April, 26, 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 Tr ansport Association

Resolution 787

Dear Secretary LaHood:

Regarding the NDC (New Distribution Capability) pro ject to be launched by IATA, we express our absolute rejection based on th e following

considerations.

1.-The air fare distribution model currently in pla ce is a system that is independent of airlines and distribution channels, namely travel agencies and tour operators. It is operated by companies r eferred to as GDS’s that rigorously comply with information transparency and guarantee, among others, ample and free global access to content/far es of those airlines who wish to participate in these GDS systems.

2.-With the NDC model proposed by IATA, the distrib ution system of air fares will be controlled by one of the market actor s: major airlines (most of them for-profit privately held companies) associate d to IATA, meaning that the transparency principle protected by the current model would be conditioned by the interest of one of the afore-men tioned party.

3.- It is a fact that passenger air transport marke ts have become more concentrated as a result of privatizations, merger s, acquisitions and commercial agreements between airlines geared to re duce competition (e.galliances and code-shares). This new air fare distribution system will foster even less competition between air carriers a nd thus negatively impactconsumers.

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Av. Providencia 2019, Of. 42B – Providencia, Chile – Teléfono 56-2-439 91 00 – Fax 56-2-439 91 18

Website: www.achet.cl – E-mail achet@achet.cl4.- The air fare distribution system that IATA plan s to implement – solely

oriented to its member’s interests – will negativel y impact the independent channel of distribution by demanding significant fi nancial investmentcost and bysetting conditions for system accesswith no g uaranteed access to full content or inventory that would allow the inde pendent channel (travel agencies and tour operators) to compete in fair co nditions; 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 cha nnel 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 operat ors thus creating a vulnerable situation both for the independent distr ibution channel and forthe consumer, especially in those markets with presence of dominant airlines.

7.-The aforementioned scenarios directly collide wi th actions currently enforced by organizations that protect fair open co mpetition 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. Furthe rmore, major airlines competing in a particular market might collude (col laborate) in the distribution of its product offer and air fares - r educing competition among each other- andhinder competitiveness in the market

.

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Av. Providencia 2019, Of. 42B – Providencia, Chile – Teléfono 56-2-439 91 00 – Fax 56-2-439 91 18

Website: www.achet.cl – E-mail achet@achet.cl8.-We thank DOT and the U.S Government the invitati on 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 an ti-trust practices. For this same reason, thisdocument will also be forward ed 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.

CHILEAN TRAVEL ASOCIATION

ACHET A.G.

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Av. Providencia 2019, Of. 42B – Providencia, Chile – Teléfono 56-2-439 91 00 – Fax 56-2-439 91 18

Website: www.achet.cl – E-mail achet@achet.cl