Ms. Kathleen Blank Riether
Office of Aviation Enforcement and Proceedings
Office of the Secretary
Department of Transportation
1200 New Jersey Ave., SE
Washington, DC 20590
RE: Advisory Committee for Aviation Consumer Protection
Sixth Meeting of Advisory Committee, October 29, 2014
Discussion on Regulating the Use of Mobile Wireless Devices for Voice Calls on Aircraft by DOT
Dear Ms. Riether:
On behalf of the Transportation Trades Department, AFL-CIO (TTD), I write in regard to an agenda item discussed at the October 29, 2014 meeting of the Advisory Committee for Aviation Consumer Protection: regulating the use of mobile wireless devices for making voice calls on aircraft. By way of background, TTD consists of 32 affiliate unions that represent workers in all modes of transportation, including aviation workers who would be negatively impacted by the introduction of voice calls while in-flight. These workers are represented by the Air Line Pilots Association (ALPA); the Association of Flight Attendants-CWA (AFA-CWA); the International Association of Machinists and Aerospace Workers (IAM); and the Transport Workers Union of America (TWU).
TTD and our affiliates strongly oppose efforts to overturn the decades-old policy that prohibits passengers from using mobile wireless devices to make voice calls while in-flight. As thoroughly explained in our filings to proceedings promulgated by the Federal Communications Commission (FCC) and Department of Transportation (DOT), we believe the introduction of in-flight voice calls pose unnecessary safety issues and security risks to passengers and flight crews, including flight attendants and pilots. Overturning this longstanding policy also creates another unnecessary distraction in an inherently disruptive cabin environment that could create adversarial interactions between passengers.
For these reasons, we disagree with Advisory Committee member Charles Leocha’s statement that voice calls could be permitted after takeoff and before landing, but restricted during other hours of flight. The safety and security concerns we raise in our comments are not mitigated by limiting voice calls to the critical phases of flight, when flight crewmembers routinely communicate important safety announcements to passengers. We also note that a majority of respondents to several public opinion surveys oppose allowing in-flight phone calls due to their potential to cause distractions and negative impacts on the flying experience. Moreover, in September 2014, 77 members of Congress representing districts across the country signed a bipartisan letter urging federal agencies to ban voice calls on commercial aircraft. It is not surprising, therefore, that a significant portion of comments filed in response to DOT’s proposal on this issue opposed voice calls during flight.
For a fuller explanation of the safety and security concerns caused by the introduction of voice calls, we refer the Advisory Committee to the attached comments filed by TTD to the FCC and DOT proceedings on this issue.
 Attached is a complete list of TTD’s 32 affiliates.
 Department of Transportation, Office of the Secretary, ANPRM, ‘Use of Mobile Wireless Devices for Voice Calls on Aircraft,’ Issued February 24, 2014, Docket No. DOT-OST-2014-0002; and Federal Communications Commission, NPRM, Expanding Access to Mobile Wireless Services Onboard Aircraft,’ Issued January 15, 2014, WT Docket No. 13-301; FCC 13-157.
 (a)Portable Electronic Devices Aviation Rulemaking Committee Report to the Federal Aviation Administration, Recommendations on Expanding the Use of Portable Electronic Devices During Flight, September 30, 2013, page 174. http://www.faa.gov/about/initiatives/ped/media/ped_arc_final_report.pdf.
(b) See also: Quinnipiac University poll, December 11, 2013, ‘Keep Cell Phones Off Planes, American Voters Say 2-1, Quinnipiac University National Poll Finds; More People Spending Less on Holiday Gifts,’ www.quinnipiac.edu/images/polling/us/us12112013_anr2s9.pdf.
(c) See also: Comments submitted by Delta Air Lines, Inc., on October 30, 2012, Page 1. Comments were filed to FAA Notice of Policy, Passenger Use of Portable Electronic Devices on Board Aircraft,” Issued August 31, 2012, Docket No. FAA-2012-0752.
 Letter led by Representatives David McKinley and Dan Lipinski sent on September 22, 2014 to DOT, DHS, DOJ, and FCC. The letter calls for a ban on voice calls and for the agencies to work together to fully address potential safety and security concerns before expanding wireless services in-flight.
TTD Reiterates Opposition to Voice Calls on Commercial Flights (4MB)