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OST-00-8164

Categories of Airline Delays and Cancellations

Counsel:  Walter Finch

Categories of Airline Delays and Cancellations

By:  Stephen Van Beek

By:  Stephen Van Beek

Categories of Airline Delays and Cancellations

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

Categories of Airline Delays and Cancellations

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

Categories of Airline Delays and Cancellations

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

By:  Stephen Van Beek

Categories of Airline Delays and Cancellations

As required by Federal statute, the Department of Transportation is considering modifying the reporting requirements regarding air carriers' quality of services. We are proposing requiring air carriers that file airline service quality performance reports under the regulations to collect and report the causes of airline delays and cancellations. Currently, there is a lack of data on the specific causes of airline delays and cancellations. The proposed changes are designed to fill the data gaps for airline delays and cancellations and provide this information to the public and other interested parties. DATES: Comment Deadline: February 25, 2002.

By:  Ashish Sen

Categories of Airline Delays and Cancellations

By:  Bernard Stankus

Petition for Amendment of the Airline Service Quality Performance Reports Rule

Because the FAA data considers only flight operations within the purview of FAA, they are not just incomplete, but also vary from airport to airport in the segments of a flight they consider. For both of these reasons we urge that DOT consider reporting on-time performance and delays and cancellations in ways that represent the complete passenger experience, not operational metrics for the FAA. At the same time, we understand that the FAA collects data for many other legitimate purposes not directly associated with communicating to the public about service issues. Our concern is simply that the agency and DOT take measures to avoid unnecessarily confusing the public about delays and cancellations.

We also urge DOT to expand the reporting of on-time data to include all regularly scheduled flights so that passengers may have complete data available to make an intelligent decision about their travel plans. This also allows for performance assessments to be made about the entire system, not just the performance of the largest airlines and airports. This recommendation was made in the On-Time Advisory Task Force Report, the precursor to your current effort.

Air Transport Association of America Petition from July 1999

Categories of Airline Delays and Cancellations

By:  B.E. Wendling

Categories of Airline Delays and Cancellations

By:  George Rummell

Categories of Airline Delays and Cancellations

By:  Bernard Stankus

Categories of Airline Delays and Cancellations

We believe that the proposed rule is a valuable first step in removing the cloud of public suspicion and concern that surrounds the issue of flight delays and their real causes. The problem is large and cannot be resolved in one step. Overall we support adoption of the rule. Our only quarrel with the rulemaking lies not in the rule but in the notice, where DOT observes "one of our aims in developing the causal reporting system is to require minimal change to the air carriers internal tracking systems." While we share the view that government regulation in this and other areas should be a minimally intrusive as possible, we do not accept the implication that flight delay reporting must be largely limited by whatever the carriers are doing today to collect information for their own purposes. The public interest in knowing what causes delays must supercede airline interests in avoiding collection of data they themselves may not use.

By:  ASTA, Paul Ruden

Categories of Airline Delays and Cancellations

The expectation that the new rulemaking will alleviate the past frustration and anger expressed by airline passengers is unfounded. The passenger issues that precluded this rulemaking were related to delay and cancel information provided on the actual day of departure. The passengers were aware of the air carriers overall performance from the Air Travel Consumer Report statistics, but their concern was only for the flight on which they had a seat. Thus, this rulemaking may provide information for aggregate delays and cancellations, it will not provide the information required and desired by the traveling public. The recommendation is better communication to the customer of delay and cancel information on the day of departure, which the airlines have already committed to through initiatives in response to the Airline Consumer Bill of Rights. As evidenced by the most recent November and December ATCR complaint data, industry complaints are at their lowest levels in 3 years. Clearly the perception of public intolerance has changed, particularly in light of the events of September 11.

By:  America West, Jeffrey McClelland

We firmly support the right of the public to be informed about causes of cancellations and delays. However, we do not believe the Department has clarified how it intends to use this new data. The intentions must be clarified and included in the proposal before it becomes a rule. Before causal reports will have any substantive relevance, there needs to be a common framework within the industry for how delays are coded. Currently, there are no standards for how airlines internally code their delays. Therefore, any causal data reports would likely be somewhat subjective, which would defeat the proposal's goal of providing the public with meaningful information. An industry study, jointly sponsored by the Department and the Air Transport Association, with a larger number of participating airlines, should explore a common coding system and develop a consensus on how it will be used. Only then can mandating compliance with the rule achieve the desired objective.

By:  American Trans Air, Ellis Fawcett, 317.247.4000

By:  Paul Asmus

Requiring air carriers to provide more detailed information on the nature of delays and cancellations will enable all the stakeholders, government, air carriers, airports, and consumers, to better understand the factors affecting air travel. The additional data collected as a result of the proposed performance reporting requirements will contribute to a better understanding of the system's strengths and weaknesses, and allow the industry to target isolated deficiencies and take appropriate action, when necessary, to resolve any ongoing performance problems. We support the agency's intention to extend the requirements to all air carriers in a future rulemaking.

By: AAA Public Affairs, Kathleen Marvaso

The implementation period for this rule must be extended sufficiently to allow for broad airline testing and government-industry discussion to resolve consistency issues. Although the pilot program was successful in establishing a framework for collecting the data, more testing is necessary. The highest degree of integrity and confidence is needed to guarantee accurate and useful reporting to the public. ATA is concerned that without more extensive testing, neither the air carriers nor the DOT can be confident that the results are reliable, consistent, and comprehensive. There was broad agreement on this subject at the August 10, 2001 meeting with DOT and airline representatives.

By:  Air Transport Association of America, John Ryan

ACI-NA and its member airports strongly endorse DOT's continuing efforts to assess the causes of flight cancellations and delays by creating a uniform system for coding and analyzing the reasons flights are delayed or cancelled. ACI-NA believes that such a system will improve industry and passenger knowledge about the causes of flight delays, provide the public with more reliable information upon which they may base personal and business travel decisions, and improve the public's perception of the aviation industry.

By:  Airports Council International - North America, David Plavin

By:  Melissa Davis

On December 27, 2001 the Department issued a Notice of Proposed Rulemaking in the referenced docket proposing to require certain air carriers to report information regarding the causes of flight delays and cancellations. The NPRM invited comments on the NPRM by February 25, 2002. Southwest was one of four air carriers that participated on the DOT's Air Carrier On-Time Reporting Advisory Committee in 2000, and in a pilot program on this subject administered by the Bureau of Transportation Statistics in 2001. Southwest has views on the issues raised by the NPRM, and will include them in comments to be filed on the NPRM in the next 10 days. Given that flight delays have dropped precipitously since September 11, and there is no apparent need to impose new delay reporting requirements in the near term, we presume that Southwest's comments will receive full consideration by the Department.

Counsel:  Southwest, Robert Kneisley

Categories of Airline Delays and Cancellations

By including a reference to passengers with disabilities as a potential cause for delay, DOT implicitly gives credence to this as a valid passenger caused delay. While passengers and crew are mentioned in this list as well, that reference necessarily implies that the instant delay is caused by another flight delay. Despite all passenger efforts to allow plenty of time for boarding, a perception already exists that passengers with disabilities cause delay. Announcements have been made in the gate area to the effect that general boarding will begin once the passenger with disabilities has been boarded. DOT should not provide further reason for this unfounded view.

By:  Paralyzed Veterans of America, Robert Herman

Without delay information from the 17 percent of carriers not required to report under this NPRM, it will be impossible for the DOT to implement well-informed market-based approaches to minimize delays. In addition, some air carriers track the initial cause of a delay for "late arriving aircraft" and some do not. Yet, the NPRM does not propose a standardized reporting system that would allow for the tracking of downline effects of earlier delays. Giving carriers flexibility in this matter, consistent with the DOT's goal to "require minimal change to the air carriers' internal tracking systems..." hampers the collection of accurate data and makes delay assignment factually inadequate. While we are sympathetic to the financial constraints of air carriers, delay reporting is not credible to the public and not useful to policy-makers when consistent data is not collected from all carriers. The City of Boston suggests that mandated, standardized reporting required of all carriers operating in the U.S. is necessary in order to gather precise and truly useful data.

By:  City of Boston The Environment Department, Antonia Pollak

Categories of Airline Delays and Cancellations

RAA members oppose DOT's proposal to expand the same reporting requirements to all medium and large code-sharing regional airlines in future. We believe it is inappropriate for regional airlines to file reports that are measured against large network carriers that operate completely different types of operations. By focusing on revenue as a single defining characteristic, the threshold fails to consider other characteristics unique to regional airlines that set them apart from the large network airlines. These include, but are not limited to, the ability to serve small and medium­-sized communities and the fact that regional airlines operate much smaller aircraft that fly significantly shorter stage lengths than the majors. Most regional airline routes are 250 - 500 miles, often subjecting them to ground delay programs initiated by FAA. This is especially true for regional carriers that operate at large hubs with substantial international service. Often regional airlines are held at the outbound station to allow long-haul flights from foreign destinations to land. It is important to note that major airlines do not experience the same level of ground holds as regional airlines experience.

By:  Regional Airline Association, Deborah McElroy

Categories of Airline Delays and Cancellations

By:  Save the Bay, David Lewis

By:  San Francisco Boardsailing Association, Peter Thorner

Categories of Airline Delays and Cancellations

Given the significant and difficult changes in airport/airline security since the tragic events of September 11 , 2001, we suggest that a separate security-related category may be helpful. While we understand that the NAS category encompasses a number of operational eventualities, separating security-related delays from other operational events might aid the Department of Transportation (DOT) in determining the efficiency of new security procedures.

By:  City of Boston Environment Department, Antonia Pollak

Categories of Airline Delays and Cancellations

By:  BTS, Robert Monniere

Airport Executive Directors of large and small non-hub airports (such as my airport [MGM]) are acutely concerned with the on-tune performance and percent completion statistics of our regional carriers. What we need is an industry standard against which we can measure the regional carriers at our smaller airports. The on-time performance and percent-completion numbers published by the BTS for selected major carriers may or may not be indicative of the regional carriers. The real reason my peers and I need this data is to help us explain to our communities that our regional service is very good. Many of us are forced to defend the regional carriers to civic clubs and others as the perception, in many circles, is that the regional carriers are much, much worse than the major carriers when it comes to on-time performance, percentage of completed flights and last/delayed baggage. Can you help me with my quest to locate such data?

By:  Montgomery Airport Authority, Phil Perry

Reporting the Causes of Airline Delays and Cancellations

As required by Federal statute, the Department of Transportation is modifying certain reporting requirements. We are requiring air carriers that file airline service quality performance reports to collect and report the causes of airline delays and cancellations. Currently, there is a lack of data on the specific causes of airline delays and cancellations. The changes are designed to fill the data gaps in reference to the causes of airline delays and cancellations and to provide this information to the public and other interested parties.  This rule is effective on June 1, 2003.

By:  Rick Kowalewski

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