Technical Feasibility of a Wheelchair Securement Concept for Airline Travel: A Preliminary Assessment (2021)

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9 1 Introduction Wheelchair securement systems for passenger use in airplane cabins are intuitively appealing as a solution to many of the hardships that people with disabilities and who are nonambulatory face when flying. Such systems are currently used and designed in accordance with widely accepted safety standards for public and private modes of surface transportation, including cars, vans, and transit buses. In using these systems, people who are non- ambulatory can board the vehicle in their personal wheelchair, stay seated in the wheelchair for the duration of the trip, and wheel off the vehicle upon reaching the destination. Indeed, the ability of people to travel while seated in their personal wheelchairs has been the norm for several decades, facilitated by public policies to ensure that people who are nonambulatory are afforded similar access as people who are ambulatory to employment, medical services, education, shopping, family and social events, and other activities and opportunities.1 A major exception to this norm has been airline transportation, which invariably requires that every passenger travel in an airplane seat. This requirement can greatly complicate access to air travel because of the need for passengers to transfer from and back to their personal wheelchairs and to use an airplane seat that does not accommodate their physical and medical needs for the duration of a flight. For some people with sig- nificant disabilities, this requirement can make air travel so inconvenient, 1 Accommodation and access laws, regulations, and design standards for individuals using paratransit vans, buses, taxis, and other passenger vehicles for surface transportation can be found at https://adata.org/ada-law-regulations-and-design-standards.

10 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL uncomfortable, and unsafe that they fly rarely, if at all. If wheelchair securement systems could be installed in airplane cabins and made suf- ficiently safe and available by scheduled airlines, more people who are nonambulatory would be able to benefit from air travel, and when doing so, they would retain more independence and dignity while experiencing less discomfort and risk of injury. Air travel has differed from other transportation modes with regard to passengers being able to travel seated in their personal wheelchairs for several reasons. Perhaps more than the vehicles of some other passen- ger modes such as trains, airplanes have severe space constraints and are held to different safety performance requirements. The space constraints complicate wheelchair movements within the airplane cabin and limit the room available for a securement location. Modifications to typically config- ured airplane interiors, including the reconfiguration or removal of tightly spaced passenger seats and other cabin features, would be needed to create the requisite room. The airplane cabin and its seating systems must meet exacting government standards for safety assurance, including crashworthi- ness and fire resistance. Safety assurance is a challenge because wheelchairs, unlike airplane seats, are not designed purposefully to perform safely in a survivable airplane crash. However, the introduction and use of wheelchair securement systems has presented space, safety, and other technical chal- lenges in all modes of passenger transportation.2 A valid question, there- fore, is whether the technical challenges associated with air transportation are so formidable that accommodations comparable to those that are now commonplace in the other modes are infeasible. In Section 432 of the Federal Aviation Administration Reauthoriza- tion Act of 2018 (Public Law 115-254), Congress mandated that the U.S. Access Board examine the feasibility of in-cabin wheelchair securement systems and the ways in which people with significant disabilities who use wheelchairs, including power wheelchairs, can be accommodated by such systems provided they are feasible.3 This study, commissioned by the U.S. Access Board in response to the legislative mandate and conducted by an expert committee, reviews the various technical issues pertaining to in-cabin wheelchair securement systems. It then assesses the available information to gauge whether any of the identified issues suggest that these systems could be feasible, or potentially infeasible, to design and implement. The empha- sis, therefore, is on providing a preliminary technical assessment that can 2 Hunter-Zaworski, K.M., and J.R. Zaworski. 2002. “Progress in Wheelchair Securement: 10 Years Since the Americans with Disabilities Act.” Transportation Research Record, no. 1779: 197–202; Hunter-Zaworski, K.M., D.G. Ullman, and J.R. Zaworski. 1993. “The Me- chanics of Mobility Aid Securement/Restraint on Public Transportation Vehicles.” Transporta- tion Research Record, no. 1378: 45–51. 3 This legislative request is presented in Appendix A.

INTRODUCTION 11 inform choices about whether and how to plan follow-on evaluations of this concept, with the goal of expanding air travel opportunities for people with significant disabilities. Congress’s specific motivations for mandating a feasibility study are not clear, but public interest in extending transportation accommodations to people who have significant disabilities has been growing since the enactment of the Americans with Disabilities Act (ADA) of 1990.4 The fulfillment of the ADA’s requirements has led people who use wheelchairs to become accustomed to—and often dependent on—being able to travel in their personal wheelchairs, which are optimized for their own physical and medical needs. As the popularity of long-distance travel has grown, and indeed become essential to some jobs and family gatherings, the burdensome nature of air travel for people who depend on their personal wheelchairs for mobility, health, and well-being has become increasingly problematic.5 The kinds of burdens that people who are nonambulatory face when seeking to travel on scheduled airlines, as explained to the study commit- tee by people with disabilities, are discussed next. An appreciation of these issues is essential for understanding why there is interest in the concept of an in-cabin wheelchair securement system and why an assessment of the technical challenges associated with its development and implementation is important. Following this discussion, the remainder of the chapter presents the study’s Statement of Task and the committee’s decisions about how to frame and assess the technical feasibility of an in-cabin wheelchair securement system that remains largely conceptual. The chapter ends with an overview of the organization of the report. BURDENS PEOPLE WHO ARE NONAMBULATORY FACE WHEN FLYING People who are nonambulatory and use wheelchairs experience several bur- dens that can make air travel inconvenient, uncomfortable, unhealthy, and unsafe. For people with significant disabilities who need to remain seated in their customized personal wheelchair, travel by scheduled airlines in a 4 See https://www.ada.gov/pubs/adastatute08.htm. 5 The ADA accessibility requirements apply to airport terminals, and the Architectural Bar- riers Act of 1968 (ABA) requires all buildings and facilities designed, built, or altered with federal funds, including airport terminals, to be accessible to people who use wheelchairs. However, the ADA and the ABA no longer apply at the point of proceeding down the passen- ger boarding bridge. While the Air Carrier Access Act (ACAA) of 1986 specifies obligations of airlines in accommodating passengers with disabilities, it has no provisions for use of personal wheelchairs in the cabin because no airline provides in-cabin wheelchair securements.

12 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL passenger seat is not possible at all. For some of these individuals, and for some others who can fly but avoid doing so because of the risks and prob- lems encountered, long-distance trips for work, family gatherings, medical care, and recreation may need to be made using other modes of passenger transportation that are more time-consuming and potentially less safe.6 Boarding and Deplaning Problems Based on a survey by the U.S. Department of Transportation (U.S. DOT), an estimated 25.5 million people (8.5 percent of the U.S. population age 5 and older) have disabilities that limit their travel.7 More than 11 percent of these individuals, or an estimated 2.8 million people nationally, identify as wheelchair users.8 According to data from the Air Travel Consumer Report, 381,792 wheelchairs or scooters were checked on scheduled flights by U.S. airlines during the second half of 2019, from July to December.9 Wheelchairs or scooters were checked on about 11 percent of scheduled air- line departures. During this half-year period, airlines enplaned nearly 460 6 See National Transportation Safety Board. n.d. “U.S. Transportation Fatalities in 2019––by Mode.” https://www.ntsb.gov/investigations/data/Documents/US-Transportation- Fatalities-2019.pdf; National Safety Council Injury Facts. n.d. “Deaths by Transportation Mode.” https://injuryfacts.nsc.org/home-and-community/safety-topics/deaths-by-transportation- mode. 7 See FHWA. 2018. “National Household Travel Survey.” https://www.bts.gov/travel- patterns-with-disabilities. The Federal Highway Administration (FHWA) conducts this survey, the National Household Travel Survey, which is the primary source of data on household travel behavior in the United States. FHWA conducted the latest version in 2017 and earlier versions in 2001 and 2009. 8 Among those with disabilities who responded to the FHWA National Household Travel Survey, 11.6 percent reported using wheelchairs, and 3.9 percent reported using power wheel- chairs. Other devices used included walking canes (36.7 percent), walkers (22.9 percent), motorized scooters (4.4 percent), crutches (2.6 percent), white canes for visual impairments (1.3 percent), and seeing-eye dogs (1.1 percent). Respondents could report using more than one mobility device. See FHWA. 2018. “National Household Travel Survey.” https://www.bts. gov/travel-patterns-with-disabilities. 9 Air Travel Consumer Report is a monthly series of reports issued by U.S. DOT’s Office of Aviation Enforcement and Proceedings. These reports were first issued at the beginning of 2019 and contain information on the combined number of wheelchairs and scooters stowed on the 17 U.S. airlines with at least 0.5 percent of total domestic scheduled flight service revenues. The data that these airlines report include both domestic and international travel. During the first few months of these reports, there appear to have been some reporting issues; therefore, the data used in this report encompass the reporting period from July 1, 2019, through De- cember 31, 2019. On average, 63,632 wheelchairs or scooters were checked monthly during this period. While these data do not cover the entire scheduled passenger airline industry, these 17 airlines enplaned 96 percent of all passengers carried by all U.S. scheduled airlines and accounted for 86 percent of all scheduled airline departures. See https://www.transportation. gov/airconsumer/air-travel-consumer-reports-2019.

INTRODUCTION 13 million passengers in total;10 hence, passengers who checked wheelchairs and scooters accounted for about 0.1 percent of all enplaned passengers. People who use wheelchairs differ in their ability to board and deplane an airplane. Some people who are ambulatory and use wheelchairs are able to walk a short distance through the passenger boarding bridge to and from their airplane seat. For passengers who are nonambulatory, the narrow width of an airplane aisle means that before boarding, they will need to transfer out of the wheelchair to an airline-provided boarding chair that is sufficiently narrow to pass through the cabin aisle. The boarding chair is usually no more than 13 in. wide, as is necessary to clear an aisle that may be only 15 in. in width.11 Passengers must transfer themselves or be lifted into the boarding chair by service agents. The boarding chair is then wheeled through the passenger boarding bridge and cabin aisle to the passenger’s seat. Once at the seat, the passenger must transfer from the boarding chair into the seat. Some passengers can transfer on their own and others will require assistance. Pas- sengers requiring assistance are usually lifted into the seat by one or more service agents. If the passenger cannot transfer independently or be lifted by service personnel, then a mechanical lift may be used for the transfer, but such devices are not widely available.12 This entire process is reversed when the passenger deplanes upon arrival. As a result of these transfers, people who use wheelchairs can encounter the following problems, as explained to the study committee by the study sponsor and people who use wheelchairs13: 10 FAA. “Commercial Service Airports (Rank Order) Based on Calendar Year 2019 (is- sued 9/26/2020).” https://www.faa.gov/airports/planning_capacity/passenger_allcargo_stats/ passenger. Derived also from U.S. Department of Transportation, Bureau of Transportation Sta- tistics. “T100 Data for Scheduled Passenger Service July 1–December 31, 2019.” https://www. transtats.bts.gov/databases.asp?Z1qr_VQ=E&Z1qr_Qr5p=N8vn6v10&f7owrp6_VQF=D. 11 The current FAA standard for aisle width was last updated in the 1954 Civil Air Regula- tions code, which was re-codified by FAA as Title 14 Part 25 of the Code of Federal Regula- tions, titled “Airworthiness Standards: Transport Category Airplanes.” The regulation states that “the main passenger aisle at any point between seats shall not be less than 15 inches wide up to a height above the floor of 25 inches and not less than 20 inches wide above that height.” 12 Lifts are not routinely available in the United States, but a few U.S. airports provide lifts at a passenger’s request. 13 This section of the report draws on presentations to the committee at its first public meeting from the U.S. Access Board (the study sponsor) and advocates for individuals with disabilities (the Preface of this report provides a list of invited presenters), and is also in- formed by congressional testimony. See “The Airline Passenger Experience: What It Is and What It Can Be, Hearings Before the House Committee on Transportation and Infrastructure, Subcommittee on Aviation, 116th United States Congress, March 3, 2020 (Testimony of Lee Page, Paralyzed Veterans of America).” https://www.congress.gov/116/meeting/house/110600/ witnesses/HHRG-116-PW05-Wstate-PageL-20200303.pdf.

14 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL • The transfer at the gate to and from the boarding chair can cause strain, discomfort, and in some cases injury to the occupant. • Boarding chairs frequently lack sufficient back support for the passenger and can be unstable on passenger boarding bridges. The narrowness of the boarding chair combined with the slope of the passenger boarding bridge can lead to lateral instability and risk a passenger falling in or from the chair, causing injury. Injury to arms, legs, and hips can also occur as passengers are pushed in the boarding chair through the narrow cabin aisle.14 The seating surface of the boarding chair may also place some people at risk of pressure injuries. • The transfer between the boarding chair and the airplane seat cre- ates a risk of injury as the passenger is lifted, moved, and placed into the seat through a tight space and over protruding armrests and safety belt buckles.15 Airplane Seat Limitations Some people who have significant disabilities may lack the flexibility, range of motion, physiological ability (e.g., tissue integrity, respiratory reserve, circulatory capacity), or postural stability to sit in an airplane seat. For these individuals, travel by scheduled airlines is not an option today. In other cases, passengers who are transferred from a boarding chair to an airplane seat may not be able to sit without pain or discomfort for even short periods of time, much less for the duration of a long-distance flight. Often these passengers will have personal wheelchairs that are equipped with seating and positioning systems tailored to meet their specific sup- port, restraint, and other physical needs. Their wheelchairs, for instance, will usually have seat cushions and back, head, neck, and foot supports to address their medical needs and minimize risk of pressure injuries.16 Fur- 14 The committee could not verify with data on frequency of occurrence or other statistics. 15 The service provider also risks serious lifting injuries. According to federal guidelines established by the National Institute for Occupational Safety and Health, the maximum rec- ommended weight for a single person to lift is 51 lb; thus, two service providers risk serious back injuries when lifting passengers heavier than about 100 lb over the backs of boarding devices and airplane seats in such tight spaces. (See U.S. Department of Health and Human Services. 1994. Applications Manual for the Revised NIOSH Lifting Equation. http://www. cdc.gov/niosh/docs/94-110.) 16 Some of the problems that nonambulatory passengers experience with airplane seats, and the problem described earlier with boarding via narrow aisles, stem from FAA specifica- tions for airplane seats and aisle widths that assume that the average passenger is 170 lb (a weight that many ambulatory and nonambulatory passengers currently exceed), standing, and ambulatory.

INTRODUCTION 15 thermore, many power wheelchairs, and some manual wheelchairs, can tilt, recline, and elevate the leg rests. A passenger airplane seat, of course, does not offer these seating functions, which are necessary for pressure relief and other medical reasons. Lost and Damaged Wheelchairs In the case of some manual wheelchairs and all power wheelchairs, they must be stowed in the airplane cabin or in the cargo hold. A concern of many passengers is that their checked wheelchairs will be mishandled or improperly secured and damaged when stowed or moved to and from the loading area and cargo hold.17 According to U.S. DOT consumer com- plaint statistics, of the 381,792 wheelchairs and scooters stowed from July through December 2019, 5,637 (or 1.5 percent) were “mishandled,” which includes devices that were “lost, damaged, delayed, and pilfered as reported by or on behalf of the passenger.”18,19 Power wheelchairs are sensitive, complex, and expensive pieces of equipment that can be heavily customized. A damaged or lost wheelchair can result in a severe loss of mobility for the passenger arriving at the destination, followed by a potentially long period of reduced mobility, discomfort, pain, and injury during the time it takes for the wheelchair to be repaired or replaced.20 Ordering a replacement wheelchair that is highly customized can take weeks or months, leaving the passenger dependent on a manual wheelchair or with no mobility at all. For some people, these risks are not worth taking, and they avoid flying. Care and Dignity The leading complaint among passengers with disabilities who file a com- plaint report with U.S. DOT is failure to provide passengers who use 17 For example, see Miranda, G. 2021. “‘This Is My Life, My Legs’: After a Woman’s Wheelchair Was Damaged on a Delta Flight, ‘Heartbreaking’ Video Goes Viral.” USA To- day, June 22. https://www.usatoday.com/story/travel/airline-news/2021/06/04/delta-breaks- womans-wheelchair-viral-tiktok-shows-her-left-tears/7510470002. 18 See U.S. DOT. 2020. Air Travel Consumer Report, February. https://www.transportation. gov/sites/dot.gov/files/2020-02/February%202020%20ATCR.pdf. 19 Unfortunately, these data do not distinguish between wheelchairs and scooters, nor do they distinguish within the mishandled category among lost, damaged, delayed, or pilfered. 20 U.S. DOT receives the greatest number of complaints in four areas: (1) wheelchair and guide assistance; (2) stowage, loss, delay, and damage of wheelchairs and other mobility as- sistive devices; (3) aircraft seating accommodations (under the ACAA, airlines are required to provide certain seating accommodations to passengers with disabilities who self-identify as needing to sit in a certain seat); and (4) travel with service animals.

16 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL wheelchairs with sufficient customer assistance.21 This complaint category includes long waits for assistance to deplane, which can cause pain and discomfort for passengers, as well as missed connections or missed pre- arranged appointments with ground transportation providers. Indeed, in- stances have been reported in media accounts of passengers receiving no assistance with deplaning.22 Advocates for people with disabilities point to the stress that can be associated with air travel for people who use wheelchairs. Not only do they experience the many risks and hardships discussed above, but the whole process—from having to wait for assistance to being physically handled by strangers—can be undignified in a way that does not compare to the experience on other modes of transportation when wheelchair securement systems are available. 21 The ACAA, 49 U.S.C. 41705, prohibits discriminatory treatment of persons with dis- abilities in air transportation. The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (AIR-21; Public Law 106-181) requires, among other things, that the Secretary of Transportation “regularly review all complaints received by air carriers alleging discrimination on the basis of disability” and “report annually to Congress on the results of such review.” These annual reports to Congress cover disability-related complaints that U.S. and foreign passenger air carriers operating to, from, and within the United States received during the calendar year, as reported to U.S. DOT by those carriers. According to the 2019 Annual Report on Disability-Related Air Travel Complaints Received in Calendar Year 2018, failure to assist passengers in wheelchairs and damaged devices received the greatest number of complaints. See https://www.transportation.gov/sites/dot.gov/files/2020-03/Summary%20 Report%20of%20CY2018%20Disability%20Complaints.pdf. The 31 U.S. carriers that sub- mitted data for 2018 reported receiving 30,950 disability-related air travel complaints and 149 foreign air carriers reported receiving 5,980 complaints, for a total of 36,930 complaints. Of all of the complaints reported by domestic and foreign carriers operating to, from, and within the United States, 17,124 (46 percent) concerned the failure to provide adequate assistance to persons using wheelchairs, an increase of 1,917 complaints over the 15,207 complaints (44 percent of the total 34,351 complaints) received in 2017. The number of complaints prob- ably underestimates the extent of problems; in a Muscular Dystrophy Association survey of 2,000 individuals with neuromuscular disabilities, only 4 percent of those who said they had experienced an access issue related to their disability had filed a complaint, and more than half of those surveyed did not know they could file a complaint; see https://strongly.mda.org/ mda-community-weighs-accessible-air-travel-new-survey-results. 22 For example, see Shaw, A. 2013. “Disabled Man Claims Delta Forced Him to Crawl On and Off Plane.” ABCNews, July 29. https://abcnews.go.com/Travel/disabled-man-claims- delta-forced-crawl-off-plane/story?id=19801554; Holohan, M. 2019. “After Wheelchair Was Lost for 12 Hours, Couple Speaks Out About Traveling with a Disability.” Today, July 24. https://www.today.com/health/couple-speaks-out-about-american-airlines-mistreatment- man-s-wheelchair-t159450; Gray, M., and S. Roth. 2015. “United Airlines Apologized After Disabled Man Crawls Off Flight.” CNN, October 27. https://www.cnn.com/2015/10/25/us/ united-airlines-disabled-man/index.html.

INTRODUCTION 17 STUDY ORIGINS AND CHARGE As noted previously, Congress mandated this study by calling on the U.S. Access Board to study “(1) the feasibility of in-cabin wheelchair restraint systems; and (2) if feasible, the ways in which individuals with significant disabilities using wheelchairs, including power wheelchairs, can be accom- modated with in-cabin wheelchair restraint systems.” Congress further directed the U.S. Access Board to consult with the Secretary of Transporta- tion, airplane manufacturers, air carriers, and disability advocates during the conduct of the study. In response to this mandate, the U.S. Access Board commissioned the National Academies of Sciences, Engineering, and Medicine to convene a committee of experts charged with determining whether it may be tech- nically feasible to equip passenger airliners with wheelchair securement systems under reasonable circumstances.23 “Reasonable circumstances,” as understood by the committee, implies a feasibility assessment that takes into account the plausibility and practicality of a system, not just its theo- retical technical possibility. To make this determination, the committee was tasked by the U.S. Access Board with assessing the design and engineering requirements for installation and use of wheelchair securement systems with both power (motorized) and manual wheelchairs.24 In doing so, the committee is expected to consider the Federal Aviation Administration’s (FAA’s) requirements for safety assurance and to examine the technical is- sues associated with system implementations, including any associated with the airplane floor structure. The full study charge, or Statement of Task, is contained in Box 1-1. Upon completion of this assessment, the Statement of Task calls on the committee to consider issues in accommodating passengers effectively with the systems, provided that there is sufficient reason to believe that they could be technically feasible. 23 For precision and consistency with wheelchair industry standards, the committee uses the term “wheelchair securement system” in this report instead of “wheelchair restraint system” used in the FAA Reauthorization Act of 2018 and the committee’s Statement of Task. The wheelchair securement system in this report consists of three main components: the personal wheelchair; the securement device used to “tie down” or otherwise attach the wheelchair to a vehicle; and occupant restraints, such as belts and straps, that secure the wheelchair user to the wheelchair. The Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) uses the term “wheelchair tiedown and occupant restraint systems” to refer to the combined securement device and occupant restraint that, as described in Chapter 2, must be tested together for safety as specified in the RESNA voluntary industry standards. 24 For consistency with more widely used terms, the committee uses the term “power wheelchairs” to refer to motorized wheelchairs and the term “manual wheelchairs” to refer to non-motorized wheelchairs. In this report, the term “personal wheelchair” refers to either a power or a manual wheelchair owned by the user.

18 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL BOX 1-1 Statement of Task The study will assess and evaluate the conditions under which it may be tech- nically feasible to equip passenger aircraft with in-cabin wheelchair restraint systems, including assessments of the following: a. design, engineering, and safety requirements for installation and use of the in-cabin restraint systems (e.g., any locking or tiedown mecha- nisms) for non-motorized and motorized wheelchairs used as seats in aircraft and the feasibility of strengthening or modifying the floor struc- ture of the aircraft’s passenger cabin to accommodate a restrained, occupied wheelchair in the cabin—taking into account, among other factors, the fact that different aircraft manufacturers and different aircraft types/models have varying specifications for cabin floors; b. design, engineering, and safety requirements for non-motorized and motorized wheelchairs to be used as passenger seats in aircraft in all phases of air travel including enplaning, midair flight (including turbu- lence), deplaning, and emergency situations. Consideration should be given to the design, engineering, and construction specifications that both non-motorized and motorized wheelchairs (and their own internal occupant restraints) would have to conform to in order to meet injury criteria limits and otherwise achieve the level of safety equivalent to that established by the Federal Aviation Administration’s (FAA’s) existing requirements for passenger seating; c. injury criteria limits for the users of in-cabin wheelchair restraint systems and the occupants of seats behind and adjacent to the users of in-cabin wheelchair restraint systems in crash situations (e.g., emergency and survivable crash environments); and d. the implications of items (a), (b), and (c) on FAA regulations and poli- cies for airworthiness, crashworthiness, and other safety requirements. If it finds, based on these analyses, reasonable circumstances under which it may be technically feasible to equip passenger airplanes with in-cabin wheelchair restraint systems, the study committee will then consider in more depth how individ- uals can be effectively accommodated using those systems. Some of the discrete issues encapsulated by the “accommodation” aspect of the study are how airlines will be able to use the systems to provide an equal level of service to air travelers with significant disabilities; the implications of removing standard aircraft seats to create the space needed for a restrained, occupied wheelchair in the cabin; the implications on cabin interior designs and furnishings (e.g., aircraft doors, aisles, galleys, lavatories); the implications on boarding and deboarding procedures and staff training; the implications on reservation procedures; and the treatment and handling of the batteries of power wheelchairs prior to and during flight. Where appropriate, the committee’s report may advise on further actions warranted for making public policy choices with respect to these systems, includ- ing recommendations on further research, information, and technical analyses.

INTRODUCTION 19 STUDY SCOPE To fulfill its charge, the committee had to consider and reach agreement on the types of determinations and advice expected from the study; issues that should be considered within and outside the study scope; and the kinds of circumstances that could be deemed “reasonable” for judging concept feasibility. After careful readings of the Statement of Task and legislative mandate, multiple consultations with the study sponsor on the study’s purpose and goals, and requests for information from airlines, airplane manufacturers, assistive technology companies, people with disabilities and their advocates, and other experts and interested parties, the committee made the following decisions. Nature of Determinations and Advice Wheelchair securement systems in airplane passenger cabins remain a con- cept, as no systems have been defined or designed specifically for general airline use. At this preliminary stage, therefore, the committee decided that the most important role for this study is to identify and assess the most significant technical issues that would need to be addressed for such systems to progress from concept to design and implementation, giving particular attention to any technical challenges that are so formidable that they could hinder or thwart this progress. Accordingly, the study’s focus is on identify- ing any major technical challenges that could render the concept infeasible, rather than trying to identify, define, and assess the most technically optimal system or to consider whether and how a system could be designed and en- gineered for all or specific airplane conditions and use scenarios. Moreover, the committee recognized that it would need to make these judgments on a preliminary basis with sound and creative use of the information at hand, recognizing that in-cabin wheelchair securement systems have not been de- veloped and subjected to extensive technical evaluation. The committee was not charged with conducting its own tests or developing its own detailed technical information on plausible securement systems. In the committee’s view, an in-cabin wheelchair securement system should have the potential to be implemented on enough airplanes that people who are nonambulatory and use wheelchairs would be able to ac- cess a reasonable number of flights to places they want to go using the system. In other words, the committee did not predicate its assessment on an overly demanding expectation that all or even most airplanes could be equipped with the systems. At the same time, the committee was not interested in gauging the feasibility of systems that could only have very limited or niche applications. Niche applications on a few airplanes serving a handful of markets would provide little real benefit to many people who

20 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL use wheelchairs and currently have little, if any, opportunity to fly. Hence, the study’s focus is on securement systems that could provide “meaning- ful” access to flying, which requires more than a few flight offerings in a few high-demand markets, but does not require complete, network-wide access.25 Likewise, the committee decided that a critical element of the concept is that it could enable people to fly seated in a wheelchair optimized to their own physical and medical needs and not require a wheelchair designed exclusively and specifically for airplane use, which could limit the utility of in-cabin wheelchair securements. An ability to fly seated in a personal wheelchair is particularly important for some people with significant dis- abilities who need their own wheelchairs when seated for long periods and for their mobility, medical, and physical needs at the destination. Accordingly, the committee decided that the purpose of its assessment was to gauge the feasibility of an in-cabin wheelchair securement concept that can meet the following two conditions: (1) allow people to travel seated in their personal wheelchairs, and (2) have the capability to be installed on enough airplanes to afford ample flight offerings. These two conditions are the norm for the accommodation of people who use wheelchairs on other modes of transportation. In examining a concept, rather than a well-defined system, with regard to these two conditions, the committee recognized early on that it would have limited ability to provide a detailed assessment of the implications of securement systems on airline operations and the means by which people who use them could be accommodated by airlines. The details of such operational impacts and accommodation requirements would depend on a system’s design, requirements imposed by FAA for their design and use, and specific airplane applications and airline procedures. The implementation of any in-cabin wheelchair securement system, however, would present some general operational and accommodation issues that can be identified and discussed even when considering these systems at the conceptual level. It would be important, for instance, for a sufficient number of airplanes to be equipped with securement systems for people with significant disabilities to have dependable access to scheduled airline service. Travelers in connecting service, for instance, could be stranded en route if very few airplanes are equipped with securement systems and the equipped airplane originally scheduled for the service is not available because of mechanical or opera- tional issues. For people with significant disabilities, such strandings could 25 The committee’s analysis therefore focuses mainly on assessing technical feasibility with regard to the two most ubiquitous families of airplanes, the Boeing 737 and the Airbus A320. This focus should not be interpreted as a determination that wheelchair securements would be infeasible for other airplanes, including regional.

INTRODUCTION 21 be more serious than an inconvenience. Likewise, reliable and sufficient customer service assistance would need to be available to passengers who choose to use the systems. While these are examples of nontechnical issues, they would need to be given serious consideration as potential obstacles to in-cabin wheelchair securement systems irrespective of their technical fea- sibility. The committee therefore recognized that it would need to identify and discuss such potentially critical issues. Although the Statement of Task does not call on the committee to ad- vise whether in-cabin wheelchair systems should be installed on airplanes, it does ask the committee to offer recommendations, where appropriate, on further actions warranted for making public policy with respect to these systems, including research, information gathering, and technical analysis. During the course of its work, the committee therefore made a point of identifying where more information would be desirable for assessing in- cabin wheelchair securement systems to make more informed public policy choices. Issues Outside the Study Scope Several other decisions had to be made concerning the study scope to keep the work focused on the Statement of Task and legislative mandate. For instance, the committee did not examine issues associated with the user of a wheelchair being able to access the airport terminal or gates, nor did it consider certain user needs that could arise in flight such as accessing lavatories and being able to evacuate in the event of an emergency. While these are important issues, they currently exist for all passengers who are nonambulatory and fly by transferring to an airplane seat, and they would not change appreciably if the passenger were to fly seated in a wheelchair. For example, passengers who are nonambulatory and cannot make the movements on their own that are needed to transfer to and from an airplane seat would not be expected to be able to make the movements required to use the lavatory, irrespective of whether that person is seated in an airplane seat or a wheelchair.26 Likewise, during an emergency situation, it is not currently possible to evacuate a passenger who is nonambulatory from an airplane cabin using an aisle chair and one should not expect that such an evacuation should be possible in a personal wheelchair. Consistent with 26 Other efforts have focused on issues with airplane lavatory access by wheelchair users who currently fly, including U.S. Government Accountability Office. 2020. “Aviation Consumer Protection: Few U.S. Aircraft Have Lavatories Designed to Accommodate Passengers with Reduced Mobility.” https://www.gao.gov/assets/gao-20-258.pdf#:~:text=Page%204-,GAO %2D20%2D258%20Aircraft%20Lavatories,order%20to%20use%20the%20facilities; and U.S. DOT ACCESS Advisory Committee. n.d. https://www.transportation.gov/access-advisory- committee.

22 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL its charge, however, the committee considered how FAA crashworthiness criteria should apply to wheelchairs, as with airplane seats, to ensure that secured wheelchairs do not become damaged in a crash and obstruct cabin evacuations. Significantly, the committee did not consider whether a technically feasible in-cabin wheelchair securement system should be installed on air- planes. Choices about whether to install these systems would entail many considerations other than a system’s technical feasibility and operational implications to include the economic impacts on the airline. The report estimates the direct expenses associated with installing a securement system on an airplane because such estimates can provide insight into the effort, complexity, and technical challenge associated with an airplane imple- mentation. Once installed, however, the systems would have impacts on an airplane’s revenue-generating potential and thus on airline economics. While these impacts would presumably be a major factor in decisions about whether to pursue such systems (and how to design them), they are outside of the study charge. Focus on People with Significant Disabilities and Power Wheelchairs As noted above, the legislation calling for this study asks for an assess- ment of the ways in which individuals with significant disabilities using wheelchairs, including power wheelchairs, can be accommodated with in-cabin wheelchair securement systems. Because power wheelchairs tend to be larger and heavier than manual wheelchairs, while also having more components and features including batteries and seating functions, power wheelchairs are the subject of most of the analyses in this report. Another important reason to focus on power wheelchairs is that they are used most often by people who have disabilities that make sitting in and transferring to and from an airplane seat particularly burdensome, if possible at all. Moreover, it can be especially troubling when power wheelchairs are lost or damaged when checked, for reasons discussed above. Accordingly, it is reasonable to assume that the people who use power wheelchairs have the most to gain from in-cabin wheelchair securement systems; therefore, any technically feasible system would need to be able to accommodate them and their wheelchairs. Although the study focuses on power wheelchairs for these reasons, the committee presumes that any in-cabin securement system that could ac- commodate power wheelchairs is likely to be able to accommodate manual wheelchairs. Therefore, the study addresses both manual and power wheel- chairs, as called for in the study charge. Whether efforts to accommodate both types of wheelchairs would in fact be desirable, however, is a matter that would need to be given serious attention if the concept is pursued

INTRODUCTION 23 beyond this preliminary feasibility review. For example, assuming the num- ber of wheelchair securement places on an airplane is limited, their use by passengers who can otherwise transfer to and from an airplane seat could make availability scarcer for people who cannot transfer and who are more likely to use a power wheelchair. Additionally, for people who can transfer to an airline seat without much difficulty, the relative benefit-risk calculus of remaining seated in a wheelchair versus flying in an FAA-certified airplane seat could differ from that of people whose disabilities make transferring highly problematic or impossible. It is reasonable to assume that users of power wheelchairs have a wide range of disabilities and degrees of impairment (e.g., some can fly indepen- dently and others may need the assistance of a traveling companion). The committee considered the potential importance of a companion seat as part of a wheelchair securement system but decided against making this a tech- nical requirement or condition for feasibility. A companion seat adjacent to the passenger seated in a wheelchair may be preferable, but it is likely to increase the technical challenge due to the added space requirements. While the need for companion seating would be a valid concern for follow- on work, the committee wanted to avoid assuming too many demanding conditions for technical feasibility. STUDY APPROACH AND REPORT ORGANIZATION The organization of this report and the content of the chapters align with how the committee conducted its work. Chapter 2 provides background information needed for the analyses in subsequent chapters. The chapter contains information on the population of personal wheelchairs in com- mon use and their size, seating position features, and maneuvering charac- teristics. It also discusses the basic structure of today’s airline service, the airplanes used for this service, and the seating systems and other relevant features of airplane cabin interiors. Both wheelchairs and airplane passen- ger cabins are subject to safety and quality assurance standards that have an important influence on their design and engineering. Accordingly, the role of the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) is discussed in this chapter, in advance of discuss- ing FAA’s safety standard-setting role in Chapter 3. A wheelchair securement “system” must be viewed as consisting of the wheelchair tiedown and occupant restraint mechanisms and a compatible wheelchair. Because safe performance is critical for air transportation, the challenges associated with designing and implementing a wheelchair secure- ment system that can satisfy FAA’s safety assurance requirements are the subject of Chapter 3. FAA closely regulates airlines and airplanes for safety, and a large body of the regulations focuses on the ability of the airplane

24 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL cabin and seating systems to protect passengers and crew in the event of impacts from a crash or emergency landing. Understanding how a secured wheelchair would perform during such an event, when considering the safety of the wheelchair occupant and other airplane passengers and crew, is imperative. FAA crashworthiness criteria for airplane seats and cabin interiors are described and then compared to criteria developed by RESNA for the crashworthiness of wheelchairs in motor vehicle transportation. While crashworthiness considerations will dictate many aspects of the design and implementation of a wheelchair securement system, space avail- ability in the airline cabin will have a significant effect as well. For safety and other practical reasons, the airplane must have the requisite space for commonly sized wheelchairs to board, deplane, and maneuver to and from a sufficiently sized and structurally supported securement location. These space considerations are examined in Chapter 4 by estimating the clear- ances and clear spaces required for a wheelchair and comparing them to the dimensions of airplane doors and cabin interiors. An illustration of a securement location implemented in one of the most common interior lay- outs of the most common airplane family in the U.S. fleet provides insight into whether space constraints could present significant technical challenges that could limit the potential for securement systems to be implemented on enough airplanes to ensure broad and reliable service coverage. Chapter 5, which is the report’s final chapter, draws on the findings from the analyses in Chapters 3 and 4 to offer a summary assessment of the technical feasibility of an in-cabin wheelchair securement system concept. Consideration is also given to important airline operational and passenger accommodation issues that could arise in implementing wheelchair secure- ment systems. The chapter concludes with the committee’s recommenda- tions about the kinds of research and evaluations needed to inform future public policy choices about in-cabin wheelchair securement systems.