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135 10.1 Introduction and Overview As noted in Chapter 1, the change in airport management to a customer-centric approach detailed by ACRP Report 157: Improving the Airport Customer Experience is also having a notice- able impact on services and accommodations for passengers with disabilities and for older travelers with functional limitations. A growing number of U.S. airports have moved beyond compliance with minimum regulatory requirements under federal, state, and local disability rights laws to more fully accommodate the needs of this diverse population. This action is borne out by the wide variety of innovations under way at airports of all sizes across the country and documented in the previous chapters of this report. However, concern raised by this research is that U.S. airportsâ many efforts are nonetheless unable to overcome a fundamental disconnect caused by our regulatory system, namely the division of responsibility between airports and airlines in providing services and accommoda- tions for these passengers. This problem prevents U.S. airports from truly taking ownership of the airport, a point made by an aviation executive in Europe when discussing the progress that airports there are making in raising levels of PRM service and that, in turn, are reducing flight delays and other operational challenges. This is a radical shift in perspective from a concern about customer experience and equity to a realization of how the quality of service for older adults and travelers with disabilities impacts airport operations in a fundamental way. This new understanding may come as a result of airports in the European Community now having control of PRM services, in addition to their other day-to-day operations. In his presentation synopsis at the Passenger Terminal Expo 2018 in Stockholm, Sweden, Aena Operations Manager Juan Ramon Mats Sebastia described the following: Synchronism at the right time between the aircraft readiness to depart and the payload onboard (passengers, baggage and cargo) is the aim of all airport stakeholders. Nowadays, although the aircraft process might be more than well monitored by the A-CDM, the bag and PRM processes are not so well monitored to detect potential losses of synchronism. By integrating this process monitoring into the AOP to alert airport stakeholders early of any disruption detected in these processes [that] may have an impact on the aircraft departure, new mitigation actions and procedures may be applied to recover the desired synchronism (Mats Sebastia 2018). A regulatory change similar to Regulation (EC) 1107/2006 is not likely to happen in the United States or Canada, but lessons can be learned from what might be the most important innovation discussed in this report. At European airports, new software solutions (such as Ozion PRM Manager, described in Chapter 12) share data on travelers with disabilities with airports, airlines, and service companies so that a passengerâs journey is seen in real time (even by connecting carriers) and service is adjusted accordingly. Airports know who is in their airports C H A P T E R 1 0 Management Practices
136 Innovative Solutions to Facilitate Accessibility for Airport Travelers with Disabilities (e.g., the number of individuals with mobility, vision, hearing, and cognitive disabilities that are traveling each year and how these numbers will grow over time). This information is critical for planning, but no U.S. airport currently has access to it. This is not to say that air travel for people with disabilities in Europe is perfect. But, now that European airports are required to provide accessible facilities and assist passengers in moving between airport arrival points and boarding gates, the likelihood that these airports will address accessibility in a comprehensive manner increases and makes it easier to measure levels of service. The latter was a specific intent of Regulation (EC) 1107/2006, as spelled out by the European Civil Aviation Conference in its accompanying Doc. 30 guidance, which set minimum standards in minutes for assistance to passengers based on whether they prenotified (European Civil Aviation Conference 2018). No such metrics exist in the Air Carrier Access Act Part 382 regulations. But, airports in the U.S. could set similar service standards in the interest of their customers and themselves. Based on airport monthly performance reports, the UK CAA publishes an annual report rating airports on their quality of assistance to passengers with disabilities and reduced mobility, a very effective way of goading poor performers to raise their levels of service (Civil Aviation Authority 2016b). Following its âpoorâ rating in 2017, London Heathrow invested US$30.7 million in service improvements for people with disabilities (Sanchez 2017). By comparison, U.S. DOT has only a very blunt instrument to judge levels of service: Disability- related complaints go to the airline or directly to the U.S. DOT. Each January, domestic and international air carriers must file annual reports of written disability-related complaints with U.S. DOT. However, these complaints are aggregated across all airports that the carriers serve in the U.S. and abroad. Only when there is a pattern of violations at a given airport (e.g., U.S. Airways at Charlotte Douglas International and Philadelphia International) does the U.S. DOT and, subsequently, the publicâwhen the resulting consent decree is publishedâbecome aware of a service problem (U.S. Department of Transportation 2013). This may be years after the problem first developed. In 2017, a Government Accountability Office report titled Passengers with Disabilities: Air Carriersâ Disability-Training Programs and the Department of Transportationâs Oversight made national news by pointing out that disability-related air travel complaints had doubled from 2005 through 2015, even when adjusted for the increase in enplanements (Jansen 2017). The report also notes that in 2015, of the total disability-related complaints submitted directly to U.S. DOT and to air carriers, the two largest complaint categories were âfailure to provide assis- tanceâ for âother wheelchairââ(i.e., someone who requires wheelchair assistance who has not been categorized as âparaplegicâ or âquadriplegicâ)âand âfailure to provide other dis- ability assistance,â both of which primarily relate to assistance at the airport. In 2015, these two cate gories together totaled 58 percent of written complaints to air carriers, a level similar to most other years, including 2016 and 2017 (U.S. Department of Transportation 2017, 2018). Other complaints primarily related to facilities or procedures at the airport included âdamage to assistive deviceâ and âstorage and delay of assistive device,â totaling 10 percent in 2015 (Government Accountability Office 2017). While most of the innovations and best practices described previously in this report relate to improvements in information and facilities for travelers with specific types of disabilities, the service failures by the previously mentioned airlines and their contractors present a more pressing problem for these airport customers. The remainder of this chapter discusses how airports are using their influence to address such service issues and to foster systemic change that makes accessibility and inclusion central to airport operations and the airport brand.
Management Practices 137 Many if not most of the problems noted in earlier chapters can be addressed by improvements in customer service, achieved by taking a close look at the gaps that exist and then working collab- oratively with other stakeholders to find solutions. This will also require increasing the quality and quantity of initial and refresher disability-related training for all staff working at the airport. 10.2 Role of Senior Management in Fostering Inclusion and Accessibility The role of senior management is key to moving beyond a mindset that views accessibility as benefiting a limited fewâand, therefore, not worth significant investment of scarce resourcesâ to recognizing that accessibility improves the experience for all customers and is a fundamental part of economic and social sustainability. While inclusion may be observed in practice at those airports that consistently make improvements in accessibility, references in the literature to the critical role of senior management in creating a culture of inclusion are scarce. An article on corporate social responsibility in Airport Improvement featured an interview with CEO of CincinnatiâNorthern Kentucky International Airport Candace McGraw, a prominent advocate for accessibility in the industry (Bradley 2016). McGraw describes corporate social responsibility as âacting ethically and responsiblyâmaking sure you not only comply with the letter of the law, but also the spirit of the law. Itâs (operating) within a framework that will build a positive image for your business while working well with neighbors, employees, and partners.â She notes that many of the airportâs corporate social responsibility initiatives are employee driven: âItâs important to get all employees and stakeholders rallied around the notion that we have to be a business [that] acts responsibly, with a social conscience.â Starting Our Adventure Right, a disability-related corporate social responsibility project mentioned in the article, is an autism familiarization program run in partnership with Delta Air Lines. Another project is a therapy-animal program using miniature horses, which evokes Kentuckyâs connection to thoroughbreds and enhances the sense of place critical to the airport brand. In 2015, Craig Richmond, president and CEO of Vancouver International (YVR), committed to accessibility on his airport website blog, Craigâs Corner: Accessible Airport. It begins with the statement that âWe want everybody to be able to fly comfortably through YVR, period. We are committed to providing the best possible airport environment for all users, including people with disabilities, older adults, and seniors.â The airport has been a proponent of universal design for 20 years and continues to make improvements to its facilities and services, many of which are detailed in his blog and in this report. Brian Ryks, executive director and CEO of Minneapolis and Saint Paul Metropolitan Airports Commission, was previously CEO at Grand Rapids Gerald R. Ford International Airport, which also excelled in accessibility under his leadership. Because the airport was not satisfied with the quality of assistance services, Gerald R. Ford International took over assistance services manage- ment through an agreement with the airlines. With regard to the Aira program described in Chapter 4, Ryks recently commented, âWe are working to ensure that travelers who are blind or [have] low vision are able to take full advantage of all [MinneapolisâSaint Paul] MSP has to offer. We continue to work closely with businesses and organizations serving people with disabilities to ensure all of our customers have a great experience at MSP.â The 2015 Sustainability Report from the MinneapolisâSaint Paul Metropolitan Airports Commission includes social well-being, as well as environmental and economic factors in its concept of sustainability. The report cites multiple examples of how the commission creates inclusion and partners with and meets the needs of its customers with disabilities (Minneapolisâ Saint Paul Metropolitan Airports Commission 2015). The report describes the commissionâs
138 Innovative Solutions to Facilitate Accessibility for Airport Travelers with Disabilities customer advisory boards, including the Travelers with Disabilities Advisory Committee, discussed later in this chapter. The Port of Seattle Commission has also committed SeattleâTacoma International to becoming âthe most accessible airport in the USA,â a title for which a number of airports are now vying. The following Ongoing Commitment to Excellence is posted on the airportâs website: The Port of Seattle Commission is dedicated to the task of making Sea-Tac the most accessible airport in the USA. Sea-Tac has recently partnered with the Open Doors Organization to evaluate our current conditions and further improve the experience we provide for all passengers. Airline senior managementâmost notably Sir Richard Branson, founder of Virgin Groupâ are coming forward to voice their commitment to inclusion and accessibility. In December 2018, Branson joined The Valuable 500 campaign with other notable business executives seeking to create an inclusive culture in business by addressing at the board level the needs of both employees and customers with disabilities (London Loves Business 2018). 10.3 Measuring the CostsâBenefits of Inclusion While the fast-growing number of older passengers needing wheelchair assistance should be impelling airports to pay greater and more comprehensive attention to accessibility, an unwillingness to invest in accessibilityâstemming in part from a narrow view of who benefits from accessibilityâmay be the major impediment to airportsâ innovation (Wolfe and Suen 2007). Developing a framework to measure the true economic benefits of accessibility was the subject of an International Transport Forum Roundtable Discussion in 2017 that generated two reports on the topic (Federing and Lewis 2017; International Transport Forum 2017). Figure 10-1 maps out the much broader beneficiaries of improved accessibility, akin to a universal design approach (i.e., accommodating the needs of individuals with disabilities benefits people with disabilities, as well as society at large). 10.4 Regulatory Requirements Under Americans with Disabilities Act Section 504 FAA is responsible for overseeing airport compliance with federal civil rights legislation. To that end, it created the Airports Disability Compliance Programâa branch of the FAA Civil Rights Officeâto educate airports on their legal responsibilities and to conduct compliance reviews (Federal Aviation Administration 2015). FAA also uses their National Civil Rights Training for Airports to spread the word about industry best practices by inviting airports and disability organizationsâsuch as Open Doors Organizationâto speak and then posting the presentations online (Van Horn 2016). In this way, FAA is encouraging airports to take more ownership of accessibility, using the leverage they have, for example, through contracts with vendors and ground transportation suppliers. FAA also exerts its influence through advisory circulars and by undertaking its own research on wayfinding for travelers with vision loss (Federal Aviation Administration 2016a). Airports have rightfully been described as the most complex regulatory environment. Figure 10-2 shows the regulations covering each role the airport plays (Federal Aviation Admin- istration 2016b). The administrative requirements under Americans with Disabilities Act Section 504 include: 1. Designating an Americans with Disabilities Act Section 504 coordinator, 2. Adopting and publishing a complaints process,
Figure 10-1. Framework for measuring the benefits of accessibility (Source: Federing and Lewis 2017).
140 Innovative Solutions to Facilitate Accessibility for Airport Travelers with Disabilities 3. Including a notice of nondiscrimination in all published public information, 4. Putting up an unlawful discrimination statement throughout the terminals, 5 Self-assessing accessibility with a transition plan and ongoing monitoring, 6. Establishing contractual agreements with all lessees, and 7. Establishing contractual agreements with air carriers. Details on each requirement are clarified in FAA Advisory Circular 150/5360-14A: Access to Airports by Individuals with Disabilities (Federal Aviation Administration 2017). 10.5 Americans with Disabilities Act Section 504 Coordinator Tasks and Duties The role of the Americans with Disabilities Act Section 504 coordinator is critical to creating and maintaining accessibility at airports, including oversight of lessees and air carriers. However, little has been written about the requirements and duties of the person filling this position. General training and certification are available from the National ADA Symposium, but the only training specifically for airport coordinators comes from the FAA at their annual event or from ACI. In addition to an online disability-awareness training class, ACI offers Accommodating Passengers with Disabilities, a 3-day workshop for airport managers developed and taught by Open Doors Organization. Typically, two or three workshops are held per year at different host airports in the United States. Lawrence Rolon, Americans with Disabilities Act 504 coordinator for Los Angeles World Airports, has compiled extensive information on the various tasks he performs at Los Angeles International Airport. These tasks fall under the following main headings: â¢ Facilities Planning, â¢ Operations, â¢ ADA Interagency and Public Managerial and Support Duties, â¢ Community Outreach, â¢ Transportation, â¢ Research, and â¢ Disability Awareness and Training. Rolon and ADA coordinators from HartsfieldâJackson Atlanta International, Denver Inter- national, and Phoenix Sky Harbor International helped create the Americans with Disabilities Act Section 504 Coordinators Forum, held annually at the FAA National Civil Rights Training for Airports in Washington, D.C. The forum provides an opportunity for exchange of best Figure 10-2. Airport roles and regulatory requirements (Source: Federal Aviation Administration).
Management Practices 141 practices and discussion of current issues affecting participating airports, as well as for education of newcomers to the position. At the first forum, held in August 2017, ADA coordinators shared best practice solutions and innovations from their airports that included the following: â¢ Compile a monthly report of all ADA complaints sent to all stakeholders (HartsfieldâJackson Atlanta International). â Use Avius Optimus off-the-shelf software to record, categorize complaints, and generate the report. â¢ Develop customer service standards (HartsfieldâJackson Atlanta International now has 10). â Provide staff members with apps to record what is happening at the airport so that the ADA coordinator can assess how well the standards are being met. â¢ Implement an employee awards program (HartsfieldâJackson Atlanta International). â¢ Compile service company monthly reports (Los Angeles International). â Require monthly data reports so that the ADA coordinator has access to detailed data on the number of assistance requests, complaints, and so on. â¢ Improve emergency management (Los Angeles International). â Include people who are foreign-language speakers, who are hard of hearing or deaf, and who have other disabilities in emergency exercises. â Provide communication training to the fire department that serves the airport. As a result, people who are deaf or hard of hearing survived in the last exercise at Los Angeles Inter- national. This action also benefits the surrounding community. â Provide emergency evacuation information online and in print for people with disabilities. â Included emergency information on airport tablets. With regard to oversight of wheelchair service providers, Rolon started the forum discussion by stating, âYouâre the landlord and have an obligation to see that everything is compliant.â The following is a summary of suggested practices: â¢ Meet regularly with providers; â¢ Provide additional services to fill gaps; â¢ Circulate ADA vans between terminals at Los Angeles International; â¢ Create service standards, and write them into contracts (e.g., âEmployee must be able to push 250 lbs. and speak English.â); â¢ Gather statistics that include the number and sizes of wheelchairs and replacements per year, the number of pushes per month and hour, and identify peak demand. 10.6 Airport Accessibility Committees 10.6.1 Internal Americans with Disabilities Act Committees These committeesâusually organized and led by the Americans with Disabilities Act Section 504 coordinatorâtypically meet on a monthly basis (or more often if required) to discuss any issues or projects that affect accessible facilities or services at the airport. Because the responsibility for accommodating customers with disabilities is shared among numerous stakeholders, all interested parties are included: â¢ Airport departments, â¢ Airlines, â¢ Airline service companies, â¢ Ground transportation providers, â¢ Concessionaires, and â¢ Security.
142 Innovative Solutions to Facilitate Accessibility for Airport Travelers with Disabilities Collaboration and cooperation among all stakeholders is critical to bridging the service gaps identified in earlier chapters. San Francisco International Airport has a Universal Design Committee to ensure that new facilities work well for all customers. The common-use self- service kiosks shown in Figure 5-16 is a prime example. 10.6.2 External Americans with Disabilities Act Advisory Committees A growing number of airports have disability advisory committees to acquire regular input from community members with disabilities. Airport staff from various departments and other stakeholdersâincluding airlines, service companies, and TSAâalso attend committee meetings to give presentations and get input on their various initiatives. Some airportsâsuch as HartsfieldâJackson Atlanta International, Miami International, and Los Angeles Internationalâ hold meetings monthly; others, such as MinneapolisâSaint Paul, meet quarterly (Figure 10-3). Members with disabilities may come from local chapters of national organizations, such as American Council of the Blind, Hearing Loss Association of America, National Federation of the Blind, National Association of the Deaf, Multiple Sclerosis Foundation, Paralyzed Veterans of America, The Arc, or a local Center for Independent Living. A list of disability organizations is included in the FAA Advisory Circular 150/5360-14A: Access to Airports by Individuals with Disabilities. Individuals with disabilities who specialize in ADA issues in state or local govern- ment may also be good membership candidates. It is important to have a mix of people with disabilities represented who travel regularly by air and/or have familiarity with ADA and Air Carrier Access Act accessibility requirements, as well as those who are new to travel. If the budget allows, a committee may want to bring in a non- local member to add additional expertise. It also sets a good tone to have an individual with a disability serve as chair, as at MinneapolisâSaint Paul International Airport. Participation is voluntary and members usually participate for a set amount of time, giving others an opportunity to have their voices heard. Carefully vetting the candidates who apply for membership is important. For examples of the types of questions to ask, visit the websites for Figure 10-3. Meeting of the MinnesotaâSaint Paul International Airport Travelers with Disabilities Advisory Committee.
Management Practices 143 HartsfieldâJackson Atlanta International and Los Angeles International and see their applications for membership. Airports that have disability advisory committees have been able to attract at least one Airport or Department of Aviation director or above to be fully active on the board. Having buy-in from upper management lends to the groupâs credibility, but it is also the key to the continuation of such committees and follow-through on the recommendations they make. A working group or advisory board gives airport planners, architects, and designers a group to consult with on questions of regulatory compliance and inclusive design. At Minneapolisâ Saint Paul International, architects regularly come before the committee to discuss specific projects and to get feedback from the members. Having a community of people who are available at any given time gives airport staff the ability to find answers reliably and quickly. The committee can also provide firsthand experience on inefficiencies in the airport, as well as giving valuable insight into how people with different disabilities interact with the airport. This type of board empowers airport personnel to use these people as a resource. And, with a good committee makeup, the airport will not only get local viewpoints but also hear national views andâin some casesâinternational perspectives. Advisory board members may also contribute to disability awareness trainings at the airport, help with community outreach, or participate in emergency exercises, as at Minneapolisâ Saint Paul International and at Los Angeles International. The authors of ACRP Synthesis 90: Incorporating ADA and Functional Needs in Emergency Exercises drew the following conclusion: âA disability advisory committee can benefit an airportâs emergency exercises, planning and general operations, and facility designâ (Smith and Haines 2018). A number of U.S. airlinesâincluding Alaska, Delta, JetBlue, Southwest, and Unitedâhave established disability advisory boards. Members review policies, procedures, services, and facilities. The airlines also invite them to travel nationally and internationally to their hubs and other key airports to provide disability awareness training. 10.7 Self-Evaluation An important requirement under the ADA and Section 504 is an initial self-evaluation, a transition plan detailing how the airport plans to address any deficiencies, and then regular ongoing monitoring of facilities and programs. FAA Advisory Circular 150/5360-14A: Access to Airports by Individuals with Disabilities notes that âBoth the ADA and Section 504 require that the airport provide for the participation of interested persons, including persons with disabilities, and organizations representing persons with disabilities in the evaluation.â After modifications are made to address problem areas, Section 504 requires that airports again consult with these organizations. Having a disability advisory committee on hand to confer with is a definite advantage. While the goal of the self-evaluation is compliance with federal regulations, airports that want to go above and beyond now have a very comprehensive tool, the âWayfinding Accessibility Audit Checklistâ included in ACRP Research Report 177: Enhancing Airport Wayfinding for Aging Travelers and Persons with Disabilities. For convenience, the downloadable checklist can be found at www.trb.org by searching for âACRP Research Report 177.â 10.8 Training The importance of disability awareness training has been emphasized throughout this report. Having ready access to the human element in the travel process is very important to older people and individuals with disabilities. Therefore, it is critical that the staff and
144 Innovative Solutions to Facilitate Accessibility for Airport Travelers with Disabilities volunteers providing information and assistance know how to appropriately and effectively interact and communicate. As feedback from the user needs focus groups and survey indicates, there is still much work to be done in this area. While some airports do minimal training, others such as San Francisco International require a full day of awareness training for everyone working at the airport. Another best practice is to include at least a short introduction to accessibility and disability awareness as part of the badging process, thus making it part of the airport brand. It is also important to include individuals with disabilities as trainers in order to break down attitudinal barriers. Training programs at London Gatwick Airport, British Airways, and San Francisco International feature interviews with individuals with a variety of disabilities that help to make up for not having trainers with disabilities in the classroom. Denver International and Philadelphia International are among the airports that regularly hire outside disability organizations to provide training. Airports that regularly hold familiarization programs in conjunction with their airline partners like the ones described in Chapter 3 also give their own staff and volunteers valuable experience in assisting individuals with cognitive and physical disabilities. Some of the programs have a specific training component, as well. Continuing education for airport managers is also important. Providing funding to travel for training or to participate in aviation conferences is not always easy, but it is an important way to keep the airport abreast of the latest developments in inclusion and accessibility. The FAA National Civil Rights Training, held annually in Washington, D.C., is free to attend. 10.9 Planning for Emergencies and Irregular Operations Before Hurricane Katrina in 2005, the needs of people with disabilities and functional limitations were rarely considered in emergency planning. This topic is now receiving greater attention within the airport community, but much still needs to be done in preparing for the types of events that can occur at an airport. ACRP Synthesis 90: Incorporating ADA and Functional Needs in Emergency Exercises is a recent resource available to airport management (Smith and Haines 2018). The report from ACRP 04-21: Emergency Communication Models for Persons with Disabilities and Non-English Speakersâ completed in 2018âwill also be helpful. Among the conclusions that stand out in ACRP Synthesis 90 are: â¢ The need for everyone who works at airport to have a clear role and training for that role, whether the emergency involves sheltering in place or evacuating; â¢ The importance of training on how to properly assist people with disabilities and others with access or functional needs in an emergency; â¢ The challenge of ensuring that wheelchair service providers are fully trained and involved in emergency response; and â¢ The value of having a disabilities advisory committee involved in emergency exercises and the planning process. Irregular operations, by definition, are not emergencies but have much in common with events that require sheltering in place. Here again, the cooperation of all stakeholdersâairport, airlines, service companies, and even concessionairesâis key to minimizing the negative impact that interrupted service and extended delays can have on individuals with disabilities and older adults. An important responsibility for the airport is to ensure that the specific supplies and
Management Practices 145 equipment needed by people with a variety of disabilities are on hand, including sleeping cots that are accessible for individuals who are nonambulatory. A resource from the Florida Department of Health that includes a sample supply and equipment list is included in References and Bibliography, along with a guide from the Federal Emergency Management Agency on planning for disability, access, and functional needs in shelters. 10.10 Fostering Innovation An impressive number of airports, airlines, and service companies in North America, Europe, and Asia are fostering innovation in various ways, benefiting people with disabilities and older adults directly or indirectly as members of the general population. Airports with in-house innovation labs include HartsfieldâJackson Atlanta International, Amsterdam Schiphol, Paris âCharles de Gaulle International, San Diego International, and Singapore Changi. A few years ago, HartsfieldâJackson Atlanta International ran an ATL Thinks! hackathon that directly sought solutions for issues affecting air travelers with disabilities. Airports are also partnering with universities. Two that are focusing specifically on disability- related innovations are Greater Rochester International with the National Technical Institute for the Deaf at the Rochester Institute of Technology and Pittsburgh International with Carnegie Mellon, a leader in robotics and wayfinding. Progress is being made by way of airports that welcome trials in their terminals. Most prominent include MinneapolisâSaint Paul Internationalâs wayfinding for travelers with vision loss and on-site wheelchair repair; CincinnatiâNorthern Kentucky Internationalâs WHILL wheelchair rentals; San Francisco Internationalâs wayfinding for travelers with vision loss; and Amsterdam Schipholâs numerous robotics trials, including Spencer Robot and eCare luggage robot. Airlines and service companies, too, are developing innovations that benefit their customers. Japan Airlines and PaxAssist each provide nonmetallic wheelchairs that allow older adults to remain seated during the security screening process. The United Airlines app stands to make a breakthrough in improving communications between customers who need assistance and the airline and service company. The TSA Innovation Task Force and FAA research on wayfinding technology for air travelers with vision loss must be called out, as well. Many companies are making a difference when it comes to inclusion, and it is clear that management plays a key role in fostering so many of the best practices discovered in the course of this research.