A review of the complaint process France Civil Aviation provides disabled passengers is cause for concerns as it fails to meet basic accessibility standards.
Updated 22.11.13 16.30 GMT
In Europe, air travel equality law (Regulation (EC)1107/2006) stipulates that “complaints concerning assistance given at an airport should be addressed to the body or bodies designated for the enforcement of this Regulation by the Member State where the airport is situated. “ In other words, if a British disabled passenger has a bad experience at Paris Charles de Gaulle airport, he or she will have to complain with the national Enforcement body, in this case the French Civil Aviation.
Reduced Mobility Rights is currently reviewing accessibility and user friendliness of the complaint process at national level.
Notably, the lack of a common European Standard is the Achilles heel of the process. Each country set up its own process and procedure. This problem is magnified by the fact that our hypothetical British passenger with special needs is faced with two options: filing the complaint with his national Enforcement body, who will then send it over to the French, or contacting France’s Civil Aviation Authority directly.
Unsurprisingly, there is no standard for internal communications between Enforcement bodies either.
Our test comprises the following elements: accessibility of information for passengers with disabilities who wish to file a complaint; user friendliness of the online interface to file the complaint; accessibility of information over the phone; professionalism and competence of officers manning phones; overall transparency of the National Enforcement Body tested by requesting information as members of the press.
User experience report
On 20 November 2013, we started the user test. Like any passenger, we began our quest for information from the airport’s website. The Aeroports De Paris English web page (link to page) dedicated to passengers with reduced mobility and other disabilities is accessible and contains all pertinent information, contacts and links. The page links directly to the Air Transport section of the Ministère de l'Écologie, du Développement durable et de l'Énergie (MEDDE). (link to page)
The page is French only, which makes it hardly accessible to passengers with disabilities who do not speak the language. Using Google Translation we make our way through the site. From the page there is no direct link to the section for passengers with reduced mobility, but a generic one to the page of Passenger Rights. (link to page)
From the generic page we chose the link to the section for passengers with reduced mobility. Information is accessible and current. However, a link to “more information” cannot be traced. (link to page)
Towards the bottom of the page we find the following: “If satisfaction is not obtained, the complaint may be filed with the Directorate General of Civil Aviation (Air Transport Directorate law office passenger air passengers - MDP/P2), as regards the issues air carriers and airport managing bodies and management of tourism (23 instead of Catalonia Paris 14th) with regard to the topics of interest to tour operators (travel package).” Regrettably, there is no link to access the mentioned complaint form MDP/P2.
We then look for a contact telephone number that we found by clicking on the contact link at the very bottom of the page.
At 13.06 GMT of 20 November 2013 we call the number listed, which turns out to be a main switchboard number. We wait on the line for 11 minutes and speak with four different people before being introduced to Mr Sanmarty.
The officer tells us he is not an expert in the Regulation, and the person we should speak to is not immediately available. He gives us his direct email address, asks us to explain the reason why we wish to file the complaint, and promises a swift reply. It takes approximately two minutes to spell out the email address to ensure it is correct, as the url differs from the one of the website page. Eventually, the email bounces, giving an “unknown user” error.
Not having been able to file our complaint we Google “Direction du transport aérien- mission du droit des passagers- bureau des passagers aériens - MDP/P2”. (link to page) The related page of Service Public gives information to an online form to file a complaint for flight delays and cancellations (EC)261/2004. The page also provides the postal address of the Civil Aviation Authority:
Directorate General of Civil Aviation (DGCA), Air Transport, Mission passenger rights, Office of air passengers (MDP/P2), 50 rue Henry Farman, FR - 75720 PARIS CEDEX 15.
Accessibility of information for passengers with disabilities who wish to file a complaint: Poor
User friendliness of the online interface to file the complaint: Poor
Accessibility of information over the phone: Room for improvement
Professionalism and competence of officers manning phones: Room for improvement
Despite our determination in filing a complaint we were unable to complete the task online. The only available option appears to be by post, clearly insufficient in this day and age.
The bare minimum passengers with disabilities should expect is clear contact information and support. In this respect, the UK Civil Aviation Authority is an example of good practice. (link to page)
Press experience report Updated 22.11.13 16.30 GMT
On 15 November we contacted the Press Office of MEDDE by phone. A press officer asked us in very poor English to email our questions. A first set of replies received on 21 November was corrected by DGAC on 22 November. The email, sent and received on the same date, contains the following questions:
Where can disabled passengers find contact information to get in touch with the French NEB?
"In France two NEBs are designated for the Regulation 1107/2006, DGAC (Ministry in charge of transports) for issues related to airports and air carriers and DGCIS (Ministry in charge of tourism)for the issues related to tour operators. There is no application form for PRM on our Ministry web site. PRM can phone the DGAC standard +33 (0) 1 58 09 43 21 and ask the "Mission of passenger rights" (MDP) if they need information or help. A lot of persons are doing so. MDP's secretariat introduces the passenger, but is not in a position to answer to issues concerning PRM.
Why is there no form for PRM issues? PRM issues are always very specific situations and it is very difficult to have a standard set of questions. MDP prefers to receive letters. In a letter passengers can explain exactly what happened to them. A form could be too much restrictive. PRM complaints explained with details and need always to be investigated very carefully."
How many disability-related complaints has the French NEB received in the last 24 months?
"No more than 15 per year. Among those some, concerns other NEBs, just are questions without any complaint, do not enter in the framework of the regulation 1107 (for example they concern third countries carriers at non EU airports), etc."
Does France have sanctions to enforce 1107/2006? If yes, please detail them.
"DGAC has a sanction procedure. Every infringement can be fined up to 7500 € - the fine can be doubled if the same infringement is checked within one year.
DGAC investigates each case. DGAC doesn't work only on the basis of passenger's complaints. This regulation totaly entered into force at the end of the mont of July 2008. France was one of the first, and perhaps the first, EU Country to fine an airline on the basis of the Regulation 1107: a "procès verbal" of infringement was sent in December 2009, the airline was fined in 2010. Our law, for the time being, does not allow to give the name of the airline."
Overall, is the French NEB satisfied with the quality of assistance French airports and airlines operating from and to France offer passengers with disabilities?
"In France this Regulation applies to about 130 airports and concerns a lot of carriers flying to or from. A very low number of complaints received by DGAC concern the handicap.We are opened to study every idea that could help us to improve the service to disabled persons."
Overall transparency of the National Enforcement Body tested by requesting information as members of the press: Room for Improvement.
Our findings raise serious questions about France determination to give disabled passengers access to the complaint procedure, a determining element in the monitoring process of quality of services and assistance airports provide passengers with disabilities. These findings also cast doubts on a recent court case that saw budget airline easyjet fined 70,000 Euro ($90,000, £58,000) by French Courts on allegations of discrimination against disabled passengers.
The French disability rights group APF actively supported the Court case. However, the group appears totally uninterested in making sure disabled passengers can independently report their complaints to the enforcement body. In recent times, ultra-low-cost airline Ryanair accused French authorities of using court cases to protect struggling Air France-KLM from competition.
In Reduced Mobility Rights opinion, the French Civil Aviation Authority must take immediate action to make the complaint process for disabled passengers accessible, user friendly, and related information must also be made available in English.