### April 29, 2013

United States Department of Transportation 1200 New Jersey Avenue, SE Washington, DC 20590

United States of America

**Re: Application for approval of an agreement (Resolution 787) by t he International Air**  **Transport Association (IATA), filed on 11 March 2013 (Docket OST**

**- 2013** 

**- 0048)** 

To Whom It May Concern,

In response to the March 11, 2013 filing with the Department of Transportation of Resolution 787 by the International Air Transport A ssociation, Air Canada files these comments, voicing our unequivocal support for the rapid approval of the Resolution.

Air Canada has a long history of serving the United States and with nearly 400 flights per day

from six Canadian cities to 49 United Sta tes airports; A ir Canada is the largest international carrier serving the Unite d States.

Air Canada is an active member of the IATA Product Distribution Group (the “PDG”) and the IATA Distribution Data Exchange (the “DDX”) Working Group, which together ha ve been responsible for the design and implementation of the New Distribution Capability (“NDC”) standard. As such, we are uniquely qualified to comment on what it represents, what it does not represent, and the potential benefits to the consumer.

Air Canada’s business model is based on simplicity, choice, and transparency for our consumers. This is evidenced by our simplified fare bundles, available on every Air Canada flight, and through our selection of ancillary add

- ons that allow our customers to further customize their final purchase. Our desire to be completely transparent with our customers, allowing them to make an informed choice for travel, is demonstrated by the significant investment we have made in our

award

- winning e

- Commerce website, www.aircanada.com . It is equally important to note that Air

Canada has made similar investments in an e

- Commerce portal for use by travel agencies ( www.aircanada.com/agents ), proving our commitment to the travel trade and our consumers who choose to take advantage of their services. Air Canada fare bundles and ancillary add

- ons are available to consumers on all worldwide versions of Air Canada’s award winning web site, including the web sites available to consumers and travel agents in the United States.

Air Canada strongly believes in the broad distribution of our entire range of products through as many distribution channels as possible. Air Can ada equally believes that the consumer and the airline are best served if the consumer is provided with as much information as possible about the cost, features, terms and conditions of the products being made available to them through their

distribution c hannel of choice. It is Air Canada’s opinion that, in general, airlines are unable to deliver on this promise through channels other than their own websites, due to the communication standard (EDIFACT) in use by current travel distribution channels, which has been largely unchanged for over 40 years.United S tates Department of Transportation

1200 New Jersey Avenue, SE Washington, DC 20590

United States of America

**Docket OST**

**- 2013** 

**- 0048** 

April 29, 2013

2 .../

The NDC communication standard will allow airlines to deliver on their promise of choice and transparency to the end consumer through whatever distribution channel they choose to use. As a modern, widely accep ted and well established technology standard, XML will allow airlines to deliver richer, more complete information to our distribution partners. The partners will be able to seamlessly integrate this information with that of our competitors and present it to the travel professional for communication to the customer. These are real benefits that are being realized by some consumers in Canada today. Together with Travelport, Air Canada has implemented a

full XML connection for the distribution of Air Canada’s product to Travelport subscribers. Travelport travel agents in Canada can use the Agencia Agency Desktop to search and sell the complete suite of Air Canada branded fare products, integrated with other airline content in an efficient display, thereby deli vering comprehensive information to our mutual customers. More information, including case studies, video demonstrations and agency testimonials, is available at www.travelport.com/Produc ts/Travelport

- Agencia

.

Air Canada is confident that with an industry wide standard, development costs will decrease, barriers to entry will be removed, new entrants will enter the market, and innovation will flourish, ultimately benefiting all stakeholde rs.

Some stakeholders have speculated that in an NDC environment, airlines will cease to offer competitive airfares to customers who do not share significant levels of personal information. This could not be more untrue. Market forces would simply not al low an airline to act in such a manner given complete access to information and competitive offers from other suppliers. Air Canada will continue to offer products to consumers at market competitive prices regardless of whether the consumer supplies any pe rsonal information. Air Canada would like to better understand each customer’s unique buying habits and preferences in order to offer tailored products that are more relevant to what the customer is shopping for. However, the decision to provide any person al information will always rest with the consumer.

In summary, Air Canada urges the Department of Transportation to approve IATA’s Resolution 787, as we believe that the development and implementation of the standard will allow the distribution ecosystem to evolve and modernize, permitting Air Canada to expand the distribution of the unique, consumer friendly aspects of our product.

Sincerely,

David Waugh
Director, International Regulatory Affairs and Facilitation

Air Canada