Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention
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Air Law Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention ABSTRACT Unruly passenger incidents on board aircraft in commercial service have become a significant operational issue faced by airlines, flight and cabin crew on a daily basis. These incidents threaten flight safety and security, impact the travel experience of other passengers and lead to significant costs and operational disruption for carriers. The Convention on Offences and Certain Other Acts Committed on Board Aircraft (ICAO, 1963), commonly known as the Tokyo Convention 1963, is the international air law instrument that deals with offences and certain other acts committed on board aircraft in flight. On 4th April 2014, States attending a Diplomatic Conference in Montreal, Canada, adopted a protocol to amend the Convention that recognised “the escalation of the severity and frequency of unruly behaviour on board aircraft that may jeopardise the safety of the aircraft or of persons or property therein or jeopardise good order and discipline on board”. This paper explores this issue and focuses on the likely effectiveness of the revision of the Tokyo Convention 1963 as part of a wider range of measures to deal with unruly passenger incidents.
Air Law Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention THE AUTHOR Mr Tim Colehan is Assistant Director, Member and External Relations for the International Air Transport Association (IATA). He is responsible for policy analysis and development as well as working with airline members, regional airline associations and others to articulate and advocate the industry positions to governments and regulators. He has been involved in IATA’s initiatives in response to the growing issue of unruly passengers including advocating for the revision of the Tokyo Convention 1963. He was part of the IATA delegation at the recent ICAO Diplomatic Conference that adopted the Montreal Protocol 2014. Prior to joining Member and External Relations, Mr Colehan was Area Manager for Thailand, Cambodia, Myanmar and Laos based in Bangkok after serving as Country Manager, Gulf Area, responsible for all aspects of IATA’s local operations and activities. Mr Colehan holds an MSc in Air Transport Management from Cranfield University, UK.
Air Law Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention Tim Colehan International Air Transport Association UNRULY PASSENGER INCIDENTS – A SIGNIFICANT ISSUE In recent years, there has been a general upward trend in instances of unruly and disruptive behaviour on board aircraft in commercial airline service. That is the conclusion drawn from statistics gathered and analysis undertaken by IATA, the trade association that represents 243 airlines that are responsible for 84 per cent of global traffic. Analysis of the IATA data shows the following common types of behaviour (IATA, 2013, p. 2): a) Illegal consumption of narcotics or cigarettes;1 b) Refusal to comply with safety instructions (e.g. an instruction to fasten a seat belt or disrupting a safety announcement); c) Verbal confrontation with crew members or other passengers; d) Physical confrontation with crew members or other passengers; e) Passengers who interfere with crew duties or refuse to follow instructions to board or leave the aircraft; f) Making threats that could affect the safety of the crew, passengers and aircraft (e.g. threat to kill or injure someone, bomb threat. Attempting to enter the cockpit has also been reported by airlines as a concern); g) Sexual abuse or harassment; and h) Other types of riotous behaviour that could jeopardise the safety or alter good order and discipline on board the aircraft (e.g. screaming, annoying behaviour, kicking and banging heads on seat backs). Long-term analysis shown in Figure 1 indicates that, for the period 2007 to 2013, there was an average of one unruly passenger incident per 1,600 flights. In 2013 alone, there were over 8,000 unruly passenger reports equating to 1 incident for every 1,370 flights. 1 The consumption of alcohol from private supply is also a reported problem although not captured as a specific category by the IATA analysis. Journal of Aviation Management 2014 9
Air Law Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention © 2014 International Air Transport Association (IATA). All Rights Reserved Figure 1: Unruly Passenger Reports 2007 to 2013 Figure 2 shows that approximately 20 per cent of these incidents were serious enough to require the intervention of police or security services at the place of landing. © 2014 International Air Transport Association (IATA). All Rights Reserved Figure 2: Unruly Passenger Incidents Requiring Police/Security Service Intervention 2007 to 2013 10 Journal of Aviation Management 2014
Air Law Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention These statistics are obtained from the Safety Trend Evaluation, Analysis and Data Exchange System (STEADES), a database owned and managed by IATA to which 170 airlines submit periodic reports (IATA, 2014). Participation in STEADES is entirely voluntary and therefore the data collected, while constituting a significant sample, is likely to under-represent the global extent of the issue. Airlines also confirmed the growing trend towards unruly and disruptive behaviour in their responses to an IATA survey conducted in 2013 (IATA, 2013). The responses from 53 members located in every region of the world demonstrate that this issue affects airlines operating in all parts of the world without being confined to any particular region and in all classes of travel. All of the airlines surveyed had experienced an unruly passenger event on their services within the last 12 months. Of those, 43.4 per cent had experienced more than 100 such events on their services in the relevant 12-month period (see Figure 3). More than 100 43.40% 50 to 100 15.09% 20 to 50 13.21% Less than 20 28.30% Figure 3: How many unruly passenger events would you estimate have occurred on your services in the last 12 months? Journal of Aviation Management 2014 11
Air Law Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention About 53 per cent of respondent airlines felt that unruly passenger events had increased in frequency on their services in the last five years (see Figure 4). Increased 52.83% Decreased 9.43% Stable over time 24.53% Not possible to say 13.21% Figure 4: In your view, have unruly passenger events increased or decreased on your services in the last 5 years? It is beyond the remit of this paper to discuss what factors may be behind the increase in unruly incidents. It is possible that it simply reflects societal changes where anti-social behaviour is increasingly prevalent. However, what is deemed acceptable on the ground takes on a completely different complexion in the confined environment of an aircraft cabin at 35,000 feet. The increasing reports of unruly passenger behaviour over recent years led IATA to develop a holistic approach to the problem, focusing on prevention, management and deterrence. On the operational side, guidance materials were developed containing advice, tools and best practices that enable airlines to enhance policies and procedures aimed at preventing and managing unruly incidents. IATA’s legal team also undertook a thorough review of the Tokyo Convention 1963 to ensure that it remains a sufficient deterrent to unruly behaviour. This comprehensive review identified a number of gaps in the Convention that needed to be addressed in light of the increasing incidence and severity of unruly incidents. 12 Journal of Aviation Management 2014
Air Law Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention LIMITATIONS OF THE TOKYO CONVENTION 1963 The gaps in the Convention that were identified by IATA’s review are outlined below: Jurisdictional Issues The identity of an unruly passenger can usually be easily ascertained because any unlawful conduct that takes place in a confined space should, in theory, facilitate the job of law enforcement authorities. However, the reality is that, in many cases following an incident, the State where the passenger disembarked does not have jurisdiction (as the State of landing) when the aircraft is registered in another State. The consequence is that the offenders are simply left unpunished, which undermines the deterrent effect that the Convention may otherwise have. In the IATA survey conducted during March and April 2013, more than 60 per cent of airlines reported that prosecutors at the place of landing cite lack of jurisdiction as a primary reason for not pursuing charges against an offender. The jurisdictional gap for certain types of passenger conduct has also been expressly recognised by the courts. Because jurisdiction does not exist in the State of landing, the hope is that: “signatories to the Tokyo Convention will be astute in seeking the extradition for prosecution of those who commit offences aboard their registered or controlled aircraft. Failing this, ‘crime’ committed aboard aircraft may go unchecked.”2 However, expanding the scope of the jurisdiction provision would actually obviate the need for a proactive approach to extradition. It must be noted, in this respect, that the State of registry is unlikely to seek extradition for minor property or conduct offences, especially in cases where the high cost of extradition processes outstrips the perceived seriousness of the conduct in question. Just because a particular conduct does not merit extradition, however, does not necessarily mean that the conduct is undeserving of summary penalty or other sanction at the place of landing. Recognising the limitations of the Convention, some States including Australia, Canada, France, the United States and the United Kingdom have already exercised State-of-landing jurisdiction and have amended their domestic laws to permit national courts to exercise jurisdiction over events that occur on board foreign aircraft which land in their territory.3 Nevertheless, many States are understandably reluctant to unilaterally extend jurisdiction to events occurring outside their territory in the absence of an international agreement. A number of States have indicated, 2 The Queen v Duggan 1995, No. 96, CACC000096/1995, Hong Kong Court of Appeal, at 5 (per Justice Mortimer). 3 While ICAO Circular 288 is a positive step forward in this area, it is IATA’s view that treaty-level rules are necessary if meaningful international uniformity is to be achieved. See further International Civil Aviation Organization. (2002). Circular 288 – Guidance Material on the Legal Aspects of Unruly/Disruptive Passengers. Montreal. International Civil Aviation Organization Publishing Division. Journal of Aviation Management 2014 13
Air Law Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention for instance, that their legislatures would not enact such a law without a basis grounded in treaty law. Moreover, in the absence of a mandatory State-of-landing jurisdiction provision, it may be difficult to convince national legislators of the importance of modifying their applicable domestic law. Another jurisdictional issue relates to those aircraft that are registered in one State but have operators that have their legal presence in another State. This is facilitated by a Protocol relating to an Amendment to the Convention on International Civil Aviation, signed at Montreal on 6 October 1980 (ICAO, 1980). In 1980, airlines leased three per cent of all aircraft and owned 97 per cent. Yet in 2014, airlines leased approximately 40 per cent of all aircraft (by operating lease). This number is projected to increase to 50 per cent in the next few years (Reed Business Information Ltd, 2014). Thus, it is reasonable to predict that it will become less and less likely over time that the State of registration will be the same as the State of the operator. A new State of operator jurisdiction would prevent the erosion of the State of registration principle over time by sensibly conferring jurisdiction upon the State most closely connected to the airline in question. It is possible that a leased aircraft may seldom, or never, visit the State of registration. It should be observed that State of operator jurisdiction is neither a new concept in air law, nor within those air law instruments that deal with criminal liability. The same or similar concept is employed in the Convention for the Suppression of Unlawful Seizure of Aircraft (ICAO, 1970), the Convention for the Suppression of Unlawful Acts against the Safety of Civil Aviation (ICAO, 1971), the Convention on Compensation for Damage Caused by Aircraft to Third Parties (ICAO, 2009a), the Convention on Compensation for Damage to Third Parties Resulting from Acts of Unlawful Interference Involving Aircraft (ICAO, 2009b), the Convention on the Suppression of Unlawful Acts Relating to International Civil Aviation (ICAO, 2010a) and the Protocol Supplementary to the Convention for the Suppression of Unlawful Seizure of Aircraft (ICAO, 2010b). Definition of Offences The Convention currently does not provide for a definition of what constitutes a criminal offence, leaving this issue to be determined by the penal law of the State having jurisdiction over the incident in question. Conduct that may constitute a criminal offence in the State of embarkation, the State of registration of the aircraft, the State of the operator or the State of the perpetrator or victim may not be a criminal offence in the country where an unruly passenger disembarked. 14 Journal of Aviation Management 2014
Air Law Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention Police or prosecution authorities, in practice, may not pursue an unruly passenger at all because they are not certain how the offending conduct fits into the scope of their domestic criminal law. In many cases, authorities simply prefer to release the passenger to his or her onward journey. In IATA’s view, some elaboration of the types of conduct prohibited would improve certainty for passengers, law enforcement authorities and airlines. Right of Recourse Unscheduled landings to disembark or deliver unruly passengers to State authorities have a significant impact on a carrier’s operating costs. A single diversion can cost anything from US$6,000 to US$200,000. For example, long haul flights may need to jettison fuel prior to landing to comply with the aircraft’s maximum landing weight limits. Other costs, such as landing fees, accommodation, ground-handling charges, passenger compensation and fuel uplift to complete the onward journey are also incurred. In many cases, crew will reach their maximum number of hours under applicable flight and duty time rules, meaning that a new crew will have to be flown in to operate the onward journey. Carriers may seek to recover these expenses from unruly and disruptive passengers through civil proceedings or some form of judicial restitution order in the context of criminal proceedings. However, the Convention is silent on a right of recourse and carriers are usually left to bear the significant cost of these events themselves. In particular, if the passenger in question leaves the jurisdiction, it will often be difficult or impossible to recover these losses. Allowing carriers the prospect of recovering the operational and post-incident costs arising from an unruly passenger incident would have a strong deterrent effect. Temporal Scope The Convention only applies when the aircraft is “in flight”, which is considered to be “from the moment when power is applied for the purpose of take-off until the moment when the landing run ends.” This is at odds with the Convention for the Unification of Certain Rules Relating to International Carriage by Air (McGill University, 2012) and the Convention for the Unification of Certain Rules for International Carriage by Air (ICAO, 1999), commonly known as the Warsaw 1929 and Montreal 1999 Conventions respectively, which deal with air carrier liability. Under those Conventions, the carrier is potentially liable to its passengers for an accident which occurs from the point of initial embarkation up until the point of disembarkation. Thus, an unruly passenger could cause injury to another passenger during embarkation and for which the airline would be liable under the Warsaw/Montreal regime. However, that same unruly passenger would not be liable of committing an offence or other unlawful act under the Tokyo Convention. Journal of Aviation Management 2014 15
Air Law Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention The recent Convention on the Suppression of Unlawful Acts Relating to International Civil Aviation (ICAO, 2010) adopts a broader scope to that of the Tokyo Convention. Under this Convention, “an aircraft is considered to be in-flight at any time from the moment when all its external doors are closed following embarkation until the moment when any such door is opened for disembarkation”. In IATA’s view, the temporal scope of the Tokyo Convention should reflect the period during which the aircraft commander’s powers apply. THE ROAD TO REVISION In 2009, the increase in unruly passenger incidents led IATA to make a formal request to the Legal Committee of ICAO to review and enhance the Tokyo Convention to allow law enforcement authorities adequate means to pursue offenders. A stronger legal framework that operators can rely upon would have a strong deterrent effect. ICAO subsequently established a Secretariat Study Group on Unruly Passengers and in October 2011 agreed that the issue of unruly passengers needed to be addressed by the international community and that the Tokyo Convention should be reviewed. A Special Sub-committee of the Legal Committee was then created to review the Tokyo Convention. The 35th Session of the Legal Committee held in Montreal from 6 to 15 May 2013 considered a draft text of a Protocol to revise the Tokyo Convention and decided to submit the text to the ICAO Council. At its 11th Meeting of its 199th Session, the Council decided to convene a Diplomatic Conference to amend the Tokyo Convention from 26 March to 4 April 2014. THE MONTREAL PROTOCOL 2014 – KEY CHANGES The Diplomatic Conference to amend the Tokyo Convention was concluded on 4 April 2014. It adopted the Protocol to amend the Convention on Offences and Certain other Acts Committed on board Aircraft’ (“the Protocol”) (ICAO, 2014) and includes the majority of the revisions that the airline industry through IATA had advocated for. Together with the operational measures already being taken by airlines to prevent and manage unruly passengers, IATA strongly believes that the Protocol will provide an effective deterrent for unruly behaviour by making the consequences of such behaviour clear and enforceable. The key changes are outlined below. Extension of Jurisdiction A significant majority of States at the Diplomatic Conference supported the extension of mandatory jurisdiction to the State of landing. However, several States expressed concerns about the impact of extending jurisdiction relating to legal certainty and proportionality, particularly where the aircraft commander decides to divert to a third country to disembark an unruly passenger. A Working Group was established during the Conference in an attempt to 16 Journal of Aviation Management 2014
Air Law Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention seek consensus. The result was that the Protocol gives mandatory jurisdiction to the intended State of landing (the scheduled destination). If the aircraft diverts to a third State, that State is still competent to exercise jurisdiction at its discretion. However, two safeguards were included as a compromise. Firstly, the offence must be sufficiently serious i.e. where the safety of the aircraft or of persons or property therein, or good order and discipline on board is jeopardised. Secondly, the State of landing must ascertain if the offence is considered an offence in the State of operator. States overwhelmingly supported the industry position and the Protocol establishes mandatory jurisdiction for the State of operator. This takes account of the increasing trend towards dry leasing aircraft where the State of aircraft registration is not necessarily the State of operator. The extension of jurisdiction will close the existing gaps in the Convention, giving States the legal tools they require to deal with unruly passengers. Definition of Offences The Protocol clarifies certain behaviours which should be considered, at a minimum, as an offence and encourages States to take appropriate criminal or other legal proceedings. These include physical assault or a threat to commit such assault against a crew member and refusal to follow a lawful instruction given by or on behalf of the aircraft commander (for safety purposes). In addition, the Conference passed a Resolution to update ICAO Circular 288 (ICAO, 2002) which establishes a detailed list of offences and model legislation that States can use when developing their domestic legislation. The elaboration of the types of conduct prohibited will improve certainty for passengers, law enforcement authorities and airlines. Right of Recourse The Protocol recognises the expressed right of airlines to seek compensation from unruly passengers at their discretion. The presence of this clause should have strong deterrent value. Scope The Protocol effectively brings the scope of the Tokyo Convention in line with other international air law instruments, giving greater certainty to carriers. THE CHALLENGE Whilst the Protocol will undoubtedly close many of the gaps in the Convention and will have a strong deterrent effect, it will only be effective if States become parties to it. The Protocol will enter into force when 22 States have deposited their instruments of ratification, acceptance, approval or accession at ICAO. Changes to domestic laws are often a prerequisite for ratification Journal of Aviation Management 2014 17
Air Law Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention of international treaties. Thus, given the vagaries of the different legislative systems and domestic political agendas, it is likely to be some time before the Protocol enters into force and even longer until it is widely ratified. Recent experience of other aviation law instruments supports this thesis. For example, the Montreal Convention 1999 (ICAO, 1999) which deals with air carrier liability has been in force for over a decade, but only 55 per cent of ICAO States are parties to it. IATA and its regional airline association partners are working with other key stakeholders to advocate for governments to prioritise the ratification of the Protocol as a key element of a wider strategy to deal with the growing problem of unruly passengers. THE NEED FOR A COMPREHENSIVE, MULTI-STAKEHOLDER APPROACH Whilst its importance cannot be understated, the new Protocol is only one element of a wider range of measures needed to effectively deal with the issue of unruly passenger behaviour. IATA has been working with its membership to develop a set of core principles (see Appendix A) which set out a comprehensive approach to tackling the issue. These principles highlight the need for governments and the wider aviation industry to work together and were unanimously endorsed at the 70th IATA Annual General Meeting in Doha in June 2014. The principles serve as industry acknowledgement of its responsibility to implement effective policies and procedures (such as de-escalation techniques, restraint and responsible service of alcohol training) that help prevent and manage unruly passenger incidents, whilst highlighting the need for governments to provide a strong international legal framework that is a stronger deterrent to unruly behaviour. Significantly, the principles also outline the need for wider stakeholder participation to help tackle this problem by taking measures to prevent issues in the air. Recent experience in the United Kingdom showed that such initiatives have been effective in reducing unruly behaviour on board flights (Daily Telegraph, 2014). Initiatives should include airport operators and airport concessionaires ensuring appropriate awareness training is provided to staff in the responsible sale and service of alcohol, etc. Ground handling agents and security service providers (e.g. screeners) are also requested to ensure their staff report unruly behaviour to the airline representatives so that they can make an informed decision on whether to accept a passenger for travel. CONCLUSION Airlines are working on numerous operational initiatives to prevent and manage unruly passenger incidents, but the industry cannot deal with the issue alone. A comprehensive and balanced approach as set out in the core principles is needed. 18 Journal of Aviation Management 2014
Air Law Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention By adopting the Montreal Protocol 2014, States have publicly recognised the increased frequency and severity of unruly passenger incidents and the inherent threat to safety, security and good order on board aircraft. The Protocol represents a once-in-a-generation opportunity for governments to put in place an international legal instrument which gives them the means to deal with unruly passengers more effectively and to deter future incidents. Therefore, urgent and widespread ratification of the new Protocol is needed. Taken together with measures being implemented by the airline industry, this will lead to a safer and a more pleasant air travel experience for all. Journal of Aviation Management 2014 19
Air Law Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention Appendix A – Industry Principles on Unruly Passengers 1. The Tokyo Convention 1963 as amended by the Montreal Protocol 2014 is a modern and effective international legal framework to deal with unruly and disruptive behaviour on board aircraft. Therefore, States should ratify the Montreal Protocol 2014 and implement consequential changes to national legislation as soon as possible; 2. As an important complementary measure, governments should consider legislation to establish jurisdiction over offences and acts committed on board foreign civil aircraft that subsequently land in their territory with an offender still on board; 3. Governments should apply ICAO Circular 288 – Guidance Material on the Legal Aspects of Unruly/Disruptive Passengers, and any subsequent updates thereto, as a guide for the development of national legislation; 4. Governments and national authorities should seek to raise public awareness of the consequences resulting from a failure to follow crew instructions or other behaviour which disturbs good order and discipline on board aircraft; 5. Where not already in place, member airlines should implement a policy for the consistent and effective handling of unruly passengers that reflects IATA Recommended Practice 1798a and the IATA Guidance on Unruly Passenger Prevention and Management; 6. Member airlines should develop appropriate training programmes for crew and ground service personnel that focus on prevention and management and include components dealing with the responsible service of alcohol (where applicable) and conflict de-escalation techniques; 7. Member airlines should clearly communicate to passengers the consequences and sanctions applicable to unruly and disruptive behaviour on board aircraft, generally and through the use of graduated warnings, as appropriate in specific cases; and 8. Airport operators, airport concessionaires and security providers are urged to engage with industry efforts by establishing procedures in respect of unruly and disruptive behaviour and, in particular, reporting their relevant observations about conduct on the ground. 20 Journal of Aviation Management 2014
Air Law Unruly Passengers: The Airline Industry Perspective on the Revision of the Tokyo Convention References ICAO. (1970). Doc 8920 – Convention for the Suppression of Unlawful Seizure of Aircraft. Montreal. International Civil Aviation Organization. ICAO. (1971). Doc 8966 – Convention for the Suppression of Unlawful Acts against the Safety of Civil Aviation, Montreal. International Civil Aviation Organization. ICAO. (1980). Doc 9318 – Protocol Relating to an Amendment to the Convention on International Civil Aviation. Montreal. International Civil Aviation Organization. ICAO. (1999). Doc 9740 – Convention for the Unification of Certain Rules for International Carriage by Air. Montreal. International Civil Aviation Organization. ICAO. (2002). Circular 288 – Guidance Material on the Legal Aspects of Unruly/Disruptive Passengers. Montreal. International Civil Aviation Organization. ICAO (2009a). Doc 9919 – Convention on Compensation for Damage Caused by Aircraft to Third Parties. Montreal. International Civil Aviation Organization. ICAO. (2009b). Doc 9920 – Convention on Compensation for Damage to Third Parties Resulting from Acts of Unlawful Interference Involving Aircraft. Montreal. International Civil Aviation Organization. ICAO. (2010a). Doc 9960 – Convention on the Suppression of Unlawful Acts Relating to International Civil Aviation. Montreal. International Civil Aviation Organization. ICAO. (2010b). Doc 9959 – Protocol Supplementary to the Convention for the Suppression of Unlawful Seizure of Aircraft. Montreal. International Civil Aviation Organization. McGill University. (2012). Convention for the Unification of Certain Rules Relating to International Carriage by Air. [WWW] http://www.mcgill.ca/files/iasl/warsaw1929.pdf (19 October 2014). ICAO. (2013). ICAO Working Paper, LC/35-WP/2-3, pp. 2, B1-B5 – Views of the International Air Transport Association (IATA) on Some of the Practical Aspects of the Issue of Unruly Passengers. Montreal. International Civil Aviation Organization. IATA. (2014). STEADES: Global Aviation Safety Data Sharing Program. [WWW]. http://www.iata.org/services/ statistics/gadm/steades/Pages/index.aspx (19 October 2014). ICAO. (2014) Protocol to Amend the Convention on Offences and Certain other Acts Committed on board Aircraft. [WWW] http://www.icao.int/secretariat/legal/Docs/Protocole_mu.pdf (19 October 2014). Reed Business Information Ltd. (2014). Ascend Online Fleets. [WWW]. http://www.ascendworldwide.com/ what-we-do/ascend-data/aircraft-airline-data/ascend-online-fleets.html (19 October 2014). The Daily Telegraph. (2014). Police Crackdown on Airport Drinking Halves Trouble on Planes [WWW] http://www.telegraph.co.uk/travel/travelnews/10834726/Police-crackdown-on-airport-drinking-halves- trouble-on-planes.html (16 May 2014). Journal of Aviation Management 2014 21
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