national association of airline passengers - exemption rulemaking

Petition for RulemakingA Proposal to Establish Minimum Standards for Seat Pitch and Seat Width

Submitted by:National Association of Airline Passengers

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IntroductionRecent news reports indicate that many airlines are reducing seat pitch and seat width in order to increase the number of passengers that may be carried on aircraft.1 Some airlines are installing more seats than the manufacturers original design or recommended configuration.

Many passengers find this higher density seating, with its reduced legroom and smaller seats, to be uncomfortable, unhealthy, and even dangerous. When combined with full or oversold flights, higher density seating can create conditions that can test the patience and equanimity of the most seasoned travelers and aircrews, and even lead to in flight altercations.

Neither seat width nor seat pitch is currently regulated by the FAA. FAA rules for seats on passenger planes are limited to the following three items:

Seats and their supporting structure, safety belts and anchorages must be designed for an occupant weight of 170 pounds, (25.785)

Aisles must have a specified minimum width, (25.815) No more than three seats may be placed on either side of an aisle.

(25.817)

We believe there is a need for the FAA to set uniform, minimum standards for seat width and seat pitch.

1

http://online.wsj.com/news/articles/SB10001424052702304384104579141941949066648



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Proposal:

The FAA should establish standards for minimum seat width and minimum seat pitch on transport and commuter class aircraft. We recommend a minimum seat width of 19, and a minimum seat pitch of 36.

The proposed rule(s) might read as follows:

25.8xx Minimum Seat Pitch.The minimum passenger seat pitch at any point between seats must equal or exceed the values in the following table:All rows except exit and non reclining bulkhead row seats: 36 inchesNon reclining Bulkhead row seats (non exit rows) 38 inches

25.8xy Minimum seat width.The minimum passenger seat width must equal or exceed 19 inches.

Why the proposed standards would be in the public interest:

We submit that uniform, minimum standards for seat width and seat pitch would be in the public interest for the following reasons:

Passengers comfort, health and safety would be improved. Flight attendants would benefit from a working in a less stressful

environment. Manufacturers and Operators would benefit from fixed standard for all

aircraft, and from the knowledge that they could not be placed at a competitive disadvantage by other carriers use of high density seating.



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Passenger Comfort, Health, and Safety:

According to the CDC, the men and women have become heavier and larger. The waist of the average American has expanded by about 2.5 inches2. The mean body weight of men, which was below the 170 lb design requirement of 25.785 in 1960-1962, now significantly exceed this value, as shown below:3

Mean Body Weight (Men)Age

(years)19601962

(lbs)19992002

(lbs)2029 164 1833039 170 1894049 169 1965059 168 1956074 159 192

However, as noted in the Wall Street Journal Article, The Incredible Shrinking Plane Seat, (Oct 23, 2013)4 airlines are sliming seats and adding rows. For example, many airlines are switching from 9 abreast seating to 10 abreast seating in Boeings 777. While this may not affect the passengers comfort when load factors are low, it does significantly increase discomfort and stress when load levels are high. 5

2 http://www.bostonglobe.com/business/2013/12/23/skirmish-for-space-planes-makes-for-even-tighter-squeeze-smaller-seats/MDsspXtK6OW0BjdaLrhT8H/story.html3 http://www.cdc.gov/nchs/data/ad/ad347.pdf

4 http://online.wsj.com/news/articles/SB100014240527023043841045791419419490666485 http://www.sfgate.com/news/article/Flight-Attendants-Fight-Air-Rage-They-say-2714238.php



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Passenger Comfort

Seat Width: Decreases in seat width can have profound effects on passenger comfort. A research conducted by Harley Street medical practice The London Sleep Centre using polysomnography to record every standard physiological sleep measurement including monitoring brainwaves, eye, abdominal, chest and hip leg movement on a selection of passengers revealed that aminimum seat width of 18 inches improved passenger sleep quality by53% when compared to the 1950s 17 inch standard.6

Seat Pitch: Decreases in seat pitch have had an even more significant impact on passenger comfort, and on occasion have led to disputes and even physical altercations between passengers.7

The industry practice of squeezing more seats into planes will bring more such incidents in the future unless something is done.8 Terry Trippler, industry observer, writing for theplanerules.com

Even passengers of smaller stature are affected:"As airlines try and squeeze as many seats into economy as possible, that decreases seat pitch which can be uncomfortable for someone like me, who is 5'3". But imagine being a foot taller squeezed into that same space." Aviation Blogger Bennett Wilson9

6 http://www.airbus.com/presscentre/pressreleases/press-release-detail/detail/airbus-calls-on-aviation-industry-to-set-a-new-standard-for-long-haul-comfort/7 http://www.usatoday.com/story/todayinthesky/2014/08/26/knee-defender-fight-united-flight-diverted/14609109/8 http://www.kare11.com/story/news/local/2014/08/29/terry-trippler-reclining-seats-airlines/14828049/9 http://www.cnn.com/2014/08/29/travel/airline-passenger-seat-recline/



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Reduced and inadequate seat pitch is of particular concern to taller passengers. "Anyone over six feet tall is going to find the 30-inch seat (pitch) very uncomfortable for a long flight, and those of my height (63) will find it impossible," stated one passenger. My legs had to go sideways and unsafely into the aisle," he said.10

Many operators have begun to recognize and respond to their passengers need for greater legroom in economy by offering this as an extra cost option. Examples include Uniteds Economy Plus, Deltas Economy Comfort, and Americans Main Cabin Extra.

Passenger Health:

Respriatory Illness: We believe that higher density seating together with greater load factors produce an on board environment that is more conducive to the spread of respiratory illness among passengers and cabin crew.

overcrowded, poorly ventilated and (sometimes) unsanitary aircraft constitute ideal environments for the transmission of viruses and bacteria, particularly on long flights. Reflecting this, travel health guidelines issued by the World Health Organization (WHO) now specifically refer to the possibility of catching infections TB in flight as realistic, especially on flights of more than eight hours. 11

10 http://www.telegraph.co.uk/travel/733141/Virgin-pays-for-lack-of-legroom.html11 The Global Threat of New and Reemerging Infectious Diseases, Page 16. http://books.google.com/books?id=EV2xStafCMYC&pg=PA16&lpg=PA16&dq=overcroweded+planes+spread+disease&source=bl&ots=xVT6q34v96&sig=RTBaDMPc_G99S5T0GeZsPpSeXDY&hl=en&sa=X&ei=6bT-U8jTHdimggS-



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Deep Vein Thrombosis: Another area of concern relates to threat of Deep Vein Thrombosis, or DVT, sometimes referred to as Economy Class Syndrome. Long periods of inactivity in cramped accommodation such as aircraft seats have been linked with deep-vein thrombosis (DVT) - a condition that causes potentially fatal blood clots.12

DVT was already a concern of passengers before airlines began the recent move to higher density seating. We believe smaller seats and reduced seat pitch will combine to make movement of any kind even more difficult, and needlessly expose passengers to additional risk from this condition.

Safety:The average passenger, both male and female, is larger and heavier than

their counterparts of fifty years ago, yet the space allowed to each passenger is being reduced. This would appear to have significant implications in the event of an emergency evacuation.

Reducing Stress on Flight Attendants:

The Association of Flight Attendants-Commuication Workers of America (AFA-CWA) and the Federal Aviation Administration (FAA) have recorded hundreds of cases of abusive or disruptive passenger behavior on the major airlines each year over the past 15 years.13

_oGwDQ&ved=0CEsQ6AEwBQ#v=onepage&q=overcroweded%20planes%20spread%20disease&f=false12 http://www.telegraph.co.uk/travel/733141/Virgin-pays-for-lack-of-legroom.html13http://consumer.healthday.com/encyclopedia/work-and-health-41/occupational-health-news-507/anger-at-32-000-feet-648505.html



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In humans, overcrowding appears to result in a decline in task performance and deterioration in social behavior. 14

According to flight attendants, oversold flights, crowded planes and small seats are making passengers grumpier.15

The core problem is definitely the airlines packing too many seats too close together into a tight space. - Flight attendant & Author Heather Poole 16

The increase in air rage incidents probably stems in good part from the frustrations passengers are increasingly experiencing these days. Flights are overbooked, lines are long, and delays have become routine. Passengers are sardined into tiny seats with little legroom; overhead baggage compartments stuffed to the gills become battlegrounds, and the snacks and services passengers are offered are stripped to the bone. 17

(It should be noted that although higher capacity seating may allow an aircraft to carry more passengers, placing more seats in the plane does not increase the amount of overhead bin space or increase the number of lavatories available to passengers.)

14 http://www.psychlotron.org.uk/resources/environmental/A2_OCR_env_crowdeffects.pdf15 http://www.sfgate.com/news/article/Flight-Attendants-Fight-Air-Rage-They-say-2714238.php

16 http://www.cnn.com/2014/08/29/travel/airline-passenger-seat-recline/

17 http://www.airspacemag.com/flight-today/commentary-air-rage-relief-2517804/?all&no-ist



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Leveling the Playing Field

The lack of uniform, minimum standards for passenger seats decreases the ability of consumers to compare prices and services offered by various air carriers. The space available to passengers can vary from airline to airline and from plane to plane within airlines. A single uniform standard would insure that fares were, in fact, comparable.

Manufacturers and Operators

One manufacturer, Airbus, has already proposed making 18 inch seat width as the standard for long haul economy air travel.18

Likewise, we believe operators would benefit from the establishment of uniform, minimum seat standards throughout the industry. An operator would not risk being placed at a competitive disadvantage by another operator using a higher density seating plan.

Other Benefits:

A common complaint associated with smaller seats is that larger passengers impinge on the space of smaller passengers. These passengers rightly feel cheated when they are required to share space they paid for with a stranger, and without compensation. Increasing seat width to accommodate a majority of individuals would benefit all passengers, large and small. The larger passenger would not feel cramped in a seat that was too small for him, and the smaller passenger could enjoy their space without being imposed upon by their fellow passengers.

18 http://www.airbus.com/presscentre/pressreleases/press-release-detail/detail/airbus-calls-on-aviation-industry-to-set-a-new-standard-for-long-haul-comfort/



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Another common complaint concerns the extent to which seats impinge on other passengers space when they recline. This has led to the development and use of devices such as the Knee Defender19, and a corresponding increase in conflict on board aircraft. Increased seat pitch would tend to reduce conflict between passengers who want to recline and those who dont.

Costs and Regulatory Burden:

We do not anticipate significant additional regulatory costs to establish this standard. However, the FAA would need to consult with airlines to establish a reasonable and practical schedule to implement changes. Ideally, changes in seat width would be phased in over a period of years, allowing airlines to make changes as part of the normal maintenance and refurbishment of aircraft.

If the FAA were to adopt these rules, operators should be encouraged to refrain from purchasing or installing smaller seats, and be encouraged to adjust seat pitch on existing aircraft to meet a more comfortable standard. Many airlines are already doing this for a limited number of economy seats.20

Changes to increase seat pitch could be implemented relatively easily. Seats are mounted on tracks, and are no more difficult to move backward (to give passengers more legroom) than they are to move forward (to squeeze in more rows).

19 http://www.kneedefender.com/goods/kneedefender.html20 (Uniteds Economy Plus, Deltas Economy Comfort, and Americans Main Cabin Extra)



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We do not anticipate any additional recordkeeping or reporting burdens as a result of this proposed regulation, except for the need to update reservations systems to reflect the new configuration of aircraft. Airfares may need to be increased to make up for lost revenue; however passengers would be receiving a better product in the form of more legroom and more comfortable seats.

Conclusion:

We believe the regulation of seat width and seat pitch and the establishment of uniform minimum standards are in the best interest of passengers and operators, and would markedly improve the quality of the passenger experience. We do not believe there would be any greater cost associated with appropriately sized seats for todays passenger as compared to the smaller seats preferred by airlines. Finally, we believe that by relieving overcrowding on board aircraft, the incidence of air rage can be reduced.

There is precedent for the regulation of space allotted to passengers on vessels. The concept of minimum standards for passenger comfort and convenience of passengers can be traced back to The United States Passenger Act of 1819, if not further. While these laws applied to the carriage of passengers by ship, they provide useful lessons when considering the transport of passengers by air.

Respectfully submitted, Douglas Kidd, Executive DirectorNational Association of Airline Passengers703-485-1498

national association of airline passengers - exemption rulemaking

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