Travel Tech Association, Author at Travel Tech Association

The Travel Technology Association (Travel Tech) filed comments on legislation currently under consideration in New York that would further regulate short-term rentals by creating a registration system and increasing taxes on rentals. The comments shared by Travel Tech describe several problems proposed bill S. 885 creates that must be addressed.

The filing points out that S.885 is inconsistent with several state and federal laws that regulate rental listings including the Communications Decency Act, and the Stored Communications Act.

The filing also illustrates how other states have instituted registration systems that provide value to municipalities without placing an unnecessary burden on homeowners or rental platforms.

“We are eager to work with you to create a legal framework for short-term rentals in New York State that balances the interests of municipalities, communities, and homeowners; however, several legal and practical problems with S. 885 require urgent attention,” Laura Chadwick, President and CEO of Travel Tech, wrote in the comments. “We urge you to continue to consult with our members and other stakeholders before establishing any new short-term rental registration system and regulatory regime.”

The Travel Technology Association (Travel Tech) is the voice of the travel technology industry, advocating for public policy that promotes transparency and competition in the marketplace to encourage innovation and preserve consumer choice. Travel Tech represents the leading innovators in travel technology, including global distribution systems, online travel agencies, and metasearch companies, travel management companies, and short-term rental platforms.

To schedule an interview with a Travel Tech spokesperson, contact Dan Rene of kglobal at 202-329-8357 or daniel.rene@kglobal.com.

White Paper Submitted to House Transportation & Infrastructure and Senate Commerce Committees

The Travel Technology Association (Travel Tech), the voice of the travel technology industry and consistent advocate for public policy that supports a competitive and transparent marketplace, released its priorities for the upcoming Federal Aviation Administration (FAA) Reauthorization by Congress. The priority list and related justification for the recommendations are contained in a white paper submitted to the U.S. Senate’s Commerce Committee and U.S. House of Representatives’ Transportation & Infrastructure Committee.

“The upcoming reauthorization of the FAA gives Congress a very timely opportunity to improve air travel for their constituents. Travel Tech members provide air travel booking services for millions of consumers each year,” said Laura Chadwick, President and CEO of the Travel Technology Association. “Our priorities for the reauthorization — ensuring ticket agents are a part of the US Department of Transportation’s consumer protection efforts, providing travelers with ancillary fee information early in the booking process and making timely refunds — are aligned with Congressional efforts.”

The Travel Technology Association (Travel Tech) is the voice of the travel technology industry, advocating for public policy that promotes transparency and competition in the marketplace to encourage innovation and preserve consumer choice. Travel Tech represents the leading innovators in travel technology, including global distribution systems, online travel agencies and metasearch companies, travel management companies, and short-term rental platforms.

To schedule an interview with a Travel Tech spokesperson, contact Dan Rene of kglobal at 202-329-8357 or daniel.rene@kglobal.com.

Any Future Regulations Should Apply Equally to All Entities Supplying Travel Pricing Information

[Arlington, VA] [February 8, 2023] – The Travel Technology Association (Travel Tech), the voice of the travel technology industry and consistent advocate for public policy that supports a competitive and transparent marketplace, filed comments today in response to the Federal Trade Commission’s (FTC) Advance Notice of Proposed Rulemaking (ANPR) seeking comments on the “prevalence of fee practices that may be unfair or deceptive acts or practices,” (Commission Matter No. R207011).

“Travel Tech members are steadfast advocates for transparency. It is core to their business models and the services they provide to consumers,” stated Laura Chadwick, President & CEO of the Travel Technology Association. “Across all aspects of travel planning, transparency allows travelers to compare options, make informed choices, and receive the best value.”

In its comments, Travel Tech details how its members provide travelers with all information provided to them by accommodation suppliers so consumers are aware of the resort fees that will be assessed on-site.

Travel Tech’s comments also address how ambiguous or overly narrow rules potentially adopted by the FTC may impact the online travel marketplace.

“Any regulation in this area must apply equally to all entities advertising travel pricing information to consumers both online and offline. Without a level playing field, it could distort the online marketplace for travel, and lead to more consumer frustration, and not less.”

The Travel Technology Association (Travel Tech) is the voice of the travel technology industry, advocating for public policy that promotes transparency and competition in the marketplace to encourage innovation and preserve consumer choice. Travel Tech represents the leading innovators in travel technology, including global distribution systems, online travel agencies and metasearch companies, travel management companies, and short-term rental platforms.

To schedule an interview with a Travel Tech spokesperson, contact Dan Rene of kglobal at 202-329-8357 or daniel.rene@kglobal.com.

“Travel Tech has long supported the U.S. Department of Transportation’s efforts to ensure consumers have access to critical ancillary fee information. We did so in 2014 and are doing so again in 2023,” stated Laura Chadwick, President & CEO of the Travel Technology Association. “For too long, consumers have lacked the consistent ability to know the true cost of different flight options.”

In its comments, Travel Tech addresses how ancillary fee information should be provided to ticket agents. In its proposed rule, the DOT seeks to omit global distribution systems from receiving mandatory ancillary fee data from airlines.

“Travel Tech strongly recommends that ancillary fee data be shared with all channels that distribute fare and schedule information,” Chadwick continued. “It is the most simple and direct way to solve the issue of ancillary fee transparency for consumers.”

Travel Tech also filed a petition today requesting a hearing on DOT’s proposed requirement to display the critical ancillary fee information on the first page of online search results. Travel Tech addresses this matter in its comments.

“Our members are the leading innovators in creating consumer-friendly online travel information sites. We are deeply concerned about the DOT’s first-page search results requirements included in the proposed regulation. These rules, if adopted as written, will clutter and confuse the online air travel shopping experience for consumers. This is especially true for travel comparison sites that display multiple airlines’ schedules and fares,” said Chadwick.

“In our comments and hearing petition, we argue that the Department should not displace ticket agents’ well-established expertise with a government-regulated website design mandate. Ticket agents should have the flexibility to design appropriate displays of ancillary fees and develop innovative new methods for consumers as well,” Chadwick continued.

The Travel Technology Association (Travel Tech) is the voice of the travel technology industry, advocating for public policy that promotes transparency and competition in the marketplace to encourage innovation and preserve consumer choice. Travel Tech represents the leading innovators in travel technology, including global distribution systems, online travel agencies and metasearch companies, travel management companies, and short-term rental platforms.

To schedule an interview with a Travel Tech spokesperson, contact Dan Rene of kglobal at 202-329-8357 or daniel.rene@kglobal.com.

On Monday, January 9, 2023, the Travel Technology Association filed comments with the Federal Trade Commission (FTC) regarding the value of first-hand, timely traveler reviews. The comments, in response to FTC’s Advance Notice of Proposed Rulemaking, focus on how consumers benefit from the ability to make informed choices when considering travel plans.

The comments state in part that “…Reviews or other quality rankings are often incorporated into search results to help consumers find, compare, assess, and book travel-related services based on a variety of factors, including value, quality, and safety. Consumers greatly value these services, and they are a key driver for travel planning and decision-making…”

In the filing, Travel Tech also encourages the FTC to “…utilize its existing authority to combat bad actors that employ the increasingly nefarious paid review-generation sites…” or “click farms.”

“On behalf of members of the Travel Technology Association, we congratulate Senators Jacky Rosen (D-NV) and Roger Wicker (R-MS) on the inclusion of their bipartisan Omnibus Travel and Tourism Act of 2021 in the Consolidated Appropriations Act of 2023 passed by Congress and signed into law by President Biden.

We look forward to working with the first Assistant Secretary of Commerce for Travel and Tourism, a new position established by the Omnibus Travel and Tourism Act. Technology continues to be a critical tool in supporting consumer travel discovery and facilitating bookings and entry into the US.

Our members, the leading innovators in travel technology, including global distribution systems, online travel agencies and metasearch companies, travel management companies, and short-term rental platforms, stand ready to support the new secretary and their efforts to develop and implement a new national strategy to increase travel to and within the U.S.”

Travel Technology Association Advocates for Airlines and Ticket Agents to Issue Refunds as Required

[Arlington, VA] [December 19, 2022] – The Travel Technology Association (Travel Tech), the voice of the travel technology industry and a consistent advocate for public policy that supports a competitive and transparent marketplace, filed comments today in response to the Department of Transportation’s (DOT) Notice of Proposed Rulemaking (NPRM) on “Airline Ticket Refunds and Consumer Protections,” – Docket No. DOT-OST-2022-0089.

“On behalf of consumers and our member companies that serve them, the Travel Technology Association is proud to stand with the U.S. Department of Transportation in assuring once and for all that airline travelers are made whole when their flights are canceled,” said Travel Tech President and CEO Laura Chadwick. “You get what you pay for, and when you don’t, you should get your money back.”

“We welcome the Department’s decision to define what constitutes a ‘canceled flight’ and ‘significant change to flight itinerary.’ These definitions will bring much-needed uniformity and clarity to what have been fraught and stressful experiences for travelers facing weather or airline staffing issues,” Chadwick continued. “Great customer service, whether before, during, or after a trip, is key to the value Travel Tech members offer. These definitions will help online travel agents better support their customers navigating frustrating flight cancellations and the labyrinth of airline customer service systems.”

In its comments, the Travel Technology Association explains that ticket agents are already bound to issue refunds “promptly” after airlines provide the authorization and funds to do so. In its draft rule, the Department proposes that customers receive refunds within seven days. However, it takes up to eleven days to secure refunds from airlines’ payment and refund systems.

“To require refunds before the funds are returned by the airline – as the proposed rule currently demands – would impose an undue financial burden and risk on ticket agents. We encourage the Department to revise this part of its proposal to reflect that airlines’ payment and refund systems are beyond the control of ticket agents.”

The Travel Technology Association (Travel Tech) is the voice of the travel technology industry, advocating for public policy that promotes transparency and competition in the marketplace to encourage innovation and preserve consumer choice. Travel Tech represents the leading innovators in travel technology, including global distribution systems, online travel agencies and metasearch companies, travel management companies, and short-term rental platforms.

To schedule an interview with a Travel Tech spokesperson, contact Dan Rene of kglobal at 202-329-8357 or daniel.rene@kglobal.com.

On behalf of the Travel Technology Association (“Travel Tech”), thank you again for the opportunity to address this meeting of the Aviation Consumer Protection Advisory Committee (ACPAC) about the Department of Transportation’s (DOT) Ancillary Fees Transparency Notice of Proposed Rulemaking (NPRM) proceeding. Travel Tech advocates for public policy that promotes market transparency and competition to encourage innovation and preserve consumer choice. We represent the leading innovators in travel technology, including online travel agencies and metasearch companies, travel management companies, global distribution systems, and short-term rental platforms.

As I stated earlier, the Travel Technology Association applauds the Department’s continuing work and commitment to this vital consumer protection matter. Travel Tech has long advocated not only for ancillary fee transparency for airlines but resort fee transparency for hotels as well. In 2014 and 2017, we supported the Department’s proposals to require airlines to share their ancillary fee information with ticket agents so that consumers could have complete visibility into the cost of their flight options, regardless of whether they use a direct or indirect channel to book their air travel. This is a worthwhile undertaking, and we stand ready to support you, ACPAC members, and the Department as it moves forward.

Today, the current state of play is this: as the text of NPRM notes, “While fare, schedule, and availability information are currently provided by the airlines to the GDSs, and by GDSs to the agents that display and sell to consumers, information about the cost of ancillary services is not typically shared.” (emphasis added.) As a practical result, consumers lack transparency about the ancillary fee costs prior to the purchase of their tickets through online travel agencies. Nonetheless, this same NPRM does not specify how critical ancillary information is to be disseminated to ticket agents, many of which currently receive fare and schedule information from a range of sources. The Department proposes to exclude GDSs from distributing ancillary fee information, even though the Department itself acknowledges that “GDSs may provide the lowest cost and most efficient way of distributing [fee] information to ticket agents that sell or display the carrier’s ancillary services.”

Many are asking the reasonable question as to why the Department would forgo such an obvious solution to the distribution of ancillary service fee information when the airlines are already choosing GDS technology to distribute their fares, schedules, and availability. The Department shares its reason why in the NPRM itself: stating that it is “attempting to minimize government interference with business relationships.”

The Travel Technology Association strongly believes that DOT must require the airlines to share ancillary fees through the same distribution channels utilized by ticket agents and metasearch sites for fare, schedule, and availability information. The Department should reconsider its conclusion to exclude GDSs in an effort to minimize government interference with contracts between airlines and GDSs. The cleanest, most direct way to solve the issue of transparency for consumers is for the airlines to provide the ancillary fee data to GDSs along with fare, schedule, and availability information as they already do. Travel Technology Association members agree that this is the most sensical approach, as do many of the other stakeholders gathered here today. Additionally, GDSs are not the only source of information for ticket agents, and distribution through all channels used to distribute fare and schedule information – such as ATPCO, and other intermediaries and aggregators – should also be required.

In the end, any requirement by the Department that airlines must share fee information with ticket agents will necessarily have some impact on business relationships. It’s inescapable. Under the Department’s NPRM proposal, ticket agents will nonetheless be forced to forge new business relationships and negotiate with more than 200 airlines in order to display this ancillary fee information. This does not make sense. Ticket agents will have to supplement the fare, schedule, and availability information they already receive through the GDS and match it to the ancillary data provided directly by the airline, a herculean task beyond the scope of a ticket agent’s day-to-day operations. Ticket agents will each individually need to take on resource-intensive development costs to make the ancillary information visible and usable on their platforms. These costs are prohibitive for many agents and a hardship as well since a clear solution already exists and is widely used – that the airlines provide ancillary data through all distribution sales channels already utilized by ticket agents and metasearch sites, including GDS, ATPCO, and other intermediaries and aggregators. This is the Travel Technology Association’s position on the matter. Again, it is the cleanest, most direct way to solve the issue of transparency for consumers, and we hope, ACPAC members, that you will agree.

There is no reason to draw the line arbitrarily at GDSs and force ticket agents to take on the development and business costs that have already been provided by the GDSs. The Department announced a different approach in 2017. After considering the substantial number of comments filed on the issue in response to its 2014 rulemaking notice on ancillary fees, it issued a supplemental rulemaking notice where it concluded that airlines should be required to share ancillary baggage fees with GDSs. We submit that the Department was right then and should follow that same determination here. Otherwise, in the end, it will be the consumer who will suffer, when this rulemaking’s ostensible purpose is to improve consumer outcomes.

On behalf of the Travel Technology Association (“Travel Tech”), thank you for the opportunity to address this meeting of the Aviation Consumer Protection Advisory Committee (ACPAC) about the Department of Transportation’s (DOT) Ancillary Fees Transparency Notice of Proposed Rulemaking (NPRM) proceeding. Travel Tech advocates for public policy that promotes market transparency and competition to encourage innovation and preserve consumer choice. We represent the leading innovators in travel technology, including online travel agencies and metasearch companies, travel management companies, global distribution systems, and short-term rental platforms.

Travel Technology Association members are critical stakeholders in this matter as they will directly implement many provisions of the final regulation. Millions of Americans rely on our member companies to do comparative searches to find the best flight options and to book their airline travel. Many of the proposals in the proposed NPRM will impact intensely complex back-end systems maintained or supported by Travel Tech members and the corresponding display of billions of dynamic data points. As such, our members continue to review the text of the proposed rule and develop our written comments to be submitted in a few days on December 19^th, 2022 or, as we hope, on some extended due date that will allow us further time to complete our deliberations and provide robust comments to the Department.

First and foremost, the Travel Technology Association applauds the Department’s continuing work and commitment to this vital consumer protection matter. Travel Tech has long advocated for ancillary fee transparency for airlines and resort fees for hotels as well. In 2014 and 2017, we supported the Department’s proposals to require airlines to share their ancillary fee information with ticket agents so that consumers could have complete visibility into the cost of their flight options, regardless of whether they use a direct or indirect channel to book their air travel. This is a worthwhile undertaking, and we stand ready to support you, ACPAC members, and the Department as it moves forward.

One of the core provisions of the proposed ancillary fee rule would require the first-page display of the fees for a first checked bag, a second checked bag, and a carry-on bag, adjusted based on passenger-specific information along with the sought-after fare and schedule information – with no links, roll-overs or other forms of flexible display allowed. The proposed rule would also require first-page display of the change and cancellation fees, and family-travel seat fees, again with no links and roll-overs or other forms of flexible display allowed[U1] . These provisions taken together are problematic for both consumers and Travel Tech members alike.

Consumers value online travel agents for their ability to facilitate the easy comparison and booking of multiple multi-brand options in a single location. By their very nature, our members’ sites offer consumers an array of flight options and information. For example, flying to Washington, DC, can entail flight search results for three different airports across at least 20 different airlines – the results can be overwhelming even for those who make this area our home. To mitigate the impact of a dizzying amount of information, online travel agents routinely invest in user interface (UX) design upgrades and usability testing to maximize customers’ satisfaction and streamline their buying experience. Travel Tech members, as a result, are deeply concerned about the Department’s proscriptive requirements to display ancillary fee information on the first page of search results and not on subsequent pages that customers routinely navigate through once a particular flight option has been selected.

A first search page display requirement for all critical ancillary fees will result in unacceptable screen clutter that will make locating flight options and information more, not less, of a challenge for consumers. Such information overload would diminish the very value our Travel Tech members offer to consumers in the first place. An overwhelming search experience could provide a real impetus for consumers to forgo comparison shopping altogether. Instead, they would potentially seek out airlines’ far more streamlined and to-the-point web pages since airlines only need to display their ancillary fee information alongside their flight offerings.

Members of the Travel Technology Association strongly believe that flexibility is essential on when and where ancillary information is displayed in search results – so long as consumers can view this information before purchase. Indeed, the Department itself states the same in the proposed rule on Page 63725 — that the goal is “to ensure that fee information about ancillary services that are critical to a consumer’s decision making is disclosed at all points of sale before ticket purchase.” (emphasis added)

Further making a case for flexibility is that the Internet is changing, and how consumers search for flight information will undoubtedly change too. I speak from my recent and direct experience working with cutting-edge innovators developing virtual, augmented, and mixed reality technology, encompassing Web3 and metaverses. The internet searches of the future will be far more immersive and embodied, with the results contextualized, even when viewed on a laptop or mobile device. Information will no longer be statically placed on a webpage or traditional seat map. Instead, it could be “seen” online floating over the seat in a “digital twin” replica of the interior of an airplane. Leading consumer brands have already begun to offer products online in this manner as if the internet shopper is viewing them in person; one can imagine how this could apply to many facets of the travel industry. By requiring the use of weblinks, rollovers, or even an opt-out option, the Department may inadvertently forestall the development of better, more innovative display options for consumers in the future.

I thank members of the ACPAC and the Department for the opportunity to address these important points about the need for flexibility in the display of critical ancillary fees to support customers and innovation as well. I welcome your questions and comments.

Laura Chadwick, President and CEO of Travel Technology Association submitted comments concerning the Mayor’s Office of Special Enforcement’s Proposed Rules regarding short-term rentals in New York City.

Travel Tech advocates for public policy that promotes market transparency and competition to encourage innovation and preserve consumer choice. We represent the leading innovators in travel technology, including global distribution systems, online travel agencies and metasearch companies, travel management companies, and short-term rental platforms.

Travel Tech Association Letter re NYC LL 18 Proposed Rules encourages New York officials to work with Travel Tech members to identify a way forward that works for New Yorkers, travelers, and third-party booking platforms.

Travel Tech Live Webinar: Top 7 Takeaways on New U.S. DOT Ancillary Fee and Refunds Rules – Watch Now

May 15, 2024

On Wednesday, May 8th, Travel Tech hosted airline industry attorneys Jol A. Silversmith and Barbara Marrin of KMA Zuckert to outline the “Top 7 Takeaways on the New U.S. DOT Ancillary Fee and Refunds Rules.” As discussed in the webinar, both rules have serious implications for both large and small travel technology businesses. Did you […]

Travel Tech Submits Public Comment on Proposed Short-Term Rental Rules

Travel Tech Live Webinar: Top 7 Takeaways on New U.S. DOT Ancillary Fee and Refunds Rules – Watch Now

How Online Travel Platforms Benefit Independent Hotels

Contact

Media Inquiries

Address