Comments to DOT’s Proposed Rule on Consumer Information Regarding On-Demand Taxi Operations
January 28, 2014
Those in the air charter community have issued comments in response to the DOT’s NPRM on Consumer Information Regarding On-Demand Taxi Operations. A summary of some of the comments follows:
· A registry program should be available which would serve as a vehicle through which customers and the rest of the private air industry could vet potential air charter brokers. Information in the registry should include: information on the air charter broker, class of aircraft that is entitled to a broker, level of liability insurance, whether it acts as an indirect air carrier, agent for the customer or agent for the direct air carrier, and accident history.
· The rule should clarify what constitutes a broker versus an agent since an agent would fall outside the scope of the rule. When acting as an agent for a charterer, an actual charter customer (not the broker-agent) should be required to sign agreements for carriage with the direct air carrier.
· Indirect air carriers involved in air medical transport services should not be exempt from the rule. They should be required to disclose the air medical transport services medical/hospital affiliation as well as the aircraft operator.
· The rule would unduly burden air taxis and commuter carriers and are unnecessary since charterers are sophisticated entities that are capable of protecting their own interests and do not need consumer protections.
· Air charter brokers operating under a GSA Schedule contract should not have to obtain a certificate of authority since no member of the public can purchase a ticket under a GSA contract flight.