Letters to the Editor

Subject:  Should the government FORCE parents to purchase airline tickets for toddlers?
From:  Name Withheld

Editor’s Note: A writer has challenged my response in FAQ # 5, to those parents who cannot afford to purchase an extra seat for their baby.

I have responded to the statements, in his first letter, by inserting comments, in italics with brackets. His second letter follows the first, without inserted comments. My final comments rely largely on Briefing Paper No. 11 August 30, 1990 by Richard B. McKenzie and Dwight R. Lee:



Richard B. McKenzie is Hearin/Hess Professor of Economics and Finance at the University of Mississippi, and Dwight R. Lee is Ramsey Professor of Economics at the University of Georgia. McKenzie is an adjunct scholar at the Cato Institute. An earlier version of these comments was filed on May 30, 1990, with the Federal Aviation Administration with reference to Docket no. 26142 by the Competitive Enterprise Institute in Washington, D.C.

I urge readers to read the entire Briefing Paper No. 11. It can be accessed at:

Unfortunately, the writer of the following letters, would not give permission to publish his name or E-Mail. I will not speculate as to why permission was refused.



Subject: FAQ#5  : How can we best protect our baby when we fly?

Dear Editor,

To ignorantly suggest to the public the use of a device unintended for use as a restraint, ala the front-carrier, for such use is irresponsible.  [Also, see the  Rational Solution]

[Why is it ignorant and irresponsible? Are you suggesting that a parent is more likely to be able to hold on to the child, during a crash or turbulence, with just arms and hands than if the child was encased in a front pack that is tied to the parent? If you are, I would be interested in hearing specific reasons as to why you think that.]

To support a safety decision with general statistics in comparison to the competition and the claim of a consumer that can't think for itself is irresponsible.

[I have no idea what this statement means. Could you try restating in a more coherent manner?]

You devalue human life when you put cost before safety-the cost of a ticket (Delta charges half price for toddlers which makes for an even cheaper compromise).

[Since any given safety device or policy has a dollar cost, the statement is meaningless. I would prefer that all parents pay for the extra ticket -- whatever the cost -- but, in the real world many will opt to drive, rather than fly, before they will buy that extra ticket. If they drive, they increase the risk by about 30 to 40 times. That translates into more children killed than if they fly. It seems to me that the one doing the devaluing of human life is the one who chooses to expose his child to a significant increase in risk if he can afford the lesser risk option.]

People like you should stay off the road.

[Why? What do you know about my driving record -- or do you make it a habit to develop firm convictions before you have the facts?]

I am not going to put my child on a ride that could possibly take his life. I'd rather walk to Alabama.

[I presume you are willing to swear, under penalty of perjury, that you have never allowed, and will never allow your child to ride in/on:

1. A bicycle.

2. Automobile.

3. A horse or pony.

4. A horse carriage.

5. A bus.

6. Roller skates.

7. Skate board.

8. Ice skates.

9. Amusement park rides.]

If you are going to build machines to transport human lives why argue the safest way possible with economics when you should be arguing physics.

[Not certain of what you mean, but I will guess. If by physics, you mean that death is more likely in a plane crash, than in a car crash (because of the increased speed), then I would agree. But, if SAFETY is really your concern, then you must also consider statistics. No one, who is really interested in the facts, will argue that driving is safer than flying. Death is much more likely in automobiles than planes simply because they crash far more often. The increase of frequency of crashes of road vehicles far outstrips the risk of death in airplanes.]

Just because you have never heard of any incidents of CAT injuring babies wouldn't make me feel lucky for mine to be the first.

[Of course you wouldn't feel lucky, if you suffered such a misfortune. But what has that to do with the facts that none have been killed so far? Again, the odds of your child being killed in an airplane, even without his own seat, are far less than being killed in a car, with a seat. Risk is what I was talking about. If you select a home and neighborhood that has a low crime risk, so your children will be safe, then why wouldn't you give the same consideration to risk factors when you transport your children?]

But then I guess it takes deaths, bad publicity and lots of lawsuits and settlements to make anything safer more economical.

[That is why the FAA is referred to as the "Tombstone Agency." Many of the safety improvements we have today, came about only after deaths and bad publicity. I am speaking of those safety items that REALLY DO lower the risk. But, forcing parents to buy an extra seat for a child under two is not one of them. Many will opt to drive instead and that means MORE children will die, not less.]

I think I am a better driver than gambler.



OKAY, let's see... Perhaps I can be less vague now that I know you do in fact exist and obviously own feelings to this matter. You are the first of whom I have encountered.

First of all, in order to trust that airlines are doing everything possible to ensure the safety of its passengers, the facts about the risks are important. The fact is a baby in a carrier designed to accommodate flight regulations strapped in a seat places the baby at the lowest risk possible. Ignoring this fact in order to keep people from fighting worse statistics on the road places the baby on the plane and at higher risk to injury or death than anyone else on the plane. I do not trust that airlines are doing everything possible to ensure safety, but most people assume, without question, that since airlines allow their young to gingerly perch upon their laps, in flight, unrestrained, there is no inherent risk.

Furthermore, hearing you, sir, arguing the point with economics and statistics bares little significance to me. The point being, of course, that children under two should not be required a seat. The economics is that many people can't afford the extra seat. That is no reason to put a child at a risk that the government won't allow an adult to take, whether they can afford it or not. Automobile statistics here are irrelevant. I won't make this choice and in fact I don't think anyone should. I would feel a lot more comfortable with the government allowing parents to sit in the child's lap, unrestrained. Now, the statistics is that more babies die on the road than in planes. I ask that you narrow your statistics down to babies traveling interstate on the safest route, during the day, at low traffic, under good driving conditions, in a safe, family car inspected by a qualified technician, with excellent driver dad or mom at the helm. There are plenty of precautions to make to reduce the risks and the statistics. These I would rather do than blindly trust a corporation that doesn't make a whole lot of sense when supporting its concern for safety.

Finally, Mr. Editor in Chief, your advice for use of an infant "front carrier" is irresponsible because you are making an uneducated guess about its ability to restrain a child. In my opinion this is just another inaccurate assurance that a child without his or her own seat is reasonably safe. And again I believe most people will take that assurance to heart because they trust that neither you, their airlines, or their government would allow it if it were not true. I believe this is an abuse of their trust and is irresponsible.

"How many survive depends, in those cases, on how fast they are able to evacuate the aircraft. In a case like that, holding the baby on the lap may actually expedite the evacuation, whereas the time to get him unstrapped from his own seat could conceivably cause enough delay to allow you to both to be overcome with toxic fumes."

How can this make any sense at all if the baby that was sitting on your lap has been "wrenched from it's mother's arms"? Newton's first law of motion: an object in motion tends to stay in motion. The baby is most likely already dead and a speedy evacuation is of little concern.

At fourteen months an average child is approximately the same size in weight as a two-year-old.

"The recent clear air turbulence tragedy, near Japan, is an extremely rare occurrence, but it does provide a graphic example of why we tell passengers to keep their seat belts fastened even when the seat belt sign is not on. Then, if you have your seat belt on when the CAT hits, you and your baby should remain in your seat, while those who are foolish enough to leave their belts unfastened will be thrown into the ceiling. I have no expertise on what kind of load (G-force) such devices can withstand. It just seems a matter of logic that it would reduce the odds..."

Telling someone to fasten his seat belt is a responsible thing to do. Telling someone to place their child in a carrier approved for aircraft is a responsible thing to do. Telling someone to use a device "not intended for use as a restraint" in lieu of a seat belt is irresponsible, especially without knowing the facts. Very irresponsible and in my opinion, liable. I think airlines know that parents are not going to make a conscious choice to put their child at unnecessary risk and would probably not fly if they had to do so.

Parents need to know that their babies are safe as the only ones in the cabin unconfined by a seat belt. Somehow they are led to believe it.

Thank you for your reply,

P.S. I believe in the case of child safety the Free Market solutions are working.

P.S.S. It just occurred to me that even carry-on luggage is required to be somehow restrained either in the overhead compartments or underneath the seat in front of you but children under two are allowed to bounce around the cabin in an event of gravitational trauma. I suppose such requirements are imposed in order to protect us from the inertia of our own luggage. Is there nothing to protect us from our own children?

Name and E-mail withheld.

Permission to identify the writer was not given.


Excerpts from the Mckenzie and Lee Briefing Paper:

"…a movement is afoot within the airline industry and Congress to nullify, in the name of safety, many of the benefits of deregulation by ending the free ride of infants and toddlers. The airline industry's support of the proposed regulation is understandable, although objectionable. If adopted, the new regulation would enable airlines to suppress important competitive forces and sell millions more seats each year.

However, the traveling public should object to the proposed rule not only because it would raise travel costs but also because it would actually increase the death rate of traveling infants and toddlers and their parents.

Statistical analyses by both the Department of Transportation and private researchers indicate that the proposal [to force parents to purchase a seat for infants] could endanger more children than it would save if the increased cost of airline travel put more families back on the highways.

In case the FAA resists changing its seating rules, Rep. Jim Lightfoot (R-Iowa) and Sen. Kit Bond (R-Mo.) have introduced legislation to mandate the use of safety seats by the 5,000 to 10,000 infants and toddlers who fly daily on the nation’s 16,000 flights. Lightfoot was spurred to introduce his bill by the death of an infant in the crash of United Airlines flight 232 in Sioux City, Iowa, last July. He reasons that rules requiring the use of safety seats in automobiles should be extended to airlines because "the potential for injury in an aircraft flying at 550 miles per hour is much greater than the potential for injury in an automobile traveling at 50 miles per hour."

Lightfoot maintains that his proposal does not mandate the purchase of additional seats, only the use of safety seats by infants. He reasons that parents can use automobile safety seats, which have also been approved for air travel, and continue to use empty airline seats free of charge, as they now do. However, the safety seat rule would have the effect of requiring parents to buy airline seats for their infants and rent child restraint systems, if they do not have their own. Very few parents would buy their own tickets— especially the cheaper advanced tickets that are not refundable—and take the risk of not being able to board at the last minute because adjoining seats were unavailable.

However, what child safety advocates and the FAA have not yet considered is that the proposal, if adopted, could have precisely the opposite effect of the one intended: the rule change could increase the travel injuries and deaths of infants and toddlers--and their parents and siblings. Those perverse results would probably occur because the rule change would drive up the cost of air travel and drive many families back to the nation's highways. And automobile travel remains far more dangerous, at least 30 times more so in terms of death rate per mile traveled, for all travelers--parents and children alike--than air travel by all scheduled (large and commuter) airlines.

In a study prepared for the FAA, Department of Transportation researchers concluded that mandatory infant safety seats could have prevented at most only one infant death since 1978. All other infant fatalities in airline crashes occurred in sections of planes where no one survived. On the other hand, nearly 1,200 children under five years of age were killed in automobile accidents in 1988. That means that there were approximately one-quarter more automobile deaths of very young children in 1988 alone than there were total deaths of children and adults on scheduled airlines during the entire 1980-88 period.

Nevertheless, our own econometric research (undertaken with colleagues at the University of Mississippi and Clemson University) on the impact of airline deregulation documents a point that the FAA and Congress must keep in mind: Air and highway travel are interchangeable. Changes in airline fares significantly alter the amount of highway traffic, and highway accidents, injuries, and deaths are highly correlated with the amount of highway travel and congestion.

Indeed, we found that airline deregulation, which led to lower air fares and an expansion of flights, increased air travel by an annual average of 11 percent and reduced passenger car travel by an annual average of just under 4 percent between 1978 and 1985. Accordingly, airline deregulation significantly reduced highway accidents, injuries, and deaths.

The proposed rule change might reduce very slightly the number of air injuries and deaths. However, the improvement in air safety will probably be extraordinarily small because there are so few infants who are air victims, because the safety seats will not be close to 100 percent effective, and because many parents will continue to hold their infants and toddlers in their laps, especially when the youngsters need to be fed or otherwise cared for to keep them from disturbing surrounding passengers.

The resulting increase in automobile deaths, although quite small, could easily be several times--quite possibly as many as 60 times--the reduction in airline deaths. Congress and the FAA should not be in the business of creating a travel safety problem that is bigger than the one they are trying to alleviate."

Again, I urge the readers to go to and read the entire Briefing Paper by McKenzie and Lee. Those who do, will notice a stark contrast between the dispassionate and rational safety analysis of the authors and the irrational and emotional approach of the unnamed letter writer. See also, the Deborah Spiegel letter, and reply. [Also, see the  Rational Solution].

July, 1998

Robert J. Boser    

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