Ticketless Travel: Passenger Notices

DEPARTMENT OF TRANSPORTATION

Office of the Secretary

14 CFR Ch. II

[Docket No. OST-96-993]

RIN 2105-AC36

Ticketless Travel: Passenger Notices

AGENCY: Office of the Secretary, DOT.

ACTION: Statement of compliance policy.

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SUMMARY: The Department is issuing a statement of compliance policy

that states that the ticket notices required by various DOT rules must

be given (or be made readily available) to ``ticketless'' airline

passengers no later than the time that they check in at the airport for

the first flight in their itinerary.

EFFECTIVE DATE: This statement of compliance policy takes effect May

22, 1997.

FOR FURTHER INFORMATION CONTACT: Tim Kelly, Aviation Consumer

Protection Division, Office of Aviation Enforcement and Proceedings,

Office of the General Counsel, Department of Transportation, 400

Seventh Street SW., Room 4107, Washington, DC 20590, telephone (202)

366-5952. An electronic version of this statement of compliance policy

will be available at http://www.dot.gov/dotinfo/general/rules/

aviation.html shortly after publication in the Federal Register.

SUPPLEMENTARY INFORMATION:

Background

Various DOT regulations require U.S. and foreign air carriers to

provide consumer notices on or with passenger tickets. These notices

provide information about protections afforded by federal regulations,

limitations on carrier liability, and contract terms that passengers

may not otherwise be aware of. These ticket notice requirements are

listed below.

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Subject Source (14 CFR)

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Oversales................................ Sec. 250.11

Domestic baggage liability............... Sec. 254.5

International baggage liability.......... Sec. 221.176

Domestic contract of carriage terms...... Sec. 253.5

Terms of electronic tariff Sec. 221.177(b)

(international).

Refund penalties (domestic).............. Sec. 253.7

Fare increases (international)........... Sec. 221.174

Death/injury liability limits Sec. 221.175

(international).

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Over the past few years, a number of airlines have introduced

``ticketless travel,'' also known as ``electronic ticketing.'' Under

this concept a passenger calls the airline, makes a reservation and

purchases the transportation during the call, typically by credit card.

Electronic tickets can also be purchased from travel agencies in many

cases. No ``ticket,'' as that document has traditionally been

configured, is issued. Instead, the passenger is orally given a

confirmation number and/or is sent a written itinerary. Upon checking

in at the airport the passenger simply provides his or her name,

furnishes identification, and is given a boarding pass or other

document that is used to gain access to the aircraft.

The Department of Transportation supports the development of

ticketless travel. The process has the potential to reduce carrier and

agent costs, and thereby costs to consumers, and to make air

transportation easier to purchase. At the same time, the Department has

been concerned that necessary information in the ticket notices

described above be provided to passengers in a ticketless environment.

Consequently, on January 19, 1996, we published in the Federal Register

a Request for Comments on the issue of passenger notices for ticketless

transactions (61 FR 1309).

Comments

We received 28 comments in response to the Federal Register notice.

Three were from industry associations: the Air Transport Association of

America (ATA), the International Air Transport Association (IATA), and

the American Society of Travel Agents (ASTA). Eleven comments were from

air carriers: United Air Lines, American Airlines, Delta Air Lines,

Trans World Airlines, Continental Airlines, Southwest Airlines, Alaska

Airlines, ValuJet Airlines, Western Pacific Airlines, Vanguard

Airlines, and KLM Royal Dutch Airlines. We also received comments from

four travel agencies (Costa Azul Tours and Travel, Carlson Wagonlit

Travel, Meston Travel Center, and Vista Travel Service), four other

organizations (Best Fares magazine, Airclaims, Ltd., QuickTix, and

Stone & Webster Management Consultants), five individuals (Mr. Philip

Sheridan, Mr. Laurence Hecker, Mr. Andrew Pickens, Mr. Peter Lyck, and

Mr. Benjamin Dornic), and from Mr. Jeremy Silverman and Mr. Gregory

Gerdes on behalf of their law school class.

In general the industry commenters did not object to providing the

notices that are currently required to be provided on or with tickets.

However, they urged the Department not to prescribe the manner in which

those notices are to be provided, e.g. the method or the time that they

are furnished to electronically ticketed passengers. The travel agent

commenters said that notice should be the responsibility of the

airlines, and that travel agencies should not be expected to bear the

cost. Most of the individual commenters said that electronically

ticketed passengers should receive written confirmation of their

reservation and fare in case there is a subsequent computer error.

ATA said that it anticipates that the consumer protection notices

that the Department's regulations require today will continue to be

provided. ATA, IATA, ASTA, most of the air carrier commenters, and

Airclaims, Ltd. said that consumer notices of the type provided with

tickets should continue to be provided, but they oppose regulation of

the method or time by which carriers must communicate those notices to

ticketless passengers. This will allow distribution systems to be more

flexible and therefore more responsive to the needs of passengers,

according to ATA. It will also generate significant efficiencies, which

ATA said is important in the industry's continuing efforts to provide

economical air transportation. Many of these commenters said that

regulating how and when the notices are to be delivered would impose

costs without commensurate benefits, and could impede emerging

technology.

IATA said that it strongly supports electronic ticketing, and that

it was still

[[Page 19474]]

developing standards for international and interline electronic

ticketing. Although they opposed detailed rules, IATA and ASTA

suggested that DOT should provide general guidelines for acceptable

times and methods for providing consumer notices.

Southwest said that 40% of its passengers are now ticketed

electronically. The carrier said that it mails or faxes the consumer

notices in question to its electronically ticketed passengers, but that

it may want to modify this procedure in the future in response to

consumer demand, new technology, or competition. Several of the

carriers said that there are many ways to get adequate notices to

passengers besides mailing them: for example, an annual mailing to

frequent flyers, a receipt provided at the airport or travel agency,

orally at the time of the reservation, on signs or handouts at the

airport, a fax-back service that will fax notices to passengers who

call a special number, or a notice screen for bookings that consumers

make via the internet or other online services.

ValuJet, a fully ticketless carrier, states that it currently

provides effective, oral notice concerning the customer's itinerary at

the time of the sale, as well as written notice when its customers

board. It contends that having to provide written notices at the time

of purchase would increase the cost of ticketless travel without

commensurate benefit.

Like ValuJet, Western Pacific and Vanguard are totally ticketless

carriers. They both said that they have procedures for providing what

they consider to be complete and timely notice to passengers. Like

ValuJet, these two airlines provide oral notice at the time of purchase

about important fare conditions, but do not provide any of the DOT

notices at the time of purchase, orally or in writing, except to note

that fares are non-refundable. All three carriers provide certain

written notices upon check-in, although these do not necessarily

include all of the DOT-mandated ticket notices or all of the required

text from these notices. These three carriers also state that they will

mail or fax written notices on request at any time.

ASTA said that notice of the reservation and fare will be provided

to clients ``when practical.'' ASTA suggests that general guidelines be

issued for delivery of other consumer notices, but that details on when

to provide the notices be left to the carrier or travel agency. If the

Department identifies deficiencies, it can then impose a more detailed

standard. For the moment, ASTA suggests that all of the consumer

notices be posted at airports, where passengers are more likely to see

them than in the fine print on tickets, which ASTA contends most

passengers don't read.

Several carriers and one travel agency chain advocated the concept

of a voicemail or ``audio-text'' system in which passengers could be

provided the choice of listening to recorded consumer notices at the

end of a reservation call, or at any other time. ValuJet estimated that

such a system could deliver a standard oral briefing by telephone for

as little as 25 cents per call.

Western Pacific described a menu-driven (``press 1 for baggage

information, 2 for oversales information * * *'') voice system that it

is studying to deliver all DOT standard notices, as well as other

information. The carrier says this system would provide the notices in

a timelier fashion than notices that arrive in the mail several days

after a telephone purchase; Western Pacific said this would be

particularly useful in the case of bookings made within a few days of

departure. (Western Pacific said that 20% of its bookings are made

within three days of departure; Vanguard said its figure is 10% to

15%.)

TWA said that carriers should not be required to provide notices to

an electronically ticketed passenger who does not request a written

confirmation, or who is offered the consumer notices but declines. TWA

and Continental described ATM-like machines that issue boarding passes

at airports, and can require passengers to choose whether or not to

receive the terms and conditions of travel and other notices. They said

that carriers should have the flexibility to deliver notices by means

such as this.

Generally, the individual travel agency commenters stated that

notice should be the responsibility of the airlines and that it could

be provided during check-in. Mr. Tom Parsons of Best Fares magazine,

however, said that ``inspecting a contract at the airport gate is like

reading the warranty on your new car after you buy it.'' Mr. Parsons

said that the notices could be provided through the computer

reservations systems; Airclaims, Ltd. suggested handouts at the point

of sale. Neither of these proposals, however, indicate how the notices

would be provided to persons who book by phone.

Meston Travel said that it gives its ticketless clients a written

confirmation of the reservation and fare and copies of consumer notices

at the time of purchase. Vista Travel said that the cost savings of

electronic ticketing have accrued to the airlines but not to travel

agencies; Vista believes that the costs of any new notice requirements

should be part of the cost of the transportation, and should not have

to be borne separately by travel agencies. Vista did say that

passengers should be provided documentation of their reservation and

fare before they arrive at the airport, or they will be at the mercy of

the carrier in the event of a computer error. Carlson Wagonlit pointed

out that many carriers rely on advertising to defray the cost of ticket

jackets, and that this could help support the cost of any notices that

must be delivered to electronically ticketed passengers at the time of

purchase.

In the Request for Comments, the Department sought comment on air

transportation purchases that take place via ``smart cards'' or online

computer services. ATA said that these types of electronic tickets

present no special issues. ATA asserts, as it does with regard to other

forms of electronic ticketing, that the carrier should be free to

determine the means of providing consumer notices. This could include

providing notices when a passenger signs an initial smart card form, or

electronic transmission of notices when transportation is purchased

online. ASTA echoed this idea, and said the notices could be provided

one time to regular clients similar to a ``signature on file''

agreement for credit card purchases.

IATA supported the concept of allowing carriers to provide notices

to users of smart cards at the time they enter into the agreement for

the card, although IATA said that alternatively the notices could be

generated each time the card is used. Delta said that it uses smart

cards on its east coast Shuttle. The carrier said that it provides DOT-

required notices at the time a smart card is issued, and also makes

them available at each smart card machine. IATA, several carriers and

Airclaims, Ltd. suggested that members of frequent-flyer programs could

be given the notices when they join the program, or annually. TWA

asserted that 33% to 50% of all passengers (depending on the carrier)

are members of a frequent-flyer program. United said that one-time or

annual notices to frequent flyers combined with other programs to

ensure reasonable notice to other customers would save costs without

having an adverse impact on the traveling public.

The Department requested comment on whether a passenger should be

able to have an independent record of his or her reservation status.

ATA said that electronic ticketing does not create any additional

likelihood that a passenger's record will be unlocatable. Continental

and Western Pacific said that the

[[Page 19475]]

confirmation number that is given to every electronically ticketed

passenger is the passenger's evidence of his or her reservation. TWA

said that the Department's concern over no-record passengers is

understandable in a historical context, but that over the past decade

there have been numerous improvements to CRS technology and that no-

record passengers are no longer a significant problem. The totally

ticketless carriers that commented (ValuJet, Western Pacific and

Vanguard) all said that they do not engage in deliberate overbooking

and as a result have few oversales. IATA said that current scenarios

contemplate some sort of confirmation being sent to passengers who book

sufficiently in advance and that this is likely to contain confirmation

of the reservation. However, IATA said, this should not be required by

regulation.

The Department requested comment on how carriers deal with fare

disputes with passengers, particularly those who purchase tickets by

phone. Both ATA and IATA simply asserted that this has not been a

problem. The passenger's fare ``will be included on passenger

receipts,'' ATA said. Western Pacific said that it experiences about

the same rate of fare disputes as paper-ticket carriers. It believes

most of these disputes arise from the customer's failure to listen

carefully to the fare restrictions information or the reservation

recap. Vanguard said that it has encountered virtually no fare

disputes.

However, a comment filed on behalf of a law school class by Jeremy

Silverman and Gregory Gerdes said that several of the members of the

class had had disputes over fares and reservations with ticketless

carriers. They stated that carriers should provide written confirmation

of the reservation and the fare to electronically ticketed passengers,

and that this notice should be provided on a timely basis. They also

noted the potential for problems in applying an unused electronic

ticket to another flight (with payment of the appropriate penalty)

after the departure date of the original flight; if the computer does

not reflect the fact that the passenger did not use the transportation,

the passenger does not have an unused flight coupon to prove this fact.

Mr. Laurence Heckler also expressed concern over reservation,

payment, and fare disputes and urged that carriers provide timely

written confirmation of these matters. Stone & Webster Management

Consultants stated that electronically ticketed passengers should

receive a confirmation of the fare and reservation and the DOT consumer

notices shortly after purchase. Costa Azul Travel said that it receives

many complaints about ticketless travel, although it didn't describe

them.

On the other hand, Mr. Andrew Pickens asserted that the notices on

paper tickets are unread and unnecessary. Mr. Philip Sheridan said that

he has been using ticketless travel for six months on United and

Southwest with no problems, and that the combination of the boarding

pass and his monthly credit card statement are all the documentation he

needs.

The Department sought comment on the costs of various notice

alternatives. Most of the comments on this point focused on the costs

of providing written notice at (or shortly after) the time of purchase.

According to ATA, the average current postage cost of mailing notices

to electronically ticketed passengers is 40 cents per passenger, but

this does not include other handling costs. Fifty million electronic

ticket transactions per year would yield a mailing cost of $20 million,

ATA said, while 150 million such transactions would cost $60 million.

ASTA asserted that having to provide notices can be a significant

cost factor (although it provided no figures). It highlighted the

burden on agencies by citing the thin profit margins in the travel

agency business resulting from changes in the commission structure and

airline initiatives to sell directly to passengers.

IATA provided no cost estimates, but said that distribution costs

would be affected by the number and length of the notices. IATA said

that the benefits of a DOT standard for consumer notices for

electronically ticketed passengers would be legal certainty,

consistency and uniformity, particularly in the international

environment. Potential negatives would be extra costs, and any

inconsistency between the required methods of distribution and the

electronic ticketing process.

ValuJet said that the cost of providing written notices at the time

of purchase, particularly passenger-specific itinerary information,

would be ``staggering'' in ValuJet's case. ValuJet and Western Pacific

both said that major airlines have significant back-office ticketing

systems that can be redirected at little incremental cost to print and

distribute written itineraries and notices to ticketless passengers.

ValuJet said that it would have to build such an infrastructure. It

estimates that postage to mail its notices would be $88,000 per month,

and additional distribution costs could be from $1 million to $2.33

million per month, which would be 17% to 42% of the carrier's 1995 net

income. Western Pacific estimated that mailing or faxing itineraries

and DOT notices within three days of purchase would cost approximately

$50,000 per month at present traffic levels. Vanguard estimated that

providing hard-copy notices at the time of sale would add $1 to the

cost of each of its transactions, or $2 million per year.

Discussion

We have decided as a matter of compliance policy not to pursue

remedial or punitive action if air carriers give, or make readily

available, to electronically ticketed passengers the written notices

required by the existing DOT ticket-notice rules no later than the time

that the passengers appear at the airport for the first flight in their

itinerary. We believe that this approach strikes the most reasonable

balance at this time between ensuring that important information

reaches consumers before they travel without inhibiting the development

of electronic ticketing and imposing additional costs that might stifle

industry innovations and result in higher prices for consumers. It also

puts all carriers on the same footing with respect to ticketless

notices; as a result of past DOT requests, many airlines currently mail

or fax consumer notices to ticketless customers at the time of

purchase, but some carriers do not.

Most of the industry commenters in this proceeding objected to the

prospect of specifically being required to provide notices at the time

of the purchase. The policy that we are implementing will not do so,

and thus will avoid imposing the costs of having to mail or otherwise

deliver written notices to ticketless passengers before the date of the

flight. We are particularly concerned about avoiding unnecessary costs

for totally-ticketless carriers, many of which are low-fare, new-

entrant airlines. As noted by ValuJet, the burden of a requirement to

provide written notices in advance of the flight would fall

disproportionately on totally-ticketless carriers since they do not

have the paper-ticket/mailing infrastructure of most larger airlines.

As a result, we could envision higher prices for consumers without

commensurate consumer benefits. The approach that we are taking will

also address the concerns expressed by travel agents; no travel agency

will be required to provide the current notices required with tickets

to ticketless passengers.

Ticketless travel is a dynamic and evolving element in the

marketing of air transportation. The Department will continue to

monitor developments in this field, and should consumer

[[Page 19476]]

problems related to inadequate passenger notice arise, we may propose

additional requirements in the future. We strongly encourage airlines

and travel agencies to work to avoid such problems, not only by making

the DOT ticket notices available to ticketless passengers at the

airport as required here but also by distributing them in other ways,

including those suggested in the comments in this proceeding. For

example, these notices could be included with newsletters or booklets

of terms and conditions mailed to members of a carrier's frequent-flyer

program or holders of the airline's affinity credit card or smart card,

posted in online booking services and on the carrier's World Wide Web

site, included in the carrier's printed timetables, or handed to

passengers who purchase electronic tickets in person (e.g., at an

airline's airport or city ticket office or at a travel agency).

Airlines may also wish to consider making the notices available in

recorded form on their reservations telephone lines (e.g., ``press 3 to

hear important consumer information'') or establishing a fax-back

service, where a consumer could call a certain phone number and have

the notices faxed to him or her. We also encourage travel agencies to

provide the notices during face-to-face transactions, or when the

agency would be mailing other documents in any event. These various

distribution methods would allow a passenger to be provided the notices

as far in advance as possible before the date of the flight, and in

many cases before purchasing the transportation. However, none of them

entails the cost of an individual mailing to each purchaser.

ASTA stated in its comments that the current notices in use by the

airlines on regular ticketed transactions do not conveniently fit on a

single sheet of paper while leaving room for other important

information that consumers routinely want to have in writing. We would

point out that much of the contractual language in notices on some

carriers' conventional tickets is not required by DOT, but is placed

there by the carrier for its own purposes. As we noted in our Request

for Comments, all of the DOT notices would fit on back of an 8\1/2\ x

11 sheet of paper, and if the international notices are not provided to

domestic passengers the domestic notices would fit on one side of such

a sheet. A sample of a domestic notice may be found at http://

www.dot.gov/general/rules/aviation.html.

ASTA and other commenters also suggested that airport signs may be

a superior method for providing notice to ticketless passengers. While

we are reluctant to rely solely on airport signs as a means of

passenger notice, we have decided to hold in abeyance a proposal that

we published in the Federal Register on June 3, 1996 (61 FR 27818) to

eliminate the required sign concerning oversales. We will publish a

separate document in the Federal Register to accomplish this. The

oversales sign will continue to be required until we have more

experience with any potential oversale problems involving ticketless

passengers.

As a result of the policy described here, the notices that are

currently required by DOT rules to accompany tickets will have to be

given or made readily available to ticketless passengers in writing no

later than when they appear at the airport for the first flight on

their itinerary. We can envision several ways of accomplishing this:

(1) Carriers could have a box or stack of the notice sheets on the

countertop at each staffed position at the ticket counter and at each

gate (since some passengers check in only at the ticket counter and

others only at the gate), with the box or stack prominently labeled

``Consumer Notices.''

(2) Carriers could keep a supply of the notices at a central

location within sight of all passengers near the ticket counter and

also near the carrier's gates.

(3) The carrier's agents could simply hand one of the notice sheets

to each passenger as they check in at the ticket counter and at the

gate, or hand it to every passenger at the ticket counter and at the

gates have a supply of the notices in sight in one of the ways

described above. The notice sheet would only have to be handed to a

passenger checking in for the first flight on his or her itinerary, but

carriers might choose to simply give it to all passengers in order to

cut down on procedure and labor time.

(4) Carriers could post a sign visible from each position at the

ticket counter and at each gate briefly describing the nature of the

notice (e.g., ``important consumer information'') and stating that a

copy is available from any counter or gate agent upon request. (It

would not be sufficient for a carrier to simply provide a copy of the

notice sheet to passengers who request it, without posting a sign,

since most passengers would not know that the notice exists.) If the

notice sheet is to be provided only upon request, manuals and training

would probably have to be updated to ensure that carrier agents are

aware of the distinction between this notice and other written material

that passengers are entitled to see upon request, e.g. the detailed

notice about boarding priorities and denied boarding compensation (14

CFR 250.9), the complete contract of carriage (14 CFR 253.4(b)), and a

copy of the DOT rule on the rights of airline passengers with

disabilities (14 CFR 382.45(d)).

If a carrier chooses to provide the notices in question to

ticketless passengers in advance of the flight date (as many airlines

do now), the policy described here will not require the notices to be

furnished to those passengers a second time when they check in at the

airport.

As indicated earlier, the Department sought comment on whether a

passenger should be able to have an independent record of his or her

reservation status in case a computer reservation record is lost. Based

on the information currently available to us, we agree with ATA that

electronic ticketing does not necessarily create any additional

likelihood that a passenger's record will be unlocatable. However,

there nonetheless appears to be the same likelihood of ``no record''

passengers as exists for passengers with paper tickets, and yet

ticketless passengers will not necessarily have written evidence of

their reservation. Continental and Western Pacific commented that a

ticketless passenger's confirmation number is the evidence of his or

her reservation; however, if a carrier cannot locate a passenger's

reservation record in the computer, a confirmation number does not

necessarily prove that the passenger had a reservation on that

particular flight. It is questionable whether carriers would board a

passenger based on a confirmation number alone. On the other hand, we

note TWA's assertion that the Department's concern over no-record

passengers is understandable in a historical context but that over the

past decade there have been numerous improvements to CRS technology and

that no-record passengers are no longer a significant problem. Our

complaint data appear to support this: in 1996 we received only four

consumer complaints against U.S. carriers about denied boardings caused

by ``no record'' reservation problems. None of those complaints was

about a totally-ticketless carrier.

The Request for Comments also noted that a conventional paper

ticket contains a record of the passenger's fare, whereas a ticketless

passenger might not have proof of the fare that had been agreed to in

the event a higher charge is posted to his or her credit card. Once

again, however, consumer complaints filed with DOT show no clear

indication of a problem in this area. In 1996 we received 52 complaints

against U.S. carriers concerning alleged overcharges, but only one of

them involved a totally-

[[Page 19477]]

ticketless carrier. The statistics do not indicate how many of the

remaining complaints may have involved ticketless transactions, but of

the 36 overcharge complaints against Major U.S. carriers (i.e.,

airlines with revenues over $1 billion per year), only three were

against Southwest Airlines or United Airlines, two Major carriers with

the earliest electronic ticketing programs.

We have no rules that require reservation or fare information to

appear on conventional tickets, and we will not require this

information to be furnished in writing to ticketless passengers at this

time. As far as we are aware, all airlines that offer electronic

ticketing provide a paper itinerary showing the fare and reservation

status either automatically or upon request. With most carriers,

passengers also have the option of a conventional paper ticket if they

prefer. A large percentage of ticketless transactions are paid for by

credit card, and those passengers have the dispute-resolution

procedures of the Fair Credit Billing Act available to them in the

event of a problem. Nonetheless, we will continue to monitor complaints

in these areas and will not hesitate to take further action in the

future if it is warranted.

Likewise, the Department will continue to monitor the evolution of

ticketless travel and any consumer problems that may arise from the

practice. The compliance policy stated herein will be reconsidered if

circumstances so justify. However, before making any substantive change

in the policy, we will provide public notice of our planned actions.

We note that under present rules, certificated carriers must

maintain consumer complaint records for a period of three years, flight

coupons from tickets for a period of one year, and other records

related to errors, oversales, irregularities, and delays in handling of

passengers for a period of one year. (14 CFR 249.20.) While we see no

need at this time to impose additional recordkeeping requirements on

carriers using electronic ticketing systems, we encourage all carriers

to maintain records sufficient and in such a fashion as to help the

Department make informed decisions in the future in this important and

evolving area of air transportation.

The compliance policy set forth above is an attempt to provide

carriers the maximum flexibility to develop their ticketless travel

systems while at the same time providing a measure of protection to

consumers from unfair or deceptive practices prohibited by 49 U.S.C.

41712. At the same time, however, carriers may find it advantageous to

continue to provide the written DOT ticket notices to ticketless

passengers in advance or to consider implementing the innovative

notification systems discussed in the comments submitted in this docket

(some of which are summarized above). In this regard, carriers may

ultimately decide that it is in their overall best financial interest

to do so considering that the preemption protections of 49 U.S.C. 41713

and 14 CFR 253.1 may not apply unless notice of contract of carriage

terms is provided to ticketless passengers at the time of sale either

orally or by contemporaneously mailed (or faxed, emailed, etc.) written

notice.

The policy described here does not affect the existing notice

requirements for conventional paper tickets. Those tickets must

continue to be accompanied by the written notices described in DOT

regulations.

Accordingly, it shall be the compliance policy of the Department

that ticket notices required by Department regulations shall be given

or made readily available to electronically ticketed passengers in

writing in a manner such as described above no later than the time that

they check in for the first flight in their itinerary.

Issued this 8th day of April, 1997 at Washington, D.C.

Charles A. Hunnicutt,

Assistant Secretary for Aviation and International Affairs.

[FR Doc. 97-10147 Filed 4-21-97; 8:45 am]

BILLING CODE 4910-62-P