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“Enhancing Airline Passenger Protections”
Jonathon Robert Nield
Graduate Program of Aviation Management & Human Factors
Arizona State University
Introduction
The seemingly insurmountable challenges presented to the airline
industry by the
Deregulation Act of 1974 have caused the demise of hundreds of
US airlines over the
past thirty years, and to this day, it continues to relentlessly
beat the financials of the
entire industry. The giants of the golden age of the airlines,
including PanAm, TWA,
Eastern, Braniff, People Express and so many more are now just a
footnote in the
tumultuous history of the airlines. A few of the legacy carriers
have survived, but they
are lagging behind the sustained profitability low cost carriers
(LCC) such as Southwest,
JetBlue, and Allegiant that have enjoyed financial success in
their relatively short, post
deregulation histories. The building financial pressures have
some visible factors,
such as rising fuel costs contributing to 23.8% in Q3 2009 of
costs to the industry and
labor which contributed 24.9% to costs in the same period.
Although the significance of
these threats should not be dismissed, a new threat is rearing
its head in recent months
that will bring about new hurdles and costs to overcome. As the
public's perception of
the airlines continues to deteriorate, the federal government
has taken an interest in
providing consumer protections in this highly visible industry.
On November 15, 2007,
the Department of Transportation issued an Advance Notice of
Proposed Rule Making
(ANPRM) in Docket DOT-OST-2007-22 titled "Enhancing Airlines
Passenger
Protections." This new rule is part of the Federal Aviation
Administration's Air
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Transportation Modernization and Safety Improvement Act.
Although this new rule is
meant to improve the passengers' experiences and turn around the
industry's downhill
battle of perception, a deeper analysis shows the rule may be
counterproductive in its
very purpose.
Summary
ANPRM Enhancing Airline Passenger Protections was drafted to
address the
following perceived issues by the Department of Transportation
(DOT):
1. Tarmac delays and the communication of contingency plans if
incidents of delay
occur,
2. Poor response of air carriers in dealing with consumer
problems and complaints,
3. Chronically delayed flights that are deceptive and unfair in
violation of 49 U.S.C.
41712,
4. Need for flight delay information on carriers' websites,
5. Lack of customer service plans and/or compliance thereof.
Background
The "Enhancing Airline Passenger Protections" rule was proposed
in response to
multiple instances in which airlines were arguably acting
grossly outside the parameters
of consumer interest and prompted regulators to define the
parameters airline should
operate in terms of consumer interests. Some of the more notable
events include the
Virgin America Flight 404 that was delayed on the tarmac for
sixteen hours and the
multiple JetBlue flights that were delayed on the tarmac at JFK
for over ten hours on
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February 14, 2007. According to the ANPRM, passengers were also
being increasingly
"harmed" by a growing number of "less extreme flight delays."
The DOT recognized that
some of the factors of a tarmac delay are out of the control of
the airlines, such as
weather, Air Traffic Control congestion, and operations
constraints. The DOT states that
under their authority and responsibility of 49 U.S.C. 41712 as
well as 49 U.S.C.
40101(a)(4), 40101(a)(9), and 41702, the DOT needs to protect
consumers from unfair
and deceptive practices which lays the foundation for the
"Enhancing Airline Passenger
Protections" rule.
Process
After the release of the ANPRM on Enhancing Airline Passenger
Protections, the
DOT received approximately 200 comments in response. Thirteen of
these were from
members of the industry while the rest came from consumers,
consumer associations,
and two US senators. On December 8, 2008, the DOT issued the
Notice of Proposed
Rulemaking (NPRM) which was slimmed down to include the
following topics:
1. Contingency plans for lengthy tarmac delays,
2. Carriers' response to consumer problems,
3. Chronically delayed flights,
4. Reporting flight delay information,
5. Customer service plans.
The DOT received 21 comments on the NPRM, of which ten were from
the industry
while the rest were from consumers and consumer organizations.
Three consumer
advocacy organizations commented on the NPRM which were
Flyersrights.org, the
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Aviation Consumer Action Project (ACAP), and the Federation of
State Public Interest
Research Groups (U.S. PIRG). The industry commentators were US
Airways,
ExpressJet, Dallas-Fort Worth International Airport, the City of
Atlanta Department of
Aviation, National Business Travel Association (NBTA), the Air
Transport Association of
America (ATA), the Regional Airline Association (RAA), the
American Society of Travel
Agents (ASTA), the Interactive Travel Services Association
(ITSA) and the Airports
Council International, North America (ACI-NA). These
organizations were then engaged
to provide commentary on each individual topic below for
consideration in the final rule:
1. Review and approval of contingency plans for lengthy tarmac
delays
2. Reporting of tarmac delay data
3. Standards for customer service plans
4. Notification to passengers of flight status changes
5. Inflation adjustment for denied boarding compensation
6. Alternative transportation for passengers on canceled
flights
7. Opt-out provisions where certain services are pre-selected
for consumers at
additional costs
8. Contract of carriage venue designation provisions
9. Baggage fees disclosure
10. Full fare advertising
11. Responses to complaints about charter service
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General Responses
The general consensus of the consumer driven organizations
stated that the
DOT was not proposing regulation that would go far enough to
protect passengers'
rights and that additional measures would be needed. The
carriers and their
associations maintained that the proposals were "unnecessary and
unduly
burdensome." The ATA stated that changes would be best made by
addressing the air
traffic control capacity and weather related issues. The airport
authorities supported the
idea of a contingency plan to be coordinated with the medium and
large hub airports.
Travel agent associations gave support to the proposed rule, but
were concerned with
being mandated to implement changes without funding on issues
for which they are not
responsible.
N.B. 49 U.S.C. 41712-Unfair and Deceptive Practices and Unfair
Methods of
Competition
It is necessary to understand where the DOT is deriving its
authority to pass the
NPRM Enhancing Airline Passenger Protections. 49 U.S.C. 41712 is
the regulation that
gives the DOT authority to implement the NPRM Enhancing Airline
Passenger
Protections.
(a) In General- On the initiative of the Secretary of
Transportation or the
complaint of an air carrier, foreign air carrier, or ticket
agent, and if the
Secretary considers it is in the public interest, the Secretary
may
investigate and decide whether an air carrier, foreign air
carrier, or ticket
agent has been or is engaged in an unfair or deceptive practice
or an
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unfair method of competition in air transportation or the sale
of air
transportation. If the Secretary, after notice and an
opportunity for a
hearing, finds that an air carrier, foreign air carrier, or
ticket agent is
engaged in an unfair or deceptive practice or unfair method of
competition,
the Secretary shall order the air carrier, foreign air carrier,
or ticket agent
to stop the practice or method.
(b) E-Ticket Expiration Notice.— It shall be an unfair or
deceptive practice
under subsection (a) for any air carrier, foreign air carrier,
or ticket agent
utilizing electronically transmitted tickets for air
transportation to fail to
notify the purchaser of such a ticket of its expiration date, if
any.
Tarmac Delay Contingency Plans- Covered Entities
The Tarmac Delay Contingency Plans will apply to any
certificated or commuter
U.S. air carrier operating any aircraft with a passenger
capacity of thirty or more.
Regional airlines will not be excluded from this rule as they
carry one out of every five
passengers domestically. Over 14% of passengers travel on
aircraft with a capacity
between thirty and sixty seats and according to the DOT and not
including this segment
into the rule would leave a large percentage of consumers
unprotected. In regards to
international flights, the DOT will permit airlines to establish
their own tarmac delay limit
that may vary according to the situation. However, it will be
required of the airline to
have that limit published in contingency plans. It is important
to note that this rule
applies to all flights on any aircraft size of a carrier if the
company operates even a
single aircraft with a capacity of thirty or greater including
chartered services.
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Tarmac Delay Contingency Plans- Content of the Contingency
Plan
The DOT adopted a final rule stating the contingency plan must
include:
1. Aircraft will not be permitted to sit on the tarmac for more
than three hours unless
the pilot-in-command determines there is a safety-related or
security-related
impediment to deplaning passengers or Air Traffic Control
advises that returning to the
gate would significantly disrupt airport operations
2. For international flights departing from or arriving to an
U.S. airport, the aircraft
will not be permitted to remain on the tarmac for more than a
set number of hours as
determined by the carrier in its plan
3. An air carrier will provide adequate food and water no later
than two hours after
the aircraft leaves the gate or touches down unless the
pilot-in-command deems the
situation unsafe or unsecured
4. Operable lavatories and adequate medical attention will be
available if needed
for the duration of the aircraft on the tarmac
5. Sufficient resources will be made available to implement the
contingency plan,
6. The plan must be coordinated at all medium and large hub
airports that the
carrier serves as well as diversion airports
Tarmac Delay Contingency Plans- Incorporation of Contingency
Plan into
Contract of Carriage
The DOT decided that it will not be required of air carriers to
include the
contingency plan into the contract of carriage. However the DOT
will require the
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contract of carriage to be posted on the carrier's website. If
the carrier chooses not to
include the contingency plan in the contract of carriage, it
must also be posted on the
website in a manner that is easy to access.
Tarmac Delay Contingency Plans- Retention of Records
The DOT will require carriers to retain records for two years of
delays that trigger
the contingency plan or lasts longer than three hours, for two
years. The content of the
records must contain the length of the delay, specific cause of
the delay, steps taken to
minimize the hardships to the passengers, whether the flight
ultimately took off or
returned to the gate, and an explanation for the delay if
lasting longer than three hours.
This also includes an explanation why the aircraft did not
return to the gate by the three
hour mark.
Tarmac Delay Contingency Plans- Analysis
The tarmac delay rule within the NPRM Enhancing Airline
Passenger Protection
has received more public attention than any other aspect of the
rule. It’s hard to refute
the fact that something needs to be done to address some of the
inhumane conditions
passengers are subjected to during lengthy tarmac delays but
this legislation simply will
not work. Dr. Amy Cohn, an associate professor of industrial and
operations
engineering at the University of Michigan wrote an insightful
article for Forbes Magazine
explaining why this rule is not going to help consumers in most
cases. She explains, "If
your flight is delayed, say, because of an ongoing thunderstorm,
the ruling won't apply
to you. It's not safe for the ground crews needed to guide the
plane back to the gate to
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stand on the tarmac as human lightning rods, so you have to keep
waiting. How about if
you are delayed because of a snowstorm? Quite likely, there will
be no available gate
for you to return to, as they are all occupied by other aircraft
that couldn't take off. So
again, the rule won't apply. Remember the international flight
that was diverted to a non-
international airport? No help for those passengers either
because it's not within the
airline's jurisdiction to establish customs and passport
control."
Another scenario that would challenge the feasibility of this
rule would involve the
following. Mike and his family of four are flying out from JFK
to Orlando International
today. After sitting on the tarmac for two hours due to the
congestion on the runways,
the airline makes the decision to bring his flight back to the
gate in order to avoid the
$27,500 fine per passenger. That is understandable considering
Mike’s plane with 250
passengers would cost his favorite airline up to $6.8 million in
fines. Mike is unaware
that the crew on his flight has now met their maximum number of
hours on duty they are
allowed to fly. Another crew will not be available for several
hours so the flight is
cancelled. Its Memorial Day weekend and Mike’s flight of 250
people scramble to fill the
few remaining seats on the next flights out. By the time Mike
gets his family to the ticket
counter, the next available flight for his family is five days
from today since load factors
were already pushing 85%. Mike and his wife already took work of
for the next three
days so they have no choice but to cancel their long planned
vacation and get a refund.
This legislation is intended to be a patch to fix the problem.
But unfortunately this
patch doesn’t even help fix the problem, it just gives the
appearance to everyone who
sees it that the problem has been fixed. At a stakeholders
meeting in DC regarding the
proposed new rules, one of the speakers was Robert Crandall,
former CEO of American
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Airlines stated that “airlines need some form of legislation to
force them to act on these
extended tarmac delays.” However he also noted that this was not
going to be simply
fixed by forcing the airlines to comply with new rules. The
problem facing the airlines
and the root cause of the tarmac delays that Amy Cohn had
mentioned is a systematic
problem that is prevalent in the very infrastructure and
mentality of the aviation industry.
The entire process of the air traffic management, safety
management systems, slot
allocation, and resource management needs to be turned upside
down and rebuilt to
address the changing industry. The 20th century saw the large
jetliners carrying more
passengers less frequently. The 21st century is shaping into a
much different traffic
pattern as low cost carriers (LCC) and even the legacies are
more frequently relying on
smaller aircraft such as Boeing 737s and Airbus A320s flying
more frequent flights to
build a more efficient fleet and network. Without addressing
these changes in the
system and coming up with new innovations to address these
systematic problems,
mandating airlines to not be delayed more than three hours is
almost comedic. U
Unfortunately Barbara Boxer of California displayed the source
of the core
problem facing the industry when she responded to Crandall’s
call to get a handle on
New York airport congestion with, “We need to get this law
passed. Then we can deal
with capping NY air traffic.” (ConsumerTraveler, 2009)
Opponents to the “Enhancing Airline Passenger Protection” rule
argue that
market forces push the airlines to regulate themselves and have
shown multiple
examples of success stories without legislation such as
Dallas-Fort Worth International
Airport where they already have a contingency plan in place for
tarmac delays.
Ironically, at the same meeting in Washington D.C. where Boxer
and Crandall were
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toting the need for increased regulation, David Carroll who
wrote and recorded the viral
YouTube video “United Breaks Guitars” spoke and performed as a
subtle hint that the
marketplace does in fact regulate the airlines especially in
this age of technology and
free communication.
Response to Consumer Problems- Designated Advocates for
Passengers'
Interests
The DOT requires carriers to designate an employee to monitor
the operations of
flights and compliance with the consumer protections in place.
The designated
employee shall have input into the decisions made in the best
interest of the
passengers. The decision of how to best monitor the performance
and compliance of
the flights will be left to each carrier.
Response to Consumer Problems- Informing Consumers How To
Complain
The DOT requires airlines to make the email address, web-form,
and mailing
address available to all passengers to communicate complaints to
each air carrier. This
information must be made available on the carrier's website,
e-ticket confirmations, and
upon request at all ticket counters and boarding gates.
Response to Consumer Problems- Response to Consumer
Complaints
The DOT requires that any covered carrier under the NPRM will be
required to
acknowledge a complaint within thirty days and provide a
passenger with a substantive
response that resolves the complaint within sixty days.
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Response to Consumer Problems- Analysis
This section of the NPRM seems to be a relevant and agreeable
component of
the legislation but also redundant. First of all, most major
airlines already have similar
policies in place. This rule is making official what is already
being practiced in the
industry. Second, there is no enforcement mechanism in this rule
and therefore is a
waste of effort and resources.
Chronically Delayed Flights as Violation of 49 U.S.C. 41712-
Covered Entities
The DOT will consider the NPRM applicable to any carrier that
accounts for at
least one percent of domestic scheduled passenger service. These
airlines will be
required to file a monthly "On-Time Flight Performance Report"
with the DOT's Bureau
of Transportation statistics. The burden of the costs to smaller
airlines would not be in
the best interest of consumers since airlines who account for
less than one percent of
the total domestic scheduled passenger service are not currently
required to collect and
report on-time performance data. This rule does not apply to
carriers that only transport
cargo and mail.
Chronically Delayed Flights as Violation of 49 U.S.C. 41712-
Definition
A flight is defined as chronically delayed if it is operated at
least ten times per
month and arrives more than thirty minutes late or cancelled
more than fifty percent of
that period. For the purpose of this rule, a flight is deemed
delayed if it is more than
thirty minutes late which is a deviation from the DOT threshold
of a late flight at fifteen
minutes. The DOT's justification of this deviation is the
difference in disruption a fifteen
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minute delay may cause to a passenger versus a thirty minute
delay. In the latter
instance, a passenger may miss a connecting flight or suffer
consequences from other
prearranged travel plans. The final rule states a flight that is
chronically delayed for
more than four consecutive months is an unfair or deceptive
practice as defined by 49
U.S.C. 41712. The DOT justification for this rule is to ensure
that airlines do not create
unrealistic schedules and also promote a higher level of
consumer confidence in the
industry. The parameters of this rule were defined around
historical data to prevent a
large number of cancellations. The DOT expresses concern of
causing mass
cancellations in its response stating, "If a significantly
larger number of flights are
defined and identified as chronically delayed flights then
carrier may choose to cancel
these flights rather than operate them." The DOT then continues
to justify that the rule
will "nevertheless not lead to a large number of flight
cancellations as we have found,
based on calendar year 2008 data provided by BTS that the vast
majority of the
chronically delayed flights as defined in this rule were not
chronically delayed for four or
more consecutive months."
Chronically Delayed Flights as Violation of 49 U.S.C. 41712-
Analysis
The issue with punitive action against air carriers for
chronically delayed flights is that in
most cases, those flights are delays due to external factors
outside the control of management.
For example, flights leaving San Francisco during certain times
of the year are going to be
chronically delayed due to low ceilings. Flights out of JFK are
often delayed due to the air space
and airport congestion. The possibility of this rule being a
tool to redirect liability away from the
FAA and DOT seems to be more likely in light of the increased
scrutiny and lack of progress of
the NEXTGEN program. Charging an air carrier of deceptive and
unfair practices because a
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flight is chronically delayed without the means of remarking the
cause of delay for the purpose
of the consumer’s decision making also seems to be in conflict
with the FAA and DOT’s interest
in improving the public perception of the industry.
Delay Data on Carriers' Web Sites- Covered Entities/Scope
Certificated carriers account for at least one percent of
domestic scheduled
passenger revenues are already mandated to track and report
on-time performance to
the DOT and release such information to consumers upon request.
The DOT will now
also require that delay data for every flight to be posted on
the carrier's website if that
carrier is a covered entity as defined above. The DOT will not
mandate travel agencies
to post the data on their websites due to the substantial costs
of implementing such
measures outweighing the benefit to consumers.
Delay Data on Carriers' Web Sites- Disclosure of Flight Delay
Information on Web
Site
The DOT requires the
following on-time
performance information
to be posted on each
covered carrier's website:
1. Percentage of
arrivals that were
on time- Within
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fifteen minutes of scheduled arrival time
2. Percentage of arrivals that were more than thirty minutes
late
3. Percentage of flight cancellations if five percent or more of
the flight's operations
were cancelled in the month covered
4. Flights that are late more than thirty minutes, over fifty
percent of the time need
to be highlighted
5. Carriers must show above data on the initial listings page of
the website or by a
hyper-link on the page of initial listings
6. All carriers must load delay data into the internal
reservations system for the
previous month between the 20th and 23rd day of the current
month
Carrier's Adherence to Customer Service Plans- Covered
Entities
All U.S. carriers operating scheduled passenger service using
aircraft with a
capacity for thirty or more passengers will be required to adopt
a customer service plan,
publish it on the carrier's website, and audit themselves for
compliance on an annual
basis.
Carrier's Adherence to Customer Service
Plans- Content of Customer Service
Plans
The DOT will require the covered
carriers to address the same elements as
the ATA's Customer First Initiative:
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1. Offering the lowest fare available
2. Notifying consumers of known delays, cancellations, and
diversions
3. Delivering baggage on time
4. Allowing reservation to be held or cancelled without penalty
for a defined amount
of time
5. Providing prompt ticket refunds
6. Properly accommodating disabled and special needs passengers,
including
during tarmac delays
7. Meeting customer's essential needs during lengthy on-board
delays
8. Handling "bumped" passengers in the case of over sales with
fairness and
consistency
9. Disclosing travel itinerary, cancellation policies, frequent
flyer rules, and aircraft
configuration
10. Ensuring good customer service from code share partners
11. Improving responsiveness to customer complaints
This rule will not apply to regional carriers who provide
aircraft via code share
agreements as only an airline that sells air transportation to
individual customers will be
required and capable of providing good customer service.
The DOT is requiring carriers to include the services a carrier
provides to mitigate
passenger inconveniences resulting from cancellations and missed
connections in their
customer service plans. The carriers will also be required to
include a process for
handling overbooked flights fairly and consistently.
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Carrier's Adherence to Customer Service Plans- Incorporation of
Customer
Service Plan into Contract of Carriage
The DOT will not mandate the incorporation of the Customer
Service Plans into
the Contract of Carriage. However, it strongly recommends
carriers to do so voluntarily
as it will help in maintain compliance as well as other
incentives. The DOT does require
all carriers to post its entire contract of carriage on its
website in a manner that is easily
accessible to consumers. Any carrier who chooses not to include
their customer service
plan in the contract of carriage will be required to post the
customer service plan online
as well in easily accessible form. According to the DOT, the
purpose of this requirement
is to ensure that consumers can easily review the airlines
obligations and time frame of
the contract. This will allow consumers to be better informed
about their rights and the
carrier's responsibilities.
Carrier's Adherence to Customer Service Plans-Audit of Customer
Service Plans
The DOT will require a carrier to audit its own adherence to the
customer service
plan on a yearly basis and make the results of the audit
available to the DOT for two
years after the audit is completed. The DOT believes that
requiring carriers to audit their
own plans internally on a yearly basis will influence carriers
to comply with their
commitments.
Carrier's Adherence to Customer Service Plans-Analysis
This section of the NPRM could have become a national
controversy for many
reasons. The section that the most attention should be drawn to
is the Incorporation of
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Customer Service Plan Into Contract of Carriage. If the DOT
accepted these clauses
into the rule, airlines would be legally bound to provide the
services stated in their
commitment to the passengers. Although it is in the best
interest of the airlines to follow
through with their customer service plans, certain circumstances
beyond the control of
the carrier may arise facilitating a need to deviate from the
customer service plan for the
benefit of the majority. If the customer service plan has been
included into the contract
of carriage, and a carrier finds itself in a situation as
described above, they could be
sued for breach of contract. In fact, the Air Transport
Associate goes as far as to say,
“The ATA challenges the DOT’s legal authority to do this in the
aftermath of
deregulation. ATA argues that the department may not substitute
a different
enforcement process other than the one Congress intended and
states that such an
imposition would subject carriers to the vagaries of law in the
fifty states.” The DOT
responds, “The Department disagrees with the arguments of the
ATA and other carrier
commenters that we lack the authority to require incorporation
of contingency plans in
contract of carriage and that such incorporation would subject
carriers to the risk of
inconsistent standards among various jurisdictions. However, the
Department has
decided that it will not require such incorporation at this
time.” Where is the DOT’s
evidence that substantiates their disagreement?
Effective Date of Rule
The DOT believes the carriers should have enough time to
implement the
proposed changes and 120 days after the rule is published in the
Federal Register is a
sufficient amount of time.
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Analysis of the Effects of the NPRM on Regional Carriers
One segment of the airline industry that did not receive
extensive consideration
for exemption was the regional carriers. It could be argued that
regional carriers have
the most to lose from this new rule as they will still be held
to the standards all other
airlines are held to but without the autonomy and ability to
quickly make decisions
regarding carrier operations. The Regional Airline Association
made the following
arguments against the inclusion of regional carriers into the
new rule:
1. Over 90 percent of passengers flying on regional aircraft
travel on flights that are
ticketed and handled by mainline carriers who schedule the
flights, and that most
carriers have no direct interaction with the consumers.
2. Requiring a regional carrier to have their own plan would
increase the conflicts
and inconsistencies that could arise as it is not clear if the
regional carrier’s own
contingency plan would supersede the contracts of the carriers
who marketed
and sold the ticket to the consumer.
3. Regional carriers have limited control over operational
decisions and the rule
would impose unfair burdens to regional carriers.
4. Providing food and water on a regional carrier is
impracticable because most
regional carriers do not have catering facilities as well as
many of the airports
they serve.
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5. Regional carriers should not be required to incorporate a
contingency plan into
their contract of carriage because most regional passengers are
subjected to the
ticketing carrier’s contract of carriage.
6. Regional airlines are not able to designate personnel with
responsibility for
influencing delay decisions since that is not a function of a
regional carrier.
7. Regional airlines lack the ability to engage in the behavior
the DOT is seeking to
prevent since regional airlines fly schedules established by
major airlines.
Of all these seemingly valid arguments against the inclusion of
regional carriers in
this rule, only one exception was made regarding the customer
service plan. This
could have widespread financial implications on not only the
regional carriers
themselves, but also the major carriers who rely on the low cost
services of the
regional carriers. In order to comply with the DOT’s new law,
regional carriers will be
incurring significantly higher costs and those will need to be
passed on to the direct
and codeshare passengers. This will indirectly result in an
increase in fares across
the entire air transportation system.
Conclusion
The DOT has stated their intentions to further refine the
“Enhancing Airline
Passenger Protections” rules as consumer feedback becomes more
available. Although
the purpose of this NPRM was too address an important deficiency
in the airline
industry, it is the opinion of this author and many others that
this “patchwork” approach
to the problem is only going to further complicate and propagate
the problem. It is the
hope of many that the legislative powers recognize the need for
a systematic approach
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to the problem and identify the true cause of tarmac delays and
consumer resentment in
the aviation industry, complacency of precedent.
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Works Cited
Leocha, Charlie. “Tarmac Delay Activists Meeting in Washington
Face Legistlative
Complexities.” Consumer Travel (2009): May 1, 2010.
http://www.consumertraveler.com/today/tarmac-delay-activists-meeting-in-washington-
face-legislative-complexities/
Cohn, Amy. “Still Stuck on the Tarmac.” Forbes. 2009. April 23,
2010.
http://www.forbes.com/2009/08/12/passenger-bill-of-rights-congress-travel-delay-
opinions-contributors-aviation.html
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http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480a7413a