Bradley W. Morris

The following comment is part thirteen in a series of thirteen comments, the whole of which I have attached in pdf form with the first part of the series. /__________/ 8. “The Department notes that the ACAA is a separate statute from the ADA. The ACAA is a specialized statute dealing only with transportation by air, in an environment in which a large number of people are confined within a limited space for what may be a prolonged period of time. The Department has long taken the position that accommodations for persons with disabilities, and DOT requirements for them, may justifiably differ between the air travel context and other contexts, such as places of public accommodation regulated by the Department of Justice under its ADA regulations. We seek comment on the application of this principle in the matter of PSAs and ESAs.” /__________/ It is true that requirements for accommodations for persons with disabilities may justifiably differ between air travel and other contexts. However, the differences should be limited to practical considerations, such as aisle width, restroom size, threshold height, etc. The same ethical principles of non-discrimination should not be thrown out the window. License for accommodation requirements to differ is not license to start from scratch with a new set of principles about which kinds of disabilities deserve external barriers to travel and which don't. I encourage revisers of the ACAA to keep this in mind when considering whether certain revisions are acceptable, and moreover whether they are best in keeping with the principles that are intended to drive both the ADA and the ACAA.