European Disability Forum


I. Request 25.11.2007 | Answer 29.04.2008

II. Request 26.04.2008 | Answer II 29.04.2008

III. Request 04.05.2009 | Answer 27.05.2009 | Request 09.06.2009 | Answer 09.06.2009

IV. Request 09.06.2009 | Answer 09.06.2009 | Request 09.06.2009

V. Informed EDF 23.12.2009

Request 25.11.2007

To whom it may concern,

at the time being, it is obviously not obligatory for aircrafts to
provide handicapped accessible toilets for short-haul flights. The
same counts for on board wheelchairs.

The German Lufthansa for example does not provide on bord wheelchairs on their short-haul flights (compare statement by Lufthansa).

The implications for passengers travelling with a wheelchair are that
they cannot use a ttoilet. That means, that they are expected no to
use a toilet for up to 3 or 4 hours (PRM’s are usually preboarded and
are the last passengers to leave the airplane).

This situations is discriminating and degrading.

Can you help me further?

I am looking forward to your answer.

Kind regards from Kiel, Germany
Kay Macquarrie

Answer 29.04.2008

Dear Mr Macquarrie,

Thanks for your e-mail which was forwarded to me as the policy officer in charge of transport within the European Disability Forum (EDF). For some reason I did not receive the e-mail you sent on the 25th of November so thanks for getting back to me.

I am aware of the discrimination by design of aircrafts across the EU and in particular the lack of accessibility of the in-flight toilets. As you state, unfortunately there is no legislation at EU level requiring physical access to aircrafts. EDF has been lobbying since years to change this situation.

However, a new EU regulation on the rights of persons with disabilities and persons with reduced mobility when travelling by air was adopted in 2006 and will enter into full application on the 26th of July this year. This regulation only deal with passenger rights, not physical access, but will hopefully be the first step towards a change of the current situation. As an example, you will see in the regulation attached, annex II paragraph 5, that air carriers must assist persons with reduced mobility in moving to toilet facilities if required. EDF is currently trying to ensure that this will imply for air carriers that they must have at least one onboard wheelchair available for the passengers with reduced mobility. The European Civil Aviation conference is the relevant body for pushing for this at the moment.

You may also be interested to know that the DPTAC (the UK advisory committee on persons with disabilities to the UK Department of transport) has recently elaborated guidelines on the design of such onboard wheelchairs:

Please do not hesitate to contact me if you have any further questions or need any clarifications.

Best regards
European Disability Forum


Request 26.04.2008

To whom it may concern,

Regulation 1107/2006 deals with Air Passenger Rights.

Could you please tell me, why there are no regulations about

1. wheelchair accessible toilets on European flights
2. no legal bindings for air carriers to provide an onboard wheelchair?

Until today, there seem to be no legal foundation which ensure access
to toilets for PRM’s on European flights, right? Shouldn’t this cenral passenger right in your focus? Obviously it does not seem to be a matter for you since you are not mentioning it in 1107/2006 nor on your website.

It would be nice if you would give me feedback on my questions and statements.

Kind regards
Kay Macquarrie

Answer 29.04.2008

Dear Mr Macquarrie,

Thanks for your e-mail which was forwarded to me.

The European Disability Forum is the representative organisation of persons with disabilities in the EU, working to ensure the respect of our human and civil rights and to promote our rights in EU legislation. We are therefore purely a non-governmental organisation, working to lobby the European Institutions, and we do not have any power to adopt legislation or to amend it without the support of the European Institutions (the European Parliament, the European Commission and the Council of Ministers).

However, EDF wash actively involved in the elaboration of the EU regulation 1107/2006 on the rights of persons with disabilities and persons with reduced mobility when travelling by air. We requested ever since the beginning of the adoption process of this new piece of legislation that physical access to aircraft (and indeed airports) should be requested through this new regulation. Unfortunately, the European Commission made it clear that they would not accept that the regulation would go beyond passenger rights. In the final version of the regulation (which you will find attached), physical access is only mentioned in the preamble of the regulation, stating that air carriers should, where possible, take the needs of persons with disabilities and persons with reduced mobility into account when deciding on the design of new and newly refurbished aircraft. However, the preamble is unfortunately not of a binding character.

The full reasons behind the lack of legislation are therefore not something that I am fully aware of (because EDF completely share your concerns and is working for additional legislation in the air sector). It is the European Commission that can respond to you regarding this. The relevant contact persons would be Mr Peter Faross, Head of the Passenger Rights unit of DG TREN and Mr Christophe Dussart, Policy officer at this same unit

As mentioned in my previous e-mail, EDF is now focusing our current lobbying efforts on ensuring that the implementation of the new regulation 1107/2006 will be correct and complete, including that the obligation to provide assistance to the on-board toilets means that all air carriers shall carry on-board wheelchairs in the cabin.

This is something that we essentially work with the European Civil Aviation Conference (ECAC) to ensure (in addition with the European Commission) as they will have a key role to play in implementing the regulation. It would be great if you could raise your concerns also with the chairwoman of the ECAC working group on persons with reduced mobility, ms [Name deleted], in order to show further support for our requests:

Best regards,
European Disability Forum


Request 04.05.2009

Dear [Name deleted],

thank you for your answer and thank you for forwarding my email to the CEN. Could you please give me the contact details of the person you were forwarding my request?

In the first letter from the EP (compare attachment, sorry only in German language), it says, that the „EP Disability Intergroup“ – which is the EDF, I guess – was informed about my petition. Is that correct?

best regards

Answer 27.05.2009

Dear Kay,

EDF and the Disability Intergroup are not the same structure. The Disability Intergroup units MEPs and EDF only assists it in its work. More information on our website:

The person I forwarded your email to does not work at CEN – she is the EDF representative at CEN working group. She would be back to you, if she can provide you with some information.

Besides you can also contact CEN itself too.

Good luck.

Best regards,


Request 09.06.2009

Dear Mrs. [Name deleted],

in November 2008 I passed in a petition about accessible airplanes to the European Parliament.

In March 2009 I received a letter from the Committee on Petitions, which stated, that they informed the „EP Disability Intergroup“ about my concern (see PDF attachment in German). It would be helpful, if you could give me confirmation, whether you received the information from the Committee on Petitions.

Best regards
Kay Macquarrie

Answer 09.06.2009

Dear Mr Macquarrie

Thank you for your email. The Disability Intergroup is an informal grouping of MEPs and does not have any authority to deal with adjudication of individual complaints. If the letter was in German (I think I received a hard copy of it), I probably sent it for the attention of one of our German members (I don’t speak a word of German myself, and neither does the current Intergroup President). The only reason the Petitions Committee would send a petition to the Intergroup would be for the information of the Intergroup and to alert our German members about the situation (if the incident took place in Germany). Please note that the European Parliament is now being reconstituted following last week’s EP election, and the Disability Intergroup had to be disbanded and will be reconvened later this year. For general information on the Intergroup’s methods of work, you can consult

I’m copying my colleague [Name deleted] in this email; she is the officer responsible at EDF for the transport policy and may give you some general overview of the policy of non-discrimination of persons with disabilities in the air transport. Please note, however, that the EDF is a political organization (and not a decision-making body) and will hardly be able to influence the decision of the Petitions Committee of the EP or of any other mechanism. We do, however, use the examples of discrimination to advance our demands for accessible transport across the EU.

I do wish I could have given you a more concrete response but it’s not in my power. I will be writing to the Petitions Committee to inform them better about the limitations to the Intergroups’ competencies and our limited ability to help individuals who are faced with inaccessible environments in the provision of goods and services.

[Name deleted]

Policy and European Parliamentary Officer
European Disability Forum | nothing about us without us

Request 09.06.2009

Dear [Name deleted],

thank you for your fast and comprehensive answer.

My intention in writing this request was to get an information, whether the Disability Intergroup was informed about the petition through the commission (as it was stated in the document, which you received in my former email).

At the time being it is like a one way ticket: since I don’t receive any information about the future procedures, I have to assume, that nothing is going to happen. I would simply like to get some feedback about the further course of my request within the structure of the Disability Intergroup.

best regards

Informed EDF 23.12.2009

Dear EDF,

I would like to inform you about the status of my petition concerning accessible airplanes.

The German Bundestag discussed the petition and decided to forward it to the

  • German Government (Ministry of Transport) for the purpose of „als Material zu überweisen“
  • Parliamentary Groups (Fraktionen) of the German Bundestag for the purpose of acknowledgement „zur Kenntnis zu geben“

In 2010 all European countries are supposed to inform the EU about the implementation of the Regulation 1107/2006. The German Bundestag assigned the the Ministry of Transport to inform the Bundestag by the end of this year, whether the findings of the petitions are part of the report to the EU.

With this paper (see attachment 20090924_petition_bundestag.pdf) the process of the petition at the German Bundestag is finished.

Kind regards
Kay Macquarrie

More information upon the course of the petitions at the Deutsche Bundestag and the European Parliament under

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