EDF Reply to the ERA Consultation on the TSI-PRM 2017

EDF position on passengers rights in multimodal transport

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The European Disability Forum (EDF) is an independent NGO that represents the interests of 80 million Europeans with disabilities. EDF is a unique platform which brings together representative organisations of persons with disabilities from across Europe. EDF is run by persons with disabilities and their families. We are a strong, united voice of persons with disabilities in Europe.

Contents

EDF position on passengers rights in multimodal transport

Introduction

Background

EDF comments on the roadmap

Conclusion

Introduction

Following the publication of the European Commission’s roadmap on “Rights of passengers in multimodal transport” of 22 December 2016, EDF was invited to give feedback on the roadmap in the framework of the Inception Impact Assessment. In the following paper, EDF will explain how this legislative initiative will benefit passengers with disabilities and with reduced mobility and why it will strengthen the existing passengers’ rights legislation in all transport modes across the EU.

Background

As EDF states in its recommendations on Article 20, of the United Nations Convention on the Rights of Persons with Disabilities (UNCRPD) in the Alternative Report to the UN Committee on the Rights of Persons with Disabilities, it is vital that the EU supports “efforts to create a seamless, multi-modal travel chain and ticketing system to facilitate travelling for persons with disabilities”[1]. Similarly, EDF has repeatedly called for the realization of seamless, independent and spontaneous travel for everyone as a long-term goal, amongst others in our position paper on multimodal terminals of 2015[2]. This can of course only be achieved once transport and the related infrastructure are accessible to all persons with disabilities, including women and girls with disabilities, and persons with disabilities requiring more intensive support.

At the moment, there are already six different pieces of passengers rights legislation in force in the EU: Regulation 1371/2006 on rail passengers’ rights and obligations[3], Regulation 1107/2006 concerning the rights of disabled persons and persons with reduced mobility when travelling by air[4], Regulation 261/2004 establishing common rules on compensation and assistance to passengers in the event of denied boarding and of cancellation or long delay of flights[5], Regulation 181/2011 concerning the rights of passengers in bus and coach transport[6], and Regulation 1177/2010 concerning the rights of passengers when travelling by sea and inland waterway[7]. These Regulations are highly valued and have proven to be an effective tool in improving the rights of passengers with disabilities and with reduced mobility. However, since the Regulations have evolved over time and are focusing each on a different mode of transport, certain gaps have been identified in their application and in the enforcement.

EDF comments on the roadmap

EDF strongly supports the proposed roadmap and the publication of legislative proposal to strengthen passengers’ rights in multimodal transport, as it is outlined in Option 4 of the roadmap (p. 5). New rules specific to multimodal journeys will close certain gaps that are currently existing and lead to problems for passengers, particularly passengers with disabilities and reduced mobility, when travelling by different modes of transport.

We need a seamless, accessible, fully integrated travel chain across transport modes:

The important thing to remember is that travel has to be seen as a chain of different transport modes, including walking, cycling, driving, taking the bus, the train, the plane, or any other combination of any other transport modes. Therefore, we cannot see each transport mode in isolation. EDF’s goal is to have a seamless, integrated, multimodal travel chain that is accessible for everyone, including persons with disabilities and reduced mobility.

This also includes the integration of different contracts of transport carriers in a single ticket, that should also lead to a full and comprehensive coverage of the rights as a passenger in case the carriers do not fulfil their obligations towards the passengers. At the same time, it is important that when new products are developed, they are being made accessible from the outset. For example if integrated electronic tickets for a service such as “rail & fly” are available to be bought via a website, this website as well as the booking service should also be made accessible to persons with disabilities. The same is true for all means of electronic ticketing or payment, as well as electronic information on websites and mobile applications as well as real-time information at transport terminals and on board of transport vehicles.

We need coherent, effective, and fully accessible redress and complaint mechanisms:

Currently, the national enforcement bodies (NEBs) are tasked to handle complaints form passengers if they have problems in one of the transport modes. Each NEB is responsible for one of the pieces of legislation and one transport modes. However, in reality the complaints often cover a combination of different modes and it is not always clear to the passenger which NEB to address. Responsibility is unclear which leads to frustration and resignation among passengers. Even worse, there is no standard that guarantees the accessibility of the complaints mechanisms so that many persons with disabilities are denied an effective redress if they have encountered problems during their journey.

We need guaranteed assistance of passengers with disabilities or reduced mobility using multimodal products

Thanks to the above mentioned existing pieces of passengers rights legislation, passengers with disabilities or reduced mobility have the right to assistance at transport terminals. While EDF would like to underline that this is a temporary measure that enables persons with disabilities to use the transport services as long as the transport infrastructure is not fully accessible yet, the goal is to have a fully accessible transport network in the long run that allows for spontaneous and independent travel for everyone.

Nevertheless, the assistance service that is currently provided is very useful and vital for many passengers to use the existing transport services. It also inspires confidence and facilitates travel for everyone. Currently these assistance services are, again, organised by transport mode and strictly separated by each Regulation. This should be changed to provide for a more coherent provision of the assistance service. For example, when taking a train to the airport, the assistance services of the airport and the rail transport operator should work closely together to provide a seamless service and avoid passengers being “stranded” in between the two services. This is already working in practice in some places but it would benefit a smoother operation if it was regulated by the EU.

Conclusion

EDF strongly supports the publication of a legislative proposal to define new rules covering multimodal journeys and guaranteeing passengers rights for the entire transport chain. It will be beneficial for all passengers and in particular for passengers with disabilities or reduced mobility.

EDF Reply to the ERA Consultation on the TSI-PRM 2017

EDF position on passengers rights in multimodal transport

Introduction

Background

EDF comments on the roadmap

Conclusion

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