45913
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45913
| OST-95-179 OST-95-623 OST-95-177 47546, 45911, 45912 45913 |
May 24, 1999 |  Petition of The Air Transport Association of
America for an Extension of the Effective Date |
Disclosure of Codesharing Arrangements and Long-Term Wet Leases and Disclosure of Change-of-Guage Services |  HTML |
Airlines and computer reservation systems have been working to reprogram their various information systems to comply with the rules' July 13, 1999 effective date. These efforts are at different stages but many remain far from complete and will require considerable additional work. They have proven exceptionally time consuming because of the need to resolve the application of the rules' requirements to different functions, the variety and complexity of the systems affected and the multiplicity of affected entities. In this regard, it is important to remember that in implementing the rule we are concerned not only with disclosure, but also with software applications. Disclosure of the information that the rules require can only occur if different airline industry systems are modified in concert. Finally, and perhaps most importantly, these undertakings are occurring at a time when immense information service resources have been committed to pressing Y2K needs. They cannot be redeployed for some time.
Counsel: ATA, James Casey, 202-626-4211
| OST-95-179 OST-95-623 OST-95-177 47546, 45911, 45912, 45913 |
May 25, 1999 |  Answer of Aerpostal
in Support of ATA's Petition |
Disclosure of Codesharing Arrangements and Long-Term Wet Leases and Disclosure of Change of Guage Services |
| Attachment: Memorandum from SABRE |
Counsel for Acropostal was in the process of drafting an Application for Exemption Authority requesting that the Department extend the effective date of the regulations herein for several months. In the interest of avoiding repetition and consolidating the proceedings so as not to have many Applications for Exemption Authority and/or Petitions filed with Dockets requesting the same extension, Aeropostal submits the instant answer in Support of ATA's Petition.
Counsel: Pierre Murphy, Elizabeth Collins
| OST-95-179 OST-95-623 OST-95-177 47546, 45911, 45912, 45913 |
May 25, 1999 | Answer of OAG
Worldwide |
Disclosure of Codesharing Arrangements and Long-Term Wet Leases and Disclosure of Change of Guage Services |
While the industry would normally be able to accomplish the necessary programming changes with a few months delay of the rules, it is facing a unique situation this year in the form of the Y2K problem. Because of the widespread concern about computer operations on January 1, 2000, corporations are devoting extensive programming efforts to insuring that computers do not crash with the new century. As a result, many companies are imposing "change freezes", under which they will not allow any software changes to their computers for some months prior to January 1. This will make it impossible for them to test the necessary programming changes required to comply with the Department's rules. OAG, therefore, supports ATA's proposal that the effective date of the rules be extended to February 15, 2000.
Counsel: Richard Fahy, 703-684-4422, rfahy@ibm.net
Disclosure of Code Sharing Arrangements and Long Term Wet Leases and Disclosure of Change of Gauge Services
| OST-95-179 OST-95-623 OST-95-177 47546, 45911 45912, 45913 |
May 28, 1999 |  Answer in Support of the
Petition of ATA for an Extension of the Effective Date of The SABRE Group |
Disclosure of Code Sharing Arrangements and Long Term Wet Leases and Disclosure of Change of Guage Services |
More-over, Sabre will impose a Year 2000-related implementation freeze for its computer systems beginning November 1, 1999 and ending on March 15, 2000. During this time period, no new implementations of any nature will be permitted in the Sabre systems. Finally, as ATA points out, the complex interrelationships of the many systems involved in providing and exchanging information about air carrier services means that a delay by any one component will impact all of the others despite the best efforts of all involved to timely meet the Department's new regulations. As the Department knows, the ATA and others are working hard on coordinating these diverse components.
Counsel: Sterling Miller, Senior Managing Attorney, Litigation and Regulatory Affairs, The SABRE Group, 817.967.6932, sterling.miller@sabre.com
Disclosures of Codesharing Arrangement, Long-term Wet Leases and Change-of-Gauge Services
| OST-95-179 OST-95-623 OST-95-177 47546, 45911 45912, 45913 |
June 11, 1999 |  Petition of the United States Tour Operators Association
for an Extension of the Effective Date and an Additional Grace Period |
Disclosures of Codesharing Arrangement, Long-term Wet Leases and Change-of-Gauge Services |
By: Robert Whitley, 212.599.6599
Codesharing Practices in Domestic, Overseas and Foreign Air Transportation
| OST-95-623 OST-95-179 OST-95-177 47546, 45911, 45912 45913 |
June 24, 1999 |  Answer
of Richard Walsh in Support of Petition of ATA for Extension |
Codesharing Disclosure / Change of Gauge / Wet-Lease |
We are an airline database publisher and compiler of airline schedules and related data. We concur with the position taken by the ATA, OAG and EDS in that the July 13,1999 effective date does not allow enough time to modify the programs and systems needed to comply. We too are facing major software changes related to Y2K compliance. We join the ATA and OAG in their request for an extension of the effective date to February 15,2000.
By: Richard Walsh
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