Carlson Wagonlit Travel

– 31, rue du Colonel Pierre Avia

– CS 91551, 75741 Paris Ce dex 15, France. Tel : +33 (0)1 41 33 60 00

– fax : +33 (0)1 80 97 75 47 C www.carlsonwagonlit.com Secretary Ray LaHood Electronically submitted

United States Department of Transportation 1200 New Jersey Ave. SE Washington, D.C. 20590

April 30 , 2013

Re: In consideration of International Air Transport Association’s Resolution
787; Docket No. OST

- 2013

- 0048

Dear Secretary LaHood,

Carlson Wagonlit Travel (CWT) respectfully submits the following comments regarding the International Air Transport Association (IATA)’s application (Docket

No. OST

- 2013

- 0048) to the U.S. Department of Transportation (DOT) for approval

of its Resolution 787.

CWT is a global travel management company with sales volume of $27.7 billion for wholly owned operations and joint ventures. We operate in more than 150 countries and territories, and serve companies, government institutions and non

governmental organizations of all sizes. Our primary clients are corporate travel buyers and their travelers.

CWT reviewed IATA’s application and attempted to assess the impact that

Resolution 787 would have on its clients if adopted. I n CWT’s opinion, the application ’ s lack of clarity and detail made such a determination exceedingly

difficult.

However, f rom what we could assess from IATA’s application, CWT is concerned about the potential for Resolution 787 to adversely affect the prices our clients pay for air travel, based on IATA’s intent to: 1. shift from fare transparency to fare opacity by removing the ability to comparison shop between carriers; and 2. remove travelers’ ability to shop anonymously by requiring they provide p ersonal information before being quoted a flight price, which could lead to biased pricing

based on traveler characteristics.

CWT supports solutions that provide our clients full content at competitive prices, while offering travelers an efficient and i ntuitive user experience. We recognize travel technology must evolve to better accommodate the merchandizing capabilities of airlines and other travel suppliers, as well as the ever

- increasingCarlson Wagonlit Travel

– 31, rue du Colonel Pierre Avia

– CS 91551, 75741 Paris Ce dex 15, France. Tel : +33 (0)1 41 33 60 00

– fax : +33 (0)1 80 97 75 47 C www.carlsonwagonlit.com expectations of travelers, but these advancements cannot come a t the expense of

the end consumer’s overall interests, which include price and access to full content. Further, CWT advocates for solutions that ensure a continued competitive

environment with continued benefits to the end customer.

CWT would consider p articipating in any industry initiative that represents the full, best interests of our clients while also benefiting our valued airline and technology partners. However, at this time, we do not have sufficient information to determine

whether IATA’s Resol ution 787 is that solution. We urge the DOT to require IATA to provide more information as part of their application, so the travel industry can better assess and react to their proposal before the DOT takes a decision on this highly important matter.

Respectfully submitted,

Douglas Anderson President & CEO, Carlson Wagonlit Travel