The National Business Travel Association (NBTA) submitted comments on three proposed regulations under development by the Department of Transportation (DOT) aimed at alleviating air traffic congestion and improving airline customer service.

NBTA Executive Director & COO, Bill Connors, CTC, said, “NBTA congratulates the Administration and the Department of Transportation for taking proactive steps to address the challenges faced by our nation’s air transportation system. While we support some of DOT’s proposed measures, others are misguided. Our basic position is this: government should establish systems for basic consumer protection and then get out of the way to let business function. No one benefits from micromanagement of customer service; the added costs of overregulation of the airline industry would only serve to inhibit innovation in the industry and increase costs for passengers.”

NBTA’s written comments notes, “Generally NBTA believes that customer service is a market-driven issue, with purchasers able to make informed buying decisions based on facts related to airline service. As certain types of information are only in the possession of air carriers, NBTA generally supports greater transparency and reporting requirements so long as such requirements provide useful information to the airline passenger and/or their purchasing agent and can be conducted with reasonable costs…Moreover, while NBTA believes the federal government has an interest in mandating certain baseline consumer protections for airline customer service – or ‘passenger rights’ – in general, airlines are in a much better position to ascertain what their customers expect and whether certain practices are worth the cost they entail. Basic economics dictate that government mandates create private sector costs, and those costs are going to be borne, directly or indirectly, by the traveling public.”

NBTA supports a number of measures aimed at increasing transparency in the aviation system, including reports on tarmac delays, a bright-line test for chronically delayed flights, and publishing delay data on carrier websites.

That transparency will increase competition by helping airline passengers and corporate travel buyers make well-informed decisions.

With respect to reimbursing passengers for involuntary denials of boarding due to overbooking, NBTA notes in its filing, “Business travelers are more likely to be flying at peak schedule times at the beginning and end of the business day, they are at much greater risk to book tickets on a flight that ends up being overbooked.” Thus NBTA proposes that DOT “require that carriers compensate travelers the greater of $400 or half of their airfare for travelers involuntarily denied boarding and arriving at their destination within two hours of their scheduled arrival time [and] the greater of $800 or half of their airfare for travelers involuntarily denied boarding and arriving at their destination more than two hours after their scheduled arrival time.”

NBTA’s Connors commented, “While DOT’s current efforts may provide short term solutions to problems of air traffic congestion, the Administration and Congress should quickly to address the long-term issues by finishing work on FAA funding and reform.”

In addition, NBTA requested that DOT initiate a rule-making or other mechanism to require federal agencies to refund government taxes and fees charged on tickets that are not actually utilized.