BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

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In the matter of: :

:

Final Rule :

Accessibility of Aircraft and : Docket No. DOT–OST–2011–0098

Stowage of Passenger Wheelchairs :

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REQUEST TO EXTEND CLOSET PLACARDING EFFECTIVE DATE

Airlines for America, on behalf of its members, has a fundamental interest in meeting the new

wheelchair stowage rule that is currently scheduled to take effect on January 13, 2014. To that end,

we request that the Department extend the effective date of the closet placarding component of that 

rule by nine months, to October 13, 2014.

The wheelchair stowage final rule was published on November 12, 20131and requires carriers to 

stow up to two collapsible manual wheelchairs in the cabin on any aircraft with 100 or more 

passenger seats by one of two methods: (1) strap the collapsible manual wheelchairs to a row of 

seats or (2) install a closet with minimum dimensions.2 If the carrier chooses to install a closet, or 

already has appropriately sized enclosures on some aircraft, the carrier must install a sign or placard 

prominently on the closet indicating that assistive device stowage takes priority over other items, 

such as crew luggage.3 This rule provides important operational flexibility that enhances the ability 

of air carriers to accommodate passengers with collapsible wheelchairs. We appreciate the 

Department’s approach to stowing collapsible manual wheelchairs in the aircraft cabin and believe 

it strikes the right regulatory balance. 

Regarding the placard component, we estimate the closet signage/placarding requirement applicable 

to aircraft with 100 or more seats impacts approximately 4,100 A4A member aircraft in the U.S. 

fleet. The ability of carriers to comply with the placarding requirement varies widely due to fleet 

diversity. Of A4A members, for example, one carrier will have to separately design solutions for 28 

different aircraft interior configurations. That carrier estimates a flow time of nine months, and 

states that they doubt that closet placards can be procured, much less designed, approved and

installed, before the effective date of the rule. Other A4A members agree that placard installation is 

a lengthy process and are in similar compliance situations with dozens of aircraft interior 

configurations.

 

1

78 Fed. Reg. 67918.

2

14 CFR 382.67(a).

3

14 CFR 382.(c).
2

The steps that an airline must accomplish include: 

1) Design/engineering of the needed placards 

2) Approval of the placards by FAA

3) Incorporation in drawings and maintenance documentation

4) Procurement

5) Installation on aircraft

An extension of time is warranted in this case because of the time to execute the above listed steps. 

The engineering design process with variations to cover more than two dozen fleet types at a single 

operator can be expected to take up to three months. One key component not factored into the 

existing short time-line is that FAA will have to approve all placarding, even a temporary paper sign 

posted on a closet, before installation. The process to gain approval for permanent placarding for 

over two dozen aircraft interiors will be a lengthy, multi-month process. After FAA approval, parts 

and placards must be procured, also a multi-month process. In order to assure consistent installation, 

it will be advantageous to place the placards and kits during scheduled maintenance visits, which is 

preferred over nightly maintenance opportunities at “out” stations that would require carriers to 

provision placards throughout their respective networks. Even with nine- months’ relief, some 

activity will still need to be assigned to overnight visits at line stations.

Finally, we believe that onboard personnel and the flying public will be best served if a few weeks 

are invested in developing an industry consensus on the appearance and wording of closet placards. 

Under a rushed attempt to meet the current, unattainable schedule, the public will encounter a 

variety of solutions causing passenger and crew confusion. Accelerating solutions to market without 

coordinated efforts to encourage consistency at the outset will degrade signage and will take years 

to unravel through attrition and replacement. The final rule’s extremely short compliance time 

equates to an emergency-level implementation of aircraft interior modifications used only in safety 

or security situations such as after the tragedies of September 11, 2001. It is not in the public 

interest to use emergency procedures in this case when more time will greatly improve the 

industry’s ability to provide consistent and accurate signage.

Accordingly, we respectfully request that the Department extend the effective dates for section 

382.67(c) for nine months, until October 13, 2014.

Respectfully submitted,

 

Douglas Mullen

Assistant General Counsel

Air Transport Association of America, Inc.

1301 Pennsylvania Avenue, NW

Washington, DC 20004

202-626-4000

dmullen@airlines.org

December 6, 2013