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					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
general aviation.

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
        PRM assistance.

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,
       including airlines.

       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
      passengers?

       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
      request?

       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
   resources.

    Airports which did not differentiate would consider doing so if the number of PRMs
   increased.

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
    complaint?

    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
    year?

    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.

       (See appendix)

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
       PRM services.

       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.

       Not applicable.

   18. What could these bodies or other stakeholders do to improve the workings of the current
       regulation?

       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
       regulation.

       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.
Appendix

Bristol International Airport
CAA Questions for review of operation of PRM Regulation May 2009

AIRPORT OPERATORS

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
      so, how?

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
       available.

Q8.    What steps have you taken to increase the number of timely pre-notifications
       you receive?

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
       others.

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
       colleagues”.

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
       Regulation?

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
       raised.

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
       a PRM.

       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
        improved?
A19.
   •    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
        written.
        We have also seen a steady increase in PRM numbers since July 2008, despite the
        downturn in general passenger figures.


         2009
                                                                               % of pax who are
                        total no. of    arriving     departing   total pax          PRM’S
                     PRM movements
         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,
        how?
       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
       passengers?
       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:
       www.dptac.gov.uk/planes
       www.flying-with-disability.org

       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:

Pre-Notification
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
       assistance.

       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
        2009

          1st quarter average
          performance

          Thomsonfly                       56.5%
          Easyjet                          68.4%
          Ryanair                          76.6%
          Bmibaby                          54.1%
          Thomas Cook                      46.5%

          2nd quarter average
          performance

          Thomsonfly                       62.5%
          Easyjet                          71.5%
          Ryanair                          79.2%
          Bmibaby                          66.3%
          Thomas Cook                      64.6%


        We share this feedback with the EMA based airlines each month.

        Our service provider, OCS receive the pre-notifications via:-
        Predominantly SITA
        E-mail
        Fax
        Telephone

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
2009.
       The PRM numbers have exceeded our predictions.
8      What steps have you taken to increase the number of timely pre-notifications you
receive?

        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
        individually.
        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?
       Ask OCS

Assistance provision
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.

Internal Changes

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
       training provided.
       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
       programme.
       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
       organizations.
       Our service standards are published on the EMA website, within the accessibility
       section.

       We have not needed to adjust the parameters as yet.


Government/Enforcement/Future Actions

16    Is there sufficient guidance on how you could interpret and comply with the
Regulation?
      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
       current Regulation?

       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:

Q.1
Do you think the Regulation has improved access to air travel for disabled passengers and
passengers with reduced mobility?

Answer.
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
service.

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.


Q.2
Has the introduction of the Regulation affected your business / organisation? If so, please
comment how?

Answer.
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
companies involved.

Q. 3
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?

Answer.
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.

Q. 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)?

Answer.
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
information.
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:
Pre-Notification

Q.5
Do you differentiate the service between pre-notified and non-pre notified passengers? If
not, would you consider doing so?

Answer.
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.

Q.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?
Answer.
The contracted special assistance pre-notification has been approx 2% since the service
commenced.
The assistance provider is notified via e-mail though the additional installation of SITA is
proposed.

Q.7
How have the number of PRM assistance requests changed since the Regulation was
introduced? Were your forecasted PRM numbers accurate?

Answer.
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
20,000 assists.
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.

Q.8
What steps have you taken to increase the number of timely pre-notifications you receive?

Answer.
We have requested that our disability assistance service provider install SITA as soon as
possible.
We constantly lobby our air carriers to provide the required information timely to service
delivery.

Q.9
Do you have any problems with the way in which airlines and tour operators pass on pre-
notifications to you?

Answer.
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
awareness.

Assistance provision

Q.10
Have you faced any particular difficulties in taking over responsibility for providing services to
disabled persons and PRMs?

Answer.
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
out.
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.

Internal Changes

Q.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 training provided.

Answer.
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.

Q. 12
What percentages of your complaints relate to the PRMs service and what are the key
reasons for complaint?

Answer.
The key complaints are lengthy waits to be assisted on and off of aircraft, incorrect methods
of assistance and delays to flights.

May 2009

UK Civil Aviation Authority Questions for review of operation of PRM Regulation

Q. 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?

Answer.
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 service.
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.

Q.14
In terms of your overall revenue from airport charges, what percentage does the per
passenger PRM charge constitute?

Answer.
The percentage of a/p charges relating to the administration of the PRM contract is 1.8%.

Q. 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.

Answer.
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.

Government/Enforcement/Future Actions

Q.16
Is there sufficient guidance on how you could interpret and comply with the Regulation?

Answer.
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.

Q. 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.

Answer.
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.
Q. 18
What could these bodies or other stakeholders do to improve the workings of the current
Regulation?

Answer.
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.

Q.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?

Answer.
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.
Passengers with
Reduced Mobility
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.
                                                                                                                                      situation.




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.
                                                                                                                                    Gloucestershire Airport
                                                                                                                                      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.
                                                                                                                                       airport operator
                                                                                • Greater governance opportunities for non-                                 their involvement in the
                                                                                                                                      awareness through
                                                                                compliant carriers                                                          communication process.
                                                                                                                                      posters, leaflets and
                                                                                • Better clarity on assistance provision setting
                                                                                                                                         publications.
                                                                                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
                                                                                                                                               N/A
                                                                                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.