Analysis of India's Civil Aviation Requirements


C. Mahesh, Advocacy Coordinator for the CBR Forum has provided the following analysis of India's Civil Aviation regulations.

Sub: Issuance of Civil Aviation Requirements, Section 3, Series M, Part I on Carriage by Air of Disabled Passengers or Person with Reduced Mobility

With reference to your letter JDG/AT/2007, Dated: 30th Aug 2007

Firstly I would like to thank you and DGCA for considering our feedback and comments favorably for the above mentioned CAR and for your prompt actions.

As you have mentioned in the letter I noticed that there is substantial revision from the earlier CAR and we greatly regard and respect this action.

The following are my comments to the revised CAR.

1 Section 1.1 – It reads as if Persons with disabilities are now able to travel because of 'Low Cost and Low Frill' airlines. This is not true as persons with disabilities have been using air travel for a 'long long' time because it is convenient and one can avoid overnight journeys. The paragraph is 'Patronising' and reads like a favour is being done for 'Disabled Passengers or Person with Reduced Mobility'. Therefore I would suggest that section 1.1 stops at the line ending "….the common man with average income group to travel by air".

2 Section 1.1 - The line starting from "Whereas persons with disabilities…" should be a new paragraph and should be rewritten as "Whereas persons with disability or persons with reduced mobility like everyone else are increasingly given the possibility to travel by air….". In this way persons with disabilities are being considered as an equal to every other passenger.

3 Section 3.1 – Definitions – the issue that a disabled person is not able to travel independently is not only because of physical or any other limitation in the individual but it also to do with the physical structure of the airports and the imposed practices/ procedures. For example: Wheelchairs cannot enter the toilets designed for disabled passengers. There needs to be an additional line in the definition that acknowledges the barriers imposed by the facilities at the airport/ airline and the air plane that in fact disables a person. Therefore there need to be a change in the sentence to acknowledge this barrier "Disabled person or person with reduced mobility means any person whose mobility when using transport is reduced due to any physical disability……. or any other cause of disability, or age or due to the architectural barriers/ barriers caused by structural/ procedural requirements and whose situation needs appropriate attention…"

4 Section 3.2 – The use of the word 'abnormal' is inappropriate and dehumanizing. Who is considered 'normal?'. People for no apparent reason behave badly/ rudely do you consider them 'normal'? Therefore I suggest that the word abnormal should be deleted, the sentence "or from obvious abnormal physical or mental conditions" should be reframed as – "or from observations observed and reported by airline personnel"

5 Section 4.1, Sub Section b – The sentence starting from "Airlines should develop emergency evacuation procedures" should be a new paragraph and not clubbed with the previous line as they are two different points.

6 Section 4.4 is the most important welcome change that acknowledges that many persons with disabilities may not need an escort. Therefore the present Section 4.4 should re-ordered and should be 4.3.

7 Section 4.3 mentions about "No airlines should be refused to carry persons traveling…severe mobility impairments….if they are accompanied by an escort" should be re-ordered and should become 4.4

8 Section 4.5 mentions about "assistance booths/ counters" - this alone is not sufficient there should also be appropriate buses/ vehicles that must be available inside the airport for transfer from one terminal to another – For example in Mumbai airport they have a Volvo bus to transfer passengers from domestic to international terminal – however the buses has steep steps and one cannot lift the passenger with the wheelchair inside the bus – and the passenger with disability has to instead come out of the airport and take a private taxi cutting across traffic to reach the international terminal.

9 Section 6.3 – Other Assistive Devices – Passengers carrying 'spare calipers' or 'mobility aid' must be able to take the same as a hand baggage and the airline should not insist on checking-in this baggage as these devices could be prone to breakage. These assistive devices are essential for the mobility and independence of the disabled persons and in addition they are not ready-made products that can be replaced/ purchased to compensate the passenger.

10 Section 7.4 mentions about 'In Transit off loading' and Section 7.6 mentions about 'Transit Stations' – However there is no mention of appropriate bus/ transport service to ensure easy and safe transit of disabled passengers. This point needs to be added in the CAR.

11 There is no mention of handling baggage of checked in luggage of disabled passenger. As a rule practiced by all airlines - the passenger with disability or passenger with reduced mobility is the last to deplane. It takes 20-30 minutes for the assistance and wheelchair to arrive inside the airplane and passenger with disability is usually the last one to collect the checked-in baggage from the conveyor belt. Therefore I request DGCA to add a new section - that says - checked-in baggage of disabled passenger should be marked with a 'Priority Tag' and the ground staff at the baggage section should keep the baggage in a safe place till the passenger arrives.

Please do get back to me for any further information/ clarifications. In addition, I would be very happy if you could send me the copy of the finalized CAR.

With kind regards

Best wishes

C. Mahesh

Advocacy Coordinator

C. Mahesh
Advocacy Coordinator
CBR Forum
14, CK Garden
Wheeler Road Extension
Bangalore - 560 084
Tel - 080- 2549 7387 or 2549 7388

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