A GLOBAL AND LEGAL OVERVIEW OF TRAVEL AGENT REPRESENTATIVES 577 “Travel agents and companies Twenty-eight travel agencies and related tour and travel associations filed responses with twenty-six opposing Resolution 787. They argue that the Resolution would eliminate the role of travel agents, which would reduce competition between air carriers and have a negative impact on the consumer. They further argue that the Resolution discriminates against independent sales and distribution channels. ASATUR Paraguay argues that, by taking out the independent players, Resolution 787 allows for invested parties (airlines) to potentially discriminate through the distribution channels. The Bolivian Agents Tour and Travel Association points out the anti-competitive risk of airlines collaborating in the distribution of offers and fares. The Asociacion Ecuatoriana de Agencias de Viajes (ASECUT) also notes that the elimination of the independent sales channel would reduce contestability in the air transport market, thereby creating barriers for new actors. BCD Travel argues that IATA’s proposal would create a new business model. Opponents note the privacy concerns raised under Resolution 787 through the use of personal identifiable information with its potential impact on consumer fare transparency. ARCTEC Alaska also refers to the potential risk of identity theft associated with storing personal information online. (...) Opponents also point out the Resolution’s incompatibility with the current distribution model, which would create problems in distributing interline tickets or code-share tickets with a mix of airlines participating in a new system based on the proposed standard and non-participatory airlines. European Travel Agents’ and Tour Operators’ Associations (ECTAA) and Guild of European Business Travel Agents (GEBTA) also assert incompatibility with provisions of EU Law. (...) The American Antitrust Institute (AAI) filed an answer opposing the Resolution.9 AAI sees NDC as an agreement of the 11 large airlines in the PDG of IATA to impose new distribution standards on the entire airline industry. AAI argues that if IATA was only attempting to develop a new technical standard for sharing information, then it would not need DOT approval, and that the way IATA crafted the application indicates that it is seeking DOT approval for a new business standard. AAI alleges that the NDC could lessen competition head-to- -head between airlines and other market participants in airfare distribution. AAI does not believe that Resolution 787 was adopted in an open process, noting that the PDG developed NDC and the resolution for nearly a year before allowing other stakeholder participation. AAI argues that this standardization of a distribution agreement between rivals is an “agreement on the rules of competition,”
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