U.S. Department 

of Transportation 

Research and 

Innovative Technology 

Administration 

Ms. Joy Journeay 

AACA Executive Director 

Alaska Air Carriers Association 

2301 Merrill Field, Drive A-3 

Anchorage, AK 99501 

Dear Ms. Journeay: 

- : . . ~ ; 

1200 New Jersey. S. E 

Washington. D.C. 20590 

December 5, 2013 

The Office of Airline Information (OAI) has received several inquiries regarding our August 6 

letter about improving both the timeliness and reliability of the carriers' financial reporting, 

specifically Schedules F-1 and F-2. The challenge oflate or inaccurate F-1 and F-2 filings 

affects all carriers through delayed or inaccurate mail rates, and also creates a burden for OAI 

staff that must then follow up on these late or inaccurate filings. Our goal is to encourage the 

carriers to give the same priority to reporting the critical financial reports that they have 

displayed in filing their T -1 00 Market reports. 

To clarify our earlier letter, I am providing the following concrete example of its 

implementation: 

Consistent with 14 CFR 298.60, the bush carriers' financial schedules for the quarter ending 

December 31,2013, are due on or before February 10, 2014; 1 while the traffic reports for the 

month of December are due on or before January 30,2014. If a particular carrier's financial and 

traffic reports are submitted on a timely basis, and if all of the data are determined by edit checks 

to be error free, OAI will continue its current practice and forward the T -100 Market data, used 

for determining mail tender, to the Postal Service on the scheduled release date: March 18, 

2014.2 

1 On February 3, 2014 as under current practice, the Office of Airline Information (OAI) will email a reminder to the 

carriers about the approaching deadline. In that email OAI would reiterate the thrust of this letter- that all of the 

data must be timely and free of any edit checks for OAI to forward to the Postal Service that data without caveat 2 The 3'd Tuesday of the 3'd month following the end of the period. 
However, if any carrier does not file "error free" financial and traffic data by those respective 

due dates, OAI will only forward T-100 Market data for the 11 months through November 30, 

2013; i.e., excluding traffic for the month of December. OAI will so notify the Postal Service.3 

Thus, any carrier submitting any required data on a delayed basis or of poor quality would lose 

credit with the Postal Service for approximately one-twelfth of its annual totals of passengers and 

freight. While there might be no significant cost to the carrier after only one month, the risk 

would grow with each passing month; if all problems have not been resolved by the next 

scheduled release date, only ten months of data will be forwarded to the Postal Service. 

Carriers should recognize that the result of submitting unreliable financial or traffic data is 

equivalent to not submitting that data at all. Rather than creating an overly harsh reporting 

regime, we believe that with the advent of the 298C web-based reporting, the carriers can now 

themselves apply some of the edit checks before submitting the 298C data to OAI, thereby simplifying 

and speeding the process considerably. OAI will still subject the data to additional internal edit checks 

and will endeavor to quickly advise the carrier when edit checks produce errors or warnings- hopefully 

well before the regulatory deadline. Given this new business model, carriers are strongly encouraged to 

submit their data early to allow adequate time for OAI to process the data, and to give the carrier 

ample opportunity to reconcile any problematic data before the due date. 

In brief, while late or inaccurate reports typically involve only a few carriers, but have an adverse 

impact on the entire industry. These straightforward incentives will encourage compliant 

reporting, but the alternative of taking enforcement action will remain. 

As we indicated in our earlier letter, we are available to discuss these matters with you, the 

carriers, or the Postal Service, by phone, either individually or by conference call. 

~inl\e. ly, r(\ \ 

i \ ' \ I~ ' } ·\ J 

~: l~ \\~ wmiam cbadwick,n 

Director, Office of Airltrfe1nformation 

CC: 

Kevin Schlemmer, DOT/OST, Kevin Adams, DOT/OST 

Kevin Hartner, United States Postal Service 

Paul Hendrickson, The Postal Service Carriers Workgroup (PAWS) 

Jennifer Rodes, DOT/BTS/OAI, Marianne Seguin, DOT/BTS/OAI 

3 Of course, OAI cannot forward to the Postal Service data it does not have, or data that was not submitted on a 

timely basis. OAI will inform carriers if and when problems are found with the data.