i

BEFORE THE 

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Comments of

DELTA AIR LINES, INC.

Comments on the Agreement Adopted by the 

Passenger Services Conference of the 

International Air Transport Association

Docket DOT-OST-2013-0048

COMMENTS ON APPLICATION FOR

APPROVAL OF AN AGREEMENT (RESOLUTION 787) BY 

THE INTERNATIONAL AIR TRANSPORT ASSOCIATION

Communications with respect to this document should be sent to:

March 21, 2013

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.com
BEFORE THE 

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Comments of

DELTA AIR LINES, INC.

Comments on the Agreement Adopted by the 

Passenger Services Conference of the 

International Air Transport Association

Docket DOT-OST-2013-0048

COMMENTS ON APPLICATION FOR

APPROVAL OF AN AGREEMENT (RESOLUTION 787) BY 

THE INTERNATIONAL AIR TRANSPORT ASSOCIATION

Delta Air Lines, Inc. (“Delta”), hereby responds 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 prices 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 commodity 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 of specialized 

product offerings both on the ground and in the air. Delta strives to be recognized as a 
Comments 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 commoditized 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 Delta flight 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 customers and provide a more personalized shopping experience --

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

individual. Delta’s website provides consumers full transparency to the features and 

benefits of the fare they are purchasing (e.g. fares with 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 travel 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 enhanced 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 differentiated 

products and services. It is unlikely the GDS will evolve at a competitive 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 – The introduction and adoption of new standards and 

innovative 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 

customer base.

3. Transparency – Customers 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, 

unpersonalized shopping airline distribution 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 

requests that a Final Order 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

Respectfully submitted,

Alexander Van der Bellen

for Delta Air Lines, Inc.