### BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

________________________________ In the Matter of: )

)

Advisory Committee on Aviation ) Docket DOT

- OST

- 2012

- 0087

Consumer Protection )

________________________________ )

COMMENTS OF U.S. TRAVEL ASSOCIATION

Communications with respect to this document should be addressed to:

Roger Dow

President and Chief Executive Officer

U.S. Travel Association

1100 New York Avenue, NW

Suite 450

Washington, DC 20005

Erik Hansen

Senior Director, Domestic Policy

U.S. Travel Association

1100 New York Avenue, NW

Suite 450

Washington, DC 20005

March 26

, 2014

### BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

________________________________ In the Matter of: )

)

Advisory Committee on Aviation ) Docket DOT

- OST

- 2012

- 0087

Consumer Protection )

________________________________ )

COMMENTS OF U.S. TRAVEL ASSOCIATION

The U.S. Travel Association is the national, non

- profit organization representing all

components of the American travel industry. We are pleased to submit the attached

national survey of business and leisure trav elers for consideration by the Advisory

Committee on Aviation Consumer Protection as it makes recommendations and by the

Department of Transp o rtation and the Office of Management and Budget as they

formulate rules relating to giving travelers the ability to both comparison shop for and

purchase key ancillary services along with base fares when they buy air travel through

airlines and ticket agents.

The survey of 1,031 U.S. business and leisure travelers was conducted Feb ruary 5

, 2014, through February 12 , 2014

.

Among the findings, the survey found that n early half of all travelers find airline ancillary

fees to be the most frustrating aspect of air travel, while nearly three

- quarters say these

ancillary fees have become increasingly frustrating in the past year.

The survey further found that nearly half of travelers surveyed (45%) find it difficult to

accurately budget for air travel due to the proliferation of ancillary fees and difficulty

determining their cost. One

- quarter of all respondents report having to pay a n ancillary

fee at the airport that they did not anticipate.

The survey found strong support ( 92%) for a rule from the Department of Transportation

(DOT) to give travelers’ the ability to both see and purchase the full cost of their travel,

including core fees such as for baggage and seat s, when shopping through traditional

travel agencies and online travel sites. The survey also found that U.S. travelers are

open to flying more frequently if the hassles associated with air travel were improved

. Three

- in

- five (60%) travelers surveyed said they would take

, on average

, 2.6 more trips

per year if hassles at the airport were reduced or eliminated.

### As an industry that generates $2.0 trillion in economic output and supports 14.6 million

jobs , travel is vital to our nation’ s economy

. We hope the submission of th ese survey

finding can assist with the formulation of a rule by DOT , and clearance of that rule by

OMB

.

Respectfully submitted,

Roger Dow

President and Chief Executive Officer

U.S. Travel Association

Attachment

## US Travel Survey

Topline Report

METHODOLOGY

Below are several findings o f the survey of US fliers, conducted on behalf of the U

. S

. Travel Association by

ResearchNow, an independent research company. Interviews were conducted online between February 5

- 12,

2014, among a nationally representative audience of 1,031 U.S. business and leisure travelers. The precision

of online polls is cal culated using a credibility interval with a poll of 1,000 accurate to +/

- 3.5 percentage

points.

Notes:

 All questions were asked of the entire sample unless otherwise indicated.

 Numbers may not add up to 100% due to rounding.

 Where shown the asterisks (* ) indicate percentages that fall below 0.5% but above 0%.

QUESTIONNAIRE

Q1. Over the past year, has the air travel process become more or less of a hassle or stayed roughly the

same?

Total Leisure Business

More of a hassle 2 7 % 28% 23%

Less of hassle 11% 10% 12%

Stayed roughly the same 62% 61% 64%

Don’t know 1% 1% 1%

Q2. Which of the following are you most concerned about before taking a trip by air?

Total Leisure Business

Delays 30% 28% 3 5 %

Airline fees (i.e., fees for bags, seat assignments, boarding priority) 26% 29% 21%

Safety 11% 11% 10%

Cancellations 9% 9% 9%

Security screening 8% 8% 9%

Unknown seat assignments 3% 3% 4%

Terrorism 3% 3% 2%

Taxes paid as part of the airline ticket 1% 1% 1%

Other 2 % 2% 1%

No concerns 6% 5% 9 %

Don’t know 1% 1% *Q 3 . Which of the following aspects of air travel, do you find most frustrating? Select up to three.

Total Leisure Business

Delays and cancellations 49% 48% 50%

Airline fees for checked bags, flight changes, seat assignments, etc. 45% 47% 42%

Overall cost of flying 37% 39% 33%

Security screening process 30% 30% 29%

Airline customer service 10% 9% 11%

Government taxes on airline tickets 9% 8% 11%

Ability to accurately determine the total cost of air travel before a trip,

including ticket prices, fees for bags, seat assignments, etc. 9% 9% 8%

Airport accommodations 4% 3% 5%

Other 3% 2% 5%

Don't know 1% 1% 1%

Q 4 (1

- 8 )

. Over the past year, please rate if the following aspects of air travel have become frustrating,

remained the same or improved.

Showing All

Ranked by Total More

Frustrating Much

more

frustrating Somewhat

more

frustrating Remained

the same Somewhat

improved Much more

improved Total

More

Frustrating Total

Improved

Airline fees for checked

bags, cancellations, flight

changes, seat assignments,

etc. 33% 39% 26% 1% 2% 71% 2%

Overall cost of flying 26% 42% 29% 1% 2% 68% 2%

Flight delays and

cancellations 15% 31% 47% 2% 4% 46% 6%

Government taxes on

airline tickets 12% 26% 55% * 2% 38% 2%

Ability to accurately

determine the total cost of

air travel before a trip,

including ticket prices, fees

for bags, seat assignments,

etc. 10% 25% 53% 4% 7% 35% 11%

Security screening process 12% 20% 52% 7% 10% 32% 16%

Airline customer service 9% 20% 61% 4% 6% 28% 9%

Airport accommodations 4% 10% 71% 4 % 5% 14% 10%Showing Leisure Travelers

Ranked by Total More

Frustrating Much

more

frustrating Somewhat

more

frustrating Remained

the same Somewhat

improved Much

more

improved Total

More

Frustrating Total

Improved

Airline fees for checked

bags, cancellations, flight

changes, seat assignments,

etc. 36% 39% 24% * 1% 75% 1%

Overall cost of flying 28% 43% 28% * 2% 71% 2%

Flight delays and

cancellations 16% 31% 48% 2% 3% 46% 5%

Government taxes on

airline tickets 13% 27% 53% * 1% 41% 1%

Ability to accurately

determine the total cost of

air travel before a trip,

including ticket prices, fees

for bags, seat assignments,

etc. 12% 25% 51% 4% 7% 37% 11%

Security screening process 13% 22% 50% 6% 9% 34% 15%

Airline customer service 9% 20% 60% 3% 6% 29% 10%

Airport accommodations 4% 10% 71% 3% 5% 13% 9%Showing Business Travelers

Ranked by Total More

Frustrating Much

more

frustrating Somewhat

more

frustrating Remained

the same Somewhat

improved Much

more

improved Total

More

Frustrating Total

Improved

Airline fees for checked

bags, cancellations, flight

changes, seat assignments,

etc. 26% 39% 29% 2% 3% 65% 5%

Overall cost of flying 22% 42% 33% 1% 2% 63% 3%

Flight delays and

cancellations 12% 32% 46% 3% 5% 45% 8%

Government taxes on

airline tickets 10% 22% 59% 1% 2% 32% 3%

Ability to accurately

determine the total cost of

air travel before a trip,

including ticket prices, fees

for bags, seat assignments,

etc. 6% 25% 56% 4% 7% 31% 11%

Security screening process 10% 18% 54% 8% 11% 27% 18%

Airline customer service 8% 20% 62% 4% 5% 28% 9%

Airport accommodations 4% 11% 70% 6% 5% 15% 11%

Q5. Now thinking back over the past year, have you chosen not to take any BUSINESS trips because problems

with the air travel system made the trip seem like more of a hassle than it was worth?

Total Leisure Business

Yes 17% 15% 2 2 %

No 79% 80% 77%

Don’t know 4% 5% 1%

IF YES

Q5a. Just as your best guess, how many more BUSINESS trips do you think you would have taken with a more

efficient air travel system?

Total Leisure Business

0 4% 6% 1%

1 19% 21% 16%

2 37% 41% 33%

3 21% 18% 25%

4+ 19% 15% 25%

Mean 2.41 2.21 2.69Q6. Now thinking back over the past year, have you chosen not to take any PERSONAL or LEISURE trips

because problems with the air travel system made the trip seem more of a hassle than it was worth?

Total Leisure Business

Yes 30% 26% 30%

No 70% 71% 69%

Don’t know 2% 2% 1%

Q6a. Just as your best guess, how many more PERSONAL or LEISURE trips do you think you would have taken

with a more efficient air travel system?

Total Leisure Business

0 1% 1% 0%

1 29 % 27% 31%

2 45% 44% 45%

3 11% 12% 9%

4+ 15% 16% 14%

Mean 2.18 2.21 2.14

Q7. Suppose that the hassles at the airport could be reduced or eliminated, do you think you would end up

taking more trips each year?

Total Leisure Business

Yes 60% 62% 56%

No 22% 21% 25%

Don’t know 18% 17% 19%

IF YES: Q7a. Just as your best guess, how many more trips do you think you would take in a year?

Total Leisure Business

0 0 % 0 % 0%

1 12 % 11 % 13 %

2 45% 4 7 % 4 3 %

3 21 % 21 % 21 %

4+ 22 % 21 % 23 %

Mean 2. 63 2. 62 2. 66Q10 . Over the past year, do you think the cost to travel by air has increased, stayed roughly the same or

decreased?

Total Leisure Business

Significantly increased 32% 35% 28%

Somewhat increased 49% 49% 51%

Stayed roughly the same 16% 15% 17%

Somewhat decreased 0 % * *

Significantly decreased 1 % 1 % 1 %

Don’t know 1% 1% 2%

Categories

Total Increased 82% 83% 79%

Stayed the same 16 % 15 % 17 %

Total Decreased 1% 1% 2%

IF PRICES HAVE INCREASED

Q11 a. Which of the following factors , in your opinion, is most directly responsible for the increased cost of air

travel?

All

N=843 Leisure

N=563 Business

N=280

Airlines reducing the number of available flights 31% 29% 34%

Increased airline fees for checked baggage, seat assignments,

priority boarding, flight changes, etc. 25% 25% 24%

Jet fuel prices 23% 22% 23%

Ticket taxes and fees 9% 9% 8%

Costs for aviation security 4% 4% 3%

Increased demand for air travel 3% 3% 3%

Don't know 6% 7% 6%Q12 (1

- 9)

. How important are each of the following factors on your decision whether or no t to purchase an

airline ticket?

Showing All travelers

Ranked by Total Important Very

important Somewhat

important Not that

important Not at all

important Total

Important Total Not

Important

The total cost of air travel, including

base ticket fare, airline fees for

checked baggage, seat assignments,

priority boarding, etc. 60% 31% 7% 1% 92% 8%

The cost of an airline ticket (not

including fees for checked baggage,

seat assignments, priority boarding,

etc.) 55% 36% 8% 1% 91% 9%

Flight schedule, including time of

departure and arrival 49% 39% 9% 2% 88% 11%

Total time it takes to fly 33% 42% 19% 5% 75% 24%

Likelihood of flight delays and

cancellations 25% 46% 23% 5% 72% 27%

Loyalty to a specific airline 19% 39% 30% 12% 57% 42%

The total amount of government

taxes and fees on the airline ticket,

but not the ticket cost itself 14% 39% 37% 9% 53% 46%

The hassle of going through airport

security 13% 32% 40% 14% 45% 54%

The rate of a specific government tax

or fee on the airline ticket (e.g. the

Aviation Passenger Security Fee), but

not the ticket cost itself 12% 32% 41% 12% 44% 54%Showing Leisure Travelers

Ranked by Total Important Very

important Somewhat

important Not that

important Not at all

important Total

Important Total Not

Important

The total cost of air travel, including

base ticket fare, airline fees for

checked baggage, seat assignments,

priority boarding, etc. 62% 31% 6% 1% 93% 6%

The cost of an airline ticket (not

including fees for checked baggage,

seat assignments, priority boarding,

etc.) 56% 36% 7% 1% 91% 8%

Flight schedule, including time of

departure and arrival 50% 38% 10% 2% 87% 12%

Total time it takes to fly 33% 42% 19% 5% 75% 24%

Likelihood of flight delays and

cancellations 25% 47% 23% 5% 72% 27%

Loyalty to a specific airline 18% 37% 31% 13% 55% 44%

The total amount of government

taxes and fees on the airline ticket,

but not the ticket cost itself 16% 39% 36% 8% 55% 43%

The rate of a specific government tax

or fee on the airline ticket (e.g. the

Aviation Passenger Security Fee), but

not the ticket cost itself 14% 34% 41% 10% 47% 50%

The hassle of going through airport

security 14% 32% 41% 13% 45% 54Showing Business Travelers

Ranked by Total Important Very

important Somewhat

important Not that

important Not at all

important Total

Important Total Not

Important

The cost of an airline ticket (not

including fees for checked baggage,

seat assignments, priority boarding,

etc.) 53% 36% 9% 1% 89% 10%

Flight schedule, including time of

departure and arrival 48% 41% 9% 2% 89% 11%

The total cost of air travel, including

base ticket fare, airline fees for

checked baggage, seat assignments,

priority boarding, etc. 57% 32% 9% 2% 88% 11%

Total time it takes to fly 32% 43% 18% 6% 75% 24%

Likelihood of flight delays and

cancellations 26% 45% 22% 5% 72% 27%

Loyalty to a specific airline 21% 41% 27% 10% 62% 37%

The total amount of government

taxes and fees on the airline ticket,

but not the ticket cost itself 11% 38% 39% 12% 48% 51%

The hassle of going through airport

security 11% 33% 39% 16% 44% 55%

The rate of a specific government tax

or fee on the airline ticket (e.g. the

Aviation Passenger Security Fee), but

not the ticket cost itself 8% 30% 43% 17% 38% 60%

Q13 . How have airline fees for checked bags, flight changes or cancellations, seat assignments or boarding

priorities impacted your air travel behavior?

All Leisure Business

I travel less than I used or planned to 33% 33% 32%

I travel the same as I used or planned to 55% 55% 56%

I travel more than I used or planned to 2% 2% 4%

Other 7% 7% 6%

Don't know 3% 4% 3%Q14 . When planning a trip, how important is it for you to be able to accurately budget the full cost of flying

(including the costs for checked bags, carry

- on bags, advanced boarding, and seat assignments)?

Total Leisure Business

Very important 58% 61% 53%

Somewhat important 34% 33% 35%

Not that important 7% 5% 10%

Not important at all 1% * 1%

Don’t know 1% 1% 1%

Categories

Total Important 92% 94% 88%

Total Not Important 8% 6% 11%

Q15 . When booking a flight, how difficult is it for you to be able to accurately predict the full costs of flying

(including the costs for checked bags, carry

- on bags, and seat assignments)?

Total Leisure Business

Very difficult 7% 6% 7%

Somewhat difficult 38% 39% 37%

Not that difficult 40% 40% 41%

Not difficult at all 14% 15% 13%

Don’t know 1% 1% 2%

Categories

Total Difficult 45% 45% 44%

Total Not Difficult 54% 54% 54%

Q1 6 . During the past year, have you paid an airline fee that you did not anticipate prior to arriving at the

airport?

Total Leisure Business

Yes 24% 2 4 % 24%

No 70% 70% 70 %

Don’t know 7% 7% 7%Q17 . During the past year, have you paid an airline fee that you did not know the actual cost of prior to

arriving at the airport?

Total Leisure Business

Yes 20% 21% 19%

No 73% 72% 74%

Don’t know 7% 7% 7%

IF YES, HAVE PAID AN UNEXPECTED FEE (Q16)

Q18 . Which of the following airlines ’ fee(s) did you pay for that you did not fully anticipate? Select all that

apply.

All

N=243 Leisure

N=159 Business

N=84

Checked bag fee 58% 59% 56%

Seat assignment fee 28% 30% 24%

Carry

- on bag fee 24% 27% 18%

Fee for taking an earlier or later flight although seats are available on

those flights 20% 19% 21%

Flight change fees 13% 13% 13%

Priority boarding fees 12% 11% 13%

Other 6% 6% 5%

Don't remember 3% 2% 4%

IF YES TO Q18 (SPECIFIC CHOICES) 1

Q1 9 (1

- 7) How did each of these fee(s) that you did not anticipate paying make you feel?

Showing All Travelers

Ranked by Very Frustrated Very

frustrated Somewhat

frustrated Not that

frustrated Not

frustrated

at all Total

Frustrate

d Total Not

Frustrate

d

Carry

- on bag fee 72% 26% 2% 0% 98% 2%

Fee for taking an earlier or later flight

although seats are available on those

flights 69% 29% 2% 0% 98% 2%

Flight change fees 69% 28% 0% 3% 97% 3%

Seat assignment fee 64% 31% 4% 0% 96% 4%

Checked bag fee 61% 36% 2% 0% 98% 2%

Other 57% 43% 0% 0% 100% 0%

Priority boarding fees 38% 41% 17% 3% 79% 21%

1 Base size varies on number who paid fee. These numbers are not statistically significant due to small sample size.Showing Leisure Travelers

Ranked by Very Frustrated Very

frustrated Somewhat

frustrated Not that

frustrated Not

frustrated

at all Total

Frustrate

d Total Not

Frustrate

d

Flight change fees 71% 29% 0% 0% 100% 0%

Carry

- on bag fee 70% 30% 0% 0% 100% 0%

Seat assignment fee 65% 31% 4% 0% 97 % 4%

Fee for taking an earlier or later flight

although seats are available on those

flights 63% 33% 3% 0% 98% 3%

Other 60% 40% 0% 0% 100% 0%

Checked bag fee 58% 39% 3% 0% 97% 3%

Priority boarding fees 50% 28% 17% 6% 78% 22%

Showing Business Travelers

Ranked by Very Frustrated Very

frustrated Somewhat

frustrated Not that

frustrated Not

frustrated

at all Total

Frustrate

d Total Not

Frustrate

d

Carry

- on bag fee 80% 13% 7% 0% 93% 7%

Fee for taking an earlier or later flight

although seats are available on those

flights 78% 22% 0% 0% 100% 0%

Checked bag fee 68% 32% 0% 0% 100% 0%

Seat assignment fee 65% 30% 5% 0% 95% 5%

Flight change fees 64% 27% 0% 9% 91% 9%

Other 50% 50% 0% 0% 100% 0%

Priority boarding fees 18% 64% 18% 0% 82% 18%

Q20. As you may know, the U.S. Department of Transportation is currently considering a new rule that would

ensure that consumers are able to see all core fees associated with their air travel such a s baggage fees and

seat fees at the time of purchase and to pay those fees up front.

Based on what you know, do you support or oppose this rule?

Total Leisure Business

Strongly support 68% 68% 68%

Somewhat support 24% 24% 24%

Somewhat oppose 3% 3% 3%

Strongly oppose 1% 1% 1%

Don’t know 5% 5% 5%

Categories

Total Support 92% 92% 92%

Total Oppose 4% 4% 4%Q21

. (1

- 2) Now you will view two opposing statements on the proposed rule by the Department of

Transportation that would ensure consumers are able to see all core fees associated with their air travel such

as baggage fees and seat fees at the time of purchase and to pay those fees up front . After hearing each

statement, please indicate how convincing you believe it is.

All Leisure Business

This rule is unnecessary because consumers can already see and pay for most fees when you buy tickets on

their websites.

Very convincing 9% 10% 7%

Somewhat convincing 27% 28% 24%

Not that convincing 36% 34% 38%

Not convincing at all 27% 25% 29%

Categories

Total Convincing 36% 38% 31%

Total Not Convincing 62% 60% 66%

This rule is necessary because consumers shouldn't have to go to an airline's website, but rather should be

able to comparison shop through online searches or working with a travel agent and can only do so if they

can see and pay for the full cost of travel, including fees.

Ve ry convincing 40% 40% 40%

Somewhat convincing 38% 38% 40%

Not that convincing 16% 17% 15%

Not convincing at all 4% 4% 4%

Categories

Total Convincing 78% 77% 79%

Total Not Convincing 20% 21% 18%

Q 22

. A fter hearing both statements do you support or oppose this proposed rule that would ensure

consumers are able to see all core fees associated with their air travel at the time of purchase and to pay

those fees up front ?

Total Leisure Business

Strongly support 53% 53% 53%

Somewhat support 34% 34% 35 %

Somewhat oppose 7% 7% 7%

Strongly oppose 1% 1% 1%

Don’t know 5% 5% 4%

Categories

Total Support 87% 86% 87%

Total Oppose 9% 8% 9%