Honorable Ray LaHood

Secretary

U.S. Department of Transportation

1200 New Jersey Avenue, S.E.

Washington, D.C. 20590

To whom it may concern,

We are writing in support of the Resolution 787 in our capacity as chairmen of the Passenger 

Distribution Group (PDG) and the Distribution Data Exchange Working Group (DDX) respectively, the 

industry bodies that are charged with the governance of the development of the XML based data 

transmission standard called for in the Resolution.

The PDG, an airline group formed in 2011 by the IATA Joint Passenger Services Conference (JPSC), is 

charged with setting the framework and scope of the proposed XML standard called for by Resolution 

787. Today it is made up of distribution executives from 17 airlines from around the world. 

The Distribution Data Exchange Working Group (DDX) was formed by the PDG in 2012. It is an open 

group that currently includes airlines, agents, IT providers, GDSs and other members of the airline 

distribution value chain. It is charged with the development of the technical standard itself. The primary 

role of the DDX is to document detailed business requirements and develop implementation guidance 

for data exchange / technical standards in the area of airline distribution. 

As chairs of these two governance bodies, we can confirm the following:

 The proposed new data specification, when implemented, will operate in parallel with the 

existing specifications. The existing data specifications for EDIFACT will be maintained. 

 Conversion from the current EDIFACT standards to the proposed new XML standards is left up to 

each individual airline. It is not mandatory. It is expected however, that over time – likely a 

period of years – most airlines, IT providers, GDSs and their agency subscribers will adopt the 

new XML standard due to its increased functionality, flexibility and efficiency. 

 The proposed new XML standards themselves are not mandatory even if airlines and their 

service providers choose to use XML to transmit data. Paragraph 1.2.2 of Resolution 787 makes 

this completely clear: “PADIS [Passenger and Airport Data Interchange Standards] message 

standards shall be used for the transmission of data. Development of messaging standards shall 

be in accordance with the provisions of Resolution 783.” PADIS standards and Resolution 783 

only relate to recommended industry procedures that are not mandatory for Members or any 

other party. Mandatory standards are governed by other Resolutions. (See, Res. 783, para. 5.3)

 The proposed new XML standards will include many optional data fields that airlines may 

choose to use or leave blank in any given transaction. The goal in the design of the standard is 
to ensure broad capability to transmit various data, not to require that any specific data element

must be used. 

 The PDG and DDX are sensitive to data privacy concerns. The proposed standard will be 

designed to support functionality to be developed by aggregators or others to protect 

consumers’ privacy. For instance, the standard will support the separation of data sent to each 

travel supplier as part of a request for a fare quote. Taking an obvious example, a frequent flyer 

number provided with a request for a fare quote will not be shared with other airlines, unless 

specifically requested by the customer. The data standards will be developed to support this, 

and additional capabilities to manage the data to support privacy concerns. However, it is not 

feasible for the designers of a global data specification to compel parties who may use it in 

scores of jurisdictions with dynamic privacy laws to all adhere to a single set of privacy rules.

 The PDG’s, and subsequently the DDX’s, efforts in this standard setting exercise are completely 

focused on augmenting the current distribution standards to provide better transparency for 

airline customers and Travel Agents. The standard setting efforts will achieve a new distribution 

capability that will enrich the current exchange between consumers and the airlines including 

intermediary third parties.

We hope this information is useful in your deliberations on the Resolution 787 application.

Thank you for your consideration.

Sincerely,

Graham Wareham

Chairman, Passenger Distribution Group (PDG)

Air Canada

Alexander von Bernstorff

Chairman, Distribution Data Exchange Working Group (DDX)

Deutsche Lufthansa