The Justice and Equity Centre’s work includes a focus on equal access to air travel for people with disability.
In our submission to the Senate inquiry into the Aviation Consumer Protection Bill Package, we provided advice on where the Bill should be strengthened to make Australian aviation services more accessible and ensure protections are available to all consumers across the entire air travel journey.
Our submission makes 33 targeted and technical recommendations, including:
- to include security screening within the scope of the Consumer Protection Framework: security screening is widely recognised as one of the most challenging points in a typical air travel journey and consumers (and particularly people with disability) should have recourse when there is a failure to meet standards;
- to narrow use of the power to exempt small airports from the Framework: while we recognise the rationale for exempting small airports with limited financial and operational capacity, we also note the significant impacts of failure in regional services on people with disability, and recommend an alternative to blanket exemptions, such as a tiered model;
- to explicitly refer to disability aids, as distinct from general baggage: people with disability face significant impacts from the loss of a disability aid, which make include loss of independence and/or risks to health and safety, so the Framework should reinforce the heightened importance of their proper handling;
- for the Bill to guarantee representation of people with disability on the Board of the Aviation Consumer Ombuds Scheme;
- for the Ombuds Scheme to apply a standard of ‘fair and reasonable in the circumstances’ to its decision-making: this is in line with the decision-making approach used in other comparable ombuds schemes, while the current proposal gives a much higher and narrower threshold;
- to embed a clear focus on systemic improvements: including by giving powers to the regulator to require action by airlines and airports to address policies, practices and service models that give rise to systemic consumer issues; and
- to require periodic statutory review: to oversee the powers the Bill will give Government to implement the substantive rights of consumers and obligations of the aviation industry.
