U

.S. Deportment of Transportation Federal Aviation Administration



### MAR 1 

### 4 2016 Mr. Paul Hudson President FlyersRights.org Aircraft Certification Serv i ce

441 I Bee Ridge Road , #274 Sarasota, FL 34233
Dear Mr. Hudson: 800 Independence Avenue , SW. Wash i ngt on , DC 20591

Thank you for your Feb ruary 21 letter regarding the Federal Aviation Administration's (FAA) February I decision to dismiss your petition for rulemaking on seat size reductions , Docket No. FAA-2015-4011.
In your letter, you point out that the docket had not been updated to include the FAA's February 1 decision by the time you received our February 1 decision. Prior to making this decision, we full y reviewed your petition as well as the comments submitted to the docket.
In your letter, you request additional clarification on emergency evacuation tests. The FAA works directly with the airplane manufacturers to conduct the full-scale evacuation demonstrations required to justify the maximum passenger occupancy. The FAA is fully involved in these demonstrations, including approval of the test plan, inspecting and configuring the test article (airplane), and witnessing the tests. Multiple manufacturers have performed evacuation demonstrations below 30 -inch seat pitch, down to 28-inch seat pitch. The extensive data we have indicates seat pitch and width does not adversely affect evacuation times. As reques ted, references regarding seat and evacuation studies, as well as potential health issues, are enclosed.
We understand your concern for the safety of the traveling pubiic. The FAA is firmly committed to passenger safety. We will continue to monitor seat designs and effects on safety and health. Sincerely,

Dorenda D. Baker Director, Aircraft Certification Service
EnclosureList of References Passenger demographics:
1. FAA Report DOT/FAA/AM-01/2 "Access-to-Egress: A Meta-Analysis Of the Factors That Control Emergency Evacuation Through The Transport Airplane TypeIII Overwing Exit" http: / / v..rwvv. faa. gov 

### I data research/research/ med humanfacs /oamtechreQot1s/2 000s/m edia/0 1 02.pdf 2. FAA Report DOT /FAA/AM-03115 "Access-to-Egress II: Subject Management and Injuries in a Study of Emergency Evacuation Through the Type-III Exit" http://www.faa.gov/data research/res earch/med humanfacs/oamtechreports/2000s/ m edia/0315.pdf 3. FAA Report DOT/FAA/AM-04/2 ''Access-To-Egress III: Repeated Measurement of Factors That Control the Emergency Evacuation of Passengers Through the Transp ort Airplane Type-Ill Overwing Exit" http: //www.faa.gov/data research/research/rned humanfac s/oa mtcchrcports/2000 s/m edia/0402.pdf Deep vein thrombosis:
1. American College of Chest Physicians. Anti thrombotic Therapy and Prevention of Thrombosis, 9th ed: ACCP Evidence--Based Clinical Practice Guidelines. 6.1.1

- 6.1.3. Chest february 2012, Vo1141, No. 2_s uppl. http: // journal.publications.chestnet.org/article.aspx?articleiD = II59399. 2. Tsai 

### J , Grant AM, Beckman MG , Grosse SO. YusufHR

. Richardson LC. (2015) Determinan ts of Venous Thromboembolism a mong Hospitalization s of US Adults: A Multilevel Analysis. PLoS ONE 10(4): e0123842. doi: 1 O.l371/journal.pone.0123842. http://www.cdc.gov/ncbddd/clvt/feature s/exis ting-condition

- ho sp ital.html. 3. Mayo Clinic. Patient Care and Health Information. Deep vein thrombosis (DVT). Risk Factors. http://www.mayoclinic.org/diseases-conditions/d ccp-vei nthrombo s i s/basics/tisk-tactors/co n- 2003 1922. 4. Boyles S. New guidel ines debunk 'Economy Class Syndrome.' WcbMD. Feb. 7. 2012. http: //www. webmd .com /dvt/news/2 0 120?07 /new-guide! ines-debunkeconomy-class-syndrome. 5. Farber D. Does cancer cause blood clots? Dana-Farber Cancer In stitute. April 4, 2014. http:/ /blog.dana-farber.org/insight/20 14/04/does-cancer-causc-blood-clots /

. 6. James A. Women's health. National Blood Clot Alliance. https://www.stoptheclot,org/learn more/womens health**i~1q.htm.** 7. Cruickshank 

### J , Gorlin Rand Jennett B. Air travel and thromboti c epi sodes: the economy class syndrome. Lancet. 1988 Aug 27;2(8609):497-8.