BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

AIR CHINA LIMITED d/b/a AIR CHINA 

for exemption authority pursuant to 49 

U.S.C. § 40109 

Docket DOT-OST-2013-0001 

ANSWER OF THE CITY OF HOUSTON 

AND THE GREATER HOUSTON PARTNERSHIP

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) 

Robert Harvey 

 President and Chief Executive Officer 

GREATER HOUSTON PARTNERSHIP 

1200 Smith Street, Suite 700 

Houston, TX 77002 

(713) 844-3600 

(713) 844-0200 (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: January 3, 2013 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

AIR CHINA LIMITED d/b/a AIR CHINA 

for exemption authority pursuant to 49 

U.S.C. § 40109 

Docket DOT-OST-2013-0001 

ANSWER OF THE CITY OF HOUSTON 

AND THE GREATER HOUSTON PARTNERSHIP

The City of Houston and the Greater Houston Partnership (collectively, “Houston” 

or the “Houston Parties”) respectfully submit this answer in support of the application of 

Air China for exemption authority to operate combination services between Houston and 

Beijing. The Houston Parties strongly support Air China’s application (as well as its 

forthcoming application for a corresponding amendment to its foreign air carrier permit), 

and urge that the exemption be granted promptly and expeditiously so that Air China 

can begin necessary preparations for the new flights, which it plans to commence in 

July of this year. 

Houston currently is the largest U.S. city without nonstop service to China – a 

factor that has impeded the ability of the City and Houston-based businesses to 

maximize trade and growth with one of the world’s most important economies. As noted 

in Air China’s application, Houston is a point open to services by Chinese carriers 

pursuant to the bilateral air transportation agreement between the U.S. and China. The 

establishment of scheduled nonstop service between Houston and Beijing would 
Answer of the City of Houston and 

the Greater Houston Partnership 

Page 2

represent a significant additional step in enhancing the City’s global transportation 

network and its future growth and prosperity. 

Despite the current lack of nonstop air services between Houston and China, the 

City and region have impressive trade links both with China in general and with Beijing 

in particular, with the Houston/Galveston Customs District ranking as China’s 10thlargest U.S. gateway for international trade. China is Houston’s overall fifth-largest 

trading partner by value, and October 2012 year-to-date data shows a 12% growth in 

trade between Houston and China over the same period in 2011. For 2011, the overall 

annual trade between Houston and China was valued at $11.9 billion, an increase of 

30.8% over 2010, and reflecting annual compound growth of 20.5% since the year 

2000. 

These figures include significant air trade with China, despite the lack of nonstop 

services. In 2011, Houston was China’s twelfth-largest U.S. gateway for airborne trade 

by value and weight; the airborne trade totaled 13.0 million kilograms, with a value of 

more than $882.9 million. Additionally, between 2005 and 2011, passenger traffic 

between Houston and China grew at an annual rate of 4.5%. The Houston Parties 

anticipate considerable stimulation of traffic once Air China’s proposed services are 

inaugurated, benefitting both the Houston economy and the U.S. economy as a whole. 

Additional data provided by the Greater Houston Partnership show that 840 

companies in Houston have business or trade connections with China; 51 firms with 

headquarters in Houston and 466 with branches in Houston operate a total of 2,734 

subsidiaries in China; and 11 Chinese and Hong Kong firms have subsidiaries in the 
Answer of the City of Houston and 

the Greater Houston Partnership 

Page 3

greater Houston area. China maintains its consulate for the southwestern region of the 

U.S. in Houston (one of 94 countries to do so – the third-largest consulate concentration 

in the U.S.), and local trade associations include the Asian Chamber of Commerce and 

the U.S.-China Federal Association of Business Councils. The city of Shenzhen is one 

of Houston’s international sister cities, and the city of Dalian is a sister port. 

Additionally, of Houston’s Asian-American population – the largest such community in 

Texas – 19% (or nearly 1 in 5) are Chinese-American. 

The relationships that Houston has forged with China despite the lack of nonstop 

air service also are consistent with Houston’s status as the premier international city of 

the southwest. Houston is the nation’s fourth-largest city, and the greater Houston 

region is the U.S.’s fifth-largest Metropolitan Statistical Area (“MSA”), with a population 

of 6.1 million. Houston has an unusually diverse economic base and a global reach. 

While energy remains a cornerstone of the economy (11 of the top 25 publicly-traded oil 

and gas firms are based in Houston), the metropolitan area also includes significant 

manufacturing facilities, especially in the aerospace and chemical industries; over 190 

life science companies; and more than 100 hospitals and health clinics, including the 

world’s largest medical facility, the Texas Medical Center. In total, twenty-five Fortune 

500 companies are based in greater Houston (the third-largest concentration in the 

U.S.). The Gross Regional Product of the greater Houston area was $442 billion in 

2011 and is estimated to be $475 billion for 2012; if it were a sovereign nation, the 

greater Houston area would rank as the world’s 26th largest economy. 
Answer of the City of Houston and 

the Greater Houston Partnership 

Page 4

Greater Houston also is a driving force in the U.S. economic recovery. It was the 

last major (defined as the 20 largest MSAs by population) metropolitan area to report 

job losses, and is a leader in job recovery; as of September 2012, it had recovered 

170% of lost jobs, and between 2010 and 2011 the metropolitan area’s economy grew 

by 2.35%. Key factors expected to fuel Houston’s future growth include the expansion 

of the Panama Canal, scheduled for completion in 2015. Conservative estimates 

anticipate that containerized cargo utilizing the Port of Houston will grow 10% annually 

as a result of the expansion, with Houston’s Asian trading partners the most likely 

source of growth. 

Houston and HAS long have been actively engaged in seeking China air service. 

Their commitment to the development of the market has included numerous airport-toairport and government-to-government contacts. For example, airport cooperation 

agreements have been signed between HAS and twelve major Chinese airports, 

specifically those in Beijing, Dalian, Hangzhou, Ningbo, Shandong, Shanghai, 

Shenyang, Shenzhen, Chengdu, Xi’an, Chongqing, and Liaoning. HAS also continues 

to provide educational programs to Chinese aviation officials, offering professional and 

executive development programs to Chinese airports, China’s Air Traffic Management 

Bureau, airlines, and governments (central, provincial, and municipal). Annually some 

150 officials from all over China attend these programs, including from nearly 70% of 

China’s civil aviation airports. Additionally, as the Department knows, Houston also has 

been a consistent supporter of U.S. efforts to liberalize the nation’s bilateral air 

transportation agreement with China. 
Answer of the City of Houston and 

the Greater Houston Partnership 

Page 5

Accordingly, the City, the Houston Airport System and its flagship airport, George 

Bush Intercontinental (IAH) are fully prepared to welcome and support Air China’s 

services. As the Department is aware, IAH is one of the nation’s premier international 

gateways, ranking as the seventh-largest international passenger gateway in the U.S. in 

2011, with more than 8.6 million international passengers. Traffic is strong and growing, 

with international passenger traffic at IAH showing an increase of 1.9% for the first 

eleven months of 2012 over the same period in 2011. IAH is the largest hub for the 

world’s largest airline, United Airlines – which is a Star Alliance partner of Air China. 

With more than 650 daily departures; service to more than 170 international and 

domestic destinations on a nonstop basis; and more than 40.1 million total passengers, 

IAH also was the seventh-largest airport in the U.S. for total passenger traffic in 2011. 

Thus IAH is an ideal gateway for China service, supplementing strong local demand 

with an extensive network of behind/beyond-Houston connections. 

Passengers and shippers utilizing Air China’s services to IAH also would enjoy 

the extensive benefits offered by one of the world’s key global gateways. The first 

“Model Port” and a leader in the Department of Homeland Security’s Global Entry 

Program, IAH offers state-of-the-art passenger arrivals processing and FIS facilities, 

world-class perishables cargo processing, and a Cargo Center capable of handling the 

world’s largest aircraft. IAH is always on the cutting edge of technology and 

infrastructure enhancements, and is a leader in implementation of NEXTGEN 

technology. HAS also has initiated capital improvement projects for IAH that will further 

enhance international and other airport facilities, boost the Houston economy, create 
Answer of the City of Houston and 

the Greater Houston Partnership 

Page 6

local construction jobs over a 7-10 year period, and enhance customer service, 

amenities and options for travelers and shippers. The groundbreaking for significant 

expansion and renovations to international terminal D is expected to occur in 2014. 

WHEREFORE, the Houston Parties urge the Department to promptly grant the 

pending exemption application of Air China, so that the latter may commence 

preparations to begin service in the Houston-Beijing market as soon as possible, and 

further grant the forthcoming application to make corresponding changes to Air China’s 

foreign air carrier permit. 

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: January 3, 2013 
CERTIFICATE OF SERVICE

I certify that on this 3rd day of January 2013, a copy of the foregoing was served 

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

Jol A. Silversmith 

George Tompkins, Jr. 

Counsel for Air China 

george.tompkinsjr@wilsonelser.com

Robert Wirick 

American Airlines 

robert.wirick@aa.com

Alexander Van Der Bellen 

Sametta C. Barnett 

Delta Air Lines 

Sascha.vanderbellen@delta.com

sametta.c.barnett@delta.com

Ranjit Seth 

Robert Foster 

Evergreen International Airlines 

ranjit.seth@evergreenairlines.com

robert.foster@evergreenairlines.com

G. Bailey Leopard 

Angeline Garbuzinski 

Federal Express Corporation 

gbleopard@fedex.com

anbird@fedex.com

Kevin Montgomery 

Peter Beckett 

Polar Air Cargo 

kevin.montgomery@polaraircargo.com

peter.beckett@polaraircargo.com

Dan Weiss 

United Airlines 

dan.weiss@united.com

Lorraine B. Halloway 

Gerald F. Murphy 

Counsel for United Airlines 

lhalloway@crowell.com

gmurphy@crowell.com

Anita Mosner 

Jennifer Nowak 

Counsel for United Parcel Service 

anita.mosner@hklaw.com

jennifer.nowak@hklaw.com

Howard Kass 

Benjamin Slocum 

US Airways 

howard.kass@usairways.com

benjamin.slocum@usairways.com

esta.rosenberg@dot.gov

barbara.hairston@dot.gov

john.allen@faa.gov

info@airlineinfo.com