In December 2019 the US Department of Transportation proposed adjustments to lavatory sizes and other accommodations on single-aisle aircraft, suggesting that the costs would be relatively low and that the overriding value to passengers is worth the effort. The changes are minimal and many advocates suggest insufficient to truly address the needs of an ever-growing population of passengers with reduced mobility (PRMs). And yet still objections from the airlines are being raised, and from an unlikely player.
The proposed lavatory changes
In what the DoT calls “Tier 1” changes to lavatory accessibility airlines operating aircraft with 125+ seats must alter the bathroom designs. The new requirements dictate that on-board wheelchairs must be able to back in to a lavatory fully, allowing the door to close or partially enter forward, allowing a passenger with reduced mobility to “stand and pivot” into the toilet. The proposed rules also require grab bars and lift handles to be installed in at least one of the on-board lavs. Faucets and controls must offer tactile indicators and both the door lock and call button must be accessible to a passenger of the stature of the 5th percentile of female height while seated on the toilet.
Read More: Wheelchair accessibility regulations to be updated with Department of Transportation proposal
These adjustments do not fully address the needs of all passengers, though they would represent a good step in the right direction should they be adopted and implemented. But even then they would only apply to new aircraft and the target date is 2024, so not really changing the travel experience for this generation.
It took more than two months for a response to be filed to the DOT’s proposal. While other responses are expected, the first fights back against the specifications for on-board wheelchairs (OBWs), lavatory upgrades and training requirements.
Regarding the OBWs, a very reasonable objection is raised that a compliant option does not exist today:
A specific technology or methodology which appears promising on paper may not actually be feasible in practice and/or may be overtaken by innovative developments…[T]he design, certification, and manufacture of a new OBW may experience the first problem. No OBW is commercially available that meets the newly-proposed requirements, and it is not clear that those requirements ever can be practically met in a single product.
Not only are there technical challenges in developing the hardware but getting it manufactured and into aircraft cabins within 3-4 years is an aggressive timeline for a new product in the aviation world.
An on-board wheelchair costs $3,000 today and the revised model would likely be more expensive, especially with additional features and the compressed production timeline. But that’s not the biggest concern. In its proposed rules the DOT calls for updates to such that “Aircraft with 125 or more passenger seats would be required to have at least one lavatory with a number of accessibility features, including accessible door locks, flush handles, call buttons, faucets, and assist handles.” The Department estimates the costs of these modifications at $1,000 per lavatory. Or, if the airlines are to be trusted, perhaps the cost is likely to be hundreds of thousands of dollars. The objection filed estimates $200,000, though does not provide specific details on where that number comes from, other than its “experience with certifying and installing new onboard equipment.”
Finally, the DOT would require additional training for crewmembers in dealing with PRMs and the new facilities on board. An estimated 15 minutes of work would be dedicated to the topic during any given cabin crew training regimen according to the DOT. Given that the work is supposed to be hands-on and include access to a mock-up of the new lavatory design the airlines object both to the time required and the DOT’s lack of consideration for building the training mock-up ($30,000 estimate) and associated training development and record-keeping costs.
The unlikely voice
That there are objections and disputes about the costs should not be a surprise. That the first filing of such came from a Japanese airline that does not operate single-aisle aircraft to the United States is, however, rather unexpected. All Nippon Airways (ANA) is the carrier that filed these comments and its positioning is interesting.
The carrier admits directly that it does not operate any planes today that would be subject to the revised guidance, “but potentially could do so in the future.” Just how well the A321LR could serve ANA for flights to the USA is unclear, though Guam seems the most likely destination.
Moreover, the carrier is concerned about spill-over from the single-aisle ruling also affecting its twin-aisle aircraft somewhere down the line, “ANA also anticipates that the final rule in this proceeding will provide a template for updated requirements for lavatories and OBWs on twin-aisle aircraft.”
Finally, the airline points out that the training requirements as well as providing information to passengers about the availability of PRM-accessible lavatories on board would likely apply as it would have to indicate to passengers which features are available.
ANA also indicates in its filing that it expects the International Air Transport Association (“IATA”) and Airlines for America (“A4A”), two industry trade groups, to file similar briefs objecting to the new rules for various reasons. Again, no surprise that the airlines oppose making the product more accessible on board, even if that is an unfortunate path to choose.
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