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Comments to Department of Transportation on Airline Ticket Refunds

DOT recently proposed a rule that would require airlines to issue refunds or non-expiring vouchers to consumers whose flights are significantly delayed or canceled or who decide not to travel for certain health reasons. Policy Integrity submitted comments in support of the proposal, and made recommendations to clarify and strengthen the final rule. In particular, we recommend that DOT strengthen the reasoning and economic foundation of the final rule by considering the following:

  • explicitly discussing fairness as a benefit in its Regulatory Impact Analysis;
  • explaining that there are benefits to codifying a rule, even if it is largely reflective of existing, voluntary policies in the affected industry;
  • acknowledging the benefits of potential behavioral changes, including the potential for reduced disease transmission;
  • defining the term "significant government assistance” to mitigate the costs DOT attributes to the lack of a clear definition; and
  • expressly concluding that the benefits of the Proposed Rule outweigh the costs.