26,102 comments to the FAA, most about what shrinking seats do to people. The FAA decided no safety rule was needed.
In 2018 Congress ordered minimum seat sizes. Here is how that order was narrowed, tested and set aside, in the government's own words.
The paper trail
-
Congress orders minimum seat sizes, within a year
"Not later than 1 year after the date of enactment of this Act … the Administrator of the Federal Aviation Administration shall issue regulations that establish minimum dimensions for passenger seats … that are necessary for the safety of passengers."
FAA Reauthorization Act of 2018, section 5771
-
The government's own auditor finds the gaps
"FAA also has not conducted sufficient research on passenger behaviors … and seat dimensions to show how they affect evacuation standards."
DOT Inspector General, which also found the FAA's last update to its evacuation standards was based on "an accident in 1991"2
-
The FAA tests evacuations on a narrow group
718 participants took part in the evacuations. The study did not include "children, people over 60, and individuals with disabilities", as the FAA's own notice later put it. It concluded that today's seats don't slow evacuation for 99% of Americans.34
-
The FAA asks the public one narrow question
Do seat dimensions delay "the group egress time … of an emergency evacuation"? The FAA was "not requesting comments regarding … passenger comfort or convenience", and called its own 90-second evacuation test "not a standard that the FAA expects to be met in every actual emergency evacuation." It did ask about seat sizes for "a broad range of passengers, including those who were not included in the CAMI study".4
-
26,102 comments come in anyway
-
A court accepts the narrow reading
"[A]lthough small seats can certainly cause soreness and stiffness, those conditions are not safety hazards … To be sure, many airline seats are uncomfortably small. That is why some passengers pay for wider seats and extra legroom. But it is not 'clear and indisputable' that airline seats have become dangerously small."
US Court of Appeals for the D.C. Circuit, turning down a request to make the FAA act6
-
The FAA says no
A petition for minimum sizes "fails to demonstrate to the FAA that the requested dimensions … are necessary for passenger safety." Concerns like families sitting together and air rage "exist irrespective of the minimum dimensions". In a crash, it argued, "a smaller (closer) pitch is safer for unbraced (i.e., the majority of) occupants." Its resources "will be dedicated to higher priorities."7
The same letter said "the overwhelming majority of comments … expressed a preference for wider seats or more legroom", and that the FAA "continues to review and analyze the more than 26,000 comments submitted."7
"… the FAA denies your petition for rulemaking."
-
Reviewers find the FAA's evacuation study doesn't support its conclusion
National Academies, reviewing the FAA's January 2021 evacuation study: its key conclusion "is not supported by the design and results of the research project."8
The FAA had leaned on that study in its 2023 letter, saying it "found that current seat dimensions accommodated 99% of the more than seven hundred passengers who took part in the study."73 The people the study left out, the reviewers noted, "are common on airplanes."
-
Still no minimum seat size
The one-year deadline Congress set passed in October 2019.
What people asked for
Drawn to the same scale. The typical request is the middle value: 34 in of row from the 2,062 distinct comments that named a row size, and 20 in wide from the 2,444 that named a width. The middle half of requests ran from 32 to 35 in of row and 19 to 22 in wide.
In their own words
Seat size needs to be regulated for the health and safety of passengers beyond the reasons of evacuation.
I am a size 20, my size and weight do not impede my ability to live a regular average life, except when it comes to air travel.
As a disabled person (mobility issues) I need to be able to lean forward enough in my seat for my face to be over my toes in order to stand up and transfer out of the seat.
I am 5’1” 120 lbs and have been in airline seats where I had to bend sideways to bend forward in the emergency landing position.
It’s insane how miserable it is to sit in a flight for 4 hours with your knees in your stomach and arms tucked in.
Stuffing people into smaller and smaller seats promotes frustration and anger.
I recently sat in a seat less than 18" wide which caused painful crushing/pressure to my hips & thigh bones for the duration of the 3.5 hour flight.
As a 72 year old woman I have difficulty getting out of my row if I occupy a window seat.
As a woman of 5’10”, it’s not uncommon for me to find aircraft seats so close to one another that I can barely adjust how my legs rest and so narrow that my hips are pressed on both sides.
The airline seats have become increasingly smaller over the years to the point whereby reclining the seat during a flight can cause an argument or commotion.
As someone who is 5’9”, it is impossible for me to get up out of my seat quickly in case of an emergency.
It's not like there's ever an option to purchase a wider seat unless you want to pay many times the amount of an economy seat for first class.
I am sick of having my knees crushed by the person in front of me who wants to lower their seat so I have no room in front of me even to hold a book.
I am a parent with a young infant and having to cram into a seat that barely fits myself with the infant is a safety hazard for the baby.
I have been flying for years and this uptick in violence and outbursts I feel is a reflection of the flying experience, being packed in like sardines and the economic and psychological implications can be measured.
Smaller seats result in wedging yourself between arm rests, which often cut into hips and thighs.
We’ve flown 9 times this summer and the seats on most airlines caused physical pain by the end of the flight.
Normal boarding & deboarding takes much longer; I cannot imagine efficient evacuation processes during an emergency.
We are humans not animals to be stuffed into smaller & smaller spaces.
People don’t like being treated like a can of sardines - all squished together.
Congress asked once. Ask again.
The 2018 law is still on the books, and its deadline passed in October 2019. Tell your representative and senators the FAA still hasn't set the seat sizes Congress ordered, and send your complaints where they're counted.
How we sorted the comments
We downloaded 26,102 of the 26,102 comments posted on docket FAA-2022-1001 through the Regulations.gov API. 110 had no text of their own: only an attachment, or nothing at all.
Many people sent the same campaign letter. We grouped near-identical letters, leaving 24,778 distinct texts; the largest letter was sent 249 times. Each distinct text was sorted once, and counts once for every comment that sent it.
A local AI model (qwen3.8:27b-mlx, run on our own computer) sorted each distinct text by theme. A comment can have several:
- Evacuation: getting out of the plane in an emergency, a crash or fire, or reaching the exits quickly. The model's tag counts only when the comment's own words mention one of these; a general word like "safety" doesn't.
- Health: pain, blood clots, injury, circulation or other medical conditions.
- Body size: tall, large or broad people, or knees and shoulders that don't fit.
- Disability and age: disabled or elderly passengers, children and infants, or limited mobility.
- Fights and air rage: arguments, air rage, reclining disputes, or neighbors spilling over.
- Cost: airlines profiting, fees, or paying extra for space.
- Comfort: discomfort, or being cramped or squeezed. The model's comfort and body-size tags count only when the comment's own words describe discomfort, a cramped seat or a body that doesn't fit; a plain request for bigger seats doesn't.
To check the sorting, Claude, an AI assistant separate from the sorting model, read 100 randomly chosen comments, plus the 20 largest campaign letters, every one of which had to be right, and judged each one itself without seeing the model's answers. Evacuation tags were right 98% of the time and caught 96% of the comments that raised evacuation. For the other harms, the figures were 92% and 100%.
Download every comment's labels (a spreadsheet with comment numbers, dates, states and themes, and a link to read each comment in full on Regulations.gov; no names).
The FAA's one question: do seat dimensions delay "the group egress time … of an emergency evacuation"?
45%raised getting out in an emergency, the question the FAA asked
88%raised harms beyond how fast people get out: health, body size, disability and age, fights, or discomfort
41% did both. Many raised the FAA's evacuation question, and even more described what else these seats are doing to them. The one thing the FAA said it was not asking about was "passenger comfort or convenience."
Public comments on docket FAA-2022-10015