BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

------------------------------------------------------

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

Air lines for America, on behalf of its mem bers, has a funda mental 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, 2013 1 and 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) st rap 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 placa rd

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 col lapsible 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, w e estimate the closet signage/placardin g 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 me mbers, for exam ple, one carrier will have to separately design solutions for 28

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

sta t es that they doubt that closet placards can be procured, much less designed, approved a nd

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 proc ess. 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 night ly maintenance opportunities at “out” stations that would require carriers to

provision placards throughout their respective network s . Even with nine

- months’ relief, some

activity will still need to be assigned to over n ight visits at line stations.

Final ly, 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 wordin g of closet placards

. Under a rushed attempt to meet the current, unattainable sched ule, 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 attr ition and replacement. The final rule’s extremely short compliance time

equates to an e mergency

- 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

3 82.67(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