4770 Biscayne Blvd. Suite 830,

Miami, FL 33137, USA

Phone: 305 269 6975

Fax: 305 264 6575

Gerhard Rienecker President

Michael Strauss CEO

www.pass-travel.com/en

Page 1 of 3

4770 Biscayne Blvd. Suite 830,

Miami, FL 33137, USA

www.pass-travel.com/en 

Phone +1 305 269 6975

Fax +1 305 264 6575

E-Mail: michael.strauss

@pass-consulting.com

U.S. Department of Transportation

1200 New Jersey Ave., S.E.

Washington, D.C. 20590

USA

Date: April 30th 2013

To Whom It May Concern

The PASS Consulting Corporation (PASS), the Miami based branch of the PASS Consulting Group, hereby 

responds to the Application for Approval of an Agreement (Resolution 787, termed as New Distribution 

Capability or NDC) by the International Air Transport Association (IATA) to the United States Department 

of Transportation (DOT) filed on March 11, 2013. We are delighted to inform you that we support the 

Resolution 787, as we see a substantial benefit of the NDC and consider it as very important for the 

travel industry. 

PASS always had the idea of a unified standard in data structure and exchange for the travel industry. As 

long ago as 2000, PASS developed a XML standard, and since has sold the source code multiple times. 

The currently discussed NDC standard, originally suggested by the Open Axis Group, can be traced back 

to PASS. 

PASS supports IATA’s application and welcomes the movement towards a modern standard, which could 

in the long-term replace working with the more antiquated EDIFACT. This electronic data interchange 

standard was first published in 1987, and therefore does not align a data transmission standard with the 

internet age. Even the first version of XML was already defined in 1998, so PASS – and hopefully the rest 

of the travel industry – is convinced it is time to finally enter a new era. 

Technology should enable creative business models and not influence them. With the new standard 

there will be more competition amongst the airlines and distributors, which should lead to declining 

prices (distribution constitutes a large part of the ticket price) and better customer service. With the no 

longer existing oligopoly (consisting of the three GDSs) and due to new search options, allowing 

travelers to personalize their flight not only by price but also by features (such as Wi-Fi, entertainment, 

etc.) more competition will result from the NDC. Furthermore boycotts like seen with Sabre and 
4770 Biscayne Blvd. Suite 830,

Miami, FL 33137, USA

Phone: 305 269 6975

Fax: 305 264 6575

Gerhard Rienecker President

Michael Strauss CEO

www.pass-travel.com/en

Page 2 of 3

American Airlines would be more unlikely, which is very much appreciated. PASS moreover thinks the 

technology is good enough, if not already too antiquated again, to start this journey. 

However PASS throws a critical look at Google, Apple and other technology companies: in the past years 

they all made clear, that they have the ideas and resources to run over the whole travel industry, by 

providing their own systems, which some of them have already patented. Compared to the past events 

in the music industry (discussing Napster and downloads, while Apple’s iTunes turned everything upside 

down), now the travel industry is at a point where other industries seem to be one step ahead. 

The suggestion now would be to stop discussing whether XML, a now about 15 year old standard, 

should be implemented, but to look forward and give a special attention to the upcoming challenges. 

Regarding all concerns against the NDC, PASS would like to take a stand on the three main arguments of 

this discussion:

1. The NDC will make the GDSs redundant.

As seen today, it is already possible to sell tickets without collaboration with the GDSs: about 

half of the tickets are directly sold by the airlines via the direct channel. Added to this, there are 

airlines (e. g. Easyjet), that sell their tickets exclusively over their website and not via the GDSs. 

As the DOT is not the advocate for the GDSs, it is not the task of the DOT to make sure the GDSs 

survive. In addition, PASS is convinced, that the GDSs are flexible and creative enough to 

improve their business case with newer technology (the NDC). Not least because they also 

operate successfully throughout the distribution chain: they run reservation-, distribution- and 

sales- systems. 

2. Due to a lack of transparency caused by the NDC, there won ́t be any more comparability for 

customers, so that the prices will rise.

PASS sees a gain of transparency, enabled by the NDC. Today it appears that a traveler has more 

transparency when using a GDS, than using the direct channel. However, the transparency is 

only based on prices and not yet on features. In addition it is provided by only three GDSs, which 

can influence buying decisions. It seems to be unreasonable to give all this market power to only 

three profit-oriented companies. A new standard could enable third-party aggregators to 

provide transparency by company offers from airlines based on features in combination with 

prices. This causes advantages for the travelers: the needed transparency would increase, so 

that they can easily pick and choose and most important, compare the offers between different 

airlines. This would introduce middle ground from the two extremes: full transparency only on 

price, provided by GDSs, versus complicated comparison provided by direct distribution through 

suppliers websites. 
4770 Biscayne Blvd. Suite 830,

Miami, FL 33137, USA

Phone: 305 269 6975

Fax: 305 264 6575

Gerhard Rienecker President

Michael Strauss CEO

www.pass-travel.com/en

Page 3 of 3

3. The privacy of the traveler is compromised by the NDC.

As entering personal information is and needs to stay optional, PASS cannot see any 

disadvantages for the travelers. Besides the GDSs are already working on the possibility to 

exchange frequent-flyer information to make discounts accessible. With the Web 2.0 or Social 

Media, data privacy in the internet age needs to be addressed in a global scale by governments 

and other institutions. It’s absurd to think that the travel industry can resolve these matters 

alone.

All in all PASS feels confident that everything will stay in the way it is now and that the only change will 

be more transparency and the option for third-party supplier to come up with innovative business 

models. People who want to be more flexible, will get the opportunity to search for personalized offers 

– those who don’t can just skip this option and search without entering personal information. This all 

will be made possible by a new and safer standard.

PASS therefore kindly requests that the DOT approves IATA Resolution 787.

We thank you for your kind consideration.

Sincerely,

Michael Strauss (CEO)

PASS Consulting Corporation

4770 Biscayne Blvd., Suite 830

33137 Miami, FL

http://www.pass-consulting-travel.blogspot.com