ATA Letter to DOT Sec. Peters Opposing Airport Auctions

Commercial aviation helps drive more than 10M American jobs and 5 cents of every dollar of U.S. GDP
Commercial aviation drives more than $1 trillion per year in economic activity
In 2012, U.S. airlines moved more than 48,000 tons of cargo per day
In 2012, the value of a kilogram of U.S. merchandise exported by air averaged 121 times the value exported by sea
For every 100 airline jobs, some 360 are supported outside of the airline industry
Federal taxes constitute $61 – or 20% – of the price of a typical $300 domestic round-trip ticket
In 2011, U.S. airlines carried 16 percent more passengers and cargo using 10 percent less fuel than in 2000
Domestically, airlines drive 5% of economic activity but account for 2% of man-made GHG emissions
From 2000-2011, airlines reduced GHG emissions by 11% while transporting 16% more passengers and cargo
From 1975-2011, U.S. airlines and their partners reduced significant noise exposure by 99%
Commercial air travel is the safest form of intercity transportation in the United States
In the most recent decade, scheduled air service on U.S. airlines was seven times safer than in the 1970s
From 2000-2012, U.S. airlines improved the on-time arrival rate from 72.6% to 81.9%
From 2000-2012, U.S. airlines reduced the flight cancellation rate sharply from 3.30% to 1.29%
Airfares are a bargain: From 2000-2012, U.S. CPI rose 33% while average domestic fare rose just 13%
Adjusted for inflation, the average round-trip domestic airfare fell 15% from 2000
2007 domestic flight delays cost the United States approximately $31 billion
In 2012, the value of U.S. merchandise exported by air reached an all-time high of $427B
In 2012, U.S. exports of air-travel services reached an all-time high of $39.5B, driving a $5.1B trade surplus
In 2012, U.S. passenger and cargo airlines spent more than $50B on fuel, averaging 36% of operating expenses
In 2012, U.S. airlines posted the lowest annual rate of mishandled baggage ever recorded
FAA projects U.S. air travel demand to top 1 billion passengers in 2027
In 2012, US airlines flew 83.4 million passengers in scheduled international service - a record high
In 2012, the total value of merchandise exported from or imported to the United States by air exceeded $927 billion
In 2012, 7.15 teragrams of merchandise was exported from or imported to the United States by air

	ATA Letter to DOT Sec. Peters Opposing Airport Auctions
	PubZone1 March 31, 2008 The Honorable Mary Peters Secretary U.S. Department of Transportation 400 7th Street, S.W. Washington, DC 20590 Re: Airport Auctions Dear Secretary Peters: The Air Transport Association (ATA) and its member airlines appreciate your leadership and commitment to reducing congestion and flight delays in the New York metropolitan area. We are committed to working with the administration and fully support practical, constructive and proven measures that will accomplish our mutual goals. The ability of the Department of Transportation (DOT) and airlines to implement meaningful solutions makes recent actions by the DOT both confusing and disappointing. By all accounts, the Department is forcing slot auctions and congestion pricing on the industry. The JFK and Newark schedule-limitation orders make it clear that the Department intends to establish a slot auction mechanism, and a recent Federal Aviation Administration (FAA) Web site notice that seeks comment from auction software designers on a potential solicitation for auction services confirms DOT’s objective. In addition, the Department has proposed changes to its policy on airport rates and charges that are specifically intended to encourage congestion pricing. These actions are legally indefensible, inconsistent with international practice and they are adamantly opposed by virtually the entire U.S. and international airline community. As discussed at length during the course of the New York Aviation Rulemaking Committee (NYARC) and in meetings with your staff and the Office of Management and Budget, DOT does not have the authority to mandate so-called “market mechanisms” – auctions and congestion pricing – to allocate access to congested airports. The Department’s general authority to manage the airspace for safety and efficiency does not provide the specific congressional mandate needed to impose an airport access pricing regime. That is why the FAA acknowledged it lacks authority for market mechanisms in the LaGuardia Congestion Management Rulemaking. Moreover, even if the Department did have such authority, it simply has not engaged in the kind of notice-and-comment process required under the Administrative Procedure Act to establish an auction scheme. Many questions about such a scheme, including who receives the revenues and how they may be used, remain unanswered. This makes the FAA auction design notice all the more puzzling. These actions also conflict with the DOT 2008 appropriations legislation, which prohibits new aviation user fees not specifically authorized by law. Public interest considerations also weigh heavily against auctions. First, auctions do not address the underlying responsibility of the federal government to improve capacity in the National Air Space (NAS) in general and in the New York region particularly – indeed they facilitate that problem; and second, auctions add even more costs for airlines that they will either be forced to absorb – at a time when airlines are trying to deal with runaway fuel costs, or fares will go up unnecessarily for the traveling and shipping public. Either way, customers, and ultimately airline employees, lose. Finally, it is clear from the presentations made during the NYARC that there is near unanimity among U.S. and foreign airlines in support of the Worldwide Scheduling Guidelines, with a secondary trading market, as the best market mechanism to allocate airport access. The issues of new entry and competition, raised by some, can be addressed adequately by appropriate rules and procedures and are not sufficient reasons to jettison this widely accepted mechanism for a complex and untried theoretical alternative. Please be assured that ATA and its member airlines want to work with the administration and fully support meaningful measures to alleviate congestion in the New York metropolitan area and throughout the NAS. I would be pleased to discuss these issues with you at your convenience. Sincerely, James C. May President and CEO PubZone2	A4A advocates measures to support aviation safety, security and well-being.