omb.2138-0040.justification2020

SUPPORTING STATEMENT
OMB No. 2138-0040
14 CFR Part 241 T100/T100f Air Carrier Traffic and
Capacity Data by Nonstop Segment and On-Flight Market
A. Justification
1. Explain the circumstances that make the collection of information necessary.
Identify any legal or administrative requirements that necessitate the collection.
The Department collects and uses traffic, operational and capacity data reported on
Schedules T-100 and T-100(f) to administer its aviation program responsibilities. In 49
U.S.C. section 41708 and 41709 the Secretary of Transportation is given the authority to
require an air carrier or foreign air carrier to file annual, monthly, periodical and special
reports concerning the movement of traffic, and the receipts and expenditures of money.
2. Indicate how, by whom, and for what purpose the information is to be used.
Indicate the actual use the agency has made the information received from the
current collection.
The T-100 reporting system is designed to collect nonstop segment and on-flight market
data for scheduled, nonscheduled, and charter flights from U.S. and foreign air carriers
for each flight to from or between U.S. points. The data elements collected are:
Code

110
130
217
219
237
239
270
310
510

Description
Carrier, carrier entity code - Segment & Market
Reporting period date - Segment & Market
Origin airport code - Segment & Market
Destination airport code - Segment & Market
Service class code - Segment & Market
Aircraft type code - Segment
Revenue passengers enplaned - Market
Revenue passengers transported - Segment
Enplaned freight - Market
Enplaned mail - Market
Transported freight - Segment
Transported mail - Segment
Available capacity payload - Segment
Available seats, total - Segment
Revenue aircraft departures performed - Segment
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520
610
630
650

Revenue aircraft departures scheduled - Segment
Revenue aircraft hours (airborne) - Segment
Aircraft hours (ramp-to-ramp) - Segment
Total aircraft hours (airborne) - Segment

From the data elements reported by the air carriers, the Department computes the
following data elements:
140 Revenue passenger-miles
210 Revenue cargo tons enplaned
230 Revenue tons transported
240 Revenue ton-miles
241 Revenue ton-miles passenger
247 Revenue ton-miles freight
249 Revenue ton-miles mail
280 Available ton-miles
320 Available seat-miles
410 Revenue aircraft miles flown
430 Revenue aircraft miles scheduled
501 Inter-airport distance
The data are used for the following purposes:
AIRPORT IMPROVEMENT
The Federal Aviation Administration uses enplanement data for U.S. airports to distribute
the annual Airport Improvement Program (AIP) entitlement funds to eligible primary
airports, i.e., airports which account for more than 0.01 percent of the total passengers
enplaned at U.S. airports. Enplanement data contained in Schedule T-100/T-100(f) are
used by the FAA in determining airport funding.
AIR CARRIER SAFETY
The FAA uses traffic, operational and capacity data as important safety indicators and to
prepare the air carrier traffic and operation forecasts that are used in developing its
budget and staffing plans, facility and equipment funding levels, and environmental
impact and policy studies. The FAA monitors changes in the number of air carrier
operations as a way to allocate inspection resources and in making decisions as to
increased safety surveillance. Similarly, airport activity statistics are used by the FAA to
develop airport profiles and establish priorities for airport inspections.
ACQUISITIONS AND MERGERS
While the Justice Department has the primary responsibility over air carrier acquisitions
and mergers, the Department reviews the transfer of international routes involved to
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determine if they would substantially reduce competition, or determine if the transaction
would be inconsistent with the public interest. In making these determinations, the
proposed transaction’s effect on competition in the markets served by the affected air
carriers is analyzed. This analysis includes, among other thinks, a consideration of the
volume of traffic and available capacity, the flight segments and origins-destinations
involved, and the existence of entry barriers, such as limited airport slots or gate capacity.
Also included is a review of the volume of traffic handled by each air carrier at specific
airports and in specific markets which would be affected by the proposed acquisition or
merger. The Justice Department uses T-100 data in carrying out its responsibilities
relating to airline competition and consolidation.
TRAFFIC FORECASTING
The FAA uses traffic, operational and capacity data as safety indicators and to prepare
the air carrier traffic and operation forecasts. These forecast as used by the FAA, airport
managers, the airlines and others in the travel industry as planning and budgeting tools.
AIRPORT CAPACITY ANALYSIS
The mix of aircraft type are used in determining the practical annual capacity (PANCAP)
at airports as prescribed in the FAA Advisory Circular Airport Capacity Criteria Used in
Preparing the National Airport Plan. The PANCAP is a safety-related measure of the
annual airport capacity or level of operations. It is a predictive measure which indicates
potential capacity problems, delays, and possible airport expansions or runway
construction needs. If the level of operations at an airport exceeds PANCAP
significantly, the frequency and length of delays will increase, with a potential concurrent
risk of accidents. Under this program, the FAA develops ways of increasing airport
capacity at congested airports.
AIRLINE INDUSTRY STATUS EVALUATIONS
The Department apprizes Congress, the Administration and others of the effect major
changes or innovations are having on the air transportation industry. For this purpose,
summary traffic and capacity data as well as the detailed segment and market data are
essential. These data must be timely and inclusive to be relevant for analyzing emerging
issues and must be based upon uniform and reliable data submissions that are consistent
with the Department’s regulatory requirements.
INTERNATIONAL NEGOTIATIONS AND ROUTES
Many air services between the United States and foreign countries are governed by
bilateral agreements. Evaluations of existing bilateral agreements and proposed changes
to such agreements are based on a determination of the traffic and revenues between the
United States and foreign countries for scheduled passenger and cargo flights as well as
charter services. In order to determine conditions of reciprocity and overall balance of
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trade, DOT conducts similar analyses for countries with which the United States does not
have bilateral aviation agreements. Information used in these analyses includes traffic
volume by countries and by city-pairs for passenger and cargo services and the
corresponding traffic yields. Load factors, aircraft seating configurations, cargo
capacities and aircraft unit cost are also used in the analyses. In limited entry markets,
the competing air carriers are required to submit an operating plan. To analyze these
plans, the Department uses current and historical traffic and capacity data to determine
the reliability of the applicants’ forecasts and to evaluate applicants’ competing fare and
service proposals.
Recently, The U.S. and the European Union agreed to open skies agreement between the
two geographic areas. T-100 data will be used to measure the effectiveness of this
agreement.
MAIL RATES
The Department is responsible for establishing intra-Alaska mail rates. The rates are
updated to reflect changes in unit costs. Traffic and capacity data are used in
conjunction with cost data to develop the required unit cost data. There are four mail
rates set within the State of Alaska – mainline, part 121, part 131, and amphibious. Also,
the United States Postal Services uses passenger and cargo market data from T-100 as the
basis for tendering bush mail to the individual carriers.
ESSENTIAL AIR SERVICE
The Department reassesses service levels at small domestic communities to assure that
capacity levels are adequate to accommodate current demand
SYSTEM PLANNING AT AIRPORTS
The FAA is charged with administering a series of grants that are designed to accomplish
the necessary airport planning for future development and growth. These grants are made
to state metropolitan and regional aviation authorities to fund needed airport systems
planning work. Individual airport activity statistics, nonstop market data, and service
segment data are used to prepare airport activity level forecasts.
REVIEW OF IATA AGREEMENTS
The Department reviews all of the International Air Transport Association (IATA)
agreements that relate to fares, rates, and rules for international air transportation to
ensure that the agreements meet the public interest criteria. Current and historic summary
traffic and capacity data, such as revenue ton-miles and available ton-miles, by aircraft
type, type of service, and length of haul are needed to conduct these analyses: to (1)
develop the volume elements for passenger/cargo cost allocations, (2) evaluate
fluctuations in volume of scheduled and charter services, (3) assess the competitive
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impact of different operations such as charter versus scheduled, (4) calculate load factors
by aircraft type, and (5) monitor traffic in specific markets.
FOREIGN AIR CARRIERS APPLICATIONS
Foreign air carriers are required to submit applications for authority to operate to the
United States. In reviewing these applications the Department must find that the
requested authority is encompassed in a bilateral agreement, other intergovernmental
understanding, or that granting the application is in the public interest. In the latter cases,
T-100 data are used in assessing the level of benefits that carriers of the applicant’s
homeland presently are receiving from their U.S. operations. These benefits are
compared and balanced against the benefits U.S. carriers receive from their operations to
the applicant’s homeland.
AIR CARRIER FITNESS
The Department determines whether U.S. air carriers are and continue to be fit, willing
and able to conduct air service operations without undue risk to passengers and shippers.
The Department monitors a carrier’s load factor, operational, and enplanement data to
compare with other carriers with similar operating characteristics. Carriers that expand
operations are at a high rate are monitored more closely for safety reasons.
INTERNATIONAL CIVIL AVIATION ORGANIZATION
Pursuant to an international agreement, the United States is obligated to report certain air
carrier data to the International Civil Aviation Organization (ICAO). The traffic data
supplied to ICAO are extracted from the U.S. air carriers’ Schedule T-100 submissions.
3. Describe whether, and to what extent, the collection of information involves the use
of automated, electronic, mechanical, or other technological collection techniques or
other forms of information technology, e.g. permitting electronic submissions of
responses, and the basis for the decision for adopting this means of collection. Also,
describe any consideration of using information technology to reduce burden.
The T-100 traffic reporting system is in compliance with the Government Paperwork
Elimination Act. The reporting system was designed to take advantage of automated data
processing. Carriers are required to submit data over a secure internet connection.
Also, by taking advantage of information technology, BTS has eliminated the
supplemental Schedules T-1, T-2 and T-3.
4. Describe efforts to identify duplication. Show specifically why similar information
already available cannot be used or modified for use for the purposes described in
Item 2 above.
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During its original review of the Department’s requirements for T-100 and T-100(f), we
were unable to identify any viable alternative data sources. There were no alternative
domestic data sources. The Department investigated the possible use of alternative
international data sources to determine whether the information contributed by member
carriers of the International Air Transport Association and the data collections of ICAO
could be used by the Department, in whole or in part, in lieu of the T-100 system. We
compared these potential alternatives with our data needs in areas of content, frequency,
coverage and timeliness. The alternative data sources failed to meet DOT needs of
consistent, timely and accurate data. Originally, DOT did use private data sources to
generate the capacity data elements for foreign air carriers operations. However, this
method proved unsatisfactory because special operating conditions (such as weather and
length of trip) can impact available capacity. The data became inconsistent, nonuniform
and skewed at best. Foreign air carriers currently report their own capacity data.
5. If the collection of information impacts small businesses or other small entities,
describe efforts to minimize burden.
Small certificated and commuter air carriers submit data in the T-100 reporting system.
Most of these carriers have taken advantage of IT to reduce their reporting burden.
6. Describe the consequence to the Federal Program or policy activities if the
collection were not collected or conducted less frequently.
Less frequent data collection would seriously erode DOT’s ability to monitor the
condition of the air transport industry. The timeliness and frequency of data collection
are critical in evaluating trends as well as monitoring individual carrier operations. The
filing frequencies were chosen after careful analysis which balanced the degree of
reporting burden against DOT’s need for current data to oversee the air transportation
industry.
7. Explain any special circumstances that would cause an information collection to
be conducted in a manner:
·

requiring respondents to report information to the agency more often than
quarterly;

·

requiring respondents to prepare a written response to a collection of information
in fewer than 30 days after receipt of it;

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·

requiring respondents to submit more than an original and two copies of any
document;

·

requiring respondents to retain records, other than health, government contracts,
grant-in-aid, or tax records for more than 3 years;

·

in connection with a statistical survey, that is not designed to produce valid and
reliable results that can be generalized to the universe of study;

·

requiring the use of statistical data classification that has not been reviewed and
approved by OMB;

·

that includes a pledge of confidentiality that is not supported by authority
established in statute or regulation, that is not supported by disclosure and data
security policies that are consistent with the pledge, or which unnecessarily
impedes sharing of data with other agencies for compatible confidential use; or

·

requiring respondents to submit proprietary trade secrets, or other confidential
information unless the agency can demonstrate that it has instituted procedures to
protect the information’s confidentiality to the extent permitted by law.

T-100 data are required to be submitted monthly. These collections are necessary to enable
DOT to adequately monitor individual carrier and industry performance in the competitive
marketplace. Quarterly data submissions obscure monthly trends that would permit a timely
assessment of the impact of management decisions on individual carrier operations. Monthly
reporting allows DOT to keep abreast of rapid changes taking place within the air
transportation industry. Please see Mail Rates, Essential Air Service, and Air Carrier Fitness
under Item 2 – uses of the data.
8. If applicable, provide a copy and identify the date and page number of publication in
the Federal Register of the Agency’s notice, required by 5 CFR 1320.8(d) soliciting
comments on the information collection prior to submission to OMB. Summarize public
comments received in response to the notice and describe actions taken by the agency in
response to these comments.
A 60-day’s notice was published in the Federal Register on February 11, 2020, 82 FR
14800 and a 30-day’s notice was published in the Federal Register on June 05, 2020, 82
FR 26567.
9. Explain any decision to provide any payment or gift to respondents, other than re7

enumeration of contractors or grantees.
No payment or gift of any kind is being made to any respondents.
10. Describe any assurances of confidentiality provided to respondents.
Pursuant to 14 CFR Section 241.19-6 (b) U.S. - international on-flight market and nonstop
segment data are confidential for 6 months and all U.S. air carrier foreign-to-foreign on-flight
market and nonstop data are confidential for 3 years, although the Department may publish
summary data when there are three or more carriers accounted for in the summary. Further,
the Department may release nonstop segment and on-flight market data by carrier before the
end of the confidential periods as follows:
(1) To foreign governments as provided in reciprocal arrangements between the
foreign country and U.S. Government for exchange of on-flight market and/or nonstop
segment data submitted by air carriers of that foreign country and U.S. carriers serving that
foreign country;
(2) To parties to any proceeding before the Department as required by the
Administrative Law Judge or other decision-maker of the Department. Any data to which
access is granted pursuant to this provision may be introduced into evidence, subject to the
normal rules of admissibility of evidence.
(3) To agencies and other components of the U.S. Government for their internal use
only.
The data are stored and retrieved on a secure server and are segregated based on World Area
Codes within the data, which identify the countries that airports are located in.
11. Are there any questions of a sensitive nature?
There are no questions of a sensitive nature.
12. Provide estimates of reporting burden.
We estimate that the reporting burden for the entire T-100/T100f system will vary between 1
hour and 12 hours per month per air carrier depending upon the individual carrier with an
average of 6 hours per monthly response.

T100 Form:
Number of Respondents: 119
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Number of Annual responses 1428
Total Burden Per Response: 6 hours
Total Annual Burden: 8,568 hours
T100F Form:
Number of Respondents: 190
Number of Annual responses 2,280
Total Burden Per Response: 2 hours.
Total Annual Burden: 4,560 hours
We estimate an average salary of $20 per hour ($270,000 annually for industry) which we
consider a reasonable estimate for the salaries of the related reporting personnel. This was taken
from the Bureau of Labor Statistics (BLS) median wage scale for 43-3031 (bookkeeping
personnel).

13. Provide an estimate of cost to the respondents. Do not include the cost of any hour
burden shown in items 12 and 14. General estimates should not include purchase of
equipment or services or portions thereof made prior to October, 1995.
Since most of the data items of the T-100 System were already collected by all the
respondents, we estimate that they did not incur additional indirect, overhead or computerrelated operating costs.
14. Provide estimates of annualized cost to the Federal Government.
The editing and processing of T-100 and T-100(f) is done by Federal Government
Employees at an average hourly rate of $35.00 per hour multiplied by 2,080 hours (40 hour
week X 52 weeks in a year) for an estimated annual cost of $72,800. The computer and
publishing costs are estimated to be $12,000 annually. The allocated cost for T-100 data
presentation on BTS web is $100,000. The total annual cost is estimated to be $184,800.
15. Explain the reasons for any program changes or adjustments in Items 13 or 14 of
OMB 83-I.
The number of reporting carriers changed due to mergers and acquisitions.

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16. Is the information received published?
Extracts of the T-100 data are published accordingly:
Publication
Air Carrier Traffic Statistics - Monthly
Aircraft Activity Statistics - Annually

Time Line
60-days after month’s end
160-days after year’s end

Also, the information is available at
http://www.transtats.bts.gov/Tables.asp?DB_ID=111&DB_Name=Air%20Carrier%20S
tatistics%20%28Form%2041%20Traffic%29%20All%20Carriers&DB_Short_Name=Air%20Carriers
17. Is the agency seeking approval not to display the expiration date for OMB
approval?
We are not seeking approval to not display the OMB expiration date on the data.
18. Explain each exception to the Paperwork Reduction Act certification statements.
There are no exceptions.

MISSION STATEMENT
The Department of Transportation (DOT) relies on the T-100 traffic reporting system to
fulfill its strategic plan. The DOT monitors and studies the movement of aircraft and
passengers through the national air space system to ensure safe and efficient operations.
DOT is committed to guide and oversee America’s air transportation system today and
into the future by taking note of statistical trends that identify airport utilization.
DOT is committed to developing transportation policies and programs that contribute to
providing fast, safe, efficient and convenient transportation at the lowest cost. Traffic
data are used in assessing long-term air traffic control and airport development needs.
Air traffic delays cost the airline industry, air travelers and the government billions of
dollars each year. Economic growth prospers when the real economic cost of
transportation is reduced. DOT recognizes that the collection and dissemination of traffic
data are critical to identifying and solving air congestion problems. DOT performs an
essential role as a catalyst for improving the quality of decisions affecting the
transportation sector. In this role, DOT serves as a facilitator by providing better
information to both the public and private sectors. Five economic trends impact
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transportation. They are globalization of commerce, growing attention to logistics in the
production process, greater reliance on private investment in transportation industry and
the rise of competing and complementary technologies. There will be accelerated
application of advanced information technologies, competitive techniques, and traffic
flow information systems within the air transportation industry. These informationrelated technologies will enable collection, management, integration, and distribution of
more transportation information in less time with better accuracy and broader application
DOT’s information systems are being integrated into agency activities, especially a
coordinated effort by the Bureau of the Office of Secretary, the Federal Aviation
Administration, the Bureau of Transportation Statistics (BTS), and the Inspector General
Office to reduce airline delays. Enplanement, departures by aircraft type, and load factor
data are critical in planning for infrastructure needs.

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