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Consumer Protection of Air Travelers in the USA

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1 Consumer Protection of Air Travelers in the USA
Samuel Podberesky, Assistant General Counsel Office of Aviation Enforcement and Proceedings Presentation to Seminario Internacional Sobre La Protección al Consumidor Bogota, Colombia — August 19, 2008

2 Agenda Office of Aviation Enforcement & Proceedings (AEP)
Consumer protection statutes & regulations enforced Enforcement procedures, penalties, & settlement practices Public education & outreach Contact information Questions

3 Consumer Complaints by Type
2006 2007 Flight Problems (e.g., canceled/delayed flights) 2,162 (26%) 4,465 (34%) Baggage 1,936 (23%) 2,894 (22%) Customer Service 1,019 (12%) 1,365 (10%) Reservations & Ticketing 1,007 (12%) 1,495 (11%) Refunds 774 (9%) 1,024 (8%) Other (e.g., oversales, disability, discrimination, frequent-flyer programs) 1,427 (18%) 1,925 (15%) Total 8,325 (100%) 13,168 (100%)

4 AEP Staffing & Structure
One of Six Offices in OST’s Office of the General Counsel Enforcement Legal aspects of Airline Economic Licensing Aviation Consumer Protection Legal Division 16 attorneys, including one assistant general counsel 2 support staff Aviation Consumer Protection Division 15 professionals, including one director 1 support staff

5 Jurisdiction We do not handle:
Aviation Safety (this is regulated by the Federal Aviation Administration) Aviation Security (this is administered by the Transportation Security Administration)

6 Jurisdiction We do handle: “Air Transportation”
Direct and Indirect Air Carriers Ticket Agents

7 Division of authority among Federal agencies & preemption of state law
To a great extent DOT's consumer protection enforcement powers are exclusive. Federal Trade Commission The FTC's consumer protection authority does not extend to air carriers. See 15 U.S.C. 45(a)(6). DOT regulates travel agents that advertise air transportation FTC regulates non-air transportation advertising by travel agents, such as hotel accommodations and cruises Preemption of state law No state may enact or enforce any law that relates to the rates, routes, or services of any air carrier having economic authority under Subtitle VII. See 49 U.S.C , but also see 49 U.S.C In a case involving a state attorney general's attempt to enforce state deceptive practice laws against airline fare advertising, the Supreme Court construed the Act's preemption provision broadly and held that state enforcement action was prohibited. Morales v. TWA, 949 F.2d 141 (5th Cir. 1991), remanded, 112 S. Ct. 2031, 119 L. Ed. 3d 157 (1992). However, the Supreme Court refused to review a case in which the U.S. Court of Appeals for the Ninth Circuit held that a traveler with a ticket and confirmed reservation, who was denied boarding by an airline because of aircraft capacity limitations, could sue the airline for compensatory (but not punitive) damages in state court. See West v. Northwest Airlines, 995 F.2d 148 (9th Cir. 1993), cert denied, 114 S. Ct (1994). The Department has taken the position that consumers are not precluded from suing airlines in state courts to enforce contractual obligations. See, e.g., the last paragraph of the notice included in 14 CFR on oversales. In 1995, the Supreme Court agreed with the Department's position in American Airlines, Inc. v. Wolens, 115 S. Ct. 817 (1995), a case in which consumers were allowed to challenge, under contract law, an airline's change to the benefits of its frequent flyer program.

8 49 USC 41712: The “Keystone” Provision
Broadly prohibits unfair and deceptive practices and unfair methods of competition in the sale of air transportation Provides DOT with enforcement authority involving competition that exceeds that of the Department of Justice in some respects. Enforceable in its own right but it is even more important as the basis for DOT rulemaking and policymaking. Examples of consumer protection rules issued at least in part based on section 41712: Full fare advertising (14 CFR ) Unrealistic scheduling / Chronically delayed flights (14 CFR ) Disclosure of on-time performance (14 CFR ) Denied Boarding Compensation/Oversales (14 CFR Part 250) Notice of Terms of Contract of Carriage (14 CFR Part 253) Disclosure of Codeshare Arrangements, Long-term Wet Leases, and Change of Gauge (14 CFR Parts 257 and 258) Public Charter Programs and Special Event Air Tours (14 CFR Parts 380 and 381) Refunds (cash/check refunds enforced directly from section 41712; 14 CFR part 374 for credit refunds) Pre-Licensing sales – sales by carrier applicants before authority is final (14 CFR 201.5)

9 Advertising: Full Fare Disclosure (14 CFR 399.84)
Fare advertisements must disclose the full price to be paid. See, e.g., Order However, certain taxes/fees may be listed separately from the advertised base-fare if they are: imposed by a government (U.S. or non-U.S.), NOT by the airline itself (e.g., airline-imposed fuel surcharge); levied on a per person basis (e.g., international departure tax), NOT as a percentage of the value of the ticket (e.g., 7.5% U.S. federal government excise tax); and clearly disclosed (including their amount) in the advertisement. This rule also applies to anything advertised in conjunction with the airfare. For example, charges for hotel stays, tours, ground transfers and rental cars become subject to the DOT price advertising rule if advertised in conjunction with air transportation. Fare advertisements necessitate the availability of a reasonable number of tickets at the advertised fare and such ads must disclose important restrictions on the availability of the advertised fares. For example: Lengthy blackout periods must be specifically disclosed. General statements such as "seats may not be available on all flights" or "restrictions apply" are inadequate. See Order A reasonable number of seats must be made available for sale at the advertised fare and general disclosure statements such as "seats are limited" do not absolve airlines of this responsibility. See Order Airlines must monitor seat availability during sale periods to ensure that when advertisements are repeated later in the sale a reasonable number of seats remain available. See Order Fare advertisements must disclose important fare restrictions, such as limited availability of seats, non-refundability and blackout dates, and must contain a prominent disclosure in proximity to the fare listing of roundtrip purchase conditions. See, e.g., Orders , , and

10 Advertising: Pre-Licensing Sales (14 CFR 201.5)
Restricts certain marketing activities of applicants for new or amended certificate or commuter air carrier authority (See, e.g., Order ): Applicants shall not advertise, list schedules, or accept reservations for the operations covered in their applications before their applications have been approved. Applicants shall not accept payment or issue tickets for the operations covered by their applications before the authority granted in their approved applications has become effective or DOT issues a notice authorizing such sales. Applicants that have received DOT approval for their proposed operations shall not advertise or publish schedules before they also possess effective “safety” authority from the Federal Aviation Administration, unless such advertising or schedule prominently states: “ This service is subject to receipt of government operating authority.”

11 Disclosure: Codeshare (14 CFR Part 257) Change of Gauge (14 CFR Part 258)
On codeshare flights to, from, or within the United States, or long-term wet leases, the identity of the airline actually providing the transportation, including its corporate name, must be disclosed. See 14 CFR Part 257. Notice must be provided as follows: By an asterisk or other identifying mark in the written and electronic schedule information that airlines provide to the public, to the Official Airline Guide and comparable publications, and to computer reservations systems (14 CFR 257.5(a)); Orally by any airline or ticket agent before booking transportation in any direct oral communication in the United States with a prospective consumer and in any telephone calls placed from the United States (14 CFR 257.5(b)); In writing on an itinerary or in separate written notice accompanying the passenger’s ticket or, if time does not allow for advance notification or in the case of e-tickets, no later than the time that the passenger checks in at the airport for the first flight in an itinerary involving a code-share service or a long-term wet-lease service (14 CFR 257.5(c)); and In printed advertisements and radio and television broadcasts made in the United States (14 CFR 257.5(d)). When an airline offers change-of-gauge service, or service that requires a change of aircraft en route but has only a single flight number, to, from, or within the United States, the en-route change of aircraft must be disclosed. See 14 CFR Part Notice must be provided as follows: In the written and electronic schedule information that airlines provide to the public, to the Official Airline Guide and comparable publications, and to computer reservations systems ( 14 CFR 258.5(a)); Orally by any airline or ticket agent doing business in the United States before booking transportation in any direct oral communication with a consumer in the United States (14 CFR 258.5(b)); and In writing, using language specified in the rule, at the time of sale or, if no ticket is issued, no later than the time when the passenger checks in at the airport for the first flight in an itinerary that includes a change-of-gauge service (14 CFR 258.5(c)).

12 Advertising: Unrealistic Scheduling (14 CFR 399
Advertising: Unrealistic Scheduling (14 CFR (a) On-time Performance Ads (14 CFR (b)) On-time Performance Disclosure (14 CFR ) Pursuant to section (a), airlines may not publish schedules that they cannot reasonably expect to achieve (e.g., schedules listing chronically late flights). Significant and routine failures to meet published flight arrival times has resulted in enforcement action against several large airlines. The routine cancellation of flights for economic reasons is prohibited. See Order Pursuant to section (b), ads making on-time performance claims must state: The basis of the on‑time performance calculation; The time period involved; The pairs of points or percentage of system operations involved; and Whether the on-time performance figures presented represent all scheduled flights or only those that operated. Pursuant to 14 CFR Part 234, the largest U.S. carriers (currently 18) are required to report their on-time performance to DOT and include information on the on-time performance of their flights in computer reservation systems. Each month DOT publishes the carriers' reported data. In view of the widespread availability of the reported on-time performance information, DOT permits the carriers subject to Part 234 some flexibility in publishing on-time performance comparison ads provided that the ads: Are accurate; Are based on (and state they are based on) flight arrival data published by DOT; State the time periods covered by the on-time performance claims (e.g. April 2007); and Accurately identify the carriers or types of carriers (e.g. " seven largest") used in any comparisons. See, e.g., Order During the course of reservations or ticketing discussions or transactions, or inquiries about flights, airlines must disclose, upon reasonable request, the on-time performance of their domestic flights.

13 Refunds (14 CFR Part 374) When a refund is due:
Airlines must forward a credit to the credit card company within seven days after receiving a complete ticket refund application. See 14 CFR Part 374 and Regulation Z: section (e)(1) of the Federal Reserve Board. Refunds for cash and check sales of tickets must be made within 20 days of the carrier receiving a complete refund application. See, e.g., Order , Order

14 Oversales (14 CFR Part 250) Part 250 permits airlines to sell more tickets for a flight than there are seats on the aircraft, which allows carriers to account for "no –shows.“ In exchange, the rule mandates compensation and other protection for ticketed passengers denied boarding. Airlines must first seek volunteers willing to give up their reservation in exchange for compensation of the airline’s choosing. To be eligible for involuntary denied boarding compensation - The passenger must hold a confirmed reservation; The passenger must meet the carrier's check-in deadline; The flight involved must be departing from a point in the U.S.; The flight must be with an aircraft having 30 or more seats; and The passenger must be bumped from the planned flight and not be rerouted to arrive at his or her ultimate destination within one hour of the passenger's original planned arrival time. The amount of denied boarding compensation (DBC) to which a passenger is entitled is based on the cost of the ticket, the length of the delay and whether the flight is domestic or international. Where the delay is 1 to 2 hours (4 hours on an international flight), the DBC is 100% of the passenger’s one-way fare up to a $400 maximum. Where the delay is over 2 hours (4 hours on an international flight) , the DBC is 200% of the passenger’s one-way fare up to a $800 maximum. Involuntary DBC must be paid on the carrier’s initiative by cash or check within 24 hours unless the passenger agrees to accept another form of compensation (e.g., a free ticket for a future flight.) DBC is not required if the airline substitutes aircraft for safety or operational reasons. Passengers can decline DBC and sue carriers for damages.

15 Baggage Liability Domestic Flights. Pursuant to 14 CFR Part 254, on flights with aircraft having seating for more than 60 passengers and any other domestic flight on the same ticket, airlines may not limit their liability for baggage damage, loss, or delay of delivery to less than $3,300 per passenger. In addition, pursuant to 14 CFR , the liability limit for disabled traveler assistive devices is the original purchase price of the device. International flights. Pursuant to the Montreal Convention, the liability limit for most international flights is 1,000 Special Drawing Rights (SDR). The SDR fluctuates daily; the current value may be found at Recently, one SDR has equaled US$ The 1000 SDR limit applies to assistive devices.

16 Notices to Passengers Certain DOT rules require that passengers be provided certain notices about their rights on or with tickets and via airport signs. Ticket notices are required on the following subjects. (A DOT policy statement recognizing on e-tickets allows notices usually provided with tickets to be provided to air travelers using e-tickets by , fax or before boarding at the airport. (62 FR 19473; April 22, 1997)): Oversales. See 14 CFR Domestic Baggage Liability. See 14 CFR International Baggage Liability. See 14 CFR Incorporated Contract Terms. See 14 CFR and Fare Increases and Penalties - Domestic. See 14 CFR Fare Increases - International. See 14 CFR Death/Injury Liability Limits - International. See 14 CFR Airport signs are required for Oversales, International Baggage Liability, Availability of International Tariffs and Death/Injury Liability Limits. Other international ticket notice and signage provisions are contained in 14 CFR Part 221, Subpart K.

17 Contract of Carriage (14 CFR Part 253)
Part 253 permits carriers to incorporate the passenger/airline contract (i.e. the contract of carriage) by reference into the airline ticket but mandates procedures for disclosing those terms. The contract of carriage must be available for inspection at the airline's airport and city ticket offices and free copies must be mailed upon a request to the airline's headquarters. Every ticket must disclose in general terms - That there are contract terms incorporated by reference; That those terms constitute a contract; How to inspect and obtain copies of the contract; The liability limits for injury and lost or damaged baggage; Claim restrictions including deadlines; Rights of carrier to change contract terms; Rules on reconfirmation and check-in times; and Carrier rights on flight delays and rerouting. Carriers must provide direct notice on tickets in order to enforce any contract term that- Restricts ticket refund ability; Imposes monetary penalties; or Permits the carrier to raise a price. The contract of carriage can serve as the basis for a passenger lawsuit if its terms are breached.

18 Public Charters (14 CFR Part 380)
Before any advertising or sales take place, a Public Charter (PC) operator must have a contract with an airline to provide the air service to be sold and then submit a PC prospectus to DOT. Fare advertisements for PCs must disclose the fact that it is a charter flight, the identity of the airline, and the fact that an operator/participant contract must be signed before a sale can be made. The operator/participant contract discloses key features, rights and obligations associated with the PC. Changes in dates, cities or hotels, or price increases totalling more than 10%, give passengers the right to cancel without penalty. The rule restricts flight cancellations and price increases during the last 10 days before departure. Passenger payments must be protected by escrow accounts and surety agreements until the air transportation is completed.

19 Smoking (14 CFR Part 252) Liability Insurance (14 CFR Part 205) Special Event Tours (14 CFR Part 381) Smoking restrictions. Smoking is prohibited in the passenger cabin and lavatories on scheduled flight segments by U.S. and foreign carriers flying in, to and from the U.S. On flights of U.S. air carriers where smoking is not banned (e.g., domestic charters), the carrier must -- Provide a no-smoking section in each class of service; and Expand the no-smoking sections if necessary to accommodate every passenger meeting the check-in deadline who requests a no-smoking seat. Liability Insurance. DOT rules set specific accident liability insurance requirements for air carriers. Special Event Tours Rule applies to tour operators selling air tours that are promoted as including a ticket to a special event (e.g., a football bowl game). The tour operator must have enough special event tickets on hand, or a written contract with the distributor for such tickets, before advertising or promoting the tour. If a consumer who pays for the tour does not receive a promised special event ticket, he or she must be refunded the entire tour price after the tour.

20 Family Assistance After Aviation Disasters (49 USC §§ 41113 & 41313)
The Aviation Disaster Family Assistance Act of 1996, as amended, (ADFAA) and the Foreign Air Carrier Family Support Act of 1997, as amended, (FACFSA) require certain U.S./foreign airlines (both passenger and cargo) to undertake certain actions in the event of their involvement in an “aviation disaster regardless of its cause or suspected cause” that results in a “major loss of life”. (Excluded from these statutes are air taxis, commuter air carriers, Canadian charter air taxis, and foreign air carriers whose foreign air carrier permits explicitly limit their U.S. operations to small aircraft only, i.e., aircraft originally designed with 60 passenger seats or less.) Those actions are listed as “assurances” contained in “Family Assistance Plans” that are filed with the Department and the National Transportation Board. (Copies of plans are available to the public on the DOT Docket at 1960 and 3304.) Among other things, airlines assure the Department that they will: Establish a toll-free number to handle calls from families of passengers Assist family members in traveling to the location of the accident and provide for their physical care while staying at such location Treat the families of non-revenue passengers the same as those of revenue passengers Retain unclaimed possessions for at least 18 months Geographical scope: Covers only aviation disasters on U.S. soil (includes U.S. territories and other possessions and 12-nautical mile territorial sea)

21 Passenger Manifest Information (14 CFR Part 243)
Information collection requirement: Covered airlines on covered flight segments must collect full name of each passenger who is a U.S. citizen (passengers who refuse must not be boarded); covered airlines must solicit contact name/number for each passenger who is a U.S. citizen (passengers are not required to provide the information). Covered airline: all foreign air carriers, except those holding DOT economic authority to operate small aircraft only. Therefore, Part 294 Canadian charter air taxis are not covered by this rule. Covered flight segment: any passenger carrying flight segment (scheduled or charter) to/from U.S. (Note contrast with geographical scope of applicability of family assistance statute, 49 U.S.C. § ) In the event of aviation disaster, covered airlines must transmit manifest information as quickly as possible to the U.S. State Dept., but no later than three hours after learning of the disaster. Collection plan filed with DOT (DOT Docket 3305)

22 Passengers with Disabilities (14 CFR Part 382)
The Air Carrier Access Act of 1986, 49 U.S.C. § 41705, mandates that DOT protect the rights of disabled air travelers. DOT has promulgated detailed rules in 14 CFR Part 382 to effectuate this mandate. Currently, 14 CFR Part 382 applies only to U.S. carriers but does serve as guidance on the application of section to foreign carriers serving the U.S. Amended Part 382 will apply to foreign carriers beginning in May 2009. The rules specify discriminatory practices that are prohibited. For example - Unless specifically permitted by a provision in 14 CFR Part 382, carriers may not refuse transportation to people on the basis of handicap, which is defined broadly in the rule. Airlines may exclude anyone if carrying the person would be inimical to the safety of the flight; Airlines may not require advance notice that a handicapped person is traveling except in very limited circumstances; Carriers may not limit the number of handicapped persons on a flight; Carriers may not require handicapped persons to travel with an attendant except in certain specified circumstances; and Carriers may not exclude passengers with disabilities from any seat unless an FAA safety rule mandates such seating. See 14 CFR which specifies FAA exit seating requirements. New aircraft have to have features to accommodate the handicapped. For example - New aircraft with 30 or more seats must have movable arm rests on at least half the aisle seats; and New wide body aircraft must have lavatories that are accessible to the handicapped. Airlines are also required to provide certain special services and accommodations for the handicapped. For example - Airlines must provide assistance in boarding, deplaning and making connections; Wheelchairs and other assistive devices have priority for in-cabin and baggage compartment storage space; and Carriers must accept battery-powered wheelchairs for carriage and must provide any necessary safety packaging at no cost to the disabled passenger. The Department rules also incorporate a number of administrative provisions. For example - Specific training is required of airline personnel; Airline procedures for complying with the rules must be submitted for DOT review; and Airlines must designate special "complaints resolution officials" to respond to complaints with prescribed deadlines.

23 Enforcement Procedures
DOT has a detailed set of regulations prescribing procedures to be used in enforcement cases. They are referred to as the Department's Rules of Practice. See 14 CFR Part 302. Certain of the rules apply generally to all adjudicatory proceedings before DOT (e.g., filing and service requirements). See 14 CFR Part 302, Subpart A. Specific Rules of Practice are set forth for enforcement cases. See 14 CFR DOT also has Rules of Conduct that regulate the activities of persons involved in DOT proceedings (e.g., ex parte contact restrictions). See 14 CFR Part 300.

24 Enforcement Procedures
49 USC – authority to investigate potential violations Initiation of Investigation On AEP’s own initiative or by referral from within DOT or FAA Informal (e.g., by letter or telephone call to AEP, usually by consumers or competitors) Formal (14 CFR ; docketed complaint by third party requiring answer by respondent) Investigative Tools 49 U.S.C and provides DOT the authority to order reports from air carriers and to inspect the premises of airlines and ticket agents 49 U.S.C provides for the issuance of subpoenas 14 CFR Part 305 provides for nonpublic investigations, with subpoena authority and testimony to be heard before a DOT Administrative Law Judge, if necessary. Little difference in process between formal and informal investigations AEP reviews complaint, seeks answer from respondent, conducts further inquiry if necessary from any person, and determines if evidence supports finding a violation.

25 Penalties Penalties/Remedies
Warning letter; may be accompanied by letter of agreement to take corrective action Order to cease and desist from similar conduct in the future Civil Penalties 49 U.S.C For non-small businesses, up to $25,000 per day per violation of permit authority, cabotage, and civil rights and consumer protection statutes and regulations (raised in 2003 from $1,100 by Vision 100) “Small business concerns” and individuals are liable for penalties of up to $1,100, $2,500, or $10,000 per day per violation of permit authority, cabotage, and civil rights and consumer protection statutes and regulations, depending on the nature of the violation Other Penalties Suspension or revocation of economic authority of an air carrier Permanent or temporary ban of individual from involvement in air transportation Criminal penalties under 49 U.S.C for knowing and willful violations with referral generally made to the DOT Inspector General

26 Procedure If Settlement Is Not Possible
Civil penalties can be assessed and cease and desist orders issued, but only after notice and hearing, unless settlement can be reached If settlement cannot be reached AEP may file formal enforcement complaint Involves a trial-type hearing before a DOT Administrative Law Judge (ALJ) ALJ decision may be appealed to DOT (Secretary or DOT decisionmaker) DOT’s final order may be appealed by respondent to U.S. Court of Appeals Injunction in U.S. District Court AEP may go directly to U.S. District Court to seek an injunction from violations of statutes or DOT orders – used only in extreme cases and very rare

27 Settlement Practices • Importantly, cease and desist orders and civil penalty assessments can be issued only after respondent has had an opportunity for notice and hearing -Hearings are extremely time consuming and resource-intensive processes, and often have no assurance of success, particularly where there are no existing rules defining unlawful conduct • Where violations are found, attempts to conserve government and private resources alike by settling the matter short of litigation are always made and are generally successful • Settlement is based on various factors, including: -Nature and extent of the violation -Actual or potential harm to consumers -Chance of success if litigated -Precedential value of the case -Size and economic condition of respondent company -Cooperativeness of respondent company

28 Settlement Practices AEP’s settlement practices are seldom understood and often misdescribed by those outside the industry. ● AEP has no authority to adjudicate consumer claims and/or make monetary awards to consumers. However, settlement is often structured to include added incentives to the carrier/violator to refrain from future similar violations, to enhance consumer services above and beyond what is required by DOT rules, and/or to educate the public and other carriers regarding DOT requirements. Examples include: - Suspension and potential forgiveness provision The respondent pays a significant portion of the assessed civil penalty and a portion, generally half, of the remaining assessed civil penalty is suspended for one year or more and ultimately forgiven if the respondent commits no further similar violations during that time period - Offset provision The respondent usually pays a portion of the civil penalty up front and another, often significant, portion of the civil penalty otherwise due the government is offset to the extent that the respondent takes certain specified action to improve services provided to consumers above and beyond what would otherwise be required by DOT rules, benefiting the public, not the Federal Treasury.

29 Assessed Civil Penalties (2000 – May 2008)
Advertising $2,492,000 Unauthorized operations $6,291,000 Civil rights (incl. disability) $13,390,000 Other consumer $2,210,500 Reporting $365,000 Total $24,748,500

30 Assessed Civil Penalties 1996-May 2008
Year Aggregate Penalty* Suspended Penalty** Total Orders $1,287, $460, $730, $290, $336, $145, $336, $219, $265, $37, $444, $206, $2,172, $806, $8,108, $521, $5,627, $774, $3,987, $842, $2,236, $796, $1,433, $726, May $475, $237, * Includes amounts that carriers were required to expend for civil rights training ** Includes suspended and ultimately forgiven civil penalties but not offsets where carriers expended sums that are included in aggregate civil penalty amounts to provide benefits to consumers above and beyond what was required by statute or DOT regulations.

31 Requests for Information
Consumers U.S. Congress Private attorneys News media Academics Foreign governments

32 Public Education & Outreach
“Air Travel Consumer Report” Other consumer publications Web site News media relations

33 Air Travel Consumer Report
Monthly publication with statistics on: Mishandled baggage Delayed and canceled flights Oversales Consumer complaints Security complaints Loss, injury or death of pets

34 Other Available Consumer Publications
Fly-Rights Tell It To The Judge New Horizons: Information for the Air Traveler with a Disability Plane Talk fact sheet series When Kids Fly Alone

35 News Media Relations “Consumer Alert” news releases Interviews
Customized complaint data and complaint examples

36 Monitoring Airline Service Quality
Consumer-reported: ■ Passenger complaints – may refer violations to Legal Division Carrier-reported: ■ Reports on oversales, mishandled baggage, on-time performance ■ Required traffic and financial data (T-100, O&D Survey) Other government agency-reported: ■ FAA operations data (e.g.,causes of flight delays) Methodology: ■ Use data to assist in reviewing specific complaints ■ Use data to identify industry trends

37 Web site: www.airconsumer.ost.dot.gov
Content: Consumer publications How to file a complaint (incl. web form) ‘Industry Letters’ (guidance for airlines) Fact sheets (bankruptcies, strikes) Links to safety and security information Format: Handicap accessible Spanish version

38 AEP CONTACT INFORMATION For licensing information: For enforcement information: • AEP main office: • Website: click on “Rules and Guidelines” for guidance documents For consumer information: • Online complaint form: click on “Filing a complaint” • Voic consumer complaint line: • Disability Hotline: (voice) (TTY)

39 Questions?


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