Minutes of the meeting

Air Passenger Rights Regulation [EC]1107/2006 First Joint Meeting National Enforcement Bodies Industry Stakeholders EUROPEAN COMMISSION "Acting together to make Regulation 1107/2006 a success" 25 January 2008 Brussels, Berlaymont Building, rue de la Loi 200 1049 room Jean Monnet Brussels, 4 February 2008 MINUTES OF THE MEETING Executive summary Since 2006, the European Commission has taken a number of initiatives in order to ensure a smooth phasing in of Regulation 1107/2006 concerning the rights of disabled persons and persons with reduced mobility1 when travelling by air. Among these initiatives a plenary European conference was held on 25 January 2008, assembling all the parties concerned: European national associations of PRMs, European association of airports and individual airports, national enforcement bodies2 of the 27 Member States and airlines associations. The objective of this conference was to ensure a successful entering into force of Regulation 1107/2006 on 26 July 2008. Therefore, each category of operators has been made aware of the specific needs and constraints of the stakeholders concerned. A detailed dialogue has been launched which can continue in a more informal and more decentralised way. It also allowed identifying the main issues at stake, and finally to making proposals for action for the Commission and every stakeholder present at the conference until July 2008 and beyond. The conference was regarded as a success by the participants. 1 Below designated as "PRM". Below designated as "NEB". 2 Commission européenne, B-1049 Bruxelles / Europese Commissie, B-1049 Brussel - Belgium. Telephone: (32-2) 299 11 11. Office: DM 28. Telephone: direct line (32-2) 2965221. Fax: (32-2) 2986540. E-mail: christophe.dussart@ec.europa.eu The meeting took place in Brussels, on 25 January 2008. During the meeting, the minutes and conclusions listed below were agreed. Introduction by Ms Anne Houtman The meeting was opened by Ms Anne Houtman, who recalled that in 6 months time, on 26 July 2008 precisely, all provisions of Regulation 1107/2006 on the rights of disabled persons and persons with reduced mobility3 when travelling by air will enter into force. Regulation 1107/2006, adopted on 5 July 2006, created major expectations for citizens with reduced mobility in the EU: the text fits into the anti-discrimination policy actively pursued by the European Union. Disabled persons and persons with reduced mobility, whether caused by disability, age or any other factor, should have opportunities for air travel comparable to those of other citizens. Disabled persons and persons with reduced mobility have the same rights as all other citizens to free movement, freedom of choice and non-discrimination. This applies to air travel as to other areas of life. Disabled persons and persons with reduced mobility should therefore be accepted for carriage and not refused transport on the grounds of their disability or reduced mobility, except for reasons which are justified on the grounds of safety and prescribed by law. This ambitious objective is explicit in each provision of Regulation 1107/2006, whose basic principles are accessibility, non discrimination, assistance and information. Ms Houtman noted that the conference has 3 objectives: firstly, to establish a first contact between all stakeholders involved, secondly to identify the main issues at stake, and finally to make proposals for action. In this context, Ms Houtman also noted with satisfaction that through its numerous contacts with the sector, the Commission did appreciate the will clearly expressed by all the professionals concerned to make Regulation 1107/2006 a success. However, the date of 26 July 2008 will see the end of the transitional period. Each stakeholder will then have to deal with the situation as it will be, and to bear the consequences of a possible failure, including infringement procedures launched by the Commission. *** The airports' experience Mr Faross introduced this point mentioning that according to Article 8 of Regulation 1107/2006, airports have the responsibility to provide the assistance to PRMS at airports outside the airplane. This responsibility will remain with the managing body of the airport even if the assistance is subcontracted to third parties. In the light of this legal obligation, airports need to be efficient in their preparations and must cover a number of practical issues, such as the establishment of quality standards for assistance, the designation of points of arrival and departure, the provision of adequate staff training, the possible outsourcing of assistance and the respect of relevant procurement procedures, the set up of a non discriminatory system of financing assistance in order to ultimately provide a seamless, efficient assistance. This session dedicated to airports had two objectives: to make sure that all airports, including the smaller ones, are aware of what needs to be done, and to 3 Below designated as "PRM". 2 present practical preparation experience that other airports that are not so advanced can benefit from. Ms Holve (ACI EUROPE) presented the successes and limits of ACI EUROPE's action towards airports. As to successes, the network of more than 400 airports members of ACI have benefited from information on Regulation 1107/2006, including regional airports which have been reached through the small and medium size airport group (SMAG) of ACI EUROPE. Participation of airports to ACI EUROPE meetings and events (Facilitation Committee, PRM Workshops) has been massive and active. The development of a PRM Notification Tool top deal with PRM pre notification data is an example of good airline-airport cooperation. Support from the European Commission has been constant and efficient, including through an information campaign which should contribute to a smooth implementation. Access to national civil aviation authorities has been allowed through ECAC. As to limits and challenges, some regional airports and airports who are not members of ACI EUROPE still lack awareness and action as to regulation 1107/2006. Airports have also different sizes and with different constraints. Access to national PRM associations for cooperation (training and quality standards) is difficult in many cases, while quality assistance and functioning of the system depends on good interaction of all stakeholders involved (airlines, tour operators, assistance providers, civil aviation authorities). On pre-notification remains the need to raise awareness of all potential PRMs (elderly…). Good communication between airports/airlines/tour operators is key, as continuous information to passengers on prenotification requirements, even after 26 July 2008. M Proveniers then presented the experience of Brussels airport where Regulation 1107/2006 is already in force. As to lessons to be taken, he insisted that pre notification is fundamental although airlines claim that they can not notify the airport if the passenger did not notify them. When other airports implement the regulation, notification times will improve but 100 % will never be achieved (last minute PRM traveller, non EU arriving traveller). Higher visibility and dedicated information to the public in the terminals has increased the number of requested assistance by 30 % in Brussels airport, with financial and operational consequences. Systematic monitoring of results is fundamental also to avoid complaints. Mr Proveniers provided a checklist of points of particular importance: the airport's PRM Workgroup must be quickly operational; quality requirements must be defined and published; pick up and drop off points must be defined and installed; the responsible person within the managing body of the airport must be clearly identified; and quality monitoring system, financing and complaint management must be in place as soon as possible. During the debate that followed, EDF objected that the increase of PRM-related assistance requests in Brussels airport could be seen as a problem. Since many disabilities are invisible and since the airport design can be a reason for requesting assistance for some persons, one must be very careful before assuming that an increase in the number of assistance requested is due to abuse of the assistance system. ACI Europe and Brussels airport answered that such an increase was of course not negative, but had an operational impact. Actual abuses of the system are a problem, since they risk to unduly lowering the quality of service to PRMs in the long run. EDF's Danish branch evoked the question of the reimbursement of destroyed, damaged or lost mobility equipment, where the thresholds established by the Montreal Convention are notoriously too low. As to the enforcement of quality standards, Brussels' airport answered a question of IACA confirming that in Brussels these are contractual and binding, and give rise to penalties in the case that they are not respected. On the issue of the awareness role of 3 national enforcement bodies already at this stage, the UK CAA expressed interest to receive information about the situation of enforcement preparation in the other Member states. In conclusion to the debate, Mr Faross expressed the wish that all stakeholders involved use the check list4 elaborated by ACI and Brussels airport as a reminder. The Commission would be also very interested in getting more information about the actions taken by the NEBs in order to ensure a good preparation for the entry into force of Regulation 1107/2006. On the destroyed, damaged or lost mobility equipment issue, Mr Faross confirmed that the Commission will issue a communication on this matter still in 2008. The role of the PRM Mr Faross introduced this point with a reminder: in order to achieve a quality preparatory work before 26 July 2008, airports are bound to co-operate on some topics with organisations representing disabled passengers and passengers with reduced mobility. The designation of points of arrival and departure and the setting up of quality standards for assistance at airports fall in this category. The latter issue is of critical importance, because PRM are best placed to judge on the required quality of assistance: airports and/or their subcontractors will have to organise their system of assistance so that they meet these quality standards. We have therefore to guarantee that organisations representing disabled persons and persons with reduced mobility can meet this challenge. These organisations need to be present at local airports so that they can make their voices heard and to be trained to present relevant and expertise-driven solutions. Ms Nyman from the European Disability Movement (EDF) presented the constraints and limits of the current action undertaken by PRM associations. Regulation 1107/2006 was a dream coming true for the disability movement, and effective cooperation is the key. But such cooperation between all stakeholders is rare at airports throughout the EU, and in the case it exists it is often unstructured. Nobody is to blame for this. It has to be noted that the disability movement lacks economic and human resources today to get sufficiently involved in the work of Regulation 1107/2006. EDF's member organizations generally feel that the role that is put on them through the regulation is not sufficiently clear and difficult to realise in practice. One cannot expect people from the disability movement at local level to work closely with the airports, and to be properly trained on the relevant legislative framework if one does not provide them with the economic and practical means for allowing for this participation and cooperation. Studies show also that a large majority of individuals with disabilities are not aware of their rights and obligations under Regulation 1107/2006. Without increased knowledge of disabled individuals there is a serious risk that discrimination occurs without any action being taken against the responsible airline/airport. It is the responsibility of all, EDF, the Commission, enforcement bodies, airports and air carriers to inform the disabled people at grassroots level about their rights. Ms Ann Frye, Chair of the Sub Group on Passengers with Reduced Mobility in European Civil Aviation Conference (ECAC), presented an EU wide approach to best quality 4 Attached to this text. 4 standards for training. The key to successful and harmonised implementation of Regulation 1107/2006 is training. Involvement and empowerment of PRM representatives is the key to successful training, but all stakeholders have a responsibility to ensure that training is delivered to the right people, at the right times and to the right standards. Regulation 1107/2006 deals with training in two areas: airport managing bodies are to set quality standards and engage with the Airport Users’ Committee and with organisations representing disabled passengers and PRMs (Article 9) and air carriers and airport managing bodies to provide training for staff (Article 11). In the context of Article 9, it is vital that representatives of EDF at local level (1) are made aware of their rights and of the detail of the Regulation and the supporting documents (ECAC Doc 30 etc); (2) are able to form a network of people in local organisations of disabled people/ PRMs who are also aware of their rights and responsibilities; and (3) are full partners in discussions with airport authorities. In the context of Article 11, the EDF representatives can also be involved in disability awareness and equality training of staff in direct contact with the travelling public, including airline staff, job specific staff e.g. security, check-in staff and the PRM service provider ( either in house or subcontracted). Therefore, action is needed through EDF to identify key people in each member state to be trained; through the Commission to organise and fund a European training workshop for these key people, as soon as possible; through National Enforcement Bodies to control the quality of the training programme in accordance with Regulation 1107 and ECAC Doc. 30 and its annexes and to permit the inclusion of training related costs in the charge levied per passenger; through airports to finance participation of the designated representative in the airport’s PRM project group and to support costs associated with providing the training to airport related staff ( PRM provider, airline staff etc). During the debate that followed, Dublin and Brussels airports raised the question of the scope of awareness training: while it is clear that all personnel falling under the responsibility of airports and airlines must receive awareness training under Article 11, it is not obvious that this training requirement goes beyond that (to airport shop personnel for instance). Additional cost incurred could also then become considerable. The possibility to standardise training at national or EU level in order to reduce costs has been mentioned buy EDF, and supported by ECAC, but opposed by ACI EUROPE which considers the situations of various airports to be too diverse to allow this. AEA recalled that such a training has been given to airlines' staff for quite a while now, and that financing their own training has never been an issue for airlines. But experience also shows that expectations towards training must not be excessive: it will no solve everything. EDF Dutch representative highlighted the need for a harmonisation of assistive technology for lifting and carrying PRM. This could ease the training of airport and airline personnel. Mr Faross concluded this session leaving open the question whether it was possible to harmonise individual needs for those who perform training. After asking opinions about the approach "Training the trainers", he took note that EDF, ACI EUROPE and AEA took a favourable approach, and that IATA even asked to be part of it to share its experience in quality training. Requirements for the entry into force of Regulation 1107/2206: the airlines' point of view Mr Faross introduced this point recalling that air carriers shall provide the assistance specified in Annex II of Regulation 1107/2006, mainly aboard aircrafts, 5 without additional charge to disabled persons and persons with reduced mobility departing from arriving to or transiting through a Community airport. Airports users and air carriers should contribute to the definition of quality standards, the designation of points of arrival and departure and the provision of adequate training as foreseen in Article 11 of Regulation 1107/2006. In addition to this, information flows on PRM notification are crucial and need to be organised between PRMs, airlines, tour operators, airports and assistance providers so that the actual needs of assistance to PRMs can be communicated to those providing assistance on the spot. When duly informed, providers can organise assistance in order to meet the requirements of these who need it. The system will only become efficient if PRMs can be convinced to announce their assistance requirements at least 48 hours in advance. Otherwise PRMs will have to rely on assistance provided on the basis of best effort . The Commission will launch a vast information campaign to inform PRMs accordingly. Mr Lefebvre (AEA) gave the airlines' point of view on the conditions for success for the implementation of Regulation 1107/2006. Four key issues for a successful implementation have been reviewed: transmission of information, standards of service, responsibility and liability and actual implementation as per July 2008. As to transmission of information, despite the pre notification system which is now being prepared in order to transmit PRMs special needs between operators, airports must be prepared to manage all forms of information which are going to be provided by airlines. As to standards of service, ECAC PRM standards were jointly developed by EDF, airlines and airports and should be considered appropriate for adoption as minimum standards. ECAC standards are not additional services, for instance assistance in case of irregularities (ECAC DOC 30, annex J, §1.4). Although not expressly listed in Annex I, they should clearly be considered as ‘standard’. As to responsibility and liability, passengers do not have a contract with airports and will consider airlines as responsible for their complete trip (ground and air). A draft agreement should be concluded between airports and airlines in order to list and pre-arrange main, standard issues of responsibility and liability. As to actual implementation as per July 2008, air transportation operations are not an exact science. This will be worsened if the PRM handling company is a newcomer, that does not know the actual operational conditions (big airport…) and has to prepare with staff, equipments etc. Perfection will not be achieved on 26 July 2008: cooperation is key, not sanctions and blames. In order to avoid the problems linked with the implementation of Regulation 261/2004, one must ensure that all publicity material is scrupulously accurate and work together (at least NEBs / airlines / airports) to discuss issues as they arise and to encourage mutually agreed interpretation of the Regulation. NEBs should intervene quickly and effectively when there is a clear breach of Regulation 1107/2006. The debate that followed focused first on liability, where ACI EUROPE mentioned that so far no agreement could be attained, and that the issue must be dealt with at local level. On information flow, it has been agreed that the transfer of information was crucial (AEA, EDF), and should not work to the detriment of PRMs: a pre notification must reach its addressee when made in due time by the PRM (EDF, DG TREN). The German EDF representative underlined the need to have non-discriminatory booking procedures for PRMs which includes an easy way to notify the PRM conditions and which covers all modes of reservation (i.e. internet bookings). IATA reacted positively to follow-up the issue. On this point, the Slovakian NEB mentioned that in its own experience, the travel agencies will most probably be the weakest link in this respect. The UK NEB then 6 briefly mentioned issues related to safety and to implementation of Annex II of the Regulation, for which Mr Faross confirmed that the Commission was working on. EDF reminded about the obligation under the regulation 1107/2006 for airlines and travel agencies to allow people with disabilities to notify their assistance needs at all points of ticket sales. General conclusion Mr Faross concluded the conference by insisting on the spirit of openness and flexibility in which everybody has been collaborating so far. Every stakeholder present at the conference should establish a checklist to organise plan and control what is required to make the entry into force of Regulation 1107/2006 a full success. As to airports, action includes the organisation of assistance on the ground provided by themselves or third parties, including all the procedures required; the definition of the quality standards for assistance by airports in collaboration with airports users and PRM organisations; the designation of points of arrival and departure; a contribution to an efficient reception and flow of information; the establishment of a non discrimination an transparent system to finance assistance; the setting up of an appropriate training system. A high degree of collaboration between airports/airlines and PRM associations must be reached here. ACI EUROPE will provide to the Commission a check list for airports to be passed to all stakeholders (NEBs, airlines, EDF) so that they can use it in the implementation process. Air carriers must contribute to the establishment of quality standards and points of arrival and departure, train their personnel, take with tour operators all measures necessary to guarantee an efficient flow of information concerning the needs of PRMs travelling by air; cooperate with the airports to establish a system to finance assistance, not refuse bookings on the ground of disability and establish appropriate booking software; propose assistance foreseen in Anne II of Regulation 1107/2006; and fulfil their information duty towards the PRMs. PRMs associations are supposed to contribute to the establishment of quality standards; to contribute to the designation of points of arrival and departure; to convince PRMs to communicate their needs in due time; and to monitor the correct application of Regulation 1107/2006. On this point, the Commission must take its responsibilities and organise a panEuropean workshop to "train the trainers" in the PRM community. The identity of participants and speakers and how they shall address the issue will be decided in connection with the stakeholders, i.e. notably EDF. The Commission's communication campaign to make PRMs aware of their rights will have to be ready on time and accurate on the content. But it will also require multiplicators to be efficient. NEBs have first to be designated by Member States: they are responsible for the enforcement of Regulation 1107/2006 as regards flights departing form or arriving at airports' situating in their territory. They have to make sure that the rights of PRMs are respected and that established quality standards are met. They must look after the satisfactory implementation of Article 8. They have to make use of the sanctions they have been empowered to use by their Member state. 7 Mr Faross also mentioned the fact that a number of issues remain open, such as the scope of the training obligation and issues related to safety. This plenary conference is the first one to be held on regulation 1107/2006, but certainly not the last one. A next conference may be relevant after the entry into force of Regulation 1107/2006, and the Commission is ready to organise it if needed. Mr Faross also recalled that DG TREN is available to stakeholders. Mr Faross also said that the minutes of the conference would be circulated within 2 weeks, and all stakeholders would have 3 weeks to give their comments, if any. The meeting was closed. 8 Attendance list: Ms ABBOTT Catherine (UK CIVIL AVIATION AUT. UK) – Ms ALVES Ines (EDF pa5 ITALY) – Ms ALBERGARIA A. Teresa (NEB PORTUGAL) – Ms ANCA Gunta (EDF SUSTENTO LATVIA) – Ms ANGELOVA Mariana (NEB BULGARIA) – Mr ANICHINI Maurizio (IATA) – Ms ANTONIO Luz (NEB PORTUGAL) – Mr ATTARD Olav (EDF pa MFOPD MALTA) – Mr BAXA Petr (NEB CZECH REPUBLIK) – Ms BESOZZI Carlotta (EDF) – Mr BOCCIA Francesco (EDF ITALY) – Mr BODART Philippe (EDF BELGIUM) – Mr BORKOWSKI Adam (NEB POLAND) – Ms BOSISIO Luisa (EDF ITALY) – Mr BREUER Yannick (EDF LUXEMBOURG) – Mr BRINZOI Daniel (NEB ROMANIA) – Mr CAMMARERI Giosue (AIRPORT DI ROMA SPA ITALY) – Mr CETINTAS Oktay (BASEL FRIBOURG AIRPORT SWITZERLAND) – Ms CHRISTOFI Marily (EDF GREECE) – Mr CUJATAR Kevin (EDF MFOPD MALTA) – Ms DELOUKA Lilian (NEB HCAA GREECE) – Ms DE SMET Monique (IATA-ERA) – Ms DE SURVILLE Caroline (ADP FRANCE) – Ms DUNCAN-SMITH Bryony (ELFAA) – Mr ELSBURY Geoff (UK CIVIL AVIATION AUT. UK) – Ms FOGELBERG Elsa (EDF pa SWEDEN) – Ms FREEMAN Liz (EAST MIDLANDS AIRPORT UK) – Ms FRYE Ann (ECAC) – Ms GENDRE Danielle (NEB CAA FRANCE) – Mr GIBSON Anthony (GALWAY AIRPORT UK) – Mr GILMORE Barry (NEB DEPARTM. OF TRANSP. IRELAND) – Mr GODEFROY Pim (HDI) – Ms GRALKA Michaela (MUNICH AIRPORT GERMANY) – Ms GREEN Caroline (ELFAA) – Ms GRIEBER Anita (EDF) - Mr HODNETT David (NEB IRELAND) – Ms HOLVE Vanessa (ACI EUROPE) – Mr HUSAIN-KAHN Athar (AEA) – Mr IERAPETRITIS Vassilis (ATHENS AIRPORT GREECE) - Mr JOHNSTONE Robert (EDF UK) – Mr JUSIA Vidjai (CAA THE NETHERLANDS) - Ms KILCOYNE Carmel (IE WEST AIRPORT IRELAND) – Ms KIISHI Pia (EDF pa FINLAND) – Mr KRUSCHE Stefan (EDF GERMANY) – Ms KULLBERG Lisbeth (NEB FCAA FINLAND) – Ms LANGE Barbara (FLUGHAFEN LÜBECK GERMANY) – Mr LEBJODA Michal (NEB POLAND) – Mr LEFEBVRE Jean Pierre (AEA) – Ms LESNIK Sasa (NEB SLOVENIA) - Ms LONGDEN Claire (MANCHESTER AIRPORT UK) – Ms LONN Annelie (ARLANDA AIRPORT SWEDEN) – Mr LOUIS Michel (BELGIAN CAA BELGIUM) - Ms LUDMANN Annik (AEROPORT STRASBOURG FRANCE) – Mr MAGRITTE Olivier (EDF) – Mr MAHLAMAKI Pirkko (EDF FINLAND) – Ms MANTOVANI Marcella (BOLOGNA AIRPORT ITALY) – Mr MARANO Daniele (EDF AUSTRIA) – Mr MARIOTTI Fabrizio (AIRPORT DI ROMA SPA ITALY) – Mr MARSENKOV Kertu (NEB ESTONIA) – Mr MAY Tim (NEB UK) – Mr MILATOS Antoine (ADP FRANCE) – Ms MONTEROALONSO Christina (AENA SPAIN) – Mr MUMME Frank (FRANKFURT AIRPORT GERMANY) – Ms NEIMANE Iveta (EDF pa LATVIA) – Ms NIELSEN Lena (EDF DENMARK) – Mr NIELSEN Mogens (EDF pa DENMARK) – Mr NORTE Manuel (ANA, SA – Aeroportos de Portugal) - Mr NOSSENT Thierry (GENEVA AIRPORT SWITZERLAND) – Ms NYMAN Maria (EDF) – Mr O'BRIEN Christophe (DUBLIN AIRPORT ATUTHORITY IRELAND) – Mr ORZECHOWSKI Michal (EDF POLAND) – Mr PARSA Ali (LFV SWEDEN) – Ms PETRAZOVA Eva (CIVIL AVIATION AUTH. CZECH REPUBLIC) – Mr PROVENIERS Jean Luc (BRUSSELS AIRPORT BELGIUM) – Ms PSILOGENIS Maria (CAA CYPRUS) - Ms PUSA Jari (FINAVIA FINLAND) – Mr RAIANO MICHEL (EDF pa UK) – Ms RAMSTEDT Annika (CIVIL AVIATION AUTH. SWEDEN) – Ms RUKOVANSKA Marcela (EDF SLOVAK REPUBLIC) – Ms RUSSE Christina (ECTAA) – Mr SCHNITZER Hedi (EDF OZIV AUSTRIA) – Mr SILVER Eric (HANNOVER AIRPORT GERMANY) – Mr STREIT NISSEN Martin (NEB DENMARK) – Ms SJOLUND Annelie (CIVIL AVIATION AUTH. SWEDEN) – Ms SZOLLOSI Erzebeth (EDF HUNGARY) – Ms TABONE Dulcie (NEB MALTA) – Ms TEMESVARI Eva-Maria (NEB SWITZERLAND) – Mr TREFFERS Bas (EDF THE NEDERLANDS) – Ms VALICKOVA Radmilla (NEB - SLOVAK REPUBLIC) – Mr VARSAMIS Iorgyos (ATHENS INTERNATIONAL AIRPORT GREECE) - Mr VARSAMOS Stamantis (ATHENS INTERNATIONAL AIRPORT GREECE) – Mr VELDE Vairis (NEB LATVIA) – Ms VEISA Aija (RIGA AIRPORT LATVIA) – Mr VERMEIR Koen (IACA) – Ms VIKJORD Anne (CAA NORWAY) – Ms WAGNER Britta (HILFSGEMEINSCHAFT BL. AUSTRIA) – Ms WACLAWCZYK Maureen (NEB GERMANY) – Ms WESTLUND Karin (EDF SWEDEN) – Mr WHITBY Simon (EAST MIDLANDS AIRPORT UK) – Mr WILLICH Martin (FRANKFURT AIRPORT GERMANY) – Ms ZEGUNYTE Virginia (NEB LITHUANIA) – European Commission: Ms HOUTMAN Anne, Mr FAROSS Peter, Mr DUSSART Christophe, Ms DIAZ PULIDO Flor, Ms ENGSTROM Pia. 5 Pa stands for "personal assistant". Commission européenne, B-1049 Bruxelles / Europese Commissie, B-1049 Brussel - Belgium. Telephone: (32-2) 299 11 11. Office: DM 28. Telephone: direct line (32-2) 2965221. Fax: (32-2) 2986540. E-mail: christophe.dussart@ec.europa.eu Annex I CHECKLIST presented by ACI PRM Regulation Key information and recommendations to European airports for a smooth implementation of the PRM Regulation 1) Quality standards ACI EUROPE would like to raise airports’ awareness on this key provision of the PRM Regulation. According to Article 9, “with the exception of airports whose annual traffic is less than 150 000 commercial passenger movements, the managing body shall set quality standards specified in Annex I and determine resource requirements for meeting them, in cooperation with airport users, through the Airport Users Committee where one exists, and organisations representing disabled passengers…The managing body of an airport shall also publish its quality standards”. ACI EUROPE therefore highly recommends airports to publish their quality standards in a visible way (on their website, etc.) by 26 July 2008. These quality standards should be agreed upon in cooperation with airlines and local Disability associations when drafting the tender and recruiting the assistance provider. Handlers and selfhandlers should not participate in this process due to conflict of interests as becoming possible candidates for the tender process. Pick-up and drop-off points within the airport boundaries shall also be defined (bus station, train stations, departure curb parking lots, etc.). These need to be equipped with seating arrangements and means of communication. 2) Training of staff Article 11 of the Regulation states that “air carriers and airport managing bodies shall ensure that their personnel, including those employed by any sub-contractor…, should provide disability-equality and disability-awareness training to all their personnel working at the airport who deal directly with the travelling public, including refreshing training when appropriate”. To help you provide the best training and assistance, ECAC together with all aviation stakeholders drafted the “ECAC Disability awareness and disability equality training guidelines for all airport and airline personnel dealing directly with the travelling public”. These guidelines are intended to be a source of information to identify best 10 practice for personnel employed in the air passenger transport industry dealing directly with the travelling public. They focus mainly on the attitudinal barriers that disabled people are facing in air travel, and they offer solutions to some of those. ACI EUROPE also recommends airports to provide training together with representatives of national PRM associations for a best training possible. These PRM representatives can be remunerated on the charge levied on air carriers for quality assistance (see article 9 §4 and 5 of the Regulation). 3) Transmission of PRM information: a) Prenotification At Brussels airport, where the PRM Regulation has already been implemented since 1 April 2007, airport managers have reported a clear increase in the number of PRMs. The main problem concerns PRMs that have not prenotified their need for assistance. According to provisions in article 7 and 9 of the Regulation, PRMs should prenotify the airlines or the tour operator of his need for assistance at least 48 hours in advance. These shall then transmit the information to the airport at least 36h before the published departure time for the flight. If prenotification is not made, the managing body shall deliver the assistance according a lower level of quality of service as agreed upon in the PRM working group. On this, ACI EUROPE would recommend you to cooperate with airlines and tour operators/travel agents in order to receive as many prenotifications as possible. At EU level, an EU video and industry campaigns (see below) will help improve prenotification. This is both in the interest of airports and airlines, since any nonnotified assistance might require additional costs, to be borne by airports which can then share the burden with airlines by levying a charge (article 9 §5 of the Regulation). To achieve quality assistance, prenotification is key. Airports should verify and keep records of the prenotification levels and intervene locally with air carriers with low prenotification rates. Moreover, the correct use of the PRM codes should be monitored and local intervention should be made in case an airline uses wrong codes in a systematic manner (for example: WCHR instead of WCHC). b) PRM Notification Tool An efficient implementation of the new PRMs Regulation requires the creation of smooth communication channels for the transmission of PRM information from airlines / tour operators to airports. In this context, ACI EUROPE and airlines associations met to develop together an IT platform with common standards. The result is an IATA Recommended Practice Document, which has been forwarded to airport’s facilitation managers through the ACI EUROPE Facilitation and Customer Service Committee in October last year. Airports will receive more information and a final document in this regard by the end of March 2008. ACI EUROPE recommends that airports sit together with airlines to work together in using this new message type. Airports should also communicate their SITA addresses to their airlines as soon as their assistance provider has been selected. These standards should ideally be implemented before the summer flight loads. 11 It is to be noted that the PRM Notification Tool will become a valid instrument but not sufficient on a day to day operation. Therefore, the match between the PAL and the PSM (message sent after departure of the flight) is important to obtain a good data quality. Good planning of resources starts with a reliable PAL (prenotification) and a reliable PSM. PSMs are sent also by SITA, therefore all airports should have one SITA address to which PALs and PSMs can be forwarded to. 4) Information campaign: European Commission’s video on PRM Regulation In the light of the new PRM Regulation, the European Commission is currentlY preparing a video explaining key provisions and requirements to European passengers. Some of the main messages of this short film will focus on the importance for PRMs to pre-notify their need for assistance and also specify the type of assistance requested. This video will be sent to airports in the form DVDs by July 2008. ACI EUROPE will keep airports posted on the development of the video, to which it contributes together with airlines and disabled associations. It will be highly appreciated if airport managers could kindly accept to display it at their airport on already existing monitors. A valid alternative would be to publish the video on the respective airports’ websites. Please also note that the European Commission plans to create on its website a portal dedicated to PRMs, with a link to a shorter version of the video and other key information to PRMs. Information on PRM assistance is also to be found on air passenger rights’ leaflets. 5) PRM equipment Before implementing the Regulation, airports will need to set in place special infrastructure and have appropriate equipment at their disposal. To do so, airports will have two possibilities: to use the equipment of their subcontractor, or airports can buy their own equipment. ACI EUROPE advises airports to opt for the last option, which will turn out to be less costly for airports in the long run. In this case, agreement should be made between the airport and the provider about the quantity of equipment needed. The type, the quality and the use of this material should also be regulated by a separate agreement covering issues like responsibility, maintenance, loss, etc. In the contract with the assistance provider, please ensure that the cost for replacement of damaged or lost equipment should be covered by the airline since this falls under the Convention of Montreal. 6) Costs Remember that in the open bookkeeping, overhead and infrastructural costs can also be included beside the cost of the PRM equipment and the cost of the provider (in case of subcontracting). This is possible as long as the costs are transparent and related to PRM assistance. 12