impact of three hour tarmac delay rules and
TRANSCRIPT
O V E R V I E W P R E S E N TAT I O N
Impact of Three‐Hour Tarmac Delay Rules and Fines on Passenger Travel Time &WelfareFines on Passenger Travel Time & Welfare
Webcast Briefing
Full paper and supporting documentationavailable at wwwtarmaclimits comavailable at www.tarmaclimits.com
EMBARGOED UNTIL JULY 20
1
THE RULE
Study AuthorsINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
Darryl Jenkins Joshua Marksy [email protected]
• Associate Director, GWU Aviation Institute (2002‐2003)
• Research in airline revenue and o e atio a a e e t ai te a e
• Founder and Director of the GWU Aviation Institute (1991‐2003)
• Faculty at GWU, Embry Riddleoperations management, maintenance, safety and airspace management
• Aviation executive experience in finance, revenue, flight operations
• President, TheAirlineZone.com• Policy and operations expert with
extensive project background• Author Handbook of Airline Economics and information technology• Author, Handbook of Airline Economics
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 2
THE RULE
Three Hour Rule & CancellationsINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
• Effective April 29, new rules limit tarmac time to 3 hours
• Punitive fines carry disproportionate risk
• Tarmac delays stopped and cancellations spikedy pp p
• Hundreds of cancellations already due to the tarmac rule, with the worst of summer yet to be reported.y p
• Public harm is significant: $3.9 billion over 20 years based on May 2010 reported data
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 3
THE RULE
Only Focused on Three Hour Limit & FinesINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
We are only concerned with the three‐hour limit and its implications for cancellations and public harm.
Generally we think the other DOT rules are good ideasGenerally, we think the other DOT rules are good ideas
– Provide food and water after two hours– Respond promptly to consumer complaints– Provide information about chronically delayed flights– Publish delay data on websitesPublish delay data on websites– Audit adherence to their customer service plans
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 4
THE RULE
Key FindingsINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
• Tarmac delays harmed 110,000 passengers per year
Fi f i l ti 200 300• Fines for violations are 200‐300x revenue
• Risk‐averse airlines are cancelling or diverting flights
• Passengers impacted who would not have had 3+ hour tarmac delay
• Tarmac rules driving a 4:1 ratio of cancellations to prevented delays(between 5 200 and 6 000 annual cancellations at current pace)(between 5,200 and 6,000 annual cancellations at current pace)
• In the short term, absence of transparent fines and enforcement is driving unnecessary cancellations
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 5
THE RULE
First Month ResultsINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
Why do cancellations matter?
• DOT assumed minimal cancellations (2.8%, or 41 flights per year)( , g p y )
• DOT claimed that tarmac rules benefited public welfare
Fi t th (M 2010) ltFirst month (May 2010) results
• Better weather year over year
• Cancellations +40%, Diversions +25%1,924
Year over Year ComparisonMay 2010 vs. May 2009
Cancellations 40%, Diversions 25%
• 140 cancellations of flights after extensive taxi‐out waits, prior to3 hour cutoff, with follow‐on
1,201
3 hour cutoff, with follow on cancellations (4:1 total ratio)
• Hundreds of other cancellations that airlines attribute to tarmac risks
140
(34)
Cancellations Diversions Taxi‐Out Tarmac Delays
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 6
that airlines attribute to tarmac risksCancellations Diversions Taxi Out Cancellations
Tarmac Delays
THE RULE
Our ResearchINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
We demonstrate key assumptions by the public and DOT are wrong.
× Tarmac delays are predictable and controllable
× E fo ce e t a d fi es do ot cha ge ca cellatio decisio s× Enforcement and fines do not change cancellation decisions
× Gate resources exist to disembark and re‐board passengers
× Diversion strategies do not changeDiversion strategies do not change
× Cancellations have no follow‐on impact
× All passengers on cancelled flights can be re‐accommodated
We revise public welfare estimates using real‐world information.
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 7
THE RULE
Need Clear Guidance on EnforcementINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
In the short term, enforcement is the key.
Threat of punitive fines drives extreme risk‐aversion and cancellations
If DOT does not intend to seek punitive fines for minor infractions, it needs to clarify its position immediately
If DOT does intend to seek punitive fines, it must acknowledgeIf DOT does intend to seek punitive fines, it must acknowledge the consequences on public welfare
Either way, DOT should update its regulatory impact estimatesto reflect real world cancellations and re booking timeto reflect real‐world cancellations and re‐booking time.
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 8
THE RULE
Final Rule & FinesINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
• 14 CFR Part 259 now prohibits tarmac delays of greater14 CFR Part 259 now prohibits tarmac delays of greater than three hours for domestic flights at most US airports.
– A tarmac delay is “the holding of an aircraft on the ground either before taking off or after landing with no opportunity for its passengers to deplane.”
– Exceptions for “safety‐related or security‐related” reasons, or by order of ATC
M i fi f $27 500• Maximum fine of $27,500 per passenger
• Complete background in Section Two of our paper
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 9
THE RULE
Enforcement UncertaintyINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
• DOT has not published specific enforcement guidance
• DOT Office of Enforcement: case by case analysis based on harm, compliance disposition, economic condition, ability to pay, etc. (April 28, 2010)ability to pay, etc. (April 28, 2010)
• Secretary LaHood: “We just leveled a $16 million fine which was the maximum fine we could level against i a e a i u i e e ou e e agaiToyota. So I don’t think anyone thinks that Ray LaHood is not going to have strong enforcement.” (April 27, 2010)
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 10
THE RULE
Maximum FinesINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
Aircraft Type Potential Revenue Potential Fine Fine to Revenue Ratio
Regional Jet70 seats $75 per passenger
$4 253 fli ht$1.56 million 366:1
$4,253 per flight(81% load factor)
A320/B737144 seats $119 per passenger
$13,880 per flight$3.21 million 231:1
$ , p g(81% load factor)
Potential revenue based on airline year‐end reports. Revenue on a flight segment (not round‐trip) basis. l b d Sk d f Y
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 11
Regional Jet based on SkyWest reported revenue per passenger for FY2009. A320/B737 based on Southwest Airlines revenue per passenger for FY2009.
THE RULE
Establishing Facts about Tarmac Delays (1)INTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
Lengthy Tarmac Delays Were Always Rare
40,000
50,000
Distribution of Taxi‐Out TimesMay 2009
250
300
Distribution of Taxi‐Out Times60 Minutes +, May 2009
2009
2009
10,000
20,000
30,000
50
100
150
200
Flights during May 2
Flights during May 2
• 546 832 total flights • 5 137 flights 60+ minute taxi out time
0
10,000
0 30 60 90 120 150 195
0
50
60 90 120 150 195Taxi‐Out Time (min) Taxi‐Out Time (min)
• 546,832 total flights
• 4,747 flights (0.87%) taxi‐out 1‐2 hours
• 355 flights (0.065%) 2‐3 hours
• 5,137 flights 60+ minute taxi‐out time
• 99.3% departed before 3 hour mark
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 12
• 35 flights (<0.01%) 3+ hours
THE RULE
Establishing Facts about Tarmac Delays (2)INTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
Lengthy Tarmac Delays Are Seasonal
Monthly Distribution of Three HourTaxi‐Out Tarmac Delays
Data Set May 2008 through April 2010
367
449
214
87 85 8149 67
214
32 476
134
ry ry ch ril ay ne ly st er er er er
Janu
ar
Febr
uar
Mar
c
Apr Ma
Jun
Jul
Aug
us
Sep
tem
be
Oct
obe
Nov
embe
Dec
embe
Source: Part 234 Reporting Data
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 13
THE RULE
Establishing Facts about Tarmac Delays (3)INTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
Tarmac Delays coincide with Diversions, but have been an alternative to Cancellations (until now)
0 05%
0.06%
0.45%
0.50%Diverted 3+ hour tarmac time0.06%6.00%
Cancelled 3+ hour tarmac time
Tarmac Delays vs. Cancellations Tarmac Delays vs. Diversions
0.02%
0.03%
0.04%
0.05%
0 15%
0.20%
0.25%
0.30%
0.35%
0.40%
0.02%
0.03%
0.04%
0.05%
2.00%
3.00%
4.00%
5.00%
0.00%
0.01%
0.00%
0.05%
0.10%
0.15%
Augu
st 2
008
ptem
ber 2
008
Oct
ober
200
8
ovem
ber 2
008
ecem
ber 2
008
Janu
ary
2009
ebru
ary
2009
Mar
ch 2
009
April
200
9
May
200
9
June
200
9
July
200
9
Augu
st 2
009
ptem
ber 2
009
Oct
ober
200
9
ovem
ber 2
009
ecem
ber 2
009
Janu
ary
2010
ebru
ary
2010
Mar
ch 2
010
April
201
0
May
201
0
0.00%
0.01%
0.00%
1.00%
Augu
st 2
008
ptem
ber 2
008
Oct
ober
200
8
ovem
ber 2
008
ecem
ber 2
008
Janu
ary
2009
Febr
uary
200
9
Mar
ch 2
009
April
200
9
May
200
9
June
200
9
July
200
9
Augu
st 2
009
ptem
ber 2
009
Oct
ober
200
9
ovem
ber 2
009
ecem
ber 2
009
Janu
ary
2010
Febr
uary
201
0
Mar
ch 2
010
April
201
0
May
201
0
Sep O
No De J F
Sep O
No De J F
Sep
No De F
Sep
No De F
• Correlation coefficient 0.24 (weak positive)
• Same events drive, but alternative strategies
• Correlation coefficient 0.83 (strong positive)
• Concurrent responses by airlines
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 14
Source: Part 234 Reporting Data
THE RULE
Establishing Facts about Tarmac Delays (4)INTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
Tarmac Delays Are Clustered on Specific Days
i O l h h A il
120
140
3 Hour Taxi‐Out Delays By Day, May 2008 through April 2010
• 215 days total with tarmac delays (of 765)85 f h 215 h d l d l
80
100
• 85 of those 215 had only one delay• 20 days represented 55% of total delays
20
40
60
0
May
-08
June
-08
July
-08
Aug
ust-
08
Sept
embe
r-08
Oct
ober
-08
Nov
embe
r-08
Dec
embe
r-08
Janu
ary-
09
Febr
uary
-09
Mar
ch-0
9
Apr
il-09
May
-09
June
-09
July
-09
Aug
ust-
09
Sept
embe
r-09
Oct
ober
-09
Nov
embe
r-09
Dec
embe
r-09
Janu
ary-
10
Febr
uary
-10
Mar
ch-1
0
Apr
il-10
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 15
Source: Part 234 Reporting Data
S S
THE RULE
Establishing Facts about Tarmac Delays (5)INTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
Tarmac Delays Are Afternoon Events During the Summer
Time of Day Tarmac Delays Occur, By Month
90
50
60
70
80
90
SEPOCTNOVDEC
10
20
30
40
JANFEBMARAPRMAYJUNJULAUG
0
6am 7am 8am 9am 10am 11am 12pm 1pm 2pm 3pm 4pm 5pm 6pm 7pm 8pm 9pm 10pm 11pm
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 16
Source: Part 234 Reporting Data
THE RULE
Establishing Facts about Tarmac Delays (6)INTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
Tarmac Delays Correlate to Severe Weather
T 3+ H E t 2009 (Bl C l )Tarmac 3+ Hr Events, 2009 (Blue Columns)Vs. National Weather Service Severe Events (Red Line)
Correlation Coefficient = 0.84
3007,000
150
200
250
4,000
5,000
6,000
,
Weather Events 3+ H
r Tarmac
0
50
100
150
0
1,000
2,000
3,000
Severe W
c Delays
00
Janu
ary
Februa
ry
March
April
May
June July
Aug
ust
Septem
ber
Octob
er
Nov
ember
Decem
ber
3+ Ta ac Se e e Weathe
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 17
Source: Part 234 Reporting Data, NOAA SPC Annual Summary 2009 (www.spc.noaa.gov)
3+ Tarmac Severe Weather
THE RULE
Establishing Facts about Tarmac Delays (7)INTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
Tarmac Delays Can Overwhelm AirportsCaused by (unpredictable) severe weather, tarmac delays occur in large numbers during
ifi i d f i G d d d d l l
3 Hour Taxi‐Out Delays on Peak Days, By AirportWith Start and End Time
specific windows of time. Gate resources are over‐taxed, extended tarmac delays result.
Date ofIncident
Airport Impacted
3+ Hour Taxi‐Out Delays
First Gate Departure
Last Gate Departure
December 11, 2008 Houston IAH 42 2:50 PM 9:20 PMJuly 24, 2008 New York JFK 42 12:25 PM 9:29 PMJuly 24 2008 Philadelphia PHL 38 12:09 PM 8:45 PMJuly 24, 2008 Philadelphia PHL 38 12:09 PM 8:45 PMJune 11, 2008 New York JFK 33 4:20 PM 8:40 PMJuly 15, 2008 New York JFK 32 3:59 PM 9:30 PM
February 12, 2010 Dallas DFW 31 6:25 AM 7:25 PMOctober 16, 2008 Houston IAH 28 2:40 PM 4:00 PMJune 27, 2009 New York JFK 25 3:10 PM 6:50 PM
Au u t 15 2008 Ne Yo k JFK 23 2 59 PM 5 20 PMAugust 15, 2008 New York JFK 23 2:59 PM 5:20 PMJuly 28, 2008 New York JFK 22 9:15 AM 1:57 PMJuly 14, 2008 Atlanta ATL 21 10:00 AM 11:31 AM
August 22, 2009 New York JFK 20 12:45 PM 4:10 PMJune 10, 2009 New York JFK 20 5:50 AM 8:15 AMMarch 2, 2009 Atlanta ATL 20 12:35 PM 8:20 PM
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 18
Source: Part 234 Reporting Data
THE RULE
Establishing Facts about Tarmac Delays (8)INTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
Tarmac Delays Impact the Northeast Most Often More than 90% of tarmac delays occur in just 8 US markets, with the B W hi id h f l i f i
3 Hour Taxi‐Out Delays by Airport, May 2008 through April 2010
Boston to Washington corridor as the focal point for recurring events.
Date TOTAL ATL BOS CLT DFW IAH NYC PHL WAS OTHERJ l 24 2008 120 2 2 56 38 19 3July 24, 2008 120 2 2 56 38 19 3July 14, 2008 65 21 1 29 7 5 2July 27, 2009 62 35 26 1 0June 11, 2008 61 1 48 7 3 2July 28, 2008 59 3 4 38 4 1 9August 15, 2008 54 1 47 4 2 0June 15, 2008 43 41 1 1J 10 2009 42 1 27 3 9 2
• New York represents 8.2% share of departures and 44.3% share of tarmac delays
• The New York to Washington June 10, 2009 42 1 27 3 9 2December 11, 2008 42 42 0June 27, 2009 39 1 37 1 0March 2, 2009 36 23 11 2August 12, 2008 34 28 2 4February 12, 2010 33 33 0August 11, 2008 29 1 2 21 2 3
corridor has 16.5% share of departures and 62% share of tarmac delays
• Tarmac events tend to be regional with impact from DCMay 28, 2008 29 1 24 1 3
Other Dates 870 33 27 38 28 26 285 51 100 100Total in Data Set 1,618 84 36 50 64 68 716 143 144 131Share of Tarmac Delays 5.2% 2.2% 3.1% 4.0% 4.2% 44.3% 8.8% 8.9% 8.1%Share of Departures,Major Airports 10.2% 2.7% 2.8% 6.4% 4.4% 8.2% 2.3% 6.0% 56.9%
NYC New York JFK LaGuardia and Newark Liberty
regional with impact from DC to NY, with follow‐on effect across eastern United States
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 19
Source: Part 234 Reporting Data
NYC = New York JFK, LaGuardia and Newark LibertyWAS = Baltimore/Washington, Dulles and Reagan
THE RULE
Establishing Facts about Tarmac Delays (9)INTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
Tarmac Delays are an Airspace ProblemTarmac delays are almost perfectly correlated to reported airspace congestion
2009 Departures, 2+ Hr Tarmac Delays, and Delays Caused by Airspace/NAS Factors
• New York represents:% of Flight % of 2+ Hr % of Flights % of Minutes • New York represents:
• 5.26% of departures
• 13.24% of ATC delays
gDepartures Tarmac Delays
gAirspace Delays Airspace Delays
Atlanta 6.50% 6.51% 12.15% 12.45%Boston 1.72% 2.41% 2.36% 2.85%Charlotte 1.82% 2.70% 2.41% 1.93%Dallas 4.11% 3.26% 3.60% 3.60%Houston 2.84% 3.19% 3.15% 2.81%
Y A• 19.24% of the total time spent
waiting for airspace to open.
• Narrow departure and arrival
New York Area 5.26% 29.27% 13.24% 19.24%Philadelphia 1.45% 5.67% 2.59% 3.09%Washington Area 3.84% 5.95% 2.86% 2.70%Other Areas 72.46% 41.04% 57.63% 51.33%System 100% 100% 100% 100%
corridors into NYC are susceptible to weather.
• Key Takeaway: antiquated FAA infrastructure is a driver of delays
Flight Departures
2+ Hr Tarmac Delays
Airspace Delayed Flts.
Minutes from Airspace Del.
Flight Departures 0.93 0.99 0.972+ Hour Tarmac Delays 0.93 0.97 0.99Airspace Delayed Flights 0 99 0 97 1 00
Correlation Coefficients
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 20
Source: Part 234 Reporting Data and DOT BTS
infrastructure is a driver of delaysAirspace Delayed Flights 0.99 0.97 1.00Minutes (Airspace Delays) 0.97 0.99 1.00
THE RULE
Conclusions about Tarmac DelaysINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
• Tarmac delays are unpredictable, seasonal and weather‐related
Limited options when they occur
• Tarmac delays occur in clusters and paralyze airports
Shortage of gates drives choice between tarmac delays and cancellations
• Tarmac delays are regional events and tied to ATC
Flight schedule reductions and re‐timing won’t solve the problem.Flight schedule reductions and re timing won t solve the problem.
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 21
THE RULE
How have airlines responded?INTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
Tarmac Delay Procedures
• Formal approach (DL, UA): specific time checkpoints
bli h d i h i
Time from Push-Back Checkpoint Action
2:00 after
Pilots confirm that food and water has been distributed. Pilots and
y
established with rare exceptions
• Informal approach (AA, WN): case by case basis, with flights
2:00 aftergate push-back Food and water cabin crew inform passengers
of the DOT rule and Delta’s compliance strategy.
2:00 Flight return Delta’s operations center conducts a review of the delayed flight and
flagged for action at 2 hours
• Result of all approaches: mandatory return to gate
2:00 gassessment
y gflags the operation for further
action.
2:15 Flight return decision
Unless takeoff is certain within 30 minutes, the flight returns to gate.
y gby 2:30 after pushback
2:30 Mandatory return
The aircraft returns to the gateeven if departure is imminent
(few exceptions permitted)
Based on interviews with airline operations teams
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 22
THE RULE
CancellationsINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
P iti fi t di i ti
MAY 2009 COMPLETED FLIGHTS BY TAXI TIME > 120 MINUTES
• Punitive fines create disincentive to risk 3 hour tarmac delays
• Airlines recall aircraft to the gate,
139
Probable gate return after 2:15
Ai i es eca ai c a t to t e gate,starting at 2:15 after push
• Up to six times the number of gate t fli ht th t
87Mandatory gate return
after 2:30
Subject to fines returns now versus flights that would statistically have 3h delay
• A significant portion of gate
45
25
Subject to fines
g p greturns cancel due to weather, resource or gate availability
120‐135 135‐150 150‐180 180+
Taxi time interval
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 23
Taxi time interval (546,832 total flights in data set)
THE RULE
ExampleINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
To illustrate: Pop‐up Storms over PA(62% of NYC tarmac delays cross this area) • Arrivals en‐route at time of event
from Florida, Caribbean, NortheastFLIGHTS ALREADY INBOUND AT 4PMPortland ME Fort Lauderdale
• Blocked corridors to the west
• Airport is open for landings
B f 3h Li i h d h ld
Portland ME Fort LauderdaleRaleigh Fort MyersPalm Beach AustinOakland San JuanLong Beach
BLOCKED WESTBOUND DEPARTURES 4‐6PM San Diego San Jose CA
NortheastInbound Flights
• Before 3hr Limit – push and hold
• Pushwestbound flights & hold on tarmac
San Diego San Jose, CAChicago Los AngelesOakland
Flights• Gates open for inbound flights
• Departwhen airspace clears
• Now – cancel and divert flightsblocked
CaribbeanI b d
Now cancel and divert flights
• Divert inbound to other cities
• Cancelwestbound flights and use aircraft for outbound
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 24
Florida Inbound Flights
Inbound Flights
use aircraft for outbound returns to Florida, Caribbean
THE RULE
May 2010 ResultsINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
MAY10 % MAY09 % Δ %
Flight Operations 542 747 546 832 (4 085) ‐0 7%
Year over year comparison:
Operations at similar levelFlight Operations 542,747 546,832 (4,085) 0.7%
On‐Time Arrivals 433,848 79.9% 440,151 80.5% (6,303) ‐1.4%
Late Arrivals 100,683 18.6% 100,688 18.4% (5) 0.0%
Weather‐Related 39,436 7.3% 47,329 8.7% (7,893) ‐16.7%
Non‐Weather‐Related 61,247 11.3% 53,359 9.8% 7,888 14.8%
p
Weather conditions improved
Cancellations up 40%
Di i 25%Cancelled Flights 6,716 1.24% 4,792 0.88% 1,924 40%
Diverted Flights 1,500 0.28% 1,201 0.22% 299 25%
Taxi Out Times (3hrs) * 1 nm 35 0.01% (34) ‐97%
Taxi Times (2‐3 hrs) 346 0.064% 355 0.065% (9) ‐2.5%
Prior to Cancellation 49 0.009% 14 0.003% 35 250%
Diversions up 25%
3 hour delays eliminated
Of flights with taxi out time between two and three hours:
Gate Return 86 0.016% 22 0.004% 64 291%
Taxi‐Out 171 0.032% 271 0.050% (100) ‐37%
Taxi‐In 10 0.002% 19 0.003% (9) ‐47%
Diversion Airport 30 0.006% 29 0.005% 1 3.4%
Taxi Times (1 2 hrs) 3 998 0 74% 4 747 0 87% (749) 16%
between two and three hours:
Cancellations up 2.5x
Gate returns up 3xTaxi Times (1‐2 hrs) 3,998 0.74% 4,747 0.87% (749) ‐16%
Prior to Cancellation 75 0.014% 40 0.007% 35 88%
Gate Return 335 0.062% 212 0.039% 123 58%
Taxi‐Out 3,143 0.579% 4,209 0.770% (1,066) ‐25%
Taxi‐In 269 0.050% 131 0.024% 138 105%
Of flights with taxi out time between one and two hours:
Cancellations up 88%
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 25
Diversion Airport 176 0.032% 155 0.028% 21 14% Gate returns up 58%* Delta Flight 2011 5/28/10 trapped on tarmac due to lightning for 182 minutes
THE RULE
May 2010 (2)INTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
CANCELLATIONS MULTIPLE GATE DEPARTURESAIRLINE May 2010 May 2009 All 2009 May 2010 May 2009 All 2009
CANCELLATIONS & RETURNS TO GATEFOR FLIGHTS WITH 2‐3 HOUR TAXI‐OUT TIMES
BY AIRLINE FOR 2HR+ DELAYSAirTran Airways 41.67% 11.11% 4.88% 25% 0% 12.20%American Airlines 15.38% 2.67% 3.95% 15.38% 1.33% 6.22%American Eagle 30.77% 17.14% 9.30% 30.77% 8.57% 12.68%Atlantic Southeast 12.90% 0% 3.37% 22.58% 12.50% 13.48%Comair 13.64% 8.57% 9.57% 13.64% 5.71% 10.49%Continental 13.33% 0% 2.41% 33.33% 0% 13.90%
BY AIRLINE FOR 2HR DELAYSIncreased cancellations at every reporting airlineAirTran 4x cancel rateUS Ai 5 l tDelta 11.49% 0% 1.75% 26.44% 0% 6.83%
ExpressJet 13.64% 0% 3.10% 45.45% 0% 13.08%Pinnacle 35.29% 0% 13.42% 5.80% 16.67% 23.49%United 3.70% 0% 2.17% 22.22% 4.17% 9.49%US Airways 10.71% 2.22% 6.66% 28.57% 8.89% 8.87%Southwest 0% 0% 0% 30% 9.09% 4.04%
US Airways 5x cancel rateReturns to gate up 5xSignificant statistical departure from history
ALL AIRLINES 14.16% 3.94% 4.83% 24.86% 6.20% 10.29%
CANCELLATIONS MULTIPLE GATE DEPARTUREAIRPORT May 2010 May 2009 All 2009 May 2010 May 2009 All 2009Dallas Fort Worth 20.00% 8.00% 7.34% 20% 0% 3.95%Detroit 28.57% 0.00% 18.18% 28.57% 25.00% 12.12%
BY AIRPORTC ttWashington Reagan 12.50% 5.88% 9.74% 37.50% 17.65% 15.90%
Newark Liberty 20.00% 0% 1.80% 80.00% 0.00% 10.21%Philadelphia 11.76% 0.00% 3.10% 29.41% 6.67% 6.67%Washington Dulles 12.00% 8% 8.46% 28.00% 0% 13.93%Chicago O'Hare 15.63% 5% 7.87% 37.50% 11% 10.16%New York La Guardia 29.79% 14% 5.03% 25.53% 14% 8.88%
Common patterns across airports – all increasePronounced impact in New York area
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 26
New York Kennedy 8.33% 2% 2.61% 25.00% 1.11% 5.81%Atlanta 14.52% 0% 5.53% 14.52% 11.11% 14.07%ALL AIRPORTS 14.16% 3.94% 4.83% 24.86% 6.20% 10.29%
THE RULE
May 2010 (3): Case Study DFW May 14, 2010INTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
SEVERE
MAY 14, 2010 CANCELLATIONS AA | DALLAS FORT‐WORTH AIRPORT
AIRPORT FLOW AND CAPACITY(Source: FAA ASPM)
15
20
25
30SE E E
WEATHER EVENT
0
5
10
10am
‐11am
‐12p
m
2‐1p
m
m‐2pm
m‐3pm
m‐4pm
m‐5pm
m‐6pm
m‐7pm
m‐8pm
m‐9pm
‐10p
m
‐11p
m
dnight
Before 10‐
11‐ 12
1pm
2pm
3pm
4pm
5pm
6pm
7pm
8pm
9pm‐
10pm‐
11pm‐M
id
ARRIVALS DEPARTURES
We estimate 75 departure cancellations were due to gate shortages and tarmac rules; 1:1 (or 75) arrival cancellations.rules; 1:1 (or 75) arrival cancellations.
Key lesson: tarmac‐related cancellations have at least a 1:1 impact on follow‐on cancellations due to aircraft availability
234 Re
ports
Sudden severe weather event that impacted the DFW airport
American Airlines cancelled 308 flights.
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 27
or network recovery
Source: D
OT Pa
rt 2
161 departures and 147 arrivals
THE RULE
Key FindingsINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
• Cancellations and diversions up significantlyCancellations and diversions up significantly
• Airlines already cancelled hundreds of flights due to the rule impacting tens of thousands of passengers
– 140 flights based on reported data from May alone
– Prevented 35 tarmac delays (4:1 ratio)
– Does not include pre‐cancellations and cancellations to free gate resources
• On pace for between 5,200 and 6,000 annual cancellations due to rule
• Diversions are a material concern for passenger welfare
We now review the public welfare implications of these results.
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 28
THE RULE
DOT AssumptionsINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
DOT projected public welfare gains of $69.1 million over 20 years.
• 2.8% incremental cancellations (41 per year) of three‐hour delayed flights.
• No follow‐on cancellations.
• No change to flights with less than 3 hour expected taxi time.
• Minimal taxi‐in and taxi‐out time for returns to gate.
G il bili d• Gate availability guaranteed.
• No material change in diversions.
• Passenger re‐accommodation time under 9 hours• Passenger re‐accommodation time under 9 hours.
Each of these assumptions must be updated.
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 29
p p
THE RULE
DOT Welfare EstimateINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
DOT assumed 2.8% cancellations of three‐hour flights.
Real‐world observations 14.16% and 4:1 overall cancellation ratio
Hundreds of flights cancelled already
• For flights that cancelled after 60 minutes of taxi, plus direct follow‐on cancellations, incremental 140 flights due to tarmac rule in May 2010.
• 140 flights to achieve 35 fewer taxi‐out delays (4:1)140 flights to achieve 35 fewer taxi out delays (4:1)
• May is not peak‐season for tarmac delays
• DOT’s analysis is based on 1,481 annual tarmac delays
• 1481 * 4 = 5,924 annual cancellations based on observations
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 30
THE RULE
Recalculating WelfareINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
Conservative Case Observed Case
DOT b li lf $69 1 illi (20 )DOT baseline welfare +$69.1 million (20 yrs)
Cost of flights returning to gate (using DOT costs)
All flights 2.5‐3.0 hours‐$12.6 million
Longer passenger re‐booking time
18.6 hours vs. 5.9 hours‐$30.8 million
14 16% cancellations 2:1 ratio of cancellations to
Incremental Cancellations
14.16% cancellations2.5 hour return to gateNo pre‐cancellations
No follow‐on cancellations315 cancellations
2:1 ratio of cancellations to prevented tarmac delays plus 1:1 indirect to direct ratio
1,481 prevented delays (DOT)5,924 cancellations
‐$210.3 million ‐$3.9 billion
Welfare Change ‐$253.7 million ‐$3.9 billion
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 31
Net public welfare change ‐$184.7 million ‐$3.9 billion
THE RULE
ConclusionsINTRODUCTION TARMAC DELAYS CANCELLATIONS WELFARE CONCLUSIONS
• Cancellations have gone up due to the rule, and it is a bad thing
• Range of public harm from $187 million to $3.9 billion
• Can’t schedule your way out of tarmac exposure – they are caused by unpredictable and prolonged events
• Is the cost to consumers in cancellations and di ersions worthwhile?• Is the cost to consumers in cancellations and diversions worthwhile?
• DOT Regulatory Analysis used to justify the action must be updated with real‐world data
• Public review is critical before any expansion or changes to the tarmac limits in the future
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 32
Detailed Calculations of Consumer Welfare ImpactAPPENDIX
CHANGE CHANGE OVERQUANTITY/ PRICE/ DURING 20 YEARS @ 7% SOURCE
KEY ASSUMPTIONS UNIT VALUE FIRST YEAR 2.6% INFLATION MATERIAL(millions) (millions)
Tarmac delayed flights (2007-2008) 1,481 DOT (RIA p42)Fli ht ith 2 5 3 0 h t i ti (07 08) 1 284 DOT (RIA 40)Flights with 2.5-3.0 hour taxi time (07-08) 1,284 DOT (RIA p40)Passengers on flights with 2.5-3.0 hour taxi 86,689 DOT (RIA p40)Average passengers per flight 68 DOT (RIA p40)Value of passenger time (per hour) $29.53 DOT (RIA p42)Passenger fee (per enplanement & deboarding) $1.37 DOT (RIA p42)Taxi cost (for each gate return or redeparture) $88.24 DOT (RIA p42)DOT assumed passenger rebook time (hrs) 5.9 DOT (RIA p42)Adjusted rebook time @ 83% load factor (hrs) 18.6 Marks and Jenkins (2010)Cancellations DOT estimate (2 75%) 41 DOT (RIA p42)Cancellations, DOT estimate (2.75%) 41 DOT (RIA p42)Passnegers on DOT cancelled flights above 3,176 DOT (RIA p42)Cancellations, observed rate of 4:1 5,924 Marks and Jenkins (2010)Cost per cancellation, airline $14,818.00 DOT (RIA p42)
STATED PUBLIC BENEFIT OF CHANGES $69.1 DOT (RIA p61)
Part One: New Returns to Gate & Re-DepartureFuel Cost Taxi-in 1 284 ($88 24) ($0 11) ($1 5) Returns to gate * taxi-in fuelFuel Cost Taxi-in 1,284 ($88.24) ($0.11) ($1.5) Returns to gate taxi-in fuelFuel Cost Taxi-out 1,284 ($88.24) ($0.11) ($1.5) Gate departures * taxi-out fuelPassenger disembarkation fee 86,689 ($1.37) ($0.12) ($1.5) Pax on 2.5-3.0 hr flights * feePassenger reboarding fee 86,689 ($1.37) ($0.12) ($1.5) Pax on 2.5-3.0 hr flights * fee
Part Two: Observed CancellationsAirline cost of incremental cancellations 5,883 ($14,818.00) ($87.17) ($1,125) (5,924 less 41) * Cost per cancelCredit for taxi-out fuel 5,883 $88.24 $0.52 $6.7 Fewer taxi-out because of cancelsCredit for passenger reboarding 397,190 $1.37 $0.54 $7.0 Fewer reboarding costsCredit for passenger reboarding 397,190 $1.37 $0.54 $7.0 Fewer reboarding costs
Part Three: Increased Passenger Travel TimeOriginal DOT passengers cancelled 3,176 Initial DOT projection of cancelled paxIncreased travel time, per passenger 12.7 Increase due to higher load factorsValue of increased travel time across group 40,335 ($29.53) ($1.19) ($15.4) (Pax) * (hours) * (value of time)Passengers on cancelled flights 397,190 Incremental passengers cancelledIncrease in hours travelled 18.6 Incremental hours to rebookValue of increased travel time across group 7,387,726 ($29.53) ($218.16) ($2,816) (Pax) * (hours) * (value of time)
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 33
g p ( ) ( ) ( ) ( ) ( ) ( )
CHANGE IN PUBLIC BENEFIT (millions) ($305.93) ($3,949)
NET PUBLIC BENEFIT (millions) ($3,880) $3.88 billion over 20 years
AirTran May 28, 2010APPENDIX
ASSIGNED PLANNED GATE GATE ULTIMATE
On May 28, AirTran had 2:1 cancellations due to gate returns
ASSIGNEDAIRCRAFT FLIGHT PLANNED
OPERATION DEPARTURE (FIRST)
DEMAND TIME
FLIGHT OUTCOME
N950AT FL432 ATL‐MCI 4:22 PM 5:40 PM REDEPARTED (AFTER GATE RETURN)N956AT FL434 ATL‐PNS 6:30 PM CANCELLED (BEFORE PUSH)N899AT FL415 ATL‐IND 6:48 PM CANCELLED (BEFORE PUSH)( )N603AT FL155 ATL‐TPA 6:50 PM CANCELLED (BEFORE PUSH)N986AT FL702 ATL‐DAY 4:32 PM 7:18 PM CANCELLED (AFTER GATE RETURN)N893AT FL380 ATL‐MLI 5:13 PM 7:19 PM CANCELLED (AFTER GATE RETURN)N309AT FL268 ATL‐BOS 5:53 PM 7:37 PM CANCELLED (AFTER GATE RETURN)N891AT FL781 ATL‐STL 5:53 PM 7:52 PM REDEPARTED (AFTER GATE RETURN)N891AT FL781 ATL STL 5:53 PM 7:52 PM REDEPARTED (AFTER GATE RETURN)N944AT FL65 ATL‐IAD 6:02 PM 7:53 PM CANCELLED (AFTER GATE RETURN)N930AT FL909 ATL‐PHF 5:38 PM 7:56 PM CANCELLED (AFTER GATE RETURN)N991AT FL333 ATL‐PHL 5:33 PM 7:58 PM REDEPARTED (AFTER GATE RETURN)N290AT FL104 ATL‐DFW 7:15 PM 8:15 PM CANCELLED (AFTER GATE RETURN)N947AT FL75 ATL FLL 7 13 PM 8 26 PM CANCELLED (AFTER GATE RETURN)N947AT FL75 ATL‐FLL 7:13 PM 8:26 PM CANCELLED (AFTER GATE RETURN)N292AT FL358 ATL‐LGA 8:55 PM CANCELLED (BEFORE PUSH)N989AT FL968 ATL‐ACY 9:00 PM CANCELLED (BEFORE PUSH)N942AT FL123 ATL‐TPA 9:00 PM CANCELLED (BEFORE PUSH)N337AT FL67 ATL‐SFO 10:05 PM CANCELLED (BEFORE PUSH)
IMPACT OF THREE HOUR TARMAC DELAY RULES AND FINES | JULY 20, 2010 Slide 34
N957AT FL995 ATL‐PIT 10:15 PM CANCELLED (BEFORE PUSH)N932AT FL395 ATL‐MLI 10:20 PM CANCELLED (BEFORE PUSH)