Two things stand out to me so far in the new ruling:

"Canceled or significantly changed flights: Passengers will be entitled to a refund if their flight is canceled or significantly changed, and they do not accept alternative transportation or travel credits offered. For the first time, the rule defines “significant change.” Significant changes to a flight include departure or arrival times that are more than 3 hours domestically and 6 hours internationally; departures or arrivals from a different airport; increases in the number of connections; instances where passengers are downgraded to a lower class of service; or connections at different airports or flights on different planes that are less accessible or accommodating to a person with a disability."

This refers to *changes* to flights/itineraries (e.g. an EU261-like rule). Does a delay constitute a "significant change"? I don't think so based on this wording. I think it's directed towards a schedule change that's made in advance and not day-of. Of course this rule can also apply to itineraries changed at the airport due to IROPS. But, a rolling delay (mechanical, weather, etc.) doesn't IMO. I'm sure the intent of this rule will be misconstrued. So, IMO, United should not be changing its 2 hour policy.

"Full amount: Airlines and ticket agents must provide full refunds of the ticket purchase price, minus the value of any portion of transportation already used. The refunds must include all government-imposed taxes and fees and airline-imposed fees, regardless of whether the taxes or fees are refundable to airlines."

This remains ambiguous and allows airlines like United to reprice your ticket as if you flew a one-way and offer a significantly reduced, or some cases zero, refund for the return portion (except for taxes). The DOT could have done work here to clarify this because I expect zero change on United's part in screwing over customers.

-RM