### u.s. Department 

### of

Transportation Office of the secretory of Transportation 

# Memorandum

Subject:
From: Notice of Communication:

~ocket: DOT-OST-2014-0056) B~~ Acting Assistant General Counsel

.Office ofAviation Enforcement and Proceedings Date: June 12, 2014

To: Chief, Dockets Please place this memorandum and the attached document in the appropriate file and in the Docket. Communication: Telephone Conference Regarding Regulatory Impact Analysis (RIA) Prepared in connection with Transparency ofAirline Ancillary Fees and Other Consumer Protection Issues NPRM Participants: Blane Workie, Office ofAviation Enforcement and Proceedings Kimberly Graber, Office ofAviation Enforcement and Proceedings Daphne Federing, HDR Engineering Inc. Thomas Gregorson, Airline Tariff Publishing Company (ATPCO) Summary of Conversation: On June 2, 2014, Blane Workie, Kimberly Graber, and Daphne Federing participated in a telephone conference with Thomas Gregorson. Department staff explained that they could not discuss the substance ofthe NPRM, and that the discussion would be summarized and placed in the docket. Mr. Gregorson stated that certain information stated in the Regulatory Impact Analysis (RIA) prepared in connection with the Department's NPRM regarding Transparency ofAirline Ancillary Fees and Other Consumer Protection Issues is incorrect. Specifically the RIA stated that" ATPCO charges the airline approximately $3,000 per month to file ancillaries" on page 49. The Regulatory Impact Analysis cited a Sabre document as the source ofinformation. The cited information was stated both in a Sabre document and in other publically available documents.

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Mr. Gregorson questioned this number and stated that it does not seem to be

correct based on 2011 as well as current ATPCO pricing for ancillary services. He explained that ATPCO does not charge airlines $3000per month to file ancillary service fee information. He noted that these numbers could be significantly overstating the ATPCO costs associated to the airlines for the distribution ofancillary fees. ATPCO requested acopy ofthe source document for review. Department staff informed Mr. Gregorson that both Department staff and HDR examined a wide range ofsource material for evidence ofthe likely costs and benefits ofthe proposed rule. This included direct requests for information from businesses, including ATPCO, trade associations and other organizations that might have relevant cost information (i.e., "primary" data); and information from other published and unpublished research and analysis regarding those costs (i.e., "secondary" data). To prepare an estimate for the likely additional costs offiling information for ancillary services, HDR used a secondary source which presented data on the additional per carrier fee to ATPCO for filing ancillaries. The fee of$3,000per month ($36,000annually) was used to estimate the cost for transmitting that data, whether paid by carriers as a direct fee to ATPCO or recovered in another manner. Department staff further informed Mr. Gregorson that the Department always welcomes additional and clarifying information directly from interested parties. Department staff and HDR will carefully evaluate all comments submitted during the public comment period, including any comments submitted by ATPCO, in order to refine its estimates ofcosts and benefits ofthe rille. Mr. Gregorson also requested a copy ofthe source document. We are providing the requested information to ATPCO and it is also attached here.;'. 

# r=------------.------------------~ Ancillary fee disclosure using ATPCO-OC

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# _-- • Forthese consumers to be apprised of the true total price of airtransportation, at least
.. core ancillary fee information must betransmitted and presented to agents in an automated, efficient, and readily useable manner via the systemsagents use by agents to comparison shop for air travel services - i.e. the GDSs 

## ;. 10ensure this, airlines must transmit this information to the GDSsusingthe AIPCD-DC data standard (unless and until the airline and GDSagree to adifferent processor data standard other than that of the airline-owned AIPCD)

• All major UScarriers havetested AIPCD-DC, and the GDSshave invested significantly to support this data standard

,. Airlines already useAIPCD to file published and private fares, and the carriers can now file ancillaries via AIPCD, with the ability to dynamically manage ancillaries

• Ancillary information can be filed through AlPCD aspart of the carrier's overall fare filing process, or directly with the GDS(using the 

## DC data standard)

• AlPCD chargesthe airline approximately $3,000 per month to file ancillaries



## • DC data standard already accommodates 130 different categories of ancillaries - for which price/applicability can vary by9frequent traveler tiers (seeslide in

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# GDSsystem enhanced for ancillaries Technical Standards Enable Broad and Rapid Deployment of Ancillaries Availability, Seats, FF# ANCILlARIES 

## No GDSfee for selling ancillaries

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## 100's of airlines Edifact or XML BASE FARES Public I Privat~ I Fitre Rules ANCILlARIES Public IPtivote Ifore Rules TransKtlonal (or notl Fl'TIerlevel
Edifact or XML BASE FARES Publi(. I Private 1 Fare Rules ANCillARIES Public I Private I Fa•• Rul•• TransKtIcNoI(or noll Fl'Tier level

ARC 

# II
Global BSPs Airline Tariff Publishing Company



### G S SHO ING ENGINE Hundreds of Airlines Millions of Fares Billions of Combinations
FULFillMENT ANCillARIES Electronic Mise. DoaJlnenls AGENT WORKSPACE

CORPORATE BOOKING TOOL 

### OTA's 

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