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Proposed Reservation System for Unscheduled Arrivals at Chicago's O'Hare International Airport - Comments of The Mark Travel Group

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Proposed Reservation System for Unscheduled Arrivals at Chicago's O'Hare International Airport

FAA-04-19411 - Proposed Reservation System for Unscheduled Arrivals at Chicago's O'Hare International Airport

October 29, 2004

Re: Comments of The Mark Travel Group | Word

The FAA’s proposal to address “unscheduled operators” includes various different types of operators. While the preference is that all types of operators be allowed to utilize airports without limitations, according to the FAA, that is not possible at O’Hare. Therefore, additional alternatives need to be considered. There are very basic differences between general aviation operations and charter operations. Moreover, there are differences between “on-demand” charters and “public charters.”

While some charter operations, particularly those that are for special events and aren’t established until a time period closer to the travel dates can be shifted to “off-peak” times, other days or to other airports, we cannot make changes to the long-term charters that we have operated at O’Hare for the past several years. If the FAA rule does not allow us to schedule these charters at the times and the number of charters that we have historically operated, we will be the one type of operation that will be discriminated against in this rule. That would be extremely detrimental to our business and to the care and service of our customers.

Mark Travel/Funjet Vacations schedules operations up to a year ahead of time to obtain gates, customs approvals and secure ground handling agreements. Since we do not have dedicated airport facilities, we need to establish loading agreements for all flights. Once those agreements are finalized, we have limited options to move flights. We start marketing and selling our services six to nine months before departure dates. Moreover, unlike some “unscheduled operators,” we cannot operate at other Chicago area airports because of our operations. Therefore, to serve the Chicago area, we need to be at O’Hare. For all of these reasons, if all operations cannot be approved FAA should distinguish between general aviation, on-demand charter operators and public charter operators.

In order to allow the public charter operations conducted by Mark Travel/Funjet Vacations to be placed on a somewhat equal footing with the other operators who control 98% of Chicago operations, the FAA needs to allow those charter operators that have been at the airport before the current problems arose, that schedule and operate charters longer than six months before date of operation, and utilize aircraft with more than 125 seats to operate the same number of charter flights as they operated in 2003-2004 . In implementing these restrictions which could dramatically impact the public charter operators, the FAA needs to ensure that those operators can continue to operate. Mark Travel will also take reasonable steps to schedule operations in non-peak periods. If we cannot operate as planned, it will impact our current and future business. FAA must also allow public charter operators to make flight reservations for the above types of flights as those charters are arranged. They should not be held to a 72-hour reservation restriction. The number of flights to be handled in this manner would be small. The ability of Mark Travel/Funjet to operate in this manner is critical to the continued economic growth of the operators and others involved in the travel packages. It is also critical that we provide affordable and competitive options to travelers in the Chicago area.

By: Jennifer Macchia

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