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Airline Passenger Rights "Costs & benefits"

Draft Summary of Discussion
By the Regulation Room team based on what people have said
Agency Documents
1 0


What’s Going on Here?

This is a summary of the discussion on the Costs and Benefits post between June 2 and September 10.  (On September 11, the post was closed to further discussion.)  The summary was written by the Regulation Room team based on all the comments people made.  This version is a DRAFT. We need YOUR help to make sure that nothing is missing, wrong or unclear.

Important dates:

Sept. 13 – Sept. 19:  Comments can be made here on the draft
Sept. 20 :  Commenting on the draft summary closed
Sept. 20 – Sept.  22:  Regulation Room team reviews comments and revises draft
Sept. 23:  Final Summary of Discussion is posted on Regulation Room and submitted to DOT Department of Transportation as a formal comment in the official rulemaking record.  (Sept. 23 is the last day of the official commenting period.)

Things to keep in mind as you read through the draft summary and make comments:

  1. The goal here is to give DOT the best possible picture of all the different views, concerns, and ideas that came out during the discussion.  This is NOT the place to reargue your position or criticize a different one.  Focus on whether anything is missing or unclear, not whether you agree or disagree.
  2. Rulemaking is not a vote. DOT is not allowed to decide what to do based on majority rule.  (Why? See Effective Commenting).  Approximate numbers are provided in the summary only to give DOT a sense of the frequency of views, concerns, and ideas.

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2 0 Who Participated in the Costs and Benefits Discussion?

The Costs and Benefits issue generated a modest amount of discussion.  10 comments were made on this post:

  • 6 comments by an estimated 6 users
    (2 comments were gathered by site administrators from the site feedback page, and added to this post by the moderator.  No username was associated with these comments)
  • 4 comments by Regulation Room moderators

Commenters included primarily people who identified themselves as air travelers.  Commenters included primarily people who identified themselves as air travelers.  One who identified himself/herself as working for a US air carrier also commented.

3 0 General Comments on Costs and Benefits of Proposed Regulations

Commenters were equally split on whether the cost of the proposed regulations would exceed their benefits to consumers.

Two commenters are concerned that the costs to carriers will endanger the industry’s financial health and hurt consumers when these costs are passed on as higher prices.

One considers the proposed regulations to be the equivalent of mandatory air travel insurance that covers passenger inconvenience, delays, and other events airlines cannot control.  He/she predicts that the “premium” for this insurance will be high, and believes that most customers, if given the choice, would prefer travel at lower cost to having additional travel interruption insurance.  DOT Department of Transportation is micro-managing the affairs of private companies.  The other predicts not only increased consumer costs, but also further strain on both carriers and mention airports struggling with less traffic.  This commenter believes that the problem is that airlines are underpricing fares to increase volume.  This is a risk to people and the industry.  What is needed is an approach that sets minimum fare prices at a level where necessary fees are covered.

Two commenters disagree.  One sees this as an issue of passengers’ rights not management freedom of private corporations.  Focusing on tarmac delay, this commenter believes that passengers should have the option to deplane, choose another flight or means of transportation, or postpone travel.  Contingency plans for ensuring this should be a condition of airlines’ getting the right to operate.  The other predicts that the costs to airlines will be much less than what is currently spent on advertising that misleads consumers.  Now, consumers incur considerable cost and inconvenience in trying to get refunds and other recovery for problems due to airlines’ nondelivery of promised service.

4 0 Comments Specifically on DOT Department of Transportation Methodology

One commenter questions why DOT Department of Transportation estimates that fee disclosure to consumers has any quantifiable cost.