AIRLINES FOR AMERICA COMMENTS ON BTS INFORMATION COLLECTION PROCEDURES
June 5, 2018
Beginning in late 2014, and continuing to the present, the Department’s Bureau of Transportation Statistics (BTS) has been pursuing an initiative to evaluate the continuing need for and usefulness of BTS collecting certain financial data from large certificated U.S. air carriers. On May 9, 2018, Airlines for America filed a comment targeting DOT’s Form 41 “Report of Financial and Operating Statistics for Large Certificated Air Carriers” requirement. A4A urged the Department to “repeal all airline reporting requirements not specifically required by statute, especially for extensive and burdensome Form 41 reporting requirements” and cited the Trump Administration’s Executive Orders 13771 and 13777 (which call for reductions in regulations and the control of regulatory costs).
A4A recommended that – at a minimum – DOT:
- Streamline employment reporting (P10 – Annual Employee Statistics by Labor Category);
- Do away with the BTS requirement that large certificated U.S. air carriers submit monthly income statement and balance sheet data to DOT (A4A instead notes that quarterly reporting should be sufficient to meet the Department’s need for information); and
- Eliminate the requirement to submit Form 41, Schedule B-43, Inventory of Airframes and Aircraft Engines.
If you have any questions, please contact Evelyn Sahr (esahr@eckertseamans.com or 202-659-6622); Drew Derco (dderco@eckertseamans.com or 202-659-6665), or Alexander Matthews (amatthews@eckertseamans.com or 202-659-6633).
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