3301 PR.03 Air Travel on University Business

Revision Date: 
April 20, 2021

Contents

1.      Overview

2.      Fundamentals of Air Travel Reservations

3.      Non-Economy Class Air Travel

4.      Frequent Flyer Programs, Personal Upgrades, and Personal Travel

5.      Air Travel on Sponsored Awards: General Principles

6.      Air Travel on Federally Sponsored Awards: Fly America Act

1. Overview

This procedure supports Policy 3301 Travel on University Business, specifically the air travel rules and requirements established in Section 3301.2.  It details the processes and guidelines relating to air travel on University business.

2. Fundamentals of Air Travel Reservations

Travelers (or their designees) conducting Yale business are encouraged to plan their travel as far in advance as possible, as the availability of lower air fares is generally greater when reservations are booked well in advance.  While the optimal booking time may vary by airline and destination, the effective practice is to book travel as far in advance as possible when plans become firm.  Note: travel on sponsored awards may be governed by different requirements.  In such instances, travelers and their designees are expected to comply with the sponsor’s (federal or non-federal) terms and conditions. 

Travelers (or their designees) are expected to select the least expensive airfare within the main cabin class (e.g., economy, coach) that is consistent with business requirements.  The University acknowledges that commercial airlines vary in their ticketing structures and do not necessarily offer consistent services in single fares.  Therefore, Yale considers “the least expensive airfare within the main cabin class (e.g., economy, coach) that is consistent with business requirements” to include the following:

  • Seat selection; and
  • Checked luggage.

Travelers (or their designees) who select a commercial airline whose economy or economy-equivalent fare includes less than the above list may purchase available upgrades within the airline’s economy or economy-equivalent class to obtain services substantially similar to the above list.  In addition, travelers (or their designees) may purchase the following items/services if they are not included in the airfare price:

  • Snacks;
  • Non-alcoholic drinks;
  • Internet access/Wi-Fi (not allowable on federally sponsored awards);
  • Pillows and blankets (not allowable on federally sponsored awards); and
  • Preferred seating within the economy or economy-equivalent class (not allowable on federally sponsored awards).

Travelers may also purchase meals and alcoholic drinks (alcohol is not allowable on federally sponsored awards) if they are not included in the airfare price, but travelers (or their designees) are expected to include such purchases as one of their allowable travel meals (see Procedure 3301 PR.01 Travel Arrangements for University Business).

A. Preferred Travel Supplier and Online Booking Tool

Travelers (or their designees) are not required, but they are encouraged, to book air travel using the University’s preferred travel supplier, Egencia.  It provides a number of services and allows travelers to take advantage of University-negotiated discounts. 

B. Charter and/or Private Aircraft

For the safety of travelers, the University does not recommend flying on charter and/or private aircraft.  The University assumes no liability for death, personal injury, or property damage in connection with charter/private aircraft travel.

If a traveler finds it necessary to travel by private aircraft due to unusual circumstances, exceptions for such circumstances require prior approval, consistent with the Exceptions and Special Circumstances section of Policy 3301 Travel on University Business.  If the exception is granted, the traveler (or their designee) must notify the Office of Enterprise Risk Management before the flight occurs for insurance purposes.  When a private plane or charter aircraft is used primarily for the convenience of the traveler, reimbursement/payment will not exceed the least expensive airfare within the main cabin class (e.g., economy, coach) that is consistent with business requirements for a comparable trip.

C. Airline Club Memberships

The University does not pay dues or fees for a traveler’s membership in airline clubs.

D. Changes and Cancellations

Travelers and their designees should endeavor to avoid change and cancellation fees whenever possible.  In the event a traveler incurs a change or cancellation penalty:

  • Penalties for changes to an airline ticket for business reasons or circumstances beyond the traveler’s control will be reimbursed.  Note: In general, airlines require that a ticket is changed or cancelled prior to flight departure to retain its value.  (Refer to subsection 5.A., below, for additional guidance on sponsored awards.)
  • When applicable, the remaining value of the ticket (less any airline-imposed penalties) should be applied to the next appropriate business trip.  Unused tickets cannot be used for personal travel.
  • Travelers will not be reimbursed for trips cancelled, changed, or forfeited (due to failure to cancel prior to departure) for personal convenience.

E. Required Documentation

Travelers (or their designees) are expected to provide documentation via an expense report for all air travel on University business (see Procedure 3215 PR.02 Yale Expense Management (PCard and Out-of-Pocket Expenses) for details on expense reports).  This documentation includes the following, at a minimum:

  • Receipt showing traveler name, flight details (including airfare class), pricing, and payment;
  • Valid business purpose for the expense.  A valid business purpose should describe enough detail to allow an approver and any subsequent reviewer to validate the need for the expense; and
  • Any additional supporting documentation required by the sections below.   

3. Non-Economy Class Air Travel

Travelers on University business are not permitted to use first class for air travel.  Travelers may, however, use business class for air travel if the relevant business office confirms before purchase that appropriate funds are available and if any of the following conditions are met:

  • Any single flight segment has a scheduled in-air flying time in excess of five (5) hours;
  • The total scheduled in-air flight time, including connecting legs, is in excess of eight (8) hours; or
  • A medical justification exists, documented in writing by a primary care provider.

Students must travel economy or economy-equivalent class regardless of duration or length of the flight.  Business class is permitted for students, however, for medical justifications documented in writing by a primary care provider.

In rare cases, other extenuating circumstances may justify the use of business class for trips that do not meet the above conditions.  Exceptions for such circumstances require prior approval, consistent with the Exceptions and Special Circumstances section of Policy 3301 Travel on University Business.

Note: For travel expenses that are administered by Yale but will be reimbursed in full by a third party, business class travel is allowable if approved and documented by the sponsoring institution/entity and documented in the expense report.

A. Documentation of Approved Business Class Air Travel

If a traveler is allowed to fly business class, the traveler (or their designee) must determine and document the cost of business class that exceeds the least expensive airfare within the main cabin class (e.g., economy, coach) that is consistent with business requirements for a comparable trip.  The traveler (or their designee) is also responsible for charging that excess cost differential using appropriate charging instructions (see Accounting for Air Travel Expenses), consistent with the following:

  • In general, the excess cost differential cannot be charged to a federally sponsored award.  Federal regulations require only the basic least expensive unrestricted accommodations class offered by commercial airlines be charged to a federal sponsored award.
  • The excess cost differential may be charged to a federally sponsored award only when the basic least expensive unrestricted accommodations class offered by commercial airlines is not reasonably adequate for the traveler’s medical needs (i.e., a medical justification exists, documented in writing by a primary care provider).

The traveler (or their designee) is responsible for documenting the cost of business class that exceeds the least expensive airfare within the main cabin class (e.g., economy, coach) that is consistent with business requirements for a comparable trip for all University travel, regardless of the charging instructions used.  To do so, the traveler (or their designee) is expected to attach documentation to the applicable expense report showing an airfare comparison from a travel service (e.g., Egencia, Sanditz, Travelocity, Orbitz, Expedia) contemporaneous with the business class booking.

  • Example: Traveler is allowed to fly business class between cities A and B for date Z.  Traveler (or their designee) books this business class flight for $1,000 (“Business Flight”).  Contemporaneous with when traveler (or their designee) books business class for this flight, traveler (or their designee) is expected to also search a travel service for flights between cities A and B for date Z.  The travel service shows the least expensive airfare within the main cabin class (e.g., economy, coach) that is consistent with business requirements priced at $700 (“Economy Flight”).  Traveler (or their designee) takes the following actions:
    • Maintains documentation showing the flight details and pricing for both the Business Flight and the Economy Flight (this includes a screenshot showing the search parameters, any search filters, and the date and time of the screenshot);
    • Calculates the excess cost differential between the Business Flight and Economy Flight at $300; and
    • Attaches documentation to the applicable expense report and provides appropriate charging instructions for the price of the Economy Flight ($700) and the excess cost differential ($300). 

4. Frequent Flier Programs, Personal Upgrades, and Personal Travel

A. Frequent Flyer Programs

The University allows travelers to accrue their own frequent flyer mileage for trips taken on University business.  The University does not, however, reimburse travelers for tickets or upgrades purchased with frequent flyer miles or other reward points.

B. Personal Upgrades

Travelers may upgrade the level of air service at personal expense or by using their frequent flyer miles or other reward points.  In opting to do so, travelers (or their designees) must document the source of the upgrade on the applicable expense report and must cover the excess cost differential between the purchased ticket and the least expensive airfare within the main cabin class (e.g., economy, coach) that is consistent with business requirements.  To do so, the traveler (or their designee) is expected to attach documentation to the applicable expense report showing an airfare comparison from a travel service (e.g., Egencia, Sanditz, Travelocity, Orbitz, Expedia) contemporaneous with the booking.

  • Example: Traveler is flying for University business between cities C and D for date Y.  Traveler (or their designee) searches a travel service, which shows the least expensive airfare within the main cabin class (e.g., economy, coach) that is consistent with business requirements priced at $500 (“Economy Flight”).  Traveler (or their designee) books this flight and then opts to upgrade to business class using their personal frequent flyer miles (“Upgrade Flight”).  Traveler (or their designee) takes the following actions:
    • Maintains documentation showing the flight details and pricing for both the Upgrade Flight and the Economy Flight (this includes a screenshot showing the search parameters, any search filters, and the date and time of the screenshot); and
    • Attaches documentation to the applicable expense report and provides appropriate charging instructions for the price of the Economy Flight ($500) and an explanation as to the source of the upgrade to business class (i.e., personal frequent flyer miles).

C. Personal Travel Combined with Business Travel

Whenever possible, personal expenses should be charged separately when making travel arrangements.  If part of the business trip is personal/leisure and requires extra bags (e.g., golf clubs), the cost of the extra bags is personal.

If a travel itinerary is structured to accommodate personal business or leisure, the traveler must pay the incremental cost of personal travel and document the costs incurred, separating personal expenses from University business expenses.  To do so, the traveler (or their designee) is expected to attach documentation to the applicable expense report showing an airfare comparison from a travel service (e.g., Egencia, Sanditz, Travelocity, Orbitz, Expedia) contemporaneous with the booking.  The cost of the University business component needs to be clearly differentiated from the cost of the personal component, as demonstrated by the examples below: 

  • Example 1: Traveler is flying for University business between cities E and F for dates W through X.  Traveler (or their designee) searches a travel service, which shows the least expensive airfare within the main cabin class (e.g., economy, coach) that is consistent with business requirements priced at $600 (“University Flight”).  Traveler (or their designee) chooses, for traveler’s personal reasons, to extend the trip for two days at the beginning, changing the start date to V rather than W.  To accommodate this change, traveler (or their designee) books a flight between cities E and F for dates V through X for $800 (“Personal Flight”).  Traveler (or their designee) takes the following actions:
    • Maintains documentation showing the flight details and pricing for both the University Flight and the Personal Flight (this includes a screenshot showing the search parameters, any search filters, and the date and time of the screenshot);
    • Calculates the excess cost differential between the Personal Flight and University Flight at $200; and
    • Attaches documentation to the applicable expense report and provides appropriate charging instructions for the price of the University Flight ($600) and an explanation that the excess cost differential was to accommodate personal travel.  The $200 excess cost differential is a personal expense for the traveler.
  • Example 2: Traveler is flying for University business between cities G and H for dates T through U.  Traveler (or their designee) searches a travel service, which shows the least expensive airfare within the main cabin class (e.g., economy, coach) that is consistent with business requirements priced at $700 (“University Flight”).  Traveler (or their designee) chooses, for traveler’s personal reasons, to add a third city, I, to the trip.  To accommodate this change, traveler (or their designee) books a flight package with legs between cities G and H, H and I, and I and G for $1,100 (“Personal Flight”).  Traveler (or their designee) takes the following actions:
    • Maintains documentation showing the flight details and pricing for both the University Flight and the Personal Flight (this includes a screenshot showing the search parameters, any search filters, and the date and time of the screenshot);
    • Calculates the excess cost differential between the Personal Flight and University Flight at $400; and
    • Attaches documentation to the applicable expense report and provides appropriate charging instructions for the price of the University Flight ($700) and an explanation that the excess cost differential was to accommodate personal travel.  The $400 excess cost differential is a personal expense for the traveler.
  • Example 3: Traveler is flying for University business between cities J and K for dates R through S.  Traveler (or their designee) searches a travel service, which shows the least expensive airfare within the main cabin class (e.g., economy, coach) that is consistent with business requirements priced at $900 (“University Flight”).  Traveler (or their designee) chooses, for traveler’s personal reasons, to add a third city, L, to the trip.  To accommodate this change, traveler (or their designee) books a flight package with legs between cities J and K, K and L, and L and J, which turns out to be less expensive at $800 (“Personal Flight”).  Traveler (or their designee) takes the following actions:
    • Maintains documentation showing the flight details and pricing for both the University Flight and the Personal Flight (this includes a screenshot showing the search parameters, any search filters, and the date and time of the screenshot); and
    • Attaches documentation to the applicable expense report and provides appropriate charging instructions for the price of the less expensive Personal Flight ($800) and an explanation that the Personal Flight is less expensive than the University Flight, even though it accommodates personal travel.  The full $800 price is considered a valid Yale business expense and is covered.

5. Air Travel on Sponsored Awards: General Principles

Travel charged to sponsored awards is subject to specific limitations and restrictions set by the sponsor(s) and, if applicable, federal regulations.  Travel restrictions may vary between federal and non-federal sponsors.  Additional restrictions not specifically covered by this policy, but sponsor specific, may apply.  Address questions to your award manager in the Office of Sponsored Projects (“OSP”).

Certain expenditures (e.g., alcohol) are “unallowable” in accordance with federal cost principles and cannot be charged to a federal award or non-federal award, depending on the terms and conditions of the award.  Some expenses not allowed on a sponsored award may, however, be reimbursed by non-sponsored funds under specific circumstances if the expense is reasonable, adheres to University policy, is broken out separately from the allowable expense(s), and is coded to the proper account number listed in the University’s Chart of Accounts.  For additional information and proper use of ledger accounts and spend categories, refer to Procedure 1305 PR.04 Unallowable Costs.

A. Changes and Cancellations

Changes and cancellations, in general, are covered in Section 2, above.  In addition to that guidance, the following applies to air travel on sponsored awards:

  • If air travel is charged to a sponsored award and subsequently cancelled or otherwise not used, the traveler (or their designee) is responsible for removing the charge from the sponsored award (i.e., crediting the sponsored award) and moving the charge to appropriate, non-sponsored charging instructions.

B. Air Travel on a Federally Sponsored Award: Airfare Pricing Principles and Documentation

Travelers (or their designees) on federally sponsored awards and subawards are expected to use the basic least expensive unrestricted accommodations class (e.g., economy, coach) offered by commercial airlines, consistent with business requirements.  The University acknowledges that commercial airlines vary in their ticketing structures and do not necessarily offer consistent services in single fares.  Therefore, Yale considers “unrestricted accommodations” to include the following:

  • Seat selection;
  • Checked luggage; and
  • Refundable fare.

Travelers (or their designees) who select a commercial airline whose economy or economy-equivalent fare includes less than the above list of accommodations may purchase available upgrades in accordance with Section 2, above.

Travelers (or their designees) on federally sponsored awards and subawards are expected to document their selection of the basic least expensive unrestricted accommodations class (e.g., economy, coach) offered by commercial airlines, consistent with business requirements, by including an airfare comparison from a travel service (e.g., Egencia, Sanditz, Travelocity, Orbitz, Expedia) contemporaneous with the booking.

  • Example: Traveler (or their designee) searches a travel service for flights between cities M and N for date Q.  The travel service shows the basic least expensive unrestricted accommodations class airfare, consistent with business requirements, priced at $400.  Traveler (or their designee) takes the following actions:
    • Maintains documentation showing the flight details and pricing for the $400 flight and the comparison flights (this includes a screenshot showing the search parameters, any search filters, the date and time of the screenshot, and at least three comparison flights (if available));
    • Selects and books the $400 flight; and
    • Attaches the documentation to the applicable expense report and provides appropriate charging instructions.

C. Air Travel on a Federally Sponsored Award: Selecting Less Expensive Airfare

Travelers (or their designees) may select airfare that is less expensive than the basic least expensive unrestricted accommodations class (e.g., economy, coach) offered by commercial airlines, consistent with business requirements (i.e., airfare that does not include seat selection, checked luggage, and/or refundable fare) (this does NOT include business class unless otherwise permitted under Section 3, above).  When doing so, travelers (or their designees) are still expected to document the basic least expensive unrestricted accommodations class (e.g., economy, coach) offered by commercial airlines, consistent with business requirements, by including an airfare comparison from a travel service (e.g., Egencia, Sanditz, Travelocity, Orbitz, Expedia) contemporaneous with the booking.  Travelers (or their designees) selecting less expensive airfare may purchase upgrades so long as the total combined price of airfare and upgrades does not exceed the basic least expensive unrestricted accommodations class (e.g., economy, coach) offered by commercial airlines, consistent with business requirements.  Note: If the traveler (or their designee) selects non-refundable airfare and the flight is not taken, the traveler (or their designee) is responsible for ensuring the charge is removed from the sponsored award.  Departmental or non-sponsored funds may be used to cover such charges.

  • Example: Traveler (or their designee) searches a travel service for flights between cities AA and BB for date ZZ.  The travel service shows the basic least expensive unrestricted accommodations class airfare, consistent with business requirements, priced at $900 (“Baseline Flight”).  Traveler (or their designee) instead opts to select a non-refundable airfare between cities CC and DD for date YY for $700 (“Alternate Flight”).  Traveler (or their designee) takes the following actions:
    • Maintains documentation showing the flight details and pricing for both the Baseline Flight and the Alternate Flight (this includes a screenshot showing the search parameters, any search filters, the date and time of the screenshot, and at least three comparison flights (if available));
    • Calculates the cost differential between the Baseline Flight and Alternate Flight at $200 (traveler may purchase upgrades to Alternate Flight up to this $200); and
    • Attaches documentation to the applicable expense report and provides appropriate charging instructions for the price of the Alternate Flight ($700) and any purchased upgrades.

D. Air Travel on a Federally Sponsored Award: Other Applicable Rules

In addition to the specific rules discussed in the sections above, the following rules, organized by subject matter, apply to air travel on federally sponsored awards and subawards:

  • Non-economy class air travel – see Section 3, above; and
  • Personal upgrades and personal travel – see Section 4, above.

Note: for all of the circumstances enumerated above, the baseline comparison airfare is the basic least expensive unrestricted accommodations class (e.g., economy, coach) offered by commercial airlines, consistent with business requirements, and NOT the least expensive airfare within the main cabin class (e.g., economy, coach) that is consistent with business requirements, which applies to air travel other than that on federally sponsored awards and subawards.

6. Air Travel on Federally Sponsored Awards: Fly America Act

Travelers (or their designees) on University business funded by a federal award must comply with the requirements of 2 CFR Part 200 and are required by 49 U.S.C. 40118, commonly referred to as the “Fly America Act,” to use United States air carrier service for all air travel and cargo transportation services funded by the United States Government.  Accordingly, it is the responsibility of the traveler (or their designee) and their departmental business office to:

  • Identify the source(s) of funds supporting the travel, determine the methodology of expense allocation, and determine whether one or more allocated source is a federally sponsored award;
  • Review the terms and conditions of the applicable award notice, award document, program announcement, and/or sponsor specific requirements to determine if any travel restrictions apply prior to making any travel arrangements; and
  • Book air travel in accordance with this procedure, any applicable travel restrictions, and the Fly America Act or Open Skies Agreement (see below).

Federal regulations (i.e., the Fly America Act) require that federally funded domestic awardees use U.S. flag air carriers when traveling between the U.S. and an international destination, between domestic destinations, or between international destinations to the maximum extent possible.

Any air transportation to, from, between, or within a country other than the U.S. of persons or property paid for from U.S. federal funds must be performed by or under a code-sharing arrangement with a U.S. flag air carrier if service provided by such carrier is available.  Tickets or documentation for electronic tickets must identify the U.S. flag air carrier’s designator code and flight number.

For purposes of this requirement, a U.S. flag air carrier service is considered available even though:

  • A comparable or a different kind of service can be provided at less cost by a foreign flag air carrier; or
  • A foreign flag air carrier service is preferred or more convenient.

Exceptions to the Fly America Act are permitted when one or more of the following conditions exist at the time travel reservations are made: 

  • A U.S. flag air carrier is not available.
  • The use of a U.S. flag air carrier would extend travel time, including delay at origin, by 24 hours or more.
  • A U.S. flag air carrier does not offer non-stop or direct service between origin and destination and would:
    • Increase the number of aircraft changes outside the U.S. by two or more;
    • Extend travel time by at least six hours or more; or
    • Require a connection time of four hours or more at an overseas interchange point.
  • For short distance travel, when both of the following two conditions are met:
    • The elapsed time between origin and destination by a foreign carrier is three hours or fewer; and
    • The use of a U.S. flag air carrier would double the time en-route.
  • An applicable Open Skies Agreement is in place.  This exception only exists if an Open Skies Agreement for passenger travel is in place between the U.S. government and the government of a foreign country.  Under this exception, the use of a non-U.S. flag air carrier is permitted when the airline is a member state carrier, transportation is between the U.S. and any point in the member state, or transportation is between two points outside the U.S.  The current Open Skies Agreements are listed below:
    • United States (U.S.) Government and the European Union (EU) (including Norway and Iceland), effective April 30, 2007; U.S.-EU Amendment, effective June 24, 2010; and U.S.-EU Amendment, effective June 21, 2011.
    • United States (U.S.) and Australia, effective October 1, 2008.  Requires city pair verification.
    • United States (U.S.) and Switzerland, effective October 1, 2008.  Requires city pair verification.
    • United States (U.S.) and Japan, effective October 1, 2011.  Requires city pair verification.
  • Current restrictions and limitations on Open Skies Agreements:
    • Current Open Skies agreements do not apply to Department of Defense (“DOD”) funds (i.e., exceptions to the Fly America Act are not permitted on DOD awards).  Therefore, only U.S. flag air carriers are applicable for DOD awards.
    • Use of Australia, Switzerland, and Japan member state air carriers require a city pair verification prior to booking travel on the air carrier.  Open Skies Agreements allow the use of a non-U.S. flag air carrier when that airline is a member state carrier (i.e., Qantas, Swiss Air, and Japan Airlines), and a city pair fare does not exist between the U.S. city of origin and the destination city within the member state.  City pair fares can be verified using GSA Airline City Pairs.

A. Fly America Act Exception Documentation

According to the U.S. General Services Administration (“GSA”), exceptions to the Fly America Act must be documented.  Specifically, to document a Fly America exception or waiver, including under an Open Sky Agreement, you must include the following information as attachments to the applicable expense report:

1. A completed and signed Form 3301 FR.06 Documentation for Travel on a Non-U.S. Air Carrier;

2. A detailed travel itinerary from a travel agent or online travel service (e.g., Egencia, Sanditz, Travelocity, Orbitz, Expedia); and

3. The search results performed at the time of booking from an online travel service that document all available flights and the existence of the Fly America exception identified on the Fly America exception form, if applicable.

Note: For those rare situations when a booking from a travel agent or online travel service with accompanying search results is not possible, please provide a detailed explanation as to why the information for items 2. and 3., above, is not being provided in addition to providing Form 3301 FR.06 Documentation for Travel on a Non-U.S. Air Carrier.  Consideration will be given to the circumstances described by the traveler (or their designee), but an exception to the documentation requirement is not guaranteed.

Travelers (or their designees) must not charge airfare without the required supporting documentation to a federally sponsored award, unless a documentation exception has been approved per the above note.  Failure to complete and attach all proper documentation (including an approved exception, if applicable) will result in removal of the applicable charge(s) from sponsored awards.

For additional guidance and assistance with the Fly America Act and Open Skies Agreements, refer to the matrix below:

Fly America Act

Airline Travel (origin & destination)

U.S. Flag Air Carrier

Open Skies (Member States)

Required

Exception Permitted

Allows for Use of EU Carrier

Requires City Pair Check to Use These Countries’ Air Carriers

Australia

Switzerland

Japan

Domestic (U.S.-U.S.)

Y

n/a

N

DOD-Funded Awards

Y

n/a

N

Intl (U.S.-EU)

N

Y

Y

N

Intl (within EU)

N

Y

Y

N

Intl (U.S.-Non EU Countries)* N Y Y N      

A city pair check is required between any point in the U.S. to any point in an Open Sky (non-EU) Member State.  If search results provide a contracted rate, U.S. carrier is required.

Intl (U.S.-Australia)

N

Y

Y

Y

If no city pair - Y

Intl (U.S.-Switzerland)

N

Y

Y

Y

If no city pair - Y

Intl (U.S.-Japan)

N

Y

Y

Y

If no city pair - Y

Intl (within other countries)**

N

Y

Y

N

Y

Y

Y

No city pair check required when travel is with a Member State carrier between any two points outside U.S.

* If travel is on a EU air carrier then the point of origin, destination or layover must be in one of the EU Open Skies Member States.  If travel is on an air carrier from Australia, Switzerland or Japan then point of origin or destination must be in Australia, Switzerland or Japan.

** If travel is on a EU air carrier then the point of origin, destination or layover must be in one of the EU Open Skies Member States.  Air carriers from Australia, Switzerland may be used for travel between two points outside of the U.S.