Negative NDC Comments Flooded DOT as Deadline Neared

As the May 1 deadline approached for filing comments on IATA’s request for Transportation Department approval of Resolution 787, the DOT was flooded with submissions from travel companies and organizations expressing outright opposition or doubts about IATA’s plans.

Most of the comments in support of the resolution were submitted fairly soon after IATA’s request was made. Those expressions of support came primarily from airlines, airline associations, ARC and ATPCO.

Controversy over NDC
Resolution 787, adopted by IATA last October, lays the foundation and the vision for a New Distribution Capability, a set of technical standards that would apply to airlines that want to distribute their merchandising efforts and ancillary products through third-party channels.

NDC has stirred up a great deal of controversy, on the one hand because it is not easily understood and on the other because IATA’s message has shifted somewhat over time.

Ambiguous language
That was illustrated by Carlson Wagonlit Travel’s response, which stated that “CWT reviewed IATA’s application and attempted to assess the impact that Resolution 787 would have on its clients if adopted. In CWT’s opinion, the application’s lack of clarity and detail made such a determination exceedingly difficult.”

CWT’s major concerns center on whether NDC will end comparison shopping and anonymous shopping. IATA has denied that its intention is to end either, but the ambiguous language of Resolution 787 has left many questions open.

“CWT would consider participating in any industry initiative that represents the full, best interests of our clients while also benefiting our valued airline and technology partners,” the TMC said in its comments. “However, at this time, we do not have sufficient information to determine whether IATA’s Resolution 787 is that solution.”

It urged the DOT to require IATA to provide more information as part of their application.

Amadeus takes nuanced approach
While Amadeus is a member of at least two organizations that oppose the resolution – the Open Allies for Airfare Transparency and the Travel Technology Association – it took a more nuanced approach to the issue in a separate filing.

“Amadeus has expressed, in general, its support for the stated objectives of NDC, such as improving airlines’ ability to differentiate and merchandise their offer,” it said in its comments.

“It also is supportive of attempts to standardize processes,” it said. “Indeed, Amadeus has shared its own XML schema with IATA and is increasingly involved in the [Direct Data Exchange] working group.”

But Amadeus also said it sees “several challenges” in the NDC project, and it made several recommendations on how IATA should alter Resolution 787: The resolution should be entirely non-binding and voluntary; references discouraging backward compatibility should be removed and provisions to enable content comparison should be included; references to content ownership should be removed, and privacy issues should be clarified.

Amadeus also said it “believes that it is not necessary for the selection or characteristics of a standard that it be embodied in a mandatory IATA resolution that binds most of the world’s airlines.”

Nor does it believe that the DOT should “appear to give its approval to one standard over another. Any IATA agreement on technical XML standards should at most be reflected in a recommended practice and not a binding resolution approved by the Department. Amadeus believes that the market should continue to govern the development of standards here.”

IATA anointed the XML schema developed by Farelogix, which donated it to Open AXIS, which in turn sold it to ATPCO for a nominal sum, as the standard for NDC. GDS companies and many of the world’s airlines use the XML schema developed by OpenTravel Alliance.

ASTA opposes approval
Meanwhile, ASTA, whose official stance has been neutral until now, in the end recommended that the DOT withhold approval of the resolution.

IATA’s documentation “gives the appearance of an unprecedented agreement among horizontal airline competitors on a new business model for the pricing and selling of airline tickets,” ASTA said.

In addition, “NDC also appears to have been designed for the purpose of defeating the fare transparency that the airlines and IATA have publicly confirmed has constrained their ability to raise the prices consumers pay.”

ASTA also joined the call for clarity on the consumer privacy issue.”

Sabre’s confidential filing
Sabre filed a confidential version of its comments under seal, subject to a motion for confidential treatment, because some of its comments refer to its future technology plans.

In a redacted version made available to the public, Sabre said IATA’s assertion that new technical standards are needed because GDSs will not otherwise be able to support efforts by airlines to highlight their amenities and services and to make “personalized” offers to consumers is not true.  

Sabre said it is “committed to and fully capable of enabling airlines to effectively and efficiently merchandise their products, including personalized offers.”

It said that it has, since 2010, the capability of displaying the full price of travel, including the costs of various ancillary services such as baggage, priority boarding and pre-reserved seat charges in its multi-carrier shopping results.

“This facility is fully operational and enables airlines to merchandize these ancillary services through all of Sabre’s tens of thousands of subscribers,” it said. “Unfortunately, airlines have largely chosen not to avail themselves of this opportunity to merchandize their special services and features even though Sabre built this facility in accordance with the specifications dictated by airline-owned ATPCO and even though Sabre has said it will not charge airlines anything extra to utilize this merchandizing capability. In a nutshell, we have the merchandizing shelves; we just need the carriers to allow us to stock them.”

Sabre also said it enables airline personalized offers on an opt-in basis using frequent traveler numbers, in contrast to NDC’s mandatory provision — at the request of any carrier — of personal information and competitively sensitive information about status on and purchases from other airlines.