Travel Agencies and Tour Operator group from Latin America.

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 arena. 

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 countries 

where theForoSudamericano de Agenciasde Viajes y Touroperadoresis represented. 

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. 

The present document is subscribe.

Asociación Argentina de Agencias de Viajes y Turismo - AAAVYT 

Asociación Boliviana de Agencias de Viajes y Turismo - ABAVYT 

Asociación Brasilera de Agencias de Viajes y Turismo - ABAV 

Asociación Chilena de Empresas de Turismo - ACHET 

Asociación Colombiana de Agencias de Viajes - ANATO 

Asociación Ecuatoriana de Agencias de Viajes y Turismo - ASECUT 

Asociación Paraguaya de Agencias de Viajes y Empresas de Turismo – ASATUR 

Asociación Peruana de Agencias de Viajes y Turismo - APAVITPERÚ 

Asociación Uruguaya de Agencias de Viajes - AUDAVI 

Asociación Venezolana de Agencias de Viajes y Turismo - AVAVIT