FAA Refuses To Consider American’s Request To Put Doors On Business Class Seats

A week before American Airlines announced their new business class suites with doors I reported that they had asked the government’s permission to install these seats.

You see, virtually everything on an airplane is more heavily regulated than you’d expect, even if you know that everything it highly regulated. For instance even giving out hand sanitizer to passengers required specific approval from the FAA. Some people mused that hand sanitizer could be flammable but the FAA had already considered and rejected that risk.

It turns out that seats with doors actually requires a specific regulatory exemption because regulations ban doors inside passenger cabins (like between coach and premium economy, or between premium economy and business, so airlines use curtains instead).

  • Regulators don’t want doors in the cabin in case those inhibit egress during an emergency.

  • So the airline had to ask the FAA to say that these doors aren’t like those doors, and besides they’ve granted other airlines the exemption already.

Credit: American Airlines

However the FAA didn’t just grant the pro forma request. Instead they refused to process it. The stated reason is that when American Airlines filed its petition, it did “not comply with the requirements of 14 CFR § 11.81.”

How was it deficient? The American Airlines electronic submission was on letterhead that did not include the carrier’s mailing address at 1 Skyview Dr, Fort Worth, Texas. It also did not list.. a fax number.

As the government explains, 14 CFR § 11.81 requires listing “[y]our name and mailing address, and, if you wish, other contact information such as a fax number, telephone number, or email address.” Since the FAA doesn’t know where to find American Airlines, and didn’t think to ask the agency’s own American Airlines Certificate Management Office, they declined to consider the request to place doors on business class seats.

This will be addressed. The FAA knows American well enough that they were able to send a letter informing them that sufficient contact information wasn’t provided. American has 30 days to provide the FAA with its address, and then they’ll consider the exemption to allow business class suites with doors on their new delivery Boeing 787-9 aircraft, new Airbus A321XLR aircraft, and retrofitted Boeing 777-300ERs, and other such planes as American shall decide.

To be sure, there is no rush. We won’t see these new seats until 2024. The actual letter from the FAA (.pdf) – which, not for nothing fails to include a date at the top – was written more than one month after American Airlines submitted its request.

It took the FAA over a month to reject consideration of American’s request for lack of a mailing. That is more time than American itself has to correct the letter, and longer than I’ve ever had to wait to receive a drivers license from the DMV.

About Gary Leff

Gary Leff is one of the foremost experts in the field of miles, points, and frequent business travel - a topic he has covered since 2002. Co-founder of frequent flyer community InsideFlyer.com, emcee of the Freddie Awards, and named one of the "World's Top Travel Experts" by Conde' Nast Traveler (2010-Present) Gary has been a guest on most major news media, profiled in several top print publications, and published broadly on the topic of consumer loyalty. More About Gary »

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  1. The FAA is an agency under the Dept. of Transportation, a cabinet level agency under the responsibility of the President.
    If you don’t like the way bureaucracy works, start housekeeping at the top

  2. It seems to me, based on the article, they did not provide adequate contact information including the petitioner’s mailing address or any other contact information.

    I get it, it sounds silly, but submission requirements exist for a reason. They are requirements. AA deals with the FAA all the time. Seems that they would know better.

    Ever try buying an airline ticket on their website, using a credit card, and forget to input the CC expiration date? Yup, rejected. Newsworthy? Nope.

    Nothing here folks, move along.

  3. @Kevin King – this was literally a request for the FAA to waive requirements, and the requirement the FAA chose not to waive was listing the airline’s address.

    The FAA had no problem writing back, so they must have had the airline’s contact information.

  4. Lets copy Delta (roll eyes) just like we did with overpricing int award seat redemption’s.
    Take the money and invest in a more comfortable seating in every class of service especially coach so I want to pay more for a better onboard experience and please don’t stop there
    What the heck do doors do.It doesn’t help with the guy snoring in front or behind you
    In smaller aircraft it makes everything more closed in
    waste of money IMHO

  5. IMO it’s a toss-up on the management of both how stupid it can be? Having contracted a lot of federal – military mostly – contracts, I understand how they work. Know your CFRs (Code of Federal Regulations) and that’s it because nothing else matters. Virtually no one (feds) knows a damn thing about the actual work/job. It’s all about how much paper you can throw at the problem. AA you don’t have an excuse.

  6. Apparently Tim thinks the president monitors the work of tens of thousands of bureaucrats. This kind of official idiocy has been going on since Caesar’s time. A chaotic and angry pathological liar would be the least likely person to improve things.

  7. Address is a mandatory field to buy a ticket online with a CC on American’s website. Not sure what the issue is. Heck, AA even makes you declare your state of residence before purchasing so it can offer you insurance.

    Here they’re filling a regulatory request that is public record without putting an address on it? Seems amateurish at best.

    If this were an online form, they would not be allowed to proceed.

  8. chaotic and angry pathological liar?
    Sounds like someone has been pretty effective at getting you worked up. If something is false, any normally adjusted person can figure that something incorrect isn’t worth addressing.

    And you still miss how organizations work. The FAA reports to the DOT which reports to the Sec’y of DOT which reports to the President. No CEO goes to the baggage handler that misloaded a bag but they sure as heck better talk to their COO if baggage issues are a problem for the company – and the COO talks to…. and on down the chain.

    Yes, if a government is failing, it is the “big guy””s job to fix it. No different with a CEO of a company

    Realities that you don’t like are still reality.

  9. Look Dune, I mean Dunn, just shut up. Even Elaine Chao, the Transportation Secretary at the time gave the orange thug the middle finger and resigned!!Have a little shame for once!!

  10. There are regulations out there that require communication by fax. No one has ever bother to revise them. Had one the other day with a state agency that required the form be sent in by fax. No letters, no email, no PDF. Fax. And fax alone. And if you can’t find a fax machine, awww, we can’t process your form. Almost surprised they don’t require it by telegram – because that hasn’t been available for a couple decades. But sure would cut down on the work they have to do – because if you can’t get it, you don’t have to process it.

    I sometimes think it’s by design. I’ve also run across doctor’s offices that require things by fax. Email is unsecure, you see…

  11. If they really cared about the ability to rapidly empty the plane in an emergency they’d take steps to expedite evacuations such as:

    Having overhead bins that lock from the cockpit so people wouldn’t be able to drag their suitcases out while other people are trying to escape with their lives.

    Run evacuation protocols that are not ridiculously ideal. Currently, everyone knows that the evacuation will happen shortly, there are no screaming children, vast amounts of smoke, people who need wheelchairs to move effectively, people of size trying to squeeze out of their seats, elderly and infirm people, people in a panic, etc.. In short, the current evacuation tests in no way reflect reality. Someday that’s going to cost a lot of people their lives.

  12. Having doors in business class is purely a cosmetic gimmic…just something more to get in the way when you want to get out of your seat to use the lav.
    Was there ever a customer survey to determine the interest and desire to have doors (of dubious size) in your little travel space. It looks like they are the lower half of a “dutch door” which really doesn’t add a lot to reducing unwanted views.

  13. @Christian – locking overhead bins might just mean passengers spend even more time tugging on the bins, trying to open them, and slowing down evacuation even further! Now if there was a button to remotely shut down all cell phones, so no one could take selfie videos of their evacuation…

  14. @ Tim Dunn — Your comment is absurd. There is absolutely nothing wrong with the FAA’s refusal to process the application. Try filing your taxes without your SSN, and let me know how that works out. Furthermore, this has zero to do with the POTUS. I think an FAA application is way below his pay grade. Maybe you’re used to the prior POTUS, who didn’t hesitate to meddle in anything and everything, no matter how petty it was.

  15. @todikaios – Nothing gets done without massive customer input. Someone’s job depends on getting that input, so of course there are surveys, mockups, studies, evaluations, human factors, etc.

    @Christian – Adding locking bins adds weight, complexity, cost, and operating cost to every aircraft and every flight. It add little to safety, not to mention that the number of evacuations on aircraft is a tiny number and most passengers (like 99.99%+) will never experience it. And even in evacuations that do occur, I can think of none that involved people getting trapped by people taking their bags. Not a good idea, but you don’t spend millions on something that would be a black swan event. You might as well put four-point harnesses and require everyone to wear helmets if you’re going to design against remote events, they would probably prove more useful more often, though barely.

  16. @Tim Dunn

    Unfortunately, these federal agencies are filled with a bureaucrat class that can’t be easily fired or replaced. It’s like teachers who can’t be fired or workers in France who have a job for life. Any change at the top does little to stop the kafkaesque nature of these agencies as the individual workers have a vested interest in being inefficient, making problems when there are none, and leaking decision making processes to the public. This bureaucrat class down to the person in the mail room has an incentive to keep ridiculous regulations and regulatory power that doesn’t serve the public.

    This is the reason why Trump did absolutely nothing in terms of draining the swamp. Admittedly, he was highly incompetent and in inept as he didn’t take basic steps every president before and since did like fire all federal prosecutors from the prior admin, replace the defense policy board, and replace the military leadership. Trump didn’t replace the defense policy board until Dec. 2021 while Biden did it March 2022 and fired all federal prosecutors from the prior admin as well. Trump didn’t order federal agencies to hire and promote specific people which cause flood these agencies with loyalists. He basically tweeted and federal agencies were unchanged from the Obama era. The left was right about Trump being cognitively impaired.

    Whatever the case, if 51% of the public wants a system 49% are harmed. We might do better to recognize that supporting democracy where 51% can cripple and torture 49% is not something that’s logical to defend.

  17. Gene,
    I think you missed the point. COMPLETELY.
    Nowhere did I say that American should get a pass for failing to fill out the form correctly.
    My point was and still is that if people don’t like it, start w/ the top of an organization and clean that up and work your way down.
    American voters don’t elect the Secý of the DOT or the FAA administrator.
    If they are ticked about how the system works, you replace the top.
    Nowhere have I said that a President does or should meddle in an application.
    All of the people that have replied clearly don’t understand that the person at the top of an organization bears responsiblity for that organization.

    But tell me what do you suppose those people that are complaining about the tyricanical FAA should do? Storm Washington DC in protest, or complain on Gary’s site, or just fill out the form properly? and more importantly, what would be the best thing to get the damn doors approved?

  18. Much-ado about nothin’, @Tim Dunn. AA petitioned the government for an exemption from a code of federal regulation (14 CFR), which specifically requires the petitioner to provide the info that AA failed to provide and has 30 days to provide to have its petition considered. End of story. There is no need to agitate to change the country’s chief executive because the government did nothing wrong. It was all “by the book.”

    On the other hand, what I found interesting is one of AA’s reasons for why the proposed addition of business-class seat doors “would be in the public interest; that is, how it would benefit the public as a whole”:

    This additional revenue [from charging more for business-class seats with doors] helps to provide an offset opportunity to reduce the cost of economy class travel, thus providing the potential to benefit all passengers of the flying public, all without compromising safety.

    While technically a plausible reason, the notion of AA as a modern-day “Robin Hood” who would take from the rich to give to the poor strikes me as a bit farfetched… 🙂

  19. C_M – I’d like to know from the users of this Forum if they were queried and had the opportunity to participate in a survey (by American) as to the value and desire for doors in Biz Class.

  20. GMAB. 14 CFR Sec. 1181 What information must I include in my petition for an exemption?, is short, sweet and clear as day.

    This is totally American’s fault. The FAA’s so-called “Refusal to Consider” is exactly the same as not correctly filling out an online form and the website highlighting the missing or incorrect information and not processing the form until the information is submitted correctly and fully. It happens to me from time to time. Instead of ranting at the website, I correct the deficiency and resubmit the form. Simple.

    That AA can’t follow simple, easy-to-comply-with instructions in regulations it should be familiar with somehow becomes the FAA’s fault in the eyes of VFTW and Tim Dunn. But the issue is that AA’s incompetency involves a regulatory body in a Democratic administration. Therefore it triggers a Pavlovian response here and becomes akin to an impeachable offense in the eyes of Tim Dunn. AA’s CEO needs to teach employees how to read and follow simple instructions.

  21. the fact people find this surprising from an airline that can’t run efficiently even on a blue sky day. This doesn’t surprise me.

  22. @todikaios – AA flies millions of people. They only need a small sample size to run the study. (It’s why you can survey 1000 people in a country of 335 million and get within a few percentage points of the outcome of an election.) The odds of any one person from that study being here are remote. Please read up on statistics to find out why this works.

  23. @C_M has a valid point, provided that certain assumptions about the sample are met, or deviations from those assumptions are adjusted for. It is called inferential statistics…

  24. No C_M! Pollsters have been getting things wrong the last few years!
    Their occult black magic has lost it’s power!
    Time to turn to that old reliable:
    our collective gut!
    Remember: math is racist!

  25. The same bureaucrats so many are willing to turn their health care and other aspects of day to day living over to.

  26. Tim. Take your love of corrupt trump and go to fake Fox News. We do not want political opinions in a travel forum we get it Trump lost and you are still mad . Go to Mar largo and get the documents he stole from Americans and sold to Putin and stop selling snake oils

  27. Even the irs code requires name address etc if it is in the regulations then you need to comply

  28. Dillion,
    you STILL don’t get it.
    If anyone cares about AA’s application being set aside for a month and then being rejected for a simple clerical issue, they should do something about it.
    I could care less about Trump.
    You can’t seem to grasp that I and the vast majority of people could care less about AA’s big seat door application.
    If they or you care about it, fire the boss that you can fire.
    Not rant about a bureaucrat that is just doing what bureaucrats do.

    The response would literally be no different regardless of who is in the WH.

  29. American Airlines – a company that should be able to put together a compliant FAA filing in its sleep – messes up a document and Tim Dunn is calling for a new President of the United States. You just can’t make this stuff up.

  30. I’m reasonably certain that the completeness review was completed within hours of receipt, and AA would’ve gotten a polite phone call warning of the deficiency. The remaining weeks were spent putting the letter through the absurdly long clearance process that political leadership requires before releasing it (btw, clearance was no faster under the previous administration — you can’t blame “the swamp” for this one). Forgive me, but I really don’t think it’s too much to ask that a petitioner include their name and address so that the public will know who is asking the FAA to waive the rules. What blows my mind is that AA surely had very expensive lawyers review this, and none thought to flag this deficiency.

  31. Gary,
    please put a reading comprehension test before someone can comment.

    For about the sixth time, let me know that I am NOT advocating for Biden to jump into this fray.

    Let me repaste my original comment
    “If you don’t like the way bureaucracy works, start housekeeping at the top”

    Four letter words can get people in trouble but two letter words can make or break the best laid plans of men.

    I said “IF you don’t like the way bureaucracy works…”

    I don’t care whether AA’s application was rejection but IF someone actually does… start at the top.

    Trump is history and so is AA’s application.

    Trump might get another chance but AA’s application certainly CAN IF they can follow the rules.

    Anyone that moans about the ill-treatment that AA got should simply ask what would have happened IF AA could have followed directions the FIRST TIME.

    And IF people could read and respond to what was said and not be triggered by their political biases, Gary would be a poor man with no one responding to his articles.

  32. Clearly a massive culture problem at the Dept. of Transportation. Let’s not let the comic stupidity of this obscure how outrageous and imperious it is.

  33. This is all hokum , AA will pay the right people off in a week and everything will be back on schedule ……Next.

  34. There’s back & forth over Biden’s role here. The plain fact is that we need a President who’s willing to tell ALL of federal government “DON’T DO STUPID $#¡+” and then punish and embarrass those who do. That’s the best way to deal with stuff like this.

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