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OST-99-6521

Renaissance Cruises, Inc.

One of the anchors of RCI's business is its Greek Isles cruise program, operating between Athens, Greece and Istanbul, Turkey with stops in the Greek Isles.3, RCI offers two packages with these five-day cruises, each accounting for about half of RCI's bookings. One package consists of air travel from the U. S. to Athens, two nights in Athens, five days on the cruise ship, two nights in Istanbul, and return to the U. S. (such packages referred to herein as "2-5-2" packages). The other package is basically the same, but is comprised of passengers purchasing premium ship accommodations who are given an extra day's hotel stay in Athens and in Istanbul. Both 2-5-2 and 3-5-3 passengers travel on the same ship, stay at the same hotels, visit the same islands, and fly on identical air service.  

The relief RCI requests is by no means extraordinary. The Department's Cruise Line Waiver program has been successful and has given cruise lines the flexibility to offer charter air packages without compromising consumer protection aims. RCI simply is asking the Department to recognize that a wholly arbitrary land/cruise ratio in the Guidelines is neither logical nor necessary. By applying its regulations and Guidelines more flexibly in the circumstances RCI describes, the Department will permit the cruise line industry to work with charter air carriers to expand their offerings to cruise passengers and meet market demand.

Counsel: Verner Liipfert, Berl Bernard, 202.371.6030

Counsel: Verner Liipfert, Berl Bernard, 202.371.6030

Renaissance Cruises, Inc.

Counsel: Verner Liipfert, John Mietus, 202.371.6030

Renaissance Cruises, Inc.

In view of the Department's decision just last year to maintain all current financial security and bonding requirements, ATA is not inclined at this juncture to propose specific reductions in any of these requirements unless the Department indicates some willingness to reconsider last year's decision in which it declined to relax any of the current requirements. ATA would, however, once again emphasize that any decision to afford either all or even just financially sound cruise lines further relief from the current bonding requirements must also be extended to direct air carriers who meet the same financial fitness criteria. There is no conceivable policy basis that would rationally support granting the cruise line industry further bonding relief without also doing so for financially sound air carriers.

Counsel:  Squire Sanders Dempsey, Marshall Sinick

Renaissance Cruises, Inc.

RCI takes no position on whether the financial security requirements for ATA should be relaxed, but it does suggest that the current proceeding is not the proper forum for consideration of such issues, and that there is no need for the Department to consider herein a general overhaul of the financial security provisions. If ATA wants relief from the provisions of Part 3 80 that apply to charter airlines, it may do so by following the same course adopted by RCI, i.e. it may seek a waiver or exemption of the provisions, and attempt to meet its burden and justify its request.

Counsel: Verner Liipfert, William Evans, 202.371.6030

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