Nearly four years after Congress directed the US Federal Aviation Administration to issue, after notice and comment, minimum dimensions for aircraft “seat pitch, width, and length” as deemed necessary for passenger safety, the FAA is now soliciting that very input from the public.

“The FAA seeks public comment on the minimum seat dimensions that are necessary for passenger safety,” it says in a notice published to the Federal Register on 3 August. Comments are being accepted for a total of 90 days.

The agency stresses that it is not seeking comment about how seat size might affect passenger comfort or convenience. Rather, it strictly wants feedback on whether or not minimum seat dimensions (including seat pitch, width, and length) may be necessary for safety, especially during aircraft evacuations.

FAA regulations require airframers to demonstrate that all passengers and crew can evacuate an aircraft within 90 seconds by conducting live demonstrations of simulated evacuations or through a combination of analyses and testing.

In its 3 August notice, the FAA says comments from the public that include technical data will be the most helpful to the agency.

That sounds like a tall order. Just how many travelers are sitting on technical data concerning aircraft evacuations? Even so, thousands of people have already weighed in.

“I have no specific technical comments about safety and the ability to fully evacuate a plane within 90 seconds, however I believe it is imperative that you include in your testing people that are in fact handicapped and older than 60,” states one commenter. “Not doing so would provide false and unreliable data. As a frequent traveler there are countless older passengers and a small number of handicapped passengers on each of my flights.”

Another commenter urges the FAA to consider how passenger size affects egress. “Our tall family of four have inseams between 34 and 38 inches. We have found that as airlines reduce the pitch, our legs fall asleep quickly from being forced into unnatural positions. When given a chance to stand, it takes 1-2 minutes for the blood to flow to allow movement to take place. This is easily a safety issue should we need to evacuate quickly. (We used to be granted exit row seating simply because we are tall, but now airlines use this row as another money maker.)”

Still another recommends the FAA consider that “physical and psychological comfort contribute to decisive and smooth action in case of an emergency. Appropriate personal space has also contributed to cooperation and collaboration.”

Historically, the FAA has not seen fit to regulate aircraft seat size, despite pressure and indeed lawsuits from Flyers Rights. Explaining its rationale to the consumer advocacy group in 2018, the FAA said: “The time it takes passengers to get out of their seats, even if those seats are relatively narrow and close together, is less than the time it takes for the emergency exits to begin functioning and for the line that begins forming in the aisles to clear.”

At that time, it said it had no evidence that a typical passenger — “even a larger one” — will take more than a couple of seconds to get out of his or her seat.

But in order to carry out the requirements of the FAA Reauthorization Act of 2018 — the legislation which directed the FAA to issue minimum seat standards — the administration chartered an Emergency Evacuation Standards Aviation Rulemaking Committee (ARC).

The committee, comprising dozens of  aviation stakeholders, including the US NTSB, Europe’s EASA, the Allied Pilots Association, the Association of Flight Attendants and Flyers Rights, met between October 2019 and May 2020 to review nearly 300 real-world evacuation events that occurred over the previous decade.

“The ARC found the overall level of safety in emergency evacuations to be very high, but made 27 recommendations to the FAA related to how the safety of such evacuations could be improved,” explained the FAA. For instance it identified several events where better communication would have enhanced the evacuation. (PDF)

In late 2019 and early 2020, the FAA also conducted simulated emergency evacuations at the Civil Aerospace Medical Institute (CAMI), the medical certification, research, education, and occupational health wing of the FAA’s Office of Aerospace Medicine.

“In these tests, seat size and spacing did not adversely affect the success of emergency evacuations. CAMI recommended, however, that the FAA continue to monitor anthropometric issues related to passenger seats,” stated the FAA in its 3 March 2022 report to Congress. (PDF)

Notably, the FAA said it “recognizes that the CAMI tests relied on able-bodied adult subjects under age 60, consistent with regulatory and ethical standards for human testing. As a result, they provide useful, but not necessarily definitive information, regarding the effects of seat dimensions on safe evacuations for all populations.”

Even as the FAA was conducting this work, the US Department of Transportation’s Office of Inspector General was doing its own audit of the FAA to assess the agency’s process for developing and updating aircraft emergency evacuation standards, including how changes in passenger behavior, passenger demographics, and seating capacity affect the standards.

It found that the FAA process for updating its evacuation standards lacks data collection and analysis on current risks. In its September 2020 report, the DOT IG stated:

FAA largely updates evacuation standards only after accidents and it conducted its last update based on an accident in 1991.

FAA also has not conducted sufficient research on passenger behaviors — such as evacuations with carry-on bags and the presence of emotional support animals — and seat dimensions to show how they affect evacuation standards.

Furthermore, FAA does not collect comprehensive evacuation data to identify needs for regulation updates, and allows manufacturers to use decade-old data in evacuation analyses. FAA’s Safety Management System requires FAA programs to collect and analyze comprehensive data using systematic procedures and policies for the management of safety risk.

However, FAA has not established a systematic process to obtain and evaluate data from accidents and demonstrations. As a result, FAA is inhibiting its ability to identify current evacuation risks and updates to its aircraft emergency evacuation standards.

The DOT IG made two recommendations to help the FAA improve its data collection and analysis for developing and updating aircraft emergency evacuation standards, saying that the FAA concurred with both recommendations.

In January of this year, Flyers Rights filed a petition in the DC Circuit seeking to order the FAA to issue minimum airline seat size standards, noting that the FAA had not even started the required rulemaking outlined in 2018 FAA Reauthorization legislation, though the statutory deadline for FAA action had passed more than two years earlier.

Now that the FAA has finally posted its notice in the Federal Register, it is accepting comments from the public for a total of 90 days. There has, perhaps, never been a better opportunity for passengers’ voices to be heard on this issue. But it seems that any seat comfort-focused complaints will fall on deaf ears. The FAA encourages commenters to review the CAMI report, and other materials in the docket, prior to commenting.

For its part, a Flyers Rights representative in 2017 told Runway Girl Network that the group was fighting for minimum seat pitch and seat width standards of 28 inches and 18 inches, respectively.

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