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Answers and Replies:

CDM Pilot Program - Comments of Air Transport Association and ACI-NA

Orders and Notices:

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Rules and Regulations:

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Grant of Petitions:

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Collaborative Decisionmaking Pilot Program Guidelines

FAA-04-17349

April 22, 2004

Comments of The Air Transport Association of America

Although carriers have had online and interline irregular operations procedures for decades, they have not developed the data collection practices necessary to comply with the data requests that the notice proposes. The development of systems to comply with such a significant data collection burden is therefore likely to deter carrier participation in the program. Rather than discouraging participation by imposing any significant new burden on carriers who agree to participate in the pilot program, the FAA should seek to conduct its evaluation of the program to the greatest extent possible with data carriers are already required to report to DOT or FAA, or that are already publicly available (such as published schedule data). To the extent additional data is requested, it should be narrowly tailored to minimize carrier burden and to focus specifically on the effect of the CDM at affected airports during the CRE. We do not think it would be necessary or appropriate to require additional detailed reporting of carrier financial data, scheduling data that is already publicly available, or extrapolations from carrier schedule changes (such as the identification of communities that lost service during the CRE). Such burdensome reporting requirements would likely undermine the pilot program by dissuading carrier participation in the first place.

Counsel: ATA, David Berg, 202-626-4000

April 22, 2004

Comments of Airports Council International - North America

In view of rebounding passenger traffic and aircraft operations in the United States as well as abroad, ACI-NA believes, and commends both Congress and FAA for recognizing, that now is the time to develop and implement forward-thinking and effective capacity management and enhancement measures before the aviation industry gets too far into the coming congestion crisis like the one that occurred in the months preceding the economic downturn that began in early 2001. The most effective method for relieving congestion and delay within the National Airspace System is through the construction of new runways, taxiways, and terminal and ground-side capacity with the help of environmental streamlining, along with the use of advanced air traffic management technologies. Additionally, Ad-NA has repeatedly urged FAA and the Department of Transportation to make it clear that America's airports have the flexibility and discretion to manage scarce capacity through marketbased approaches that include such measures as congestion pricing and auctions, which ACI-NA, most mainstream economists and the U.S. Department of Justice believe would most efficiently allocate scarce airport resources. See, e.g. Exhibit A, Comments of ACI-NA, July 22, 2002, Docket OST-2001-9849, "Notice of Market-Based Actions to Relieve Airport Congestion and Delay" (submitted in this docket without exhibits), see also, Comments of the United States Department of Justice, June 20, 2002, Docket No. FAA-2001-9854, "Notice of Alternative Policy Options for Managing Capacity at LaGuardia Airport and Proposed Extension of Lottery Allocation"

Counsel: Morrison & Foerster, Bradley Lui, 202-887-1500

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