Joint position by Armateurs de France, EPF and EDF in view of the second reading of the proposal for a regulation on the rights of passengers when travelling by sea and inland waterway

Armateurs de France (The French Shipowners’ Association) , the European Passengers’ Federation (EPF)and the European Disability Forum (EDF) share certain key goals, in particular that of ensuring the right for all passengers to travel on a non-discriminatory basis and in the best possible conditions. Our associations have therefore started a dialogue regarding the proposed regulation on passengers’ rights, in order to identify common positions and to discuss outstanding issues. It is also hoped that this dialogue will constitute a basis on which carriers and associations championing passengers’ generally and particularly persons with reduced mobility or disabled personswill be able to build, once the regulation has been adopted.

EDF, EPF and Armateurs de France are in favor of thebroadest possible scope of application of the regulation, in order to ensure that passengers’ rights are protected as widely as possibleand to avoid distortions of competition between carriers.

EDF, EPF and Armateurs de France therefore propose:

- That the text applies to all passenger services into and from the EU, regardless of the nationality of the carrier,

-That the threshold, in terms of tonnage and number of passengers carried, be as low as possible.

EDF, EPF and Armateurs de France wish that the regulation create an appropriate and flexible, system to ensure smooth assistance for the passenger, adapted to the working environment of the carrier.Persons with reduced mobility or disabled persons should be able consistently to obtain any necessary assistance through arrangements that are appropriate for their needs and easy to call on.

Therefore :

-in cases where the carrier does not wish to or cannot provide assistance, and therefore requires the presence of an accompanying person, he or she should travel free of charge, but should not be considered a servant or agent of the carrier

- in order to facilitate the provision of assistance, the need for assistance should be notified 48 hours before departure at the latest, but early notification (at the time of booking) should be encouraged.

-The passenger should receive a confirmation of the booking of assistance.EDF, EPF and Armateurs de France underline though that there must be a possibility to allow for some flexibility as to the notification schemes.Taking into account the 48 hr timeframe for the notification of assistance,as proposed under the draft regulation, it is therefore suggested that the carrier stipulates in writing or by e-mail or by telephone, or in other reasonable and appropriate waysthe time at which the passenger should present himself (article 11 b) i).

We hope that these common positions will be taken into account by the Parliament and the Council during the second reading.

Contact persons:

European Disability Forum: Maria Nyman, Policy Officer,

tel: +32 (0)2 285 61 84

European Passenger’s Federation: Christopher Irwin, Vice Chairman,

tel: +44 (0)7900 218 290

Armateurs de France: Blandine Huchet, European Affairs

tel +33 (0)1 53 89 52 58

About Armateurs de France

Armateurs de France is the professional organization representing the French shipping companies. Our 60 members are involved in several activities: freight transport, maritime services and passengers transportation. Its members carry 12 million passengers every year

About EPF

The European Passengers’ Federation is an association that links more than thirty national and regional passengers’ organisations from throughout Europe. EPF’s purpose is to further the interests of public transport users at the European level. It is concerned particularly with the advancement of passengers’ rights and the promotion of sustainable mobility.

About EDF

The European Disability Forum (EDF) is the European umbrella organisation representing the interests of 65 million disabled citizens in Europe. EDF membership includes national umbrella organisations of disabled people from all EU/EEA countries, accession countries and other European countries, as well as European NGOs representing the different types of disabilities. It is estimated that 60% of this population are women. The mission of the European Disability Forum is to ensure disabled people full access to fundamental and human rights through their active involvement in policy development and implementation in Europe.

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