of feedback can be found in Appendix A.
International Standards for Disability Access to Aviation
The International Civil Aviation Organisation (ICAO) and international industry bodies, such as the Airports Council International (ACI) and the International Air Transport Association (IATA), provide guidance material to facilitate the transportation of passengers with disabilities. Measuring the DAFP initiative against international guidance material allows us to identify possible improvements to the Australian approach.
Annex 9 “Facilitation” to the Convention on International Civil Aviation (Annex 9) specifies the international standards and recommended practices (SARPs) to facilitate access to air travel for passengers with disabilities. It provides a high level overview for a range of topics including respecting the dignity of the individual, whole of journey access, accessibility of travel information and training programmes for airport and airline operators.
In order to assist member states to comply with the SARPs in Annex 9, the ICAO Facilitation Panel's Working Group on Persons with Disabilities created the “Manual on Access to Air Transport by Persons with Disabilities” (the ICAO Manual) to provide detailed guidance material for each stage of a passenger's journey, ranging from booking a ticket to connections leaving the airport.
The ACI produced a handbook for airport operators titled Airports & Persons with Disabilities (ACI Handbook) and IATA put in place Resolution 700 (IATA Resolution) which specifies the standards operators should follow when providing services to passengers. The ACI Handbook and the IATA Resolution were noted as part of this Review.
Comparison of the DAFP Guidance Material with the ICAO Manual
The ICAO Manual is structured similarly to the DAFP templates with each chapter representing a stage in the passenger's journey. While the ICAO Manual combines the guidance material for airports and airlines into a single document, the DAFP guidance material is divided into separate templates for airline operators, regional airline operators, airport operators and regional airport operators to better address the specific nature of various Australian aviation industry operators.
The majority of the content in the DAFP templates is consistent with the ICAO Manual. However there are a few minor discrepancies. For example, ICAO Manual sections 1.4—1.5 states that the services provided to persons with a disability should be ‘seamless' and that there should be no points in the journey where a person is left without assistance.
The DAFP templates do not expressly state this objective and, in practice, feedback forms to this review indicate that some passengers believe they do not receive sufficient kerbside assistance. Kerbside assistance includes assistance from passenger drop-off and parking areas (including train and bus drop-off areas) to the check-in counter and from the baggage collection area to the pick-up and parking areas.
In addition, ICAO Manual sections 10.1—10.5 specify that airlines should cover any loss or damage to mobility aids. However, there is no recommendation in the DAFP templates that suggest airlines adhere to this policy. Some major Australian domestic airlines state in their DAFP that passengers must obtain travel insurance to cover the risk of loss or damage to their mobility aid.
Submissions to the Review provided valuable insight into the practical implementations of the DAFP initiative. Based on an assessment of the feedback received from both members of the aviation industry and the disability sector, the Department proposes that the AAF consider the following recommendations to improve and further refine the DAFP initiative.
Recommendation 1: Increase public and industry awareness of DAFPs
Feedback from the disability sector indicated that awareness of DAFPs is low among the general public. It was found that passengers with a disability make reservations through a variety of methods including telephone and internet bookings. Also, reservations are often made by third parties, such as family members, community service providers or travel agents.
To ensure DAFPs are increasingly used, it is suggested the AAF consider promoting the availability of DAFPs to both passengers with a disability and others who may be making reservations on their behalf, through the following actions.
Action 1: The AAF updates the DAFP guidance material to encourage airlines to notify passengers of DAFPs during the initial booking stage where possible.
Where possible, airlines should notify passengers who identify as having a disability of the airline's DAFP during the booking stage.
For a telephone booking, staff members could be instructed to advise passengers of the DAFPs during the booking process. In circumstances where the passenger cannot access the plan online, staff could offer to send the passenger a hard copy of the document.
For an internet booking, a link could be created from the online booking system to the DAFP located on the operator's website. It is noted that there may be some difficulty in implementing this arrangement as some airlines do not own the booking systems they utilise.
Action 2: The AAF updates the DAFP guidance material to encourage operators to ensure their DAFP is easy to find on their website.
During this review it was found that while the majority of DAFPs were accessible within two clicks from the operator's home page, some operator DAFPs are difficult to locate because they are hidden under multiple subpages and different operators place them under different sections of their website.
It is suggested that the AAF update the guidance material to encourage operators to:
- place their DAFP as near to the homepage as possible;
- ensure the DAFP is available through the website's search function; and
- use a visual symbol on the operator's homepage that links directly to the relevant section of the website. A suggested symbol is the international access symbol for persons with disabilities shown in Figure 1.
The AAF guidance material could also suggest operator websites conform to the Web Content Accessibility Guidelines as set by the World Wide Web Consortium (W3C), if this is not already the case.
The table at Appendix B identifies which DAFPs are easily accessible and which could be placed on a more prominent page of the operator's website.
Action 3: The Chair of the AAF writes to and informs the Australian Federation of Travel Agents and major travel agencies of the DAFP initiative and asks for their assistance in distributing DAFP information to their members.
Passengers with a disability often make bookings through a travel agent. It is suggested the Chair of the AAF write to the Australian Federation of Travel Agents and major companies to promote the use and distribution of DAFP plans. While some airlines may already provide travel agents with information about making reservations for passengers with a disability, this information may be more specific to the systems and processes travel agents use to make a booking. They therefore may not be suitable for use by passengers who may benefit from access to a reference document which explains what they can expect from a particular airline or airport on the day of travel.
Action 4: The Australian Airports Association (AAA) uses the airport Community Aviation Consultation Groups to pass on information about the DAFP initiative.
Leased Federal Airports are expected to maintain Community Aviation Consultation Groups (CACGs). These groups are a mechanism to ensure there is appropriate community engagement on airport planning and operational issues.
The Department's Guidelines for CACGs suggest that the terms of reference for each group include “access issues for passengers, including passengers with a disability.” Some groups, such as Darwin Airport's CACG, include representatives from the disability sector. The AAA can use the CACGs, whose airports support regular public transport operations, to regularly inform the members of the DAFP initiative and DAFP plans.
Action 5: The Department contacts the AAA and airport operators to encourage them to consider disability access in their Master Plan and Major Development Plan processes.
As part of their Master Plan and Major Development Plan processes, airport operators should be encouraged to consider the passenger's whole-of-journey experience. It is proposed the Department write to each airport operator that has a DAFP and encourage them to consider disability access as part of their planning process. This would encourage airport operators to actively consult and receive feedback from the disability sector and the public.
Consideration of disability access matters early in the planning process will allow operators to ensure the appropriate infrastructure is available from the beginning when changes can be readily implemented.
Recommendation 2: Make DAFP information easier to understand
Feedback received from the disability sector indicates that some DAFPs are complex, overly wordy, or require a high level of literacy. A number of suggestions were made about how to make DAFPs easier to comprehend.
The Department asks that the AAF consider the following actions for improving the comprehension of plans.
Action 1: The AAF improves the DAFP guidance material and templates by encouraging the use of visual symbols in DAFPs to make information more user-friendly.
It is suggested the AAF review DAFP guidance material and templates to identify possible improvements which will assist operators make their plans more accessible for passengers. Feedback from the disability sector advised that the use of visual symbols and representations are a highly effective method for conveying complex information to passengers with a disability.
Hence, the DAFP templates could be updated to provide specific examples or areas where the use of visual symbols may be helpful for passengers. This could include maps of the airport which identify the locations of hearing loops and pictures of airline/airport supplied wheelchairs. It is noted that some operators already include such diagrams in their plans.
Action 2: The AAF updates the DAFP guidance material to encourage airline and airport operators to develop complementary media for DAFPs.
To assist passengers understand the information provided in plans, airline and airport operators could consider developing complementary media in addition to their DAFP. For example, some submissions suggested operators create separate information sheets for each type of disability to complement the overarching DAFP. This could include individual information sheets for passengers with vision impairment, hearing impairment, mobility limitations and passengers travelling with assistance animals.
The information sheets would serve as a quick reference guide and checklist for a passenger with a particular disability and, if more information is needed, they can refer to the airline or airports DAFP. It is noted that some airlines, including Qantas and Virgin, already provide a separate webpage for passengers with a specific type of disability, such as a visual or hearing disability, alongside their DAFPs.
One submission from the disability sector suggested that an instructional video about the services available by a particular airline or airport operator would better convey information to passengers with a disability and their carers. This could greatly assist passengers with reading or comprehension difficulties and who find DAFPs overly wordy and complex.
Ultimately individual operators should determine what complementary material is most appropriate, taking into account their unique business models and operational requirements.
Recommendation 3: Consider the whole-of-journey experience for passengers with a disability
A frequently raised concern is that passengers have not been provided with sufficient information or appropriate assistance which has impeded the quality of their journey. This includes passengers being made to wait in wheelchairs for extended periods of time for assistance, a lack of assistance to and from kerbside drop-off and pick-up areas, a lack of inflight entertainment and a lack of assistance with baggage collection.
The travelling experience can also be improved for passengers with a disability through providing information about secondary services such as the locations for retail stores, restaurants and other businesses. It is also important to recognise that passenger's broader journey maybe affected by their air travel and it is important that the relevant information is communicated to the passenger to assist them.
This review represents an opportunity for airline and airport operators to address gaps in the whole-of-journey experience for passengers with a disability.
Action 1: The AAF updates the DAFP guidance material to encourage operators to better coordinate assistance to passengers with a disability with other service providers.
A passenger with a disability may engage with a number of service providers through their journey, including airlines, airports, customs and immigration, security screening operators, public transport organisations, retail stores and restaurants. Communication and active engagement between service providers could give passengers a more complete travel experience.
Feedback forms indicate that there is confusion around whether the airline or airport operator can provide certain services such as kerbside assistance. It is suggested that the AAF update the DAFP guidance material to encourage airline and airport operators to write how they will coordinate with each other as well as other service providers to improve a passenger's whole of journey experience. This would include addressing where gaps in the whole-of-journey experience may occur.
The benefits of this approach are that it would allow airlines and airport operators to complement each other's assistance to the passenger. Discussions about assistance to passengers with a disability could form part of existing airline and airport consultation arrangements, such as those dealing with facilitation and security issues.
Action 2: The AAF updates the DAFP guidance material to cover provisions related to airline policies related to the damage or loss of mobility aids and consider options for providing appropriate assistance to the passenger until the mobility aid is repaired or recovered.
A damaged or lost mobility aid could prevent a passenger with a disability from continuing their journey.
It is suggested that the DAFP guidance material be updated to cover provisions related to airline policies related to the damage or loss of mobility aids having regard to the specification in the ICAO Manual. The DAFP guidance material should encourage airlines to clearly articulate the type of assistance the airline will provide to passengers, and the extent of that assistance, in their individual DAFP.
It is suggested that airline operators consider the possible options to assist passengers whose mobility aid has been damaged or lost during their flight. This may include providing the passenger with appropriate support to assist them in reaching their destination and/or reimbursing the passenger for any costs or expenses incurred for the period they did not have access to their mobility aid.
Recommendation 4: Promote a Better Approach for Reviewing individual DAFP's which includes consultation with the disability sector.
Feedback from the disability sector suggests some plans are outdated and do not reflect service provided on the day of travel. It is suggested the AAF promote better approaches to reviewing plans.
Action 1: The AAF updates the DAFP guidance material to encourage a better approach to reviewing DAFPs which includes consultation with the disability sector.
It is suggested that the AAF update DAFP guidance material and templates to encourage airline and airport operators to conduct regular reviews of their DAFPs that includes active engagement with local and national disability groups. DAFPs should be updated when airlines and airport make changes to their procedures which will impact on passengers with a disability.
DAFP guidance material could be updated to include basic guidance on factors operators should consider when reviewing their DAFPs, such as:
- regular and active consultation with the disability sector;
- feedback received through complaints;
- changes to airline and airport infrastructure and operational polices; and
- changes to infrastructure and policies of other services providers operating at airports.
This will allow for a more robust review while also being flexible enough to take into account the differences between the size, geographical location and operating requirements of individual airline and airport operators. DAFPs should be, at a minimum, reviewed annually to ensure they are current.
It is suggested that the DAFP guidance material also include advice to assist operators to consult with the disability sector. For example, the guidance material could include information to on the types of disabilities they need to consider (e.g. sensory, physical and intellectual) and the details of representative organisations. This could aid a broader range of consultations such as when airport operators create major development plans (Recommendation 2: Action 5) or when operators engage with other service providers to better coordinate services (Recommendation 3: Action 1).
Following consideration and agreement by the AAF, the Department will update the DAFP guidance material. The Department will seek any comments from the AAF members on the revised material before publishing it online.
The Chair of the AAF will then write to airline and airport operators to advise the outcome of the DAFP review and provide a copy of the revised guidance material and templates.
Appendix A: Summary of the Feedback Forms
|Airline operators indicated that the feedback received on their DAFPs from the public was useful and helped improve the plans.|
|The majority of airlines have arrangements in place for reviewing their DAFPs. Some mechanisms are informal, such as irregular feedback from passengers, while others conduct annual or biennial reviews which include consultation with disability stakeholder groups.|
|All major airline operators seek to ensure that the practices on the ground reflect the policy stated in the DAFPs through a range of methods including staff training in disability awareness and procedures for using specialised equipment and incorporating the DAFP content into internal policies, procedures and manuals, such as the Cabin Crew Operations Manual.|
|All airport operators have a feedback arrangement in place with some relying solely upon the feedback received through their customer relations area while others actively engage with the disability sector.|
|When reviewing their DAFPs, some airports have no contact with external stakeholders while others actively engage with local disability organisations.|
|All airport operators try to ensure that practice on the ground reflects the policy outlined in their DAFPs through staff training arrangements. Some airport operators that employ contractors have stated it is the contractor's responsibility to implement their own procedures and training for assisting passengers with a disability.|
|Airport operators suggested that clearer guidelines on disability consultation would assist them in preparing their plans.|
|The disability sector indicated a lack of public awareness about the DAFP initiative with 24 of the 32 responses saying that they or their family and friends were unaware about the existence of DAFPs.|
|Airline and airport operator websites should follow the Web Content Accessibility Guidelines as set by the World Wide Web Consortium. DAFPs should be published in both WORD and PDF format to assist those using screen reading software.|
|Bookings for passengers with a disability are often made by third parties such as community service providers, health therapists and family members who might not be aware of the DAFP initiative.|
|Some passengers, particularly passengers with vision impairment, obtain information about what to expect on the day of travel through word of mouth.|
|DAFPs are often difficult to find on operator websites because they are located under subdirectories. A direct link to DAFPs should be placed on the homepage of operator websites or in a consistent location across operator websites and search functions on operator websites should be better linked to DAFPs.|
|Passengers should be notified about an airline's DAFP during the booking stage and travel agents should be aware of DAFPs.|
|A landing page, either on the website of the Department, a peak aviation organisation or a peak disability sector organisation, which provides a list and links to all available airport and airline DAFPs would be helpful for passengers with a disability and those making bookings on their behalf. (Note: This already exists on the Department's website.)|
|Content of the Plans|
|Some of the feedbacks forms suggested the use of visual symbols and images to compliment the written instructions in the DAFPs.|
|Many DAFPs are overly wordy, unclear and require a high level of literacy. This is even reflected in the title of the plans. A simpler title could assist in better search abilities.|
|DAFPs should include additional information about whole of journey considerations including assistance from passenger drop-off/pick-up and check in/baggage collection areas.|
|DAFPs should include a passenger ‘frequently asked questions' section.|
|Policy differences between airlines can create difficulties for travellers who expect that each airline and airport will provide the same level of service. Having to access multiple plans for the one journey creates confusion for some passengers.|
|DAFPs focus on passengers with physical disabilities and do not account for passengers with intellectual disabilities and autism.|
|It would be helpful if plans had separate sections for different types of disability (for example mobility impairment, hearing impairment, vision impairment and intellectual disability) which explains what the passenger can expect throughout their journey.|
|There are key areas of assistance which are not provided, not provided consistently, or not provided in accordance with airline or airport operators' stated policies. These types of issues, rather than the accessibility and contents of DAFPs, are significant hurdles for passengers with a disability accessing air travel.|
|Passengers in airport wheelchairs should be provided with appropriate, consistent service and should not be left in airport wheelchairs for unnecessary lengths of time.|
|Passengers should be provided with assistance when escalators and lifts are out of order in airports.|
|Airlines should introduce subtitles on all inflight entertainment.|
|Airlines should allow online access for disability bookings (currently some airlines require that bookings be made by phone).|
|Airlines should introduce adjustable aircraft seats/airline wheelchairs to meet different wheelchair heights when transferring.|
|Airlines should promote better training of cabin crew regarding different requirements for passengers using wheelchairs.|
|Airlines or airports should provide kerbside assistance from passenger drop off, including car parks and taxi and bus drop off areas, to airline check-in counters.|
|Airline and airports should ensure equipment and services are available on the day of travel and staff are trained to operate the equipment safety and effectively.|
|Announcements should be provided visually for passengers with hearing impairments and hearing loops should be operational throughout airports.|
|Assistance should be provided to passengers when collecting baggage (as this can be extremely difficult for passengers with vision impairment who are unable to identify which bag is their bag on the carousel).|
|Airlines should apply a consistent approach regarding the carriage of guide dogs and assistance animals.|
Appendix B: Accessibility of DAFPs from the Airline and Airport Operator's Homepage
|Organisation||Is the DAFP available on the operator' website?||Is the DAFP easy to find on operator website? (one subpages or less)||Does the DAFP appear when using the search function on the operator's website?|
|Airnorth||Yes||Yes (one subpage under ‘plan your trip/special needs')||Yes|
|Jetstar||Yes||Yes (one subpage under ‘plan and book/specific assistance')||Yes|
|Qantas||Yes||Yes (one subpage ‘under fly/specific needs')||Yes|
|Regional Express||Yes||Yes (one subpage under ‘travelling and flight info/ booking info')||No search function available|
|Skippers Aviation||Yes||Yes (one subpage under ‘flight info')||No search function available|
|Tiger Air||Yes||Yes (homepage but not in the ‘special needs and assistance section')||No search function available|
|Vincent Aviation||Yes||No (two subpages ‘flying with us' and ‘special needs'||Yes|
|Virgin Australia||Yes||Yes (one subpage under ‘planning')||Yes|
|Cathay Pacific||Yes||Yes (one subpage under ‘travel information/special assistance')||Yes|
|Singapore Airlines||Yes—called Equal Access Plan||Yes (one subpage under ‘travel information/special assistance')||Yes|
|Qatar||Yes||Yes (one subpage under ‘travel/disability assistance')||Yes|
|Organisation||Is the DAFP available on the operator's website?||Is the DAFP easy to find on operator website? (one subpages or less)||Appears in search function?|
|Adelaide Airport||Yes||Yes (one subpage under passengers/special assistance)||Yes|
|Brisbane Airport||Yes||Yes (one subpage under passenger information/disability access)||Yes—through disability access link|
|Canberra Airport||Yes||No (two subpages under travellers information/special assistance)||No search function available|
|Darwin Airport||Yes||No (two subpages under passenger info/terminal info)||Yes—through terminal info link|
|Hobart Airport||Yes||Yes (under passenger/accessibility)||Yes –through accessibility link|
|Perth Airport||Yes||No (two subpages under passenger information/passenger assistance)||No|
|Melbourne Airport||Yes||No (under three subpages flight and passenger info/maps and facilities/disability access)||Yes|
|Sydney Airport||Yes||Yes -but not obvious (one subpage under prepare/quick links special assistance)||Yes|
|Alice Springs Airport||Yes—called Disability Access Plan||Yes (one subpage under passenger info/disabled persons info)||Yes|
|Diamantina—Bedourie Airport||Yes||Yes (under aerodromes page of council website)||Yes—through aerodromes page|
|Cairns Airport||Yes||No—only under one subpage, but hidden at the bottom of the page under airport/passenger facilities||Yes –through access for all link|
|Ceduna Airport||Yes||Yes (under the airport page of the Ceduna council website)||Yes|
|Dubbo Airport||Yes||No—only under one subpage but not easy to find as placed under ‘about the airport'||No|
|Flinders Airport||Yes||Yes (under airport page of council website)||No|
|Geraldton Airport||Yes—called Disability Access Plan||Yes (one subpage under disabled access)||Yes|
|Gold Coast Airport||Yes—called Information for Guests with Special Needs||Yes (one subpage under at the airport/ special needs)||No search function available|
|Hamilton Island||Yes||Yes (on council website under airport/ terminal information)||Yes|
|Hervey Bay Airport||Yes||Yes (two subpages under airport facilities/disability access0||Yes|
|Kalbarri Aerodrome||Yes||Yes (on shire website under aerodromes)||No|
|Launceston Airport||Yes||Yes (under passenger info/disability plan)||Yes|
|Mackay Airport||Yes||Yes (one subpage under airport/access for all)||Yes—through access for all link|
|Mount Gambier Airport||Yes||Yes (on home page under quick links, special needs)||No search function available|
|*Mount Isa Airport||No||In the ‘regulatory' section there is a link to the DAFP but it does not work||No|
|*Newcastle Airport||No—but does have information for ‘passengers with restricted mobility'||No||No|
|Orange Airport||Yes||Yes (on airport page of council website)||No|
|Parkes Airport||Yes||Yes (on airport page of council website)||Yes|
|Rockhampton Airport||Yes||No—on airport page of council website under publications||No search function available|
|Townsville Airport||Yes—but called Information for Guests with Special Needs||Yes (under travelling/passengers with special needs)||No search function available|
* These airlines and airports have previously corresponded with the Department stating they have DAFPs but the plans were not accessible on their websites.