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 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/SB100014240527023043841045791419419

49066648
Petition 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 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 inches

Non 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 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 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)

1960–1962

(lbs)

1999–2002

(lbs)

20–29 164 183

30–39 170 189

40–49 169 196

50–59 168 195

60–74 159 192

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 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-tightersqueeze-smaller-seats/MDsspXtK6OW0BjdaLrhT8H/story.html

3 http://www.cdc.gov/nchs/data/ad/ad347.pdf

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

5 http://www.sfgate.com/news/article/Flight-Attendants-Fight-Air-Rage-They-say2714238.php
Petition 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 

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 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 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-aviationindustry-to-set-a-new-standard-for-long-haul-comfort/

7 http://www.usatoday.com/story/todayinthesky/2014/08/26/knee-defender-fight-united-flightdiverted/14609109/

8 http://www.kare11.com/story/news/local/2014/08/29/terry-trippler-reclining-seatsairlines/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 passenger’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 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.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+

planes+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 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%20disea

se&f=false

12 http://www.telegraph.co.uk/travel/733141/Virgin-pays-for-lack-of-legroom.html

13http://consumer.healthday.com/encyclopedia/work-and-health-41/occupational-health-news-507/anger-at32-000-feet-648505.html
Petition 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, 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.pdf

15 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
Petition 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 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-aviationindustry-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 devices such as the Knee Defender

19, 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 don’t. 

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.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 

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 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. 

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 Director

National Association of Airline Passengers

703-485-1498