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

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1 Executive Summary Congress mandated in Section 432 of the Federal Aviation Administration Reauthorization Act of 2018 (Public Law 115-254) that the U.S. Access Board examine the feasibility of wheelchair securement systems for pas- senger use in airplane cabins and the ways in which people with significant disabilities who use wheelchairs can be accommodated by such systems if feasible. This study, commissioned by the U.S. Access Board and conducted by an expert committee, reviews technical issues pertaining to the concept of an in-cabin wheelchair securement system; provides a preliminary as- sessment of whether the technical issues suggest that the concept is feasible or potentially infeasible; and recommends actions to fill gaps in technical information needed for more definitive assessments of feasibility and for public policy considerations about the systems and their potential to ex- pand air travel opportunities for people with significant disabilities. A wheelchair securement system for passenger use in an airplane cabin is an intuitively appealing solution to many of the impediments to air travel faced by people who are nonambulatory. While no securement systems of this type exist in scheduled airline service, the norm for most other modes of transportation is for people to be able to board a vehicle in their personal manual or power wheelchair, stay seated in that wheelchair for the duration of the trip, and wheel off the vehicle at the destination. Airline transporta- tion, however, is an exception because it invariably requires people who are nonambulatory to fly in an airplane seat. For reasons explained in this report, this requirement can greatly complicate access to airline service by making flying uncomfortable, painful, injurious, and sometimes impossible. Of interest, therefore, is whether the technical challenges associated with

2 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL the development and implementation of in-cabin wheelchair securement systems are so formidable that the service that wheelchair users have grown accustomed to in other transportation settings is infeasible for airline travel. This report identifies and examines potential technical challenges to the development and implementation of an in-cabin wheelchair securement system that could be installed on enough airplanes to provide nonambu- latory people with airline flight offerings in enough markets to provide meaningful (and not niche) service availability. The focus is on a securement system concept that can accommodate personal wheelchairs, as opposed to wheelchairs designed and optimized specifically for airplane travel. Personal wheelchairs are often customized to the physical and medical needs of the occupant, and are often considered essential for the person’s comfort, health, and well-being during travel and when at the destination. In particu- lar, the following three major technical considerations were deemed most relevant to this preliminary assessment of concept feasibility: • Whether airplanes common to airline service have enough doorway and interior space to enable a power or manual wheelchair to enter and exit the passenger cabin and maneuver to and from a secure- ment location that provides sufficient room for the functioning of the securement system and medically essential wheelchair position adjustments; • Whether an airplane floor and its structure can accommodate the loadings imparted by an occupied power wheelchair; and • Whether a secured personal wheelchair can meet the crashworthi- ness, occupant injury protection, and other relevant air transpor- tation safety requirements of the Federal Aviation Administration (FAA). In addition to these technical issues, the report identifies several important airline operational and passenger accommodation issues that would war- rant careful consideration as part of any initiative to develop and introduce an in-cabin wheelchair securement system intended to provide reliable and meaningful levels of flight service to people who are nonambulatory and have significant disabilities. KEY FINDINGS ON TECHNICAL FEASIBILITY With respect to these major technical considerations, the study findings suggest the following: • Airplane boarding door clearances and cabin aisle space should not present major physical impediments to personal wheelchairs

EXECUTIVE SUMMARY 3 entering and exiting an airplane and maneuvering to and from a securement area located near the boarding door. A large majority of airplanes have a main boarding door with sufficient width to enable a large majority of personal wheelchairs to pass through. While it was not possible to examine the cabin interior dimen- sions and layouts of all airplanes in the U.S. airline fleet, the most common interior layouts for the two most ubiquitous families of airplanes, the Boeing 737 and the Airbus A320, should require only modest interior modifications to create a wheelchair securement area located at the front of the cabin near the turn from the main boarding door. • The removal of two successive rows of seats in a cabin location near the boarding door should provide sufficient room in most airplanes for a securement location spacious enough to allow the occupant of a wheelchair to maneuver into and out of the location and, once secured, to use physically and medically essential wheel- chair position functions without impinging on the space of other passengers. • The removal of two successive rows of seats in most airplanes should free up enough airplane floor structure to accommodate the load imparted by the heaviest of occupied power wheelchairs using load distribution systems that are commonly employed for seat assembly attachments, including pallet systems. • The removal of two successive rows of seats should provide suf- ficient clear space to satisfy FAA criteria that the wheelchair oc- cupant and nearby passengers do not risk serious head and leg injuries from striking objects or structure during a survivable crash or emergency event as long as the wheelchair remains secured and its occupant restrained. • Many personal wheelchairs, including power wheelchairs, comply with motor vehicle transportation safety and crash performance standards (WC19) for wheelchairs established by the Rehabilita- tion Engineering and Assistive Technology Society of North Amer- ica (RESNA). Because WC19 wheelchairs have four brackets for securing tiedown straps and anchor points for a lap safety belt, this can provide a widely available and standardized interface for an in-cabin wheelchair tiedown and occupant restraint system. • RESNA’s crash performance test for WC19 wheelchairs has some similarities with one of FAA’s two dynamic crash tests for airplane seats in which the predominant impact vector is horizontal. FAA’s horizontal test requires an airplane seat to demonstrate the abil- ity to avoid severe deformation, retain items of mass, and protect the occupant from severe head and leg injuries from a 16-g peak

4 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL dynamic loading along the airplane’s longitudinal axis, such as from a survivable crash or emergency landing impact when the airplane is primarily moving forward. To meet the WC19 standard, secured wheelchairs must demonstrate crashworthiness, occupant restraint, and battery and component retention in a frontal motor vehicle crash occurring at 30 mph. The horizontal test condition in this case creates a dynamic loading that averages 20 g, which is higher than the peak 16-g loading of the FAA test, and also as- sumes a nearly instantaneous deceleration from 30 to 0 mph. • RESNA’s WC19 standard does not include a test condition com- parable to FAA’s second dynamic crash test in which the predomi- nant impact vector is vertical. This second test is also intended to demonstrate the seat structure’s ability to avoid severe deforma- tion, retain items of mass, and protect the occupant from spinal injury but under vertical loadings characteristic of a survivable airplane crash during an attempted takeoff or emergency landing with a high descent rate. In the absence of a WC19 vertical test, technical evaluations are needed to determine the crash and injury protection performance of wheelchairs when subject to such verti- cal forces, which seldom occur in motor vehicle crashes. Likewise, RESNA’s flammability testing standards for wheelchairs differ from FAA’s standards for airline seats, and thus technical evaluations are needed to gauge the ability of wheelchairs to satisfy FAA criteria for resistance to post-crash fires. Future efforts to fill these gaps in technical information will benefit from RESNA’s crashworthiness standards for wheelchairs. The standards provide a performance minimum, or widely applicable baseline, for wheelchair evalua- tions on the basis of FAA test criteria, as many commonly used wheelchairs comply with the RESNA standards today and more wheelchairs could be designed to comply with them in the future. If the WC19 and other RESNA standards did not exist to provide such a common baseline, the job of evalu- ating a heterogeneous population of personal wheelchairs for compliance with FAA criteria could be technically daunting and potentially impractical. KEY FINDINGS ON OPERATIONAL AND ACCOMMODATION ISSUES The implementation of an in-cabin wheelchair securement system, if tech- nically feasible, would require airlines to address a range of operational and passenger accommodation issues, including assurance of the system’s safe and proper use by passengers, the provision of adequate airline pas- senger support and equal service treatment, and a reasonable and reliable

EXECUTIVE SUMMARY 5 level of securement system availability on scheduled flights. This study’s assessment of technical issues provides insight into how some of these re- quirements could be addressed. Notably, the technical assessment of cabin space requirements suggests that designating a securement location in the passenger seating area near the left forward boarding door would require only modest physical changes to the interiors of many common airplanes. Another potentially important operational and accommodation benefit of this securement location is that the left forward door is widely used for general passenger boarding; therefore, users of wheelchairs could enter and exit the airplane through the same boarding bridge and cabin door used by all other passengers. The use of a single door for all boarding would minimize airline operational impacts and result in more equal service treat- ment among passengers. Ensuring operational practicality and equitable treatment of all pas- sengers is necessary; however, in only having a securement system concept to evaluate, as opposed to a fully defined system, the committee had limited ability to assess airline operational and passenger accommodation issues. Nevertheless, the report does point to potential challenges associated with providing needed passenger assistance and service, fare reservation sys- tem capabilities, procedures for validating wheelchair boarding eligibility, and protocols and power management for controlling wheelchair seating functions in flight. These issues are discussed in Chapter 5 of this report, recognizing that specific measures to address many of them would depend on system designs and on any relevant implementation requirements estab- lished by the U.S. Department of Transportation (U.S. DOT), FAA, and individual airlines. The committee’s deliberations did surface some general operational and accommodation issues that would require careful consideration during the planning and implementation of any wheelchair securement system. An operational issue that could be particularly vexing concerns the ability of an airline to ensure that passengers with significant disabilities traveling in their wheelchairs do not become stranded en route, such as during con- necting service, due to the unplanned substitution of an airplane that lacks in-cabin wheelchair service. For some people with significant disabilities, unreliable or disrupted service could be more serious than an inconve- nience. Airlines would need to find solutions to this potential problem and ensure that trained service agents are available to provide passenger as- sistance in all of the airports that they serve with airplanes equipped with wheelchair securement systems. The extent to which the assurance of reliable and sufficiently available securement systems on airplanes could create operational and accommoda- tion challenges will depend in part on the level of passenger demand for in-cabin wheelchair service and the nature of this demand—for instance, if

6 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL many more people who use wheelchairs choose to fly and whether people with significant disabilities constitute a smaller or larger share of secure- ment system users. The level and nature of demand will affect an airline’s motivation to equip more airplanes with securement systems and affect service agent training requirements. Passenger demand, however, is difficult to gauge at this point, because it would presumably depend in large part on whether people who do not fly now because of difficulties sitting in and transferring to and from an airplane seat would be willing to fly if they could remain seated in their personal wheelchairs. Passenger demand would also depend on interest from people who are nonambulatory and fly occa- sionally now but who might fly more often if they did not face the risks and difficulties of seat transfer or worries about their personal wheelchairs being lost or damaged when checked. Assessing demand for in-cabin wheelchair service is therefore a complicated but potentially critical step for making decisions about equipping airplanes with wheelchair securements and un- derstanding and addressing ensuing operational and accommodation needs. The committee was not asked to advise whether wheelchair securement systems should be installed on airplanes, which is a choice that would entail considerations that go beyond a system’s technical feasibility and opera- tional and accommodation implications to include airline implementation costs and economic impacts. Passenger airplane interiors are space con- strained and airlines generate revenue in accordance with seating capacity and fare classes. The implementation of a wheelchair securement system would require the redesign of interior space in ways that would affect airplane seating capacity in total and by fare class, which are all likely to impact airline economics. The committee was well aware of this likelihood, but an assessment of airline economics was not part of the study charge. It is reasonable to presume that Congress too was aware that in-cabin wheel- chair securement systems would probably affect airline seating capacity and revenue, but the request for this study does not state that a determination of feasibility should be predicated on a system having no or minimal impacts on airline economics. CONCLUSIONS AND RECOMMENDATIONS After reviewing the available information, as summarized in the findings above, the committee did not identify any issues in this preliminary as- sessment that seem likely to present design and engineering challenges so formidable that they call into question the technical feasibility of an in- cabin wheelchair securement system and the value of exploring the concept further. While the report’s analyses and findings suggest that equipping enough airplanes with securement systems to provide meaningful levels of airline service would require substantial effort, the types of cabin modifica- tions required to provide the needed space and structural support would

EXECUTIVE SUMMARY 7 likely be of moderate technical complexity for many individual airplanes. Further assessments, including efforts to fill the information gaps identified in this report, would appear to be warranted, particularly to understand how secured personal wheelchairs are likely to perform relative to FAA’s safety criteria in restraining and protecting occupants during a survivable airplane crash or emergency landing. The committee believes that such follow-on assessments are warranted because the many feasibility issues that could indeed be assessed using the information at hand appear to be manageable from a technical perspective. Concerted efforts to understand the remaining technical uncertainties through more focused analysis and testing, as described in the recommendations offered next by the committee, would enable more informed public policy decisions about the feasibility and desirability of in-cabin wheelchair securement systems. • The U.S. Department of Transportation and the Federal Aviation Administration (FAA) should establish a program of research, in collaboration with the Rehabilitation Engineering and Assistive Technology Society of North America (RESNA) and the assis- tive technology industry, to test and evaluate an appropriate selec- tion of WC19-compliant wheelchairs in accordance with applicable FAA crashworthiness and safety performance criteria. The research program should address, but not be limited to, assessing the per- formance of WC19 wheelchairs secured in an airplane cabin during a survivable crash, an emergency landing, and severe turbulence by maintaining their form, restraining their occupants and pro- tecting them from injury, retaining batteries and other items of mass, and providing adequate fire resistance. Consideration should be given to different conditions experienced in flight, such as the occurrence of unexpected severe turbulence while a wheelchair’s seat position functions are activated (e.g., leg elevation, recline, and tilt). The research should be conducted to inform decisions that may need to be made by U.S. DOT and FAA in response to petitions and other requests for in-cabin wheelchair securement systems to be allowed or even required on passenger airplanes; by RESNA and the assistive technology industry to identify opportu- nities to align existing wheelchair transportation safety standards with performance criteria required for airplane transportation; and by the airline and aircraft industries to more fully understand the implications of and opportunities for providing travelers who are non ambulatory and have significant disabilities with the ability to remain seated in their personal wheelchairs during flight. • The U.S. Access Board should sponsor studies that assess the likely demand for air travel by people who are nonambulatory if they could remain seated in their personal wheelchairs in flight. The

8 WHEELCHAIR SECUREMENT CONCEPT FOR AIRLINE TRAVEL studies should estimate the total demand for this service as well as the nature of this demand, including the demand by people with varying degrees of impairment. The studies should assess both the extent to which and how people with different disabilities are likely to use the securement systems, which could better define the space needed in the airplane cabin for wheelchair maneuvering and securement, provide insight into passenger support and service assis tance requirements, and inform airline decisions about needed levels of fleet coverage and flight availability. Ideally these recommended next steps of research, testing, and evalu- ation would be planned and programmed in a systematic manner—or in accordance with a high-level “roadmap”—that takes into account the series of follow-on decisions and work that would be needed depending on the research, testing, and evaluation results. Numerous issues would need to be addressed in concert and stepwise. For instance, it would be important to find ways to ensure that wheelchairs brought on board an airplane cabin do not create security issues and are kept crashworthy as they age and are potentially modified. A fuller understanding of the training requirements of airline personnel will be needed, along with testing and simulations to con- firm the actual amount of cabin space required for wheelchair maneuvering and securement and the in-flight use of essential wheelchair seat position functions. A more in-depth understanding of the likely travel experience of passengers using the systems will be needed, along with the implications of their installation and use on airline operations and economics. A strategic roadmap that identifies and connects these issues and fol- low-on requirements could be important for sustained progress toward the realization of in-cabin wheelchair securement systems should evaluations indicate continued promise. The roadmap could contain key decision points where information from the results of testing and analyses can be assessed for confidence and on the basis of risk analysis to define and prioritize next steps for information gathering and for furthering engineering and design activities, standards and regulation development, and practical re- quirements for implementation (e.g., personnel training requirements). U.S. DOT would be the logical lead for the development of such a roadmap in collaboration with the agencies and entities identified in the recommenda- tions above and with consultation and input from a wide range of interests and experts, including the airlines and their passenger service personnel, airframe manufacturers and interior component suppliers, people with dis- abilities and their advocates, and the assistive technology industry. Inasmuch as Congress called for this study, the committee trusts that Congress will consider these recommendations and the need for agency resources to execute them.