Thursday, March 12, 2009 Responds to Department of Transportation Rulemaking Proposal (formerly Coalition for an Airline Passengers Bill of Rights) today filed comments on the U.S. Department of Transportation's Notice of Proposed Rulemaking (NPRM) on "Enhancing Airline Passenger Protections."

Our Comments:

-Summary of position

In short we commented that the U.S. DOT should strengthen and adopt a final regulation on this topic as soon as possible. DOT must set minimum standards for U.S. airlines to meet in preparing their Contingency Plans to deal with lengthy tarmac delays - rather than letting each airline set its own guidelines without Federal review and approval. Those Contingency Plans and the 1999 -- unenforceable -- "Customer First Commitments" of the major airlines must be included in all airline Contracts of Carriage -- their contract agreement with their passengers. It is also critically important that DOT monitor the language the airlines insert in their Contracts of Carriage so that those airline promises and other obligations will be easily understood by laymen and not be so conditioned by exceptions that a state court (small claims) judge wouldn't be able to decide the passenger's claim.

- Submitting comments

We are inviting our members and any other members of the public to review our comments and, if you agree with them, posting a letter of support on that Docket (in indicating the degree of your support, and any other supplemental comments (or differences) that you would like to offer.

While the technical deadline for DOT's receiving comments is today (March 9), DOT will accept, post and fully consider your comments if received within the next few days.

The easiest way to file comments is by faxing your letter to (202)493-2251. It usually takes about one business day for the DOT to post comments. You may also submit your comments directly into the docket portal (go to and follow the online instructions for submitting comments), or by mail:

Docket Management Facility,
U.S. Department of Transportation, 1200
New Jersey Ave., SE., West Building
Ground Floor, Room W12–140,
Washington, DC 20590–0001.

At a minimum, include the docket number in your heading as we have done so that your letter will be recorded in the correct docket:

Docket No. DOT-OST-2007-0022
RIN No. 2105-AD72

Here is a link to the DOT Notice of Proposed Rulemaking that we filed our comments against.

Sincerely yours,

Kate Hanni