PWDA Submission to the Aviation Disability Standards consultation
About the consultation
PWDA responded to the consultation on Aviation Disability Standards – Submission to the Department of Infrastructure, Transport, Regional Development, Communications, Sport and the Arts.
As co-chair of the Co-design Committee for the Aviation Disability Standards, PWDA has worked with the Australian Federation of Disability Organisations (AFDO), the Justice and Equity Centre (JEC) and the Department for Infrastructure, Transport, Regional Development, Sport and the Arts to develop standards to improve air travel for people with disability.
What is being proposed
A co-design process with people with disability was used to develop these standards. Other parts of government and the aviation sector have also shared their expertise to help this process work.
This consultation provided information in accessible formats, information sessions were held by the government and co-hosted by PWDA, JEC and AFDO, to help people make their own submission. We appreciate all the effort everyone has made throughout the process to share their thoughts and ideas about how aviation needs to change to improve accessibility and equity.
PWDA position
Together the Steering Committee has worked to keep people with disability and the wider community informed about the co-design process and the consultation, and we have worked to ensure that the ways we send and receive communication remain inclusive and accessible.
Three co-design workshops were held with people with disability from representative organisations and some individuals who brought different lived experiences of disability and air travel from across Australia. These workshops were facilitated by people with a lived experience of disability, accessible communication and translation into Easy Read, Auslan and captioning was used in the preparation and distribution of documents and the facilitation of the workshops.
We have structured our responses around these stages, and we have focussed our submission on finding the best ways for the standards to give effect to:
- what workshop participants called for
- additional things the youth consultation called for
- additional things we heard from people with disability, whether at information sessions, the explainer forum or via our advocacy work
- ensuring the standards able to be implemented and evolved over time based on the feedback of people with disability, to improve the accessibility of aviation.
We have incorporated this together, rather than separating it out into what we heard, or into a discussion section.
Our submission also notes how the Aviation Disability Standards fit into, and are impacted by, the Disability Standards for Accessible Public Transport Amendment 2026 and the Aviation Consumer Ombuds Scheme. In the forum we held many of the things people had questions about, such as reporting, training, accountability against the standards, and the handling of disability aids, will be covered through a combination of these laws, regulations, and the standards once implemented, rather than by the Aviation Disability Transport Standards alone.
PWDA recognises that people with disability have very different lived experiences, and ideas about making air travel more accessible for them. We have encouraged people to have their say directly to help shape the standards, so that they incorporate as many of the lived experiences and ideas people have as possible.
This submission has been endorsed by Children and Young People with Disability Australia a the peak not-for-profit community organisation representing the rights and interests of children and young people with disability (aged 0-25) in Australia.
Recommendations
- Recommendation 1: Apply the regulatory approach to all standards covered by the consultation paper, rather than allowing standards to be optional.
- Recommendation 2: When regulating to achieve the standards, provide timeframes for completion, a requirement to report progress and an accessible explanation for things expected to take more than 2 years to achieve.
- Recommendation 3: Airports should be responsible for the entire journey through the airport up to boarding and disembarking, and airlines should be responsible for booking, information management and the in-flight experience.
Whole of Journey Options
- Recommendation 4: PWDA supports additional training requirements related to safe transfers and the handling of assistance equipment, and we call for all aviation staff and contractors, including security, to receive disability awareness/disability-affirming training appropriate to their role that is co-designed, facilitated and delivered by people with disability.
- Recommendation 5: Every Airline and Airport should have a disability reference group, who must be consulted about significant changes that may impact the experience of people with disability. Airports with smaller numbers of customers must still be represented but may have the option of appointing a shared disability reference group for smaller airports within a state or region.Representation must include First Nations people with disability from communities where airports are located.
- Recommendation 6: PWDA recommends annual reporting by the aviation industry on how they are complying with the disability specific aviation standards, after an initial audit period of 2 years to generate the first report.
- Recommendation 7: PWDA recommends the government create audit and reporting templates to help smaller airlines and airports, rather than exempting them, and to support the creation of auditing jobs for people with disability.
- Recommendation 8: PWDA recommends inviting disability reference groups to help set the priorities for audit and reporting.
Planning and Booking Air Travel
- Recommendation 9: PWDA supports offering passenger assistance profiles.
- Recommendation 10: If airlines limit the number of passengers on a flight who require assistance to board and disembark, the limit for that flight must be published at the time a passenger books. If it is for any reason other than safety, the reasons must also be published.
- Recommendation 11: If a person informs the airline of the assistance services they require:
- at least 48 hours before departure, then the airline/ airport must provide that service and confirm with the person in writing
- less than 48 hours before departure, then airlines may only decline to provide the service for safety and genuine operational reasons, which must be published.
- Recommendation 12: People with disability must not be required by airlines to book over the phone and must be able to access the same fares as other customers regardless of the method of booking.
- Recommendation 13: PWDA supports the proposed regulations for seeking approval to fly with an assistance animal, for check-in, the carriage of the animal in the cabin and for relief accessories.
- Recommendation 14: We call for the completion and integration of the Assistance Animal National Principles when they become available.
- Recommendation 15: PWDA recommends that regulations require airlines:
- ask for the same information about ‘dangerous goods’,
- provide a decision within 48 hours of an application,
- explain any rules a person needs to follow onboard when dangerous goods are carried in an accessible format, or
- if carriage is refused, provide reasons for doing so when making the decision.
- Recommendation 16: PWDA recommends airlines be required to explain clearly which disability aids are allowed to travel in the cabin, their dimensions, the application process, any applicable rules, and that airlines be prevented from charging extra to carry disability aids.
- Recommendation 17: PWDA recommends that airlines be required to work with their disability advisory groups to develop clear explanations, and evolve rules appropriate to carry disability aids safely onboard, and to regulate what happens when disruptions occur.
- Recommendation 18: PWDA supports regulating when a person with disability must travel with a carer, requiring that the person be seated next to their carer and that carer names be allowed to be change free of charge.
- Recommendation 19: PWDA recommends that airlines be required to work with their disability advisory groups to develop clear explanations, and evolve rules for situations where there is disagreement over whether a passenger can travel independently.
- Recommendation 20: PWDA supports regulating when airlines to restrict when they are able to ask for medical certificates to situations where medical assistance or oxygen is deeded during the flight, or the person has to travel in a stretcher or incubator.
- Recommendation 21: PWDA recommends also regulating and explain clearly any other times when aviation staff my ask to see medical certificates, and situations where they must be renewed.
- Recommendation 22: PWDA recommends regulating that clear information about accessibility options be made available before a person books their journey.
- Recommendation 23: PWDA recommends requiring that information about airports and flight bookings be provided in accessible formats.
- Recommendation 24: PWDA recommends that airlines and airports work with their disability advisory groups to ensure that communication is provided in accessible formats.
- Recommendation 25: PWDA recommends regulating airlines and airports to ensure that people with disability receive timely and accessible information about flight disruptions, and what they need to do.
- Recommendation 26: PWDA supports regulating to require airlines to advise people with disability about the reasons their flight has been refused, and of how to book an alternative or access a refund.
- Recommendation 27: PWDA supports regulating the information provided about seating and accessibility features before a person books their travel, and that a person’s request be taken into consideration.
At the Airport
- Recommendation 28: PWDA recommends option 1 that allows the passenger with disability to chose when they transfer from their mobility device to the airport/ airline device, the minimisation to time required to be spent in this device, and the requirement that the person not be left in an airport/airline device unattended for longer than 30 minutes.
- Recommendation 29: PWDA supports regulating self check-in facilities to ensure they are accessible to people with disability.
- Recommendation 30: PWDA supports requiring the installation of assistance points where people with disability can access help and accessible information.
- Recommendation 31: PWDA supports government developing new standardised regulations for airport wayfinding to improve, legibility, and wayfinding accessibility, for people with disability.
- Recommendation 32: PWDA supports requiring that airports/ airlines also be required to communicate any changes about departure gates or travel in the same accessible formats as for flight disruptions.
- Recommendation 33: PWDA supports the development of regulations to improve access for arrivals at and departures from airports.
- Recommendation 34: PWDA supports regulations that Provide clear information and priority for people with disability at security.
- Recommendation 35: PWDA supports regulating to require that people with disability be involved in the co-design of accessible facilities at airports.
- Recommendation 36: PWDA supports regulating to require airports and airlines are required to protect disability aids from damage and loss, and track their movement and report to the owner.
- Recommendation 37: PWDA supports regulating to require that airports and airlines give passengers with disability choice about how they would like to be transferred from their own mobility aid to the airline’s wheelchairs or seats, using approved equipment and staff trained in safe transfer practices.
On the Aircraft
- Recommendation 38: PWDA supports regulating airports and airlines to ensure step-free access is provided consistently to board aircraft, and that people with disability have a choice about when they board and are not climbed over by other passengers.
- Recommendation 39: PWDA supports regulations to store disability aids close to them inside the aircraft.
- Recommendation 40: PWDA supports creating clear regulations to allow the use of disability aids on flights if it is safe to do so, about how to check whether a disability aid can be used on a flight, and that require an explanation when they cannot be used.
- Recommendation 41: PWDA supports creating clear regulations requiring the return of mobility aids as soon as possible after flight arrival.
- Recommendation 42: PWDA supports regulating to require that flight information be made available in accessible formats, and that if wi-fi is available and a person needs to use it for their communication device to function, they should be provided with free access.
- Recommendation 43: PWDA supports creating regulations to make in-flight food and drink more accessible.
- Recommendation 44: PWDA supports creating regulations to improve the accessibility of aircraft toilets within specified timeframes.
- Recommendation 45: PWDA supports requiring that in-flight entertainment be made accessible.
- Recommendation 46: PWDA supports requiring that aircraft have accessible passenger controls.
- Recommendation 47: PWDA supports increasing the number of aircraft seats with moveable armrests across all classes of seating.