CAA Performance Framework for Airline Accessibility Analysis

The Civil Aviation Authority (CAA) is dedicated to ensuring that all passengers, including those with disabilities, have equal access to air travel.

In order to achieve this goal, the CAA has recently launched a consultation on its draft Performance Framework for Airline Accessibility, also known as CAP2486. This consultation aims to gather feedback from stakeholders and the public in order to develop a comprehensive framework that addresses the needs of disabled passengers and ensures their rights are protected. The content of CAP2486 covers several key areas related to airline accessibility:

1. Legal Framework: The document outlines the legal basis for the performance framework, which is grounded in the UK's and European Union's Regulation (EC) No 1107/2006. This law mandate that airlines provide assistance to disabled passengers and ensure their equal access to air travel.

2. Objectives and Scope: The draft framework sets out the objectives and scope of the performance measures, which include monitoring and assessing airlines' compliance with accessibility regulations, identifying areas for improvement, and promoting best practices in the industry.

3. Performance Measures: CAP2486 proposes a set of performance measures that airlines will be audited on. These measures include the provision of information and assistance to disabled passengers, the handling of complaints, staff training, and the availability of accessible facilities onboard aircraft.

The context of the CAP2486 consultation reflects the CAA's commitment to ensuring equal access to air travel for disabled passengers. By seeking input from stakeholders and the public, the CAA aims to develop a robust and effective performance framework that addresses the needs of disabled passengers and holds airlines accountable for providing accessible services.

We have analyzed the draft of CAP2486 released earlier today and divided our comments into three categories: the good, the bad, and the ugly.

The Good

James Fremantle and his team at the Civil Aviation Authority have done a great job running a thorough fact-gathering exercise across the aviation industry. Their findings are the bedrock of the proposals contained in the Airline Accessibility Framework. While most proposals fall well within current industry standards, some innovative proposals originating from the Air Carrier Access Act are coming into play, like the availability of onboard aisle chairs on all aircraft (currently there is no such rule in the UK and European legislation), the availability of storing a personal manual wheelchair in the cabin, and movable armrests on at least 50 percent of seats. These proposals have been made to enhance the travel experience for passengers with disabilities and ensure that they have equal access to air travel.

The implementation of these proposals would be a significant step forward in promoting inclusivity and accessibility in the aviation industry. However, it is important to note that there is still a long way to go in terms of ensuring that all disabled passengers are able to travel comfortably and safely, without facing any discrimination or barriers.

The Bad

Although the proposed framework has addressed many inconsistencies, one that has yet to be resolved is the suggestion of giving airlines with very good ratings the obligation to fit their cabins with at least 50% of movable armrests, an essential requirement in the United States, but with no such equivalent existing in the U.K. or Europe. The tantalizing promise of improved ratings might not be enough to convince airlines to launch the costly endeavor of updating the insides of their planes.

Forgetting to consider cabin densification, or the attempt to fit as many passengers as possible into the cabin while disregarding seat pitch, was an oversight of monumental importance. This is an enormous worry for the elderly, those with impaired mobility, and those who are overweight.

The chapter dedicated to website and app accessibility brings up yet another contentious matter: the CAA is suggesting that airlines with WGAC 2.1 compliant platforms should be rated "very good". But, at the same time, we strongly feel that if a platform doesn't adhere to web accessibility standards, it should automatically receive a "poor" rating.

The Ugly

One major concern with the CAP2486 draft is the lack of enforcement mechanisms to ensure compliance with the proposed regulations. Without proper oversight and penalties for non-compliance, these proposals may not be effective in improving accessibility for passengers with disabilities.

Anna Bowles, Head of Consumer at the CAA, expressed a sentiment that has sparked eager anticipation - despite the fact that the airlines' watchdog lacks the capacity to follow through. "The initiative to launch the framework is meant to ensure airlines uphold their responsibilities to less mobile and disabled customers throughout their journey," Bowles stated. "People must have the assurance that the services offered when traveling meet their needs."

Leading the public to believe that the CAA has meaningful powers to uphold the rights of disabled people would be ill-advised, as its ability to deliver such assurances is simply nonexistent.

Despite the success of the CAA's creative system of public rating in airports, the proposed framework could still be fatally flawed due to an erroneous assumption; it may not prove as effective when applied to airlines. Airports are fashioned by the individuals inhabiting the regions they service, however, airlines have minimal dependence on them.

The budget airline industry has chosen to prioritize affordability over service standards, often resulting in poor ratings. Surprisingly, this could work in their favor: by not assisting as many disabled passengers, airlines can shorten their turnaround time and ultimately improve their overall on-time performance. On the other hand, if an airline meets and exceeds new service standards and does well on accessibility ratings, it could experience the exact opposite. Consequently, the CAA's proposed framework could potentially give rise to market manipulation, creating a domino effect with significant repercussions expanding to airports.

Conclusions

James Fremantle and his remarkable CAA team have truly outdone themselves, crafting a draft that could be the ideal foundation for new legislation designed to bolster the rights of disabled people traveling by air. Their actions have, as always, gone above and beyond the call of duty. But, no matter what perspective one takes, CAP2486 is just guidance and, hence, cannot be enforced. Significantly, we took into account the danger of unscrupulous airlines exploiting the system and profiting by seeking to be rated "poor" for the provision of inadequate services to those with disabilities, while the airlines that offer quality service would be subject to a financial disadvantage. Sadly, after careful consideration, we deemed it wisest to provide a negative response to Query 1 of the survey.: "Do you agree we should introduce an airline accessibility framework?"

More information on the consultation

By gathering feedback and refining the proposed framework, the CAA can develop a comprehensive system that effectively monitors accessibility regulations, ultimately leading to improved experiences for disabled passengers. The consultation opened today and will close on July 21st. Click here to review the draft of CAP2486 and share your comments.