The shiver of collective OTA fear during the Google Destinations presentation at this week’s Phocus Wright conference in Fort Lauderdale was palpable.

Google has applied its vast technology resource to produce a product which could easily dominate the top of the travel search funnel; it’s called “Google Destinations”. With an emphasis on inspiration via content aggregation, and a laser focus on price comparison using cached pricing data, Google at first glance appear to have produced another killer application.

The key advantage Google has over any other travel player is its total dominance of search, which gives it the ability to deliver huge customer volumes to any new tools. So when Google launches a new travel product, we had better take notice.

Apparently 45% of travel searches start with a destination-led query e.g. ‘holidays to Majorca’. Google, via a visual carousel, will place “Google Destinations” at the top of organic listings and are therefore set to divert traffic from traditional link-driven search, to a content-rich format.

Once a destination has been chosen, customers will be delivered to an aggregated super page of relevant content, featuring destination and attraction information, video, weather etc. This is supplemented by a popularity index to show the best time and date to travel based on weather and price. Admittedly great content, but nothing too scary so far…

It was the ‘What’s next?’ section of the presentation that created the shiver.

Google are using cached flight and hotel data to create daily best-value destination and route pricing. This is presented as a simple slider, showing the cheapest periods to travel to the destination across the year within a month by month view or a more traditional specific date search. Alternatively, customers can utilise a budget slider to see which destinations fall within their budget and desired dates.

Once customers have decided on their destination and date of travel, they can drill down through results using traditional filters such as star ratings and UGC review scores, as well as continuously comparing prices between non-stop flying and via flying, or their chosen duration verses slightly longer or shorter stays e.g. the price to add an extra weekend on a 7-day trip to extend it to a 9-day trip.

Once the route and dates have been decided, the customers will be deep linked into the existing Google flight and hotel searches, which currently still link out to suppliers’ sites. However, it was 100% clear at the conference that instant booking and payment via Google Pay are fast approaching.

The scale of the data being aggregated and the speed of results being presented back are amazing. When combined with Google’s ability to deliver simple user interfaces, this creates a very impressive product that, in my opinion, could quickly become a game-changer.
Google continues to avoid the regulatory downsides of being an OTA by maintaining a media model where bookings are made directly with suppliers. However, the customer tools Google are providing squarely compete with the functionality delivered by the traditional OTA sites.

Google again stated that the motivation for the new “Destination Search” is to improve both customer inspiration and remove friction from the mobile booking process. I have to say they are doing a great job.

A less obvious but key motivation may also be to rebalance the power game in a USA OTA market, where 2015’s mega consolidation game resulted in Expedia and Priceline controlling 65% of the market. In a mobile-dominated world where real-estate is restricted, these two advertisers completely dominate. The new destination search will allow Google to flow bookings to a much more diverse customer base by acting as a virtual OTA, whilst maintaining its media model.

You may ask, “Why are Google bothered about other advertisers when competition between the big two keeps click cost high?” Google have always taken a long term view and realise that if they stop providing traffic to smaller players, these will be forced to work more closely with their biggest competitors i.e. social media giants like Facebook. Secondly, if competition in auctions is controlled by two players, competition could mysteriously disappear.

Being the best market place for advertisers, whilst reducing consumer friction in the mobile world remains the Holy Grail for Google, and they appear to be on the right track. Unfortunately, bi-product may be direct competition with OTAs.

If the only differentiator between the two offerings is how payment is made, it appears inevitable that OTAs will soon be complaining in the courts about an abuse of power by Google, in terms of how prominently “Google Destinations” is promoted within search results. An answer that its decided by a “secret source algorithm” may not cut it as a justification.

Travel Weekly’s Breakfast briefing last week provided a fascinating insight into the thought processes of Google’s top UK team. For me it provided a clear indication of their future direction in travel.

As a “customer” centric business, Google described how customers’ demands for instant answers, rather than lists of relevant links, has driven much of their innovation as the market migrates to a mobile dominated search space.

This has driven the development of both their Flight and Hotel searches, which allow customers to enter the data required to move directly to a relevant result or “answer”, when they click through to the supplier. Add in the ability of a younger generation of early adopters, to use voice activation tools such as Siri, to drive their mobile searches and you can quickly see their point.

Google customer centric idealism is financially facilitated by the “Auction” nature of their bidding model. Reduced click volumes resulting from delivering higher quality answers to customers, are compensated by high bid costs making Google revenue neutral on almost all improvements in customer experience.

Interestingly, Google stated that the biggest driver of click inflation is a flat market, with little growth in search volumes, as this forces advertisers to spend more to maintain or increase their share. Currently, most desktop markets are in decline due to the big switch to mobile, which has resulted in bid cost inflation in this sector. Ironically, although mobile click cost started lower, rapid inflation has also occurred in this sector driven by competition for the reduced advertising space available.

Google’s auction model automatically means they are likely to be the biggest winners from the above market forces, unless customers can find answers more quickly and easily elsewhere. Hence Google’s move with its Flight and Hotel finder tools entering the travel price comparison sector in order to head off threats from sites like Skyscanner, Teletext and Travel Supermarket. Price comparison sites make it easier to answer a key customer question, “Who is the cheapest provider?” thus encroaching on Google’s desire to provide the most relevant answer to a customer’s search.

Google’s current model remains firmly a media play, with customers being handed off directly to the airline or to major OTAs within their hotel search to complete the booking.

In my opinion Google are like to remain a media play for the holiday transactions serviced by OTAs, because of the high regulatory burden that comes with being the “principal” and their inability to provide an answer quicker in this complex transaction.

In the flight sector Google is also faced by a customer’s clear preference to book directly with the airline carrier and are therefore unlikely to add value.

However, the hotel only sector is less clear-cut in my mind. Currently this sector remains highly fragmented with Google being forced by technology restrictions, to integrate with “intermediary” OTAs who aggregate hotel stock and take payment. The key question is can Google add value by removing this layer?

Unless there is a specific advantage of booking directly with the hotel, the answer is no. Google’s recent launch of “Hotel Offers”, where hotels can offer “discounts” or “added value” offers to a targeted range of Google customers, is a move at adding such a motivation and may indicate their future direction.

In my opinion, rather than becoming an OTA, Google are more focused on driving higher “answer” relevancy by working with advertisers to apply the “big data” they generate from customers movements within their sites, to drive more tailored advertising.

Remarketing advertising is a perfect example of this, with the highest converting OTAs already spending 30% plus of their PPC advertising funds on remarketing. We all know that currently remarketing is a relatively crude tool, and you’re often hounded for weeks by adverts for items you have already brought elsewhere. However, imagine the “Big Data” that Google can bring to the party.

Most websites use Google Analytics and attribution tools that tell Google which customers have brought items during a site visit and which ones have not. Imagine if this data could then be passed to a competitor, to allow them to identify what the customer was looking for but did not buy from their competition. This could then be used to target these customers with highly personalised and relevant “pre-visit” marketing adverts.

At the end of the day advertisers might not like this, but it is highly customer centric, allowing customers to find via Google the best provider for their needs quicker than ever before. Don’t rule it out guys, given the power Google has to dictate terms to the online advertising market place.

Former On Holiday Group chief Steve Endacott has returned as chairman of Teletext Holidays as the company plots a major marketing push.

Teletext plans to put its brand name back in holiday-bookers’ minds as it champions a “book by phone” message.

The campaign will be the company’s first ‘above the line’ advertising – using TV, print, billboard and other traditional media – in four years.

Endacott will lead the move on behalf of a venture capital investor, having joined Teletext as non-executive chairman in July.

The company currently has a board of Endacott, product technology director Graham Farrugia and customer and marketing director Tom Sainsbury.

Endacott said: “Teletext is a freak of nature. No retail brand ever appeared on it, but 20 million people brought holidays through the brand.

“It’s a heritage brand. It stands for cheap holidays, late availability and booking by phone.”

The re-launched Teletext will offer package holidays by phone, sourced from single supplier Truly Travel.

Endacott believes its ‘book by phone’ message will fit perfectly with the consumer shift to mobile internet use.

He said: “The shift to mobile creates more opportunities over the phone.

“The average [online travel agency] customer visits 23 sites. The average conversion is 0.7%. Customers are getting data overload. We can provide a better customer experience by phone.”

Teletext launched press adverts and bus billboard ads on a minor scale this month, but plans a bigger push this spring.

Endacott said the marketing budget would be “substantial” but declined to give a figure.

However, he said: “We will be exploiting the same sort of media as Low Cost Travel Group which has spent a substantial amount.”

Teletext signed a single-supplier deal with TTA-member Truly Travel at the end of 2013 and now provides the sole distribution channel for the company, with Truly Travel fulfilling bookings through a call centre in Hyderabad, India.

The holidays will be fully protected both under the TTA trust account and Truly Travel’s Atol. But Endacott said: “We won’t be making a virtue of bonding because the CAA has failed to make it a differentiator.

Endacott said Teletext currently handles “circa 300,000” passengers a year.

Of his colleagues on the Teletext Holidays board, Sainsbury joined from Tesco three months ago and Farrugia has been with the company since September 2013.

Farrugia said: “We have dramatically overhauled the consumer experience, overhauled the website and given the call centre the tools to connect with the consumer.”

But Endacott said: “There is a lot further to go. Over the next three years we’ll re-engineer the whole booking process, for example to allow screen sharing and so customers can pay without entering their details.”

Endacott’s On Holiday Group ceased trading almost a year ago.

Running the MyTravel retail and tour operations in 2003, I saw a big opportunity to exploit the fledgling Dynamic Packaging sector by creating a bed bank and building Dynamic Packaging (DP) technology via my technology business CWT Digital. Therefore, I jumped and have been deeply immersed in the Dynamic Packaging sector for the last 11 years.

Some of my investments such Holiday Taxis, CWT Digital, Rock Insurance and Internet Traveller have prospered and been extremely successful, however as widely reported the On Holiday Group’s bed bank operations collapsed in March 2014, under the weight of a £4.5m dispute with HMRC. Fortunately, my good friend Manny managed to pick up the assets and staff for virtually nothing, in order to create Magic Rooms, so not was the effort was wasted. However, even Manny has not been brave enough to venture into the B2C Consumer direct world yet. Why not you may ask?

The key problem with Dynamic packaging is that it’s a “Commodity” market, where each retailer has access to the same basic ingredients, in terms of flights, hotels and transfers. Unique, product is virtually unheard of.

The 1.0 DP battle involved taking the commodity holiday sector away from the then fat and inefficient traditional tour operators and forcing them to move their focus to “Differentiated” holidays. The internal DP battle between the first “On line Travel Agents” (OTA’s), revolved around who had the fastest and best web sites. Quickly a relatively level playing field was achieved and technology stopped being a key differentiator, with everybody expanding fast.

The 2.0 battle was focused on PPC and SEO spend within Google. Here, the Google algorithm around click history, created a massive barrier to new entrants and saw companies such as Travel Republic and On the Beach, given a major early mover advantage, as their PPC history protected their top positions within most destination, resort and hotel search results.

However, even these brands are now being strangled by the perfect nature of the Google advertising model. Given the complete measurability of PPC advertising within a commodity market, its not really surprising that click costs have risen so high, that they match or even exceed the commissions built into the holiday prices.

The recent rapid migration away from desktop (now 48% of Google clicks) to the newer tablets and mobile phones has also created massive issues for the On Line Travel Agent community (OTA’s). This is because cross platform tracking is hard and although mobile conversions are lower, OTA’s dare not be present in this growing sector. Hence, PPC performance has declined markedly on the last 18 months eroding profits.

In my view we are now entering the 3.0 stage of the Dynamic Packaging evolution. This stage will be the “Age of the Brand” with strong brands evolving and moving ahead of the pack.

My logic is hopefully relatively simple to follow.

• Brand traffic cost pence, compared to pounds for most other PPC traffic sources.
• Brands can afford to advertise across all platforms; since even brand clicks on mobiles   lasting minutes can be cost effective in the booking funnel.
• Companies with high brand traffic have markedly lower advertising cost.
• Lower advertising costs allow lower prices, which in turn drive more sales in a price sensitive commodity market place, creating a virtuous circle of growth.

This is exactly why the aggressive Low Cost Holidays management team have invested around £6m this year in “Above the line advertising” (ABL) to try to build their brand and direct brand traffic. Theoretically, over time this brand traffic will reduce their average Google costs enough to balance this massive investment.

However, its no longer practical to just spend millions on traditional interruption based marketing such as TV, Radio or outdoor media to create a brand. Social Media and in particular Consumer Reviews are having a massive impact on brand. The first thing consumer do when researching holidays is to look for pier-to-pier reviews on sites such as Feefo, Review Centre and Tripadvisor. If companies do not respond virtually instantly to complaints received via Face book or Twitter, whole streams of uncontrolled criticism can kick off. The bottom line is that if you do not offer a great booking experience and a great holiday you heading for trouble.

The sector is therefore faced with some massive challenges that need to be addressed to allow sustainable brands to be developed.

• Lack of inspiration. Most online sites insist the customers know exactly what they want before they can make a search and quickly try to force customers down a relatively inflexible booking funnel e.g. here are results for Majorca for 7 nights from Gatwick on date X. With an emotive product like travel, customers need to be inspired and explore in a much more flexible way. At the moment homeworkers and shop staff are much better positioned to perform this role, with most OTA’s just competing on price.
• Offer over load. Customers visit 23 online sites before booking and spend 24 hours researching holiday options. A key reason for this is that DP sites offer millions of options and do not in my opinion, have enough focus on making recommendations.
• Little product control. Few DP agents even know what is pulling through into their sites, as they have 20 plus XML bed suppliers, 49 airlines and multiple transfer providers. I am not convinced that they effectively control product quality, let alone Health and Safety compliance.
• Suppliers judged on price. Agents complain to suppliers about over bookings, customer complaints and general service levels, but still sale on solely based on price and do not effectively reward suppliers focused on quality. Hence, suppliers now focus on price and little else.
• In-Resort infrastructure. Few agents operate 24-hour duty offices or have local ground handling agents providing reps in resort to look after clients. Therefore, they are relatively ineffective in dealing with issues in resort and have to wait for written complaints upon the customers return. In general these customers are unrecoverable and likely to share their reviews using social media.

All of the above issues do have solutions, but most cost money, which historically companies have hesitated to spend whilst competing in such a low margin price competitive sector.

However, there is no point spending millions on advertising, if it’s all undone via poor service levels, which are shouted about via social media by unhappy customers. The benefits of repeat traffic are becoming so great and the damage social media can do to brands offering poor quality service or holidays, that change is inevitable.

Exploiting the 3.0 evolution is obviously going to be easier if you already have a brand. This does make successful entrepreneurial start ups in the DP sector look unlikely moving forward, unless they are exploiting specific niches and are focused on high quality differentiated holidays.

Given this I personally intend to keep my recent pledge to focus my start up energies outside of travel.

Within travel I will obviously continue working on my existing interests, but will focus more on consultancy work. There are still some very interesting travel brands capable of dealing with all the above issues and surging to the top of the pack. Sadly, its unlikely I will be own one unless somebody is willing to loan me a large check book, as the days of pure start ups appear to be over in travel.

I recently took two of my sons on a NBA Basketball tour of 5 American cities and was amazed at how easy it was to put together such a complex tour via the internet, using the ticket resell site Stubhub, booking.com for hotels and Airbnb for luxury private accommodation.

Interestingly, I’ve historically never had the confidence to book privately owned accommodation over the Web, but the advent of user reviews and one previous experience of using Airbnb services, has converted me into an avid advocate of this type of accommodation. For literally the same price as a single hotel room, I was able to secure a two bedroom luxury apartment in central Los Angeles and the same again in a prime location near Central Park in New York. These options provided great locations, increased privacy and most importantly space to unwind after several hectic days sightseeing, shopping and of course watching NBA Basketball.

Airbnb is currently valued at $10billion and recently announced its intention to provide a much wider range of travel services to its customers, in order to replicate the services offered by its hotel competitors. However, interestingly it is also getting increasingly tied up in what appear to be “hotel protectionist” legal actions, from people such as the Mayor of New York. Not surprisingly, he does not want to see all the lovely tax income New York gets from its hotels, disappearing into the internet ether of bank accounts of private owners. So clearly Airbnb is a massive threat to the traditional hotel sector.

Currently, I would suggest that few UK Travel Agents would even consider using Airbnb as a source of accommodation, even though most will now be Dynamically Packaging with a wide range of Bed Banks. In some ways they may be right to hesitate, since I doubt Airbnb are willing to offer “product indemnities” or provide even a basic “Health and Safety” audit on their supplied properties. However, this may be another “King Canute” approach by Travel Agents, to the way the internet is changing consumers purchasing patterns in the travel industry and perhaps they should be embracing it as a new product alternative.

In my opinion, it is clear that sites like Airbnb, of which there are already many, offer both superior accommodation and a much more in-depth cultural experience when travelling. Instead of the convenience of the hotel buffet breakfast, concierge or spa, you’re forced to explore the local area in order to find the equivalent services. For example, we ate in the local restaurant’s recommended by the property owners, who use them daily and sourced gym access by going online and signing up for free trial passes, offered by the major fitness chains such as 24 hour Fitness or LA Fitness.

The trip therefore felt much more like an exploration of the USA, rather than the usual “Culture Vulture” tours that I have previously experienced and had the added benefit of sport, more sport and even more sport to keep my two boys happy and bonded with their dad. Personally, I see events based trips visiting multiple cities and using private accommodation as a highly attractive niche, offering high margins and a large degree of differentiation if it is done correctly. It may not be my next venture, but it has certainly made it to the ideas shelf.

The directors of OHG Accommodation Ltd have today announced that they been forced by HMRC continuing to withhold £4.5m of disputed TOMS VAT to put the business into administration. This is because they are unable to pay all hotel bills as they are falling due and want to secure an orderly wind up of the business from a customer and travel agency partner perspective. As a result its Dubai based trading partner Euro Rooms Direct Ltd has also decided to stop taking forward bookings.

OHG has had lengthy discussions with most of the major bed banks over the last week, to try to persuade one of them to take over the client account and the £19m of forward bookings carrying £600k of profit. Again this would have minimised disruption to customers and OHG’s travel agency partners. However, we are saddened to report that only one bed bank was willing to complete a deal to help their travel agency partners. Unfortunately, this deal floundered last night, because of deliberate and inaccurate leaks to the Spanish press along with legal complexities relating to the client account.

All monies received from agents is held in ring fenced client accounts and will be returned by the On Holiday Group to agents in the next few days along with the bookings effected in resort. Unfortunately, this does mean customers will have to pay their bills in resort and reclaim the funds from our travel agency partners.

On Holiday Group CEO Steve Endacott commented, “The timing of the Supreme Court ruling in favour of Medhotels could not be more ironic and maddening. We are obviously glad that it gives a virtually guaranteed £4.5m pay out to our hotel partners, however it is likely that this will take a further 6-9 months to secure from HMRC and we have had legal advice that we can not trade until this point, without going into Administration.

I am outraged that HMRC have been able to take £4.5m of disputed VAT charges on a “guilty until proven innocent basis” and it has taken a ridiculous 4 years for to receive a Supreme court ruling that ratifies all our legal advice that we were acting correctly as the “Agent of the Hotelier” and HMRC where wrong in their stance.
The withholding of £4.5m money has effectively destroyed the OHG bed bank business, since it forced us to stop selling EU VAT zone hotels and removed the working capital required to effectively operate a bed bank. We are obviously exploring the potential for a damages claim, but our lawyers advise it is very hard to secure damages against HMRC who seem to have virtually unlimited rights when you are in a VAT reclaim position.

We have been forced to take the decision to put the company into administration due to pressure from hoteliers to make payments, which OHGA cannot do without the return of the £4.5m held by HMRC. Not surprisingly our hotel partners are not willing to wait up to another 9 months to receive payment. Obviously, I am absolutely gutted and deeply sorry to put 65 staff at risk today”

Endacott explained the background to the VAT dispute as follows, “Traditional tour operators, who own their own aircraft, shops networks and have ATOL licences, are deemed “principals” operating in the UK. As such, they have always paid VAT on the profit related to the accommodation element of holidays under the TOMS VAT scheme. However, when the UK market evolved and dynamic packing was invented, bed banks all set up on the basis that they were the “agent of the hotel” and the relevant VAT should be paid in the local market, where the actual product e.g. the hotel stay, is consumed. Unfortunately, Med Hotels (latterly renamed to Secrethotels2) made a mess of their structuring and actually changed in a matter of weeks from an agent to a principal and back again, sparking an investigation from HMRC.

Unbelievably this dispute has raged for over 4 years and in the meantime HMRC has applied a “guilty until proven innocent” approach to the rest of the UK bed bank sector, accessing all players retrospectively over a 4 year period and forcing bed banks to pay TOMS VAT under protest until their individual cases can be heard.

It has always been our lawyer’s opinion that OHG has followed the correct procedures from day one and has not breached the disputed Medhotels behaviours. However, because Medhotels has been the “case precedent” OHG has not been able to effectively progress our own case until this case was resolved and a clear ruling on the subject made.

The other key problem is that UK Travel Agents self-invoice and deduct VAT when making payments to bed banks on both EU VAT zone and non-EU VAT zone hotels where no VAT is payable. OHG then has to reclaim millions of pounds of this VAT from HMRC every year, before paying VAT on its much smaller profits. Hence, when the dispute arose HMRC just refused to pay back any travel agency VAT moneys. Although, there are numerous hardship protections for companies disputing what VAT they should pay to HMRC, unbelievably there is absolutely nothing you can effectively do if you’re in a reclaim position.”

The Supreme Court ruling has now been received and clears Medhotels but unfortunately it is to late to save OHG, however it does make it virtually certain that OHG’s administrators will be able to recover the disputed £4.5m of VAT and repay it to OHG’s creditors who are mostly overseas hoteliers.

Endacott explained that the directors had not been able sell On Holiday Group as a going concern. “On Holiday Group as the largest independent bed bank in the UK obviously has major strategic value to any of the large OTA’s. There are multi-million pound synergies by placing a higher proportion of OTA’s buying requirement in-house and the buying power advantages of combining B2C focused distribution with a broad B2B distribution networks. We have therefore had extensive and detailed discussion over the last 6 months with a number of interested parties, however all deals have floundered because of the £4.5m VAT dispute and its inherent risks. We obviously would have liked to resurrect these discussions, but again we have run out of time.

It is expected that the collapse of OHG will leave its creditors which are primarily its overseas hotel partners with unpaid debts of £7m plus, since the collapse will make worthless many of OHG’s assets such as investments in other source markets or IT systems.

This week Paul Evans (Low Cost Holidays), one of the co-founders of the Association of Travel Agents (ATA) resigned with a simple message: “Sorry, solved the problem by moving to Spain. We are out”.
This location move out of the UK by a major OTA is, ironically, one of the outcomes the ATA had predicted to regulators and has been lobbying to prevent.
The combination of the impending reforms to the European Package Travel Regulations (PDT’s) and ever increasing regulatory costs of operating on the UK, compared to other European member states or so called “off shore” solutions outside of the EU, make such moves virtually inevitable.
Whilst operating based in the UK, Low Cost Holidays (LCH) incurred ATOL charges of £2.50 per pax, which on its approximate 1m passengers, would cost a whopping £2.5m. Compare this to Spanish Tour Operating bonds which start as low as €60k. It will literally save LCH millions by moving to Spain via this lower cost alone.
Add to this the much lighter regulatory touch, where balance sheet inspections and requirements are not as arduous as those imposed by the CAA, and you have reason enough to make the move to Spain, right now as Low Cost have.
However, these costs shrink into insignificance when compared to the cost of TOMS VAT, which could be imposed on every travel agent selling holidays by the revised European PTD.
ABTA has taken the view that even thought the revised PTD’s will impose “Principal” status on UK travel agents selling holidays, that this does not necessarily mean they will become liable to pay TOMS. However, the ATA believes this is highly naïve position.
Why would the major UK tour operators stomach a position where they have to pay TOMS, but other Principals selling dynamic packages do not?
I can guarantee they will be lobbying hard for HMRC to impose TOMS VAT on dynamically packaging agents, and in an environment where the UK Government is desperately seeking increased tax revenues, why would this not occur? The TOMS VAT charge has been estimated as £20 per passenger and therefore in Low Cost’s case alone would equate to £20m extra cost.
Spain has demonstrated how their “Bed Bank” sector has been treated by Spanish tax regulators recognising the “Agent of the Hotel” approach – expecting their locally based hotels to pay IVA (Spanish form of VAT) rather than their agency distribution partners.

When applied to packages sold under a Spanish licence, it in effect dramatically reduces the IVA on any holiday package and makes it highly attractive to be based in Spain. Hence, even though the majority of Low Cost’s passenger volume still originates from the UK, they can deliver at a lower cost by being based in Spain. In a price sensitive market is likely to grow their market share, at the expense of UK based business.
So in one neat and highly legal move, Low Cost have torn a gaping loop-hole on the UK regulatory framework, which the CAA are now running around looking for ways to close.
Andy Cohen of the CAA could not have put out a more strongly worded condemnation of the Low Cost move, but in reality European Law makes the CAA powerless to stop Low Cost continuing to sell holidays in the UK, completely out of the their control.
The UK Industry may like to think that without the ability to show either an ATOL or ABTA logo that Low Cost’s booking levels will drop. Unfortunately, the evidence to support this hope does not exist, as demonstrated by the fact that less than 5% of holiday makers decided to cancel their holidays when notified of the change of bonding by Low Cost.
I can only recommend therefore that the CAA continue with its current sensible approach; of commercial negotiation with the major OTA’s and airline holiday companies to get them to join the ATOL environment on a voluntary basis at a sensible cost. Remove the short term cost advantage and few players will disrupt their business models by moving to Spain unless the saving is substantial.
However, the TOMS VAT threat imposed by the revised European PTD’s as they stand will make the cost advantage of moving so great it may not be resistible.
This is why the ATA will continue to work closely with the CAA to push the continuation of the current Flight Plus regime with both UK and European regulators. This recognises the need for Travel agents to trade as agents and not principals and as such avoids the imposition of TOMS VAT.
If Flight Plus is not retained and principal status is imposed it will create an uneven playing field against the unregulated giants of bookimg.com and low cost carriers sourced by a few Google clicks. If this occurs the commodity holiday sector, currently serviced by OTA’s and UK high street agents, will either be destroyed or forced to move out of the UK reducing both tax and bonding revenues.
Personally, I regard Paul Evans and his Low Cost Holidays group as smart players, who were able to adjust their trading model to save millions, and have done so.
However, abandoning the ATA cause is something I hope to persuade Paul was a premature and short-term decision that he should not have made. If not, some of the other ATA members may end up buying Paul a beer in Palma every Friday night come 2016!

This summer’s heat wave put the topic of “Connected Kids” and the evolution of their holiday requirements at the forefront of my planning for Summer ‘14.  For as long as I can remember, mum’s have dreaded the 6 week summer school holidays because of their kid’s need for intensive interaction, play dates or days out, to offset their inevitable boredom.

However, the Internet, game consuls and Sky TV have brought massive changes in our children’s behaviour, with the new challenge being how to get them out of their bedrooms and outside.  Over the last 10 years beach destinations have embraced Sky TV, with football games, Coronation Street etc. being available in bars in virtually every major destination. Owners simply consider it a cost of doing business – if they do not offer this service their revenues decline rapidly.

Oddly, most hotels regard Digital TV and Internet access as revenue opportunities via paid for services, rather than being willing to invest in them as service differentiators. This might be acceptable if the service they provided was actually effective. I have lost count how many times I had to sit in a hotel reception to use the Wi-Fi or gone to connect in the room only to realise my iPhone, iPad or Mac cannot be plugged into the out-dated Internet cable provided.

To be fair, a key problem is the sheer size of most hotels. It is relatively simple for a bar or coffee shop to provide a free Wi-Fi service, since their maximum concurrent capacity is likely to be 10-20 people trying to use the service. Also customers are less likely to want to use streaming services for watching Netflick’s etc. and more likely to just be downloading emails or accessing Facebook.

Conversely, most beach hotels will have 200 plus rooms on multiple floors over a wide expanse of space. Hence, whilst most provide Internet access often it simply cannot cope with the demand and this results in a poor impression for hotel. Soon, a key search criterion for beach hotels, driven my kid’s requirements, will not just be “Does it have Wi-Fi”, but what broadband speed does it offer! Believe me this is coming.

At next month’s World Travel Market event in London, I have organised a session with key industry players to discuss this exact topic and try to raise the awareness of the importance of the issue with our hotel partners.  Personally, I want to take a radical look at the whole in-resort entertainment experience for kids and will be suggesting some of the following

Þ      My DJ set. Keep some of the traditional cheese of the nightly kids discos, but allow the slightly older kids to create play lists on their iPhones so they can have their own DJ sets during the evening.

Þ      International electro Olympics. Most online games support multi player action. So allow kids to create national teams and compete against each other. You never know we might finally be able to beat the Germans at a penalty shoot out on FIFA ‘14.

Þ      Game Hardware. As online gaming has developed, the equipment for playing games on has become incredibly cheap relative to the Game discs themselves. In my opinion hotels should put space aside and invest in 10-20 game consul and TV combinations, whilst leaving the kids to bring their own game discs or renting game disc’s in order to generate a revenue stream to pay for the initial £5-10k investment required. However, more progressive hotels will follow the bar owners approach to this and just see it for what it is; a basic cost of doing business.

Þ      FREE WiFi per Floor. Make the investment and put in a broadband connection in per floor and Wi-Fi routers labelled with the floor number. This will make it incredibly simple for customers to know which one to connect to. Wi-Fi cannot continue to be a revenue opportunity in the future since it is going to be a basic hotel service.

Þ      Capturing customers email address. Make customers access passwords to the Wi-Fi their email address. This will open up a new world of cost effective CRM, where hotels can encourage customers to leave online reviews and pass on discount codes, which can turn customers in to hotel advocates that bring in other customers.

 Even this approach will have to evolve over the next 5 years, as the EU finally move to banish outrageous and completely unjustifiable “roaming” charges that customers are currently ripped off by, when using their mobile phones overseas.

Realistic roaming fees will see individual mobile phones becoming the access point for all customers computing devices via tethering. However speed may remain a big restrictor in some beach countries where 3 or 4G networks have not been rolled out.

The bottom line is that if hotels do not evolve their offering it will be harder to get kids to go on the traditional beach holidays and if they do not experience them as kids, don’t assume they will prefer them over other holiday option when they become adults themselves. We really are talking about an investment in to the future of beach holidays here.

 

The Association of Travel Agents (ATA) initial reading of the draft Package Travel Directive (PTD) was positive. It appeared that the European authorities had listened to our key argument, that agents must be allowed to continue to act as agents when selling “Dynamically Packaged” holidays using low cost carriers and hotel suppliers.

The concept of “Assisted Travel” seemed to be added specifically to allow travel agents to sell holiday elements in the same way customers book them online, which would have been a key concession. Online, customers book and pay for a flights e.g. Easyjet in one transaction and then immediately follow this with the booking and payment for a hotel from a different provider e.g. Booking.com. The “Assisted Travel” provision excludes a holiday booking from being a package as long as each element is booked and paid for separately. However, clauses elsewhere regarding making multiple bookings within one visit, will make it virtually impossible for most high street agents and OTA’s to come within the definition of “Assisted Travel” and these bookings instead will be classed as packages. Ironically, “Assisted Travel” will cover all bookings made via Google for holiday components and will therefore give Google compiled unprotected holidays a major cost advantage over travel agents, the very thing the ATA have been arguing against.

“Assisted Travel” seemed to try to allow agents to continue to “Manually” create “Dynamically Packaged” holidays by putting holiday elements together, but arbitrarily insists they take payment separately for each element of the holiday, one component at a time. Unfortunately this ignores the practicality that customers want to know that they have secured their chosen holiday accommodation, before booking a flight or visa versa.

Under the current drafting however, if these same components are offered in a basket approach by an OTA, these elements need to be treated as a full package and financially protected. To be fair this is actually very similar to the “Flight Plus” model introduced by the UK Government in 2011 and if the draft PTD’s only applied financial protection in the same way this does, then few OTA’s would complain.

The draft PTD goes considerably further by imposing all the full liabilities of a standard package. The problem is that this does not recognise the differences between a traditional tour operation, which the original PTD was designed to cover and the modern internet world of dynamically packaging OTA’s.

The major tour operators own their own airlines and work with a narrow range of hotels, with representatives in resort and local ground handing partners. This gives them a great deal of control over their product offering and the ability to deliver the Health and Safety requirement, as well as the quality of the product in resort.

On the other hand, the online travel agency model has hardly any control, since they do not own the airline, work with a massive range of hotels and do not have a presence in resort. In my opinion the rapid growth of this sector proves that customers understand this model. They are happy to book more “independent” holidays without the hand holding of the traditional operators, because they are much cheaper, even though they offer a lower level of protection. The European bureaucrats have not presented any research showing customers are unhappy or unaware of this reduced protection.  However, the current drafting will make it very hard for OTA’s to continue to deliver these holidays and creates an anti competitive environment, which could dramatically restrict customer choice.

OTA’s often sell more than 50,000 hotels either via direct relationships or “bed banks”.  Is it really reasonable to expect an OTA to accept responsibility for the health and safety standards of such a range of hotels, whilst sites selling “hotel only” like Booking.com, can sell exactly the same hotels to customers with no such liabilities?

In the modern internet world Google is actually the largest “Travel Agent”, since with one click customers can move between booking flights with Easyjet and hotels with Booking.com. The fact that they make two separate payments seems a strange thing to define whether they need the protection provided by the PTD. This has been imposed simply because the European regulators drafting the revised PTD, recognise that it will be virtually impossible to track such transaction over the internet or decide which party should provide protection under their current definitions.

Most players would agree that the travel market is evolving into a spectrum with the major tour operators “Differentiated” product at one end of the spectrum and the giant Booking.com at the other selling virtually every hotel available. The major tour operators have been vocal about how they are positioning themselves out of the commodity market, which is the lifeblood of Dynamic packaging and are focusing on differentiated product that only they can offer. Obviously from their perspective dragging the OTA community in to the full package regulations is a positive move. It will push up the prices of the holidays offered by OTA’s making, their own products look more attractive. Not surprising they have been using both their strong influence within ABTA and direct lobbying to push for just such an outcome.

The OTA community provide consumers a lot of convenience and financial security by offering a basket approach to booking a holiday. However, the imposition of further regulatory burdens threatens OTA’s ability to be cost effective, compared to a customer using Google to book their own components individually. For example my own company, On Holiday Group has to pay a massive £200k a year plus, for public liability insurance because the market for this product is so limited. Therefore, the extra cost of liability insurance, increased compensation payment and further regulatory cost could easily push up holiday prices by £10-15 per person even before we consider the application of TOMS VAT.

The key flaw with the proposed revised PTD’s as they stand, is that they will create an uneven playing field. In a commodity market, even a few pounds can make the difference to a holidaymaker, who is simply not focused on the potential down sides when booking. In my opinion, they are likely to vote with their fingers and build holidays using Google to find flights, hotels and transfers, which they can book individually a lower cost, without the extra £10-£15 per person OTA’s will now have to charge them.

The net result could therefore be that the new regulations push more customers away from booking via OTA’s, who offer financial protection under Flight Plus, to un-regulated and unprotected holidays. The biggest winners under this legislation will be companies like Google and Booking.com, which as we all know pay little tax in the UK, whilst UK based jobs will be destroyed as many OTA’s will be forced to consider relocating to countries that do not impose these burdens or simply shutting down.

For many years the UK industry lead by ABTA and supported by the CAA have been calling for an “All Flights Levy”, where it would be the airlines responsibility to provide financial protection for their failure. Combine this with the obvious move of making individual hotels responsible for their own Health and Safety via a centralised accreditation scheme and you have the right solution. This would cover the whole of the booking spectrum including customer’s component bookings using Google and provide the level playing field the ATA continues to fight for. However, unfortunately this would appear to be a pipe dream and the ATA will continue to focus on amending the current drafted regulations.

The good news is that the European regulators so far have been willing to listen to common sense and have already moved substantially in their drafting. Therefore, it’s a time to just work harder and explain the issues clearly and forthrightly. The ATA will certainly not be giving up the fight to get a fair and balanced solution, but does need the support of the entire agency community who are all going to be adversely impacted if the draft legislation is not changed.

 

During the ash cloud crisis of 2010, holiday sales suddenly dropped by 25% whilst customers sat back and assessed how long it would be before planes could fly again i.e. a major event.

So it’s a bit of a shock that a simple heat wave over the last week has had the same level of impact on sales, with most major OTA’s reporting sales down by more than 20%. To be honest few of us saw this coming, having expected a decent lates market without the distractions of Euro Football tournaments, the London Olympics or Royal Weddings.
Like most business owners in travel I have been desperately looking around for an explanation and an idea of how long this weak demand may last.
Unfortunately my personal conclusion is that it will probably last as long as the heat wave does, and rather than delaying the booking decision, it may be simply removing customers from the market.

A combination of recession and electronic evolution would seem to have increased the vulnerability of the commodity sector of the UK travel market to good weather.
As per my previous blogs, I like to categorise the holiday market between the “Haves” and the “Have nots”. The “Haves” with their jobs and low mortgages have never been better off and are happy to trade up to the “Differentiated” holidays offered by the major tour operators. The “Have nots” who traditionally book late using credit cards, have been impacted more by the recession and hence when a heat wave hits, it’s very tempting to shelve the overseas holiday and just sit in the garden.

We also need to take into account the “Electronic Evolution” that has occurred over the last 5 years. Like many parents I used to dread the long summer holidays and the difficulty of keeping kids entertained at home. However, these days with the advent of high speed internet, X-Box, play station, video on demand and Sky TV, kids have never been happier sitting at home enjoying the electronic world.

As an industry I think we should recognise this threat and push our hotel and tourist board partners on the importance of investing in FREE high speed Internet in all holiday hotels. If we cannot provide the connectivity our kids demand in life, don’t be surprised if they start refusing to go on holiday with their parents to destinations that only offer a beach and a pool. It may have been good enough for us as kids, but it’s clearly no longer good enough for this generation.

So when the kids are happy at home and the parents can get a free tan in the back garden, I suppose a 20% drop in relatively expensive school holiday sales should not actually be a big shock, it felt this week.

However, before we all get too depressed I think we should remember that summers like this statistically only occur every 13 years and for the majority of the time UK summers are complete rubbish. So let’s all do a rain dance and hope things get back to normal – sooner rather than later!