In the DOT’s first Enhancing Airline Passenger Protections proceeding, I filed a comment as to the risk of opportunistic behavior by GDS’s taking advantage of potential new regulations requiring airlines to purchase information distribution services. After pointing out the potential unintended consequences of the regulation DOT was considering, I offered three alternatives that would improve the information available to consumers while avoiding negative side effects.
Public comment on Enhanced Airline Passenger Protections
In 2010, the Department of Transportation issued a Notice of Proposed Rulemaking (NPRM) as to enhancing airline passenger protections. I filed a comment as to one of the subjects under discussion: whether and how airlines should be required to disclose fees through GDS’s, and what might happen if the DOT imposed such a duty without airlines contracting in advance to obtain such service from GDS’s.