IATA SURVEYS NON U.S. MEMBER AIRLINES ON PERSONS WITH REDUCED MOBILITY ISSUES

October 12, 2016

The International Air Transport Association (IATA) has requested immediate input from all Non-U.S. Member Airlines regarding potential new Persons with Reduced Mobility (PRM) regulations that IATA is currently negotiating with the U.S. Department of Transportation (DOT). The following topics are being considered in IATA’s survey:

Service Animals:
To avoid continuing issues of fraud and abuse of current rules allowing dogs and other trained service or support animals on board aircraft for no additional fee, IATA is negotiating the potential introduction of a “decision tree” approach to replace third party documentation requirements in situations where a passenger cannot provide credible assurances that an animal is a service animal. Under this approach, passengers wishing to bring a service or emotional support animal on board would have to submit an on-line questionnaire in order to certify under penalty of perjury that: (1) the passenger is a PRM in need of a service/emotional support animal; and (2) the animal is trained to provide the required service.

IATA is asking all Non-U.S. Member airlines to answer the following questions, the responses to which will be de-identified prior to being provided to DOT:

• Does your carrier prefer that the current regulation remain unchanged and that carriers can require people who are seeking to bring emotional support animals to produce third party medical certification or are you willing to accept the decision tree approach?
• If you prefer that the regulation remain the same, please provide examples of countries you fly to that would require passengers with emotional support animals to have medical certification.
• Are there other factors IATA should consider when arguing against a decision-tree approach?

Accessible In-Flight Entertainment:
IATA, Airlines For America (A4A) and airline representatives have indicated a willingness to make new in-flight entertainment systems fully accessible to PRMs by a specific date to be determined. IATA is opposed to any requirement to retrofit existing IFE’s due to costs and the lack of availability of accessible content to be accessed by IFE’s.  IATA has also opposed requirements to offer PRMs personal entertainment devices until such time that accessible IFE’s are made available.

IATA has asked all Non-U.S. Member airlines to answer the following questions:

• How much of your current fleet is equipped with IFE equipment?  Please provide fleet type, fleet counts, IFE system manufacturer, and IFE system.
• How much of your current IFE equipment can support closed captioning for deaf and hard of hearing passengers?  Please provide fleet type, fleet counts, IFE system manufacturer, and IFE system.
• How much of your current IFE equipment can support audio descriptions for blind passengers?  Please provide fleet type, fleet counts, IFE system manufacturer, and IFE system.
• How much of your current content (e.g. movies, TV shows, games, carrier-created videos, etc.) is accessible (i.e. supports closed captioning and audio descriptions) to blind, deaf, and/or hard of hearing passengers?  Please provide individual percentages for movies, TV shows, games, and carrier-created content.
• How much of your content is produced in the U.S. and in the English language?
• Does your airline have the ability to stream content to a carrier-owned portable electronic device (PED)?  If yes, please provide the total number of planes that have this capability, including fleet type, fleet counts, and streaming supplier information.
• Does your airline have the ability to stream content to a passenger-owned PED?  If yes, please provide the total number of planes that have this capability, including fleet type, fleet counts, and streaming supplier information.
  Does your airline currently offer PEDs (either free or for a fee) for customers to view content?
• How much of your current content is edited specifically for your airline?  Please provide individual percentages for movies and TV shows.

If you are interested in responding, please send us the information and we will ensure it is submitted in an anonymous fashion.

If you have any questions, please contact Evelyn Sahr (esahr@eckertseamans.com, 202-659-6622) or Drew Derco (dderco@eckertseamans.com, 202-659-6665).

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