I have heard the Department of Transportation wants to outlaw GDS bonuses because it thinks the entire system of quotas, shortfall penalties and bonuses -- known collectively as "productivity pricing" -- may be preventing agencies from using other booking methods that may be in the consumer's best interest.

Does the DOT have any evidence that agencies are booking fares that are not in the consumer's best interest?

A: The DOT has no evidence. It is merely suspicious that agencies may be acting contrary to the consumer's interest because GDS vendors give agencies an incentive to book through them and assess penalties when a minimum isn't reached.

It now is up to the trade to show the DOT that its suspicion is not well-grounded.

On the day this column appears, all interested parties will be filing their comments in the GDS rule-making proceeding.

It is probable that several airlines will support the proposed ban on productivity pricing, just as they did in 1997, when the DOT last sought comments on these issues.

The anti-bonus carriers included Delta and Continental. These airlines naively asserted that if GDS bonuses were eliminated, they would pay less in booking fees.

In Delta's case, as Alan Fredericks wrote in a column last May 20 [Traveling,"Airline Double-Talk"], "there are so many ironies in the airlines' arguments that it's hard to know where to begin."

It was ludicrous for the largest owner of Worldspan to complain to the government about GDS booking fees. (Earlier this month, Delta, Northwest and American agreed to sell their shares in Worldspan.)

Larger, corporate-oriented travel agencies would bear the brunt of any decision to outlaw productivity pricing. They need to show the DOT that their current GDS contracts leave plenty of room to make non-GDS bookings without incurring shortfall penalties.

The agencies also need to show that they do make such bookings regularly -- on the Web, on secondary GDSs and even through Web-booking enhancements provided by their primary GDS vendor.

The GDS vendors themselves need to show that they now are offering kinder, gentler contracts that allow agencies ample cushions to make non-GDS bookings without incurring penalties.

They also need to emphasize their efforts to induce airlines to place their Web fares in the GDS in return for price breaks on booking fees.

Mark Pestronk is a Fairfax, Va.-based attorney specializing in travel law. He answers your questions in the TravelWeekly.com Legal Ease forum. To contact Mark directly, e-mail him at [email protected].

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