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– North America

To Department of Transportation Aviation Consumer Protection Committee June 28, 2012

Airports Council International

- North America represents local, regional and state govern ing bodies that own and operate commercial service airports in the United States and Canada. Our 3 45 member airports enplane more than 95 percent of the U.S. domestic and virtually all of the international airline passenger and cargo traffic in North America.

Airports are the “public face of aviation” in hundreds of communities throughout the United States, working with airlines an d other service providers to meet passenger needs and provide a pleasant travel experience. We believe that it is critical that the Advisory Committee consider th e airport p erspective and I very much appreciate the opportunity to appear before you today.

It’s true that many of the issues being studied by this C ommittee are the responsibility of parties other than the a irports. However, a recent ACI

- NA nationwide poll showed us that traveler knowledge about “who does what” at airports is quite limited. For exa mple, we found that 20 percent of consumers believe d that airports we re responsible for delayed or cancelled flights. Almost a third blame airports for problems with lost or mishandled bags and almost half believe that airports are responsible for planes being st uck on the tarmac awaiting departure or arrival at the gate.
Because the image of airports is intrinsically linked to whether or not we’re meeting passenger needs, we have a critical stake in resolving shortcomings throughout the air travel experience. We also understand that passengers expect airports to help resolve their problems because airports are part of their community, working not only to bring price and service competition

, but also to improve the travel experience.

It is important to understand that f ailure to meet consumers’ needs often has root causes that also have a significant impact on airport operations and facilities. Whether the problem involves providing timely and accurate information, on

- time departure or arrival performance , baggage handli ng or resolving extended tarmac delays, Improvements to any or all of these areas would help airports more effectively serve passengers, airlines and cargo services.

Enhancing the passenger experience and meeting consumer needs also ensures that airports can continue to generate jobs and economic development in their communities. The unfortunate fact is that p assengers often associate a negative travel experience with the airport at which the instance occurred, regardless of the reason for the problem. If p assengers lose con fidence in the operations at an airport because of failures in customer service

, they may fly out of another airport in the future or use a competing mode of transportat ion . This impacts the finances of individual airports, the airport in dustry as a whole and the local economy in hundreds ofACI

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communit ies throughout the United States

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- NA’s February 2012 study found that America’s commercial airports are a powerful economic engine, generating 10.5 million jobs and $1.2
tr illion in total economic impact in 2010

. Airports a re responsible for about 8 percent of U.S. gross domestic product and an estimated 7 percent of jobs.
Over the last four years ACI

- NA has been very active in responding to DOT regulatory proposals on behalf of airports and we appreciate the Department’s consideration of our comments. Whether the proposal involved compensation for o vers old flights and denied boarding, chronically

- delayed flights, airline customer service plans, flight status changes

, delay data, reporting of mishandled bags o r emergency contingency plans, ACI

- NA has consistently advocated that the Department ensure that passengers have relevant , accurate and timely information to assist in making more informed travel decisions.

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- N A also has not only been active in working with the FAA and DOT but also with the U.S. Access Board in improving the access for passengers with disabilities to the national air transportation system. A irport operator s want to ensure that the needs of pas sengers with disabilities are accommodated, regardless of who might be responsible for providing the actual service to the passengers . We have been a leader in working with airlines and organizations representing passengers with disabilities

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- NA has a lso participated in public hearings and seminars by FAA, DOT, DOJ, DOL, EEOC, the U.S. Access Board, and the National Council on Disability and has provided extensive training and information to our airport members regarding the accommodation of passengers with disabilities. We have also provided the airport perspective on numerous regulation proposals from federal agencies regarding individuals with disabilities.

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- NA is very pleased that DOT and other federal agencies have adopted many of our suggestions in developing final rules over the last four years . We were particularly pleased in 2011 when DOT expanded the tarmac delay regulations to cover small and non

- hub airports and require d domestic and international airlines to coordinate thei r plans wi th each U.S. large, medium , small

, and non

- hub hub airport served , as well as diversion airports . ACI

- NA had long

a rgued that it was critic al to protect passengers at more than 300 smaller airports in the United States as the impact of tarmac del ays at these facilities often is even more pronounced than at larger facilities

. Even with these regulatory enhancements, much work remains to be done. As last year ’s early winter storm in the Northeast showed, there must be better coordination before and during severe weather events or other flight disruptions . Further

, airports must be empowered to tell FAA and airlines “no more flights” if the facility cannot accommodate the aircraft or respond to airline requests for help in a reasonable time. FAA and airlines also must provide airports with accurate information about diverted flights and other diversion airports to prevent overloading any single diversion airport.

Effective means of communicating information about rapidly changing airport conditions and flight status

— including diversion information in real

- time among all operational stakeholders

— airports, airlines, the FAA Air Traffic Organization, TSA and CBP

— is a critical component of enhancing the passenger experience and minimizing passenger incon venience during severe weather and other mass diversion events. We are heartened by the actions of airport operators to implement surface management solutions, which are improving airports’ and airlines’ situational awareness in good weather and bad. We have also been impressed by the private sector’s development of tools

— some of which have been provided free of charge

— to share key operational information in real

- time throughout the NAS. We encourage the FAA to follow these examples and provide mechanism s for airports and the airlines to have better situationalACI

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awareness and make better operational decisions before and during diversion events for the benefit of passengers

. In closing, w e would ask this Committee to recommend that DOT take action to provide all consumers the same level of protection. ACI

- NA believes it i s long overdue for DOT to expand delay and mishandled baggage reporting, as well as provisions related to oversales and denied boarding compe nsation to all commercial airli n e s, not ju st those “covered carrier” that account for at least one percent of domestic scheduled passenger revenue

. To the passenger, the effects of delays, baggage mishandling or denied boarding are the same no matter which airline actually operates the aircraft or the size of the airplane . Additionally, given the fact that regional airlines now transport one out of every four domestic passengers and operate half of daily domestic flights, as well as provide the only scheduled service to approximately 70 percent of U.S. airports, it is critical that DOT include their operations in consumer protection regulations as well

. There is no justification for providing consumer protections only to those traveling on the nation’s largest airlines. All passengers deserve the c ustomer service , passenger protections and legal rights afforded by DOT regulations

. Thank you again for the opportunity to present the U.S. airport industry perspective. I look forward to answering your questions.