signatory letter

14 September, 2007

Mr. Jacques Barrot
Vice President
European Commission
Rue de la Loi, 200      
B-1049 Brussels

Dear Mr. Barrot,

We the undersigned Signatories are writing to express our grave concern over recent developments related to the Commission review of the CRS Code of Conduct.

We understand that the Commission’s view is that the term “parent carrier” will be interpreted on a case-by-case basis and, revealingly, that the definition of a “parent carrier” requires control, even though the Code clearly states that ownership OR control triggers the parent carrier requirements. Such a definitional change would strip the Code of the basic consumer protections that have been overwhelmingly endorsed by consumers, business travelers and travel agencies in the stakeholder consultation process.  The leadership of travel industry and consumer organizations, who represent the consumer of commercial air transportation services, is conducting a Customer Hearing on 20 September in Brussels to examine this issue in detail. 

Compounding our concern over this ongoing regulatory redefinition is the overall consultation process. If the definition of “parent carrier” is being de facto changed through a new interpretation, then such a change should have been front and centre of the consultation process. Instead, no direct questions have been asked about the meaning of this definition or what a change would mean. Furthermore, we feel that we have been misled by the Commission which has publicly stated the need to maintain the basic core protections associated with “parent carrier” while apparently behind the scenes preparing to make them meaningless.

Contributing to this confusion is a recent statement by an Amadeus spokesperson, saying that they have not been subject to the parent carrier requirements for the past two years. We now understand more fully the Commission statement buried in the Commission Summary of Consultations: “There appears to be confusion among stakeholders about the interpretation of the definition of ‘parent carrier.’”

As you might imagine, we are extremely dissatisfied with both the content and procedural aspects of DG TREN’s management of this issue. It is clear that now, more than ever, the term “parent carrier” requires a precise definition and input from all stakeholders. Therefore, in the name of better regulation, we would urge you to consider reopening the public consultation to enable this matter to be discussed in a fair and open manner. This should not be a hasty process but one which is in keeping with the vital issues at stake for consumers and all other participants in the air transport and travel distribution markets.

We would be grateful if you could take the time to meet with us, as soon as schedules permit, in order to discuss the issues at stake and how the Commission intends to proceed further with the Code’s revision.  A representative of our group will be in touch with your office to see when a meeting with you might be held.

We look forward to your response.

Yours sincerely,

International Airline Passengers Association
Institute of Travel Management
Belgian Association of Travel Management
Advantage Focus Partnership
Finnish Business Travel Association
Scottish Passenger Agents’ Association
Business Travel Coalition
Danish Business Travel Association
The Coalition for Fair Access to Reservations in Europe
The Guild of Travel Management Companies
Travel Alliance
American Standard Companies 
DuPont de Nemours
Airbus UK
WORLDHOTELS
Autodesk, Inc.
Academic Medial Center AMC
ATS Euromaster Ltd
Tommy Hilfiger
Heineken International
Nike NEON BV
Océ-Technologies B.V.
BEA Systems
CIGNA
Tate Lyle Europe N.V.
FLO Corporation
Inter IKEA Group
INPO
Marathon Oil Ireland Limited
Liberty Global Europe
NATS Limited
PerkinElmer, Inc.
Rich Products Corporation
Sara Lee Corporation
TRW Automotive
UCB Pharma
RMIC Corporation
Sanmina-SCI
SEACOR MARINE INTNL
Serco 
Dunkin' Brands Inc.
FANUC Robotics Amercia, Inc.
MedSupply 
HealthCare California
UCB Pharma SA
UMICORE
All Seasons Travel
AMEC Travel Management Ltd
Amity World Business Travel
Austin Travel
B.S. Executive Travel Limited
Bagshot Business Travel
Ben LAwries Travel Ltd
BLUE MARINE TRAVEL
Buon Viaggio Travel
Business Travel Plus
Caldwell Travel, Inc.
Capable Travel Ltd
Christine Nugent Business Travel Limited
Commodore Int Tvl
Cresta World Travel Ltd
Delta Travel
DeNovo Management
Esprit Rainbow Travel
Eton Travel Agency Ltd
Fair's Fare
First American Travel
Forward Travel Management
Freudenberg-NOK
Giles Travel Ltd
GLEN TRAVEL Ltd
Gondrand Viajes
Greenstar Travel
Horizon Travel Agency
Ickenham Travel Group PLC t/a Business Travel Direct
John Proctor Travel
Jules Boutin Travel Bureau
LasVegasConventionTravel.com Inc.
Matrix Travel Management
MEON VALLEY BUSINESS TRAVEL
Metro Travel Tours
Network Appliance
Norad Travel Ltd
Norseman Travel Limited
Novo Nordisk A/S
Omega Executive Travel Ltd
Omega World Travel
Portman Travel Limited
QA Business Travel Ltd
Quorn Business Travel
Review Travel Management
Stork NV
Strand Travel Limited
T2Impact Ltd
The Business Travel Partnership Ltd
The Travel Centre (Norwich) Ltd
The Travel Company Edinburgh
THE TRAVEL PROFESSIONALS LTD
The Travel Team, Inc.
TRAVEL AGENT NEW DEAL TRAVEL SAS 
Travel Associates, Inc.
Travel Management Alliance
Travel Shoppe
Travel Time Travel Agency, Inc.
TravelHarbour
Travelogica AB
TRAVELWISE GROUP LTF
Travelwise International
TRAVELWORLD INTERNATIONAL
Valtours ehf /GmbH
VantagePoint Venture Partners
WAYTE TRAVEL MANAGEMENT 
WebShoppingDepot.com
Windsor Neate Travel
Wotton Travel Limited
Xchanging Procurement Services Limited