April, 2013

The Honorable Ray LaHood Secretary U.S. Department of Transportation 1200 New Jersey Avenue, SE Washington, Dc 20590

Re: Docket No. OST

- 2013

- 0048

– International Air Transport

Association Resolution 787

Dear Secretary LaHood:

Regarding the NDC (New Distribution Capability) project to be launched by IATA, we express our absolute rejection based on the following considerations.

1.

- The air fare distribution model curre ntly in place is a system that is independent of airlines and distribution channels, namely travel agencies and tour operators. It is operated by companies referred to as GDS’s that rigorously comply with information transparency and guarantee, among oth ers, ample and free global access to content/fares of those airlines who wish to participate in these GDS systems.

2.

- With the NDC model proposed by IATA, the distribution system of air fares will be controlled by one of the market actors: major

airlines (most of them for

- profit privately held companies) associated to IATA, meaning that the transparency principle protected by the current model would be conditioned by the

interest of one of the afore

- mentioned party.

3.

- It is a fact that passenger air tra nsport markets have become more concentrated as a result of privatizations, mergers, acquisitions and commercial agreements between airlines geared to reduce competition (e.galliances and code

- shares). This new air fare distribution system will foster e ven less competition between air carriers and thus negatively impactconsumers.4.

- The air fare distribution system that IATA plans to implement

–

solely oriented to its member’s interests

– will negatively impact the independent channel of distribution by demanding significant financial investmentcost and bysetting conditions for system accesswith no guaranteed access to full content or inventory that would allow the independent channel (travel agencies and tour operators) to compete in fai r conditions; even worse, this scenario would allow large and major airlines to increase their participation in the distribution area

.

5.

- Not having an indirect and independent sales channel like travel agencies and tour operator would highly reduce

cont estability in the air transport market.

The latter would set entry barriers for new actors willing to complete for the business.

6.

- NDC will provide IATA with confidential customer profile information currently stored by travel agencies and tour operators thus creating a vulnerable situation both for the independent distribution channel and forthe consumer, especially in those markets with presence of dominant airlines.

7.

- The aforementioned scenarios directly collide with actions currently enfor ced by organizations that protect fair open competition on behalf of the consumer.

Considering all preceding concepts, our conviction is that implementing NDC will ensue discrimination against the indirect and independent sales and distribution channeland thus foster conditions for the development of a less competitive air transport marketplace. Furthermore, major airlines competing in a particular market might collude (collaborate) in the distribution of its product

offer and air fares

- reducing competi tion among each other

andhinder competitiveness in the market.8.

- We thank DOT and the U.S Government the invitation to

express our opinion about the IATA NDC project.

9

. - Our entity is pleased to witness the concern of most governments that curre ntly protecttheir consumer citizens against

anti

- trust practices. For this same reason, thisdocument will also be forwarded by us to pertinent anti

- trust government organizations advocating in our countr y

.

10

. - Regarding the NDC (New Distribution Capability) project to be launched by IATA, we manifest our absolut rejection of the indicated aspects in the present document.

BOLIVIAN AGENTS TOUR & TRAVEL ASSOCIATION