Travel Agencies and Tour Operator group from Latin America.

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

1.-The air fare distribution model currently in pla ce is a system that is independent of airlines and distribution channels, namely travel agencies a nd tour operators . It is operated by companies referred to as GDS’s that rigorously comp ly with information transparency and guarantee, among others, ample and free global acce ss to content/fares 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 actors: major airlines (most o f them for-profit privately held companies) associated to IATA, meaning that the transparency p rinciple 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 marke ts have become more concentrated as a result of privatizations, mergers, acquisitions and commer cial 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 a nd thus negatively impactconsumers.

4.- The air fare distribution system that IATA plan s to implement – solely oriented to its member’s interests – will negatively impact the ind ependent channel of distribution by demanding significant financial investmentcost and bysetting conditions for system accesswith no guaranteed access to full content or inventory t hat 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 th eir participation in the distribution arena

.

5.-Not having an indirect and independent sales cha nnel like travel agencies and tour operator would highly reduce contestability in the air trans port 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 consume r, 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 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 com petitive air transport marketplace. Furthermore, major airlines competing in a particul ar market might (collude) (collaborate) inthe 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 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 anti-trust practices. F or this same reason, thisdocument will also be forwarded by us to pertinent anti-trust government organizations advocating in countries

where the ForoSudamericano de Agenciasde Viajes y Touroperado res is represented.

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

The present document is subscribe. Asociación Argentina de Agencias de Viajes y Turism o - AAAVYT Asociación Boliviana de Agencias de Viajes y Turism o - ABAVYT Asociación Brasilera de Agencias de Viajes y Turism o - ABAV Asociación Chilena de Empresas de Turismo - ACHET Asociación Colombiana de Agencias de Viajes - ANATO Asociación Ecuatoriana de Agencias de Viajes y Turi smo - ASECUT Asociación Paraguaya de Agencias de Viajes y Empres as 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 Turis mo - AVAVIT