Tell DOT what you think of their proposed rules

by Charlie Leocha on June 11, 2010

In a dramatic effort to gather passenger comments about the newest rulemaking proposed by the Department of Transportation (DOT) the government has partnered with Cornell University and created Regulationroom.org.

This is the place make any comments about the sweeping new rulemaking that has been proposed by DOT. This is the website that will allow passengers to file their comments for review by DOT and help shape the final outcome of the rulemaking.

For those who are interested, click here to download the complete proposed rulemaking.

Read through it. If you are a traveler, these new rules will affect you every time you get on an airplane or purchase a ticket.

This collection of proposed rules increases compensation for travelers bumped involuntarily from flights, allows passengers to cancel reservations within 24 hours at no charge and requires full disclosure of baggage fees among other issues.

Read through columns that will be published on ConsumerTraveler.com, at ConsumerTravelAlliance.org, on Elliott.org and other websites. Pay attention to articles in your daily papers.

If you want to give the government a piece of your mind concerning these new rules, go to www.regulationroom.org and let the DOT know how you feel.

You might say something like:

From my point of view the most important part of these new rules are regarding the release of all airline fees at the same time as airfares. With unbundling of airfares, consumers must know all of the costs before they can make an informed decision.

Or,

It’s about time that passengers get a 24-hour ticket refund/change rule to change their mind, change a mistake they might make when purchasing a ticket or to change the date of travel.

This outreach to the public is one of the first times that the government has directly sought comments regarding a rulemaking that will have dramatic effects. How well the public responds to this effort will also dictate whether the administration will continue with this kind of collection of public sentiment.

You’ll have to register. The site can be slow at times. Moderators often ask for additional comments. All in all this is a grand first effort at collecting comments directly from the public.

In Washington, there are two major ways that change is effected. One is through the legislative process whereby a bill is introduced to Congress, passed by both the Senate and the House of Representatives and then signed into law by the President.

The second is through rulemaking. In this process, the department in charge of a particular area of administering the law creates proposed rules, published them for comment (normally 60 days) and then decides on the final rule based on the comments.

The legislative path leads through a Byzantine path of congressional committees on one side of the Hill in either the Senate or House of Representatives. Once the bill is passed by the House or Senate, it begins its path through the other legislative body going through committee hearings and votes once again.

The rulemaking path is different but just as difficult. First, the department involved, DOT for our purposes right now, studies the situation and creates rules after consulting with what Washington calls “stakeholders” in the process. Then after months (sometimes years) of consideration, analysis of budgetary impact and careful drafting, DOT releases a notice of proposed rulemaking (NPRM).

This release of the NPRM is followed by a comment period (in this case, 60 days) from airlines, airports, air traffic controllers, pilots, flight attendant and consumers. After the comment period the DOT will huddle and create the final rule that will be published in the Code of Federal Regulations (CFR).

Access to the legislators and regulators in order to influence either of these paths is the work of lobbyists and advocacy groups. Their value is in the knowledge of the legislative path and regulation rules that must be followed. These lobbyists and other advocacy groups all eventually develop contacts within various committees, with Senators and Congressmen, with regulators and administrators so that they can keep their constituents’ views in front of those who make the final decisions on either a bill or a rulemaking.

Using this website, www.regulationroom.org, allow consumers to speak directly to DOT without the need for lobbyists or advocacy groups. This as a dramatic outreach to the American public.

We are dissecting this rulemaking and writing about it every day at least for the next few weeks. Please take time to read our columns and them make your comments both on our website and directly to DOT through www.regulationroom.org.

Columns that focus on issues in this proposed DOT rulemaking —

Goverment will require airlines to offer complete picture of ground delays

New tarmac delay contingency plans — what’s in it for you?

Airline fees are here to stay, tell passengers up front

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