Background

The Americans with Disabilities Act (ADA) and the Air Carrier Access Act (ACAA) ensure the rights and accommodations of individuals with disabilities in the United States. The ADA provides a comprehensive national mandate for the elimination of discrimination against individuals with disabilities, including in employment, public accommodations, and transportation. The ACAA addresses the rights of passengers with disabilities in air travel and requires airlines to accommodate the needs of these individuals.    

Airlines and airports play critical roles in implementing these laws. Airlines are responsible for ensuring that their services, from booking to boarding, are accessible, while airports must provide accessible facilities. However, the intersection of the ADA and ACAA can create challenges, as the ADA covers public spaces such as airport terminals, whereas the ACAA governs the treatment of passengers by airlines within the airport terminal. The Federal Aviation Administration (FAA) and the U.S. Department of Transportation (DOT) also have regulatory authority over air travel, including consumer protections, safety, and operational standards. While FAA's primary focus is on safety and efficiency of the national airspace system, it plays a supporting role in ensuring compliance with accessibility standards through various policies and guidance. It includes collaboration with the DOT, the U.S. Department of Justice (DOJ), and other agencies to ensure that regulations and guidance related to disability accommodations are upheld.

Objective

Provide a report that details the legal obligations for airports and airlines arising out of the Americans with Disabilities Act and the Air Carrier Access Act, including accommodations for visible and invisible physical and mental impairments that substantially limit one or more major life activities. The report should focus on the onset and extent of the airport and airline obligations and where they statutorily and practically overlap or where there are gaps. It should explain the statutory text imposing the obligations and the relevant agency interpretation as reflected in regulations and policies, and which agencies (DOJ, DOT, FAA, etc.) regulate and enforce these requirements vis-à-vis airports and airlines. Two or three case studies should provide good collaborative practices between airports and airlines that enhance physical and service accommodations for passengers with disabilities.

Status RFP expected Feburary 2026