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  CTA Home :
Accessible Transportation : Surveys and Reports : Communication Barriers Communication BarriersA Look at Barriers to Communication Facing Persons with Disabilities Who Travel by AirFall 1997Available in braille and on audio cassette and computer disk.VOICE: (819) 997-6828 Table of Contents CHAPTER 2: THE CONSUMERS' PERSPECTIVE
APPENDIX A Original Correspondence from the Canadian Council of the Blind APPENDIX B Letter to the Industry from the National Transportation Agency of Canada and List of Addressees APPENDIX C List of Interviewees APPENDIX D Bibliography
Background On January 24, 1995 the Agency received a letter from Mr. John Bullen, the National President of the Canadian Council of the Blind (CCB) (Founded in 1944, the CCB is an organization of people who are blind, and which provides social and recreational activities for persons who are blind or who have low vision. The CCB is also a national consumer group representing the interests of many Canadians who are blind or who have visual impairments. The CCB has 92 clubs across Canada, nine provincial divisions and a national office.). The letter expressed concern over a number of issues related to the communication of information to persons travelling by air who are blind or who have low vision. The CCB asked the Agency to inform the organization of the different alternative format policies currently in effect for Air Canada, Canadian International, their airline partners, and airports managed by Transport Canada. In responding to the CCB request, the Agency decided to expand the scope of the investigation to include communication issues for all persons with sensory and cognitive disabilities and also to include newly commercialized airports. A letter was sent out to air carriers and to airports to gather the information. The Agency then arranged consultations with over 50 groups, organizations and individuals representing persons with disabilities to get a better understanding of their need for information when travelling and to listen to solutions to improve their ability to travel by air. At the same time, research was conducted to find out what other organizations and other countries were doing with respect to the communication of information. The Agency also looked at the cost of available information technology. In December of 1996, an interim version of this report was circulated for comment to the persons, air carriers, and airports who participated in the consultations. Other government departments and interested persons received copies of this interim report upon request. Approximately 320 copies were distributed and 30 persons submitted comments. On the whole, comments were very positive and encouraging. Many additional practical suggestions were offered. Where possible, comments are reflected in this report. The first chapter, "Defining the Gap", summarizes the responses received from the industry. Chapter 2, "The Consumers' Perspective", outlines the results of consultations with the community. Common issues are presented first and then other results are grouped according to four main categories: persons who are deaf or hard of hearing, persons who are blind or have low vision, persons who are deaf-blind, and those who have a cognitive disability or have been labelled as persons with a learning disability. Chapter 3, "Closing the Gap", analyses the information gathered during the consultation process (chapters 1 and 2) and feedback received on the Interim Report. Recommendations that flow from this analysis are then developed to meet the needs of air travellers with sensory or cognitive disabilities. Finally, chapter 4, "Plan of Action", outlines the Agency's plan of action to remove barriers to communication in air travel. In its letter of January 24, 1995 (see Appendix A), the Canadian Council of the Blind (CCB) expressed concerns over a number of communication issues in the air industry which, in the Council's opinion, constitute undue barriers to travellers who are blind or who have low vision. These concerns were: * the lack of information available in alternative formats from both air carriers and travel agents; * an inconsistent understanding by all parties of what constitutes "accessible"; and * a lack of service standards. The CCB also expressed concern that the privatization of Canadian airports might result in a loss of influence or ability to bring about positive change. Finally, the CCB noted that the issue of communication of information has remained relatively unexplored. Prior to CCB's letter, the Agency had taken certain initiatives to improve communication of information and accessibility for persons with sensory or cognitive disabilities. The Personnel Training for the Assistance of Persons with Disabilities Regulations and the Air Travel Accessibility Regulations (Part VII Terms and Conditions of Carriage of Persons with Disabilities of the Air Transportation Regulations) contain some provisions to address the specific needs of persons with sensory or cognitive disabilities. Moreover, in response to individual complaints concerning communication of information issues and after having determined that there were undue obstacles, the Agency had ordered that corrective measures be taken by air carriers or terminal operators. However, as a result of CCB's letter, the Agency decided to examine the entire issue of communication of information for persons with disabilities when travelling by air. The Agency decided to investigate the availability of information in alternative formats as requested by the CCB. The Agency also decided to expand the investigation to include communication of information issues for all persons with sensory or cognitive disabilities. This investigation was initiated by the National Transportation Agency (NTA), the predecessor of the Canadian Transportation Agency (CTA), under the auspices of the then National Transportation Act, 1987 (NTA,1987). Under this legislation, the NTA had the responsibility to ensure that persons with disabilities can obtain access to this country's transportation system by eliminating unnecessary or unjustified barriers as well as having the power to inquire into issues related to these matters. The CTA continues to have the responsibility under the Canada Transportation Act to ensure that persons with disabilities can obtain access to this country's transportation system by eliminating unnecessary or unjustified barriers. Under the Canada Transportation Act which came into force July 1st, 1996 certain proceedings begun under the NTA, 1987 are to be completed by the CTA under the NTA, 1987 unless otherwise ordered by the Governor in Council. This investigation is not an exception and therefore, the CTA is completing the investigation. On May 23, 1995, a letter was sent to 49 different carriers and airport operators (see Appendix B), including Air Canada, Canadian International and their respective airline partners, as well as to commercialized and Transport Canada-operated airports. Specifically, the letter requested: * a description of all policies that deal with the publication of information in alternative formats; * copies of any alternative format publications produced by the addressee; * an outline of any communication or marketing strategies related to persons with disabilities; * a description of any communication technology used and its related cost which is benefitting persons with sensory disabilities; and * a copy of their training program for the assistance of persons with disabilities so that the Agency could tell whether the program addresses the needs of persons with sensory or cognitive disabilities. 1.3 Response from the Industry Over 90 per cent of the industry responded to the initial letter. The following summarizes the responses: * None of the air carriers or airport operators reported having an Alternative Format Policy in place. Several carriers submitted large print/braille safety cards which are provided on their aircraft. There was no indication of any other information available in braille, audio cassette or large print. * Some Canadian air carriers and terminal operators are providing information on the Internet. One terminal operator indicated that they were in the process of establishing a website on the Internet that will provide the option of larger print and/or audio for those with visual impairments. Another carrier has placed its schedule on computer diskette. * Several carriers and terminal operators have published pamphlets or booklets on services being offered to persons with disabilities; however, none of these publications are available in an alternative format. One of the newly commercialized airport operators indicated that they will install talking elevators and braille/tactile signage. * All the carriers and terminal operators indicated that they offer, or were in the process of implementing, training programs which include material dealing with the assistance of persons with sensory or cognitive disabilities. Several replies included a copy of a training manual illustrating sections on how staff can meet the communication needs of persons with disabilities. * One of Canada's major air carriers indicated that it provides a toll free reservation system via TTYs. Several terminal operators offer TTY services and one of the privately-operated terminals will be offering an assistive listening device system in the near future. One of the carriers reported that up-to-date flight information is displayed visually on monitors in the terminal and on boarding-gate signage. In addition, this carrier noted that boarding gates feature electronic signage that activates a flashing "boarding" message. * There was no indication of any additional provisions for communicating with travellers who are cognitively disabled. Since these responses were received by the Agency, other innovations have been introduced by the industry. 1.4 The Agency Continues the Investigation Review of the industry response revealed that at that time there were few measures being taken to provide necessary information in basic and essential ways to persons with cognitive or sensory disabilities. Therefore, more information on the needs of persons with disabilities when travelling by air and on the technologies available to meet those needs was gathered by interviewing consumers and asking them about their communication needs. CHAPTER 2: THE CONSUMERS' PERSPECTIVE 2.1 Consultations with Consumers This chapter is an account of what people said during the consultations which took place between December 1995 and May 1996 with over 50 groups and individuals with sensory or cognitive/learning disabilities across Canada. Specifically, meetings were organized with 17 groups representing consumers who are blind or who have low vision, 12 groups of consumers who are deaf or hard of hearing, eight groups or organizations speaking on behalf of persons who have been identified as having a cognitive or learning disability, and 14 groups or individuals from cross-disability or senior citizen's organizations. A list of organizations and individuals contacted as well as those who submitted comments on the Interim Report can be found in Appendix C. In addition, some comments submitted in response to the proposed Code of Practice Respecting Aircraft Accessibility for Persons with Disabilities issued in March 1996, were taken into account in this report as they dealt with communication of information issues. The Agency is confident that the groups and individuals consulted represent a significant portion of the population with sensory or learning disabilities. Most of these consultations were attended by more than one individual, and representatives from organizations presented the views of their members. Moreover, these groups covered a wide representation of perspectives from across Canada and many common themes arose. Several of the group consultations involved 10 to 25 persons. Feedback came from a diverse group of travellers, from those who travelled every week to those who travelled only occasionally. While the Agency attempted to reflect the broad range of comments received, the reader should be aware that it was not possible to include all the opinions, views and concerns raised. Whenever possible, the Agency reported the concerns and issues which were common to the majority of respondents. A standard questionnaire was developed to be used as a guide for the consumer interviews. This questionnaire was designed using the typical stages of a journey as an outline. The stages were identified as: planning and reserving a trip, getting confirmation of travel arrangements, orientation within the terminal, and orientation within the aircraft. Questions on the accessibility of information available at each of these stages were raised. Consumers were asked to describe their travel experiences, and if the information to which they have access is adequate and if not, how it could be improved. Certain safety-related comments were heard during the consultations which should be addressed by Transport Canada. They are being included in this report to bring to the attention of the appropriate authorities. 2.2 Highlights of Consultations 2.2.1 Common Issues Upon reviewing the volumes of information gathered during the course of the interviews, it was revealed that often different people would use similar solutions to solve different problems. For example, persons who are blind or who have low vision, persons who are deaf or hard of hearing, and persons who are cognitively disabled all suggested a user-friendly help-desk to solve or minimize a variety of obstacles. Common issues such as these are presented at the outset and only those obstacles or solutions which are specific to a type of disability appear under separate headings. General Comments Many participants generally felt that staff (in particular, air crews) were helpful and friendly. They had noticed an improvement in the service they had received in recent years. Interestingly enough, most of those interviewed also said that more staff training is needed. Some focused on the need for increased awareness of the requirements of persons with a print disability or other less visible disabilities. Respondents thought that some of the different service groups were better trained than others. In particular, security personnel and ground staff were identified as lacking awareness or being inadequately trained. The participants in general had noticed improvements in overall accessibility but recognized that communication is a weak link. According to numerous persons interviewed, many carrier and airport staff do not know what services are offered nor their company's policies with respect to persons with disabilities. As well, the people interviewed indicated that they, as customers, often do not know about the available services offered by the industry to assist them. A general lack of customer knowledge about all aspects of air travel was noted. Many participants noted that they would prefer that all written information (brochures, signs, itineraries, safety cards, etc.) be in plain language. Finally, a fair number of the groups interviewed commented that despite all the changes and improvements in technology and assistive devices, personal assistance remains very important. Often it is the most expedient way to get from one point to another, particularly when one is in an unfamiliar environment like an airport. Sometimes it is the only way to get the information one needs. Personal assistance and written information are considered to be complimentary to one another. Planning and Reserving a Trip The majority of participants indicated that they call travel agents directly to make their travel arrangements. Most participants felt that the process of selecting and reserving their flights on their own by consulting different timetables and schedules would be too time consuming. Many commented that they used the same agent who had been made aware of their specific needs over the years. Most frequent travellers indicated that they had found adequate solutions for reserving a flight. In addition, many persons felt they did not have access to information on air travel discount offers or other related information. Many participants are persons with a print disability and do not have ready access to mainstream media like newspapers and magazines. Page 10 Getting Confirmation of the Arrangements Participants wanted a plain language itinerary in large, boldface print with limited use of codes and symbols. People with low vision frequently suggested that carriers simply print documents with darker ink and larger fonts. Several respondents highlighted the use of the 24-hour clock as confusing. These travellers would feel more comfortable using a 12-hour clock with a.m. and p.m. indicated in their travel information. Orientation Within the Terminal * Availability of Assistance Concerns were raised with respect to the availability of assistance within the airport complex. All groups said that air terminals are a difficult environment to cope with. Getting to the check-in counter and flight connections were identified as particularly troublesome. It was noted that travellers sometimes prefer to travel at off-peak times when the airport is less busy, but that there is less assistance available at those times. * Help Desk The implementation of a help desk located consistently within terminal buildings was deemed useful by the participants. For example, the desk or a direct line phone to the help desk could be situated next to a main entrance. It was also suggested that this help desk be open during off peak hours to provide assistance to persons with disabilities who prefer to travel when the airport is quieter. It was mentioned that help desks should be more than just a "lotto centre". Persons working at the help desk should be highly trained to meet the needs of the travelling public, which includes senior citizens and persons who are disabled. The groups representing seniors felt that personal help would be frequently selected over computerized information, although, both should be available at all times. The user-friendly aspect of help desks would include the choice of how the information was presented, either in person or through the use of interactive video screens. It was also suggested that the information generated by computer should be available for printing if desired. * Announcements and Flight Information It was pointed out by most people, not just travellers who are hard of hearing, that announcements made in the terminal could not be understood because the information was not clear, was given too quickly and was not repeated. Comments were also made that flight-related verbal announcements were no longer made throughout the airport (for example, in restaurants or washrooms). As well, information available on electronic bulletin boards was often scrolled too quickly. Most respondents raised concerns with respect to flight information monitors. The following suggestions were made to improve access to flight information: - lower the information monitors to eye level, - enlarge the print, - improve the contrast, - avoid colour contrasts which are difficult to perceive such as red print on a black background, - use plain language, - reduce the use of codes, - scroll the information slowly, - install interactive computers with a "you are here" map, and - install electronic bulletin boards with flashing lights for changes in flight information. An enclosed information booth, reducing ambient noise and light, was suggested as a possible solution, where travellers could go to obtain flight or terminal information. It was also suggested that this booth include an audio system allowing a person who is blind or who has low vision to access up-to-date flight information, as it appears on the monitor/video screens. It was also noted that these machines should have the capability to allow the user to repeat information at will. Some participants who are learning-disabled stated that they would choose a computer to get information rather than asking for personal help. People with hearing disabilities felt that a computerized information device would allow the user to have the information repeated until they were confident they understood. On the other hand, it was mentioned that many senior citizens are not comfortable with technology. One group stated that, in general, they often will not use voice mail or computers and would normally prefer to communicate directly with a person. Therefore, the option to speak directly to a person should continue to be available. Furthermore, information booths, if installed, should have a port for plugging in a computer to access the information electronically (also useful for business travellers sending faxes), a voice synthesizer or a portable braille device. On this subject, it was also suggested that an electrical outlet and a phone jack should be available near the pay phones so that portable TTYs or computer/facsimile machines could be connected. * Advance Information Numerous participants supported the idea of making available advance information about airport facilities. They felt that this information would help them to be as independent as possible. Many types of advanced information were suggested including: large print maps with an accompanying explanation of symbols/signs which would be encountered, or maps combined with signs and auditory cues for way finding, word maps, brochures in alternative formats, tactile maps of all airport terminals to be encountered during a journey, and audio guides (similar to the systems used at many museums). It was emphasized that the traveller has to know where the signs/paths are in order to use them. For example, many people liked the idea of tactile maps for orientation, however, the suggestion was made that they be combined with tactile markings within the airport so travellers can check periodically where they are in order to orient themselves properly. These tactile markings could include well-contrasted textured floor markings, as well as symbols on posts and at intersections. As one individual stated, "it would be nice to know you are headed in the right direction even if someone is guiding you". It was noted that this information would be useful to the general travelling public as well as to persons with disabilities. In addition, the participants noted that maps should include the location of ground transportation facilities such as shuttle buses. For many, shuttle buses are the preferred method of travel because of their lower cost, but this service is often difficult to locate. * Connecting Flights Connecting flights cause anxiety. Some travellers avoided any trips which required connections and would opt for direct flights even if the schedule was less convenient for them. One commenter pointed out that he had encountered disputes between the air and the ground crew over whose responsibility it was to provide him with assistance during a connection. It was also pointed out that there was nothing worse than being left in the middle of a waiting area for a three-hour layover without being told where the washrooms were or to be forgotten while waiting for assistance to board an aircraft. * Signage In the terminal, participants indicated that signage often causes difficulty. Travellers would prefer to see more colour coding, greater contrast and increased print size with plain language using pictographs. These pictographs would help to overcome any problems travellers might have reading either English or French and reduce the effect of too much text when the signs are bilingual. Participants indicated that there is a tendency to ignore signage which would take a long time to read. Inappropriate placement of signage can present an obstacle to easy movement around an airport (for example, if the signs are too small or in an awkward location with respect to the path of travel). Persons who are blind or who have low vision thought directional signage to be slightly better than signs indicating washrooms, moving sidewalks, stairs, and other areas of potential danger. Another suggestion was to install sound cues at all intersections, pedestrian crossings and on public doors. * Consultations with the Community of Persons with Disabilities Frequently, participants recommended the establishment of "barrier free" committees at all airports. These committees could review existing facilities and procedures with respect to the communication of information to travellers with sensory disabilities. For example, they could review the location of emergency alarms and recommend changes where necessary. Orientation within the Aircraft Many participants indicated that seat markers and individual call or control buttons at seats should be better identified using tactile and visual means of identification. It was suggested that these buttons be positioned in a more accessible and consistent place. Uneven lighting in the aircraft creates shadows, making it more difficult for persons with low vision to see seat numbers, and other buttons. Several suggested placing large, well contrasted tactile or braille markings on the seats or overhead bins. It was mentioned that radio reading services or magazines could be made available on the extra audio channel. Generic travel information could also be made available on these extra channels (for example, customs requirements, safety briefings, aircraft features, baggage limits, duty-free items for sale, and airline policies). Concerns were expressed that persons who are blind or who have low vision are missing information available to other travellers through the standard reading material provided by carriers. 2.2.2 Issues Raised by Travellers Who Are Deaf or Hard of Hearing General Comments While the need to improve staff training was raised by the majority of consumers consulted, participants who are deaf or hard of hearing were particularly concerned about the air industry staff's lack of knowledge of proper face-to-face communication techniques. Many participants were concerned that dedicated pen and paper were not available to facilitate the communication process. It was suggested that pen and paper be made available, in plain view, at all points of contact: at the ticket counter, the boarding gate and on board the aircraft. Planning and Reserving a Trip The main problem identified by participants who are deaf or hard of hearing was getting access to travel agents' and air carriers' phone lines to get the information required to plan and reserve a trip. It was also pointed out that advertisements, particularly for air travel discount offers, include voice-only phone numbers. Many felt that in situations where a TTY number isn't readily available and advertised, a fax number should be listed. In general, respondents felt that carriers should have a TTY and that the TTY number should be advertised and as easy to find as the general number. When a carrier installs a TTY, it was recommended that it should be installed close to the computer terminal where reservations are entered by airline personnel. It was noted that those carriers who had installed a TTY for reservations often had not installed it in a location which was practical for reservation personnel; and persons contacting the carriers felt they had to wait extraordinary amounts of time while being served. It was also recommended that the TTY be well maintained. Comments were received that where there are automated computer reservation systems available, there should also be adequate volume control, a message repeat function and easy access to personal assistance. No consensus could be found on the issue of identification of needs at the time of reservation. Half of the participants recognized the value of self-identification to get better service from the airlines. They also acknowledged that many people who are deaf or hard of hearing have a reluctance to self-identify. Reasons for this reluctance ranged from feeling that they would be treated like a child if they self-identified to feeling that they did not require extra services. Some participants recognized that if persons who are deaf or hard of hearing elected not to self-identify, the carrier's staff should not be expected to guess what their needs are. Getting Confirmation of the Arrangements Reconfirming or reserving a flight with an automated computer reservation system was identified as a problem. Most charter flights and some air travel discount offers require that the passenger reconfirm at a specified time in advance (usually 48 hours). Passengers who are deaf or hard of hearing risk losing their seats because often the only way to reconfirm a flight is through an automated voicemail system. Voicemail is difficult to use because it does not allow for repetition. If part of a message is missed, there is often no way to start over again before the end of the message. It was suggested that everybody should be allowed to reconfirm with faxes, TTYs or have an alternative to voicemail, such as having the option to speak directly to a person. Orientation within the Terminal The majority of participants commented on the lack of, or the small number of TTYs and volume-control phones in airports. Many suggested that TTYs and volume control phones be more clearly identified, properly maintained and available 24-hours a day. (In some cases, the TTY is located at the help desk which is only open from nine a.m. to five p.m.). All airport personnel should be aware of how TTYs operate and where they are located. It was also noted that it was impossible to phone an airport to obtain flight information with a TTY. Travellers who are hard of hearing requested the installation of pay phones with adequate volume-control and/or amplification. It was observed that many of the larger American airports have pay phones which have jacks to plug in computers, fax machines, and TTYs and provide good quality sound amplification. These phones were primarily installed for business travellers and present the added benefit of also being adaptable for people who are deaf or hard of hearing. The installation of sound baffles between each ticket agent counter would be a way to overcome the problem of too much ambient noise. This arrangement, combined with assistive listening devices, would greatly assist travellers in their ability to communicate. Several travellers who are deaf or hard of hearing indicated that they have encountered difficulties with security. A suggestion was made to install a green light/red light system at security. A green light would mean that you could proceed to your gate and a red light would mean that a further check was required. Another individual noted that more signage was needed to facilitate movement of persons through security and customs areas. One respondent related that he had been asked to remove his hearing aids and put them through the x-ray machine. On another occasion, he was told that he should have packed them in checked luggage. Many travellers noted that they try to sit as close as possible to the departure gate counter and watch for announcements because they are concerned they will miss something important or be forgotten by airline staff. They noted that it is not always possible to find seating close to or in clear view of this counter. Therefore, it was suggested that designated seating should be available closer to the gate so that persons who are deaf or hard of hearing can see the activity at the desk and inquire each time about what is being said when announcements are made. Orientation within the Aircraft The biggest problem identified by participants is that they cannot hear the on-board announcements. Several reasons were cited: sound of the engines, announcements during a movie, and ambient noise. It was recommended to stop the movie when making an announcement. Several participants commented that the on-board lighting was often too dim and the attendant too far away to permit lip reading during a safety briefing. Very few persons who are deaf or hard of hearing recommended preboarding. As long as they were made aware of any changes to their flight, generally these persons could see no advantage to preboarding. Another respondent suggested that when the boarding announcement is made that the applicable numbers should be displayed when boarding by row. This respondent often preboards because she cannot hear the row numbers being announced. Several participants indicated that they prefer to sit in the quietest area of the aircraft (which is in front of the engines). Even when sitting in the quietest part of the aircraft, some people still turn off their hearing aids during take off and landings. Staff should be made aware of this practice. Participants indicated that the installation of headsets which are compatible with hearing aids would improve their ability to understand what was being said. It was mentioned that headsets in the business or first class portions of some aircraft are already hearing aid compatible. It was suggested that headsets be distributed upon boarding. Another suggestion was made to always equip two seats with headsets even on small aircraft to provide improved access to the public address system. Another recommendation was to use a Visual Communication Network (VCN) for announcements. These real time electronic messaging boards are becoming more common on subways and commuter trains to announce stops and delays. Many participants identified a need for assistive listening devices (ALD) on board aircraft. It was not, however, possible to obtain consensus with respect to the type of ALD which would be best suited for use on board an aircraft. It was believed that some ALDs would interfere with other communication devices used within the aircraft (for example, communications between the pilots and the air traffic control). Half of the participants indicated that they would like to have the in-flight films and the safety videos captioned. 2.2.3 Issues Raised by Travellers Who Are Blind or Who Have Low Vision General Comments A principal obstacle to the mobility of passengers who are blind or who have low vision that was identified during the course of the interviews was the lack of availability of documents in alternative formats. Many suggestions were made to improve this situation. Generally, it was felt that if something was deemed important enough to publish for the general public, it was important enough to be printed in alternative formats. However, it was pointed out that there was a difference between specific flight-related information a passenger needs to know for a short period of time and general reference information a passenger needs to know for an extended period of time. Several participants who travel alone talked about their inability to identify airport personnel and the resulting anxiety caused by, for example, being asked for one's passport by an unidentified person. Several participants also indicated that they encounter problems with security staff. For example, they had been separated from their cane, escort or dog guide while going through the security check point. It was suggested that when service representatives approach anyone they know has a sensory disability, they should first identify themselves and who they work for before performing an official function or offering assistance to the traveller. As a general note, the issue of self-identification was not debated because the benefits of self-identification appear to be better known and accepted by the majority of persons who are blind or who have low vision. Most travellers who are blind or who have low vision consulted for this report felt that it was beneficial to have some combination of personal assistance and enhanced information available at all stages of the journey. However, it should be noted that an advocacy organization of the blind felt that there are no communication barriers to air travel which could not be overcome by travellers themselves. Planning and Reserving a Trip Most participants were concerned that the information they provide to air carriers on their needs is often not properly passed on to the airport staff or flight crew. The suggestion was made to establish some method whereby this information would be properly passed on to appropriate personnel. Participants generally prefer to make their reservations by phone. Some frequent travellers using a particular route saw a need for timetables in alternative formats. Some of these travellers flew so frequently on regularly scheduled routes that they had taken the time to produce their own timetables in an alternative format. Most participants did not deem it essential to have flight schedules and timetables in an alternative format. However, it was deemed essential to have access in an appropriate alternative format to a publication or brochure describing services, terms and conditions of carriage, special meals, baggage allowances and damage claim procedures of air carriers and other transportation service providers. It was pointed out that travellers who are blind or who have low vision need to know the same information as the general travelling public. In many cases the participants did not realize that information about these types of services was available from airlines and therefore do not know to ask for this information in other formats. It was recommended that an Alternative Format Policy be developed for all information available to the general public. It was suggested that this Alternative Format Policy would help eliminate many problems encountered by travellers with disabilities. This policy would outline the availability of braille, large print, audio and electronic documents for items such as itineraries, route schedules and brochures. Such a policy should specify how the information will be supplied when a particular document is no longer available or temporarily out of stock. It was pointed out that it was also important to provide up-to-date information in alternative formats. A policy should require that any updates or reprints of brochures or other publications also include their production in alternative formats and mention their availability on the cover of the original publication. It was suggested, for those who are print-disabled, that a toll free phone number be included in large print on the cover of all publications. Travellers could then dial the number and have a summary of the publication read to them and/or have an alternative format version sent to them. Getting Confirmation of the Arrangements An important issue for participants was being able to have an itinerary or travel information in an alternative format. Having that information accessible would increase their ability to travel independently. Specifically, they thought an itinerary should contain the date and time of departure, the seat number, the airline, flight number, stopover information, a confirmation number, and information about unusual procedures like the departure tax collected at the Vancouver Airport. Some were willing to ignore the "other pieces of paper" if they could access this one sheet with basic information clearly presented on it. Orientation within the Terminal Navigating through terminals is often the most stressful part of a trip. The large terminals were almost invariably mentioned as a very unfriendly environment. The "gap" between the entrance doors of the terminal and the air carrier's counter was identified as a major obstacle. Many pointed out that they felt they had to bring someone with them, either a family member, a friend or the taxi driver in order to get to the ticket counter. In addition to the provision of a help desk and information phones already mentioned in the general section, other solutions to eliminate this "gap" were put forward. The provision of textured carpeting at entrances which would lead to a help desk was suggested. Also it was suggested that providing a short-term parking space next to a main entrance for taxi drivers or others who would be assisting persons with disabilities to the ticket counter or help desk would be beneficial. Rope cueing systems were identified as an obstacle. The comment was made that sometimes there is little choice but to go all the way through a line to find out if it is the correct one. It was also suggested that there should be tactile markings on the floor to identify the beginning of the line. In addition to the advance information requirements discussed in the general section, persons who are blind suggested a brochure be made available to them on how to obtain a ticket in the airport or what to do when you get to the ticket agent. For example, participants wanted suggestions on what to hand the agent, where to place their bags or what the procedures and screening options were at security check points. It was also pointed out that the verbal announcements were not descriptive enough. During an announcement about a flight departure, in addition to stating the carrier, the flight number and the gate number, it was suggested that a description of the location of the gate be added (for example, in the far northeast corner of the departure concourse). Changes to boarding passes were discussed by several travellers with vision problems. The suggestion was made that notches or colour coding be added on multiple boarding passes to identify the order of use. Another suggested that the gate number be written on the boarding pass with a large marker. This would be a simple solution which would help many find the gate independently. Some, however, stated that they could identify boarding passes and no changes were necessary. It was also suggested that the gates/doors/loading bridge entrance be better contrasted with the surrounding walls. Orientation within the Aircraft Most participants indicated that the individual safety briefing should include a descriptive orientation of aircraft features such as: the location of the nearest exit (Transport Canada regulations require that passenger safety briefings indicate the location of the nearest exit.), the location of the nearest washroom and its basic layout (which would include the location of the door lock and flush handle). Several suggested that all washrooms on board planes should be standardized and the doors should be marked with a tactile button "to make sure that it is not the coat closet". A suggestion was also made for carriers to develop generic information about their fleet as some U.S. carriers do. Several U.S. carriers provide a book in alternative formats containing general information about the aircraft (for example, exits, capacity, layout). A respondent suggested that the airlines reserve the bulkhead seats for readers of braille who bring their own reading material because braille documents are very bulky and the extra space would be useful. Concern was expressed that the large print and braille safety cards did not contain the equivalent information to the standard print safety cards. Air carriers should review the contents of the cards to assure that no vital information is missing. As well, participants felt that a review of all the travel-related information available to the general public should be performed to ensure that all travellers have equivalent information. One respondent stated that he travelled an average of 24 times per year and had never received an individual safety briefing. It was also indicated that a general description and/or demonstration of the call and audio buttons would be of great assistance. Another concern was that the demonstration of how to use the safety equipment was not effective. It was, therefore, suggested that carriers schedule regular demonstrations of safety equipment for prospective travellers. During these demonstrations the travellers could "pull the red tab" on the oxygen mask and try out the emergency chutes. Luggage posed many problems for persons who are blind or who have low vision. It was commented that the luggage carts should be in a standard location near the entrances and exits. Another suggestion presented was that passengers who are blind or who have low vision be able to carry their luggage on board to save having to retrieve it with the assistance of airline personnel. One traveller recounted difficulties he had had trying to describe the luggage he had never seen. Another point made was that airline staff should be responsible for filling out the customs forms for those with a print disability and not the passenger seated next to the traveller with a disability. When deplaning, it was suggested that verbal instructions be given on deplaning procedures, that is, passengers would like to know if they are using the same door as when they boarded, whether there is a jetbridge or stairs to the tarmac as well as the route to the baggage return area. 2.2.4 Issues Raised by Travellers Who Are Deaf-Blind General Comments It was pointed out that deaf-blindness is a distinct disability and the communication methods used by people who are deaf-blind may be different from those of people who are either deaf or blind. Communication methods used by people who are deaf-blind vary depending on a number of considerations such as: nature of the disability, amount of residual sight and/or hearing, education, method of communication used before becoming deaf-blind, and comfort level with various forms of communication. It was noted that congenitally deaf-blind persons may not travel with the same independence as the larger group of persons who became deaf-blind later in life. Respondents indicated that in general, persons who are deaf-blind have seen no improvement in overall accessibility. In particular, they felt that persons who are deaf-blind are not informed about the services offered by the industry to assist them. Commenters advised that communication with persons who are deaf-blind is possible using the one-hand manual alphabet. Deaf-blind respondents requested that service personnel become more familiar with the particularities of communicating with persons who are deaf-blind, both when they are travelling alone and when they are using the services of an intervenor. Orientation within the Aircraft It was noted that communication between airline personnel and persons who are deaf-blind concerning emergency evacuation issues, safety procedures and customer service-related issues requires more dialogue and cooperation between this community and the industry. 2.2.5 Issues Raised by Travellers with Cognitive or Learning Disabilities General Comments Most comments centred around the training of staff and the importance of being patient. The point was made on several occasions that the majority of persons who have been labelled as having learning disabilities are capable of travelling independently with the right kind of help. Some persons with cognitive or learning disabilities do not process information the first time they receive it. Repetition is important to assure comprehension. Many felt it was the responsibility of the personnel providing the assistance to verify if the information being given has been understood by the passenger. Planning and Reserving a Trip There was a definite reluctance to self-identify when booking a flight because of the negative connotations associated with cognitive and learning disabilities. The majority of respondents stated that a third party, either a family member, a friend or a representative would usually make reservations on their behalf. It was noted that experienced flyers often use the same travel agent who has been made aware of their specific needs. Some felt that the wide range of travel-related choices needed to be explained in more detail. It was indicated that all travel options are not immediately evident to the traveller with a cognitive disability. Therefore, travel agents and carriers should be made aware that other factors may need to be explored. For example, the concept of the "cheapest fare available" and whether the passenger is required to stay overnight on a Saturday might have to be explained more carefully. It was suggested that a hotline be set up for travel agents which outlines services available for persons with disabilities. Respondents recommended that it could be on-line as part of the reservation system. It was pointed out that this hotline would make available to the travel agents information on what services are available from individual airlines to assist passengers who are disabled. Getting Confirmation of the Arrangements It was recommended that the itinerary and other "need to know" information be made available in alternative formats, for example, in audio, as well as in large print. It was explained that some people process information better if two sources, such as audio and visual information, are presented simultaneously. Audio tapes were considered invaluable because many travellers with learning disabilities experienced difficulty reading. For example, it would be helpful to those consulted if travel agents prepared tapes of an itinerary. A description of symbols and their meanings which would be encountered during the trip was requested. Some persons with learning disabilities would like to be able to obtain step- by-step instructions on how to proceed on their journey. For example, the instructions would include a descriptive narrative such as: "Ask the taxi driver to drop you off at the first door, once through the door look for the blue and red airline logo". Orientation within the Terminal The need for personal and patient help, especially for wayfinding and making flight connections, was emphasized and considered invaluable. Sometimes, the amount of information needed varied for each individual and would be too much to read from a brochure; thus, personal help was often the preferred alternative. The implementation of colour coding to help in wayfinding was also suggested. For example, upon disembarking everyone could be told to follow the green line to get to the baggage return area. This consultation revealed that sometimes in airports there is a problem with information overload and that colour coding would reduce the number of pieces of information all travellers would need to process. Some travellers indicated that they would also like to have an idea of how long it would take to walk from point A to point B. This would give them confidence that they had not missed their destination. The groups and individuals interviewed felt strongly that there should not be a help desk which is only for persons with disabilities. This was not considered to be "community living" (The concept of community living is a movement which encourages persons with learning or cognitive disabilities to fully integrate into the community.) and would stigmatize and discourage these persons from using the help desk. However, it was suggested that a space for a designated greeting area could be allocated for all those persons who are to be met at an airport. Some examples given were: unattended minors, business travellers, politicians as well as persons with disabilities. One group suggested the use of "Persons in Green Coats" who would volunteer at airports to assist any travellers who might need help. It was suggested that senior citizens could be recruited. Orientation within the Aircraft The participants suggested that following the safety briefings, staff should inquire whether anyone has any questions. Travellers with learning disabilities should also have the option of having a personal briefing if they feel it is necessary. At the very least, it was felt that these passengers should be encouraged to ask questions or request assistance at any time during the flight. Page 26 In addition to the safety card, participants saw a need for a large print information card with pictographs describing the buttons at their seats as well as the location and layout of the bathrooms. It was also suggested that a demonstration of how passenger equipment was operated would be helpful. Some concerns about baggage retrieval were expressed. It was suggested that a brief description of how to get to the baggage return area just prior to deplaning would help remind passengers with learning disabilities that they need to pick up their bags before leaving the airport. This description would also help to instill the confidence the traveller needs to find his/her bags without assistance. In undertaking this investigation, the Agency tried to identify the communication barriers facing persons with disabilities while they travel by air. Identifying and creating an awareness of the information gaps which need to be bridged will lead to the improvement of the quality of the travel experience for many Canadians with sensory and cognitive disabilities. The Agency learned throughout this investigation that the lack of adequate information is a reality for thousands of Canadians, be they persons who are blind or who have low vision, persons who are deaf or hard of hearing, persons who are cognitively disabled, persons who are deaf-blind or persons who are illiterate. According to Statistics Canada's 1991 Health and Ability Limitations Survey (HALS), it is estimated that almost three quarters of those adults with a disability have what may be termed as a sensory or cognitive disability (30 percent have hearing disability, 30 per cent a cognitive disability, while 14.5 percent have a visual disability) (It should be noted that because many persons with a disability have more than one disability, these percentages cannot be added.). The Canadian National Society of the Deaf-blind estimates that there are approximately 3,000 persons who are deaf-blind in Canada. Moreover, these figures are expected to grow as the baby boom generation approaches retirement age and begins to experience the decreased sensory abilities often associated with aging. While this report focuses on the information needs of persons with disabilities while they travel, the information enhancements proposed in this report will benefit all travellers. Initially, the Agency heard from Canada's major transportation service providers about some innovative communications initiatives, such as TTY reservation systems and safety cards in braille and large print. While valuable, the Agency realized that these positive initiatives were evolving in isolation and that an overall perspective on the information needs of travellers with disabilities was needed. As the consultations were progressing, common issues and concerns were consistently being raised by consumers and it is clear that there are communication barriers facing travellers with disabilities during the different stages of travel. The Agency is of the view that the consumer consultations have demonstrated that communication is a weak link. Most persons with disabilities do not know which services are offered by the industry, and similarly, many employees are not fully knowledgeable about the policies and the accessible services offered by their employers. When they plan and reserve a trip, persons with sensory and cognitive disabilities encounter several difficulties. Information about the services or about air fares that are being offered by the industry are either not communicated or not in an accessible format for those who cannot read regular print material. Moreover, the means to communicate with air carriers and airports are not accessible: the increased reliance on voice mail and the absence of TTYs or inadequate TTY service are particularly relevant. The Agency is also of the view that there are particular communication barriers for people with sensory disabilities in terminals. There is a gap between the terminal's main entrance and the carriers' ticket counters where little or no assistance is available. Terminal announcements and their accessibility cause concern. Moreover, personnel have difficulties communicating with travellers who are deaf or hard of hearing, and providing appropriate information to travellers who are blind or who have low vision. Travellers with a cognitive disability have difficulties finding their way within terminals and obtaining appropriate assistance. The Agency also believes that the consultations have revealed that travellers with sensory and cognitive disabilities are facing communication obstacles while on board the aircraft. One issue of particular importance was the lack of available information related to the passenger-operated features on board an aircraft. The information gathered during the consumer consultations has convinced the Agency that there is an information gap for travellers with disabilities and, during the course of the interviews, hundreds of suggestions and ideas were offered to close that gap. A wealth of valuable information was discovered. There were repeated examples cited by consumers of low-tech, low-cost solutions that would enhance the travel experience. Using markers to write boarding-gate numbers in large print, pads of paper and pencils on the counter for use by passengers who are deaf, use of descriptive public address announcements and taking a little more time explaining information to passengers were among the many examples that have convinced the Agency that much can be done today to close the information gap. A common theme repeated by consumers across Canada was the importance of personal contact and exchange of information. The Agency believes these consumer consultations have shown that the high level of personal assistance already offered to travellers with disabilities who desire it, can only be complemented by developments in information technology. At the same time, travellers with disabilities wishing to travel with minimal assistance would be provided with the knowledge to make self-reliance a reality within a helpful and sensitive service environment. The Agency found a high level of interest and concern among transportation industry representatives for the information needs of this segment of the customer base. Some of the consumers' findings and proposed solutions were discussed with industry representatives. These suggestions were generally well received by the industry and there was a genuine interest to work collaboratively towards innovative solutions. Moreover, since this investigation was launched, the industry has implemented new solutions to improve the communication of information to travellers with disabilities. More TTYs and volume-controlled phones are being installed in airports. New assistive listening devices are also being installed in airports. In February 1997, the Air Transportation Association of Canada (ATAC) hosted a workshop on the communication of information for many persons with sensory disabilities. The purpose of the workshop was to get persons with disabilities together with members of the industry to discuss the barriers they face while travelling by air and to identify workable solutions. The recommendations of the Interim Report were discussed at this workshop. The recommendations and suggestions in this report are presented as a starting point on the journey to easier information access for all. Background The Agency recommendations listed below were developed in the context of the National Transportation Policy contained in section 5 of the Canada Transportation Act which states in part that: ... a safe, economic, efficient and adequate network of viable and effective transportation services accessible to persons with disabilities and that makes the best use of all available modes of transportation at the lowest total cost is essential to serve the transportation needs of shippers and travellers, including persons with disabilities... [ ... ] (g) each carrier or mode of transportation, as far as is practicable, carries traffic to or from any point in Canada under fares, rates and conditions that do not constitute [ ... ] (ii) an undue obstacle to the mobility of persons, including persons with disabilities. [ ... ] In developing these recommendations, the Agency also took into consideration Transport Canada's policy "Access for All" which sets out the Canadian Policy on Transportation Accessibility, namely that: When travelling, persons with disabilities are entitled to be treated with the same dignity, consistency and consideration afforded to other travellers and to receive services customarily available to the general public. This entitlement extends to information and directions that can be understood by travellers with cognitive or sensory disabilities. These recommendations also take into account previous rulings of the Agency with respect to communication of information-related complaints, as well as recent inquiries and existing regulations. Comments and suggestions received following the publication of the Interim Report are incorporated into the recommendations of this Final Report. 3.1 Recommendation on Information for Travellers with Disabilities One of the common themes throughout the consumer consultations was that travellers with disabilities are generally not aware nor do they know how to find information to become informed air travellers. The Agency recognizes that the rules, regulations and conditions of air travel are diverse and complex. As such, the information is often compartmentalized, difficult to understand and cannot be found in a centralized location. There is a need for a publication that would provide specific facts to assist persons with disabilities to become better informed consumers when they are travelling by air. Recommendation 1 The Agency recommends that a guide for travellers with disabilities be produced. Initial discussions were therefore held with industry, consumers and other government departments to explore their possible involvement in a partnership with the Agency to prepare such a publication. The response was positive. The Agency will therefore work with these partners to develop this publication. 3.2 Recommendations to Air Carriers and Airports The following are recommendations to the air industry. The next eight recommendations apply to the industry as a whole. Additional recommendations relating respectively to airports and air carriers are presented separately. The Agency is confident that solutions can be found to benefit travellers with disabilities. These solutions will also improve the communication of information to the general public and will be cost effective for the air industry to implement and maintain. 3.2.1 Alternative Format Policy The Agency is convinced that all travellers should be able to access essential transportation-related information. Being able to know and refer to travel information, knowing which information is available, and having access to the same transportation information as all travellers, were common themes among those consulted. Moreover, the Agency believes that travellers should be able to confidently expect an equitable, consistent and uniform level of access throughout the industry. Therefore, to achieve this equitable and consistent access within the industry, the Agency believes that air carriers and airport operators should make their best effort to provide in alternative formats all transportation-related information that is otherwise available to the general public. Recommendation 2 The Agency recommends that all air carriers and airport operators outline in a clear and concise Alternative Format Policy, how they will provide to persons with disabilities information that is otherwise available to the general public. An Alternative Format Policy should: * indicate that transportation-related information will be available in alternative formats, e.g. brochures describing services available for persons with disabilities, policies respecting terms and conditions of transport, regulations respecting the carriage of passengers and luggage, itinerary and individual travel information, terminal orientation material, etc; * describe documents that will be readily available, documents that will be produced on request, and indicate the amount of advance notice required for the production of customized documents; * describe alternative means to provide the information when a document requested in a particular format is not immediately available; * describe formats that will be used, recognizing that some people might require more than one format; * indicate reasonable time frames required to produce documents in alternative format; * describe what measures will be taken to assure that alternative format materials are of good quality; * indicate means to inform the target population of the availability of information in alternative formats (For example, service providers could promote the availability of alternative format versions on the cover of conventional print publications, and offer to prepare an itinerary in large print at the time of booking. * require that documents be produced in plain language; * always provide for an alternative way to communicate with the carrier or the airport in public communications (e.g. fax number, E-mail address, or TTY number along with the voice number in seat sales advertisements; alternative to voicemail only for getting information, TTY number to phone the airport and air carriers for information, not just a public-use TTY at the airport); * indicate that any information introduced on the Internet will also be accessible to travellers with disabilities; * require that alternative formats are available at the same price to the customer as their print counterparts; * indicate that charts and graphs will need to be converted in order that the same message be conveyed; * require that in cases where it is not possible to make the alternative format documents identical to the regular print versions, the differences should be noted in the alternative format document; and * require that alternative format versions of documents are kept up to date and are available in both official languages. In addition, these individual alternative format policies should be available to the general public upon request. In developing these policies, the industry may consider consulting the Generic Alternative Format Policy to be developed by the Agency in collaboration with a working group staffed with representatives of the air transportation industry. The Agency found that the cost of producing material in alternative formats varies greatly by quantity, nature of the original material and the medium. The cost also varies depending on whether or not the material is produced in-house or produced by a firm specializing in the production of alternative formats. Among the solutions put forward during this investigation, several can be classified as low-cost. For example, producing a document in large dark print requires minimal additional cost output, assuming the document is computer generated. Text processing software allows the user to select font styles and many printers are capable of producing a variety of print sizes. Similarly, the cost to produce a document on a diskette would be low and be comprised of the document conversion time and the cost of the diskette itself. Electronic text sometimes contains symbols which a voice synthesizer cannot read. These symbols, plus charts and diagrams must be replaced with equivalent information. Again, assuming the document is already produced electronically, making a copy on a diskette is very inexpensive. The cost to produce documents in braille and on audio cassette, either in-house or by a specialized firm, is more expensive, but our research has revealed that this would not be prohibitive. For example, an American carrier indicated that to produce 4,000 copies on audio cassette with a braille label, of its 24-page special needs brochure cost $0.93 (U.S.) each. Ordering 2,000 braille and large print versions of the same brochure cost $2.22 (U.S.) each. Throughout the consultations, participants indicated that personal help was considered invaluable, which confirms findings of previous surveys and studies performed in Canada and in other countries. Moreover, improvements in access to information technology were not considered a replacement for the availability of personal help. Recommendation 3 The Agency recommends that the industry continue to provide personal services currently offered to travellers with disabilities. Most participants indicated, however, that more staff training is required, particularly with regard to: the improvement of face-to-face communication techniques with people who are deaf or hard of hearing; the importance of staff identifying themselves and for whom they work when approaching a person who is blind; and the importance of listening and repeating if required. Groups representing persons who have low vision also reported that on occasion security personnel had held them back and would not allow them to proceed to their gate unescorted. Therefore, the need to improve sensitivity training for security personnel in airports should receive special attention. The need to improve training of transportation personnel has been a recurrent theme for a number of years. This is why, in 1994, the Agency implemented the Personnel Training for the Assistance of Persons with Disabilities Regulations. The Agency's monitoring of the implementation of these Regulations has indicated that most of the air industry is in compliance and has trained its personnel as required by the Regulations. Despite noticeable improvements in levels of awareness on the part of industry staff, the fact that training remains an issue might indicate that the problem is no longer a question of compliance with the Regulations, but might rather be a matter of effectiveness of training or a matter of closer management of the quality of day to day service provided by personnel. Service providers should take appropriate measures to ensure reliable provision of quality service to travellers with disabilities. Recommendation 4 The Agency recommends that the industry establish quality control mechanisms to ensure that consistent, reliable service is provided to travellers with disabilities. As suggested by the industry, those mechanisms could include identification of an official whose functions would be to respond to complaints raised by travellers, including travellers with disabilities. Recommendation 5 The Agency recommends that, when preparing refresher training, emphasis be placed on the importance of personnel having a working knowledge of services and policies offered by air carriers or terminal operators to travellers with disabilities, including communication of information issues. Recommendation 6 The Agency recommends that persons with disabilities be involved in refresher training sessions. 3.2.3 Elimination of the "No-Man's Land" Many participants were particularly concerned about the apparent "no-man's land" between the terminal's main entrance and the check-in counter. The Agency believes this gap is creating a major obstacle to the travel of persons with disabilities and that practical solutions exist to overcome this problem. Recommendation 7 The Agency recommends that airport and air carrier personnel work together to close the gap between the terminal's main entrance and the carrier's ticket counter. In their search for solutions, airport operators and carriers should consider the numerous suggestions put forward by consumers ranging from increased personal help to more sophisticated devices. It was suggested that personal help could take the form of airport staff monitoring the main entrances more closely, or engaging volunteers acting as good-will ambassadors. Another suggestion was to allow short-term parking for drivers escorting persons with disabilities to check-in counters. The installation of help desks or the provision of automated information devices at main entrances or in consistent places at all terminals should also be considered. These devices could take many forms such as direct-line phones, or interactive computer terminals. It was also indicated that help desks should not be special services desks exclusively for persons with disabilities, but rather designated as greeting areas for all passengers who might require extra attention. 3.2.4 New Developments/Technological Changes The pace of innovation within the travel industry means that new systems and procedures are constantly being introduced. Recommendation 8 When developing new technologies or facilities or upgrading existing technologies or facilities, the Agency recommends that the needs of persons with disabilities be addressed to facilitate accessibility. Research studies have shown that while it might be relatively expensive to retrofit or modify systems or installations to make them accessible, it is considerably less expensive and less problematic to build in accessibility features at the conception stage of new systems or installations. In making this recommendation, the Agency is particularly focussing on technological developments on the horizon, such as electronic ticketing and electronic material on the Internet. Electronic ticketing will most likely require the traveller to interact with a machine, similar to an automatic bank teller, which produces travel documents. The Agency believes that the industry should, at this stage of its developmental work, incorporate the needs of travellers with disabilities in the prototypes. 3.2.5 Involvement of Persons with Disabilities During the consultations, several participants raised the issue of the need to involve persons with disabilities when designing or developing services dedicated for them. Suggestions to this end were put forward such as, barrier-free committees at airports, involvement of persons with disabilities in training programs, direct surveys for those who do not have a voice as part of an organized group, etc. The Agency recognizes that some of these suggestions have already been implemented by some airports and air carriers, and would like to reinforce the importance of this partnership between the industry and the community. Recommendation 9 The Agency recommends that air carriers and airport operators formally involve persons with disabilities when developing services or finding solutions to better serve persons with disabilities. 3.3 Recommendations to Airport Operators 3.3.1 Physical Accessibility of Airports Several of the suggestions and recommendations gathered during the consumer consultations to close the communication gap dealt with the physical accessibility of airports (e.g. signage, flight information monitors, identification of air carriers' counters, rope cueing, assistive listening devices, and sound baffles at ticket counters). Other issues raised dealt more with services that could be implemented by airport operators to improve access to information and with orientation within the terminals. While both types of findings have been reported for the guidance of service providers, the Agency will, at this time, limit its recommendations to services that could be presently implemented by airport operators to improve accessibility. The recommendations and suggestions made during the consultations, to modify some physical accessibility features of airports to improve the communication of information to travellers with sensory disabilities, are reported in Chapter 2. They included: improving and simplifying the signage; colour coding the directional signage; lowering the flight information monitors as well as increasing the print size and improving the contrast; improving the public announcement systems; installing phone systems to have access to up-to-date information; installing an auditory wayfinding system, as well as installing visual alarms. Following the release of the Interim Report for comment, concerns were voiced that some airports may be presently in the process of renovating their facilities and may proceed with the installation of flight information monitors which are difficult to access. Recommendation 10 The Agency recommends that no new flight information monitors be installed which are above eye-level and which do not have significant colour contrast, large print or use audio-echo technology. While the Agency is convinced that other changes and improvements in this area would contribute to closing the communication gap, the Agency will not make any other recommendations at this time on these issues related to the physical accessibility features of airports. While these are important issues, they address only part of the much larger issue of terminal accessibility. Therefore, they will be considered when the Agency undertakes to study the question of full terminal accessibility. The Agency believes that it is preferable to develop and implement a comprehensive and global policy on terminal accessibility. 3.3.2 Services that Could Be Implemented Now General Announcements and Individual Communications During the course of the interviews the need to improve communications in the terminal was a recurrent theme. The anxiety created by not being able to easily communicate with personnel at counters, not hearing the announcements or not understanding where a service is located were mentioned on several occasions. Suggestions to improve the situation were also put forward. While solutions requiring physical changes to airports need to be considered in the overall context of the physical accessibility of airports, the Agency was informed of practical low-tech, low-cost solutions that could easily be implemented now to eliminate some of the communication obstacles. Recommendation 11 The Agency recommends that every point of contact between the terminal employees and the public be equipped with dedicated pen and paper to ensure that communication is facilitated with travellers who are deaf or hard of hearing. Recommendation 12 The Agency recommends that public address announcements be improved by speaking more clearly, more slowly and repeating the message. Recommendation 13 The Agency recommends that any announcement about airport services also include a description of the service location. Terminal Information Many participants believe that navigating through terminals is the most stressful part of a trip. Not knowing where the different services are located and which services are available, were situations which were often described as difficult. It was also mentioned that having access to advance information about an airport could contribute significantly to increasing the level of confidence and independence of travellers with disabilities. Recommendation 14 The Agency recommends that airport operators provide advance information about terminal layouts and that this information be available in alternative formats. This information could take many forms. A brochure or a pamphlet could be produced to describe the main features of the airport, including the location of the different services available, and a brief summary describing the symbols used in the airport. In addition, a schematic map could be produced. TTYs and Volume-Controlled Phones The question of availability of TTYs and volume-controlled phones at airports was frequently raised. Most of the time, airport personnel do not appear to know where the TTY is located, directional signage is very poor or nonexistent, and TTY service is often not available 24-hours a day. The Agency believes that having access to TTYs and volume-controlled phones is essential for travellers with disabilities. Recommendation 15 The Agency recommends that airport operators ensure that an adequate number of public TTYs and volume-controlled phones are available, in both the public area and the arrival and departure area, 24-hours a day. Recommendation 16 The Agency recommends that personnel be fully aware of the location of such TTYs and volume-controlled phones, and that these phones be properly indicated by appropriate signage. 3.4 Recommendations to Air Carriers 3.4.1 Services that Could Be Implemented Now Self-Identification The issue of self-identification (of a disability) was a delicate topic which surfaced many times during the course of the interviews. No consensus could be found on this issue. The Agency believes that the benefits to the traveller of clearly expressing what is required are not yet known to many travellers with disabilities. Recommendation 17 The Agency recommends that air carriers actively promote understanding among travellers with disabilities of what services are available for persons with disabilities, as well as the benefits of self-identification. Itineraries in Alternative Formats The need for a plain language travel itinerary, available upon request in alternative formats, was mentioned repeatedly by participants throughout the consultations. The Agency believes that the travel itinerary is a key document and that the number of comments received with respect to this document warrants that air carriers pay particular attention to it. As many participants have indicated, they would do without other travel documents in alternative formats if they could easily access this one sheet with basic information clearly presented. Recommendation 18 The Agency recommends that air carriers start providing itineraries or individual travel information in plain language with minimal use of codes and acronyms. Page 41 Recommendation 19 The Agency recommends that itineraries and individual travel information be made available in the appropriate alternative formats. Recognizing that the majority of bookings are done by travel agents and tour operators, air carriers are also encouraged to work in concert with their agents to facilitate this change. General Announcements and Individual Communications Air carriers also need to increase the accessibility of announcements and communication with passengers in airports. Recommendation 20 The Agency recommends that air carriers ensure that dedicated pen and paper are available at every check-in counter to facilitate communication with travellers who are deaf or hard of hearing; that they ensure public address announcements are clearly enunciated, made more slowly and repeated; and that they include a description of the service location. Recommendation 21 The Agency recommends that, if passengers request it, air carriers use well-contrasted markers to write down the boarding gate number in large characters for those who have difficulties reading the information on boarding passes or else use a tactile mark, to facilitate their identification. Security The recommendation below did not appear in the Interim Report. Problems as a result of miscommunication in the security area were raised again in the comments received following distribution of the Interim Report. Similar concerns were raised at the ATAC-sponsored workshop in February 1997. Persons who are deaf or hard of hearing related that they cannot hear if the alarm beeps when they go through security, and are often unsure of whether or not they can proceed to their gate. Recommendation 22 The Agency recommends that security personnel use both audio and visual means to indicate whether or not travellers can proceed to their boarding area after passing through the magnetometer. Reserved Seating at Boarding Gates The Agency was informed that additional stress was generated for many passengers with disabilities by not being able to hear or see the boarding announcements or changes to flight schedules. Many travellers with disabilities are still not confident that airline personnel will remember to advise them personally. Recommendation 23 The Agency recommends that air carriers designate reserved seating at boarding gates for passengers with disabilities. This would also assist service personnel in identifying passengers requiring assistance. 3.4.2 Aircraft Physical Accessibility Features Comments were made during the consultations with respect to the need to improve communication of information on board aircraft. Two of these issues, namely the need to ensure that travel-related announcements are accessible to all travellers as well as the use of tactile seat markers relate to the physical accessibility of aircraft. A proposed Code of Practice concerning Aircraft Accessibility for Persons with Disabilities was issued by the Agency in March 1996 for public comments. Several comments similar to those gathered during this investigation were presented to the Agency in response to the proposed Code. Recognizing all of these comments, the Agency decided to modify the Code to include the following two new provisions: * when a carrier makes announcements to passengers, such as announcements concerning stops, delays, schedule changes, connections, on-board services and claiming of baggage, the carrier should have the means within the aircraft of visually and verbally providing these announcements to persons with disabilities; and * tactile markers to indicate row numbers should be placed on overhead bins or on passenger aisle seats. The final Code was issued with these new provisions in November 1996. These provisions will become effective on January 1st, 1999. The industry has indicated its commitment to abide by this Code of Practice. The Agency will also conduct periodic surveys to monitor the implementation of the Code. 3.4.3 Orientation Within the Aircraft The Agency notes that Transport Canada's safety regulations require air carriers to orient passengers to the safety features of the aircraft. The need to have a better description of the aircraft features -- such as the location of the washroom and orientation inside the washroom, as well as a description of the control mechanisms located at the passenger seat -- was raised several times during the consultations and again in the responses to the Interim Report. In addition to the current braille safety card, the need for a written document in alternative formats describing the safety and operational features of the aircraft was also mentioned several times during the course of the interviews. The Agency is of the view that solutions to this matter will require the cooperation of Transport Canada, the industry and the Agency, given the complexity of the issues involved. Recommendation 24 The Agency recommends that upon request, air crews verbally give information about the operational features of the aircraft to passengers with disabilities, supplemented with written information where possible. As noted previously, a dialogue concerning safety issues is currently underway between persons who are deaf-blind and the industry. The results of these discussions will provide a good foundation for commencing a review of service issues of concern to travellers who are deaf-blind. Recommendation 25 The Agency recommends that the Air Transport Association of Canada sponsor an industry focus group to discuss customer service issues of concern to travellers who are deaf-blind. The Agency would welcome an opportunity to participate in these discussions. Communication is a key element of air travel: whether it be to get information about travel options, reserve and confirm a flight, find out about where to board a flight or ask for assistance on board. The ability to communicate is essential if people are to give and receive information. Many people who are unable to hear or understand the spoken word or see the written word, have difficulties accessing air travel. It is recognized that any solution suggested may be improved or made obsolete by new technology. The communication of information is a multifaceted issue. This is why the Agency, after having considered all the information gathered during this investigation, decided to provide general principles rather than precise requirements. The Agency also believes that this approach will allow the industry to develop and implement innovative solutions in accordance with the particularities of individual operations. What is required in a small airport may be quite different than what is required in a large international terminal. Moreover, people have many different needs, so the primary goal is to move towards an air travel environment where information is exchanged widely in as many different formats as needed. Over time, the demand for information in different formats will increase. It was noted that many persons with disabilities do not ask for information in a format which they can better use because they have come to expect that it is not available. Growth in demand for alternative formats will increase as the population ages Industry is urged to seriously consider the Agency's recommendations. Some respondents to the Interim Report stated that they would prefer to see regulations put in place in lieu of voluntary measures. As well, concerns were raised that sufficient mechanisms are not in place to allow the Agency to address inadequate voluntary implementation of these recommendations. The Agency believes that it has the legislative authority to address these concerns should they arise. However, the Agency remains confident that the industry is demonstrating a better understanding of the needs of this growing segment of their customer base. Discussions with the industry during this investigation have also shown that they are ready to take positive steps to improve the communication of information to persons with a sensory or cognitive disability. Working Groups The positive response to the Interim Report confirmed the Agency's belief that the communication of information to persons with sensory and cognitive disabilities is an important issue. As one of the mechanisms to facilitate implementation of these recommendations, the Agency has decided to form working groups to tackle specific issues. These working groups will focus on high priority service needs of persons with disabilities as identified in this report. The Agency has decided to form working groups to address four principal issues. Working Group 1 - Information Guide The objective of this group is to develop an information guide which will provide specific facts to assist persons with disabilities to become better informed consumers when they are travelling by air. A draft version of the document will be circulated for comments to members of the Agency's Accessibility Advisory Committee and to members of the Working Group. Working Group 2 - Generic Alternative Format Policy The objective of this group is to develop a Generic Alternative Format Policy which individual carriers and airports could adopt or use as a basis for developing their own policy. Working Group 3 - Assistive Communication Device Policy The objective of this working group is to discuss the possibility of establishing a transportation-related policy for assistive communication devices and to advise on a future course of action with respect to the use of assistive communication devices when travelling by air. Working Group 4 - New Technologies The objective of this working group is to recommend guidelines and raise awareness of access needs to public-use machines within the transportation network. For example, installing an electronic ticketing machine which has large buttons does not render the machine accessible if the information screen is not properly colour contrasted, in large print or if audio-echo technology is not used. Each working group will be composed of representatives from: consumer groups of and for persons with disabilities, the airline industry, an airport authority or airport group, and when necessary a representative from a manufacturer and/or representatives from other government departments. Initiatives will be undertaken to involve other segments of the travel industry. The Agency intends to contact the Association of Canadian Travel Agents (ACTA), the Canadian Institute of Travel Counsellors (CITC), and the Canadian Association of Tour Operators (CATO) to participate in these working groups. The Agency will also be relying on the active participation of its Accessibility Advisory Committee members and respondents to this consultation to facilitate committee work. The Agency anticipates that the working groups will be formed by December 1997 and that each group will develop a strategic plan. The strategic plans should give realistic time frames to achieve improvements in communication of information to persons with disabilities. The Agency knows that more work is being done on research and development issues associated with In-Cabin Information Technologies and Electronic and Audible Signage Standards. This work is being coordinated by Transport Canada's Transportation Development Centre (TDC) with Agency staff participation. The results of TDC's research will contribute to the development of the Agency's policy in this area. Monitoring The Agency has decided, in addition to the establishment of the working groups, to actively monitor progress to determine whether regulations or a detailed code of practice should be developed to implement its recommendations. The Agency intends to contact the larger air carriers and airports annually for two years and have them complete a questionnaire based on the recommendations outlined in this report. The Agency's powers to act upon complaints filed by consumers will also continue to offer a mechanism to review individual situations to determine whether or not an undue obstacle exists with respect to communication of information to passengers with disabilities. The Agency is confident that this plan of action which combines the monitoring of improvements to the communication of information to persons with sensory or cognitive disabilities, with the establishment of working groups to stimulate discussions between affected parties, along with continued goodwill which has been demonstrated by participants to date, will provide the basis for significant improvements in the transportation network for persons with cognitive or sensory disabilities.
APPENDIX A: Original Correspondence Letter from the Canadian Council of the Blind
National Office January 24, 1995 Dear Mrs. MacDonald: The Canadian Council of the Blind (CCB) is the nation's only national consumer organization representing the needs and concerns of individuals who are blind and vision impaired. Recently, the Council presented a workshop on accessible transportation before its membership. although it was acknowledged that tremendous progress had been accomplished in recent years, some issues were voiced which warrant the attention of the National Transportation Agency. A major concern is one that deals with the limited and misleading information on accessibility provided by carriers and travel agents alike - an inconsistent understanding by all parties of what constitutes "accessible". Indeed, the lack of information provided in alternate formats - braille, large print, audio cassette and/or computer disk - represents a serious hindrance as well as an undue barrier to our travelling membership. Furthermore, our members feel that an area that urgently needs to be addressed is that of "standardization of services". We are especially concerned as a good many Canadian airports are being privatized and the authority to influence and bring about positive change may be lost. It is our view that technology to provide information to passengers who are blind and vision impaired is available and can now be purchased at minimal costs, but is not used in this application. We therefore call upon the Agency to inform us of the different alternate format policies adhered to by Transport Canada Airports, Air Canada, Canadian International and their airline partners. In accordance to the Transportation Act, 1987, we would request a response to these concerns. Your reply will assist members of the CCB and government in meeting its mandate of integration and inclusion into every aspect of Canadian life. Sincerely, John Bullen National President
Letter to the Industry from the National Transportation Agency of Canada (Canadian Transportation Agency since 1996) and List of Addressees. Please note that the National Transportation Act, 1987 referred to in the letter has been replaced in 1996 by the Canadian Transportation Act. Please refer to subsection 170. (1) and paragraph 170. (1) (d) of the new Act. National Transportation Agency of Canada To Attached List: The National Transportation Agency of Canada is in receipt of a request from the Canadian Council of the Blind (CCB), a national organization representing persons who are blind and visually impaired, calling upon the Agency to inform them of the different alternate format policies adhered to by Canadian airports, Canadian air carriers and their airline partners. In its letter (copy attached), the CCB comments on the limited and misleading information on accessibility provided by carriers and travel agents, the lack of information provided in alternate formats, the standardization of services and the availability of technology at minimal cost. The Agency has initiated an investigation into the issues addressed in that letter. The Agency has included in its investigation the communication of information to persons with hearing and cognitive disabilities. Subsection 63.3 (1) of the National Transportation Act, 1987 (NTA, 1987), provides that the Agency may inquire into a matter for which regulations may be made under subsection 63.1(1) in order to determine whether there is an undue obstacle to the mobility of persons with disabilities. Subsection 63.1(1) provides that regulations for the purposes of eliminating undue obstacles may be made concerning, among other things, the communication of information to persons with disabilities. In order to assist the Agency in its investigation would you please provide the following information: A description of all policies that your organization has in place or under review that deal with the publication of alternate formats of information. Copies of any publications which are produced in alternate formats. A description of any communication or marketing strategies of your organization pertaining to persons with disabilities. A description of any new communication technology used by your organization which would benefit persons with sensory disabilities and any available information concerning costs of such technology. A copy of your personnel training program for the assistance of persons with disabilities established under Personnel Training for the Assistance of Persons with Disabilities Regulations to determine whether the program addresses the needs of persons with sensory and cognitive disabilities. Your reply is requested within 45 days from receipt of this letter. Should you have any questions, please do not hesitate to contact Hélène Nadeau, Assistant Director, Accessible Transportation Directorate at (819) 997-0806. The Agency will place on its public record any document filed with it in respect of any proceeding unless the person filing the document makes a claim for confidentiality in accordance with section 11(1) of the Agency's General Rules. Sincerely, Marie-Paule Scott, Q.C. Mr. John Bullen C. Rogers
List of Addressees 1. Claude S. Constantineau Air Alliance Inc. Sainte-Foy QC 2. W.F.T. Groth AirBC Limited Richmond BC 3. Linda Legault Air Canada Saint-Laurent QC 4. Lorrie Linn Air Nova Inc. Enfield NS 5. Scott Tapson Air Ontario Inc. London ON 6. Pierre Roy Canadian International Airlines Ltd. Calgary AB 7. Pierre Roy Canadian Regional Airlines Ltd. Calgary AB 8. Cynthia Joyce Northwest Territorial Airways Ltd. Yellowknife NT 9. Janet Shrieves* Halifax International Airport Elmsdale NS 10. Harold B. Hefferton Transport Canada St. John's NF 11. W. J. Eagan Moncton Airport Moncton NB 12. Cora Pictou Saint John Airport Saint John NB 13. Michael D. Campbell Charlottetown Airport Charlottetown PE 14. Richard Koroscil* Vancouver International Airport Richmond BC 15. G. Hamburg Prince George Airport Prince George BC 16. Dennis M. Geddes Nanaimo Airport Cassidy BC 17. Laurie L. Brown* Victoria International Airport Sidney BC 18. Larry Filipek Canadian Airlines International Ltd. Toronto AMF ON 19. Lloyd A. McCoomb Pearson International Airport Toronto AMF ON 20. Dwayne Butta* Calgary International Airport Calgary AB Page 56 21. Raymond J. Off Edmonton International Airport Edmonton AB 22. Bob Milburn Edmonton Municipal Airport Edmonton AB 23. Wayne D. Harley Transport Canada Regina Airport Regina SK 24. W. A. Restall Transport Canada John G. Diefenbaker Airport Saskatoon SK 25. L. Bishop Transport Canada Winnipeg International Airport Winnipeg MB 26. Donald D. Hector Transport Canada Grande Prairie AB 27. Marcel Martineau Transport Canada Aéroport de Rouyn-Noranda Rouyn-Noranda QC 28. Darryl Laurent Transport Canada Terrace Airport Terrace BC 29. Jim Logan Transport Canada Whitehorse Air Terminal Building Whitehorse YT 30. Steve J. Baker Transport Canada London Airport London ON 31. Harley Nikkel Transport Canada Timmins Airport Timmins ON 32. Brian Hawick Transport Canada Kamloops Airport Kamloops BC 33. Robert J. Barradell Transport Canada Yellowknife NT 34. Patrick Kenny Transport Canada Deer Lake Airport Deer Lake NF 35. Yvon Duquette Transports Canada Aéroport International Jean-Lesage Sainte-Foy QC 36. Paul Conrad Transport Canada Thunder Bay Airport Thunder Bay ON Page 57 37. H. J. Rossiter Transport Canada Gander International Airport Gander NF 38. Jim Pintarak Transport Canada Sudbury Airport Garson ON 39. A. N. Graham Transport Canada Windsor Airport Windsor ON 40. H. McKiernan Ottawa MacDonald-Cartier International Airport Gloucester ON 41. Gilles St. Pierre* Aéroport International de Montréal Dorval QC 42. Yves Provencher Aéroport de Mirabel Mirabel QC 43. John Bell Sault Ste Marie Airport Sault Ste Marie ON 44. F. Whelan Transport Canada Sydney Airport Sydney NS 45. C. Kaldestad Cranbrook Airport Cranbrook BC 46. Ernest C. Blake Fredericton Airport Fredericton NB 47. M. Lafrance Aéroport de Sept-Îles Sept-Îles QC 48. Alex Home Toronto City Centre Airport Toronto ON 49. James W. Sanders* Canadian National Institute for the Blind Ottawa ON 50. Howard Goldberg* Air Transport Association of Canada Ottawa ON 51. Jean-Marc Labelle Conseil aéroportuaire canadien Montréal QC 52. C. Rogers Transport Canada Ottawa ON 53. Janyce Clark Transport Canada Ottawa ON 54. Victor Barbeau Transport Canada Ottawa ON Page 58 55. Hartley Bressler North York ON 56. Nick Tasker Task Micro Electronics Dollard-des-Ormeaux QC 57. George Petsikas* Air Transat Mirabel QC * indicates that this person or group provided comments to the Interim Report
List of Interviewees Consumers 1. Dr. Nora Browne/Charles Laslo Canadian Hard of Hearing Association Newfoundland Chapter St. John's NF 2. Myles Murphy Newfoundland Coordinating Council on Deafness St. John's NF 3. George Gaudet Learning Disability Association of Canada Stratford PEI 4. Francis Drake Sir Frederick Fraser School for the Blind Halifax NS 5. Wayne Huskins Revenue Canada Support Services for the Sensory Impaired Halifax NS 6. John Bullen Canadian Council of the Blind Bathurst NB 7. Pierre Lainey Handidactis* Montréal QC 8. Jacinthe Daviau/Pierre Ferland Institut Nazareth et Louis-Braille Longueuil QC 9. John Hall Montreal Association for the Blind Montreal QC 10. Nathalie Burlone Association du Québec pour l'intégration sociale Montréal QC 11. Yvon Mantha* Centre québécois de la déficience auditive Montréal QC 12. Yvon Provencher R.A.A.Q Montréal QC 13. Nancy Lacoursière Association de Montréal pour la déficience intellectuelle Montréal QC 14. Daniel Guertin* Office des personnes handicapées du Québec (OPHQ) Drummondville QC Page 61 15. Pauline Lazure Association du Québec pour enfants avec problèmes auditifs Montréal QC 16. Claire Charest Association québécoise des personnes aphasiques Montréal QC 17. Suzanne Pinard Centre québécois de communication non-orale Montréal QC 18. Peter Park/Vicki Clarke People First of Canada Toronto ON 19. Connie Laurin-Bowie Gabrielle Kresic Canadian Association for Community Living Downsview ON 20. Cathy O'Connor/John Ford Canadian Hearing Society Toronto ON 21. Kerry Wadman* Canadian National Society of the Deaf-Blind North York ON 22. Bill Fitzgibbons Canadian Deafened Persons Association Ottawa ON 23. Doug Shirton Canadian Deaf Sports Association Gloucester ON 24. Ross Bales Canadian Blind Sports Association Gloucester ON 25. James Sanders* Canadian National Institute for the Blind Ottawa ON 26. Pauline Mantha* Learning Disability Association of Canada Ottawa ON 27. Yvonne Peters Council of Canadians with Disabilities Winnipeg MB 28. Mel Graham Council of Canadians with Disabilities Winnipeg MB 29. David Martin Manitoba League of Persons with Disabilities Winnipeg MB 30. Brenda Cook*/David Greenfield Visually Impaired Persons Action Council (VIPAC) Saskatoon SK Page 62 31. Bev Boehm Saskatchewan Voice of the Handicapped Saskatoon SK 32. Judy Nadon-Yuen Canadian Association of the Deaf* Saskatoon SK 33. Jean Fahey Saskatoon Association of Community Living Saskatoon SK 34. Diane Earl/Fran Vargo Premier's Council on the Status of Persons with Disabilities Edmonton AB 35. Colin Cantlie* Canadian Hard of Hearing Association Calgary AB 36. Wendy Eadie Hope Foundation of Alberta Edmonton AB 37. Bruce Gilmour U.B.C. Disabilities Resource Centre Vancouver BC 38. Byron Smith Jericho Hill School for the Deaf (Residential Program) Vancouver BC 39. Dr. Paul Gabias* National Federation of the Blind: Advocates for Equality Kelowna BC 40. 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