Airport Operators Association Response to CAA Review of PRM Regulation Implementation
The Airport Operators Association (AOA) is the trade association that represents the interests of
British airports. Our membership comprises 74 airport companies, representing all of the nation's
international hub and major regional airports in addition to many serving community, business and
In 2008 AOA member airports handled more than 228 million passengers, nearly 2.5 million tonnes
of freight and over 2.3 million air transport movements. An independent study has also shown that
these airports are major players in the aviation industry's contribution of some £11.4 billion to the
UK's annual gross domestic product (around 1.2% of total GDP).
AOA welcomes the opportunity to respond to this review of the PRM Regulation implementation. In
order to respond to this review AOA surveyed members, responses came from BAA Heathrow, Peel
Airports Group, East Midlands (MAG), Birmingham, Prestwick, TBI Airports Group (Cardiff, Belfast
and Luton), Bristol, Gloucestershire, and Newcastle. The responses received from the airports are
attached to this document.
Key points of AOA’s Response
• AOA and its members believe the legislation has had a positive impact on improving access
to air travel for disabled passengers and those with reduced mobility.
• AOA members were concerned about the costs of implementing the Regulation and the
inconsistency between airlines willingness to pay.
• Responses also highlighted the high staffing levels needed to implement the Regulation.
• AOA would like to see more definite guidance produced by the CAA to alleviate issues of
individual interpretation and the information on what constitutes a PRM.
• We would like to see regulatory bodies encouraging airlines to pay the charges relating to
Impact of PRMs Regulation on customers:
1. Do you think that the Regulation has improved access to air travel for disabled passengers
with reduced mobility?
Yes, AOA and its members believe that the introduction of the Regulation has greatly
improved access for PRMs. The number of PRMs across UK airports has increased. Since
implementation Cardiff airport has seen a 300% increase per month in the number of PRMs.
2. Has the introduction of the regulation affected your business/ organisation? If so, how?
Yes. Airports have highlighted the labour intensity of the regulation; in particular the amount
of time required to manage the implementation of the regulation and to oversee third party
contractors and other staff dealing with PRMs.
An increase in costs was also highlighted by respondents. Luton airport stated that it had led
to the breakdown of good working relationships with the various companies involved,
Heathrow reported that the regulation had caused additional pressures in areas such as
operations and operational planning because the numbers had been higher than forecast
and it was difficult to accommodate all the requirements under the original plan. The
passenger experience had also been impacted due to waiting times for assistance.
3. How aware do you feel are the travelling public aware of their rights and responsibilities
under the Regulation? Do you have any evidence of misuse of the regulation by
Levels of awareness of rights differed. Younger passengers and frequent flyers tend to be
more aware than others. Evidence suggests, in some cases, PRMs are not aware of the
responsibility they have to inform airports, airlines, handling agents etc of their
requirements before they travel, making assistance difficult.
It was evident from responses that, although it was difficult to substantiate, the regulation
was misused by people trying to beat queues and get on the aircraft first. Bristol airport
highlighted that misuse of the regulation added significant cost to the airport and airlines.
4. What advice do you provide to passengers on the assistance that they might require or
Airports provide information to PRMs about assistance via their websites, and telephone
help lines, for example East Midlands has a dedicated page that includes services available
and a brief description of Regulation 1107/2006. Cardiff airport reported it had made
contact with local disability groups to best inform passengers on assistance requirements.
Experience of PRM Implementation
5. Do you differentiate the service between pre-notified and non pre-notified passengers? If
not, would you consider doing so?
AOA received mixed responses from members regarding pre notification. The airports that
do differentiate include Bristol, Birmingham, Newcastle, Heathrow, Belfast, Prestwick and
Cardiff. These airports reported they differentiated between pre-notified and non pre-
notified on the grounds that Service Level Agreements agreed for pre-notified PRMs meant
that they had priority, especially during peak times and also allowed airports to plan their
Airports which did not differentiate would consider doing so if the number of PRMs
6. Since the Regulation was introduced, what percentage of requests for pre-notification are
passed on to you by airlines or tour operators at least 36 hours before the published
departure time for the flight? How are you notified?
AOA believes that individual airports would be best placed to answer questions regarding
percentages of pre-notification as data collected by AOA shows that this can vary heavily
from airport to airport. (Appendix A contains all the information received from members)
Airports report that they receive direct communication, via telephone or email, from
airlines, handling agents, tour operators and PRMs directly. To increase the efficiency of pre-
notification, airports have installed PAL/CAL/ SITA systems, with other airports in the
process of installing these systems to increase pre-notification.
7. How have the number of PRM assistance requests changed since the Regulation was
introduced? Were your PRM numbers accurate?
AOA members highlighted that whilst overall passenger numbers have fallen, due to the
recession, the number of PRMs has increased Birmingham airport reported that this had led
to a increase is cost per departing passenger. A number of airports did not collect data on
PRMs prior to the implementation of the Regulation, however. Forecasts made by airports
have been in accurate. Actual numbers have been higher than expected; this has meant
more staff time and resources to ensure the regulation is fully implemented.
8. What steps have you taken to increase the number of timely pre-notifications you receive?
Airports are working closely with all parties involved to increase pre-notification. A number
of airports are currently installing SITA to assist in pre-notification.
9. Do you have any problems with the way in which airlines and tour operators pass on pre-
notifications to you?
Airports highlighted inconsistency between airlines in terms of pre-notification. Information
is often unreliable due to in-correct codings. Belfast airport highlighted that PRMs
themselves are not aware of their responsibility. Failing to pre-notify airlines causes
problems with passing on their assistance requirements to the airport.
10. Have you faced any particular difficulties in taking over responsibility for providing
services to disabled persons and PRMs?
The main difficulty indicated by airports having taken over responsibility of PRMs is the level
of staffing required. It was highlighted by AOA members that forecasts for correct staff levels
had been miscalculated due to inexperience and a higher than predicted number of PRMs
using UK airports.
East Midlands airport also indicated that the number of people accompanying a PRM in the
Ambulift had caused problems, especially on incoming flights and cabin crew being unaware
of PRM capacity constraints.
The financial burden placed on the airport was also a difficulty, especially with passenger
numbers falling and the misuse of the Regulation. Heathrow highlighted the cost of PRMs to
be 35p per departing passenger, about £11m per annum. Newcastle’s cost per departing
passenger was 25p, about £500,000 per annum. These costs will increase during year 2.
11. Have you had any problems delivering suitable training for your staff (including security
staff and ground handlers)? Have you had to introduce training where none was provided
before? Please provide details of your training policy and of the specific training provided.
Airports have not had any problems delivering suitable training for their staff. Front line staff
had already received basic training to deal with PRMs and people with disabilities. Manual
handling and other training had also been put in place by airports to ensure that the
regulation was fully implemented.
Individual airports are better placed to provide specific details of training provided.
12. What percentages of complaints relate to PRMs service and what are the key reasons for
The responses received by AOA showed that on average less than 5% of all complaints are
related to PRM services at airports. The main reasons given for complaints were waiting
times and the process of embarking and disembarking the aircraft.
13. What was your per passenger charge in the first year of the Regulation (i.e. from 1 July
2008 to 30 June 2009)? Did it cover the costs you anticipated? Did it change during the
During the first year of the regulation the cost of the regulation per departing passenger
varied between 18.5p and 26p. At Heathrow it was 35p. Prestwick airport absorbs the costs
incurred is assisting PRMs. All airports reported that the higher than forecast number of
PRMs meant that the anticipated costs were not covered. Charges were not amended during
the year, it was reported however, that the charge for year 2 was being re-negotiated.
14. In terms of your overall revenue from airport charges, what percentage does the per
passenger charge constitute?
Individual airport operators would be better placed to answer.
15. How did you develop service standards for PRM services? Have any amendments been
made based on your experiences since implementation? Please provide details as to
where your service standards are published.
Members have reported that service standards have been developed following published
regulations, AOC and DfT Guidance, past experience and individual interpretation.
AOA feels that as individual airports have set service standards they would be better place to
inform where they are available.
Government/ Enforcement/ Future Actions
16. Is there sufficient guidance on how you could interpret and comply with the Regulation?
We believe that guidance has been subject to individual interpretation and as a result there
is not enough emphasis on responsibility of airlines to pay the charges arising from funding
AOA members would like to receive more definitive guidance, particularly on what
constitutes a PRM as the regulation has been abused by non-qualifying passengers.
17. Have you had any experience in dealing with the CAA, EHRC or DfT in relation to these
issues? Please comment on experience, clearly indicating which body you are referring to.
18. What could these bodies or other stakeholders do to improve the workings of the current
AOA believes that the regulation, as it stands, could be improved through encouraging
airlines and other stakeholders to send through timely pre-notifications, this was a noted by
the majority of respondents to the AOA survey; airlines taking more responsibility to pre-
notify airports and awareness of the operational pressures on facing airports in dealing with
increasing numbers of PRMs; and encouraging airlines to pay the charges as per the PRM
Airports have been hit with a financial burden from the implementation of this legislation
with airports, including Cardiff and Bristol, citing the need for costs to be met by airlines.
It has also been suggested by East Midlands Airport, Belfast and Heathrow that the CAA
produce an information database for airports to use as a reference point to allow airports to
discuss their provisions for PRMs and offer each other guidance as some airports have
greater understanding of the provisions required than others.
19. The European Commission is planning to review the implementation of the Regulation in
2010. In what ways do you think could the Regulation be improved?
AOA and its members believe that the Regulation could be improved through closer
relationships between all stakeholders to ensure a better service for PRMs notably through
pre-notification and cost recovery.
AOA believes that creating national forums, in which all stakeholders are involved, would
aid the implementation of the Regulation. The review needs to look at cost recovery and
encourage airlines to pay the charges through a charging mechanism. We would also like to
definitive guidelines published so that there is a national standard.
Bristol International Airport
CAA Questions for review of operation of PRM Regulation May 2009
Impact of the PRMs Regulations on You and Your Customers:
Q1. Do you think the Regulation has improved access to air travel for disabled
passengers with reduced mobility ?
A1. Yes undoubtedly the introduction of the Regulation has greatly improved access to
air travel for PRMs.
Q2. Has the introduction of the Regulation affected your business / organisation? If
A2. Yes it has affected our organisation in that a lot of management time is spent
overseeing the provision of the service to ensure our contractor is providing the
service to our customers as outlined in the Regulation.
Q3. How aware do you feel are the travelling public aware of their rights and
responsibilities under the Regulation? Do you have any evidence of misuse of
the regulation by passengers?
A3. They are becoming more and more aware of their rights although we do not believe
they are equally aware of their responsibilities in that prior notice is required.
Feedback from our PRM provider indicates that quite often they are used as a
portering service above and beyond the requirement of the regulation. It is also
interpreted by the PRM provider that in some instances the service is used to gain an
expeditious route through the airport, in order to board the aircraft ahead of other
passengers. Whilst it is difficult to obtain unequivocal evidence to support misuse we
do believe that misuse occurs frequently. This incurs significant additional cost to BIA
and the airlines.
Q4. What advice do you provide to passengers on the assistance that they might
require or request ?
A4. We provide information on our website covering the above.
Experience of PRM Implementation:
Q5. Do you differentiate the service between pre-notified and non-pre notified
passengers? If not, would you consider doing so?
A5. Yes, if there is a busy period, pre-notified get priority to ensure the provider meets
the agreed SLAs. Where we can, we try to provide a uniform service to all our PRMs.
Q6. Since the Regulation was introduced, what percentage of requests for pre-
notification are passed to you by airlines or tour operators at least 36hrs
before the published departure time for the flight? How are you notified?
A6. 36 hours before approximately 40% of PRM numbers are notified, overall
approximately 65% of PRM numbers are notified 24hrs prior to STD. Notification is
by email or SITA address.
Q7. How have the number of PRM assistance requests changed since the
regulation was introduced? Were your forecasted PRM numbers accurate?
A7. Our forecast of PRM numbers for the first year were accurate, however the total
number of passengers have dropped considerably due to the economic climate.
Therefore in real terms PRM numbers are actually well above those predicted. to
date - circa 20%, we believe this is in part due to greater awareness of the service
Q8. What steps have you taken to increase the number of timely pre-notifications
A8. We have worked very closely with the local AOC and the Handling agents to ensure
we expedite the flow of information.
Q9. Do you have any problems with the way in which airlines and tour operators
pass on pre-notifications to you?
A9. Yes, there is a lot of inconsistency, certain airlines are a lot more pro-active than
Q10. Have you faced any particular difficulties in taking over responsibility for
providing services to disabled persons and PRMs
A10. From a management perspective we have not faced any unexpected difficulties in
taking on the responsibilities other than a lot of Airport Authority staff time in
managing the service. We do however have problems recovering the cost from
certain airlines. Indeed one in particular has refused to pay the required charge.
Q11. Have you had any problems delivering suitable training to your staff (including
security staff and ground handlers)? Have you had to introduce training where
none was provided before? Please provide details of your training policy and
of the specific training provided.
A11. No we have not had any problems delivering training and we have had to introduce it
where comprehensive training had not previously been provided.
Our policy is to ensure that all staff that come into contact with PRMs at the least
have basic awareness training. We use the format provided by Skill Boosters bdp
media group; “Disability Confident – working with disabled customers and
Q12. What percentages of your complaints relate to the PRMs service and what are
the key reasons for complaint?
A12. We receive very few complaints; luckily we have a very efficient service provider who
works very well with the Airport Authority and ground handlers. When we do get the
odd complaint it is normally for the length of time the PRM has to wait for baggage in
the arrivals hall.
Q13. What was your per passenger charge in the first year of the Regulation (i.e.
from 1st July 2008 to 30th June 2009). Did it cover the costs you anticipated?
Did it change during the year?
A13. Our charge for the first year was 23p per departing passenger. No it did not cover the
costs we anticipated due to the sharp fall in overall passenger numbers and the fact
that the cost base is relatively fixed. To date we have under recovered costs by
approximately 12%. We are currently negotiating with the Airlines to increase costs in
the second year to recover the loss. This is proving to be very challenging as the
airlines are also suffering from the current economic climate.
Q14. In terms of your overall revenue from airport charges, what percentage does
the per passenger PRM charge constitute?.
A14. Approximately 1.25%.
Q15. How did you develop service standards for PRM Services? Have any
amendments been made based on your experiences since implementation?.
Please provide details as to where your service standards are published.
A15. We developed the SLAs from past experience and calculated what reasonable
response times are for both the PRM and the service provider. The more onerous the
SLA the more costly to the Airline, however we were also mindful when compiling the
need to provide a good service to the customer. So far the service provider has met
the standards set and there has been no need to amend them. Initially our service
standards were provided to the Airlines operating at BRS with reports containing
performance levels provided on a monthly basis.
Q16. Is there sufficient guidance on how you could interpret and comply with the
A16. Although the regulation is on the whole very comprehensive, more specific guidance
should be provided on what constitutes a PRM. This would especially help the
service provider who at the moment is obliged to offer PRM assistance to literally
anyone who requests it, this issue negatively impacts the service for genuine PRMs.
This is the biggest issue we face and we believe results in misuse.
Q17. Have you had any experience in dealing with the CAA,EHRC or DfT in relation
to these issues? Please comment on experience, clearly indicating which body
you are referring to.
A17. The only direct contact the airport authority has had is with a member EHRC before
the regulation was implemented. This communication was in the form of a meeting
on site to ensure we met the expectations of the EHRC. No major issues were
Q18. What could these bodies or other stakeholders do to improve the workings of
the current regulation?
A18. If more time/thought could be given to providing guidance on what constitutes
Also re-emphasis to the Airlines and Tour Operators on the importance of pre-
notification of PRM assistance to ensure the provision of a seamless service.
Make it mandatory that Airlines need to pay the agreed charges. Open book
accounting and other safeguards can be employed to provide the Airlines confidence
that the charge is appropriate.
Q19. The European Commission is planning to review the implementation of the
Regulation in 2010. In what ways do you think could the Regulation be
• Review the interpretation of who qualifies for PRM assistance and ensure this is
made clear for all in the revised regulation.
• Re-emphasise the importance of pre-notification of PRM assistance
• Provision for full cost recovery from Airline community
East Midlands Airport response
UK Civil Aviation Authority
Questions for review of operation of PRM Regulation
Impact of the PRMs Regulations on You and Your Customers:
1 Do you think the Regulation has improved access to air travel for disabled
passengers and passengers with reduced mobility?
Yes there has been a significant improvement in the standard of service provided.
This is confirmed by the level of positive feedback we have received, both verbal and
We have also seen a steady increase in PRM numbers since July 2008, despite the
downturn in general passenger figures.
% of pax who are
total no. of arriving departing total pax PRM’S
January 1866 149047 135281 284328 0.66
February 1624 149208 146140 295348 0.55
March 2227 163792 162270 326062 0.68
April 2591 188975 183877 372852 0.69
May 3894 203402 228193 431595 0.902
2 Has the introduction of the Regulation affected your business / organisation? If so,
We are reviewing the scope of our existing services and facilities to ensure we are
able to cope with the increasing numbers of PRM’s travelling through EMA. For
example we are in the process of increasing the capacity of our disabled car park.
The only other effect has been the requirement for staff to monitor, audit and
manage the contract on behalf of EMA
3 How aware do you feel are the travelling public are of their rights and responsibilities
under the Regulation? Do you have any evidence of misuse of the regulation by
To date there is little evidence of misuse.
4 What advice do you provide to passengers on the assistance that they might require
(i.e. distances at airports) or request (i.e. what mobility equipment they can take)?
EMA has a dedicated accessibility section on our web site. This gives general details
of the disabled services available at the airport. We have added a brief description of
Regulation 1107/2006 explaining what this means to passengers, along with a link to
the EHRC web site.
Passengers may download a copy of our disabled travel guide “”Access” which gives
more specific details of the airport facilities.
We have included internet links to relevant disabled travel sites. See below
For advice on flying with your assistance dog contact:
www.guidedogs.org.uk or www.hearingdogs.org.uk
Useful web links:
The UK government code of practice for access to air travel for disabled people may
be found at: www.dft.gov.uk
Printed copies of the EMA “Access” brochure are placed in our two passenger
assistance lounges, our PRM contract provider’s desk, the main information desk
and the reception desk of our company headquarters.
We do not provide advice on the carriage of mobility equipment as any limitations are
imposed by the airlines.
Experience of PRM Implementation:
5 Do you differentiate the service between pre-notified and non-pre notified
passengers? If not, would you consider doing so?
We do not currently differentiate between the two groups. However, given the
increasing numbers of PRM’s this may be a consideration in the future. The main
reason for doing this would be, to encourage passengers to pre-book their
We do however have two levels within the service standards. There are slight
differences for pre-notified and non notified. This follows the ECAC model
6 Since the Regulation was introduced, what percentage of requests for pre-notification
are passed to you by airlines or tour operators at least 36 hours before the published
departure time for the flight? How are you notified?
We have been monitoring the airline performance with relation to pre-notification, on
a monthly basis.
This table shows the percentage of pre-notifications received for the first 6 months of
1st quarter average
Thomas Cook 46.5%
2nd quarter average
Thomas Cook 64.6%
We share this feedback with the EMA based airlines each month.
Our service provider, OCS receive the pre-notifications via:-
7 How have the number of PRM assistance requests changed since the Regulation
was introduced? Were your forecasted PRM numbers accurate?
PRM assistance requests have almost doubled when comparing 2008 statistics with
The PRM numbers have exceeded our predictions.
8 What steps have you taken to increase the number of timely pre-notifications you
We hold regular meetings with the airlines to assess performance and discuss ways
of improving it still further.
If we had an issue with a specific airline we will see the relevant Station Manager
For example we had some initial problems with Thomsonfly, and in particular the
poor performance of their European outstations. Working in partnership with them we
have seen a twofold increase in destination pre-notification.
We have worked to promote the need for disabled passengers to pre-book their
assistance. This has been communicated via the EMA web site and as part of a
programme of training which is delivered to travel agents throughout the region.
9 Do you have any problems with the way in which airlines and tour operators pass on
pre-notifications to you?
10 Have you faced any particular difficulties in taking over responsibility for providing
services to disabled persons and PRMs?
Operationally the transfer has been largely successful.
Our main concern is based on the enormous financial changes which have adversely
affected aviation generally.
Our service provider is under pressure, as their predicted income is significantly less,
whilst the numbers of PRM’s they are processing is increasing.
This is placing a strain on their existing resources.
Over the last 3 months we have started to find a problem with the number of
companions wishing to accompany the PRM in the ambulift. We have tried to limit the
number to one. This has had a degree of success with flights departing from EMA,
however we are experiencing very real capacity issues on our inbound flights.
This seems to be due to a lack of understanding from the cabin crew. They fail to see
the importance of limiting the number of companions. A recent example was an
inbound IT flight with 10 PRM’s on board. When OCS arrived at the aircraft a total of
40 people were waiting for transfer to Arrivals. Clearly this problem is more
pronounced at EMA because we do not have an air bridge operation, which
increases our dependence on the ambulifts.
In general airline crew need to be more aware of the impact their actions can have on
the PRM operation.
The short turn round times for low cost airlines are a particular challenge at EMA.
Until recently the airlines appeared to limit the numbers of certain categories of PRM,
based on safety considerations. These limits now seem to have been removed and
yet the airlines still expect us to complete the turn round and meet the SLA’s which
were formulated, and agreed on the former capacities. Again the real issue rests
with the airlines who do not seem to appreciate the impact that this sort of
operational change may have on the PRM service.
11 Have you had any problems delivering suitable training to your staff (including
security staff and ground handlers)? Have you had to introduce training where none
was provided before? Please provide details of your training policy and of the specific
OCS are the PRM service provider at East Midlands Airport
Although EMA staff have received disability awareness training prior to the
introduction of the Regulation,
MAG (Manchester Airport Group) have recently launched a company wide
It is expected that this will be delivered to all EMA customer service staff during the
latter half of 2009.
Security at EMA is provided by G4S – they provide disability awareness training as
part of their induction process.
12 What percentages of your complaints relate to the PRM service and what are the key
reasons for complaint?
From 1st August 2008 – 30th May 2009 we have received the following via the EMA
comment card system:-
Compliments 18 (along with numerous letters and cards received by OCS)
Complaints 2 (of which only 1 was upheld after investigation)
13 What was your per passenger charge in the first year of the Regulation (i.e. from 1
July 2008 to 30 June 2009). Did it cover the costs you anticipated? Did it change
during the year?
• Cost per departing passenger was 23.7 pence
• The cost has not been adjusted so far. However it is reviewed on a quarterly
basis and may require some minor adjustment upwards in the near future.
The agreement between EMA and the contractor includes a scale of charges
which is designed to provide a degree of protection for either side, in the
event of fluctuations in passenger numbers (up or down).
We may be required to invoke this in order to reduce the losses the contractor
has incurred as a direct result of the fall in departing passenger numbers.
14 In terms of your overall revenue from airport charges, what percentage does the per
passenger PRM charge constitute?
The airlines are invoiced separately for the PRM service.
We do not consider the PRM charge to be income as we simply cover the service
provision and contract charges, and do not make a profit.
15 How did you develop service standards for PRM services? Have any amendments
been made based on your experiences since implementation? Please provide details
as to where your service standards are published.
The service standards are based on those contained within the ECAC- Code of Good
Conduct in Ground Handling for Persons with Reduced Mobility. (A copy of the EMA
standards may be found in Appendix 1)
These were discussed and agreed with the EMA based airlines and external disabled
Our service standards are published on the EMA website, within the accessibility
We have not needed to adjust the parameters as yet.
16 Is there sufficient guidance on how you could interpret and comply with the
At present this is limited and could be improved.
17 Have you had any experience in dealing with the CAA, EHRC or DfT in relation to
these issues? Please comment on this experience, clearly indicating which body you
are referring to.
To date, EMA has consulted twice, with Tim May at the CAA.
On both occasions we have received prompt replies with clear and concise advice.
18 What could these bodies or other stakeholders do to improve the workings of the
It would be helpful if the CAA could establish an information database so that airports
could access the range of advice that has already issued. This may be a useful
reference tool, based on the assumption that airports of a similar size and capacity
will have comparable issues.
19 The European Commission is planning to review the implementation of the
Regulation in 2010. In what ways do you think could the Regulation be improved?
TBI London Luton Airport response
AIRPORT OPERATORS – Response to CAA Audit
Impact of the PRMs Regulations on You and You’re Customers:
Do you think the Regulation has improved access to air travel for disabled passengers and
passengers with reduced mobility?
As the port did not previously perform this function and have limited access to historical
information we are unable to make an informed judgement.
However our airline partners have made much representation to the port regarding their
perception of an existing poor service.
We have also received numerous complaints from PRMs.
This we believe to be affected by the unprecedented demands of this service and the
expectation from air carriers that the port authority would appoint a competitively priced
During the process of appointing a suitable service provider there was reluctance from the
air carriers to participate in defining service levels and also a reluctance to increase existing
costs that were in existence prior to EU1106/07.
There is no doubt that this is an extremely labour intensive service and many of the issues
we have experienced have been primarily because of this.
Formerly there were different agents involved and therefore there was a previous opportunity
to call upon greater resources from other areas within the business.
It has been noted that since the regulation came into effect in July 2008, handling agents
and air carriers now seem to negate any responsibility for PRMs.
Delays are often unfairly attributed to the PRM assistance service causing poor PRM
perception and the breakdown of formerly good relations between staff.
Has the introduction of the Regulation affected your business / organisation? If so, please
Yes, it has affected the perception of the airport and the service it offers. Some PRMs have
intimated that they will no longer travel through the airport due to the poor service they have
received. It is considered that it may have had a detrimental affect on the port reputation.
This has also led to deterioration in previously good working relations with the various
How aware do you feel are the travelling public of their rights and responsibilities under the
Regulation? Do you have any evidence of misuse of the regulation by passengers?
Some of the travelling public do seem more aware but there are still many that do not appear
to understand the requirement to pre book this service.
There are also passengers using the assistance service who clearly do not need it but find it
a more suitable way to access and egress aircraft, rather than joining the general public in a
possibly longer or more cumbersome route.
What advice do you provide to passengers on the assistance that they might require (i.e.
distances at airports) or request (i.e. what mobility equipment they can take)?
Information is available on the airport's website.
There are also telephone contact numbers where PRMs can request a free "disability guide"
posted to their home in advance of travel (Large print or CD format is also available). PRM's
can contact our Accessibility Manager via telephone where they can request advice and
There are a further two e-mail addresses offering the same service.
Within the terminal where long distances or stairs may present difficulties there is signage
advising of the duration of the walk or advice on how to find an appropriate alternative.
There are three Help Units outside of the Terminal Building explicitly for the use of PRM's,
two of which display location maps of the terminal facilities.
Experience of PRM Implementation:
Do you differentiate the service between pre-notified and non-pre notified passengers? If
not, would you consider doing so?
This is extremely difficult to implement operationally and we are aware that the air carriers
are not always advising us in advance. From a customer care viewpoint we would be wary
of differentiating, particularly as PRMs may have pre-booked and it could be the fault of the
air carrier that the information was not passed. It should also be recognised that not all
PRMs know to pre-book or may have difficulties in doing so.
Since the Regulation was introduced, what percentage of requests for pre-notification are
passed to you by airlines or tour operators at least 36 hours before the published departure
time for the flight? How are you notified?
The contracted special assistance pre-notification has been approx 2% since the service
The assistance provider is notified via e-mail though the additional installation of SITA is
How have the number of PRM assistance requests changed since the Regulation was
introduced? Were your forecasted PRM numbers accurate?
The previous disability assistance service provider would not allow the airport to access their
figures but the previous year (2007) was believed to be at approx 38,000 assists.
The figure since the regulation came into effect in July 2008 through to December 2008 is
Between January 2009 and May 2009 the number of assists is17, 500 assists.
The PRM numbers have slightly exceeded the forecast (we anticipated 30% uplift) but the
nature of the assistance requirements and the amount of staff required to deliver the service
was severely underestimated by the appointed contractor.
What steps have you taken to increase the number of timely pre-notifications you receive?
We have requested that our disability assistance service provider install SITA as soon as
We constantly lobby our air carriers to provide the required information timely to service
Do you have any problems with the way in which airlines and tour operators pass on pre-
notifications to you?
Only in so much as the information can be scant and unreliable. Even with SITA the
information is only of value if it is correctly processed and often the nature of the requirement
is not accurate. It is considered that both airlines and their agents still lack disability
Have you faced any particular difficulties in taking over responsibility for providing services to
disabled persons and PRMs?
Poor passenger perception, low staff morale (care team) and the deterioration of the
relationship between the port and the air carriers has presented the greatest difficulty.
It has also been difficult to provide adequate staff to support the demands of this service,
particularly with little or no advance notice.
PRMs and air carriers have an understandable expectation of prompt assistance upon the
PRMs arrival but during peak periods it is extremely difficult to provide this service and thus
meet the PRM's expectation within a financially constrained and contracted service.
As the PRM assistance service is not the airport's core business this service was contracted
The original incumbent (pre the regulation) did not comply with the tender brief and therefore
was not appointed.
The subsequent handover to the new contractor was extremely poor with severe knock-on
effects to the customer.
As the cost of the new service was both the air carriers responsibility to bear and
considerably higher than had been previously, air carriers were understandably insistent that
the port select the cheapest of the compliant bids. This manifested in a 'minimum service'
methodology. Whilst the service has since improved, the service provider is experiencing
severe financial loss and is not keen to provide further upgrades to the service (mainly staff
resources) to enhance the product.
It is felt that any difficulties that have been experienced could have been overcome with
greater financial support from the air carriers that is equilateral to their expectations.
Have you had any problems delivering suitable training to your staff (including security staff
and ground handlers)? Have you had to introduce training where none was provided before?
Please provide details of your training policy and of the specific training provided.
Airport security and front line staff have been receiving disability training for several years.
This has been provided by the local Disability Resource Centre and has also been passed
on to other airport staff responsible for delivering training. This has included disability
awareness, manual handling, disability etiquette and deaf and blind awareness. All new
starters are also provided with a disability guide handout on induction. It is proposed to
continue this training in the winter period by focusing on issues involved with Mental Health.
The disability assistance service provider directly employed for the PRM service has
organised similar training package. Additionally their employees have also undergone further
training with Scope and Guide Dogs for the Blind. The policy is for all staff involved with the
handling of PRMs to receive both induction, on the job and annual refresher training. It is felt
that Third Parties such as ground handlers and air carriers have limited training but do not
seem to regard it as necessary now that they are no longer directly responsible.
What percentages of your complaints relate to the PRMs service and what are the key
reasons for complaint?
The key complaints are lengthy waits to be assisted on and off of aircraft, incorrect methods
of assistance and delays to flights.
UK Civil Aviation Authority Questions for review of operation of PRM Regulation
What was your per passenger charge in the first year of the Regulation (i.e. from 1 July 2008
to 30 June 2009). Did it cover the costs you anticipated?
Did it change during the year?
In accordance with CAA guidelines, the charging mechanism was calculated per departing
passenger. The tariff was 18.5pence.
It did not cover the costs and in fact led to a severe shortfall in staffing levels which impacted
The port authority is currently negotiating the rate for the impending year. This is proving
challenging with a service provider keen to recoup any losses.
In terms of your overall revenue from airport charges, what percentage does the per
passenger PRM charge constitute?
The percentage of a/p charges relating to the administration of the PRM contract is 1.8%.
How did you develop service standards for PRM services? Have any amendments been
made based on your experiences since implementation? Please provide details as to where
your service standards are published.
The airport began with holding regular meetings with the based air carriers to benchmark the
PRM service to ensure it met with their safety standards and minimum service levels.
Meetings were then held with disability focus groups to gain a better understanding of their
experiences with relation to air travel.
These findings were then incorporated into the EU regulation No 1107/2006 service
standards and a working document compiled. It has been necessary to modify several
operational functions to meet with the demands of the PRM service. The airport's service
standards are published on our website.
Is there sufficient guidance on how you could interpret and comply with the Regulation?
It would be more helpful if more emphasis was placed on the accountability of the air carriers
in this regulation. Though the responsibility is given to the airport authorities there seems to
be inadequate guidance regarding funding by the air carriers which has resulted in a poorer
service than required.
They have not welcomed the increase in the Per Departing Passenger rate regardless of the
fact that the service now provided is far more demanding than previously and it is felt that
they often show little support towards their PRM passenger.
Have you had any experience in dealing with the CAA, EHRC or DfT in relation to these
issues? Please comment on this experience, clearly indicating which body you are referring
The airport Accessibility Manager has attended a DFT conference regarding the carriage of
guide dogs. This has led to various meetings with reps of Animal Health and the subsequent
granting of the appropriate licence. She has sought advice from Tim May, DFT on various
issues relating to the Regulation.
Further guidance has been taken from the updated version of the Access to Air Travel for
Disabled Persons and Persons with Reduced Mobility - Code of Practice.
What could these bodies or other stakeholders do to improve the workings of the current
Encourage users of the service to pre book with their exact requirements and encourage the
air carriers to pass this information on, both promptly and accurately. Instigate more airline
participation and responsibility. Encourage airlines to improve their websites ensuring that
disability information is more accessible. Many airlines are difficult to contact on this subject
so many PRMs have difficulty in pre booking.
The European Commission is planning to review the implementation of the Regulation in
2010. In what ways do you think could the Regulation be improved?
Encourage ways of ensuring that all airport users unite in their involvement in the PRM
service so although it continues to be a seamless service, it is more of a joint venture,
thereby discouraging a "it's no longer our problem" mentality. This should be in both
operational participation and financial support.
Survey Newcastle Airport Cardiff Airport BAA Heathrow Gloucestershire Airprot Birmingham Airprot Belfast International Airport
Has the number of Yes. The business The number of Prms has • No data available for PRM numbers pre- Plus 21%. This is greater than Prior to the change in legislation the individual airlines had
PRMs increased at has had to adjust increased by 300% to 1200 / legislation, anticipated under the regulation. knowledge of all information relating to PRM total
your airport over resources to handle month since the introduction • Data from past 12 months show increase With the recent With passenger numbers falling movements. Unfortunately this information was not
the past 3 years? PRMs accordingly of the legislation. The feedback 0.8% passengers travelling as PRM’s – 1.29% at introduction of a and PRMs rising there is an always recorded therefore we had to estimate the figures
Has this affected (increased costs). indicates a positive reaction to peak, month on month increase scheduled service, by impact on the cost per departing for Year 1. The estimate was 21,000 the actual figure was
your business, How? the service from the travelling • Additional pressures on operation, impact on Manx2.com, the number passengers. 28,000. However, we believe that the number of PRMs has
public viewing it as a facilitator operational planning, staff levels, passenger of PRMs has increased increased over the past 3 years and part of this is due to
in encouraging and promoting experience, contract costs significantly. However, this customers raised awareness of the assistance available.
travel for the elderly. It is very has not affected our There has been a positive effect on our business as we are
much a USP for Cardiff as we business - the service much more aware of customers needs, there has also been
work towards an inclusive remains as it has always a negative effect as the contracter has required much
environment. been and additional staff more management oversight than other third party
have facilitated the contractors.
How aware are the The travelling public Awareness has increased by • Low public awareness of change to process Frequent flyers are aware of the Regular travellers are aware of the regulation, less
public of the appear to fairly well word of mouth amongst the owner, airline/airport operator, at start of regulation. Birmingham Airport frequent travellers appear to be less well informed. We
regulation? What informed - travelling public, the promotion implementation have a web site which gives PRM provide on line information on the service and are working
assitance do you particularly younger of the facilities available via the • Increased awareness following publicity information. The service level closely with user groups to raise awareness. Less than 5%
provide on what PRMs. We provide a airport website and the campaigns, BAA website. Details of the regulation agreement and walk times are of complaints relate to PRM matters.
PRMs may require? tailored service from distribution of information • Assistance provision in many forms, are not published. advised within the terminals. The
What percentage of Car Parks through to leaflets to all local disability wheelchair + agent, agent as guidance, buggy However, advice is service provider will check on
complaints relate to aircraft depending organisations recommended by operation, loan equipment, ambi-lift for provided on an ad-hoc what assistance is required when
PRMs service? on individual needs. Disability Wales. At all points of boarding/disembarkation, hosted areas, basis to passengers who in contact with the PRM. Contact
contact detailed descriptions of porterage, require it. Staff will assist is made with local disability
the various ways assistance • Approximately 11% of complaints received at by carrying bags and groups. Approx 3.5% of
may be offered are described. Heathrow relate to PRM operation folding wheelchairs are complaints are from PRMs.
Complaints relating to the PRM (approximately 25% of these are service provided/will be carried
service are less than 5% failures) free of charge.
has never received a
complaint about the
service offered to PRMs.
Do you differentiate Yes. Pre-notified Yes we do. The service • Pre-notified passengers are given priority Pre-notified and non-prenotified Our service level agreement states that non-pre notified
between pre- PRMs allow us to providers are contractually over un-notified passengers are treated in accordance with customers may have to wait longer for asistance but if
notified and non-pre plan our resource obliged to provide 100% service • www.baa.com contains service standards to our service level agreement resources are available they will be assisted immediately.
notified passengers? allocation. SLAs are to all pre-booked passengers in encourage pre-notification Manx2.com will only which is based on the regulation We are notified by the airlines and handling agents
For what reason? slightly different for accordance with the legislation • Airlines pass information via PAL/CAL/PSM, accept pre-notified PRMs time periods for giving assistance. informing the service provider directly. Installation of the
How are you non-pre notified and best endeavours to achieve SITA (& fax) to advise of PRM codes, phone under their terms and We try to give all PRMs the same SITA link will assist with this in the near future.
notified? PRMs. Notification the targets for all non pre- calls also received for late information conditions. When service but if demand is great ,
by PAL/CAL from booked passengers. Bookings requests/changes passengers book their the pre-notified take priority. Pre-
airlines. take place for departures via seats they must make it notifications are advised by
the airlines, tour operators and clear if they have specific airlines.
the passengers themselves needs. Due to aircraft size
directly with the PRM desk restrictions, only
passengers who can walk
unaided up the steps can
be allowed to board. The
Airport will accept PRMs
from other passenger
carrying flights on a non-
pre notified basis, offering
the best service that
facilities will permit.
Have there been any Yes as we did not We have experienced problems • Airlines failing to advise of PRM passengers, We have been working with Two problems, there does not appear to be a high level of
problems in the way have SITA address with the advance notification often with high volumes PRM’s and no PRM airlines to advise pre- pre-notification by customers at time of booking and the
your airport is for receiving information for arriving codes notifications by SITA. There is a lack of a SITA link compounds the problem. We have
notified? What steps PAL/CAL. Airlines passengers. We believe that • Use of local AOC/AOCA’s to advise problem with receiving incorrect emphasised the need for the link to be set up,
have been taken to asked to send these the installation of SITA will community of notification levels by carrier codings. Pre-notifications are not unfortunately implementation has still not taken place.
increase by e-mail/fax/web- provide a more robust way of • HAL hold regular meeting with carriers to received from Indian sub-
notification? based app. Some recording the precise improve data transmission Gloucestershire Airport continent carriers. Working with
airlines cannot send movement of Prms and are • CAA advised (by HAL & Airlines) when has had no problems in airlines to try and improve
this info in a format working towards that goal. escalation required for issues regarding airlines the way it is notified of communications.
that we can receive failing to comply with notification PRMs. Nothing more can
but we are working requirement, on site CAA meetings held. be done to increase
on a solution with • Improvements are being seen in transmission notification.
SITA. of accurate data from airlines
Have you faced any We have always The increased uptake of the • Reluctance from some airlines to support We have not faced any significant The difficulty has been that we had little knowledge of
diffuculty in taking handled PRM at NCL. service, complicated by the airport authority in taking responsibility for problems in taking responsibility how to oversee the service and guidance was expensive
over responsibiltiy We have a failure of passengers to pre their passengers as we contracted OCS who were and in some cases difficult to obtain. The service was
for PRMs? Have you comprehensive in- book led to problems regarding • Abuse of service by some carriers following already the Airlines service contracted out and the contractor was responsible for
had to introduce house training resource levels and staff removal of 3rd party to carry out multiple provider. Staff training includes training provision, however front line airport staff also
any staff training? programme for allocation. Planning the additional tasks as bolt on to PRM provision NVQ Level 2 in Customer Service, underwent practical PRM handling and awareness training.
Please provide any induction including resources in advance is critical (non- English speakers, CIP buggy movements, as well as manual handling, sign As an airport authority we now find ourselves held to
details you have on handling, etiquette, in the delivery of 100% of the heavy baggage, large families) language, disability awareness account by airlines who expect a flawless yet inexpensive
staff training vehicles and service level agreement. It is • Change of charge mechanism results in and equality. The main difficulity service. In our opinion the present service provided by the
equipment etc. and obvious there are service challenge by airline regarding assistance PRMs have always been a is the communication link contractor is far superior to what was in place 18 months
refresher training providers who are leaders in provided, ie. Self assisting passengers are seen factor in operations and through the chain from time of ago.
once a year. this field; it is our belief that as a service failure not independence enabling there have never been any booking regarding whether
those service providers who – previous airline agreements were mainly ‘pay issues in facilitating them. assistance or correct assistance
have experience in the aviation per push structure’ Staff have been trained in has been booked. Other partner
standard –Jarops (Joint aviation • Airlines abusing service as they pay manual handling and are companies on site have been
requirements-operations) and regardless of PRM’s assisted, encourage briefed to be aware of the advised of our local set-up but it
current legislation are better passengers to request late assistance as airline needs of all passengers at is difficult to control whether the
placed to provide this service service enhancement all times. information is cascaded to staff.
effectively. Staff training for • Training delivered by service providers,
this legislation in particular has includes disability awareness training,
included Scope training for the customer care, manual handling, lifting
Prm operatives and disability techniques for seating passengers, other
awareness training for all specialist modules
personal that may come in • Training reviewed by BAA / Consultant from
contact with passengers disability group prior to contract launch
requiring assistance. Further • Airport staff notified via various
training will be undertaken communication tools, advising of changes and
What was your per 25p per passenger The charge per departing • Charge was 35p per departing passenger The PRM charge for 2008/09 was The charge was 18p per departing pax for Year 1. This was
passenger charge in passenger was 24 pence this • No amendments to charge in 1st year £0.26 per departing passenger a significant underestimate and will probably be increased
the first year of price was not amended –we • PRM represents 10% when included in and remained constant in Year 2 to around 28 - 30p.
regulation? Did this are still negotiating prices for airport charges throughout the year. PRM
have to be year 2 charges represented 1.1% of total
amended? What No additional charges are turnover for the year. The
percentage does levied by Gloucestershire charge has been increased to
this charge Airport. £0.28 for 2009/10 due to
represent in terms contractual RPI increases and
of airport charges? falling passenger levels.
How did you The SLA document The service standards were • Developed in line with legislation guidelines Service standards have been Standards were developed by research and benchmarking
develop service was developed by formulated in conjunction with and set to exceed minimum requirement developed in line with the across the aviation sector and factoring in the legislative
standards for PRM the Landside the AOC. Protocols form the • Worked with airlines, AOC and guidance regulation and in line with the requirements. Amendments have been made and will
services? Have Operations Manager basis of the working document from accessibility manger for BAA experiences of the service continue to be made where necessary. Guidance has been
amendments been in consultation with in providing these services and • Changes made in line with operational provider. The service standards provided by consultants but given that the legislation is
made? Have you AOC members at have been amended as requirements following start up to enable are constantly reviewed via open to individual interpretation it is a potential
received sufficient NCL. It has not necessary in an attempt to improvements to the passenger experience monthly review meetings, 'minefield' with little 'case law' or precedent to refer to.
guidance on how to needed amending. deliver consistency to all through Heathrow - focus on transfer areas attendance at PRM forums, by
comply with this We have received passengers and airlines. Service standards are in benchmarking and in accordance
regulation? some guidance but Deficiency notices are served accordance with legal with best practices. The service
could use more. against these protocols for any requirements and provider receives sufficient
failure in service delivery. We Manx2.com specifications - guidelines on the legislation via
were fortunate to have amendments have not internal company
guidance from the Equality and been made thus far. communications.
Human Rights commission Sufficient regulatory
which was practical and guidance is available and
constructive. We continue to Manx2.com have their
work closely at a local level Terms & Conditions
with the organisation. structure to conform to.
What could be done It may be necessary to • National level working forums to share To review how the regulation is We have found the DfT Access To Air Travel for Disabled
at a national and EU determine more definitive learning and understanding working in practice and to give Persons and PRMs - Code of Practice to be extremely
level to imrpove the guidelines as the general • Regular ¼ or monthly areas of focus further guidance on how the useful but would like to see the CAA to provide a
workings of the conclusion is that they do not communicated at national level communication between all comprehensive PRM guidance document along the lines of
regulation and the go far enough and are open to • Limit opportunities for service to be abused parties can be improved. PRMs CAP 642 focussed on PRMs. A formal industry wide forum
Improved passenger and
regulation itself? inconsistent interpretation. as a fast track, late arrivals assistance also need to be more aware of would also be useful.
• Greater governance opportunities for non- their involvement in the
compliant carriers communication process.
posters, leaflets and
• Better clarity on assistance provision setting
passenger expectations, for example not all
will passengers will receive a 1-1 service
Any other n It is imperative that all costs • Ensure tour operators capture assistance It is difficult for airlines and tour Airlines are extremely reluctant to accept increases and
comments? Eg are transparent to facillitate requirements operators to equate the level of each individual airline has its own idea on what is an
regarding cost proactive co-operation • Ensure Tour operators communications to service that they receive against acceptable service level. The economy airlines are more
passthrough to between the airlines, the passengers sets realistic expectations of service the cost that they have to pay as focused on OTP than on 'soft skill' Service Delivery.
airlines and tour service providers and the provision they are only interested in the
operators airport managers. • Greater understanding of service provision service to their particular airline
and legislative guidelines for passengers, ie not in the totality of the contract.
transfers, dignified assistance: pre board & The cost is also for the same level
disembarkation when aircraft is clear, conflicts of service whether for scheduled
with tight connection times. or low cost, business class or
• Conflicting legislation between EU and other economy.
legislations relating to PRM’s.