The Association of Retail
Travel Agents (ARTA) continues its strenuous objections to the consideration of the
International Air Transport Association (IATA) proposal to manage the .travel TLD.We
support fully the recommendations of ICANN's evaluation team that IATA's proposal
raises "significant representativeness issues" and, therefore, should not be considered
by the ICANN Board of Directors this week.
IATA is not -- and, given its legal
structure, will never be -- "broadly representative of the diverse global travel
industry."
Stripping away any legally nonbinding promises on independence made
in its proposal, IATA must give its primary loyalty to the 275 airlines around the
world that comprise its membership. Those airline members of IATA -- not the
"675,000 to 759,000 potential registrants" claimed in IATA's proposal -- will carry
the greatest weight in future binding decisions involving the awarding of .travel
registrations.
The many, many other segments of the global travel community who
have the most at stake in the administration of .travel registrations -- from travel
agents to car rental companies, tourist boards to cruise lines, railroads and hotels
to consumer travel advocates -- have no legal standing within IATA. Therefore,
there's no legal guarantee that IATA would not change its promised rules for administering
.travel names once ICANN awards its initial approval.
That's a major concern to
many small business owners and travel retailers across North America who have learned
firsthand the dangers of allowing airline cartels like IATA the opportunity for chokeholds
on commerce with consumers. Under its nonprofit charter, IATA legally represents
large global airlines that have an extremely spotty record of anticompetitive behavior,
alleged collusion, and outright antitrust law violations in the United States, Canada,
and the European Union, as well as other global jurisdictions.
Indeed, our association
won litigation in the United States against a similar airline cartel in the mid-1980s
that applied unfair criteria to airline ticket sales and settlements, and we filed
a legal complaint against IATA with the U.S. Department of Transportation in the
1990s to block the launch of a discounted airfare Web site that threatened to violate
U.S. antitrust laws. (IATA abandoned its plans for the site, in the face of
growing industry opposition.)
In our opposition, we concur with the concerns expressed
earlier by travel industry groups such as the U.S. Travel Agent Registry (representing
1,000 members) and the Outside Sales Support Network (representing 5,500 members).
Unlike
other commenters, we will not receive any financial or business benefit from IATA's
proposal, and we have not reached any deals with IATA to remove our opposition in
return for automatic approval of our members (bypassing the business fitness evaluation
promised by IATA in its proposal).
We appreciate ICANN's longsuffering efforts
to solicit as much public comment as possible on the new TLD applications, and we
offer our complete and absolute support to the ICANN evaluation team's recommendation
NOT to approve IATA's .travel application.
John K. Hawks, APR
President
Association
of Retail Travel Agents (ARTA)
2692 Richmond Road, Suite 202
Lexington, KY
40509-1542 U.S.A.
info@artaonline.com