On 8th August 2019, IATA, the International Air Transport Association, the trade body for airlines worldwide, tweeted:
We have a lot of work to do but we’re determined to ensure that all disabled passengers can travel with safety and dignity. Our AGM Resolution sets out a code of practice which we call on governments to adopt.
While the airlines, via IATA, admitting they have an accessibility problem is welcome, their AGM Resolution is problematic in several areas. I initially tweeted my concerns, but I’ve now pulled them together into this blog post to allow me to expand on them in slightly more detail. I’ll be quoting the relevant section of the IATA release before each of my responses. Quoted text in italics, the particular section I’m addressing bolded, my own comment prefaced with DG:, original text with IATA:
From their Press Release at link:
IATA: Seoul - The International Air Transport Association (IATA) 75th Annual General Meeting (AGM) unanimously approved a resolution to improve the air travel experience for the estimated one billion people living with disabilities worldwide.
DG: One billion is distinctly on the low side for a world population of almost 8 billion and an incidence of disability of around 1 in 5.
IATA: The AGM
confirms the commitment of airlines to ensuring that passengers with
disabilities have access to safe, reliable and dignified travel, and calls upon
governments to use IATA’s core principles for accommodating passengers with
disabilities.
These
principles aim to change the focus from disability to accessibility and
inclusion by
bringing the travel sector together with governments to harmonize regulations
and provide the clarity and global consistency that passengers expect.
DG: This is a
classic faux pas, the disability equivalent of “We don’t think of you as black”.
The focus needs to be disability, accessibility and inclusion, together and as
one, because without focusing on our disability you can’t meet our access
needs in an inclusive manner. For the simplest example, accessibility needs are different depending on
whether someone is using crutches or a wheelchair. Accessibility isn’t possible
without a simultaneous focus on disability.
IATA: “Airlines
were ahead of their time when, 50 years ago, we set out standards to ensure passengers
with disabilities had access to air travel.
DG: And yet major airlines,
such as Ryanair*, were notorious for regularly denying wheelchair users boarding as recently as 2006, only stopping when the EU made this illegal via EC 1107/2006 concerning the rights of disabled persons and
persons with reduced mobility when travelling by air (see link), and for behaving like petulant children when courts ruled they had to
apply accessibility provisions.
And we still regularly hear
of denied boarding incidents outside of the US and EU.
* For clarity Ryanair and most of the Low Cost Carriers/budget airlines aren't IATA members, but they operate under the international treaties that IATA negotiates and are a core part of the industry, and a nexus for problems for disabled people.
* For clarity Ryanair and most of the Low Cost Carriers/budget airlines aren't IATA members, but they operate under the international treaties that IATA negotiates and are a core part of the industry, and a nexus for problems for disabled people.
IATA: But now
we need to go further. The numbers of persons with disabilities travelling by
air are set to increase significantly as populations expand and grow older. We
applaud the UN Convention on the Rights of People with Disabilities.
DG: It may be worth noting at this point that UNCRPD dictates the responsibility of states to provide for disabled people, or support them in:
Equality and non-Discrimination (Article 5)
Accessibility (Article 9)
Situations of Risk and Humanitarian Emergencies (Article 11)
Equal Recognition before the Law (Article 12)
DG: It may be worth noting at this point that UNCRPD dictates the responsibility of states to provide for disabled people, or support them in:
Equality and non-Discrimination (Article 5)
Accessibility (Article 9)
Situations of Risk and Humanitarian Emergencies (Article 11)
Equal Recognition before the Law (Article 12)
Person Mobility
(Article 19)
Work and
Employment (Article 27)
Participation in cultural life, recreation, leisure and sport (Article 30)
all of which are potentially impacted by the ready availability of air transport to disabled people.
Participation in cultural life, recreation, leisure and sport (Article 30)
all of which are potentially impacted by the ready availability of air transport to disabled people.
IATA: With today’s resolution the industry is committed to ensure that passengers living with disability can travel safely and with dignity,” said Alexandre de Juniac, IATA’s Director General and CEO.
The resolution
requests that the International Civil Aviation Organization (ICAO) apply IATA’s
core principles as the basis for its multilateral initiatives on accessibility
for passengers with disabilities. This work is vital to help harmonize national
legislation and regulations which otherwise could create a patchwork of
confusing or even contradictory requirements for passengers and airlines.
DG: This is a problem; it appears to be an attempt to bounce ICAO into adopting the IATA proposals without requiring or allowing for consultation with disabled people. It becomes even more of a problem when we examine the Core Principles in detail (see below). ICAO is a UN agency used to dealing at state level, so the ability of individual disabled people or groups to access its deliberations is limited in the extreme.
Under the disability movement’s guiding principle of Nothing For Us, Without Us, we must be involved in all stages of the development of airline accessibility standards.
DG: This is a problem; it appears to be an attempt to bounce ICAO into adopting the IATA proposals without requiring or allowing for consultation with disabled people. It becomes even more of a problem when we examine the Core Principles in detail (see below). ICAO is a UN agency used to dealing at state level, so the ability of individual disabled people or groups to access its deliberations is limited in the extreme.
Under the disability movement’s guiding principle of Nothing For Us, Without Us, we must be involved in all stages of the development of airline accessibility standards.
IATA: Wheelchair assistance
An IATA survey of 48 airlines reported that the requests for wheelchair assistance grew 30% between 2016 and 2017, putting strain onto the quality of the service provided.
DG: So scale the service provisions to meet the need. It really isn’t difficult. As disabled people increasingly demand our rights to travel, the numbers will inevitably increase until they reflect the number of wheelchair users in society (around 1 person in 55 from recent UK stats).
IATA: Airlines and airports are working together to ensure that wheelchair assistance is available to those who need it. In parallel, they are also working to develop other forms of assistance for passengers who are mobile but do not feel comfortable navigating through a large airport.
DG: It’s worth addressing airport design here. For buildings which necessarily feature flat surfaces and lifts between floors, airports can be remarkably inaccessible. Part of the problem is often the time provided for disabled people to reach the necessary gate. This is an artificially created form of inaccessibility via time constraint that could be simply addressed by aiding disabled people to set out for the gate in ample time, rather than leaving them to wait for a last-minute announcement.
IATA: For passengers with disabilities who travel with their own mobility aids, damage when stowed is a major concern. Airlines are working with associations of passengers with disabilities, airports, ground handlers, and regulators, to look at ways to improve this. One option under consideration is to develop standard procedures related to the loading of passengers’ mobility aids.
DG: This is good, this is how things should work, but some of the Core Principles seem at odds with this statement. And let us be clear here, damage to mobility aids is not rare, US stats are showing that the round trip risk of damage to a wheelchair is as high as 1 in 5 on some airlines, with over 30 wheelchairs damaged or destroyed nationally per day. And this is in the US, where FAA sanctions for violation of the Air Carrier Access Act far exceed those of other National Aviation Authories for violations of their disability legislation.
IATA: “We know that many passengers with disabilities rely absolutely on their mobility aids and we recognize that any damage to them can be a serious, even traumatic, issue. Our aim is to ensure that passengers with disabilities can travel with peace of mind knowing that their mobility aids will arrive undamaged and fit for use,” said- de Juniac.
DG: Peace of mind as a wheelchair user can only be possible if we know that if something does happen to our chair, and things will happen no matter what guarantees we’re given, we will be provided without quibble with a like-for-like replacement and a suitable (not mass-market one-size-fits all) loan chair until that is available. Non-wheelchair users are generally unaware that an individually fitted chair generally has a lead time of three months to produce and that non-individually fitted chairs are often dangerous. This is not simply "serious, even traumatic", it is a safety issue. I’ve twice partially dislocated a hip using a non-fitted chair and for wheelchair users in general the lifetime incidence of life-threatening pressure sores, vastly increased by non-fitted chairs, is already around two thirds.
Moving on to the Resolution (if the language seems odd, it’s diplomatic treaty speak). If you wish to look at the original (link here) be aware that I suspect there is a problem with the setup of the document for those using screenreaders, Adobe Acrobat will read pages 1 and 2, but apparently not page 3.
IATA: RESOLUTION ON PASSENGERS WITH DISABILITIES
RECOGNIZING the positive steps already taken by airlines to provide air travel to people with disabilities that is safe, reliable and dignified;
DG: If disabled people are having so bad an experience of air travel that IATA needs to admit it has a problem on the international stage and propose ways of dealing with it, then this self-congratulatory tone is ill-advised and does not read well to the disabled audience.
IATA: APPLAUDING the aims of the United Nations Convention on the Rights of People with Disabilities;
ACKNOWLEDGING the benefits of government and industry working together to support the travel needs of people with disabilities and the need to prioritize safety at all times;
DG: And disabled people? What are we? Chopped liver?
Nothing For Us, Without Us.
IATA: The 75th IATA Annual General Meeting:
1.AFFIRMS the commitment of all member airlines to provide safe, reliable and dignified travel for people with disabilities and calls upon all other air transport sector stakeholders to do the same;
2.CALLS UPON governments to make use of the IATA Core Principles on passengers with disabilities (Appendix I) in the development of national legislation and policies;
3.REQUESTS the International Civil Aviation Organization (ICAO) to apply these principles as the basis for multilateral initiatives related to passengers with disabilities.
DG: These two paragraphs are hugely problematical. They call for the wholesale adoption of the IATA principles (and we’ll see below they do it in such a way as to potentially affect all access law, not simply airline flight) and nowhere is there a call for governments and ICAO to consult with disabled people.
Nothing For Us, Without Us.
Moving on to the actual Core Principles IATA wants adopted.
IATA: Appendix I
IATA CORE PRINCIPLES ON PASSENGERS WITH DISABILITIES
DG: Still viewing us as self-loading cargo, I fear.
IATA: Persons with disabilities are important to the air transport sector. This is why IATA has developed these practical principles to help airlines work collaboratively with regulators and to provide a safe and satisfying travel experience to their valued customers.
DG: Again disabled people are left out of having any influence in the equation.
Nothing For Us, Without Us.
IATA: Policy Principles
CP1.Accessibility: The air transport sector should continue to promote inclusiveness and universal accessibility for all passengers, including for persons with disabilities.
CP2.Common Definition: National legislation (and supranational regional instruments) should apply a common, inter-operable definition for passengers with disabilities. National law definitions should be consistent with the relevant standards of the International Civil Aviation Organization (ICAO), including those under Annex 9 to the Chicago Convention.
CP3.Harmonization: In keeping with CP2, national legislation on passengers with disabilities should be harmonized to the greatest extent practicable. The principle of harmonization should apply equally to the policies, procedures and practices implemented pursuant to national legislation.
DG: These two Core Principles are hugely problematical. Applying them would undermine disability rights legislation, potentially worldwide. The UK has a particularly inclusive definition of disability under the Equality Act 2010 which carries over into all UK law. Most countries have a somewhat less inclusive definition. So, any suggestion that the UK should adopt a more common definition of disability would result in people losing disability rights across the whole slew of UK law. While for countries with less inclusive laws it becomes much more difficult to change them to the inclusive UK model if they are defined rigidly by international treaty.
I’ve also looked at the mentioned Annex 9 of the Chicago Convention, which doesn’t seem to define disability, but does contain 40 ‘Recommended Practices’ for carriage of disabled passengers. Unfortunately, they’re only ‘recommended’, and some are problematic.
IATA: CP4.Clarity: National legislation should be clear and unambiguous in its terms. Such legislation should not infringe treaty obligations or other obligations of international law.
DG: Core Principle 4 is perhaps the single most problematic item in the entire document. It is difficult to read this as anything other than a calculated attack on the US and Canada (and the EU has considered joining them) requiring that air carriers ignore the maximum compensation limits of the Montreal Convention for damaged or destroyed cabin or hold baggage ($1550, yes really) when dealing with wheelchairs or other medical goods damaged or destroyed in transit. And that assumption undermines the expressed intent of the document, because wheelchair users can never be confident in flying while the Montreal Convention limits remain.
For illustration, my very basic, bottom-end manual chair has a replacement cost of around $3600. A powerchair can easily run over $15,000, and a high-end prosthetic limb, of which an amputee might have several, can run over $50,000. A compensation limit of $1550, which is insisted on by international treaty, is simply an impossible constraint for disabled people to accept.
Given its chilling effect on air travel by disabled people, and mobility being a defined right under multiple articles of UNCRPD, I think we potentially need to consider whether the Montreal Convention is compatible with UNCRPD.
IATA knows the Montreal Convention is hugely problematic for disabled travellers, and that many airlines continue to hide behind it. It’s extremely difficult to assume good faith in this Core Principle.
If IATA wants to insist on national accessibility law following treaties designed to support the airline industry, and the Montreal Convention in particular, then clearly those treaties must be renegotiated to take real replacement costs into consideration.
IATA: CP5.Consultation: Regulators should consult with the airline industry and other air transport sector stakeholders well before legislation, policies, procedures or practices are adopted. Such consultation processes should be transparent and meaningful.
DG: I’ll be generous and assume that disabled people are meant to be included under “other air transport sector stakeholders,” but it is far from clear that that is the case.
Nothing For Us, Without Us
IATA: CP6.Impact assessment: Regulators should undertake a comprehensive impact assessment that deals with the costs and benefits of any proposed regulatory action.
DG: Such an impact assessment should of course consider the costs of not providing disabled people with full access to air travel and standing in contravention of UNCPRD on a human rights issue.
IATA: CP7.Fair application: National legislation should contain safeguards to prevent exploitation of the system for personal convenience
DG: This is horrendously offensive, it’s a dogwhistle shout-out to the bigoted belief that all disabled people are out for what we can get, if not actual fakes and frauds.
IATA: Process Principles
CP8.Assistance: Airlines should assist passengers with disabilities in a manner that takes into account the best interests of the passengers, relevant safety regulations and operational realities.
DG: This sounds innocent enough, but has a huge concealed problem that fatally undermines the stated principles of the Resolution. By ‘operational realities’ IATA means the abilities of low-cost carriers such as Ryanair to deplane incoming passengers, service and clean the aircraft, and emplane the outgoing passengers in around 25 minutes from wheels stopped. It is this pressure, this ‘operational reality’, that pressurizes baggage handlers to the point that wheelchairs are deliberately mishandled and tossed around the hold, then have a cabin-load of baggage stacked atop them, because they simply cannot do their job properly in the time available. ‘Operational realities’ should indeed be taken into account, but as one of the core problems denying wheelchair users confidence in airline travel.
IATA: Persons with disabilities are important to the air transport sector. This is why IATA has developed these practical principles to help airlines work collaboratively with regulators and to provide a safe and satisfying travel experience to their valued customers.
DG: Again disabled people are left out of having any influence in the equation.
Nothing For Us, Without Us.
IATA: Policy Principles
CP1.Accessibility: The air transport sector should continue to promote inclusiveness and universal accessibility for all passengers, including for persons with disabilities.
CP2.Common Definition: National legislation (and supranational regional instruments) should apply a common, inter-operable definition for passengers with disabilities. National law definitions should be consistent with the relevant standards of the International Civil Aviation Organization (ICAO), including those under Annex 9 to the Chicago Convention.
CP3.Harmonization: In keeping with CP2, national legislation on passengers with disabilities should be harmonized to the greatest extent practicable. The principle of harmonization should apply equally to the policies, procedures and practices implemented pursuant to national legislation.
DG: These two Core Principles are hugely problematical. Applying them would undermine disability rights legislation, potentially worldwide. The UK has a particularly inclusive definition of disability under the Equality Act 2010 which carries over into all UK law. Most countries have a somewhat less inclusive definition. So, any suggestion that the UK should adopt a more common definition of disability would result in people losing disability rights across the whole slew of UK law. While for countries with less inclusive laws it becomes much more difficult to change them to the inclusive UK model if they are defined rigidly by international treaty.
I’ve also looked at the mentioned Annex 9 of the Chicago Convention, which doesn’t seem to define disability, but does contain 40 ‘Recommended Practices’ for carriage of disabled passengers. Unfortunately, they’re only ‘recommended’, and some are problematic.
IATA: CP4.Clarity: National legislation should be clear and unambiguous in its terms. Such legislation should not infringe treaty obligations or other obligations of international law.
DG: Core Principle 4 is perhaps the single most problematic item in the entire document. It is difficult to read this as anything other than a calculated attack on the US and Canada (and the EU has considered joining them) requiring that air carriers ignore the maximum compensation limits of the Montreal Convention for damaged or destroyed cabin or hold baggage ($1550, yes really) when dealing with wheelchairs or other medical goods damaged or destroyed in transit. And that assumption undermines the expressed intent of the document, because wheelchair users can never be confident in flying while the Montreal Convention limits remain.
For illustration, my very basic, bottom-end manual chair has a replacement cost of around $3600. A powerchair can easily run over $15,000, and a high-end prosthetic limb, of which an amputee might have several, can run over $50,000. A compensation limit of $1550, which is insisted on by international treaty, is simply an impossible constraint for disabled people to accept.
Given its chilling effect on air travel by disabled people, and mobility being a defined right under multiple articles of UNCRPD, I think we potentially need to consider whether the Montreal Convention is compatible with UNCRPD.
IATA knows the Montreal Convention is hugely problematic for disabled travellers, and that many airlines continue to hide behind it. It’s extremely difficult to assume good faith in this Core Principle.
If IATA wants to insist on national accessibility law following treaties designed to support the airline industry, and the Montreal Convention in particular, then clearly those treaties must be renegotiated to take real replacement costs into consideration.
IATA: CP5.Consultation: Regulators should consult with the airline industry and other air transport sector stakeholders well before legislation, policies, procedures or practices are adopted. Such consultation processes should be transparent and meaningful.
DG: I’ll be generous and assume that disabled people are meant to be included under “other air transport sector stakeholders,” but it is far from clear that that is the case.
Nothing For Us, Without Us
IATA: CP6.Impact assessment: Regulators should undertake a comprehensive impact assessment that deals with the costs and benefits of any proposed regulatory action.
DG: Such an impact assessment should of course consider the costs of not providing disabled people with full access to air travel and standing in contravention of UNCPRD on a human rights issue.
IATA: CP7.Fair application: National legislation should contain safeguards to prevent exploitation of the system for personal convenience
DG: This is horrendously offensive, it’s a dogwhistle shout-out to the bigoted belief that all disabled people are out for what we can get, if not actual fakes and frauds.
IATA: Process Principles
CP8.Assistance: Airlines should assist passengers with disabilities in a manner that takes into account the best interests of the passengers, relevant safety regulations and operational realities.
DG: This sounds innocent enough, but has a huge concealed problem that fatally undermines the stated principles of the Resolution. By ‘operational realities’ IATA means the abilities of low-cost carriers such as Ryanair to deplane incoming passengers, service and clean the aircraft, and emplane the outgoing passengers in around 25 minutes from wheels stopped. It is this pressure, this ‘operational reality’, that pressurizes baggage handlers to the point that wheelchairs are deliberately mishandled and tossed around the hold, then have a cabin-load of baggage stacked atop them, because they simply cannot do their job properly in the time available. ‘Operational realities’ should indeed be taken into account, but as one of the core problems denying wheelchair users confidence in airline travel.
IATA: CP9.Guidance:
Airlines should provide clear guidance to passengers with disabilities on their
requirements for the carriage of mobility devices and medical equipment.
DG: Clarity would be welcome, but requirements need to reflect the needs and realities of wheelchair users and other disabled people.
DG: Clarity would be welcome, but requirements need to reflect the needs and realities of wheelchair users and other disabled people.
IATA: CP10.Training:
Airline and aviation service staff should be supported by their employers in
acquiring and maintaining the proper knowledge, skills and abilities to provide
passengers with disabilities a seamless and dignified travel experience.
DG: This training must be mandatory, and ideally delivered by disability access consultants with a lived understanding of the issues.
DG: This training must be mandatory, and ideally delivered by disability access consultants with a lived understanding of the issues.
IATA: CP11.Reducing
burdens: National legislation should be balanced in its application and should
not impose disproportionate or impracticable burdens on airlines.
DG: This really doesn’t help convince disabled readers that the airlines have changed. After all, they’ve been willing to stack disproportionate and impractical burdens on disabled people for decades.
DG: This really doesn’t help convince disabled readers that the airlines have changed. After all, they’ve been willing to stack disproportionate and impractical burdens on disabled people for decades.
IATA: CP12.Communication:
Regulators should strongly encourage passengers with disabilities to provide pre-notification
of their needs in advance of their travel.
DG: This is calling for an actual reversal of the accessibility state of the art, which increasingly considers turn-up-and-go the applicable standard. Much of the UK train network is already turn-up-and-go, with the allowed maximum notice on those parts that aren’t to be reduced to 2 hours by 2022. Is the airline industry really less capable than the rail industry? How long does it take to drive an ambulift from terminal to plane?
DG: This is calling for an actual reversal of the accessibility state of the art, which increasingly considers turn-up-and-go the applicable standard. Much of the UK train network is already turn-up-and-go, with the allowed maximum notice on those parts that aren’t to be reduced to 2 hours by 2022. Is the airline industry really less capable than the rail industry? How long does it take to drive an ambulift from terminal to plane?
IATA: CP13.Coordination:
Air transport sector stakeholders and governments should coordinate their approach
in order to deliver consistent end-to-end service to passengers with
disabilities regardless of location and national borders
DG: Noticeably absent from the requested coordination are disabled people. Improved
processes must be developed in consultation with us, otherwise there is no
guarantee they are actually improved.
Nothing For Us, Without Us
Conclusions
There is a lot of good buried in here, and IATA acknowledging publicly that the industry has a problem is extremely welcome, but there are many distinctly problematic elements in the 'Core Principles' which point to disabled people either not being consulted, or being ignored
Nothing For Us, Without Us
Conclusions
There is a lot of good buried in here, and IATA acknowledging publicly that the industry has a problem is extremely welcome, but there are many distinctly problematic elements in the 'Core Principles' which point to disabled people either not being consulted, or being ignored
Dear David,
ReplyDeleteYou have made a great many points here and we will attempt to respond to many of them here. Our overarching point would be that we are indeed reaching out to representative groups for passengers with disabilities, and we would certainly invite you to work with them as we attempt to address the issues which you have highlighted, including any which we have not responded to here.
Regardless of whether it is a billion or more than a billion, it is clear that disabilities affect a very large number of people, and that’s why harmonized and coordinated policy is important to us.
Regarding your criticism of the wording of our principles to “aim to change the focus from disability to accessibility and inclusion”, we respectfully suggest you have misinterpreted what this means for us. We believe in a model that seeks to change society in order to accommodate people living with impairment; we do not seek to change persons with impairment to accommodate society. E.g. It is not the inability to walk that keeps a person from entering a building by themselves, but the stairs that are inaccessible that keeps a wheelchair-user from entering that building.
In terms of calling on ICAO to adopt our principles, we are not seeking to ‘bounce’ ICAO into anything. But the fact is that national laws might be implemented without coordination between the states. Given the complexity of air transport, uncoordinated legislation on so important a human rights issue is a disservice to the passengers and the airlines we represent, and ICAO is a vital organisation for better harmonization of regulations. We would consider this an exercise in ‘leveling up’ rather than trying to find a lowest common denominator.
We accept that the AGM Resolution used rather fussy diplomatic language. The important thing is that we are consulting extremely regularly with, and taking into account the views of, disabled passengers’ groups. We value their perspective and invite you to join forces with them to talk to us. Examples include in the UK, the Heathrow Access Advisory Group, and in the US with Open Doors for Disabilities and others.
There’s much more to discuss – for example, we would welcome your perspective on how to scale the service provision at airports, and how to design them to better help passengers with disabilities. And regarding wheelchair damage, of course this is a huge issue. Please believe that we are sincere in wanting to solve this problem but there are no immediate easy answers. We can only say we’re sorry to hear of your bad experience, and we know that it is by no means a unique one.
Finally, to address your comment that our call for disabled services not to be exploited by those not in need was “horrendously offensive.” The point of this comment is that there is evidence that people who are not in real need of wheelchair assistance are using it, which given the huge increase in demand we mentioned, obviously impacts on the services that are available for those in genuine need. The key point here is that we’re not saying that people are doing this deliberately – it may be that they simply are unaware that other options may be available. For example, if the issue is wayfinding rather than mobility, perhaps there are other options to help those passengers rather than just giving them a wheelchair. This was certainly not intended to be an “offensive” suggestion.
In conclusion, we’re sad to read that you feel ignored. This is not the intention of the Resolution and nor is that the principle under which IATA is conducting its work on disability inclusion and accessibility. We hope to work with you in the future as we continue our consultation and listening exercise with disabled passengers’ groups.
What evidence do you have that "people who are not in real need of wheelchair assistance are using it"?
DeleteWho is making this determination? Airport staff? By looking at the disabled person?
The prejudice experienced by those who can walk short distances but need wheelchairs for longer is well known. The same goes for those who "look well".
Sadly many such people have had very bad experiences at the hands of airport personnel. Would they form part of the basis for your assertion?
Unless your evidence comes from the disabled people themselves saying that they are using wheelchairs for uses other than mobility, then I'm afraid that your assertion is highly suspect.