BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Joint Application of 

UNITED AIRLINES, INC. and 

SKYWEST AIRLINES, INC. 

for an exemption pursuant to 49 U.S.C. § 40109 

and designations (Houston-Leon/Guanajuato, 

Mexico) 

Docket DOT-OST-2014-0058 

Docket DOT-OST-2014-0059

REPLY OF THE CITY OF HOUSTON 

Communications with respect to this document should be sent to:

Mario C. Diaz 

 Director 

Ian Wadsworth 

 Chief Commercial Officer 

Department of Aviation 

CITY OF HOUSTON 

16930 John F. Kennedy Blvd. 

Houston, TX 77032 

(281) 233-3000 

(281) 233-1859 (fax) 

Rachel B. Trinder 

Jol A. Silversmith 

ZUCKERT, SCOUTT & 

 RASENBERGER, L.L.P. 

888 Seventeenth Street, N.W. 

Washington, D.C. 20006-3309 

(202) 973-7927 

(202) 342-0683 (fax) 

rbtrinder@zsrlaw.com

jasilversmith@zsrlaw.com

For the City of Houston 

 and the Greater Houston Partnership 

Dated: May 12, 2014 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Joint Application of 

UNITED AIRLINES, INC. and 

SKYWEST AIRLINES, INC. 

for an exemption pursuant to 49 U.S.C. § 40109 

and designations (Houston-Leon/Guanajuato, 

Mexico) 

Docket DOT-OST-2014-0058 

Docket DOT-OST-2014-0059

REPLY OF THE CITY OF HOUSTON 

The City of Houston (Houston or the City) respectfully submits this reply to the 

joint application filed on April 18, 2014 by United Airlines, Inc. (United) and SkyWest 

Airlines, Inc. (SkyWest) (together, the United carriers), and the answer filed by 

Southwest Airlines Co. (Southwest) on May 5, 2014, concerning the exemption authority 

requested by the United carriers – which includes a U.S.-Mexico operating carrier 

designation for SkyWest on the Houston-Leon/Guanajuato, Mexico route, and a 

marketing carrier designation for United to permit United to display its “UA” designator 

code on SkyWest’s flights on that route. 

Houston is extremely fortunate to be the largest U.S.-Mexico air transportation 

gateway, with flights to more than 25 destinations in Mexico. Its success in this regard 

reflects many factors, including the City’s geographical location and its status as a world 

class international community, with extensive global trade ties. Notably, in 2013 Mexico 

was Houston’s largest overall foreign business partner; the value of the trade was more 

than $28 billion. 
Reply of the City of Houston 

Page 2

With one of the strongest regional economies in the U.S. and a fast growing 

population, Houston is experiencing rising demand for global air service. To 

accommodate this growth, multiple airport expansion and development projects are 

underway at both George Bush Intercontinental (IAH) and William P. Hobby (HOU or 

Hobby) airports. Houston’s two principal carriers, United and Southwest, have made 

significant facilities funding commitments in partnership with the City. At IAH, a new 

concourse at Terminal B was recently opened and a new 15 gate international terminal 

is being planned. At Hobby, a new international terminal will open in 2015, which will 

support additional service to Mexico, the Caribbean and northern South America. 

An essential factor in Houston’s ability to attract extensive air service from both 

U.S. and foreign carriers has been the U.S. Government’s success in expanding the 

route opportunities available for international service through Open Skies agreements. 

As of now, however, open opportunities do not yet exist for air services between the 

U.S. and Mexico; the applicable bilateral not only severely limits the number of carrier 

designations available in each city-pair (to as few as two per nation in many cases), but 

also requires that an operating carrier (which does not itself hold out services in its own 

name) obtain a separate designation even when its mainline carrier already holds one 

for the same city-pair. This severely limits competition in many key U.S.-Mexico 

markets, as well as the operational flexibility of carriers. 

The City is aware that U.S. negotiations with Mexico are scheduled for the end of 

May, and Houston is extremely hopeful that the talks will produce at least a very broad 

liberalization of the agreement that will remove the designation limits and operating 

carrier designation requirements currently applicable. If agreement on a sufficiently 
Reply of the City of Houston 

Page 3

liberalized U.S.-Mexico bilateral is reached, then grant of requests such as that of the 

United carriers will become entirely routine and will not impact the opportunities 

remaining for other carriers wishing to serve the same city-pair. However, without such 

a liberalized agreement, carriers such as Southwest may have no option but to seek the 

designations held by other airlines where those carriers (combined with the latter’s 

operating carriers) hold more than one designation in limited entry U.S-Mexico markets. 

Houston is very much aware that the U.S. Government has diligently sought 

bilateral liberalization with Mexico over many years, and hopes that the current 

Government of Mexico will come to the negotiating table ready to achieve significant 

liberalization within a very short time frame. Houston hopes that this matter can be 

resolved within the next few months so that both the United carriers and Southwest 

have available to them all the designations they need to meet traffic demand. 

Insofar as the current application is concerned, the City welcomes the 

commitment of the United carriers to their Houston-Mexico services as well as 

Southwest’s plans for new international services starting in 2015. Additionally, because 

Houston understands that Southwest does not oppose the application that is pending in 

these dockets and simply asks that the Department reaffirm guidance previously set 

forth regarding making designations available to ensure competition among carriers, 

Houston respectfully supports Southwest’s request. It is important that airlines, the City, 

and the industry as a whole have the benefit of that guidance for future planning 

purposes. The confirmation sought in this case by Southwest is of a well-established 

policy, and should not be controversial. 
Reply of the City of Houston 

Page 4

Respectfully submitted, 

Rachel B. Trinder 

Jol A. Silversmith 

ZUCKERT, SCOUTT & 

 RASENBERGER, L.L.P. 

888 Seventeenth Street, N.W. 

Washington, D.C. 20006-3309 

(202) 973-7927 

(202) 342-0683 (fax) 

rbtrinder@zsrlaw.com

jasilversmith@zsrlaw.com

For the City of Houston 

 and the Greater Houston Partnership 

Dated: May 12, 2014 
CERTIFICATE OF SERVICE 

I certify that on this 12th day of May 2014, a copy of the foregoing was served on 

the parties named below in accordance with the Department’s Rules of Practice. 

 

Jol A. Silversmith 

msinick@ssd.com

(Counsel for Alaska Airlines) 

robert.wirick@aa.com, 

benjamin.slocum@aa.com, 

francis.heil@aa.com, and 

howard.kass@aa.com

(American Airlines) 

sascha.vanderbellen@delta.com and 

sametta.c.barnett@delta.com

(Delta Airlines) 

jhill@cooley.com and 

perkmann@cooley.com

(Counsel for JetBlue Airways) 

matwood@cozen.com

(Counsel for Kalitta Air) 

robert.cohn@hoganlovells.com and 

patrick.rizzi@hoganlovells.com

(Republic Airlines) 

temerson@skywest.com

(SkyWest Airlines) 

bob.kneisley@wnco.com and 

leslie.abbott@wnco.com

(Southwest Airlines) 

dkirstein@yklaw.com and 

jyoung@yklaw.com

(Counsel for Spirit Airlines) 

john.frederickson@suncountry.com

(Sun Country) 

hershel.kamen@united.com, 

dan.weiss@united.com, 

steve.morrissey@united.com, 

karine.faden@united.com, 

thomas.bolling@united.com, and 

abby.bried@united.com

(United Airlines) 

sseiden@crowell.com and 

gmurphy@crowell.com

(Counsel for United Airlines) 

anita.mosner@hklaw.com and 

jennifer.nowak@hklaw.com

(Counsel for UPS) 

dsmalls@ups.com

(UPS) 

john.varley@virginamerica.com and 

barbara.russell@virginamerica.com

(Virgin America) 

paul.gretch@dot.gov, 

brian.hedberg@dot.gov, 

brett.kruger@dot.gov, and 

reese.davidson@dot.gov

(DOT) 

john.s.duncan@faa.gov

(FAA) 

ronald.williams@ustranscom.mil 

(USTRANSCOM) 

urskr@state.gov 

(State Department) 

pmurphy@lopmurphy.com

info@airlineinfo.com