Written by Amy Bonds

In the past twenty years, plane seats, pitch (space between two chairs) and bathrooms have continued to shrink for one reason, money. Plane manufacturers and airlines can increase their profits if they are able to get more people on the plane. Flyer’s Rights, a non-profit airline consumer organization, estimates only 20% of the US population can comfortably fit into plane seats, leading to health and safety violations(1).

The Federal Aviation Administration (FAA) is currently asking for public comment about the size of airline seats. This call is in response to their safety evacuation testing which found the size of seats did not affect the effectiveness of an evacuation(2). Looking more closely at the data, the trial had a very limited sample size. Researchers excluded children, individuals over 60, and people with disabilities. The population of children in the U.S. is 73 million according to The State of America’s Children 2021 by the Children’s Defense Fund(3). Individuals over the age of 60 represent 54.1 million people in the US according to the 2020 Profile of Older Americans by Administration for Community Living(4). According to the Centers for Disease Control and Prevention (CDC), people with disabilities account for 61 million people in the U.S(5). This means that over 50% of the U.S. population was not represented in these evacuation testing studies.

​Beyond the evacuation concerns, there are health and safety concerns related to the current size of seats and bathrooms. When folks cannot comfortably sit in the current cramped seats, the risk of deep vein thrombosis is elevated. Current airplane seats  are 16-18 inches wide, which is not inline with American’s with Disabilities ACT (ADA) seat requirements, ADA recommends between 28-32 inches wide. Airplanes should be required to have ADA compliant seats and bathrooms available on all flights. Bathrooms raise another health and safety concern. Many airlines have bathrooms that are only 24 inches wide, with very limited room to maneuver. This leaves many unable to use plane bathrooms due to inaccessibility. Many are left intentionally restricting their food or water intake in order to not need to use the bathroom on the plane. Knowing that if they have an emergency, they will not be able to use the bathroom. See example about this experience from a recent NYT piece(6).  Furthermore, dehydration is a major risk factor for deep vein thrombosis(7).

The FAA public comment is open until November 1, 2022, you can post your comment at https://www.regulations.gov/commenton/FAA-2022-1001-0001. I am not recommending having a form letter for comments as the directions discourage against it, stating that they won’t be considered. Instead here is a checklist of how to leave an informed comment on this forum.  

  1. Provide data or evidence to support your claims, which increases the likelihood of the comment being considered. Feel free to include any of the date provided in this post and make it your own. Recommend including the ADA in helping determine what the minimum seat and bathroom requirements should be. 
  2. Recommend increasing the size of seats to the minimum ADA requirement of 28 inches  Recommend increasing the pitch between seats to at least 35 inches
  3. Recommend increasing the size of bathrooms for accessibility
  4. Consider including personal information about how the lack of regulation in seat size has affected your life, which can strengthen your comment.

Additional Information that can be included in your comment:

  1. “Seats have continued to shrink by some airlines, and people are continuing to get larger,” said Paul Hudson, president of FlyersRights.org. “Our estimate is that only 20% of the population can reasonably fit in these seats now. It’s beyond a matter of comfort, or even emergency evacuation, there are serious health and safety issues when you’re put in cramped conditions for hours on end.” https://www.usatoday.com/story/travel/airline-news/2022/07/29/airplane-seat-size-faa-public-comments/10154050002/
  2. “Average leg room has gone from 35 inches to 31 inches and as low as 28 inches on some airlines.” https://flyersrights.org/f/the-case-of-the-incredible-shrinking-airline-seat
  3. Average seat on a plane is 16-18 inches and accessible seating is 28-32 inches https://www.bloomberg.com/news/articles/2022-08-03/faa-seeks-comments-on-airline-seat-sizes-some-advocate-for-inclusive-seating
  4. “This invitation will include the opportunity to provide information regarding minimum seat dimensions necessary for passenger safety as they pertain to children, individuals over 60, and individuals with disabilities, because the CAMI study did not include participants from those communities” (PL-115-254-Sec-337-Aircraft-Cabin-Evacuation-Standards.pdf, 2)
  5. “Why are human beings forced to sit in such close proximity that passengers paying hundreds of dollars can’t be spared this dilemma? The fault is not with ourselves or our neighbors, but with an air travel industry squeezing every last nickel out of its seating plans without the slightest worry of government intervention.” https://www.baltimoresun.com/opinion/editorial/bs-ed-0218-airline-seating-faa-20200218-qx7q6zjmmfga5auq4hrgtztqqm-story.html
  6. The Department of Transportation Office of the Inspector General report about the need to update emergency protocol. “According to DOT OIG 2020 report, FAA Has Conducted Insufficient Research on Passenger Behaviors and Demographics, and Seat Dimensions To Determine How They Affect Standards.  https://www.oig.dot.gov/sites/default/files/FAA%20Oversight%20of%20Aircraft%20Evacuations%20Final%20Report%20-%2009-16-20.pdf

1.​www.usatoday.com/story/travel/airline-news/2022/07/29/airplane-seat-size-faa-public-comments/10154050002/
2. PL-115-254-Sec-337-Aircraft-Cabin-Evacuation-Standards.pdf, 2
3.https://www.childrensdefense.org/state-of-americas-children/soac-2021-overview/#:~:text=CHILD%20POPULATION%3A%20America’s%20children%20are,majority%20of%20children%20under%205.
4. https://acl.gov/sites/default/files/Aging%20and%20Disability%20in%20America/2020ProfileOlderAmericans.Final_.pdf
5.www.cdc.gov/ncbddd/disabilityandhealth/infographic-disability-impacts-all.html#:~:text=61%20million%20adults%20in%20the,is%20highest%20in%20the%20South.
6. www.nytimes.com/2022/08/08/travel/air-travel-wheelchair.html 
7.nyulangone.org/conditions/deep-vein-thrombosis/prevention#:~:text=Dehydration%20contributes%20to%20the%20development,periods%2C%20such%20as%20while%20traveling.