SUMMARY OF COMMENTS SUBMITTED TO DOT REGULATORY REFORM DOCKET
January 12, 2018
On October 2, 2017, DOT published a request for comments requesting “input on existing rules and other agency actions that are good candidates for repeal, replacement, suspension or modification.” In total, over 2800 formal and informal comments were submitted to the docket (Docket DOT-OST-2017-0069) from all facets of the international aviation community, as well as individuals, and interested parties who deal with other modes of transportation such as busing, shipping and rail. Some of the aviation-related entities that commented include the International Air Transport Association, Airlines for America, the Regional Airlines Association, the Cargo Airline Association, the American Association of Airport Executives, the Air Line Pilots Association, and the Association of Asia Pacific Airlines; U.S. airlines including Delta Air Lines, United Airlines, American Airlines, Southwest Airlines, Sky West Airlines, Alaska Air, Atlas Air, Cape Air, and JetBlue Airways; foreign carriers such as Kuwait Airways, the Lufthansa Group, Air France/KLM, Qantas Airways, El Al, Avianca, Westjet, Singapore Airlines, and Etihad Airways; and others such as Airports Council International-North American, Embraer, Bar Harbor Airport, the Memphis-Shelby County Airport Authority, Florida Airports Council, and the Society of Travel Agents.
Comments addressed a broad range of topics, including the extraterritorial application of DOT regulations and their impact on foreign carriers operating to the United States, current regulations concerning passengers with disabilities (i.e. Part 382) and issues relating to the carriage of service animals and the provision of wheelchair assistance, code-share performance data reporting, antitrust immunity, the mishandled baggage statistics rule, the tarmac delay rule, DOT regulation of airline customer service plans, DOT rules governing mistake fares, pilot training and qualification requirements, FAA operations specifications, and many others.
It will take the Department some time to review and evaluate comments filed to date before making any decision as to what changes, if any, should be made to existing regulations. We will continue to monitor this matter and keep our readers appraised of any new developments.
If you have any questions, please contact Evelyn Sahr (esahr@eckertseamans.com, 202-659-6622) or Drew Derco (dderco@eckertseamans.com, 202-659-6665).
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