Consultation outcome

Summary of responses to the Aviation 2050 consultation, chapter 5: Enhance the Passenger Experience

Updated 17 July 2022

Introduction

Chapter 5 of the Aviation 2050 consultation, ‘enhance the passenger experience’, sets out proposals to provide consumers with the confidence to fly, and ensure industry is responsive to consumer need. Aviation 2050 proposed the development of a new Passenger Charter to promote good practice, create a shared understanding of levels of service, and communicate roles and accountability to drive service improvements.  The charter was seen as an opportunity to provide an easy to find, one-stop-shop for information on:

• accessibility standards for disabled passengers and passengers with reduced mobility (PRMs)
• service standards for consumers with hidden disabilities and/or allergies
• expectations around the management of disruptive passengers
• service levels for processing people at the border

• standards for notification of delays, complaint handling and compensation claims

• expectations and obligations on compensation and repatriation for when an airline becomes insolvent
• standards for booking information and clear terms and conditions

In addition, the proposal in 2050 was for the charter to be supported by:

• a performance framework with clear key performance indicators (KPIs) to allow monitoring, reporting and ongoing improvement
• expanded enforcement powers for the CAA with respect to legal obligations for passengers with reduced mobility and compensation claims
• new standards for open data, data sharing and data protection
• improved border performance standards through changes to business and delivery models and funding arrangements
• enhanced passenger representation

Responses to this chapter included a variety of individuals, industry stakeholders (including airlines and airports) consumer facing groups (such as groups representing disabled people), environmental/community groups, trade associations, parliamentary groups and MPs.

Passenger Charter

The majority of respondents were in favour of developing a new Passenger Charter addressing the areas outlined in the consultation. A recurring theme related to the need for clarity on the aim of the charter, with respondents wanting the charter to be clear on what it is trying to achieve, as well as how it would be implemented.

There was some suggestion, from a range of respondents including airlines, trade associations and some individuals, that the charter should not be used to set service standards outside of the existing air passenger rights Regulations. In addition, that it should be non-binding, and should not increase the burden on airlines and therefore result in higher prices for consumers.  Conversely, some felt the charter should go further, for example expanding it to include journeys to and from the airport or incorporating the European Civil Aviation Council’s standards on accessibility (ECAC Doc 30). Some of the consumer facing groups also suggested that legal rights should be separated from best practice to avoid confusion for consumers, and for standards around flight delays and cancellations to be improved.

Some responses expressed the need for further consultation and engagement with working groups and industry when developing a Charter to ensure it addresses areas where there is a clear market need or evidence of consumer detriment, and to ensure agreement on the direction of the charter. There was some concern that the charter would just be restating existing measures.

Accessibility

Respondents typically regarded passengers with reduced mobility and accessibility needs as high priority. Acknowledgement was made of the current system and precautions being implemented to improve the experience for those passengers, although it was also accepted that more needed to be done and that flying should be accessible and comfortable for all. For example, there was suggestion of improved data collection, and outcome-focused frameworks for industry standards, harmonisation of the definition of PRM charges at airports, and improved infrastructure.

Airlines and airports indicated commitment to improving this aspect of consumer experience and suggested they were open to working with others on proposals in this area.

Some individuals urged for consideration of helping those with reduced mobility that are otherwise independent, such as those with upper limb disabilities.

Regarding passengers with hidden disabilities, there was general consensus that there was more to be done. It was identified that there were difficulties identifying and supporting passengers with hidden disabilities, and varying opinions on the best ways to approach the issue. On the whole, respondents were content with implementing a system and wanted to improve the flying experience for these passengers. There were a few specific issues flagged in this area, including:

The need for one holistically approved and used system, rather than different places using different systems and causing confusion for passengers and staff.

Secondly, the idea of wearing a lanyard or anything that may single someone out is not necessarily suitable, as it could make individuals feel uncomfortable and could potentially be discriminatory.

Thirdly, there needed to be clear signposting to help those with hidden disabilities when travelling by air, rather than putting the onus on the individual to seek out this information.

Allergies

For those who touched on allergies it was generally agreed that the information was not accessible and/or not clear enough. A central point for all information on allergies that was easy to navigate, and provided clear instructions and guidance was suggested as a sensible resolution to this issue. There was also some support for restricting the sale of nuts on flights, where an individual with a nut allergy is onboard.

Disruptive passengers

Many of the responses regarding disruptive passengers were in favour of a zero-tolerance approach, with clear behavioural guidance available publicly. Options around alcohol included alcohol limits being put in place, alcohol licencing, removal of miniatures from airport duty free shops. There was also focus on gathering data and evidence in this area, including a suggestion of government undertaking a study to understand the nature of disruptive passengers. There were some concerns raised around the fairness of limiting alcohol, and how it could be implemented and enforced. Although the numbers of disruptive passenger cases was low at the time according to the responses, there was some suggestion of potential increases in cases. In addition, there was a lot of support to implement a scheme or policy to further reduce cases, such as campaigns to raise awareness around intoxication.

Border Experience

Border experience was a priority for airports specifically, as well as respondents in general, with a clear view that there needed to be improvements. One popular suggestion was around implementing new technology and further roll-out of e-gates in terms of numbers and broader eligibility. Some other consumer facing groups highlighted that new technology may not be appropriate for everyone, for example those with dementia, or other disabilities.

There was some focus on accessibility, for example, providing clear information to passengers so that they could make reasoned decisions on whether they required assistance at the airport.

Some industry groups did not support the idea of costs relating to improvements in border security to be covered by passengers, with some suggesting government should take responsibility for these costs. There were also some suggestions around improving visa processes, and business aviation users having reduced Border Force intervention.

Complaints and compensation

Most respondents to the complaints and compensation section acknowledged a need for improvement. Highlighting the need for clarity, including a clearer pathway to complain and with routes available that ensure appropriate compensation is available. There was some concern about overregulation that could limit competition, and a call for a categoric list of ‘extraordinary circumstances’ to make it clearer for industry and consumers when compensation would be due.

Booking information

Questions around booking information received many responses, with a focus on the need for clearer information being made available for consumers when purchasing a trip, as well as clarity around terms and conditions. Suggestions included that information should always be easily accessible and available for all without ‘hidden’ elements.

Approach to new Aviation Charter

The Aviation Passenger Charter (published 17 July 2022) was developed as single point of information that provides clear guidance to passengers on their rights, responsibilities and reasonable expectations when booking flights, and travelling by air. It aims to improve consumer confidence to travel by air and provides guidance on each stage of the passenger journey from booking to if things go wrong.

The Aviation Passenger Charter does not set new standards; however, government will continue to work with industry to consider and implement standards and improvements to ensure consumers are provided a high standard of service.

The Aviation Passenger Charter has been developed alongside the aviation sector, travel industry and disability and consumer groups, ensuring that it provides accurate and helpful information for passengers on their rights and responsibilities, as well as reasonable expectations on the service they should receive from the aviation sector throughout their journey. In addition, the responses to Chapter 5 of the Aviation 2050 consultation, on enhancing the passenger experience, have been taken into account in the development of the Aviation Passenger Charter.

The Aviation Passenger Charter is not intended to be a legally enforceable document, but it does outline the existing legally enforceable rights. It is intended to provide you, as a passenger, a helpful point of information when you are travelling by air. Every effort has been made to ensure the information contained in this Charter is as up to date as possible.

Since the Aviation 2050 Consultation, there have been some developments in areas that were included in the original proposals. These have therefore not been included in the Aviation Passenger Charter.

The Civil Aviation Authority (CAA) has already reviewed and strengthened accessibility performance standards for airports and continues to work with airports to improve their services in this space. The CAA is committed to introducing an airline accessibility framework, and this will be developed outside of the Charter.

A separate consultation on Aviation Consumer Policy Reform, which ran from 31 January to 27 March 2022, sought views on a variety of proposals to reform aviation consumer policy. These issues will be considered further outside of the charter. Proposals included:

• consideration of amending the current limits of compensation for damage caused to wheelchairs and mobility aids
• whether the CAA should have additional enforcement powers for consumer rights breaches
• whether Alternative Dispute Resolution should be mandatory for all airlines operating to, from and within the UK

The Home Office conducted a Call for Evidence on airside licencing and concluded that it would not be appropriate to extend licencing airside at this time.

Government continues to consider how we can continue to protect passengers financially by working closely with the CAA to ensure protection provided through the Air Travel Organisers’ Licensing (ATOL) scheme remains fit for purpose. This includes working with the CAA on ATOL reform and considering how we can introduce civil sanctions powers for the CAA to deal with non-compliance with ATOL regulations. These considerations form part of government’s wider ongoing ATOL policy work and will therefore not form part of the charter.