The Consumer Travel Alliance (CTA) and the Business Travel Coalition (BTC) filed reply comments to those filed by a group of airlines regarding transparency of airline fees. The airline comments are seeking to present the disagreements about a pending Department of Transportation rulemaking that may mandate up-front and clear dislosure of airline fees at the same time as airfares are disclosed as an internal business issue. Both CTA and BTC feel that these are clearly consumer issues.
Here are the complete comments filed by CTA and BTC.. Excerpts from the comments follow.
The two consumer organizations clearly identify this issue as a consumer issue where truth in advertising and the ability to compare prices in their entirety are the basic issues.
DOT should not allow this important rulemaking to become a battleground between different parts of the air transportation community. Contract negotiations and related strategies between the airlines and their GDSs and ticket agents are outside of the purview of DOT and are not pertinent to this rulemaking and should not be allowed to obscure the pro-consumer focus.
Both BTC and CTA strongly protest current airline practices that deceptively offer the specter of lower airfares in order to gain enhanced positioning on Internet displays while aggressively increasing and hiding ancillary fees for transportation elements that were once considered an integral part of the ticket price.
This “unbundling,” as the practice is termed, coupled with the airlines’ decision to withhold the new ancillary fees from ticket agents and not fully disclose them to stifle price comparison shopping for consumers, deceives U.S. and foreign passengers into believing the prices offered are lower than the eventual full cost of travel. Often ancillary fees add dramatically to published airfares.
All suggested remedies offered by the airlines eliminate the ability to easily compare total, all-in prices across airlines. Consumers’ confusion is only exacerbated when potential travel costs involve connections between different airlines that are sometimes within the same airline alliance, airlines that have no alliance affiliation or codeshares.
The two consumer organizations note that calling an airfare a different name doesn’t make it different
The airlines also claim that they are not hiding their fees when they refuse to share their ancillary fees (once offered as a part of overall airfares) across all of their ticket agents as has long been required by Section 41712. For years, DOT has required the full cost of airline travel to be available to the public, including through all ticket agents. The airlines must be required to meet the intent of the statute and DOT’s full fare advertising regulations, rather than being allowed to dismantle an airfare and then narrow the definition of what needs to be disclosed.
Businesses are facing hurdles in trying to deal with hidden fees as much as leisure travelers, perhaps more.
While a leisure traveler’s major issue is the ability to compare all-in airfares, business travelers and corporations that fund business travel activities have to deal with a more complex series of management and accounting problems created by the refusal of airlines to file their ancillary fees. As ancillary fees grow and become a significant portion of the overall air travel cost, corporations need to have some way to manage, control and account for these costs.
Not only is there an unknown universe of ancillary fees but also, these charges vary at the airline’s whim depending on the corporate traveler’s frequent flier level, the flier’s credit card usage and where and when the ancillary fees are encountered and paid. Furthermore, the airlines provide no way to measure the impact of their ancillary fees on travel policy, expense reports and per diem limits and may leave the door open to fraud and abuse. To make comparisons, control and tracking even more difficult, the airlines do not use a standardized system to report ancillary fees.
Finally, both CTA and BTC ask for basic truth and transparency.
The consumer point of view, whether from the business side or the leisure side, is that airlines should be required to disclose their ancillary fees at the same time and in the same manner as they disclose airfares and make them available across all ticket sales channels in which the airline chooses to sell its services. This is the only way that travelers can determine the full cost of travel so that individuals and corporations can compare the full, all-in cost of travel in order to make decisions among different alternative travel options.
The airlines can run their businesses any way they choose with as many extra fees as they feel are necessary, packaging those in a limitless variety of manners, but they must be required to tell consumers the full cost of travel wherever and through whatever channel they choose to sell airline tickets.
That is not too much to ask.
Charlie Leocha is the President of Travelers United. He has been working in Washington, DC, for the past 14 years with Congress, the Department of Transportation, and industry stakeholders on travel issues. He was the first consumer representative to the Advisory Committee for Aviation Consumer Protections appointed by the Secretary of Transportation from 2012 through 2018.
