Pje. Antonio Roca No121 E-mail: presidencia@apavitperu.org

Urb. Santa Beatriz, Lima 1 Perú Web. www.apavitperu.org

Telf.: (511) 433-1111 Fax: (511) 433-7610

ASOCIACIÓN PERUANA DE AGENCIAS DE VIAJES Y TURISMO

FUNDADA EL 27 DE MAYO DE 1947

 

April, 29, 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 

impact consumers.
Pje. Antonio Roca No121 E-mail: presidencia@apavitperu.org

Urb. Santa Beatriz, Lima 1 Perú Web. www.apavitperu.org

Telf.: (511) 433-1111 Fax: (511) 433-7610

ASOCIACIÓN PERUANA DE AGENCIAS DE VIAJES Y TURISMO

FUNDADA EL 27 DE MAYO DE 1947

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 investment cost 

and bysetting conditions for system access with 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 for

the 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 channel and 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 other- and hinder competitiveness in the market.
Pje. Antonio Roca No121 E-mail: presidencia@apavitperu.org

Urb. Santa Beatriz, Lima 1 Perú Web. www.apavitperu.org

Telf.: (511) 433-1111 Fax: (511) 433-7610

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 protect their consumer citizens against anti-trust practices. For 

this same reason, this document 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.