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Airline Passenger Rights "Data reporting requirements"

Draft Summary of Discussion
By the Regulation Room team based on the NPRM
Agency Documents
1 0


What’s Going on Here?

This is a summary of the discussion on the Data Reporting Requirements post between June 2 and September 10.  (On September 11, the post was closed to further discussion.)  The summary was written by the Regulation Room team based on all the comments people made.  This version is a DRAFT. We need YOUR help to make sure that nothing is missing, wrong or unclear.

Important dates:

Sept. 13 – Sept. 19:  Comments can be made here on the draft
Sept. 20:  Commenting on the draft summary closed
Sept. 20 – Sept.  22:  Regulation Room team reviews comments and revises draft
Sept. 23:  Final Summary of Discussion is posted on Regulation Room and submitted to DOT Department of Transportation as a formal comment in the official rulemaking record.  (Sept. 23 is the last day of the official commenting period.)

Things to keep in mind as you read through the draft summary and make comments:

  1. The goal here is to give DOT the best possible picture of all the different views, concerns, and ideas that came out during the discussion.  This is NOT the place to reargue your position or criticize a different one.  Focus on whether anything is missing or unclear, not whether you agree or disagree.
  2. Rulemaking is not a vote. DOT is not allowed to decide what to do based on majority rule.  (Why? See Effective Commenting).  Approximate numbers are provided in the summary only to give DOT a sense of the frequency of views, concerns, and ideas.

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2 0 Who Participated in the Data Reporting Requirements Discussion?

Data Reporting didn’t generate a lot of direct discussion.  Eight comments were made on this post:

  • 6 comments by 6 users
  • 2 comments by Regulation Room moderators

In addition, two people commented on carrier data reporting in discussing Tarmac Delay.  We include these other comments in this summary.

Those commenters who responded to our interest survey question identified themselves as air travelers.

3 0 Methodology and Burden on Carriers

One commenter worries that the difficulty of compiling such data will ultimately result in higher ticket prices.  All other commenters disagree.  They say that technology should make data recording relatively easy, as long as computers are doing most of the compilations rather than airline employees. One commenter specifically mentions that the data collection is automated for the large domestic carriers so it should be easy for the smaller carriers and foreign carriers to implement the same automated system to collect data.  Another points out that various types of transportation vehicles (from fighter jets to Formula 1 cars) compile data via computers.  He/she suggests implementing data reporting via a standard technology that uploads to computers, where reports could be generated by the airlines (or, another commenter suggests, by DOT Department of Transportation itself.) This same commenter suggests fines or route losses for airlines that do not upload data and or fail audits.

One commenter on Tarmac Delay discussed data reporting in connection with the Tarmac Delay Contingency Plans:  Airlines should keep statistics about delays and their handling of them, conduct periodic reviews, and revise their Plan with the goal of improving customer satisfaction and reducing the causes for the delays (a Six-Sigma approach, explained in the Tarmac Delay summary).  Another commenter on this topic emphasized the value of having tarmac delay data available by airport, not just air carrier.

4 0 Importance of information

The commenter concerned about costs to carriers and, ultimately, consumers from additional reporting also questions the usefulness of the information:  He/she believes that no one will use the information because it will be outdated as soon as it is published.  Another commenter counters that online performance data is an important statistic that some travelers use in making choices among carriers.  This commenter also argues that publishing their performance data makes airlines pay more attention to their own performance, especially as compared to other airlines.

5 0 Privacy

One commenter is concerned about privacy as well as transparency.  He emphasizes that information on passengers that would be shared with others should be clearly specified, and passengers should be so advised.