Carlson Wagonlit Travel – 31, rue du Colonel Pierre Avia – CS 91551, 75741 Paris Cedex 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 nongovernmental 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. In CWT’s opinion, the 

application’s lack of clarity and detail made such a determination exceedingly 

difficult. 

However, from 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 personal 

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 intuitive 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-increasing 
Carlson Wagonlit Travel – 31, rue du Colonel Pierre Avia – CS 91551, 75741 Paris Cedex 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 at 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 participating 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 Resolution 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