The DOT is changing a number of rules relating to commercial air traffic. The public comment period is open right now.

What the DOT is proposing:

http://www.dot.gov/affairs/2010/dot11010.html

Background of the problems they see:

http://www.dot.gov/affairs/2010/Back...on%20Rule.html

My thought is we use this as an opportunity to guide the DOT rules. Goals: 1) abolish some of the bad sales and operations practices DL has. 2) In lieu of abolishing them, require they are explicitly documented in the CoC.

To make comment go to:

http://www.regulations.gov/search/Regs/home.html#home

Click on "Submit a Comment" and enter docket ID: DOT-OST-2010-0140
Click Search. You'll see the rule making documents. Click "Submit a Comment"

I would also say the rule making process isn't the venue for complaining about DL. The purpose is to comments on the rules, but I don't see an issue highlighting real world examples that will assist the DOT in closing loopholes..

Outside of voicing support for the DOT list I'm going to comment on:

A Fares treated like Y fares at DLs discretion.

What else would be appropriate to comment on?

Thanks for the heads up.

My additions to the list:

1) The farce of "direct flights" and how DL management handles them
2) Reporting of mechanical delays and cancellations as a separate, trackable class of event (get them out of the "all airline caused" category
3) Mandatory refund of bag fees for lost or delayed baggage... in real currency, not DL dollars
4) More generally, Dl's tendency to try to provide refunds in DL dollars (e.g., in the case of a downgrade in a paid fare)
5) More transparency in the classification and reporting of delays. For example, mechanical delays that get re-classed at WX. Misreporting of actual delay times (my favorite... pilot apologizes for begin 23 minutes late in the departure, DL computer shows a 9 minute delay.

Or go to:

http://www.regulations.gov/search/Re...00006480b09f7a

The OP does a service by providing a link for formal comments, but it's not as if bad practices are limited to Delta. Here's a list of DOT's Aviation Consumer Protection Division enforcement orders over the last year:

Enforcement Orders

COPA Airlines, disability reporting 2010-07-15
Delta Air Lines and Northwest Airlines, codeshare disclosure 2010-07-04
Sceptre Tours 2010-06-28
Cayman Airways 2010-06-21
Mercy Flights 2010-06-18
FarePortal 2010-05-31
Delta Airlines 2010-05-30
AirTran Airways 2010-05-29
Falcon Air 2010-05-15
Continental Airlines 2010-05-09
RM Aviation 2010-05-01
Aero Services 2010-04-17
Southwest Airlines 2010-04-14
Bahamas Air 2010-02-27
Luxury Air Jets 2010-02-17
Myrtle Beach Direct Air & Tours 2010-02-16
United Airlines Inc. 2010-01-13
TAM Linhas Aereas 2010-01-08
Canadian Helicopters Limited 2009-09-10
Spirit Airlines 2009-09-08
Costa Cruise Lines 2009-09-03
United Air Lines 2009-08-17
Quebec d/b/a Univair Aviation 2009-08-12
Hawaiian Airlines, Inc. 2009-08-04
Continental Airlines, Inc. 2009-08-03
U.S. Airways, Inc. 2009-08-02

For the details, http://airconsumer.ost.dot.gov/rules/consentorders.htm

Since I'm Hub bound and almost everything I fly is a true non-stop. What is the issue with it?

The DOT docs seem to indicate this is the direction they are going in, so I would recommend voicing support. See the DOT background document for bullet items to quote.

I'm not sure where to shoehorn that into their RFC. You might want to tie it into the IDB changes, indicating the airlines should have more detailed reporting in order to track compliance.

Because there's nothing "direct" about it -- it's misleading.

Wow! With more than 3000 posts, have you been living in a cave?

One example: The other day I was on DL61 which goes JFK/ATL/GIG. It arrives in ATL at concourse A and leaves from concourse T on a different plane altogether. It's planned - NOT a last minute aircraft swap. JFK/ATL is late, and the thru pax onboard assume they'll be ok going on to Rio! But noooo!! ATL/GIG leaves on time. Also, often times it's even a different aircraft TYPE indicating that the whole "direct flight" concept is kind of a scam! A side note is that the airlines only give FF miles from A to C as opposoed to A to B + B to C. Did I miss anything?

So perhaps we could say:

Some airlines engage in the deceptive marketing practice of claiming traditional connecting service flights as a "direct flight". These so called "direct flights" have stops, involve plane change(s) and often terminal changes. Because it is not truly direct in anyway the consumer is mislead about the inherent connection/misconnection risks. A weather delay in a connection city could cost the consumer hundreds of dollars in hotel, transportation and phone costs.

Good comments so far... Definitely include the item about some fares being sold and market as first class, but the airline treating them as coach in the situation of cancellation or misconnect... in particular searching for first class and being presented with a first class fare which is a -UP fare, but nowhere does it state that it is actually an upgraded coach ticket.

It will be interesting to see how airlines react with the DBC going up to 650... I wonder if they'll adjust their algorithms to not oversell as much.

Only one thing....unless really look for it on DL.com - all indications are that the flight is truly direct. I did ICN->PDX last week. That's what the Itinerary said. 1 flight number, no indications there was a stop. Had no clue until about 1 week before there was a stop in NRT. At least it was the same aircraft type (no seat issues) but due to a delay in the ICN->NRT part - I almost missed NRT->PDX. If I had known it wasn't a true non-stop - I might have booked differently

One more to add, abolish liability limits on items checked into luggage. Given that so many items now have electronics in them they can pretty much deny anything from an iPod to a coffee maker.

Which is why, of the six comments I submitted, 5 make reference to the industry in general.

Only the comment pertaining to DL's "A" fare class fraud was specific to DL... and even then, I allowed that other airlines might have similar practices.

I don't seek to discourage anyone from posting comments at the DOT site, in fact I encourage it.

But, it is going to take a lot of postings to be heard above the background noise.

109 pages of public comments... no, I did not read them all. But every one I opened, (repeat, every one) pertained to the peanut allergy issue.

Seriously?? With no way to verify what you had in the luggage you want there to be no liability limits.

What all big government people fail to understand is that NOTHING comes free. Impose a boat load of unreasonable rules that cost money - those costs gets passed along to the consumer.

Another issue:

Award tickets should have an allowed 24 hour no-fee cancellation period, just like purchased tickets.

http://www.flyertalk.com/forum/14379815-post37.html