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VIA EMAIL TO rpsahi@dgca.nic.in August 15, 2007 TO: FROM: In Re: "Draft Civil Aviation Requirements (CAR) Section 3 Series 'M' Part I - Carriage of Physically Challenged Passengers by Air" Dear Sir: The American Association of People with Disabilities (AAPD) is pleased to offer a brief comment in regard to the draft policy cited above. AAPD is the largest independent national nonprofit cross-disability member organization in the United States, dedicated to ensuring economic self-sufficiency and political empowerment for the more than 51 million Americans with disabilities. AAPD works in coalition with other disability organizations for the full implementation and enforcement of disability nondiscrimination laws, particularly the Americans with Disabilities Act (ADA) of 1990 and the Rehabilitation Act of 1973. Firstly, AAPD urges and encourages the DGCA to hold public hearings, meetings or consultations that include the diverse populations of persons with disabilities from the various regions of the country before finalizing its policy. Secondly, we recommend that DGCA develop an appropriate public and open procedure before finalizing any policy. This would mean developing a schedule over a period of time with sufficient public and open review steps, and with a broad number of stakeholders, to review the policy and to finalize it. This could include seeking written comments over a three-month period, for instance, or conducting a series of en banc meetings in different regions of the country, or similar actions that would ensure a larger number of people with disabilities, and their family members, are aware of the draft policy, could comment on and strengthen it, and who would benefit from its implementation. We encourage you to do this because, like India, the United States is a continental country; and it is AAPD’s experience and observation that it is important to involve and to hear from as many persons with disabilities as possible on critical issues. Furthermore, for a policy to be acceptable and implemented broadly and deeply, it is best if large numbers of persons are familiarized with policy proposals. Particularly important is involving a wide range of stakeholders most likely affected. The active involvement of many groups and persons, and most specifically persons with all kinds of disabilities and medical conditions, and their family members, in the formulation of the policy could go a long way to ensure a better outcome. Furthermore, we encourage your final policy to be in alignment with and to reflect your People With Disabilities Act that asserts the "Rights of Persons with Disabilities to travel independently and make independent choices." Implementing policy is never easy, but we encourage you to develop a timely, orderly approach that will involve persons with disabilities at every step of the way. Sincerely, Jenifer Simpson
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