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 currently 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 others, 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 transport 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 even 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 fair 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 

contestability 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 enforced 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 competition among each otherandhinder 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 currently 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 country.

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