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1	April 20 1 3

U.S.	Department	of	Transportation 1200	New	Jersey	Avenue,	S.E. Washington,	D.C.	20590

To	Whom	It	May	Concern,

APPLICATION	FOR	APPROVAL	OF	AN	AG REEMENT	(RESOLUTION	787)	BY	THE

INTERNATIONAL	AIR	TRANSPORT	ASSOCIATION (IATA)

1. I	refer	to	the	invitation to	submit	comments to	the	United	States	of	America Department	of	Transportation	(DOT) in	support	of	the	International	Air	Transport Association’s	filing	of	Resolution 787	which	through	its	implementation	would establish	a	New	Distribution	Capability	(NDC) enhancing	the	development	and	growth of	the	aviation,	tourism	and	travel	industry.

2. The	Airlines	Association	of	Southern	Africa	(AASA), which	herewith	submits	this

support ,	represents	seventeen	Southern	African	airlines	domiciled	in	the	geographical

area	i n	Africa	South	of	the	Equator	and	includes	the	Southern	African	Development Community	(SADC)	countries.		AASA	is	one	of	the	regional	Airline	Associations recognized	by	IATA	in	promoting	the mutual interests	of	Airlines	in	this	region and works	closely	with IATA	to	promote	mutually	beneficial	objectives	and	strategies

.

3. IATA	has	since	its	formation	been	the	global	lea der	of	the	airline	industry.		It has	the distinction	of	developing,	promoting	and	implementing	standards,	systems	and procedures	which	have	as sisted	airlines	in	meeting	the	needs	of	its	Member	Airlines	to satisfy	changing	customer	requirements	within	a	developing,	accelerating technological	environment.		It	is	within	this	context	that	IATA	has	developed	the	ND C to	effectively	take	this industry to	the	next	level.

4. AASA	therefore	supports	IATA’s	proposed	Resolution	787 and	its	motivation	thereof, with	the	following	additional	comments :2

a. Resolution	787	has	been	drafted	with	the	objective	of	maximizing	the	ben efit	for the	pas senger	that	uses	the	services	of	the	travel, tourism, airline	and	hospitality industry.

b. We	are	aware	that the	Travel	Agency g roups and	Global	Distribution	System	(GDS) Service	Providers	have	noted	some	concerns	with	the	proposal.		However,	in	our analysis	and	discussion s,	we	have	been	unable	to	identify	any	substantive	issues that	lead	us	to	believe	that	the	NDC	will	adversely	impact	the	ability	of	the	Travel and	GDS	industry	to	continue	to	offer	the	quality	service,	which	they	provide	to	our

mutual	customers.

c. Impleme ntation	of	the	NDC (effectively	a	“next	generation”, faster,	cheaper, modernized	data	transmission	standard) will	enable	the	airlines	to	provide	an enhanced	product	offering ,	including	alternative	fare	options	and	ancillary	services,

via	their	traditional channels, in	the	best	interest	of the	customer. We	concur	fully with	the	case	presented	by	IATA	that	Resolution	787	will	bridge	the	inefficient	gap between	direct	and	indirect	channels	through	presentation	of	the	airlin es	complete offering ,	as	passengers	strive	to	make	their	decision on	the	best	available	options

for	their	travel	needs.

d. We	believe	that	the	implementation	of	the	NDC	standard	will	ensure	a	more competitive	distribution	environment	between	Airlines	on	service	offerin gs	and price,	leading	to	better	prices	and	improved	customer	service.

e. An a dditional	matter that	is of	importance	in	considering	the	IATA	proposal	is	that in	considering	the	rights	of	the	passenger,	t he	NDC	does	not	infringe	on	airline customer	privacy	ri ghts. Passengers	will	have	the	option	to	personalize	their requests	to	the	level	they	desire.

f. From	the	A irline s	perspective,	it	is	up	to	the	A irlines	to	decide	whether	they	will implement	the	new	NDC	standard,	or	remain	with	the	current	GDS	used	EDIFACT

standard

, which	IATA	have	stated	that	they	will	continue	to	support	in	addition	to

the	new	NDC. There	is	therefore	in	our	view	no	prejudice	to	the	use	of	the	cu rrent
GDS	and	standards	should	A irlines	and	the	travel	industry	wish	to	remain	with	this

system.

g. From the	Travel	Agent	perspective,	airlines	will	be	able	to	provide	agents	with greater	product	offerings	and	content	to	enable	them	to	provide	better	value	to their	customers.		As	partners,	the	new	NDC	will	enable	GDS’s	to	display	this

additional	conten t	received	from	the	airlines.

5. In	conclusion,	IATA	has	a	vision	for	growing	and	developing	the	global	avi ation industry. A n ew	innovation such	as	the	proposed	new	NDC	is	just	such a	new initiative which	must	be	supported.		We	believe	that	IATA	has	made	a strong	case	for	the3

approval	of	the	Resolution	787

, and	we	recommend	that	the	US	DOT	approves	IATA’s application	accordingly.

Yours	sincerely

Chris	Zweigenthal

Chief	Executive