As you know, ASTA filed a formal complaint with the Department of Transportation (DOT) against American Airlines (AA) alleging unfair practices in connection with its implementation of New Distribution Capability (NDC) technology. In turn, AA filed its answer to the complaint, followed by a reply submitted by ASTA. At this point, it’s in DOT’s hands to determine whether it will investigate AA’s business practices. However, because the regulations do not require DOT to render a decision within a particular timeframe, we believe time is of the essence.
This is where you can help. To nudge DOT to action, we would greatly appreciate you taking a few minutes to submit written comments to DOT detailing how AA’s actions have adversely affected your agency’s operations and your clients. While ASTA laid out the case for enforcement against AA in its filings, for maximum impact, it is crucial that the decisionmakers at DOT hear from you personally and directly. Among the specific points you may wish to raise in your comments are:
Price Discrepancies – significant variations in AA ticket prices when comparing those available via EDIFACT versus those published on an NDC-enabled channel or AA’s website.
Booking Challenges – difficulties associated with inability to efficiently comparison shop, book multi-city itineraries, etc.
Lack of Functionality to Service Bookings – ticket exchanges, cancelled/partially used tickets, etc.
Interference with Duty of Care – interference with the agency’s obligations to its clients’ employees when traveling on behalf of their employer.
Inability to Fairly Compete with American as Ticket Distributor – unfair provisions of the Governing Travel Agency Agreements (GTAA) e.g., prohibition on automated re-shopping, inability to use aa.com for commercial purposes, restrictions on imposing service fees, etc.
These are only examples based on what’s been reported to us over the last year. Feel free to address in your comments any issues or concerns you believe are relevant to DOT’s consideration of the matter.
In the search box, enter docket number DOT-OST-2023-0147 and click “Search”.
Click on “Complaint of the American Society of Travel Advisors, Inc. against American Airlines Alleging Unfair Practices and Request for Relief Pursuant to 49 U.S.C. 41712” (last docket entry from the top).
Click on the blue “Comment” box. This directs you to the “Write a Comment” page.
Once there, you can either type your comments directly into the text box or upload a Word or .pdf document containing your comments.
Fill in the requested information in the remaining fields and then click on the blue “Submit Comment” box.
Note that once filed on the docket, your comments become part of the public record. As such, please take care to not include in your submission any information that you would prefer stay private.
