BEFORE THE OFFICE OF THE SECRETARY U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON D

. C

.

________________________________ ___ _ _ ) 2012 C HICAGO - C ANCUN ) Docket DOT - OST - 2012 - 0001 COMBINATION S ERVICE P ROCEEDING )

_________________________________ ___ _ )

_____________________________________ ) Application s of ) ) AIRTRAN AIRWAYS, INC

. ) Docket DOT - OST - 2011 - 0225 ) FRONTIER AIRLINES , INC. ) Docket DOT - OST - 201 1 - 02 14 ) For an exemption pursuant to ) 49 U.S.C. § 40109 )

_____________________________________ )

REPLY OF AIRTRAN AIRWAYS, INC

. Communications with respect to this document should be sent to:

Bob Jordan Rob ert W. Kneisley President Associate General Counsel AIRTRAN AIRWAYS, INC. Leslie C. Abbott 9955 AirTran Boulevard Senior Attorney Orlando, FL 32827 SOUTHWEST AIRLINES CO. 1901 L Street, N.W. , Suite 640 Washington, D.C. 20036 bob.kneisley@wnco.com (202) 263

- 6284

J anuary 31 , 20121 BEFORE THE OFFICE OF THE SECRETARY U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON D

. C

.

__________________________________ ___ ) 2012 C HICAGO - CANCUN ) Docket DOT - OST - 2012 - 0001 COMBINATION SERVICE PROCEEDING )

_____________________________________ )

_________

____________________________ ) Application s of ) ) AIRTRAN AIRWAYS, INC

. ) Docket DOT - OST - 2011 - 0225 ) FRONTIER AIRLINES , INC. ) Docket DOT - OST - 201 1 - 02 14 ) For an exemption pursuant to ) 49 U.S.C. § 40109 )

___________________________________ _ _ )

REPLY O F AIRTRAN AIRWAYS, INC.

AirTran and Frontier 1 have already submitted five rounds of pleadings in this
carrier selection matter since last November. All relevant evidence is in the record and the case is ripe for decision. Confirmatio n of this fact is that Frontier’s January 26 Answer contains almost nothing new , but i nstead just re - hashes th e same specious arguments that Frontier advanced in its previous pleadings

. At this point t he record is
clear: AirTran/Southwest should be select ed as the carrier that will best meet the Department’s goal of “maximize[ing] public benefits” in the Chicago

– Cancun market. 2
The advantages of AirTran/Southwest ’s service proposal in this market are many and manifest :

1 Common names of carriers are used. 2 Order 2012

- 1

- 4, January 9, 2012, at p. 2.2

AirTran’s proposal for serving M DW

- CUN, as demonstrated by Southwest’s long history of service and consistent low fares at MDW , will provide far greater public benefits than Frontier . AirTran/Southwest will pressure the ORD carriers and discipline their pricing in a way that Frontier ca nnot . At the same time Southwest/AirTran will balance the a i r service to Chicago residents by offering service at MDW , hav ing the most beneficial impact on the structure of competition in the Chicago

- Cancun market

. Frontier, by contrast, wishes to be one of four carriers serving Cancun from ORD , ensuring no service at MDW. Under the circumstances, it is not surprising that Mayor Emanuel and many other Chicago leaders have expressed their strong support for AirTran/Southwest’s proposal

. Moreover, Frontier has a charter contract with Apple Vacations that will cover 88% of the seats it propose s to operate (Exhibit FL

- R

- 1) . Frontier nevertheless wants scheduled authority in this market , an outcome that would needlessly bar AirTran/Southwest

– and Midway Airport

– from competing

. Other than a fanciful hope for interline connecting passengers from its two direct competitors at ORD , there is nothing in Frontier’s f ive plead ings that suggest it could successfully market the 12% of seats that may or may not be committed to Apple. 3
AirTran/Southwest’s proposal , on the other hand, would not bar its competitor from participating in the CHI

- CUN market , as Frontier can fully car ry out the Apple contract via the almost unlimited charter provisions of the U.S.

- Mexico bilateral agreement. AirTran’s proposal is thus a “win

- win” for the Department and the public, yet another way in which AirTran/Southwest will maximize public benefit s in the CHI

CUN market.

AirTran/Southwest is between 40 and 110 times larger than Frontier in Chicago, depending upon the measure of size used (see Exhibit FL

- SR

- 1). With just a single MDW route, Frontier has only a miniscule presence in the Chicago mar ket and no

3 See AirTran’s January 26 Answer at pp. 2

- 6 and Exhibit FL

- R

- 1.3

traffic support at ORD. 4 By contrast, AirTran/Southwest has a 57

- route network at MDW. With no online or interline feed, a Frontier ORD

- CUN award would very likely end up just like the 20 of its 23 U.S.

- Mexico routes that Frontier has either
s uspended for long periods of time or totally abandoned

. Frontier promotes itself as a low

- fare alternative. However, it has made no mention of what its fares will be. This is because Apple will set the total package price for 88% of t h e seats that Fro ntier is proposing . Frontier will have no control over what the consumer pays for the air transportation portion of the tour package. W e do know that in head

- to

- head competitive markets at DEN, Southwest is lower

- priced in 18 of the 27 markets; and overa ll, its average price is 2.7% lower than Frontier (Exhibit FL

- R

- 12 ).
AirTran/Southwest is clearly the applicant that will maintain the best service to the public over time . Since 2003 Frontier has attempted service in 23 U.S.

- Mexico routes , but has pr ovided uninterrupted service in only three of those . It has abandoned 13 of its attempted Mexico routes , and been in and out of another 10 with inconsistent patterns of service. The three successful routes all have their own feed support at DEN , which Fro ntier obviously lacks in Chicago

. AirTran/Southwest expects to receive its Single Operating Certificate (SOC) by the end of the first quarter, and achieve full schedule integration later this year. Despite Frontier’s exaggerated rhetoric, t here is no r eal issue about connectivity. In terms of distribution, Southwest has h a d unparallel e d s u c c e s s i n r e a c h i n g c o n s u m e r s w i t h its
own i n d u s t r y l e a d i n g website , www.southwest.com . This has reduced its distribution costs and its dependency on expensive outside vendors. Nevertheless, it does distribute through GDS’s, but to a lesser degree than Frontier. And in this case, Frontier will not be distributing and booking reservations for at least 88% of its seat capacity , as Apple wi ll handle sales and reservations.

4 Fr ontier makes the irrelevant point that its single route to/from MDW produces more local passengers per departure than Southwest at MDW (Exhibit A

- 3)

. But this is the result of a carrier having no connecting passengers because it operates only one route. A irTran/ Southwest, on the other hand, will be able to carry both local and connecting passengers due to their large number of online connections at MDW.4

In terms of consumer ratings of airline services, AirTran and Southwest were ranked first and fifth respectively for overall quality , while Frontier placed ninth

. See AirTran’s January 26 Answer at pp. 13

- 15. The same AQR study revealed that Frontier’s consumer complaints per 100,000 passengers are five times the number for Southwest. The consumer appeal of scheduled service by AirTran/Southwest is orders of magnitude greater than Frontier ’s

. Moreover, few if any of F rontier’s for

sale passenger amenities may be available to Apple’s charter passengers. Apple Vacations will decide what is included, and what is not, in its bundled package price. Beyond these over

- arching points , AirTran will address the few new argu ments

r aised by Frontier in its January 26 Answer.

I. AIRTRAN/SOUTHWEST’S POTENTIAL CONNECTING TRAFFIC A T MDW IS UNDERSTATED

. In its January 19 Supplement , AirTran/Southwest showed that it would connect
21 on - line markets at MDW with less than 40% circui ty in support of Cancun service (Exhibit FL

- 107), even though the carrier serves a total of 57 nonstop routes at MDW (Exhibit FL

- 104). Limiting projected connections in this fashion was simply an effort to
be conservative in measuring AirTran/Southwest’s connecting potential . I n fact, Southwest today carries a large number of passengers in markets with greater than 40% circuity . Nevertheless , Frontier attacks AirTran /Southwest’s projected connections as “grossly overstated,” claiming that cities with cur rent nonstop service to Cancun should be excluded, leaving only seven behind gateway cities supporting MDW

- CUN service ( Frontier Answer at pp. 3

- 4 ). In fact, the opposite of Frontier’s c harge is true: AirTran/Southwest have
understated their connecting potential at MDW. Southwest carried over 1.4 million5

connecting passengers via MDW in markets that had nonstop service during the 12 months ended September 30, 2011 (Exhibit FL

- SR

- 4). These passengers traveled in 467 unique O&D markets via MDW despite h aving a nonstop alternative o n S o u t h w e s t

. For example, 15,000 passengers travelling between IAD and SAN connected at MDW despite the existence of nonstop service between IAD and SAN

. Therefore, Frontier’s argument that markets with current nonstop service to CUN sho uld be ex cluded from AirTran/Southwest’s connecting markets is belied by Southwest’s experience at MDW today. Moreover, 220 of the 467 markets noted above have circuity exceeding 40% when connecting at MDW compared to travelling nonstop . For example, 2, 582 passengers in the BUF

- MCO market connected at MDW despite circuity of 44 % compared to nonstop BUF

- MCO service

. Collectively the se 220 markets generated over 216,000 passengers. 5 All of this demonstrates that AirTran’s projection of connecting traffic at MDW was in fact very conservative since it did not include any markets with greater than 40% circuity.
Frontier ’s attack on AirTran/Southwest’s connecting potential is especially ironic coming from a carrier that has virtually zero connecting suppor t. Frontier would carry no online connecting passengers at ORD since it has no service at ORD , and instead
bases its entire claim of behind

- gateway support on interline connections from direct competitors at ORD. But as AirTran has already shown, Frontie r has no realistic hope of attracting such passengers except for the few that fall into Frontier’s lap as a result of

5 U.S. DOT Origin

- Destination Passenger Survey, YE Q3 2011. In fact, counting all Southwest MDW marke ts (not just those having nonstop alternatives), Southwest carried a total of 367,411 passengers who connected at MDW in markets with greater than 40% circuity ( Id .).6

flight cancellations or oversales by United or American. See AirTran Answer at pp. 4

- 5 and Exhibit FL

- R

- 2

. II. MDW IS PREFERRED BY HALF THE CH ICAGO MARKET , M A I N L Y A S A CONSEQUENCE OF SOUTHWEST’S LOW FARES

. As shown in AirTran Exhibits FL

- 11 7 , F L

- 11 8 and FL

- 11 9 , in markets where services are similar between the two Chicago airports, AirTran/Southwest originates as much traffic at MDW as the ORD carriers . This is in part because the geographical location of MDW is preferred by a large segment of the Chicago population, and in part
due to Southwest’s lower fares. As a further public benefit, Southwest has caused air fares to decline si gnificantly in head

- to

- head markets competitive with ORD. This “Southwest Effect” has been demonstrated in numerous exhibits that AirTran previously submitted to the Department. Nevertheless, Frontier persists in an ostrich

- like denial of reality in cla iming that the “Southwest Effect” at MDW is a “myth , ” and MDW fares do not discipline ORD fares (Frontier Answer at pp. 9

- 12)

. Beyond the voluminous material that AirTran has already submitted to establish MDW’s strong disciplining effect on ORD, 6 the att ached Exhibit
FL

- SR

- 3 presents additional compelling evidence 7

. That exhibit presents 12 pairs of
markets , each consisting of (1) a market served both by Southwest at MDW and carriers at ORD, and (2) a market of very similar nonstop distance that is serve d only at ORD and not by Southwest . In each of the 12 comparison s the average ORD fare is significantly lower in markets where Southwest competes at MDW vis

- à

- vis the markets that are not served by Southwest at MDW. In fact, the “fare premium” achieved i n the

6 See, e.g., AirTran’s January 19 Supplement at p. 7 and Exhibits FL

- 120,

- 121 and

- 122; and AirTran’s January 26 Answer at p. 7 and Exhibits FL

- R

- 3 through FL

- R

- 10

. 7 Based on current DOT O&D data (12 months ended September 30, 2011).7

12 ORD markets that do not face Southwest’s competition at MDW ranges as high as 106% for the SDF/DSM comparison (Exhibit FL

- SR

- 3 ). There can be no residual doubt that Southwest disciplines the fare structure at ORD, and that award of the Chicago

Ca ncun route to AirTran/Southwest will pressure UA and AA pricing far more than the
minimal service that Frontier might offer to the public outside of the Apple charter
program. In Exhibit A

- 4 Frontier attempts to show obliquely that MDW fares do not
disci pline ORD fares because the average fare differential is +15% in favor of ORD. Frontier supports this assertion by reference to a DOT observation that EWR does not discipline LGA fares. However, there are key structural differences between the New York/N ewark airports and Chicago . As shown in Exhibit FL

- SR

- 4 , a diffuse group of LCC’s provide only 12% of the seat capacity at EWR, and only 16% at LGA. However, in Chicago , LCC competition ( provided almost entirely by Southwest and AirTran ) is much stronger and more broadly available. LCC services are concentrated at MDW and LCC’s account for 29% of all domestic seat capacity in Chicago. Again, there is no
doubt that low

- fare services have permeated the entire Chicago landscape and caused fares to decline significantly at both ORD and MDW.
Frontier wants the Department to believe that fare discipline means fare equality. It doesn’t; AirTran has already explained why average fares are naturally higher at ORD for reasons having nothing to do with competiti on from MDW (AirTran Answer at pp. 7

- 9). But the disciplining effect of MDW is clear from the fact that ORD fares are materially lower in markets that are served by AirTran/Southwest from MDW . This fact
is incontrovertible

– both in Chicago and across th e AirTran/Southwest system.8

Frontier resorts to a 1998 case involving TWA, America West (HP) and several
other now - defunct carriers to support of its claim that MDW does not discipline ORD. The facts in that 14

- year old case are very different from the c ompetitive dynamics between MDW and ORD today, however. The primary issue facing DOT in that case was United’s argument that HP’s service at MDW adequately competed with UA at ORD so that it would be unnecessary to award HP slots at ORD. But as AirTran’s exhibits have shown, AirTran/Southwest have a far greater competitive impact in the Chicago market at MDW today than HP did with a minimal presence at MDW 14 years ago. In addition, in rejecting United’s argument, the Department stated that “there is no comparison in available connecting opportunities” between ORD and MDW. Today, with Southwest/AirTran’s 220 daily departures to 57 nonstop destinations from MDW, this is no longer the case. Midway is one of Southwest’s largest airports, and is known for i ts many convenient connections to dozens of destinations across the country. Finally, the Department’s 1998 decision was made in the very different context of a slot proceeding where a dominant legacy carrier was attempting to bar slots from being
awarded to a new entrant carrier. Here, of course, no slots are involved, and under AirTran’s proposal neither applicant will be barred from competing in the CHI

- CUN
market.

III. AIRTRAN/SOUTHWEST IS THE LOW - FARE APPLICANT I N T H I S PROCEEDING , NOT FRONTIER

. Throu ghout all the pleadings during f ive rounds of exchange in this case, Frontier repeatedly describes itself as the low

- fare carrier and United and American as the high

fare incumbents. Yet, nowhere in this case has Frontier disclosed what its fare or price9

to the public will be. Nowhere has it compared its proposed fare to that of UA and AA in the Chicago

- Cancun market. Nowhere has Frontier told the Department what Apple’s bundled tour package prices will be and what portion of the bundled price is represe nted by Frontier’s air transportation service. Its claim to be the low

- fare alternative is therefore nothing but a hollow allegation with no evidentiary support

. AirTran has compared the prices actually charged to consumers 8 by AirTran/Southwest versus Frontier at I T S Denver hub, as shown in Exhibit FL

- R

- 12. In the 27 nonstop DEN markets where both carriers compete head

- to

- head, AirTran/Southwest’s average price is lower in 18 markets, and its weighted average price over all 27 markets is 2.7% lower tha n Frontier. Frontier’s January 26 Answer (at p. 12) makes erroneous fare comparisons for Southwest. It improperly relates Southwest fares from Exhibits FL

- 120 and FL

- 121 , ( based on a data source that exclude s all ticket taxes, segment fees and PFC’s ) , to Southwest fares in the same markets using a different data source which includes all taxes and fees. 9 This comparison greatly overstates the true amount of Southwest’s fare increase, which was in line with an industry

- wide response to rapidly rising fuel costs in any event. Finally, for at least 88% of its seat capacity proposed in this case Frontier will have no say whatsoever as to what price the passenger will pay. That will be determined unilaterally by Apple Vacations (Exhibit FL

- R

- 1). For the rema ining 14,784 seats that Frontier might market directly to the public in competition with its alleged

8 Price to the customer includes base air fare plus average checked baggage and reservation change fees. 9 Ai rTran’s exhibits are sourced from the DOT Origin

- Destination Survey accessed by a provider that excludes government taxes and fees from the fare data. Frontier’s comparison is based on the DOT Domestic Airline Fares Consumer Report, which includes governm ent taxes and fees.10

interline partners (United and American), there is no indication in the record what its fares might be if it operates those off

- season filler flights at al l.

IV. AN AWARD TO FRONTIER WOULD BE ESPECIALLY RISKY GIVEN ITS ABYSMAL TRACK RECORD IN SERVING MEXICO , ESPECIALLY FROM MARKETS OTHER THAN DEN

. Frontier’s Answer makes several references to the DOT’s stated carrier selection criteria, but ignores any menti on of one of the most important factors in this case , namely “which applicant will be most likely to offer and maintain the best service for the traveling and shipping public.” 10 AirTran/Southwest addressed this issue in its January 19 Supplement. In Exhi bit FL

- 115 AirTran/Southwest presented Frontier’s extremely checkered history in serving 26 different U.S.

- Mexico routes since 2003. Exhibit FL

- 115 shows that of the 26 markets attempted by Frontier, it has completely abandoned 13 of
them and has interrup ted service in another 10 markets. Frontier has maintained
continuous service in o nly three of the se 26 Mexico routes, and all three are hub

supported routes from Denver to Mexico. Frontier’s Answer takes no issue with the accuracy of the data portrayed i n Exhibit FL

- 115. It simply states that the 10 routes designated in Exhibit FL

- 115 as interrupted service are in fact “scheduled seasonal routes.” But t his attempted justification does not wash

. A closer examination of the se 10 routes ( depicted by
dashe d blue lines in Exhibit FL

- 115 ) tells a different story. As shown in Exhibit FL

- SR

- 4 , five of the 10 routes in question had service interruptions for 12 or more consecutive
months . In the cases of MCI

- SJD, MKE

- CUN and DEN

- ZIH, Frontier abandoned those

ma rkets for almost three years . In the case of the five other routes, the periods of

10 Order 2012

- 1

- 4, at p

. 2 (emphasis added).11

service suspension differed from year to year in spite of the fact that sunspot leisure
vacation markets typically have stable seasonality pattern s . This is especially tru e for fixed points of origin, like Denver or Chicago. Just as Frontier took no issue with the accuracy of the data presented in Exhibit
FL

- 115, AirTran/Southwest has no quarrel with the accuracy of the data shown in Frontier’s Exhibit A

- 6 , which presents AirTran’s unblemished and uninterrupted record of service to Mexico. It is useful for the Department to compare the two U.S.

- Mexico
service histories side

- by

- side , and AirTran has done this in Exhibit FL

- SR

- 6 . Even a cursory examination of this e xhibit demonstrates that the applicant “ most likely to offer
and maintain the best service for the travelling public” is AirTran/Southwest.

CONCLUSION
F or the reasons stated above and in its prior submissions, AirTran r equests that the Department act as soon a s possible to grant its A pplication for E xemption and designate AirTran to provide scheduled foreign air transportation of persons, property
and mail between Chicago Midway Airport and Cancun

.

Respectfully submitted,

_________________ _____ Robert W. Kneisley

January 31 , 201212 CERTIFICATE OF SERVI CE I hereby certify that on January 31, 2012, a copy of the foregoing was served via e - mail on the following persons:

robert.cohn@ho ganlovells.com (Frontier Airlines) patrick.rizzi@hoganlovells.com (Frontier Airlines susan.kurland@dot.gov paul.gretch@ dot.gov brian.hedberg@dot.gov brett.kruger@dot.gov todd.homan@dot.gov esta.rosenberg @dot.gov john.allen@faa.gov ursk@dos.gov Rosemarie S. Andolino Commissioner City of Chicago Department of Aviation r osemarie.sandolino@cityofchicago.org Erin O’Donnell Managing Deputy Commissioner City of Chicago Department of Aviation, Midway Airport Erin@cityofchicago.org

__________________________ Leslie C. Abbott

## Southwest/ AirTran’s Far Larger Presence In Chicago Than Frontier Will Strongly Support Cancun Service

Source: U.S. DOT Origin & Destination Survey & U.S. DOT T

- 100 Onboard data, YE Q3 2011. OAG Schedules for March 2012. Docket DOT - OST - 2012 - 0001 Exhibit FL - SR - 1

1,689

17 0 200 400 600 800 1,000 1,200 1,400 1,600 1,800

Southwest/AirTran Frontier 228,588

2,058 0 50,000 100,000 150,000 200,000 250,000

Southwest/AirTran 57

1 0 10 20 30 40 50 60

Southwest/AirTran Frontier Annual Passenger O&D (000) Annual Onboard Passengers (000)

Weekly Aircraft Departures Weekly Seat - Departures Destinations 17,682

301 301 9,858

## Southwest Carried Over 1.4 Million Connecting Passengers

Via MDW In 467 O&D Markets With A Nonstop Alternative

WN Connections via MDW in Markets with Nonstop Service Markets 467 WN Passengers 1,421,549

Note: Nonstop service defined as 5 or more weekly roundtrip departures. Source: U.S. DOT, Origin

- Destination Passenger Survey, and Official Airline Guide, YE Q3 2011. Docket DOT - OST - 2012 - 0001 Exhibit FL - SR - 2

## The Southwest Effect Is Alive and Well:

ORD Fares Are Significantly Lower I n Markets Where Southwest Competes at MDW
Current (YE Q3 2011) Average ORD Fare

ORD Market STL CVG SDF DSM CLE LEX MSP CAK BNA SGF LIT ROA RDU ABE ORF HPN BDL BTV BOS PWM RSW SRQ TUS BOI Distance (miles) 258 265 286 299 316 323 334 344 409 438 552 531 647 654 717 738 783 763 867 900 1120 1035 1437 1437 % No WN MDW Higher 98% 106% 89% 82% 79% 36% 59% 40% 33% 68% 26% 42% Note: Includes Fared passengers only. Source : DOT, Origin

- Destination Passenger Survey YE Q3 2011. ORD Fare When WN Offers MDW Nonstop Service ORD Fare When No WN MDW Nonstop Service Docket DOT - OST - 2012 - 0001

Exhibit FL - SR - 3

## Newark and LaGuardia Have Far Less LCC Competition Than Chicago
Weekly Seat Departures

Note: Includes only domestic routes Source: Official Airline Guide Schedules for the week of March 12

- 18, 2012. Legacy Seats LCC Seats

287,075 320,097 906,119

12%

88% 16%

84% 29%

71% Docket DOT - OST - 2012 - 0001

Exhibit FL - SR - 4

EWR
253
34 269

51 LGA Chicago

644
262 Seats (000)

Total Seats 287 320 906Source: US DOT T

- 100 Data, OAG Schedules.



## Frontier Has Been Absent For More Than 12 Consecutive Months in

Five of Its 10 So - Called “Seasonal” Mexico Routes “Seasonal” Service with Suspensions Longer than 12 Consecutive Months

Period of Service Suspension Service Period

Service Suspended Longer than 1 2 Consecutive Months DEN

- ZIH

STL

- CUN

IND

- CUN

MCI

- SJD

MKE

- CUN Docket DOT - OST - 2012 - 0001

Exhibit FL - SR - 5



## 34 Months



## 20 Months

19 Months

34 Months

34 MonthsSource: Exhibit FL

- 115 and Frontier Airlines’ Exhibit A

- 6. 

## AirTran is the Applicant “Most Likely To Offer and Maintain the Best Service”

AirTran’s Unblemished Record of Serving Mexico

DEN

- MZT DEN

- CUN DEN

- SJD DEN

- PVR DEN

- ZIH SLC

- CUN MCI

- CUN AUS

- CUN BNA

- CUN STL

- CUN MCI

- PVR DEN

- CZM DEN

- ACA IND

- CUN SAN

- CUN MCI

- SJD LAX

- SJD DEN

- GDL SMF

- SJD SJC

- SJD DFW

- MZT SMF

- PVR SJC

- PVR MKE

- CUN ABQ

- PVR STL

- PVR Frontier’s “Proven Track Record” of Serving Mexico Jan 2003 Jan 2004 Jan 2005 Jan 2006 Jan 2007 Jan 2008 Jan 2009 Jan 2010 Jan 2011 Jan 2012 Dec 2012 May 2011 Sep 2009 Jan 2008 May 2006 Sep 2004 Jan 2003 Docket DOT - OST - 2012 - 0001 Exhibit FL - SR - 6

ATLCUN

BWICUN

MKECUN

SNASJD

SNAMEX

SATMEX

SATCUN