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CNIB submission brief to the House of Commons Standing Committee on Transportation

As part of our efforts to ensure safe and accessible journeys for all Canadians who are blind, Deafblind, or have low vision, CNIB appeared before the House of Commons Standing Committee on Transportation (TRAN) on April 18, 2024, to provide testimony for its study on accessible air transportation for persons with disabilities. CNIB also submitted a written briefing note encompassing our testimony and recommendations for the government, regulators, airlines, and other air transportation service providers. The full briefing note can be accessed by clicking the following link: CNIB submission to the House of Commons.

The briefing note provides an overview of common barriers encountered by persons who are blind, Deafblind, or have low vision when travelling by air throughout each stage of the journey, from trip planning to arrival at the final destination, including the unique experiences of travellers with guide dogs.

CNIB has issued the following recommendations:

  1. CNIB recommends that the CTA collaborate with airport authorities, airlines, and other industry stakeholders for full implementation of the ATPDR, prioritizing areas where solutions exist and can be rolled out immediately, including personnel training, accessible information and communications, accessibility complaints processes, and policies and practices related to accommodations.
  2. CNIB recommends instituting a formal process for the routine review of air travel regulations regarding passengers who are blind, Deafblind, or low vision, and that the CTA routinely audits compliance with the ATPDR.
  3. CNIB recommends the CTA collaborate with government to strengthen enforcement of air transportation accessibility requirements, including through more proactive oversight activities and consistent application of monetary and other penalties in cases of non-compliance.
  4. CNIB recommends that federally regulated air service providers deliver enhanced personnel training regarding the needs and requirements of passengers who are blind, Deafblind, or low vision to ensure that passengers receive consistent and dignified service at all points of the travel journey, including booking, check-in, security, boarding, and in flight.
  5. CNIB recommends that documents and submission processes be streamlined and made accessible for all passengers using formats such as fillable digital forms or an accessible app that is compatible with assistive technologies, like screen reading and magnification software, and that alternate formats be readily available upon passenger request.
  6. CNIB recommends the CTA clarify the expectation that federally regulated air carriers retain information provided by passengers in relation to requests for service for a minimum of three years, unless the passenger requests otherwise.
  7. CNIB recommends that regulators and federally regulated air transportation service providers adopt the International Working Group’s recommendations to improve the accessibility and effectiveness of IATA SSR codes, to ensure all personnel who may interact with the passenger have the necessary information to provide appropriate service at each point along the journey.
  8. CNIB recommends that the requirement for carriers to provide passengers with guide dogs an additional seat at no extra cost, which currently applies only to domestic travel, also be adopted for international flights that are operated by a Canadian airline, and flights operated by international carriers that are arriving to, or departing from, a Canadian airport.
  9. CNIB recommends consistent enforcement of the CTA’s One-Person-One-Fare Policy Decision where Canadian jurisdiction applies. However, this policy must only be applied at the request of the passenger and must not prohibit the passenger from travelling independently on future journeys if they so choose.
  10. CNIB recommends that all airlines and air transportation service providers recognize the right of independent passengers with disabilities, including those travelling with a minor, to access curb-to-curb guidance upon request.
  11. CNIB recommends the CTA develop a streamlined process to respond to accessibility complaints in a reasonable timeframe. This process must centre the experience of the traveller throughout, and any administrative burdens or costs must be borne by the regulated entity rather than the individual to ensure the complaints process is itself accessible.
  12. CNIB recommends that passengers with disabilities only be required proof of disability once to an airline’s medical desk, with this information kept on file attached to their frequent flyer profile for use on all subsequent flights. Information from the passenger’s frequent flyer file should be shared with check-in staff so that the check-in process is seamless. Passengers could be given a separate identifier number as well to allow passengers to book subsequent flights independently without having to contact the medical desk.
  13. CNIB recommends that airlines be required to modify their websites to allow passengers with disabilities who are traveling with guide or service dogs to access early check-in benefits for their flight.
  14. CNIB recommends that if airlines intend to make any changes to a passenger’s booking that affects the accommodations requested by the passenger, the airline must provide ten days’ notice to the passenger with reasons why the change was made. This process must give the passenger the opportunity to respond to the proposed change.
  15. CNIB recommends the development of standardized forms for passenger accommodation requests to ensure the type of information collected by all carriers doing business in Canada is consistent. Information identifying a passenger’s accommodation needs should be kept by the airline permanently and accommodations should only be removed by the passenger and not the airline.
  16. CNIB recommends that the Government of Canada develop accessibility standards that must be adhered to before a business may provide services at an airport. Any equipment that is used by any airport or any airline, government agency or company doing business at an airport must be fully accessible (e.g., credit card terminals, check-in terminals, CBSA terminals, etc.).
  17. CNIB recommends that airports install wayfinding technology to assist blind passengers to find gates, rest rooms, guide dog relief areas, check-in counters, and other businesses operating at the airport. Airports should be required to advertise what technology they have installed and how a person who is blind can access it.
  18. CNIB recommends that all border services apps used to enter Canada, or the United States must be made fully accessible to people with all disabilities.
  19. CNIB recommends that all services provided on the aircraft must be accessible to passengers who are blind or low vision, including services provided on entertainment systems. Accessibility standards for entertainment systems used by Canadian airlines should be developed and enforced with financial penalties for the airlines of they do not comply.
  20. CNIB recommends that air transportation service providers ensure passengers with disabilities are treated with dignity at all times during their journey. Services delivery methods that demean anyone with a disability in general or those with a specific disability, when offered and rejected by a passenger, should not be required by an airline for a passenger to receive appropriate service.
  21. CNIB recommends that mandatory training programs be developed for all security staff to ensure the level and quality of training is consistent between airports and is not dependent on the contractor delivering the security services.
  22. CNIB recommends that airlines and airports should provide appropriate training to all customer-facing staff on sighted guide and how to work with an individual with a guide or service dog. Individuals with disabilities and the agencies who provide services to them should be consulted on the type and structure of such training.
  23. CNIB recommends the development of mandatory standards regarding the provision of meet-and-assist services when passengers arrive at a new airport.
  24. CNIB recommends that airlines and airports should provide specific training on how to assist travelers who are blind in retrieving their luggage. Luggage retrieval should be seamless, and the passenger should not be passed from one person to another during the process. 
  25. CNIB recommends that airlines and airports provide specific training on expectations for providing curb-to-curb service for passengers who are blind or have low vision. Passengers who are blind should expect and receive curb-to-curb service when arriving at the airport of origin and arriving at their destination airport. This means receiving assistance in finding appropriate ground transportation, waiting with the passenger until they are in the conveyance area, and locating check-in counters as required.

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