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Advisory to Canadian Operators of Metroliner and Beechcraft 1900 Aircraft

Subject: Boarding of Passengers with Disabilities

The Canadian Transportation Agency (Agency) is a quasi-judicial tribunal mandated under the Canada Transportation Act to regulate the federal transportation network. As part of this mandate, the Agency is responsible for ensuring that undue obstacles to the mobility of persons with disabilities are removed from federal transportation services and facilities in two ways: on a case-by-case basis, by adjudicating individual complaints, and, on a systemic basis, by developing regulations, codes of practice and standards or by examining issues related to the level of accessibility in modes of transportation under federal jurisdiction.

The objective of this Advisory is to assist the operators of small aircraft having 19 seats and fewer in exploring means of boarding and deplaning passengers with disabilities, and to remind the operators of the importance of properly informing their customers about the availability of boarding equipment and procedures at Canadian airports.

In a study entitled Boarding Small Regional Aircraft conducted for the Transportation Development Centre of Transport Canada⁽¹⁾ on boarding equipment and procedures for small aircraft operating passenger services at Canadian airports, the Fairchild Metroliner (Metroliner), the Beechcraft 1900-D Commuter (Beechcraft 1900) and the Hawker-Siddeley 748 (HS-748) were identified as having compatibility challenges with certain types of boarding and/or transfer devices used by Canadian regional carriers. The study found that small aircraft having more than 19 passenger seats operated by Canadian carriers, such as De Havilland DHC-8 series, Saab SF-340 and Embraer series, are more accessible due to their larger size. Finally, the study revealed that passengers with disabilities who use a wheelchair and need boarding and deplaning assistance are not always informed by the carrier of the various types of boarding equipment and procedures that may be available at the airports.

⁽¹⁾ A Summary of the Report is available on the Transport Canada website at www.tc.gc.ca/tdc/summary/14000/14077e.htm. A hard copy of the full report may be obtained from the Transportation Development Centre, 800 René Lévesque Boulevard West, Suite 600, Montreal, Quebec, H3B 1X9

The Accessible Transportation Directorate of the Agency therefore undertook to examine the equipment and procedures used by carriers operating the Metroliner and the Beechcraft 1900 aircraft to explore what measures could be taken to improve the accessibility of these aircraft for passengers who need boarding and deplaning assistance. Of the aircraft identified in the above-mentioned study, it was decided to focus on the Metroliner and the Beechcraft 1900 as these two aircraft combined represent the largest fleet of small aircraft having 19 passenger seats and fewer used by Canadian operators for scheduled services. Some operators advised that the HS-748 is mostly operated in cargo or mixed configuration for the carriage of bulk freight in remote northern communities and, therefore, is not normally used as a commercial passenger aircraft in regular scheduled services.

As part of the examination conducted by the Accessible Transportation Directorate, Bearskin Airlines demonstrated the equipment and procedures used by the carrier for the boarding and deplaning of passengers with a mobility impairment on its Metroliner aircraft. The flight and/or ground crew carry the passenger up the steps of the aircraft using a "straight back" such as a Washington type boarding chair. In the vestibule of the aircraft, the passenger is transferred, in a sliding motion with a minimum of lifting, from the boarding chair to the smooth surface of a small bench specially designed by the carrier for this purpose which is placed in the aisle beside the non-emergency seat in the front row. The passenger is then transferred from the bench onto the seat, again in a sliding motion. The height of the bench matches the height of the seat of the boarding chair at one end and of the aircraft seat at the other. The carrying and lifting of the boarding chair on the aircraft stairs is performed in a manner that, according to the carrier, prevents back injury for the personnel doing the lifting. Two persons are needed to assist in the boarding and there is at no time more than two persons (the passenger and one staff) on the aircraft stairs.

With respect to the Beechcraft 1900, a demonstration of the boarding procedure and equipment used by the operator on this aircraft presented a significant problem for the transfer of the passenger from the Columbia boarding chair provided by the carrier to the aircraft seat. The boarding device is too wide for the aisle of the aircraft and can only access the first row of seats. Another device may be needed to transfer certain passengers from the Columbia chair to the aircraft seat.

During the study, it was also found that, on both the Metroliner and the Beechcraft 1900, the (non-emergency exit) front row seats are, in general, the most accessible for the transfer of mobility impaired passengers from the boarding chair. The transfer of passengers with reduced upper body strength may, however, present some difficulty on the Beechcraft 1900 because the seat armrests on this aircraft cannot be removed or tilted to facilitate the transfer of the passenger. This problem does not appear on the Metroliner because of the absence of seat armrests on the aircraft. While not tested on the Beechcraft 1900, the system used by Bearskin Airlines may provide a viable option to transfer passengers on board the Beechcraft 1900 if the seat armrests can be moved.

It is recognized that, depending on the level of upper body strength of the passenger and the strength of the carrier personnel assisting in the boarding or deplaning, the accessibility of the Metroliner and Beechcraft 1900 aircraft for persons with a severe mobility impairment may present significant difficulties or may be impossible in certain circumstances. Nevertheless, the operators of these aircraft are encouraged to consider all options, including simple and inexpensive devices such as the one designed and used by Bearskin Airlines. Also, it is recommended that operators of Beechcraft 1900 consider the installation of movable armrests on the seats in the non-emergency front row of the aircraft to facilitate the transfer of passengers with a mobility impairment and to ensure the safety of both the passenger and the operator's personnel. Further, it is recommended that the operators of both aircraft take into consideration the configuration of the passenger cabin vestibule and the width of the aisle, including between armrests, when they acquire equipment for the boarding of passengers with a mobility impairment and the transfer to their seat in the aircraft.

The Agency is aware that air services to a large number of Canadian destinations are now provided using smaller aircraft for commercial and economic reasons, including capacity and demand. In past decisions on complaints, the Agency determined that it should not interfere with operators' internal operations to the extent of dictating the transportation equipment they must use. However, considering the physical limitations of small aircraft such as the Metroliner and the Beechcraft 1900, operators should make every practicable effort towards optimizing the accessibility of the equipment they choose to use.

With respect to the communication of information on the availability of boarding and deplaning equipment and procedures used at the airports they serve, carriers are reminded that section 4 of the Accessibility Guidelines for Small Aircraft Services for persons with disabilities on aircraft with 29 and fewer passenger seats issued by the Agency in 2004 recommends, in part, that carriers:

1. describe equipment and services available to accommodate persons with disabilities; and

2. discuss both the level of accessibility and the limitations of the aircraft, the tarmac, the facilities and the availability of boarding equipment for the available services to accommodate that person' disability-related needs.

To facilitate compliance with these Agency guidelines, carriers are encouraged to ensure that accurate and updated information on procedures and the availability of boarding equipment at each airport is maintained in their reservation system and any other sources of public information, where practicable. Carriers should emphasize to their personnel, as well as to their agents, the importance of providing such information to the customer at the time of booking in order to properly assist persons with disabilities in making educated decisions and choices in their travel plans.

The Accessible Transportation Directorate of the Agency wishes to acknowledge the cooperation of the operators of Metroliner and Beechcraft 1900 aircraft who took part in its study and provided demonstrations of their boarding equipment and procedures for persons with disabilities.

Should you have any questions regarding this matter, you may communicate with Diane Mainville, Manager, Regulations, Research and Analysis Division at (819) 997-0806 or diane.mainville@cta-otc.gc.ca.

September 2005