Who Participated in the Customer Service Plans Discussion?

Customer Service Plans generated a moderate amount of discussion.  There were 79 total comments:

  • 68 were made by 50 users
    (5 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.)
  • 11 were moderator comments

Commenters included primarily people who identified themselves as air travelers.  Four commenters identified themselves as belonging to another interest group: two as researcher/experts, one as working for a travel agent or Global Distribution System (GDS), and one as undefined “other.”

From September 13 to September 19, the Draft Summary was available for review.  Two people made comments. During this period, the Regulation Room team reviewed the comments on the Customer Service Plan post again; as a result of this review, some additional detail has been added to this summary.


Most commenters support DOT’s proposals, saying they are generally reasonable and appropriate.  Many commenters express general frustration with air travel and airlines, and some want DOT Department of Transportation to go further in setting minimum standards and prohibiting certain current practices.  Several commenters, however, oppose additional regulation, fearing that the costs will be passed on to consumers.  They expect air travelers to accept the normal risks of flying and believe that the market will set appropriate standards based on consumers’ choice of carrier.

Because many of the topics that DOT Department of Transportation may include in a set of minimum standards for customer service plans are the subject of separate posts, the discussion on this post overlaps with discussion summarize in Tarmac Delay, Ticket Oversales/Bumping, Baggage and Other Fees, and other summaries.  We have not consolidated comments from this post into those others.

Flight Delays, Cancellations, Ticketing and Fee Practices

Many comments favor requiring airlines provide full refunds (including fees, surcharges, and taxes) as well as compensation for hotels and meals if there is a significant delay in flight time.  Some suggest that any delay over three hours is “significant”; others are willing to let DOT Department of Transportation define “significant delay.”  At least one commenter favors requiring a passenger’s ticket to be transferable to another carrier who has a flight leaving shortly for the same destination.

On the issue of cancellation, one commenter favors the idea of a 24-hour window for passengers to cancel and receive a refund for all fares and fees, without penalty, from the point of purchase.  Another suggests a three-day window prior to the scheduled departure date to either cancel or reschedule a flight without additional fees.  One commenter wants airlines to offer travelers cancellation insurance.

Three commenters urge DOT Department of Transportation to adopt a rule that airlines may not reschedule or cancel passengers’ already purchased flights without an automatic refund.

Two commenters urge a rule that tickets are transferable to third parties. One argues that it is unreasonable to prevent a consumer from transferring a ticket he/she has bought and paid for;  transferability of purchased goods and services is the norm.  There is no security threat, for the new traveler would arrive at the airport with a ticket in his/her name and have to show ID

One commenter asks for a rule prohibiting airlines from charging different prices for aisle, window and exit seats.

Responding to DOT’s suggestion of requiring airlines to publicize the lowest possible fare, one commenter, who self-identified as working for a travel agent or Global Distribution System, opposes the idea: the complexities and diversity of methods associated with fare calculation make such a rule impractical.


Commenters propose a number of changes to current practices on overbooking and bumping compensation (see also proposals in Ticket Oversales/Bumping).

  • Three commenters urge a requirement that airlines put bumped passengers on flights of other carriers.
  • Three support requiring airlines to compensate bumped passengers on zero-fare tickets by refunding frequent flyer miles.
  • Several commenters propose ways airlines could reduce unprofitable empty seats without overbooking.  One suggests that all tickets be subject to a “use em or lose em” policy, or that the value of unused tickets should be reduced by 50%.  Another suggests that airlines sell some portion of tickets that include a guaranteed seat, but that beyond that, tickets should have “first come, first served” seating.  A third suggests a reservation system like that of commercial cruise lines, in which nonrefundable deposits are required on all tickets.
  • One commenter urges DOT Department of Transportation to restrict or otherwise forbid bumping altogether on international connecting flights.


Nearly 15 commenters urge DOT Department of Transportation to require refund of baggage fees when luggage is late or lost.  (See also proposals in Baggage & Other Fees.) Various standards were suggested for “late”:  several commenters suggest two hours; one suggests 12 to 24 hours depending on how far the passenger is from the airport; one says that it should depend on the particular circumstances of travel.

One commenter opposes additional baggage regulation, arguing that the possibility of late and lost luggage is part of the normal risk consumers take when flying.

Airport and In-Flight Experience

One commenter is concerned about whether greater protection should be provided to minors who flying alone.  Two commenters respond to this concern.  One, recounting his/her own experience of flying alone as a mature minor, argues against blanket policies in this area; this commenter believes the best solution is to give airlines leeway.  The second states that parents/guardians who allow children to fly alone are assuming a risk, and airlines should not be responsible for specially protecting every potentially vulnerable passenger.

Two commenters raise the issue of traveling with pets. One objects strenuously to being charged $100 or more each way for having a pet in the carrier this passenger uses for the carry-on luggage allowance.  Another argues that dogs should be allowed to sit in a seat it the traveler is willing to pay for it.

Several commenters want improved standards for customer service.  Many want easier, faster access to customer service representatives and better service when they do get an agent.  One suggests a requirement that airlines provide human customer service support for passengers with booked flights, while another suggests a mandatory maximum period of time a customer could be placed on hold or otherwise delayed from speaking to an airline representative.  One expresses frustration with time-consuming phone menus that often do not result in an agent who can actually help with the problem.

More than half a dozen commenters express serious dissatisfaction with how far airlines have reduced legroom and other seat dimensions.  They urge DOT Department of Transportation to set minimum standards in these areas.  Some commenters propose a requirement that very large passengers purchase two seats.

Four commenters want DOT Department of Transportation to prevent airlines charging separate fees for necessary inflight items.  Fees for blankets provoke particularly strong reactions.  One commenter points out that the airline, not the passenger, controls cabin temperature.  This same commenter would include water, since the rule against bringing liquids through security forces passengers to pay inflated prices from airport venders, and meals on flights of 5 hours or more.  More generally, one urges restriction of solicitations (e.g., credit cards and other products) by flight attendants during the flight.

One commenter says that DOT Department of Transportation should consider penalties for, or requirements on, passengers to minimize delays due to passenger behavior.

Applicability, Enforceability, Transparency

More than a dozen commenters urge that, regardless of what minimum standards are adopted, the standards should be uniform, and made easily accessible to consumers prior to booking.  One commenter emphasizes that new regulations must also apply to online booking services and other air travel sellers.  About a half dozen stress that any proposed change should apply to both domestic and international carriers.

Five commenters agree with DOT’s proposal to include customer service plans and standards in the contract of carriage.  One points out that this will will help passengers comparison shop among carriers.  Two argue that passengers should be able to pursue legal action against airlines in their jurisdiction of convenience and should generally face fewer barriers to holding airlines accountable.

Three commenters say that carriers should disclose the safety history of their flights, with accuracy certified by a third party.  They say that consumers should have access to this information prior to booking.

General Desirability of Regulation

Although most commenters express general support for minimum federal standards of customer service and airline practices, several commenters strongly disagree. These commenters are concerned that government-mandated standards will result in higher operating costs that airlines will simply pass on to the consumer.  Some consider the inconvenience of, for example, altered flight schedules and mishaps such as lost luggage to be part of the normal risk of flying.  These commenters advocate giving consumers the choice of whether to take those risks in exchange for cheaper flights.  They believe that consumers themselves can effectively police the airline industry by choosing which carriers they fly with; the market will then enforce standards of conduct among carriers

Other commenters respond to this position by arguing that the structure of the airline industry is monopolistic, so consumers do not realistically have much choice among carriers.  A commenter who self-identifies as a researcher or expert says that price increases are not the inevitable result of regulation, and that other industries adapt to increased regulation by improving efficiency.

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