i BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

Comments of
DELTA AIR LINES, INC. Comments on the Agr eement Adopted by the Passenger Services Conference of the International Air Transport Association Docket DOT - OST - 20 13 - 0048

COMMENTS ON APPLICATION FOR APPROVAL OF AN AGREEMENT (RESOLUTION 787) BY THE I NTERNATIONAL AIR TRANSPORT ASSOCIATION

Communications with respect to this document should be sent to:

March 21 , 2 0 13 Chris Phillips Managing Director

– Distribution Strategy DELTA AIR LINES, INC. 1030 Delta Boulevard Atlanta, Georgia 30320 Andrea Fischer Newman Senior Vice President, Government Affairs Alexander Van der Bellen,

Managing Director, Government Affairs and Associate General Counsel Christopher Walker

Regional Director, Government Affairs DELTA AIR LINES, INC. 1212 New York Avenue , N.W. Washington, DC 20005 (202) 842

- 4184 sascha.vanderbellen@delta.comBEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

Comments of
DELTA AIR LINES, INC. Comments on the Agr eement Adopted by the Passenger Services Conference of the International Air Transport Association Docket DOT - OST - 20 13 - 0048

COMMENTS ON APPLICATION FOR APPROVAL OF AN AGREEMENT (RESOLUTION 787) BY THE I NTERNATIONAL AIR TRANSPORT ASSOCIATION

Delta Air Lines, Inc. (“Delta”) , hereby respond s to the Application for Approval of an Agreement (Resolution 787) by the International Air Transport Association (“IATA”) to the United States Department of Transportation (“DOT”) submitted on March 11, 2013

. For over 40 years, airlines have distributed content through third party distribution networks centered on Global Distribution Systems ( “ GDS ” ) and travel agencies. These networks were established during the regulated airline era when the government played a key role in what markets airlines flew and the pr ices charged for flights and there was limited differentiation between carriers. The GDS systems were developed to create efficiency in the distribution of airline content and served their role well for the era. Unfortunately, this model reinforced a com modity based sales model by differentiating carriers only by their two

- letter airline code and price. Post airline deregulation, airlines began investing significantly to differentiate their products and services from competitors through the introduction o f specialized product offerings both on the ground and in the air. Delta strives to be recognized as aComments of Delta Air Lines Page 2 superior airline, and has spent more than $3 billion in consumer product enhancements including onboard wifi, lie flat seats, premium lounges, and a state

- of the

- art website to make shopping for these products quick and easy

. Unfortunately, the GDS technology distributing content to travel agencies did not evolve at the same pace. Airline products
and services continue to be sold in the same commodi tized manner through most of the traditional GDS/travel agent distribution network. In other words, a seat is just a seat . A customer shopping for a first class ticket from JFK to LAX using outdated GDS technology would have no way of knowing that the De lta f l ight has lie flat seats, in

- seat video and wifi

– but a competing flight has inferior upright seats and no amenities

. Delta has invested in important new functionality on delta.com allowing Delta to recognize its customer s and provide a more person alized shopping experience

-- featuring relevant products of potential interest and special offers tailored to the
individual

. Delta’s website provide s consumers full transparency to the features and benefits of the fare they are purchasing (e.g. fares wi th or without change fees) and the product they will experience on the particular flight (whether equipped with wifi, in seat video, or lie flat seats) . Intuitive options are presented to the customer to determine how they may want to customize their trav el experience to meet their individual needs.
Based on direct customer feedback and the growth of booking volumes , it is clear that customers value this new experience and are increasingly purchasing their tickets on delta.com.
IATA Resolution 787 will expand this type of innovation and provide multiple benefits to the industry and to customers who purchase tickets through travel agencies. The functionality enabled by Resolution 787 will provide travel agent outlets the ability to offer the type of enh anced shopping environment currently available only on airline direct websites. These benefits include:Comments of Delta Air Lines Page 3
1. Consumer Choice & Offer Comparison

– The distribution of Delta content through the GDS continues to be managed as a commodity . In most situations, Delta is only differentiated from its competitors based on a logo/airline code and a fare. There is minimal consumer transparency related to travel flexibility options and diffe rentiated products and services. It is unlikely the GDS will evolve at a comp etitive pace to implement a modern retail environment supporting a personalized, non

- commoditized shopping experience without the competitive spur provided by IATA Resolution 787.
2. Innovation

– T he introduction and adoption of new standards and
innovativ e technology will accelerate competition in the distribution of airline tickets and allow travel agency access to functionality that enables the type of shopping environment found on airline direct websites , enhancing travel agent relevance to their
custome r base.
3. Transparency

– C ustomers will have enhanced access to the same types of information available on airline direct websites to make fully informed purchase
decisions across airlines.
4. Choice

– This resolution does not mean end of the anonymous ,
u npersonalized shopping airline distributio n as the market knows it today; rather it provides a path forward to develop new alternatives . GDS and travel agencies may
determine that the current model works for their business needs and will continue to
exist in that environment. Others will migrate to this new platform to provide the
increased level of more personalized service for those customers who demand it

. Accordingly, Delta urges the Department approve IATA Resolution 787 and request s that a Final Or de r be issued as soon as possible. This will enable the airline industry to begin delivering the benefits of a customer focus distribution system, and promote competition with the legacy GDSs which continue to dominate existing
distribution channels.Comments of Delta Air Lines Page 4
R es pectfully submitted,

Alexander Van der Bellen for Delta Air Lines, Inc.