Comments
in Opposition To The DOT's Proposed Changes To Rules Governing
CRS Usage
March 14, 2003
Norman Y. Mineta
Secretary of Transportation
US Department of Transportation
400 Seventh Street, S.W.
Washington, D.C. 20590
Dear Secretary Mineta:
Writing on behalf of the airlines most significant
customer base, business travelers and the companies which fund
their trips, I am compelled to advise you that the proposed changes
to the rules governing the use of Computer Reservation's Systems
represent a major reversal of every hard-fought consumer protection
clause in the current regulations. Not only will they frustrate
current attempts to reach a long-term solution to the airlines'
problems, they will further encourage corporations to seek alternatives
to flying.
1) The airlines maintain the proposed changes
will lower distribution costs, and (by inference) airfares. Considering
the financial status of the nation's carriers, this commitment
to discounting travel seems unrealistic at this time.
2) Removing the regulation that that airlines
must provide equal access to all fares offered on the CRS will
drive up cost in three ways:
-- By opening the door to CRS/airfare bias
-- By deliberately complicating the airfare search process (driving
up process time)
-- By virtually requiring corporations or travel agencies to subscribe
to multiple CRS systems
3) The proposed changes will require the introduction
of entirely new process for corporate travel departments and their
agencies. The expense of retrofitting and retraining will ultimately
come out of existing travel budgets.
4) The proposed changes introduce an additional
annual negotiation between carriers and CRS subscribers.
5) The benefits associated with the dangled carrot
of greater Web fare accessibility (long sought after by business
travel managers) are offset by competitive safeguards that would
now be lost under the proposed changes.
I regret that there is no silver-lining in the
CRS rule changes as proposed: not for business travelers, not
for their corporations, nor for the airlines. I respectfully suggest
that the Department of Transportation abandon these changes in
pursuit of realistic long-term changes, with mutual benefits,
that encourages business travel and a healthier economic environment
for the transportation industry.
Sincerely,
Mark Williams
President
Association of Corporate Travel Executives
