Travelers United comments submitted to the docket for DOT rulemaking

Travelers United filed it comments with the Department of Transportation (DOT) Notice of Proposed Rulemaking (NPRM). The Transparency of Airline Ancillary Fees and Other Consumer Protection Issues — Docket: DOTOST20140056 –comments totals more than 80 pages and included in-depth discussions of the main rulemaking sections.

The Travelers United comments were joined by the National Consumers League.

Here are the Appendices A, B and C for the NPRM. These include an ancillary fee study by IdeaBank, a survey conducted by Open Allied for Airfare Transparency and Travelers United, another survey conducted by Travelers United in response to requests in the NPRM from DOT.

This is App A&B&C NPRM Comments Travelers United & NCL – Google Docs

Here is the link to Appendix D — a series of screenshots that show the lack of ancillary fee price transparency in today’s airlines website.

Here are the conclusions from the comments
For the reasons discussed above, Travelers United and NCL urge the Department to issue promptly a final rule in this proceeding that requires airlines to disclose to all ticket agents through which they choose to distribute their fare, schedule and availability information, including GDSs, OTAs, metasearch websites, corporate and brick-and-mortar travel agencies, dynamic and transactable information on all ancillary services.

The Department should issue a rule that at a minimum, carry-on baggage, first-checked baggage, second-checked baggage and seat reservation fees, be included in pricing displays. The Department should also mandate that all other passenger-specific, itinerary-specific ancillary fees be made available by the airlines to all ticket agents in an IT language format that can be used to create and publish booking/comparison-shopping/information platforms. This pricing data must include all ancillary fees and airline-created fee packages.

Travelers United and NCL also urge the Department to adopt its proposed rule to codify its broad interpretation of “ticket agent” to embrace intermediaries, including metasearch companies especially as it affects advertising of airline costs. However, Travelers United and NCL recommend the creation of a “firewall” between activities of large entities that involve other functions such as search, advertising, user reviews and information publication from the airline purchasing and comparison shopping process.

Travelers United and NCL does not find a need for a ticket agent customer standards other than requiring that ticket agents insure that current requirements for airline ticket refunds, 24-hour holds of prices and itineraries, as well as others mandated by DOT, be guaranteed by ticket agents to customers as they are required for airline travelers.

Travelers United and NCL does not feel that there is a workable and effective way to disclose carriers marketed on websites. This is a matter for education and any DOT mandate may create consumer harm as it seeks to notify consumers of the marketed-carrier limitations of search on various ticket agent web platforms.

Travelers United and NCL support both the disclosure of all ancillary fee pricing data and the removal of any restrictions on this data and our organization fully supports transactability of all prices and fees associated with the purchase of airline transportation. If transactability is mandated as a part of this rulemaking, requirements forbidding post-purchase price increases for fees will become moot.

Travelers United and NCL strongly support DOT proposals regarding code-share reporting on partner airlines and changes proposed on tracking mishandled baggage; website disclosure of code-share services; amendments to CFR Part 257; and, prohibition of undisclosed bias.