Petition for Rulemaking A Proposal to Establish Minimum Standards for Seat Pitch and Seat Width Submitted by : National Association of Airline Passengers

Page 1 of 10 Introduction Recent 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 manufacturer’s original des ign 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 cre ate conditions that can test the patience and equanimity of the most seasoned travelers and aircrews , and even lead to in flight altercations . N either seat width nor seat pitch is currently regulated by the FAA . FAA rules for seats on passenger planes a re 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/SB100014240527023043841045791419419 49066648Petition for Rulemaking A Proposal to Establish Minimum Standards for Seat Pitch and Seat Width Submitted by : National Association of Airline Passengers

Page 2 of 10 Proposal: The FAA should establish standards for minimum seat width and minimum seat pitch on trans port and commuter class aircraft. We recommend a minimum seat width of 19” , and a minimum seat pitch of 3 6 ” . 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: 3 6 inches Non reclining Bulkh

ead row seats (non exit rows) 38 inches § 25.8xy Minimum seat width. The minimum passenger seat width mus t 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 s afety 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 f

r om the knowledge that they could not be pl a ced at a competitive disadvantage by other carrier’s use of high density seating.Petition for Rulemaking A Proposal to Establish Minimum Standards for Seat Pitch and Seat Width Submitted by : National Association of Airline Passengers

Page 3 of 10 Passenger C omfort , Health, and S afety : 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 inches 2 . 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 show n below: 3 Mean Body Weight (Men) Age (y ea rs) 1960
– 19 62

(lbs) 1999
–2002

(lbs) 20

–29 164 183 30

– 39 170 189 40

– 49 169 19 6 50

– 59 168 195 60

– 74 159 192 However, a s 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 Boeing’s 777. While this may not affect the passenger’s 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 .html 3 http://www.cdc.gov/nchs/data/ad/ad347.pdf 4 http://online.wsj.com/news/articles/SB100014240 52702304384104579141941949066648 5 http://www.sfgate.com/news/article/Flight - Attendants - Fight - Air - Rage - They - say 2714238.phpPetition for Rulemaking A Proposal to Establish Minimum Standards for Seat Pitch and Seat Width Submitted by : National Association of Airline Passengers

Page 4 of 10 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 Sle ep Centre using polysomnography to record every standard physiological sleep measurement

– including monitoring brainwaves, eye, abdominal, chest a nd hip leg movement

– on a selection of passengers revealed that a minimum seat width of 18 inches improved passenger sleep quality by 53% when compared to the 1950’s 17 inch standard . 6 Seat Pitch: Decreases in seat pitch have had an even more significan t 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

– Te rry 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 Wilson 9

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/Petition for Rulemaking A Proposal to Establish Minimum Standards for Seat Pitch and Seat Width Submitted by : National Association of Airline Passengers

Page 5 of 10 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 (6’3”) 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 pas senger’s need for greater legroom in economy by offering this as an extra cost option. Examples include United’s Economy Plus, Delta’s Economy Comfort, and American’s Main Cabin Extra. Passenger Health : Respriatory I llness: We believe th at higher densit y 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 idea

l 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 s pecifically refer to the possibility of catching infections TB in flight as “realistic,” especially on flights of more than eight hours. “ 11

10 http://www.t elegraph.co.uk/travel/733141/Virgin - pays - for - lack - of- legroom.html 11 The Global Threat of New and Reemerging Infectious Diseases, Page 16. http://books.google.com/books?id=EV2xStafCMYC&pg=PA16&lpg=PA16&dq=overcroweded+ plane s+spread+disease&source=bl&ots=xVT6q34v96&sig=RTBaDMPc_G99S5T0GeZsPpSeX DY&hl=en&sa=X&ei=6bT - U8jTHdimggS -Petition for Rulemaking A Proposal to Establish Minimum Standards for Seat Pitch and Seat Width Submitted by : National Association of Airline Passengers

Page 6 of 10 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 be lieve s maller 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 heavi er 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 o f 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%20disea se&f=false 12 http://www.telegraph.co.uk/travel/733141/Virgin - pays - for - lack - of- legroom.html 13 http://consumer.healthday.com/encyclopedia/work - and - health - 41/occupational -health - news - 507/anger - at 32 - 000 - feet- 648505.htmlPetition for Rulemaking A Proposal to Establish Minimum Standards for Seat Pitch and Seat Width Submitted by : National Association of Airline Passengers

Page 7 of 10 “In humans, o

vercrowding 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 a irlines 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. Fli ghts 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 ar e 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 ava ilable to passengers. )

14 http://www.psychlotron.org.uk/resources/environmental/A2_OCR_env_crowdeffects.pdf 15 http://www.sfgate.com/ne ws/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 - istPetition for Rulemaking A Proposal to Establish Minimum Standards for Seat Pitch and Seat Width Submitted by : National Association of Airline Passengers

Page 8 of 10 Leveling the Pl aying 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 f rom 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 standa rd 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 o perator would not risk being placed at a competitive disadvantage by an other 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 p aid 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 small er 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/Petition for Rulemaking A Proposal to Establish Minimum Standards for Seat Pitch and Seat Width Submitted by : National Association of Airline Passengers

Page 9 of 10 Another common complaint concerns the extent to which seats impinge on other passenger’s “space” when they recline. This has led to the development and use of devi ces such as the K nee D efender

19 , and a corresponding increase in conflict on board aircraft. I ncreased seat pitch would tend to reduce conflict between passengers who want to recline and those who don’t . Costs and Regulatory Burden: We do not anticipate si gnificant additional regulatory costs to establish this standard. However, t he 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, o perators should be encouraged to refrain from purchasing or installing smaller seats, and be encouraged to a djust seat pitch on existing aircraft to meet a more comfortable s tandard. Many airlines are already doing this for a limited number of economy seats. 20 Changes to increase seat pitch could b e implemented relatively easily. S eats are mounted on tracks, an d 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.html 20 (United’s Economy Plus, Delta’s Economy Comfort, and American’s Main Cabin Extra)Petition for Rulemaking A Proposal to Establish Minimum Standards for Seat Pitch and Seat Width Submitted by : National Association of Airline Passengers

Page 10 of 10 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 sea ts. 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 today’s 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. T here is precedent for the regulation of space allotted to passenger s 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 Director National Association of Airline Passenge rs 703 - 485 - 1498