Wednesday, 10 January 2018

The Amazing Race 30, Episode 2

Reykjavik (Iceland) - Amsterdam (Netherlands) - Antwerp (Belgium)

This episode of The Amazing Race, like the previous one, featured helicopter shots of spectacular Icelandic scenery. They helped show why Icelandic tourism marketers have been so successful in recent years in changing perceptions of the country as an aviation hub. Flying between America and Europe via Iceland has changed from a perceived drawback to an asset: from an unwanted interruption of the journey and change of planes to a desirable stopover opportunity.

Foreigners visiting Iceland as a stopover en route to or from somewhere else still far outnumber those for whom Iceland is the primary destination, but that is changing. I know some people who've gone to Iceland and back recently from the U.S., without continuing on to Europe.

Despite these changes, Iceland's its role as a transatlantic budget airline hub remains an interesting case study in the history of discounted airline ticket pricing and routes and the ways it has been controlled by politics and oligopoly rather than competition.

Why was it that Icelandic airlines offered lower prices between North America and Europe than any other airlines to a generation of backpackers?

Continue reading "The Amazing Race 30, Episode 2"
Link | Posted by Edward, 10 January 2018, 23:59 (11:59 PM) | Comments (0) | TrackBack (0)

Wednesday, 3 January 2018

The Amazing Race 30, Episode 1

New York, NY (USA) - Reykjavik (Iceland)

Stopovers in Iceland and other stopover possibilities on flights to and from the USA

Season 30 of The Amazing Race started with the cast members having to fly from New York City to Reykjavik, Iceland.

The racers all took the same flight on Icelandair, one of two Iceland-based airlines that flies to and from the USA. So the winner of this leg of the race was decided by what happened after they arrived at Keflavik Airport near Reykjavík. The key task for the racers required them to arrange letters spelling out the name of a plaza in Reykjavík, Ingólfstorg. Several of the racers were slow to realize that "Ingolfstórg" is not the same as "Ingólfstorg".

English is written without diacritical marks. Diacritical marks aren't even listed in the index of my copy of the Encyclopaedia Britannica, and "accents" get only a passing mention at the end of the essay on alphabets and writing systems. In English, "accent marks" are used, if at all, as optional aids to pronunciation that help indicate the sound of the underlying letters.

In many other languages, diacritical marks aren't optional. They are not regarded as "modifiers" but as symbols used to distinguish between what are thought of as different letters. In Icelandic, "ó" is not considered to be the same letter as "o". As a rule, you should assume that if a word is written with diacritical marks, you need to include them when you write the word, or it might not be understood.

I'll have more to say about flights on Icelandair next week when the racers continue on to Europe.

But while the racers are stopping over in Iceland, let's talk a little about stopovers in general.

Along with Dubai and Singapore, Reykjavík is one of the quintessential "stopover" destinations: a place that most visitors probably wouldn't have gone to at all except that it was "on the way" to their "real" destination. If you have to change planes there anyway, why not stop over for a few days and check it out?

That doesn't mean that you might not find Reykjavík, Dubai, or Singapore worth the trip as a destination in their own right. (Or you might not. But that's a matter of taste, not of intrinsic touristic value, the concept about which I'm extremely doubtful.) Increasing numbers and a growing percentage of visitors to each of these places are visiting them as their destination rather than merely as a stopover en route to somewhere else.

For government ministries of tourism, and sometimes for airlines, promoting stopovers is a problem of making lemons out of lemonade. How do you turn, "To get a cheap ticket on Icelandair, you have to change planes in Reykjavík, instead of taking a direct flight from the USA to Europe," into, "On an Icelandair ticket to Europe, you can stop over for a few days in this really cool place that would otherwise be expensive to get to, Iceland, for no extra charge"?

Many fares requires a change of planes but forbid stopovers longer than 24 hours or longer than until the next flight to your final destination (which might be more or less than 24 hours). For an airline, it's a tricky judgment call whether potential ticket buyers' perceptions of its hub (this is all about perception, which may have nothing to do with reality) are such that offering free stopovers is a way to sweeten an otherwise unattractive-seeming routing, or whether its hub is perceived as a desirable and valuable additional destination worth paying extra for.

That makes it almost axiomatic that the places where free stopovers are offered are not the first places you would think of as places you would expect to transit and/or want to stop over. The interesting stopover possibilities are in places where there is a disjunction between perceived attractiveness as a destination and your particular tastes and interests, as well as in the hub cities of airlines that are less well-known, or offer a better combination of price and routes than their reputation for quality of service (which reputation may also have little relationship to reality).

Unless I'm in a hurry, I generally welcome opportunities for stopovers, especially in places that I haven't been before, that I wouldn't otherwise be likely to get to, and that are inexpensive.

In 2008, I spent a week in Yemen on an unplanned stopover. We were scheduled to change planes in Sana'a and continue to Asmara, Eritrea, on the same day. But because of complications with our visas for Eritrea, we ended up staying in Sana'a for a week. We wouldn't have chosen to go there, but I'm very glad we had a chance to see what it was like, and meet some people there, before the start of a war in which the US government, acting in our name, has been an active participant.

How can you find out what stopovers might be possible, where, on which airlines?

The simple answer is to ask an expert travel agent. That's not a useful answer any more, however, since there are so few remaining travel agents with this kind of expertise. Too few travellers recognize the value of their expertise and are willing to pay enough to keep them in business.

Finding stopovers on your own requires luck, guesswork, or learning some of the skills and paying for some of the tools of a do-it-yourself travel agent. There's no easy way around this. Don't say I didn't warn you! But if you think it might be worth the effort, here's some guidance:

Continue reading "The Amazing Race 30, Episode 1"
Link | Posted by Edward, 3 January 2018, 23:59 (11:59 PM) | Comments (0) | TrackBack (0)

Monday, 1 January 2018

Bicycling the Danube, Part 3: Highlights and Lowlights

Cycling the Danube (Part 3 of 3):

In Part 1 and Part 2 of this series, I talked about why you might (or might not) want to take a trip by bicycle along the Danube, and about some of the practicalities of such a trip.

In Part 3, below, I'll highlight a few interesting things (not by any means all, and not necessarily the "best") places and things to see and do along the river or nearby, and a couple of particularly outstanding places we stayed.

Continue reading "Bicycling the Danube, Part 3: Highlights and Lowlights"
Link | Posted by Edward, 1 January 2018, 14:00 ( 2:00 PM) | Comments (0) | TrackBack (0)

Bicycling the Danube, Part 2: Practicalities

Cycling the Danube (Part 2 of 3):

Many of the reasons for choosing to take a trip by bicycle along the Danube River that I discussed in Part 1 of this series are logistical and practical: It's one of the easiest and most comfortable long-distance cycling routes in the world, even if you don't think of yourself as a cyclist.

In Part 2, below, I'll give some additional practical advice for those who are thinking about a trip like this.

And in Part 3, I'll highlight a few specific places to see, do, and stay along or near the river that I found interesting and/or enjoyable, and that you might miss if you weren't looking for them.

Continue reading "Bicycling the Danube, Part 2: Practicalities"
Link | Posted by Edward, 1 January 2018, 13:00 ( 1:00 PM) | Comments (0) | TrackBack (0)

Bicycling the Danube, Part 1: Pros and Cons

[A "Radler" in German can mean either either a bicyclist or a mildly-alcoholic drink consisting of half beer and half lemonade.]

Cycling the Danube (Part 1 of 3):

My partner and I spent six weeks in June and July 2017 travelling 2000 km (1200 miles) by bicycle along the Danube River from Donaueschingen, Germany, to Belgrade, Serbia -- about 60% of the river's length from its source to the Black Sea.

Travel and tourism statistics rarely include bicycling as a mode of transportation. But a case could be made that the Danube -- at least the 800 river kilometers (500 miles) from Donaueschingen to Vienna, and perhaps the 300 km (200 miles) further downstream to Budapest -- is the world's preeminent long-distance bicycle tourism route. Certainly it's the best-known and most heavily travelled long-distance bicycle tourism route in Europe.

In high season, more than a thousand cyclists a day on overnight journeys -- not counting day-trippers -- pass through some of the more popular sections of the upper Danube in Germany and Austria. I don't know of any other route of comparable length, anywhere in the world, that has as large a volume of through multi-day travel by cycling tourists.

Yet despite the iconic status within Europe of the Danube as a cycling route popular even with people who don't think of themselves as cyclists, it has a relatively low profile in the USA, even among cyclists who travel to Europe. Some of the factors discussed below that make the most popular parts of the upper Danube so attractive for casual cyclists make it less so for "serious" cyclists, although hard-core riders might nonetheless enjoy the lower parts of the river.

For bicyclists from the USA, the most popular cycling destination in Europe is France, followed by the U.K., Ireland, and (more distantly) Italy. Germany is an afterthought for most American touring cyclists, and Austria isn't thought about at all. If Americans think about bicycling along a river in Germany, it's almost always the Rhine, not the Danube. Some U.S. tourists travel along the Danube, but almost all of them do so on river cruises.

I bicycled along much of the Rhine, including almost all of its course through Germany, in 2014. I've travelled by bicycle in France, the U.K., and other countries in Europe. There are many good reasons to choose these, and other, destinations for bicycle tourism.

But Europeans choose to cycle the Danube in such large number for good reasons, and I think more overseas visitors should consider it.

In Part 1 of this series, I'll give some of the reasons why you might enjoy bicycling along the Danube even if you don't think of yourself as a cyclist, and why you might not.

In Part 2, I'll give some practical advice for those who are thinking about a trip like this.

And in Part 3, I'll highlight a few specific places to see, do, and stay along or near the river that I found interesting and/or enjoyable, and that you might miss if you weren't looking for them.

Continue reading "Bicycling the Danube, Part 1: Pros and Cons"
Link | Posted by Edward, 1 January 2018, 12:00 (12:00 PM) | Comments (0) | TrackBack (0)

Wednesday, 20 December 2017

Former Selective Service director admits draft registration has failed

Bernard Rostker, who was Director of the Selective Service System (SSS) from 1979-1981 durung the attempt to resume registration of all young men in the U.S. for possible military conscription, has publicly admitted what I've been saying for decades: failure by young men to notify the SSS of address changes renders the list of registrants so incomplete and inaccurate that it probably couldn't be used as the basis foir a draft that would stand up to legal challenges to its fairness.

Here's the key portion of Rostker's recent podcast interview with Lillian Cunningham of the Washington Post:

This episode of The Washington Post's "Constitutional" podcast examines the history and evolution of the draft in America with ... Bernard Rostker, former director of the Selective Service and a senior fellow at the RAND Corporation....

CUNNINGHAM: So this is where we are today. America continues to maintain a military registration system. Every young man in the United States between ages 18 and 26 is required to be registered. But if a draft were ever called again, using that list as a basis for the draft would face major constitutional hurdles.

First, because the sex-discrimination argument would now need to be revisited. And also because, the list of registered men's names is problematic.

ROSTKER: The list that they have I doubt could pass the legal definition of a complete and objective list, because it is structurally flawed and Selective Service knows it.

CUNNINGHAM: Many young men don't ever actively register for the draft themselves. Their states automatically send their information to the Selective Service when they get a driver's license. But if they move apartments -- or across the country -- the information doesn't necessarily get updated. And what about the men without driver's licenses? Or the ones who live in states that don't automatically register them?

ROSTKER: It's a list that I'm sure the courts would throw out immediately because it's not accurate.

...CUNNINGHAM: Two bills were introduced in Congress last year that would end registration all together, one was proposed in the House and one in the Senate. The Senate bill, proposed by Senator Rand Paul, was called the Muhammad Ali Voluntary Service Act.

I asked Bernie if he thought these might ever gain enough traction to go through.

ROSTKER: Politicians don't want to be accused of not being soft on defense by not having a standby Selective Service system that's adequate. But that has now survived for decades, and for the life of me I cannot see how it adds any anything to our defense effort.

CUNNINGHAM: This from a man who ran the program.

Link | Posted by Edward, 20 December 2017, 10:47 (10:47 AM) | Comments (0) | TrackBack (0)

Sunday, 10 December 2017

"No airline adheres to the Privacy Shield"

The U.S. Department of Transportation has consistently failed to protect consumers against deceptive advertising and opaque pricing by airlines that frustrates comparison shopping, while blocking any enforcement against airline of any rules promulgated by other Federal agencies or of the state and local truth-in-advertising and other consumer protection laws that apply to other businesses.

As I discussed in an article here last week in response to the latest outrage, I've been complaining about this for years.

DOT's dereliction of its duty to protect consumers extends to privacy protection as well, an issue highlighted by a report and staff working document released last week by the working party of data protection authorities of the European Union and EU members.

Airlines' privacy obligations under U.S. Federal law are limited: Under U.S. law, airlines can legally violate consumers' privacy, as long as they don't lie about what they do. But DOT has made no attempt whether airlines are truthfully disclosing their privacy practices, and has brushed off complaints that airlines violated their own privacy policies and lied about their practices.

Whether most other U.S. businesses comply with their professed privacy policies is subject to the jurisdiction of the Federal Trade Commissionn. But the DOT has zealously defended the exclusivity of its jurisdiction over airlines against any regulation of airline practices, with respect to privacy or anything else, by the FTC, any other Federal agency, or state or local consumer protection or law enforcement authorities.

I've complained about this in testimony to both the FTC and the DOT, as have other consumer advocates and state Attorneys General (2000 letter, 2006 letter).

Laws in Canada, the European Union, and some other countries restrict transfers of personal information from those countries to countries where personal data isn't adequately protected by law. Without adequate privacy protections and enforcement mechanisms in the U.S., it wouldn't be legal for businesses in those countries to transfer data to the U.S. about customers, travellers, or other individuals.

Because DOT and only DOT has jurisdiction over airlines, the U.S. government has had to pay lip service to DOT's commitment to policing airlines' compliance with their privacy policies when the U.S. has tried to persuade other countries that the U.S. provide adequate legal protection for personal information.

A bogus claim by the DOT that it would take action against any airline that lied about its privacy practices was an essential element in the so-called "Safe Harbor" framework negotiated to provide a legal fig leaf for businesses transferring personal data from the EU to the US.

After the highest EU court determined (unsurprisingly) that the Safe Harbor framework failed to satisfy the adequacy requirements of EU law, a similar and equally bogus claim by the DOT about its commitment to enforcement of airline compliance with published privacy policies was an element of the Privacy Shield (Safe Harbor 2.0) negotiated to provide businesses with a renewed legal fig leaf for transfers of personal data from the EU to the U.S.

So how many airlines claim that they comply with the Privacy Shield? To date, none.

And what has DOT done about this? To date, nothing.

We know this not from DOT but from documents released by European participants in the first annual joint US-EU review of compliance with the Privacy Shield.

According to the report by the Article 29 Working Party on the US-EU meetings:

The DoT made a presentation of its jurisdiction (over airline agencies and ticket agencies on the basis of the Unfair and deceptive practices Act) and of its activities. It has the authority to enforce civil penalties (up to 22 100 dollars for each violation).

No airline company currently adheres to the Privacy Shield, and initially 27 entities identified DoT as regulator (some by mistake). In total, 13 Privacy Shield companies are registered under the DoT's jurisdiction . For 10 of them, DoT's jurisdiction has been validated, while the jurisdiction issue of the other 3 is being examined. All of these 3 companies nevertheless appear on the Privacy Shield list.

Questioned on this, the DoT, the DoC and the FTC indicated that the allocation of jurisdiction between the DoT and the FTC did not stop the self-certification process as the DoT and the FTC have concurrent jurisdiction.

It would be a good thing if the FTC had such concurrent jurisdiction over airline practices with respect to privacy and other consumer issues. But the DOT has consistently claimed that its jurisdiction over airlines is exclusive, and it has used that claim of exclusive jurisdiction to discourage or prevent the FTC from getting involved in any investigation or enforcement of violations of privacy policies by airlines.

In litigation, DOT has argued ever since the Airline Deregulation Act of 1978 that has exclusive jurisdiction over airlines. And that's still the claim made on the US government's official Privacy Shield Web site, as noted in the staff working document prepared for the Article 29 Working Party in preparation for its report on the Privacy Shield review:

A company may only certify if it is subject to the investigatory and enforcement powers of the FTC or the DoT. The FTC and DoT's respective jurisdictions are described on the Privacy Shield website as follows: "...The DOT has exclusive jurisdiction over U.S. and foreign air carriers...."

No airline company had certified under the Privacy Shield at the time of the Annual Joint Review.

Like its predecessor "Safe Harbor", the "Privacy Shield" is a sham. Its name is Newspeak.

Europeans and Americans alike need to recognize that the DOT does not adequately protect air travellers' privacy. Airlines will stop making false claims about respect for their passengers' privacy only when European, Canadian, and/or other non-U.S. privacy and data protection authorities impose sufficiently severe financial penalties on airlines and computerized reservation systems to motivate them to change their typically undisclosed and systematically insecure and privacy-invasive practices.

[Correction: The article above has been corrected to remove an erroneous statement in the original version that the FTC is part of the Department of Commerce. The FTC is a quasi-independent regulatory agency, not part of the Department of Commerce.]

Link | Posted by Edward, 10 December 2017, 17:01 ( 5:01 PM) | Comments (0) | TrackBack (0)

Friday, 8 December 2017

U.S. Dept. of Transportation ends review of airline truth-in-advertising rules

Yesterday the U.S. Department of Transportation (DOT or USDOT) announced that it has terminated two ongoing "rulemaking" proceedings related to disclosure and transparency of airline fees, and withdrawn its proposal for rules which would have required airlines "to disclose baggage fee information to consumers when fare and schedule information is provided".

As my friend Charlie Leocha of Travelers United notes in his apt denunciation of DOT's abdication of any effort to protect consumers against bait-and-switch airline price advertising:

This withdrawn rulemaking was created to allow airline consumers to determine the full cost of travel, including airfare as well as ancillary fees together with their exceptions and exemptions. Without clear, public data available to travel agents and on the Internet, travelers find it impossible to effectively comparison shop. By withholding this information from normal airline ticket sales channels, the airlines are misleading consumers about the true cost of travel.

This rulemaking has been in play for half-a-decade with thousands of pages of testimony and comments from consumers and all travel stakeholders. The claim that this rulemaking is "of limited public benefit" is simply not true.

It's not as though DOT has been aggressively protecting consumers. DOT has been dragging its feet, studying and collecting comments on whether additional rules were necessary to protect airline consumers against deceptive advertising since 2011 without finalizing the necessary regulations. But now DOT has officially abandoned any consideration of such rules.

In theory, the existing DOT regulations regarding truth in airline advertising and fare transparency, as well as Federal laws giving the DOT exclusive responsibility for policing deceptive airline practices, remain on the books. But DOT's withdrawal of its proposed rules on ancillary fee disclosure is a signal that DOT's already grossly inadequate enforcement of existing laws protecting airline ticket purchasers will become even more lax. Caveat emptor.

As I've noted in another context, President Trump campaigned on a platform of rolling back Federal regulations, including rules to protect consumers. Trump is the former owner of a (failed and bankrupt) airline, and he appointed Carl Icahn, his fellow billionaire and the former owner of another bankrupt airline, as his special advisor on repeal of "excessive regulation". Icahn resigned less than a year later in the face of allegations of conflict of interest for which he is now under investigation by Federal prosecutors. It should come as no surprise to anyone that Trump's program for deregulation, as planned in consultation with Icahn, includes putting an end to any effort to protect consumers against deceptive practices by airline owners such as Trump and Icahn.

DOT's determination not to address this issue through administrative rulemaking is, as Travelers United notes, a clear indication of the need for Congressional action:

It is time for Congress to get involved. If DOT, tasked with protecting the American public from misleading and deceptive practices, will not act, Congress must....

If DOT will not act, the current system must be abandoned and airline consumers should be provided the same rights of all other consumers -- the right to petition their local courts for justice.

That would require repealing Federal preemption of state and local consumer protection and truth-in-advertising laws as applied to airlines and airline ticket agencies. I've been talking about this in print for almost 20 years; it was at the top of my Federal airline consumer protection agenda eight years ago, as the Obama administration was setting its course; and it remains so today as the Trump administration is putting into effect its thoroughgoing opposition to consumer protection with respect to airlines or other businesses.

Link | Posted by Edward, 8 December 2017, 15:07 ( 3:07 PM) | Comments (0) | TrackBack (0)

Monday, 27 November 2017

New look for

Over the Thanksgiving weekend, The Identity Project deployed the first redesign of its Web site in more than a decade.

I hope that the new look and formatting will be easier on the eyes and easier to read on a variety of devices, including those with small screens.

For the last ten years, more of my writing has appeared on than anywhere else.

If you've been interested in this work and/or my writing, but put off by hard-to-read colors, fonts, and layout, please give it a fresh look and let your friends know about it.

Link | Posted by Edward, 27 November 2017, 08:56 ( 8:56 AM) | Comments (0) | TrackBack (0)

Tuesday, 14 November 2017

Is Silicon Valley building the infrastructure for a police state? Yes, it is.

I was interviewed by Reason.TV for their latest report, Is Silicon Valley Building the Infrastructure for a Police State? New AI tools could empower the government to violate our civil liberties.

If you have ten minutes to watch the video, it's a good introduction to some of the issues I've been working on for the Identity Project including Palantir, pre-crime policing, automated decision-making and control ("extreme vetting"), and the homeland-security industrial complex.

Link | Posted by Edward, 14 November 2017, 15:12 ( 3:12 PM) | Comments (0) | TrackBack (0)