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 forme d 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 wo rld

. 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 air line distribution value chain. It is charged with the deve lopment 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 govern ance 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 EDIF ACT 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

se rvice providers choose to use XML to transmit data

. Paragraph 1.2.2 of Resolution 7 87 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.” PADI S 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 in clude 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 isto ensure broad capability to transmit various data, not to require that any specific data element

must be u sed.

 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 o f da ta 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 airli nes , unless specifically requested by the customer

. T he data standards will be developed to support this, and additional capabilities to manage the data to support privacy concerns

. However, it is not feasi ble for the designers of a global d ata 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 augment ing the current distrib ution 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 intermedi ary 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