BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

------------------------------------------------------

In the matter of: :

:

Final Rule :

Enhancing Airline : Docket No. DOT-OST-2010-0140

Passenger Protections :

------------------------------------------------------

REQUEST TO CLARIFY BAGGAGE RULES AND TO EXTEND EFFECTIVE DATES

The Air Transport Association of America, Inc., the International Air Transport Association, the 

Regional Airline Association, and the Air Carrier Association of America, on behalf of their

members, have a fundamental interest in meeting the new, highly complex and labor intensive 

passenger baggage rules that are currently scheduled to take effect on January 24, 2012. To that 

end, we request that the Department extend the effective date by one year to January 24, 2013 for 

the “baggage allowances and fees” requirements in 14 C.F.R. 399.87 and the “baggage notice”

requirements of 14 C.F.R. 399.85(c). Additional time is necessary for carriers to implement these 

requirements accurately and to preserve the benefits of existing and future automation. Critical 

sources of information needed to comply with these rules do not yet exist. Until the technical 

standards for one or more baggage rule databases are finalized carriers cannot develop the internal 

IT systems and procedures that will interact with these databases. Moreover, stakeholders1are also 

adjusting compliance plans and efforts as the Department continues to clarify specific details of the 

new baggage rules. Simply put, our member carriers cannot develop complex new systems, test, 

populate and update them by the current deadline. This extension would give carriers essential time 

to overcome fundamental changes in baggage rules that require substantial investment and reengineering of carrier reservations, check-in and baggage information systems, in addition to 

retraining of airline employees. We also request additional clarification in several areas.

Overview

The scope of this extension request is very limited, focusing only on certain new baggage 

requirements. U.S. and foreign carriers have met the relatively short deadlines the Department set 

for the vast majority of the final rule published less than seven months ago. This industry 

accomplishment was an enormous undertaking and shows the commitment carriers have to 

implementing the Department’s new rules. However, compliance with the two specific baggage 

rules addressed herein require additional time. The Department recognized the difficulty in meeting 

these baggage rules in the first extension request, when it noted “the difficulties in applying the 

same baggage allowances and fees across an itinerary when they [airlines] cannot readily access 

each other’s fee schedules.”2 In addition, the Department has met with ATPCO on several 

occasions to clarify aspects of the baggage rule and notice requirements and will issue additional 

guidance in the Department’s Frequently Asked Questions (FAQs). The public is not well served 

 

1

Stakeholders in this context include U.S. carriers, foreign carriers, carrier vendors, and other groups providing baggage 

rule information. 

2

76 Fed. Reg. 45183.
2

by proceeding with rules that will only result in consumer harm and confusion, not benefits, 

especially if carriers are forced to proceed with makeshift, almost certainly manual measures before 

compliance is technologically feasible. To ensure maximum public benefits, carriers should focus 

their resources on developing the technology solutions that are necessary to implement these new 

baggage requirements.

As set forth in the attached 12 declarations from U.S. carriers, foreign carriers and vendor that work 

on carrier baggage information systems, complying with the baggage rule and notice requirements 

by January 24, 2012 will be extremely difficult and not in the best interest of passengers. The 

Department’s new baggage rules modify the world-wide management of baggage information that 

has developed over the past 50 years. Existing systems were not built to accommodate downstream 

application of baggage rules or fees and technology does not exist to bridge this gap. IATA 

recently changed this system to require that the “most significant carrier” baggage rules apply to an 

international itinerary. The IATA changes were adopted in 2008, took effect in April 2011, and the 

industry is still working to comply with them.

3

 Changing the fundamentals of this baggage system 

a second time in the same year is consuming carrier and vendor resources further complicating 

compliance by January 2012.

Creating technology solutions to identify which fee to apply and to transmit baggage rule and fee 

data among worldwide airlines is a complex, multistep and multiparty process. The first step in this 

process is creating a product(s) or database(s) of all U.S. and foreign carrier baggage rules and fees. 

We understand that one possible industry solution for this first step will not be completed until 

January 24, 2012. Next, carriers and vendors who manage carrier data systems must determine how 

to access the information in the product(s) or database(s) created in step one. This access must 

account for all the different channels carriers use to communicate with passengers, including 

website, kiosks, and check-in counters at hundreds of airports, many of which currently have little 

or no ability to communicate with other airline systems. Next, carriers must extensively test data 

sharing systems to ensure continued efficient passenger service. We note past passenger system 

problems have severely disrupted passenger service.4 Finally, carriers will have to train employees 

on the baggage rule and fee procedures, a lengthy process.

If an extension is not granted, carriers would be forced to adopt error-prone makeshift procedures 

that would substantially delay passenger check-in, create long lines at airports, substantially reduce 

the availability of automated self-service check-in, including the fast growing popular remote 

check-in systems, increase the likelihood carriers will apply the wrong carrier’s baggage fees that 

will lead to confusion and disenchantment and increase the risk of delayed or lost bags.

5

These 

results were clearly not intended by the Department and would result in substantial harm, not 

benefit, to the public. Agents would have to conduct a manual override at the airport pulling

passenger name record data on an individual passenger basis to determine which carrier’s policies 

and fees apply.6 In most cases, airport check-in counters do not have internet access, which could 

 

3

Sato Statement page 1.

4

For instance (1) U.S. Customs and Border Protection computer systems malfunctioned, preventing the processing of 

thousands of passengers at LAX. See http://www.consumeraffairs.com/news04/2007/08/lax_computers.html; (2) 

failures of Virgin Blue’s Naviatare reservations system in 2010 shut down the airline on two separate occasions, 

resulting in hundreds of flight cancellations and thousands of stranded passengers. See 

http://delimiter.com.au/2010/09/26/navitaire-outage-strands-virgin-blue-passengers/

5 Guillemette Declaration at 15, page 4; Bryant Statement page 2.

6

Player Declaration at 4, page 2; Resnick Declaration at 9, page 4.
3

require carriers to use paper copies of other airline bag rules.7 Agents would have to read and apply 

another carrier’s bag prices and policies for each passenger. Inhibiting automated check-in would 

drive passengers to lobby check-in with carrier agents, generating congestion in airports to the 

detriment of passengers.8 

Therefore, it is in the public interest to delay the application of sections 399.87 and 399.85(c) for 

one year so carriers and vendors can develop solutions that will continue the automated check in 

system and provide timely accurate information to passengers.

Timeline

On April 25, 2011, the Department issued a multi-faceted passenger protection final rule, which 

included extending several rules to foreign carriers, additional contingency plan and customer 

service plan requirements, adopting a four hour tarmac delay rule for international flights departing 

or arriving in the U.S., changing full fare advertising and denied boarding compensation rules, 

prohibiting post-purchase price increases and choice-of-forum provisions and instituted several new 

passenger baggage rule and notice requirements. In June 2011, several different parties petitioned

the Department for a limited effective date extension for several parts of the final rule. On July 7, 8 

and July 21, 22, 2011 the Department held two public forums to discuss the final rule. Both forums 

were well attended by stakeholder representatives and many questions were addressed and many 

others raised.

On July 28, 2011, the Department extended the effective date for full fare advertising requirements

(section 399.84), baggage rule and notice requirements (sections 399.85(b) and (c) and 399.87), 

post-purchase price increases (sections 399.88 and 399.89), flight status notifications (section 

259.8) and reservation hold requirements (section 259.5(b)(4)) to January 24, 2011. On August 19, 

2011, the Department responded to questions raised at the forums by publishing a frequently asked 

questions (“FAQs”) document, on the Aviation Consumer Protection Division, DOT website.9 The 

Department subsequently amended the FAQs to include guidance on baggage notice rules (399.85) 

on September 6, 2011. On October 19, 2011, the Department amended the FAQs to include 

guidance on baggage allowances and fees (399.87). We thank the Department for its engagement 

and willingness to address serious concerns and limitations of industry and the industry’s questions, 

as we see this dialogue as an essential part of successful implementation in the interest of the 

consumer.

Baggage allowance and fees (399.87)

Under 399.87, the Department requires that the same baggage allowances and fees apply to a 

passenger throughout an itinerary that originates or ends in the U.S. In the case of a codeshare 

itinerary originating or ending in the U.S., the marketing carrier’s baggage allowances and fees

must apply throughout the itinerary. For non-codeshare flights to or from the U.S. the baggage 

rules that apply at the beginning of the itinerary must apply to the entire itinerary.

 

7 Resnick Declaration at 9, page 4.

8

Player Declaration at 8, page 3; Resnick Declaration at 9, page 4; Guillemette Declaration at 15, page 5; Stumbo 

Declaration page 2.

9 Answers to Frequently Asked Questions Concerning the Enforcement of the Second Final Rule on Enhancing Airline 

Passenger Protections (EAPP #2 FAQs), found at http://airconsumer.ost.dot.gov/rules/EAPP_2_FAQ_10-19-2011.pdf
4

On October 19, 2011 the Department released 5 pages of guidance on 399.87 that included the 

following additional points:

 In the case of a passenger itinerary composed of more than one ticket, the rule does not 

require a downline carrier to apply the baggage allowances or fees of the first carrier if the 

flight of the first carrier is on a separate ticket from the other flights.

 The baggage allowances and fees that apply at the beginning of a passenger’s itinerary apply 

to the entire itinerary, regardless of whether there are any stopovers in the itinerary.

 Section 399.87 does not prohibit carriers from using the “most significant carrier” (MSC) 

methodology for international flights as set forth in IATA Resolution 302, as conditioned by 

DOT Order 2009-9-20, to determine which carrier’s baggage rules apply to international 

itineraries.

 Section 399.87 and 399.85 apply to baggage “handling” fees. Therefore, any handling fees 

that apply at the beginning of the itinerary apply to all remaining flights in the itinerary.

 Government imposed taxes on baggage fees are subject to the disclosure requirements in 

section 399.85.

 Charging the bag fee in different currencies depending on a passenger’s departure city is 

permitted but the fee applied at the beginning of the passenger’s itinerary (or its close 

equivalent in another currency) must apply throughout.

 Section 399.87 applies to excess, oversize, and special baggage fees, in addition to standard 

checked baggage fees.

 A passenger can be charged for an additional bag or a bag that has become overweight 

because of additional items being placed in the bag. The baggage rules selected by the first 

carrier (the marketing carrier in the case of a code-share on the first flight) would apply.

 The rule does not prevent a carrier from charging a baggage fee each time the baggage is rechecked for domestic itineraries.

Carriers appreciate this specific guidance and are working to incorporate these guidelines into their 

compliance plans. This takes time, however, and certain clarifications naturally raise additional 

questions.

Baggage Notice Requirements (399.85(c))

Section 399.85(c) requires U.S. and foreign carriers, their agents, or ticket agents selling air 

transportation in the U.S., must provide notice of baggage fees at the summary page in an online 

purchase and in all e-ticket confirmations for air transportation to, from, or within the U.S. The 

regulation also stipulates that “fee information provided for a carry-on bag and the first and second 

checked bag must be expressed as specific charges taking into account any factors (e.g. frequent

flyer status, early purchase, and so forth) that affect those charges.” 

On September 6 and October 19, the Department issued additional guidance on this section, which 

included the following significant clarifications:

 Carriers cannot list the carrier’s standard baggage fees for carry-on, first and second checked 

bag fees on the e-ticket confirmation. A carrier must provide specific information to 

consumers about all the factors that cause the fee for a carry-on bag and the first and second 
5

checked bag to vary so passengers can determine for themselves the fees that would apply to 

them.

 A range of fees is not specific enough to comply with this rule.

 Carriers must provide information on e-ticket confirmations regarding baggage fees on 

code-share or interline itineraries. Under section 399.87, the baggage allowances and fees 

that apply at the beginning of an itinerary must apply throughout. Therefore, any disclosure 

under section 399.85(c) must take into account the fees that apply to that itinerary pursuant 

to section 399.87.

This guidance is very valuable to carriers, and requires both time to assimilate and this direction in 

turn has raised additional questions in the carrier community.

Baggage Information Management

The Department’s baggage rules and notice requirements have far reaching impacts. For instance, 

any system that checks in passengers on an itinerary that includes a U.S. destination or origin must 

be updated and automated to ensure it can accommodate the new baggage rule changes.10 

Therefore, carrier airport stations that use Departure Control Systems (“DCS”) to check in 

passengers and provide carrier agents information on the applicable baggage rules must be modified 

to accept information from potentially hundreds of interline and codeshare partners.

11

 A DCS 

handles large amounts of data originating from passengers that book directly with the airline.12 This 

data includes passenger information and baggage rules on the day of check-in.

13

 The DCS must be 

able to process extremely large amounts of information very quickly in order to check in passengers 

and any baggage expeditiously to ensure a smooth passenger experience and to prevent 

overcrowding of airport facilities, especially those in limited non-secure space. DCSs are typically 

stand-alone systems that currently cannot access the internet and are unable to access information 

on other carriers’ baggage fees.

14

 

Current check-in systems do not store and cannot access information on any flight segments that 

took place earlier in time. This limitation makes it impossible for check-in systems to identify prior 

carrier(s) in an itinerary and the baggage policy applied by the first marketing or operating carrier.

15

 

Carriers generally do not receive the complete itinerary for passengers that book with other airlines 

or with ticket agents because reservation systems across the industry are not perfectly integrated and 

do not exchange complete information.16 Individual carriers have no control over the information 

that is received on a connecting passenger, therefore, any solution to this problem will take an 

industry-wide effort.17 The types of information that current DCS cannot access but will need to in 

future include notification to an agent that a “most significant” carrier is different than the operating 

 

10 Player Declaration at 4, page 2; Resnick Declaration at 3, page 1; Stumbo Declaration pages 1-2.

11 Player Declaration at 4, page 2; Litschke Declaration at 5, page 2. Hallenbeck Declaration, page 1; Resnick 

Declaration at 3, page 1; Bryant Statement page 1.

12 Resnick Declaration at 4, page 2.

13 Hynes Declaration at 7, page 2; Guillemette Declaration at 13, page 2.

14 Hynes Declaration at 7, page 2; Hallenbeck Declaration at 3, page 1; Resnick Declaration at 4, page 2; Puddifoot 

Statement page 1; Guillemette at 14.3(iii), page 4; Sato Statement page 1; Fortson Statement page 1; Collins Statement 

page 1; Bryant Statement page 1.

15 Hynes Declaration at 7, page 2; Resnick Declaration at 4, 5, page 2.

16 Resnick Declaration at 4, page 2; Guillemette at 14.3(ii) at page 4.

17 Resnick Declaration at 4, page 2; Player Declaration at 7, page 3.
6

carrier, recognition and application of different fees and policies, recognition of passengers on 

codeshare/interline itineraries or who have been rebooked from other airlines as a result of irregular 

operations or a denied boarding situation, and the correct baggage acceptance policy or fees to 

permit an agent to manually override the current check-in system with the correct fee amount or 

acceptance policy.18 The baggage notice requirements in section 399.85(c) raise identical concerns 

because current carrier e-ticket automated processes and other systems that could be used to 

disclose baggage rules and fees to passengers also do not have access to other carrier baggage rules 

and fees.19

Stakeholder Initiatives

The baggage rule will require most airlines in the world to have the capability to share passenger 

itinerary and baggage rule and notice information, since the final rule requires the same baggage 

rules apply throughout an itinerary for any passenger whose ticketed origin or destination is a U.S. 

point.

20 The complex methodology to access, share, and interpret the shared baggage information 

can begin once uniform baggage information standards are set, which as of this filing they have not 

(see unresolved questions below).

21

 Carriers could meet this baggage rule information sharing 

requirement in different ways. ATPCO is developing one information sharing process by 

enhancing existing tariff databases to include updated baggage rule information on 293 airlines. We 

have been told that ATPCO will have a database including most of the required baggage allowance 

and fee information by January 24, 2012. Other solutions may also meet the regulatory 

requirements. As explained below, this is one step in a lengthy compliance process.

Extending the Deadlines is Necessary and Will Benefit the Public

As discussed above, the development of a comprehensive, automated solution to the new baggage 

rule and disclosure requirements cannot proceed at full speed until all unresolved questions are 

answered.22 The process of answering unresolved questions began on September 6, 2011, when the 

Department issued its first guidance on section 399.85. The process continued when the 

Department issued additional guidance on 399.85 and its first guidance on section 399.87 on 

October 19, 2011. We are aware that the Department met with ATPCO several times to answer 

additional questions, the latest meeting taking place on November 7, 2011. As noted at the ATPCO 

meeting and below, there are still several unresolved critical issues that need to be addressed before 

a method for sharing baggage information can be developed (such as the ATPCO product). 

Planning by carriers, vendors, and other stakeholders is significantly altered each time the 

Department issues additional guidance.23 

Developing one or more baggage rule and fee databases is the first step in a long process for all 

stakeholders to comply with the new rules.24 Once one or more databases with the baggage 

information becomes available (or another solution is identified), carriers and vendors will begin the 

 

18 Player Declaration at 4(A), page 2.

19 Hynes Declaration at 15, page 3; Fortson Statement at 1; Stumbo Declaration page 1; Hallenbeck Declaration page 4; 

Friedli Statement page 1.

20 Hynes Declaration at 5, page 1; Guillemette Declaration at 14.1, page 3.

21 Hynes Declaration at 7, page 2.

22 Forston Statement page 2.

23 Litschke Declaration at 7, page 3; Sato Statement page 1.

24 Fortson Statement page 2.
7

process of planning and modifying carrier systems.25 Stakeholders will have to spend a significant 

amount of time modifying carrier systems to access the web, interface with at least one baggage rule 

information database, download, recognize and process information generated by these databases, 

and then transmit that information in useable form to the various check-in systems.

26

 In addition to 

all of the IT work, the Industry will have to establish standards as to how the information will be 

shared between carriers.27 There is no ndustry standard today for carriers to notify one another 

which baggage rule to enforce.28 Consequently, there will be lots of work to do at and Industry level 

to reach consensus on how to solve these issues. Carriers and vendors will also have to spend a 

significant amount of time testing this connectivity before exposing passengers to the new system.29

In order to maintain current passenger check-in processes, carriers will need a service that can 

access and process data requests with an extremely reliable and fast uptime.30 

The viability of a web-based system, if that is the ultimate solution or one of the solutions, is 

completely dependent on interface between a carrier system and the 3rd party providing the external 

data, the internet connection at an airport, and the size of data downloads; any one of these factors 

could slow or crash a system bringing automated passenger check-in to a halt.31 Slow or 

temporarily unavailable passenger check-in systems will operate to the disadvantage of the traveling 

public, the group these rules are intended to benefit, and will result in delayed check-in, improperly 

checked baggage, missed flights, and passengers traveling without their checked baggage. In 

addition, carrier airport and reservations customer service agents will have to receive training on the 

new rules and carrier procedures, an estimated six month process.

32

 However the training program

cannot be created until the Department provides additional guidance.33

Carriers will also have to modify websites and kiosk software that provides check-in capabilities 

and could be used to pay for checked baggage.34 Curbside “skycap” check-in systems have limited 

functionality and typically cannot see a passenger’s full itinerary if it includes interline travel.35

Therefore, curbside check-in could be limited until a solution is developed and any solution to the 

final rule will have to be multifaceted, and account for changes to multiple systems.36

In the event our understanding that carriers will not be required to honor competitors’ elite flyer 

baggage rule policies is incorrect (see below), the complexity of accessing and applying world-wide 

carrier baggage rules and fees will be further exacerbated.37 The Department clarified in FAQ 34 

that any excess, oversized, or special baggage fees must apply throughout an itinerary, adding 

 

25 Guillemette Declaration at 14.2(i), page 3; Forston Statement page 2.

26 Hallenbeck Declaration page 2; Puddifoot Statement page 2; Guillemette Declaration at 14.2(i), page 3; Stumbo 

Declaration page 2; Collins Statement page 1.

27 Friedli Statement page 1.

28 Id.

29 Hynes Declaration at 7. page 2; Hallenbeck Declaration page 2; Litschke Declaration at 8, page 3; Stumbo 

Declaration page 2.

30 Hynes Declaration at 8, page 2; Hallenbeck Declaration page 2; Litschke Declaration at 9, page 4.

31 Fortson Statement page 1.

32 Puddifoot Statement page 3; Guillemette Declaration at 14.4, page 4; Stumbo Declaration page 3.

33 Player Declaration at 8, page 3; Hallenbeck Declaration page 3.

34 Resnick Declaration at 10, page 4; Guillemette Declaration at 21, page 5; Stumbo Declaration page 2.

35 Resnick Declaration at 10, page 4.

36 Litschke Declaration at 6, page 2; Resnick Declaration at 10, page 4; Puddifoot Statement page 1.

37 Player Declaration at 5, page 2; Stumbo Declaration page 3.
8

complexity to the rule.38 In addition, some carriers factor bag size and weight as part of their 

baggage policy, some carriers do not.

39

 

Global compliance with 399.87 for itineraries that originate or depart the U.S. will require airlines 

around the world to file and regularly update baggage fee information and make the same major 

check-in system modifications and investment as U.S. carriers.40 The complexity of a unilateral 

Department regulation is a burden for both U.S. and non-U.S. carriers, especially when it appears 

section 399.87 conflicts with Resolution 302 (see unresolved questions below). The notice 

requirements of section 399.85(c) will also burden U.S. and non-U.S. carriers, forcing website and 

e-ticket changes for those itineraries that originate or depart the U.S. 

In addition, carriers do not have access to complete passenger itineraries that originate with a 

Global Distribution System (“GDS”).

41

 Therefore, carriers and vendors will have to work with 

GDSs to modify systems and release additional data, which is dependent on GDS willingness to 

work with carriers to provide this additional information.

Compliance with section 399.85(c) will expand the scope and complexity of developing programs 

and systems that share baggage rule and fee information among carriers. Any architecture that is 

built to receive and determine the correct baggage rule and fee information for section 399.87 will 

also be used to communicate with e-ticket and website ticket purchasing engines to meet the 

baggage notice requirements of section 399.85(c).42 Therefore, carriers and vendors around the 

world not only have to reconfigure DCS interfaces to accept and utilize baggage information for 

passenger check in functions but also have to modify website and ticketing functions to meet 

passenger baggage notification requirements.43

Given the significant amount of time each step in the compliance process will take after one or more 

baggage information databases are created, tested, and active, which is likely to be January 2012, 

carriers and vendors will not have enough time to complete the necessary steps to comply with the 

new baggage rules.44

Unresolved Questions

We ask the Department to confirm or answer the following unresolved issues that will significantly 

alter baggage information sharing and carrier implementation plans for sections 399.87 and 

399.85(c).

1. For codeshare flights please confirm that the marketing carrier baggage rules can choose to 

apply any set of baggage rules, for instance IATA resolution 302 or the operating carrier 

baggage rules, as long as the same rules apply throughout the itinerary.

 

38 EAPP #2 FAQs, page 32.

39 Player Declaration at 6, page 3.

40 Player Declaration at 5, page 2.

41 Hynes Declaration at 9, page 2; Guillemette Declaration at 12, page 2.

42 Hynes Declaration at 15, page 3; Fortson Statement page 2.

43 Hynes Declaration at 15, page 3; Puddifoot Statement page 3.

44 Litschke Declaration at 8, page 3; Collins Statement page 1; Player Declaration at 6, page 3; Resnick Declaration at 3, 

page 1; Hynes Declaration at 10, page 2; Stumbo Declaration page 2; Guillemette Declaration at 14.2, page 3; Sato 

Statement page 2; Bryant Statement page 1.
9

 

2. For interline flights or itineraries in the absence of a codeshare agreement such as an online 

travel agency created itinerary, confirm the first carrier can choose to apply any set of 

baggage rules, such as the 2nd operating carrier baggage rules, as long as the same rules

apply throughout the itinerary.

3. Confirm that carriers do not have to honor a preceding carrier’s baggage exemptions 

throughout an itinerary. Examples include frequent flyer status, credit card holder, 

passengers in first or business class seating for one leg of an itinerary but economy class 

seating in subsequent legs of the same itinerary.

4. Confirm that 399.87 and 399.85 do not apply to an itinerary ticketed and sold on a route not 

involving the U.S. that is modified during irregular operations to include a stop in the U.S.

5. Confirm that 399.87 does not apply to carry-on baggage policies.

6. Confirm that “baggage allowance” in 399.87 means rules regarding a passenger’s first and 

second bag and not additional bags, to be consistent with the section 399.85(c) notice 

requirements.

7. Section 399.87 FAQ 27, Example 3:

“Example 3 (domestic code-share): As in example 2, Carrier A operates the Miami-Washington 

and New York-Miami segments, and Carrier B operates the Washington-New York segment. 

However, Carrier B’s code and flight number are shown on the ticket for the Miami-Washington 

and Washington-New York segments, and Carrier A’s code and flight number are shown for the 

New York-Miami segment. Because the first flight is a code-share and Carrier B is the 

marketing carrier for that flight, Carrier B’s baggage allowances and fees apply throughout the 

itinerary.”

45

Confirm that Carrier B’s baggage allowances and fees could defer to Carrier A’s policies.

8. FAQ 29 states that section 399.87 does not prohibit carriers from using the “most significant 

carrier” methodology for international flights as set forth in IATA Resolution 302 as 

conditioned by DOT Order 2009-9-20.46 There are two conditions in DOT Order 2009-9-

20, the second condition states “in the case of code-share flights that include a point in the 

United States, the Most Significant Carrier (MSC) shall be the Marketing Carrier.”47 The 

IATA definition of the MSC is substantively different and much more complex:

“MOST SIGNIFICANT CARRIER (MSC)

3) the MSC is.

a) For travel between two or more IATA areas, the carrier performing carriage on the first sector 

that crosses from one area to another.

 

45 EAPP #2 FAQs, page 32.

46 EAPP #2 FAQs, pages 30-31.

47 Department of Transportation Order 2009-9-20, Docket Number OST-2008-0367, Section 2(b) page 9.
10

Exception: IATA area 123 only, the carrier providing carriage on the first sector that crosses 

between IATA area 1 and IATA area 2.

b) For travel between IATA Tariff sub-areas, the carrier performing carriage on the first sector 

that crosses from one sub-area to another.

c) For travel within a IATA Tariff sub-areas, the carrier performing carriage on the first 

international sector.”48

Can the Department explain how section 399.87 as clarified in FAQ 29 does not prevent (and 

conflict with) the application of IATA Resolution 302 when the definitions of MSC in IATA 

Resolution 302 and DOT Order 2009-9-20 are different? Is a carrier to apply Resolution 302 in 

all aspects except for the definition of MSC?

9. Can a carrier choose to apply a less restrictive baggage fee (more generous to the passenger) 

than the fee otherwise applicable under section 399.87?

10. Confirm that itineraries traveling “via” the U.S. will be exempt from (1) sections 399.85 and 

399.87 and (2) the Department’s two reservations in Order 2009-9-20, the same way 

baggage charges are exempt for itineraries wholly outside the U.S. For purposes of this 

request, “via” refers to itineraries that begin and end outside the U.S. but include a 

connection or stopover in the U.S. 

We note that answers to each of these questions may raise additional questions that will require 

stakeholders to modify current compliance plans and we respectfully request the Department give 

the uncertainty on several issues at this late date weighty consideration in its decision to extend the 

effective dates.

* * *

The new Department baggage rules require many substantial changes from multiple stakeholders. 

As described herein, information technology development by the scores of carriers affected by the 

rule is highly dependent on standardized third party sources of baggage information which is not yet

available. The changes require U.S. and foreign carriers and vendors to invest enormous amounts

of time, effort, and money to re-program and upgrade their technology systems. Before such 

systems are put into use, carriers must carefully test these changes, as changes made to these 

systems can ripple through other areas of the business creating unintended harmful side effects for 

not just carriers, but consumers and travelers as well. Carriers must also extensively train 

employees before applying changes to the public. Carrier compliance plans cannot be fully 

completed until stakeholders receive additional clarification from the Department, clarification that 

may itself lead to additional questions.

Accordingly, we respectfully request that the Department extend the effective dates for section 

399.87 and section 399.85(c) for one additional year, until January 24, 2013.

 

48 IATA Resolution 302.
11

Respectfully submitted,

 

Douglas Mullen Roger Cohen

Assistant General Counsel President

Air Transport Association of America, Inc. Regional Airline Association

1301 Pennsylvania Avenue, NW 2025 M Street, NW

Washington, DC 20004 Washington, DC 20036

202-626-4000 (202) 367-1250

dmullen@airlines.org cohen@raa.org

Edward P. Faberman Douglas Lavin

Executive Director Regional Vice President, North America

Air Carrier Association of America International Air Transport Association

1776 K Street, NW Suite 300 – North, 601 Pennsylvania Avenue, N.W.

Washington, DC 20006 Washington, DC 

(202) 719-7420 (202) 628 9292

epfaberman@acaa1.com lavind@iata.org

November 18, 2011

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Attachment 7
BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

------------------------------------------------------ 

In the matter of: : 

 : 

Final Rule : 

Enhancing Airline : Docket No. DOT-OST-2010-0140 

Passenger Protections : 

------------------------------------------------------ 

Statement of Michelle Bryant, Lufthansa: 

This statement is being submitted with respect the DOT’s Final Rule Enhancing Airline 

Passenger Protections. 

In the absence of automated baggage processing rules in both our departure control and 

reservation systems, it is not possible for carriers, including Lufthansa, to meet the current 

January 24, 2012 deadline. 

Presently, there is no central repository for carrier baggage policies and fees, which means that 

Lufthansa, like all other airlines, is left to try and find an interim solution at all our stations 

around the world. This may very well entail receiving daily or weekly baggage information from 

all airlines with which Lufthansa has codesharing/interline agreements. This is impractical, and 

even if such processes are set up, the chances of having accurate information for all carriers at all 

times is improbable. 

 

There are no viable automated solutions to display baggage allowances and fees in our 

reservation system when the passenger’s reservation is made and ticket is issued or at time of 

check-in when the passenger is at the airport. While baggage rules are filed with ATPCO our 

systems are only capable of displaying the Lufthansa baggage allowance and fees. An automated 

solution to process baggage rules to support both display and pricing of airline ATPCO baggage 

filings is currently under development by our IT system provider. However, this solution will not 

be available until the end of 2012 or early 2013. There are third party solutions to access baggage 

rules online, but such solutions cannot be used at check-in kiosks since these solutions depend on 

the internet. Additionally, our check-in agents work on a legacy system which does not have 

internet access. 

 

Furthermore, in order for our website to be able to display the baggage rules and fees it will 

significant changes and coding, which can not be accomplished within the existing timeframe. 

 

Lastly, Lufthansa in the process of migrating its departure control system to another platform. In 

order to migrate from one system to another, we have frozen all developments on the current 

departure control system. The automated baggage solution would be incorporated on our new 

check-in system. 

 
Therefore, it is respectfully requested that the DOT grant the instant application for an extension 

of the deadline to implement 399.87 which would not only benefit the industry, it would also 

prevent passengers from being subjected to incorrect calculations of baggage allowances. 

 

Michelle Bryant 

Manager Distribution Systems 

and IATA Industry Affairs 

 

Deutsche Lufthansa AG 

Reservation Systems - FRA IS/R 

Lufthansa Aviation Center 

D-60546 Frankfurt/Main 

tel. 49 69 696 51056 

fax. 49 69 696 39715 

e-mail: Michelle.Bryant@dlh.de 

November 18, 2011 
Attachment 8
Page 1 of 4

Name

Lauren Puddifoot

Employee title

Alliances Systems Business Partner

Employee responsibilities

I am responsible for ensuring all Codeshares and Alliances work as efficiently as possible through 

system development. I have been seconded as Business Owner of this Advanced Baggage Rules 

project as I have SME knowledge of our airline reservations system and knowledge of associated 

systems and their update processes, including the website and graphic user interfaces (GUIs) used 

for customer facing roles. I have previously worked on projects applying change across different 

areas of our business.

Airline Reservations System

Our airline reservations system is SHARES B. 

Historical explanation of our system

SHARES B is a legacy Transaction Processing Facility (TPF) system developed in the 1970s by 

Electronic Data Systems who were bought out in 2008 by HP and now operate as HP Enterprise 

Services, based in Los Angeles. SHARES B is not web-based and does not use Extensible Markup 

Language (XML); therefore development of the system takes much longer than a web-based system.

US Airways also uses this system and Continental operate on a similar platform, SHARES A. 

SHARES B is used for the creation of passenger bookings, inventory control, check-in and can be used 

to message to other global distribution systems (GDSs) through teletype messaging.

We have hundreds of applications that run off of SHARES B. Any changes that are made to it have to 

go through a steering group to assess their business impact. Changes to these applications are made 

in conjunction with, or more regularly after, changes to SHARES B.

What the new DOT rule requires in contrast to the capabilities of our systems

1. SHARES B does not currently contain our baggage rules or fees. 

Virgin Atlantic currently advises customers of our baggage allowance verbally through our Contact 

Centre, in information on our website and on our e-ticket confirmation e-mails and faxes. The new 

US DOT rule requires Virgin Atlantic to advise passengers of the baggage allowances at the time of 

booking through our Contact Centre, on our website, on e-tickets and at check-in. This will all require 

SHARES B and secondary applications to contain our baggage rules and additional fees. 

2. Our greatest challenge is to change SHARES B to retrieve these rulings from Airline Tariff 

Publishing Company (ATPCO) and apply them correctly as per the US DOT ruling. This will take a 
Page 2 of 4

significant amount of the HP programmer’s time, approximately 3000 hours. We are already 

working with them to ensure we comply with the US legislation regarding Secured Flight ‘Overfly’ 

compliance, and we will have to secure extra resources for this project. 

3. Once these changes have been made to SHARES B we then need to filter these rulings through to 

many of our applications that run off SHARES B.

The main applications we need to change, subsequent to changes to SHARES B:

 Contact Centre GUI - Vega

 E-ticket fulfilment system - ERICA

 Website

 Airports GUI – Babel

4. We need to file our baggage rules and additional fees according to US DOT rulings and ensure they 

are applied correctly. We are particularly concerned with how these will be applied on multi-airline 

bookings involving codeshare partners and interline partner airlines as there is a significant 

difference between the US DOT ruling and IATA resolution 302 regarding marketing flights and 

operating flights.

Our baggage rules and additional fees are filed with ATPCO according to IATA resolution 302 for 

agents and other airlines to use through their own computer reservation system (CRS) or GDS. We 

do not currently use the information in ATPCO in SHARES B as we do not currently have a link 

between the two systems. Therefore other carriers can only access our baggage information through 

our filing in ATPCO; they cannot retrieve baggage information from our own system. 

Challenges Virgin Atlantic faces in order to meet the DOT rule

1. SHARES B is a legacy system that will take a long time to change.

2. Many applications also require changing and this will take time and can only be changed 

once SHARES has been updated.

3. We have a system code-freeze every January and early February as this is our busiest selling 

period.

Virgin Atlantic Airways currently faces challenges to meet the ruling by the 24th January 2012 

because we are reliant on HP, our airline reservation system owner, to change SHARES B to display

ATPCO baggage rulings when quoting fares, issuing e-tickets and checking passengers in at our 

airports. This change will require a new link from ATPCO to SHARES B to be created and tested. The 

data that is fed through will then need to be translated into various areas of SHARES B and HP have

estimated that the updates required to meet the US DOT ruling will take approximately 3000 hours. 

These changes include: a baggage allowance to be displayed in a fare quote for contact centre 

agents to use; baggage allowances and additional baggage rates to be displayed on electronic tickets 

and in the automated check-in record used at our airports. Most of these updates are in the 

planning or design phase and HP have initially estimated changes to be completed by February 2012, 

at the earliest. Once these changes have been delivered by HP we then have to change our 
Page 3 of 4

associated systems and GUIs. These systems cannot be changed until we know how SHARES B will 

display our baggage allowances and those of our interline or codeshare partners.

The SHARES B system is too complicated for all of our staff to use, approximately 50 people 

company-wide use, or are aware of, the native entries required to use our reservations system, 

these employees are mainly in non-customer facing areas where they maintain and work on projects 

to develop SHARES B, namely Commercial Systems and IT. All other users across the globe use a GUI. 

In our Contact Centres a GUI called Vega is used to enable call centre agents to quickly and 

efficiently book passengers. The development of this GUI is done in maintenance cycles, typically 

updating Vega 5-6 times a year. This maintenance is carried out by a third party vendor. The next 

update is due to be released in late February to early March and development for this release must 

be completed before January. If HP are not able to develop SHARES B by the end of December then 

we will not be able to update Vega until the next release date around May 2012. 

Virgin Atlantic staff or agents at our airports also use a GUI system, Babel GUI, that will need to be 

updated subsequent to any SHARES B changes. Virgin Atlantic Airways believes we may be able to 

develop this software for late February and the rollout to most of our destinations will take 

approximately 2 months. Our Airports Training department have advised me that if this is a small 

change then all staff and handling agents globally will be notified of the update by their managers 

which should only take a matter of days. We predict we will only have to make a small change to the 

GUI, but the change is reliant on changes being completed in SHARES B.

We do not currently show additional baggage prices on our e-ticket confirmation, for our own 

flights or for our codeshare or interline partners; this change is again dependent on changes being 

made to SHARES B first. The development of our e-ticket system, ERICA, is handled in-house by our 

IT vendor TCS, the work required to change the e-ticket is significant and will take 2-3 months for 

this already stretched team of two subject matter experts. E-tickets are sent out after bookings are 

made by our Contact Centre and on our website.

Our website is updated in maintenance cycles, as Virgin Atlantic Airways do not sell interline sectors 

on our website, the development required is not as detailed as that required for SHARES B, and its 

content is not as dependent on SHARES B as many of our other systems. Also as this is all XML and 

JavaScript changes it is much easier to update than SHARES B. Therefore we believe we will be able 

to make most required changes by the end of this year, with a number being delivered on the 24th

January itself, in an extraordinary website maintenance release containing only US DOT required 

changes. As detailed above, the changes to e-ticket confirmations will still need to be made, e-tickets 

are also sent out when bookings are made on the website.

Timeline

HP have asked us to take part in an extraordinary meeting with other SHARES B carriers at the end of 

November or early December to further discuss the system changes Virgin Atlantic Airways require 

in order to meet the US DOT’s ruling. Development of SHARES B will not begin until that meeting is 

closed and HP have a clear view of the development all SHARES B carriers require. With a predicted 

3000 hours of development we do not have enough time to develop, test and rollout changes in 
Page 4 of 4

order to meet the 24th January deadline in SHARES B, let alone our secondary applications, this is 

why we are appealing for an extension to the deadline of 24th January 2012. 

Virgin Atlantic Airways believes as more realistic target would be April 2012. 

November – Representatives from Virgin Atlantic will attend an ATPCO conference to discuss how 

the US DOT rule will be applied. Dependent upon the decisions of this meeting ATPCO may need to 

develop their systems, this could take a month. This development will then need to be filtered down 

through SHARES B and the GDSs. 

I will hopefully meet with HP and other SHARES carriers in November to discuss the changes we all 

require to SHARES. However, this may be moved to early December due to Thanksgiving 

celebrations.

December - January – HP will work on changing SHARES B. Changes may be made to the SHARES B 

test environment in January which will help the developers of Babel GUI, Vega GUI and ERICA. 

However, I suspect it will more likely be February.

January – Once we are aware of the changes that will be made to SHARES B we may be able to plan 

what changes need to be made to our other applications and plan development times more 

specifically.

Changes will be made to the website with an extra-ordinary release that has been approved by IT 

Change Management as the only change to be made to a customer facing application during our 

code-freeze.

February – Virgin Atlantic Airways will start user acceptance testing (UAT) of the changes to the 

SHARES B System. Once this is completed we will then be able to start comprehensive development 

of Vega, Babel and ERICA.

March – We will continue development, UAT and regression testing of our secondary applications. 

UAT typically takes 1-2 weeks, regression testing takes one further week.

April – Virgin Atlantic Airways will roll-out system changes worldwide and deliver training where 

necessary to our global operation. Changes to Vega may be made at the start of May as this is the 

approximate date of the next maintenance release, should we miss the December deadline.

Prepared 4th November 2011
Attachment 9
BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

------------------------------------------------------ 

In the matter of: : 

 : 

Final Rule : 

Enhancing Airline : Docket No. DOT-OST-2010-0140 

Passenger Protections : 

------------------------------------------------------ 

Statement of Mitsue Sato, All Nippon Airways:

- Since when it was determined that IATA resolutions 300 and 301 were to be expired on March 31st,

2011 and Resolutions 302 would replace them as a common rule for determining baggage rules, the 

industry has made great efforts to put in place the automated baggage rule in pricing system and DCS 

system in accordance with Reso 302 and US DOT reservation in order to make them work properly and 

more customer and user friendly.

- However, despite of our great efforts, the industry is still in the middle of the path and is required to 

keep enhancing the systems to make better handling of baggage for our customers in the new rule. 

Especially, what we found out after the implementation of IATA Reso 302 with US DOT reservation is 

that we would need something more for our check-in agents to handle the same baggage allowance 

shown on the ticket and apply correct baggage charges based on the baggage allowance information. 

Thus, ANA is now working on developing the following new enhancements in our DCS system.

 1) To display the baggage allowance information from e-ticket on the check-in screen

 2) To create a pricing mask of the itinerary from e-ticket and enable our check-in agents 

 to re-price the ticketed itinerary to find out which carrier is MSC and to show a 

 catalogue of baggage charges for the MSC.

 3) As for cases when ANA is MSC, because our baggage charge rules are simple, to 

 make a table of our baggage charges in the system for the check-in agents to display 

 a pricing mask and sum-up the charges automatically.

 4) And after getting the result of the baggage charge to be applied to the passenger, to 

 issue an automated excess baggage ticket from the priced information

- Because we currently don’t have the above automated processing in DCS system, we have to take a 

long time for passenger’s check-in. If we could have an internet environment in DCS system, things 

must have been easier, however our current DCS system in all stations has no capability to use the 

internet access like as general DCS system in this industry, we need to make changes in the program of 

our DCS which requires quite a long time usually.

- And while we are working on those remaining system enhancements, US DOT 399.87 has been 

clarified, so we reviewed and evaluated the impacts on our current ABR processing in the pricing system.

Here is the summary of the result.

 *Firstly the biggest change was that 399.87 has changed the basic assumption in 

 automated baggage rule processing that US DOT reservation is applied over the 

 methodology of IATA Resolutions 302 and not independent. However we now have to 
 put a new thought that the first carrier could be a 302 opt-out carrier and the MSC rule 

 shouldn’t be used in that case.

 *The system now needs to do an additional itinerary check to differ domestic and 

 international itineraries. And as for the international case, the system need to find out 

 if the first carrier opts out Reso 302 or not.

 *Please see the attached document for more details of the changes which are now 

 required for 399.87 in our pricing system. The blue colored parts are the new changes.

- Looking at the big system impacts we’ve found out as shown in the attachment, ANA has to tell not only 

us but the industry would need more time for the system developments than 2 months and a half which 

is allowed for us from today till 24Jan2012 in order to meet the US DOT requirements along with the 

DCS developments for aligning with the automated baggage rule. Thus we would highly appreciate US 

DOT would kindly reconsider the extension of the mandate date of 399.87. 

_______/S/___________

Signature

Mitsue Sato

Assitant Manager, 

IT Strategy&Planning

Marketing & Sales

All Nippon Airways

November 11, 2011
Attachment

≪Comparison of ABR processing between the current and the future of US DOT Rule 399.87≫

Current

Step 1 Check itinerary if US DOT rule shall be applied or not

Step 2 ★When US DOT rule shall be applied

The first carrier’s baggage rule will be applied to the whole 

itinerary. If the first flight is a code-share flight, the marketing 

carrier’s rule will be applied.

★When IATA 302 shall be applied

The baggage rule of MSC shall apply per checked portion. 

*When MSC files an option of Deferred Marketing Carrier, the 

marketing carrier’s baggage rule will apply.

Step 3 If there’s no matched rule in MSC’s baggage rule, baggage rule 

of the check-in carrier will apply.

If there’s no matched rule in MSC’s baggage rule, baggage rule 

of the check-in carrier will be applied.

Step 4 If there’s no matched rule either in the check-in carrier’s rule, 

blank will be reflected. 

If there’s no matched rule either in the check-in carrier’s rule, 

blank will be applied. 
Blue colored parts are new changes by 399.87.

After the implementation of US DOT rule 399.87

Step 1 Check itinerary if it is US domestic itinerary or international one

Step 2 ◆When US domestic itinerary

⇒The first check-in carrier’s baggage rule will be applied to the whole itinerary. If the first flight is a code share flight, the 

marketing carrier’s baggage rule will apply.

◆When international itinerary

⇒to the next itinerary check if US DOT rule shall apply or not

Step 3 ★When US DOT rule shall apply

Check if the first check-in (marketing) carrier chooses 302 Opt 

out option or not

★When IATA 302 shall apply

Baggage rule of MSC will be applied to each checked portions. 

*When MSC sets Deferred Marketing Carrier option, marketing 

carrier’s rule will be applied.

Step 4 ■When the carrier opts out IATA 302,

⇒The first check-in carrier’s rule will be applied to the 

whole itinerary.

■When the carrier follows IATA 302

⇒The MSC’s rule will be applied to the whole itinerary.

*If the first check-in carrier or MSC’s flight is a code-share 

flight, the marketing carrier’s rule will be applied.

If there’s no matched rule in MSC’s baggage rule, baggage rule 

of the check-in carrier will be applied.

 Step 5 If there’s no matched rule to the sector, blank will be applied.
Attachment 10
BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

------------------------------------------------------

In the matter of: :

:

Final Rule :

Enhancing Airline : Docket No. DOT-OST-2010-0140

Passenger Protections :

------------------------------------------------------

Statement of Daniel Friedli, Hewlett-Packard:

Thank you for the opportunity to comment on the final rulemaking as we share in your desire to 

protect airline passengers. HP has over 300,000 employees and they help serve the more than 1 

billion people who rely on HP technology every day. With business in 170 countries around the 

world we are no stranger to travel logistics and we work hard to ensure that our employees and 

customers get to their destinations safely. Please see our comments below in response to the final 

rule aimed to enhance airline passenger protections. 

Section 399.85c states which information must be provided on the ETKT receipt. As the e-ticket 

represents the contract with the client, and not the receipt, we must ensure that the data put on the 

receipt is stored within the ETKT itself. This is very important to ensure that the same 

information is given to the customer every time. If we merely pull the data from the data source 

(fares system, ATPCO, etc) and print this on a receipt, any down-line person or system will not 

be aware of the exact charges, conditions and other baggage related information that was 

presented to the passenger. 

The new DOT rule fails to dictate that the first carrier use the methodology as defined in 

Resolution 302, thus that first carrier could do the determination based on internal rules. 

However, these rules will be applicable for the whole journey. If the rules are not stored in the 

ETKT itself, they will never be known to any of the down-line carriers, making it impossible to 

know or enforce the rules, and reproduce a receipt with the same information.

This means, as a system provider, I cannot offer the functionality my carriers require. In my 

humble opinion, for this to work through all instances, and also in follow-up transactions such as 

ETKT exchanges, all data must be stored in the ETKT. While this may be possible in reasonable 

time for the airline’s own system and ETKT’s, transmitting this data between airlines, between 

GDS’s and airlines and between ground handlers and airlines will not be possible until we define 

an industry standard on how to format and exchange this data. 

HPtogether with All Nippon Airways (ANA) ), had submitted agenda items to IATA’s Ticketing 

Committee to initiate some of these changes. Aside from the fact that there was opposition to 

these industry changes, even if these had been approved, the implementation of the changes 

systematically will take considerable time. The reason for this is that the changes to the data 

being transmitted are considerable. We (and all other involved entities) need to upgrade to a 
newer version of the EDIFACT and/or XML messages for Electronic Ticketing. These are huge 

changes that will take a lot of time 

I could imagine that, if the DOT gives us a one year extension, we could drive an interim 

solution to provide this data in the messages, allowing carriers and other involved parties to 

fulfill the requirements set forth by the DOT. That would require a few things:

a) Review and possible updates to the already submitted agenda items. HP would offer, for 

the sake of the industry, to suggest the necessary changes and submit these agenda items

b) An expedited approval process through IATA/ATA to accept the agenda items

c) An interim solution to add these to the interline, GDS and ground handling messages

d) The effort of all carriers and system providers to code and test these message changes

e) Follow-up tasks such as then updating the ETKT database, itinerary and receipt printing 

routines.

Please take into account that this will be a multimillion dollar industry effort just to do this 

within the short timeframe given, even with an extension of one year. Preferable would be an 

extension of 18 months – this will not reduce the costs, but allow for a better implementation of 

the solution, avoiding ‘quick and dirty’ fixes which will have to be re-coded at a later stage, or 

only fulfill part of the DOT requirements. Further, we need a freeze on requirement changes of 

ABR. This freeze must be for airlines, industry bodies (IATA/ATA), ATPCO and government 

agencies. We already need to reprogram our systems, less than one year after implementation, to 

change to the new DOT rules as per 399.87. Further changes may potentially slow us down 

further, or trigger re-work of already developed modules.

HP will be more than happy to help with any supporting materials you may need. HP is 

committed to complying with industry and government standards and regulations, and to support 

our hosted carriers in their effort to do so as well. We are also committed to finding the most cost 

effective but sustainable solutions not only for our airline customers, but also for the airline 

industry as a whole.

_______/S/______________

Signature

Daniel Friedli

Office of Strategy & Technology | Business Solutions

Product Manager – Transportation

November 14, 2011
Attachment 11
Page 1

Cathay Pacific Airways - Airports Department (AHQ) Update: 4Nov2011

Statement from Mr. Russ Fortson, Cathay Pacific Airways

My name is Mr. J. Russ Fortson – Manager Customer Services and Product 

Development – Airports, Steering Committee Chairman of the Enhancing Airline 

Passenger Protections Cross Departmental Project of Cathay Pacific. 

 A historical explanation of CX Systems 

Currently, Unisys CUPID and CUPAC are Reservations and Departure Control

Systems used respectively in Cathay Pacific (CX). CX has a tentative plan to 

migrate to Amadeus from its Reservation System CUPID in February 2012, where 

Departure Control System will follow in 2013. 

Both current systems are non-web-based and do not have the capability to 

communicate with other airline systems to obtain required information on baggage 

and fare information etc. 

E-Tickets are issued through CUPID and by online via our website, 

www.cathaypacific.com . For online bookings, CX has been using Amadeus as the 

Internet Booking Engine (IBE) which enables customers to booking tickets through 

the website. 

In the back-end process of online bookings, development work is required for the 

associated business logic for both CX and Amadeus on the web-pages. Currently, it 

does not comprise any baggage rules and fees specifically stated in either the webpages along the online booking flow or the e-ticket confirmation/receipt. 

 New DOT rules in contrast to the capabilities of your systems

The DOT rule is to display the free baggage allowance and applicable fees for the 

first and second checked bag and carry-on on the first page of the fare quotation and 

e-ticket confirmation. Such requirement also applies to itineraries that include 

codeshare and/or interline sectors in which case the carrier would need to disclose to 

the passenger (in the booking flow and e-ticket confirmation) the baggage policies of 

a single carrier (e.g. the Most Significant Carrier) whose policies will be applied 

throughout the itinerary.

There are 2 Key issues:

a. Regarding the mandatory requirement on baggage information to be displayed 

in the web booking flow, and the text for baggage allowances and fee of the 

Most Significant Carrier (MSC) shown in the e-ticket confirmation receipt, a 

major gap has been determined. CX has no capacity to provide the MSC carrier 

and their respective baggage fees other than CX.

Today, industry information is also not available in Amadeus resulting in difficulty 

for CX to obtain the true MSC for displaying such relevant information in the 

web-pages and in e-ticket itinerary receipts.

An industry solution from ATPCO will be able to provide carriers with the 

required information. However there is a dependency on ATPCO solution. The 
Page 2

Cathay Pacific Airways - Airports Department (AHQ) Update: 4Nov2011

implementation date and the timeline for Amadeus to receive this information for 

display on CX web and e-ticket receipts is currently not confirmed. 

b. With the Final Rule implementation date of 24th January 2012, and our 

Reservation System migration to Amadeus as planned on February 2012, there 

will be a time gap of a few weeks that the current CUPID systems will still be in 

use after the implementation. The current Reservation migration effort is huge 

and implementing this solution on two different systems will cause CX 

duplication of effort, resources and cost. Bearing in mind, the solution 

implemented in CUPID will be for such a short interim period. 

 What challenges your company faces in meeting the new requirements –

The first and greatest challenge we face is the uncertainty of when the industry 

solution (ATPCO/GDSs) is in place as it is still under development. Without the 

baggage data provided to drive extra information from baggage pricing, our in-house 

ticketing system would not be able to obtain the MSC information appropriately. It is 

still not concrete when Amadeus would be able to obtain MSC information from 

ATPCO, and/or what MSC information could Amadeus provide us before and after 

the effective date of the rule, i.e. 24th January 2012.

Even after the execution of the ATPCO, it is still necessary for internal system 

development on building the connectively between ATPCO and Amadeus to enable 

collection of accurate baggage information to process ticketing as accordance to the 

requirement, and to incorporate these information in the CX web-pages and e-ticket 

receipts. The cost and lead time of such development has not yet been determined 

with the dependency. 

The second challenge is to allocate duplicate resources for two systems 

development according to the implementation date as of 24th January 2012. As 

CUPID e-ticket receipt will no longer be used after Amadeus goes live planned on 

February 2012, thus what needs to be changed for the CUPID ET receipt will only be 

used for a few weeks after the implementation of the Rule until the migration. 

Lastly, with the migration of Reservation CUPID to Amadeus, to ensure stability, CX 

will have a development freeze period for 3 months after the cutover. The freeze 

period is subject to further change or extension. The migration of reservations 

systems is a huge undertaking within the company and all resources are focused on 

smooth and successful implementation. 

 A proposed timeline for compliance

CX has been communicating with respective parties, Amadeus and ATPCO to advise 

what solutions can work out to provide the true MSC and the timeline; however the 

schedule is still fluid. 

Once after the ATPCO solution is available, there is a need to establish system 

connectivity and CX internal system development for the web-pages and e-ticket 

confirmation display. Therefore, we would like to propose a timeline of six to eight 

months after the ATPCO solution is available. 
Page 3

Cathay Pacific Airways - Airports Department (AHQ) Update: 4Nov2011

___/S/______________________

Signature

Russ Fortson

Manager Customer Services and Product Development – Airports

Cathay Pacific Airways

November 11, 2011
Attachment 12
BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

------------------------------------------------------

In the matter of: :

:

Final Rule :

Enhancing Airline : Docket No. DOT-OST-2010-0140

Passenger Protections :

------------------------------------------------------

Statement of Fiona Collins, Business Domain Architect for Selling and Servicing, British 

Airways.

 I am responsible for design and systems architecture for all selling systems in particular 

ba.com, as well as any servicing activity including excess baggage purchase - both pre-paid 

and at the airport

 We use classic DCS currently which is a bespoke TPF system that is managed for BA by 

Amadeus. It cannot currently interface with any system other than Amadeus reservations and 

does not support web-services in any way.

 The new rules mean that our DCS system needs to be able to communicate with ATPCO to 

access baggage data - mainly charges information but also allowances to validate that the 

correct allowance has been applied.

 Our challenges in meeting the U.S. DOT rules are two fold - our current DCS system is not 

currently capable of supporting any web-services functionality and our agents don't have 

access to web-enabled front ends at the majority of our airport locations except in the back 

offices (which may not be anywhere near the actual customer service desks). In addition, 

upgrading to a new DCS makes more sense than modifying an older system. It takes time to 

get through the upgrade decision process.

___/S/_____________________

Signature

Fiona Collins

British Airways