August 15, 2007

Comments to the Indian Office of the Director General of Civil Aviation

The government of India has invited comments on proposed Civil Aviation Requirements and amendments. Follow this link. Comments are due today! Yet this monumental policy, with international impact, is being promulgated without input from the Indian disability community.

Here are thoughts to consider when reviewing the draft policy:

1. The draft DGCA policy does not acknowledge that persons with disabilities has the same right to travel by air as any other passenger – instead the draft reads "Carriage of Physically Challenged Passengers"

2. The policy includes derogatory statements and apparently deputizes lay persons to pass medical judgements – Example - "obvious abnormal physical or mental conditions observed and reported by airline personnel or industry-associated persons" – what is the meaning of "abnormal"?

3. There is ambiguity in the use of terminology – Example – "Physically Challenged Passenger means a passenger with physical or mental disability or incapacitation; or with a medical condition which requires individual attention or assistance" – This definition is not in any way connected with the definition of 'Disability' that has been used in India's Persons with Disabilities (PWD) Act, 1995

4. The policy in its present form can be used to the airline to deny persons with disabilities from traveling by air independently. Section 4.3 of the policy says "that a person with severe mobility, hearing and vision impairment should be accompanied by an escort who will be responsible for enplaning and deplaning" This goes against the spirit of the PWD Act and is in violation of the rights of persons with disabilities to travel independently and make independent choices; a limitation of civil rights.

5. At present all passengers (disabled or not) who us the assistance at the airport are seated on a chair with wheels that makes it impossible for persons to propel independently – so all users are severely disabled by design. What are the basis/ criteria to judge persons with 'severe' disability – who decides?

Your comments should reach DGCA by 15th August 2007 by e-mail at mailto:rpsahi@dgca.nic.in or by post to
Shri R. P. Sahi, Joint Director General,
Office of the Director General of Civil Aviation,
Opp. Safdarjung Airport,
Aurobindo Marg, New Delhi
110 003

Posted by rollingrains at August 15, 2007 05:40 PM