Adding a new dimension to the controversy, the Association of Retail Travel Agents (ARTA) reports that it has submitted comments to the U.S. Department of Transportation (DOT) regarding the DOT's proposed rulemaking to expand reporting of ancillary fees related to air travel. ARTA questioned the economic need for DOT data collection, its costs and consumer benefits. The DOT is considering new rules on airline disclosure of ancillary fees and has requested industry comment before it issues new policies.
At the core of ARTA's concerns is the lack of any economic justification provided by the DOT to collect such data, nor any benefits to consumers as a result of requiring air carriers to provide such data, ARTA said. "Absent such clarification and analysis, respondents are unable to provide a reasonable and proper response to the request by the DOT for public comment," ARTA continued.
"We just can't provide a meaningful reply if the DOT has not detailed the economic and consumer benefits for requiring such a massive collection of fee data. Tell us what the advantages to stakeholders are, and we'd be all too happy to provide appropriate comments", said ARTA Chairwoman Nancy Linares.
Absent such details, ARTA has asked the DOT to delay any added reporting requirements.
ARTA said it had "general concerns that collection of such fee data may be a case-in-the-making to impose taxes on such fees, which would not only increase overall costs to travelers, but also add to the burden of travel agents taxing, collecting, exchanging and refunding such optional services or components of such services."
ARTA also stated that the DOT might set a precedent for other transportation providers, including rail and sea, to report their à la carte optional fees, and that ARTA knows of no other industry required to provide such data on optional products and services in the sale of a base product or service.
Professional travel agents are well-aware as to where to find, analyze, and explain these optional fees to consumers, ARTA said.
Lastly, ARTA stated that the data dissemination and distribution of these fees must not be used as an attempt to force airlines to provide such fee data to global distributions systems (GDSs).
ARTA is concerned that any such mandate would create substantial economic harm to travel agents by interfering with the normal negotiation process between airlines and GDSs, the lack of which, usurped by government intervention, might give rise to costs imposed on travel agents.
ARTA asked if travel agents would have to pay for such data which might otherwise have been provided free of charge to travel agents through the standard course of airline/GDS negotiations. As related matters are already before the courts, it would be inappropriate for the DOT to advance any proposed fee reporting rulemaking at this time, ARTA said.