BEFORE THE

US DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C. 

In the matter of: 

Docket No.:

Enhancing Airline Passenger DOT-OST-2010-0140

Protections 

Request by the International Air Transport Association (IATA) for a 60 day 

extension of the comment period

On June 8, 2010, the Department of Transportation (DOT) issued the Notice of 

Proposed Rulemaking (NPRM), “Enhancing Airline Passenger Protections,” 

(hereinafter “Proposal”) which seeks to expand upon the published Final Rule 

under the same title (DOT-OST-2007-0022). 

The aviation industry remains committed to providing exemplary service to its 

passengers and believes cooperation between carriers and governments can 

result in valuable improvements in the global aviation system. However, 

regulations in this area can lead to extensive unintended consequences, which 

could reduce service to passengers and adversely impact an industry pivotal to 

the global economy. 

The Proposal provides only until August 9, 2010, 60 days from publication, for 

the public to comment on this Proposal. IATA respectfully requests an additional 

60 days to submit comments regarding this NPRM, citing the following factors: 

 ̧ The Proposal seeks to impose on US and foreign carriers significant 

and new regulatory burdens, which the industry must adequately 

analyze in order to provide comprehensive and useful comments to the 

DOT. As the regulation would touch almost all aspects of an airline’s 

business, IATA members need to consult with multiple offices on the 

cost, timing, feasibility and potential unintended consequences of the 

proposal. Sixty days is not a sufficient time period in which to collect 

the extensive amounts of data and information from all affected parties 

necessary to evaluate this Proposal. 
 ̧ In particular, the Proposal specifically requests detailed information on 

the impacts, costs, and benefits on foreign carriers of proposed time 

intervals for deplanement, contingency plans, customer service plans, 

communication strategies, covered operations, data collection and 

publication, denied boarding compensation, pricing, fees and oversale 

regulations, and other provisions. Much of this data is not readily 

accessible and industry stakeholders need considerable time to collect 

and provide meaningful comments on these subjects. 

 ̧ The Department has published an extensive cost benefit analysis of 

the proposed regulation. IATA and member airlines will need to secure 

the support of outside experts in order to provide a meaningful 

response to this analysis. 

 ̧ Furthermore, the Proposal could raise implications in terms of U.S. and 

international law. The industry must be provided sufficient time to 

discern these impacts on US and foreign carriers and on the industry 

as a whole.

 ̧ Finally, the comment period for this NPRM falls during the busy 

summer travel and vacation season, during which airline resources are 

stretched to the limit. In order for IATA and industry stakeholders to 

provide valuable comments on all aspects of the proposal, the 

comment period must be extended into the fall. 

For these reasons, IATA requests an additional 60 days to collect the 

aforementioned essential information to provide valuable comments on the 

Proposal. 

Thank you in advance for your consideration of this request. 

Sincerely, 

Douglas E. Lavin 

Regional Vice President, North America 

International Air Transport Association 

601 Pennsylvania Avenue, NW Suite 300 North 

Washington, D.C. 

202-628-9292 

lavind@iata.org

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