Getting Better Information About Air Travel Delays:
How benefit-cost analysis and information quality principles can solve the problem
5 Jul 2007 in Information Quality
In the wake of JetBlue's latest problems, air travel in general is getting more attention. Much of this is focused on various proposals for air travel "customers bills of rights." We've shown that CBORs don't (and possibly can't) address every circumstance of interest. They also have the peculiar effect of taking service quality out of the domain in which airlines can compete. An alternative approach not only allows airlines to compete on service quality, but encourages them to do so.
One requirement for this to work is passengers have to have access to high-quality information that addresses the kind of service quality questions they care about. The Department of Transportation has issued regulations concerning air travel delays. There is mounting evidence that these rules have not yielded the kind of information passengers need.
Jeff Bailey and Nate Schweber say in the New York Times that the official statistics reported by the Department of Transportation on airline delays do not reflect the actual delays experienced by airline travelers.
As anyone who has flown recently can probably tell you, delays are getting worse this year. The on-time performance of airlines has reached an all-time low, but even the official numbers do not begin to capture the severity of the problem.
That is because these statistics track how late airplanes are, not how late passengers are. The longest delays — those resulting from missed connections and canceled flights — involve sitting around for hours or even days in airports and hotels and do not officially get counted. Researchers and consumer advocates have taken notice and urged more accurate reporting.
Though it isn't mentioned, the Times story follows closely after a press release issued by an activist group on June 21. Activists want a congressional investigation as prelude to a legislative solution -- an "Airline Passengers’ Bill of Rights."Activists dislike the current reporting system, saying that it provides a misleading picture:
“The full picture is a lot worse” than the data compiled from airlines by the government, said Paul Hudson, executive director of the Aviation Consumer Action Project, founded by Ralph Nader.
BENEFIT-COST ANALYSIS
The current reporting scheme was established by regulation issued on November 25, 2002. The public process for developing that regulation began 25 months earlier. The table below contains links to the docket.
The Department of Transportation did not perform a Regulatory Impact Analysis, a requirement that normally would have applied to a regulation that is "economically significant" under Executive Order 12866. DOT asserted that the rule was not economically significant -- i.e., it did not have effects exceeding $100 million in any one year. This requires a pinched definition of "effects," especially because the Department's 14-page regulatory evaluation noted that the value of passenger delay was in the billions of dollars:
While a precise dollar value cannot be placed on the improvement in aviation service that would result from implementing this proposed rule, BTS believes the benefits would greatly outweigh the costs to the reporting air carriers. In a study, the DOT'S Inspector General estimated that in the year 1999, delays costs the 10 largest scheduled domestic passenger carriers an estimated $3.28 billion; and cancellations costs ranged from $540 million to $1.03 billion. The estimated costs to passengers on delayed flights is also in the $billions. A minor improvement to air carriers' on-time performance will more than account for the added cost to report causal data (Regulatory Evaluation at 4).
Even small improvements in the system could have yielded more than $100 million in effects. For that reason, it's unclear why DOT didn't designate this rule economically significant and perform a Regulatory Impact Analysis.
The docket shows that airlines were thoroughly represented in the regulatory process, but passengers were not. This is not the fault of DOT, which appears to have run an open process. It is an inherent feature of regulation in which regulated entities have concentrated interests and regulatory beneficiaries do not. For that reason alone, a Regulatory Impact Analysis would have been highly beneficial. Benefit-cost analysis provides a framework for preventing special interests from dominating. Because passengers care more about passenger delays than aircraft delays, benefit-cost analysis likely would haver changed the entire structure of the reporting system.
INFORMATION QUALITY
This is a classic case where the adherence to government-wide information quality standards established by the Office of Management and Budget would be beneficial. These standards contain four principles:
- Quality. All information is not equal. Higher quality information is more valuable, especially when it is used for influential purposes. Public reporting on air travel delays clearly qualifies as an influential purpose.
- Utility. Information must be useful for the legitimate public purpose for which it was intended.
- Integrity. Information must be managed with a clear chain of custody to ensure that it free from manipulation or error. Chain of custody provisions ensure that if it is improperly changed, it can be ascertained where in the chain this occurred. Whenever possible, it's good to know who changed it.
- Substantive, presentational and procedural objectivity. Information must be substantively objective ("accurate, reliable, and unbiased") and ""presented in an accurate, clear, complete, and unbiased manner." OMB requires that influential information be transparent and reproducible, a requirement that can be understood as procedural objectivity.
The changes proposed in this final rule should increase the quality of data collected on the causes of airline delays and cancellations, thus increasing our ability to evaluate potential air traffic problems and allocate the appropriate resources toward mitigating these problems (67 FR 70544).
Now that DOT has had five years of experience with information quality principles, this is a good time to review the way air travel delays are measured and reported and revisit the 2002 regulation. The regulation does not provide the information airline passengers want to know, and it can be fixed without legislation.
| Document Number | Document Type | Filing Date | Title | Files |
|---|---|---|---|---|
| Federal Register Publication | 10/23/2000 | Notice of Public Meetings. | PDF (119609 bytes) PDF (122298 bytes) 1 Page |
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| Advisory Committee Report | 11/27/2000 | Agenda Air Carrier On-Time Reporting Advisory Committee | TIF (18799 bytes) PDF (58117 bytes) 1 Page |
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| Advisory Committee Report | 11/27/2000 | Air Carrier On-Time Reporting Advisory Committee Draft Meeting Summary. | TIF (195781 bytes) PDF (350107 bytes) 3 Pages |
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| Comment(s) | 11/27/2000 | Air Carrier Association of America - Comments | TIF (189405 bytes) PDF (338896 bytes) 3 Pages |
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| Advisory Committee Report | 11/27/2000 | Executive Summary Interim Report to the Secretary of Transportation: Categories of Cancellation and Delay for Air Carrier On-Time Reporting | TIF (1038407 bytes) PDF (1876182 bytes) 15 Pages |
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| Supplement | 11/27/2000 | Air Travel Consumer Report | TIF (1836355 bytes) PDF (3821893 bytes) 39 Pages |
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| Supplement | 11/27/2000 | Supplement | TIF (43823 bytes) PDF (83088 bytes) 1 Page |
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| Supplement | 11/27/2000 | Secondary ("rub-off", "resultant") Causes of Delay "Reporting Forward" Sequences | TIF (21271 bytes) PDF (59719 bytes) 1 Page |
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| Supplement | 11/27/2000 | Classifying Departure and Arrival Delays | TIF (91281 bytes) PDF (136307 bytes) 1 Page |
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| Supplement | 11/27/2000 | Suggestions on Measuring Air Traffic Delays and Identifying Their Causes | TIF (323343 bytes) PDF (548640 bytes) 4 Pages |
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| Supplement | 11/27/2000 | Two Part Framework for Reporting and Analysis | TIF (36989 bytes) PDF (66181 bytes) 1 Page |
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| Supplement | 11/28/2000 | Plane Talk: Coping With Flight Delays | TIF (214737 bytes) PDF (337859 bytes) 2 Pages |
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| Supplement | 11/28/2000 | New DOT Fact Sheet to Help Travelers Cope with Flight Delays | TIF (104271 bytes) PDF (188275 bytes) 2 Pages |
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| Advisory Circular | 11/28/2000 | Advisory | TIF (503375 bytes) PDF (627699 bytes) 4 Pages |
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| Supplement | 11/28/2000 | ATC Daily Report | TIF (77171 bytes) PDF (157950 bytes) 2 Pages |
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| Supplement | 11/29/2000 | NOCC Summary | TIF (357073 bytes) PDF (792835 bytes) 9 Pages |
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| Supplement | 11/28/2000 | FAA Adminstrator's Daily Alert Bulletin | TIF (1895337 bytes) PDF (2365631 bytes) 81 Pages |
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| Supplement | 11/29/2000 | Air Carrier On-Time Reporting Advisory Committee Draft-Meeting Summary | TIF (130943 bytes) PDF (227978 bytes) 2 Pages |
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| Supplement | 11/29/2000 | Agenda Air Carrier On-Time Performance Reporting Advisory Committee | TIF (20913 bytes) PDF (50118 bytes) 1 Page |
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| Supplement | 11/29/2000 | Air Carrier On-Time Reporting Advisory Committee Meeting Summary | TIF (335969 bytes) PDF (618544 bytes) 5 Pages |
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| Supplement | 11/29/2000 | Total System Delays-Calendar | TIF (614583 bytes) PDF (1330181 bytes) 13 Pages |
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| Order | 11/29/2000 | Operational Data Reporting Requirements | TIF (700907 bytes) PDF (1274659 bytes) 11 Pages |
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| Supplement | 11/29/2000 | Air Carrier On-Time Reporting Advisory Committee Draft-Meeting Summary | TIF (279695 bytes) PDF (488041 bytes) 4 Pages |
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| Supplement | 11/29/2000 | Traffic Emplanement for the 12 Months Ended December 1999 | TIF (62729 bytes) PDF (133350 bytes) 2 Pages |
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| Supplement | 11/29/2000 | Technical Reporting Directive - Title 14 Code of Federal Regulations Part 234 Amended, Technical Directive #6 | TIF (842833 bytes) PDF (1462660 bytes) 11 Pages |
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| Supplement | 11/29/2000 | Agenda - Air Carrier On-Time Reporting Advisory Committee | TIF (19873 bytes) PDF (59035 bytes) 1 Page |
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| Supplement | 11/29/2000 | Draft-Issues to be Addressed by the Advisory Committee | TIF (74255 bytes) PDF (149870 bytes) 2 Pages |
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| Supplement | 11/29/2000 | Points Where Delays are Reported by BTS and FAA | TIF (37495 bytes) PDF (73148 bytes) 1 Page |
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| Supplement | 11/29/2000 | Agenda-Air Carrier On-Time Reporting Adivisory Committee | TIF (33003 bytes) PDF (63820 bytes) 1 Page |
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| Supplement | 11/29/2000 | Aviation System Performance Metrics - ASPM Overview | TIF (2580957 bytes) PDF (3310334 bytes) 19 Pages |
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| Supplement | 11/29/2000 | On-Time Data Bureau of Transportation Statistics | TIF (158411 bytes) PDF (265315 bytes) 2 Pages |
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| Supplement | 11/29/2000 | Airline Service Quality Performance Reports | TIF (47779 bytes) PDF (82032 bytes) 1 Page |
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| Supplement | 11/29/2000 | Air Carrier On-Time Reporting Advisory Committee Attendee List | TIF (44407 bytes) PDF (78800 bytes) 1 Page |
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| Report | 11/30/2000 | Air Travel Consumer Report | TIF (1757763 bytes) PDF (3641927 bytes) 37 Pages |
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| Supplement | 11/30/2000 | Best Practices for Improving Air Travel Experience | TIF (1961783 bytes) PDF (2948969 bytes) 18 Pages |
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| Federal Register Publication | 12/27/2001 | Notice of Proposed Rulemaking re Reporting the Causes of Airline Delays and Cancellations | PDF (63488 bytes) PDF (63488 bytes) 7 Pages |
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| Regulatory (Assessments and) Evaluation | 12/31/2001 | Regulatory Evaluation | TIF (884307 bytes) PDF (991033 bytes) 14 Pages |
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| Letter(s) in Support | 01/08/2002 | Letter from Airports Council International North America (ACI-NA) | TIF (130329 bytes) PDF (229597 bytes) 2 Pages |
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| Letter(s) in Support | 01/10/2002 | B.E. Wendling | DOC (21504 bytes) PDF (5447 bytes) 1 Page |
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| Comment(s) | 01/14/2002 | George A. Rummell | TXT (998 bytes) PDF (3038 bytes) 1 Page |
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| Correspondence | 01/31/2002 | Communication Concerning The Reporting of the Causes of Airlines Delays and Cancellations | TIF (60741 bytes) PDF (101137 bytes) 1 Page |
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| Comment(s) | 02/22/2002 | American Society of Travel Agents, Inc. | WPD (8259 bytes) PDF (9440 bytes) 2 Pages |
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| Comment(s) | 02/25/2002 | America West Airlines Position Paper on Causal Delay Coding NPRM 14 CFR Part 234 | TIF (454541 bytes) PDF (824158 bytes) 6 Pages |
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| Comment(s) | 02/25/2002 | Melissa Davis | DOC (28672 bytes) PDF (11574 bytes) 3 Pages |
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| Comment(s) | 02/25/2002 | Paul D. Asmus | TIF (169587 bytes) PDF (200216 bytes) 3 Pages |
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| Comment(s) | 02/25/2002 | American Trans Air | TIF (162591 bytes) PDF (199644 bytes) 2 Pages |
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| Comment(s) | 02/25/2002 | AAA Public Affairs | TIF (88309 bytes) PDF (112266 bytes) 2 Pages |
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| Comment(s) | 02/25/2002 | Air Transport Association of America, Inc. | TIF (388333 bytes) PDF (447162 bytes) 7 Pages |
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| Comment(s) | 02/25/2002 | Airports Council International - North America | TIF (361857 bytes) PDF (413751 bytes) 8 Pages |
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| Correspondence | 02/25/2002 | Southwest Airlines Co. | TIF (54173 bytes) PDF (75706 bytes) 1 Page |
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| Comment(s) | 02/25/2002 | The Paralyzed Veterans of America | TIF (203795 bytes) 5 Pages |
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| Comment(s) | 02/26/2002 | City of Boston Environment Department | TXT (5961 bytes) PDF (5834 bytes) 3 Pages |
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| Comment(s) | 03/01/2002 | Regional Airline Association | DOC (41984 bytes) PDF (10958 bytes) 3 Pages |
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| Comment(s) | 03/07/2002 | Save the Bay | TIF (44739 bytes) PDF (77565 bytes) 1 Page |
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| Comment(s) | 03/07/2002 | San Francisco Boardsailing Association | TIF (305065 bytes) PDF (539010 bytes) 4 Pages |
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| Comment(s) | 03/11/2002 | City of Boston Environment Department | TIF (188799 bytes) PDF (348658 bytes) 3 Pages |
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| Comment(s) | 06/13/2002 | Comment concerning the on-time performance and percent completion statistics of regional carriers | TIF (37676 bytes) PDF (58502 bytes) 1 Page |
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| Response(s) | 06/13/2002 | Response to a late comment concerning the on-time performance and percent completion statistics | TIF (33089 bytes) PDF (59436 bytes) 1 Page |
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| Federal Register Publication | 11/25/2002 | Final Rule | PDF (83850 bytes) PDF (88651 bytes) 11 Pages |
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| Comment(s) | 03/10/2003 | Dan Moore | TXT (908 bytes) PDF (27971 bytes) 1 Page |
