As the stage lengths for single-aisle aircraft increase, bathroom needs for passengers who are unable to walk or stand are taking center stage in potential new rules that may affect airlines and airframers.
Those rules could come as soon as next year, assuming members of a government and industry committee that has its final meeting in October can agree on the changes.
Launched by the U.S. Transportation Department in April, the Accessible Air Transportation Advisory Committee is tasked with studying certain aspects of the 1986 Air Carrier Access Act (ACAA) as they relate to passengers with disabilities. Along with representatives of the Transportation Department, the FAA, Airbus and Boeing, committee members include those from United Airlines, JetBlue Airways and Delta Air Lines as well as a number of organizations that advocate for the disabled.
The committee’s conclusions about the definition of service animals, accessibility of inflight communications for hearing- and sight-challenged passengers, lavatory access on single-aisle aircraft and several other topics will be considered for what the department calls a “negotiated rulemaking.”
Of the three main topics, increased lavatory access for single-aisle aircraft is the most controversial and likely the most expensive for airlines and airframers to implement. Under FAA regulations, twin-aisle aircraft delivered after 2010 and operating in and to the U.S. are required to have at least one “accessible” lavatory, meaning in part large enough so a passenger in an onboard wheelchair can perform a seated transfer between the wheelchair and toilet.
There has been no parallel requirement for single-aisle aircraft, the logic being partly that use of a lavatory was not so much an issue on short flights. The FAA, in contemplating the negotiated rulemaking, noted an “industry trend” toward greater use of single-aisle aircraft not equipped with accessible lavatories for medium- and long-haul flights and recognized the disability community’s “distress” over the situation.
“The reality is that widebody aircraft are becoming scarce on trips to our state and are replaced by single-aisle aircraft,” says Michael Okamoto, chairman for the Disability and Communications Access Board for Hawaii in his comments to the department regarding the committee’s work. “This is a critical issue for individuals both in our state and coming to our state, as any out-of-state trip to or from another state is a minimum of 5 hr.”
The issue for airframers and airlines is the extra space needed for a seated-transfer lavatory. According to an accessibility study by Boeing, Airbus and several airline members of the committee, a single-aisle lavatory is typically 33-36 in. wide by 38 in. deep, but the accessible lavatory for a typical twin-aisle aircraft is 56 in. wide by 41 in. deep. Widening the lavatory by 23 in., at least for a Boeing 737, could require removing a row of seats or moving the lavatory. On the 737, the lavatories are typically located on either side of the cabin and the galley across the back. On Airbus A320-family airliners, the lavatories are typically along the rear wall of the cabin, providing more leeway for adaptations, including “cabin-flex” design options for side-by-side lavatories with a partition that opens for wheelchair access.
While removing a row of three seats in front of the lavatory or elsewhere would be the most obvious solution on many aircraft, the loss to the industry over the 25-year life of an aircraft would be 110,000 seats not sold, or 375 million seats not sold, considering all of the single-aisle aircraft in the U.S. fleet. The accessibility study from Airbus, Boeing and airlines concludes that the net loss on each of the unsold seats would be $98. And if the wider lavatories were required on new aircraft starting in 2018, the total loss to the airline industry through 2042 from three fewer seats on each flight would be $22 billion; $33 billion if the existing fleet is retrofitted.
“Much of the cost would be incurred by the public through higher fares, reduced service to marginally profitable locations and reduced seating availability,” says the study report from Airbus, Boeing and airlines.
Manufacturers and airlines are leaning toward a phased-in approach whereby no changes would be required on existing aircraft and minimal adjustments would be necessary on new single-aisle aircraft of existing designs starting two years after a final rule is published.
Adjustments include installation of a visual barrier around the lavatory entrance for privacy during a standing transfer, increased accessibility at airports, improved compatibility of onboard wheelchairs and enhanced flight attendant training. For new single-aisle type designs with more than 125 seats, the group suggests implementing the same rules as for twin-aisle aircraft.
What is not yet clear is the potential for lost revenue from “persons with reduced mobility” not flying or taking a different airline using single-aisle aircraft with larger lavatories.
“The airlines’ narrow focus on short-term profits versus long-term gain is evident when it ignores the needs of 67% of would-be disabled air travelers who . . . avoid air travel due to the absence of accessible lavatories,” says one commenter to the Transportation Department.