Post-Covid Airline Information for Older Passengers with Disabilities

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Most restrictions that made air travel difficult during the pandemic have been eased. As travelers return to the skies, family members may be concerned about booking flights for older loved ones who are living with disabilities. Fortunately, airlines are required to accommodate most disabled passengers. 

As passengers grow less wary of flying in the post-pandemic world, it is time to update our original guide to airline travel for older passengers who are coping with disabilities. Passengers and their family members should consult our original guide for detailed information about airport screening, requesting accommodations, traveling with a companion, and other issues of interest to disabled travelers.

Protections for Disabled Airline Passengers

The Air Carrier Access Act (ACAA) protects the rights of disabled airline passengers. The act defines “disability” as either a temporary or permanent condition that impairs a major life activity. Walking, seeing, breathing, and communicating are examples of major life activities.

The ACAA prohibits discrimination against passengers with disabilities. Airlines may not refuse to board a passenger because the passenger is disabled and may not limit the number of disabled passengers on a flight. Airlines may not demand advance notice that a passenger is disabled, although they may ask for advance notice before providing certain accommodations that require preparation time.

Airlines may not prevent disabled passengers from exercising the same opportunity offered to other passengers to select their own seats. Disabled passengers generally have priority requesting seats with movable armrests. Disabled passengers have the same right as other passengers to sit in an emergency exit row if they are able to perform required tasks. 

The Department of Transportation regularly amends the rules that require airlines to accommodate the needs of disabled passengers. Our guide to booking flights for older family members details most of those rules. An amended rule governing service animals and a proposed rule addressing accessible lavatories are discussed below.

Rule Change Governing Service Animals

In general, the ACAA requires airlines to transport service animals in the cabin for free. The revised version of the service animal rule was adopted in 2020. Although the rule still requires airlines to allow disabled passengers to be accompanied in the cabin by no more than two service animals, the revised rule is in some respects more friendly to airlines than to passengers. 

The revised rule defines a “service animal” as a dog that is trained to perform specific tasks. Airlines are no longer required to transport any service animal in the cabin other than a dog. Airlines can require the dog to be leashed, harnessed, or otherwise tethered onboard the aircraft.

The airline may require a passenger to fill out a form to certify that a service dog is in good health, well-behaved, and trained. If the flight is longer than 8 hours, the airline can require the passenger to certify that the dog is trained to avoid going to the bathroom for a prolonged time or has been trained to do so in a sanitary way.

The revised rule also excludes dogs that serve only as emotional support animals from the definition of “service animal” unless the dog is trained to perform specific tasks that relate to a disability. Airlines can treat an emotional support animal as a pet and impose the same rules for transportation that it applies to all other pets. Although they are not required to do so, airlines are free to treat emotional support animals as if they were service animals. Airlines have generally not accepted that invitation.

The rule draws a distinction between an untrained emotional support animal and a trained “psychiatric service animal.” A psychiatric service animal is a dog that is individually trained to do work or perform tasks for an individual with a psychiatric, intellectual, or other mental disability. Either a professional trainer or the dog owner may train the dog. For example, a dog might be trained to detect early signs of an anxiety attack and to alert an owner who suffers from an anxiety disorder. 

The current rule governing psychiatric service animals is more passenger-friendly than the former rule. Psychiatric service animals are treated in the same way as other service animals. Disabled passengers with psychiatric service animals are no longer required to provide a letter from a licensed mental health professional detailing the passenger’s need for the animal. Nor can they be required to check in earlier than nondisabled passengers.

The DOT was concerned that passengers might pretend to be disabled and might disguise their pets as service dogs to bring them on the aircraft at no charge. Disability rights advocates were concerned that airlines might discriminate against disabled passengers if they were entitled to insist on certifications or other training documents that disabled owners of service animals do not otherwise need. 

The DOT compromised by allowing airlines to decide whether a dog qualifies as a service animal by (1) asking the owner if he or she is disabled and, if so, what disability-related tasks the dog is trained to perform; (2) observing the animal’s behavior; and (3) looking for physical indicators that the dog is a service animal, such as vests and harnesses. Airlines may not inquire about the nature of a passenger’s disability. Since airlines must consider all three factors, it is doubtful that an airline can lawfully refuse to fly a service animal simply because it is not wearing a vest.

Proposed Rule Change Governing Accessible Lavatories

The ACAA and its implementing rules require all twin-aisle aircraft purchased since 1990 by a US-based airline to have an accessible lavatory. A lavatory is deemed “accessible” if it allows passengers using the airline’s aisle wheelchair to enter and maneuver with enough room to use all lavatory facilities. Since only a few aircraft on major US airlines were placed into service before 1990, most wide-bodied jets now have accessible lavatories.

Current rules do not require single-aisle aircraft to have an accessible lavatory. Aircraft manufacturers often offer an accessible lavatory as an option, but most airlines did not purchase that option when they added single-aisle aircraft to their fleet. The unavailability of accessible lavatories is a problem for passengers who use wheelchairs, as airlines are increasingly relying on single-aisle aircraft for flights of four hours or more. 

A proposed rule, if adopted, would require newly purchased single-aisle aircraft to have at least one accessible lavatory. Since airlines typically operate newly acquired aircraft for about 30 years, many years will pass before most single-aisle aircraft meet the needs of passengers who use a wheelchair.

Chart of Disability Accommodations by Airline

All airlines transport wheelchairs in the aircraft’s cargo compartment, provided the wheelchair will fit through the cargo door. Most larger aircraft have at least one space for in-cabin storage of collapsible wheelchairs. They make that space available on a first-come, first-serve basis. 

Motorized wheelchairs are not allowed in cabins, but passengers are generally allowed to check them at the gate and must be given assistance boarding and exiting the aircraft on a wheelchair furnished by the airline. Keep in mind that the airline industry regularly damages or loses wheelchairs that are transported with cargo.

The following updated chart compares four accessibility features of aircraft operated by popular airlines that operate within the United States. The chart indicates whether all, some, or none of the aircraft operated by each airline have:

  • At least some seats with movable armrests.
  • An aisle chair (onboard wheelchair).
  • An aisle chair accessible lavatory.
  • Cabin storage for at least one collapsible manual wheelchair.

Regional airlines that fly shorter routes typically operate smaller aircraft that are less likely to offer the accessibility features described in the chart. Disabled passengers who are uncertain about an airline’s ability to meet their needs on a particular flight should consult with the airline’s special assistance desk 48 hours before their scheduled departure. 

Airline Movable Armrest Aisle Chair Accessible Lavatory Wheelchair Storage
Air Canada¹ all all some some
Air France² all all some all
Alaska Airlines all all some all
Allegiant Air all all some all
American Airlines all all some all
American Eagle some some none some
British Airways² all all some all
Delta Airlines³ some some some all
Frontier all all some some
Hawaiian Air all all some some
JetBlue all all none all
Lufthansa2 all all some some
Southwest Airlines all all none all
Spirit all all some all
United Airlines4 all all some all

1 Information is limited to flights serving airports in the US, excluding Air Canada Express and Air Canada Rouge.
2 Information is limited to flights serving airports in the US.
3 Excluding Delta Connection, Endeavor Air, and other regional carriers operated by Delta.
4 Excluding United Express, Mesa Airlines, and other regional carriers operated by United.

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