Regulations Governing Air Passenger Rights during Periods of Airline Delay
HDR prepared a Regulatory Impact Analysis (RIA), in support of the 2009 Rulemaking on Enhanced Airline Passenger Protections. More commonly referred to as "The Passenger Bill of Rights" in the press, the regulation contains several provisions intended to improve minimum passenger comfort and increase fairness to consumers, including a highly publicized requirement for deplaning passengers on domestic flights who have been waiting on the tarmac for three hours. The RIA estimated the incremental costs and benefits against the current status of passenger rights accruing to passengers, air carriers and other entities regulated under this action, as required by Executive Order (EO) 12866 and as per OMB Circular A-4. The RIA also separately discussed estimates of the cost to small carriers to comply with the rule.
HDR drew from key tenets of transportation economic theory and utilized evidence-based findings on the value of traveler time and preferences, applying them in new ways. Cass R. Sunstein, Administrator of the Office of Management and Budget's Office of Information and Regulatory Affairs, has publicly praised this analysis, stating "In a rule protecting passengers from long delays on the tarmac, the Department of Transportation offered a rigorous, and highly quantitative, analysis of both costs and benefits."