1. 2018 CRO RECURRENT COURSE

2. Objectives DOT Updates 01 Key Issues As Defined by DOT 02 Case Studies
Course objectives should be written in clear and concise language that is easily understood by the learner.
DOT Updates 01
Key Issues As Defined by DOT 02
Case Studies 03
Quiz 04

3. Statistics 2017 Total Consumer Complaints to DOT 1193 29%
There was a drop in the total number of complaints to DOT in 2017 compared to 2016
2017 Total Consumer Complaints to DOT
1193
29%
Difference from 2016 58
2017 Disability Complaints to DOT
2017 Breakdown
Flight Problems – 2
Oversales - 0
RR/TT – 1
Fares - 0
Refunds – 4
Baggage - 9
passenger Service – 1
Disability – 0
Ads/Animals - 0
Discrimination - 0
Other - 0
1.7% 17
2017 Complaints against BR

4. What’s New at DOT Passengers with Disabilities
NOTHING.

5. Notices of Proposed Rule Making
NPRM – Service Animals
DOT is seeking to reduce the abuse by passengers who bring unusual animals or pets as service animals .
NPRM - IFE
DOT is seeking to make IFE accessible to all passengers with disabilities
NPRM – Accessible Lavs
DOT is trying to determine whether or not narrow-bodied aircraft should be required to have accessible lavs.
An organized layout like this one can help the learner to take in the content more easily and quickly. This is a key design consideration in any course.
Wheelchairs
DOR is aware of the abuse in WCHR usage but are not inclined at this time to make any changes

6. LAWA Observations and Comments

7. LAWA ADA Office
Airports are required to have an ADA Coordinator to ensure airport compliance and to respond to consumer complaints regarding airport facilities
Service animals are the biggest issue at LAX
ACAA more lenient than ADA
Service calls for cleaning after animal “mistakes” up 840% since 2014
Other Complaints
Misunderstandings
Rude employees including airline staff
Lack of knowledge
Lack of training
RR offices unfamiliar with airport operations
“We don’t do that”

8. FAA Responsibilities and Comments

9. FAA – Responsibility for People with Disabilities
Ensure airports meet obligations with regard to non-discrimination for people with disabilities
Airports
Section 504 of the Rehabilitation Act (Sec. 504)
Americans with Disabilities Act (ADA).
Air Carriers Access Act (ACAA)
Disability Access Authorities

10. FAA- Airport Authority Disability Obligations
Role
Requirements
State/Local government entity
Subject to title II (Subtitle A) of the ADA and 49 CFR Part 34
Recipient of Federal Assistance
Subject to Sec. 504 and 49 CFR Part 27
Employer
Subject to Title I of the ADA
Landlord
Ensure tenants meet Title III of the ADA
Transportation Provider
Subject to Title II (Subtitle B) of the ADA and 49 CFR Parts 37 and 38
Air Travel
Subject to ACAA
An organized layout like this one can help the learner to take in the content more easily and quickly. This is a key design consideration in any course.

11. FAA – Sec. 504 Responsibility for People with Disabilities
Must provide an ADA/Sec. 504 Co-Ordinator
Ensure compliance
All leases and contracts must have a nondiscrimination clause
Provide Boarding assistance (28 CFR 27.72)
Provide accessible ground transportation (49 CFR 37)
Maintenance (28 CFR )
Post Nondiscrimination information
Self evaluations of programs, services and facilities every 3 years
Provide an accessible loading and unloading zone every 100’ (ADAAS)
Maintain accessible routes inside terminals and protect people with disabilities from protuberances e.g. drinking fountains
Airports
FAA – Sec. 504 Responsibility for People with Disabilities

12. FAA – Sec. 504 Responsibility for People with Disabilities
Primary Airports > 10,000 enplanements/year
Must provide post security animal relief area in all terminals
Must provide closed captioning of audio-visual displays
Accessible kiosks

13. DOT Observations and Comments

14. DOT – Spirit of the Regulation
DOT requires that airline personnel act in the ”Spirit” of the regulation.
They want airlines to do what is necessary to meet the requests of their passengers

15. DOT L.E.A.D
Tips for providing Excellent Service to passengers with disabilities provided by DOT
<iframe width="560" height="315" src=" frameborder="0" allow="autoplay; encrypted-media" allowfullscreen></iframe>

16. DOT Miscellaneous Thoughts
Top 5 Disability Complaints to DOT
WCHR assistance
General
Damage to assistive devices
Seating
Service Animals
ACAA makes it UNLAWFUL to discriminate against passengers with disabilities
The idea of temporary disability, e.g. broken leg, is unique to 382
DOT Miscellaneous Thoughts

17. DOT – WCHR Assistance Wheelchairs
Airlines and airports need to look for better ways to provide curbside assistance
Passengers must identify themselves as having arrived at the airport and need assistance
Passengers must explicitly waive their need for any additional assistance - Waive the 30 minute rule
Airlines must have a written agreement with US airports they serve that airport will provide ramps and lifts in good operable order
Passengers using assistive devices often afraid to fly because of potential
An organized layout like this one can help the learner to take in the content more easily and quickly. This is a key design consideration in any course.

18. DOT – WCHR Assistance Wheelchairs
DOT is also looking a better ways to define “prompt and timely” for passenger assistance. Currently DOT will look at the totality of the circumstances surrounding the experience. The focus is on departure assistance.
For arrivals they are sticking to “at the door of the aircraft” as the standard to follow.
Airlines and airports must provide an adequate number of WCHR and personnel to handle the load.
To prevent abuse, airline personnel can ask the passenger “How does the WCHR assist with your mobility issues”
While DOT continues to look at delivery and abuse issues, it appears to be a low priority for them
An organized layout like this one can help the learner to take in the content more easily and quickly. This is a key design consideration in any course.

19. DOT – WCHR Assistance Wheelchairs
DOT says that the obligation to provide a WCHR only applies to the passenger requesting the WCHR
If a passenger has a (lap) child and wants the child to share the WCHR with them, DOT agrees that the child can ride on the lap, BUT ONLY IF IT CAN BE DONE SAFELY
While airlines must provide WCHR assistance from the aircraft to the curb, the is NO obligation to wait with the passenger at the curb as long as there is some place for the passenger to sit and wait for their ride
An organized layout like this one can help the learner to take in the content more easily and quickly. This is a key design consideration in any course.

20. DOT - Service Animals
ACAA defines a service animal as one that is individually trained to assist a person with a disability and/or is shown by documentation to be necessary for the emotional or psychiatric well being of the person
Airlines are required to provide MAAS to animal relief areas at US Airports for service animals only although the relief area is open to all animals
Airlines may and should deny boarding to any animal is NOT behaving properly

21. DOT - Service Animals Service Animals
All service animals must behave properly to be accepted on a flight.
DOT is searching for a way to minimize abuse by persons who try to claim that their pet is an emotional support dog. They are looking specifically at the letters supposedl written by a licensed mental health professional
DOT is also recognizing that Emotional Support and Psychiatric Support for TBI and PTSD are not the same. Psychiatric Support dogs are trained, like Service dogs, to alert the handler to symptoms of their condition
An organized layout like this one can help the learner to take in the content more easily and quickly. This is a key design consideration in any course.

22. DOT Service Animals

23. DOT – Spirit of the Regulation
To meet the “spirit” standard, airline personnel must do their best
When a passenger requests non-standard assistance, the correct response is “Let me see how we can help you”, not “we don’t do that”
Customer complaints to DOT are infused with the perception that the agent did not care about the passenger (they were rude)
The perception of not caring and/or rudeness can be interpreted as a violation of 382.

24. Case Studies