Asociación Latinoamericana y del Caribe de Transporte Aéreo | Latin American and Caribbean Air Transport Association

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Aerolíneas Argentinas | Aeroméxico | Aeroméxico Connect | AeroRepublica | Aerosur | Air Canada | Air Jamaica | Avianca | Bahamas Air | Caribbean 

Airlines | Cayman Airways | Continental Airlines | Copa Airlines | Cubana de Aviacion | Delta Air Lines | GOL | Iberia | LAN | LAN Ecuador | LAN Perú | 

LIAT | Mexicana | Mexicana Click | Pluna | TACA | TACA Perú | TAM | TAM Mercosur | TAME | UPS | Volaris | VRG Linhas Aéreas-Grupo GOL

6355 NW 36 Street, Suite 601 | Miami, Florida 33166 – USA | Tel. +1 786 388 0222 - Fax +1 786 522 7315 | www.alta.aero

In the matter of: 

Enhancing Airline Passenger Protections 

Docket No.: 

DOT-OST-2010-0140

Request by the Latin American and Caribbean Air Transport Association (ALTA)

for a 60 day extension of the comment period 

The Department of Transportation (hereinafter “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). 

Latin American and Caribbean airlines are committed to provide exemplary service to its passengers and

are convinced that cooperation between carriers and governments can result in valuable improvements in 

the global aviation system, but an excess in 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. ALTA respectfully requests an additional 60 days to submit comments regarding this NPRM, 

citing the following factors: 

i) The Proposal seeks to impose on ALTA airline members’, among other foreign carriers, significant and 

new regulatory burdens, which the industry must adequately analyze in order to provide comprehensive 

and useful comments to the DOT. Since the regulation would touch almost all aspects of an airline’s 

business, our members need to consult with multiple offices on the cost, timing, feasibility and potential 

unintended consequences of the proposal, this sixty days lapse is not enough to collect the extensive 

amounts of data and information from all affected parties necessary to evaluate the Proposal in full;

ii) In particular, the Proposal specifically requests detailed information on the impacts, costs, and benefits 

on 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 our airline members need considerable time to collect and provide meaningful comments 

on these subjects;

iii) The DOT has published an extensive cost benefit analysis of the proposed regulation which ALTA and 

its member airlines will need analyse further to to provide a meaningful response; and
Asociación Latinoamericana y del Caribe de Transporte Aéreo | Latin American and Caribbean Air Transport Association

_______________________________________________________________________________________________________________________

Aerolíneas Argentinas | Aeroméxico | Aeroméxico Connect | AeroRepublica | Aerosur | Air Canada | Air Jamaica | Avianca | Bahamas Air | 

Caribbean Airlines | Cayman Airways | Continental Airlines | Copa Airlines | Cubana de Aviacion | Delta Air Lines | GOL | Iberia | LAN | LAN Ecuador 

| LAN Perú | LIAT | Mexicana | Mexicana Click | Pluna | TACA | TACA Perú | TAM | TAM Mercosur | TAME | UPS | Volaris | VRG Linhas AéreasGrupo GOL

6355 NW 36 Street, Suite 601 | Miami, Florida 33166 – USA | Tel. +1 786 388 0222 - Fax +1 786 522 7315 | www.alta.aero

iv) Moreover, the Proposal could raise implications in international law which will need to be precisely 

addressed by foreign carriers.

In order for ALTA and its member airlines to provide valuable comments on all aspects of the proposal, the 

comment period must be extended into the fall. 

For these reasons, ALTA 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. 

Alex de Gunten

Executive Director 

ALTA