BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

___________________________________________

Joint Application of )

)

 AMERICAN AIRLINES, INC. ) 

 US AIRWAYS, INC. )

 AMERICAN EAGLE AIRLINES, INC. )

 PSA AIRLINES, INC. ) Docket DOT-OST-2013-____

 PIEDMONT AIRLINES, INC. )

 )

for approval of the transfer of international route )

authorities pursuant to 49 U.S.C. § 41105 )

___________________________________________)

JOINT APPLICATION OF AMERICAN AIRLINES, INC., US AIRWAYS, INC., 

AMERICAN EAGLE AIRLINES, INC., PSA AIRLINES, INC., AND PIEDMONT 

AIRLINES, INC. FOR APPROVAL OF THE TRANSFER OF INTERNATIONAL ROUTE

AUTHORITIES 

Communications with respect to this document should be sent to:
 

Stephen L. Johnson Virasb Vahidi

Executive Vice President, Senior Vice President – Marketing and

 Corporate and Government Affairs Planning and Chief Commercial Officer

US Airways, Inc. American Airlines, Inc.

111 West Rio Salado Parkway P.O. Box 619616, MD 5634

Tempe, AZ 85281 DFW Airport, Texas 75261

 

Howard Kass William K. Ris, Jr.

Vice President, Legal and Senior Vice President – Government 

 Government Affairs and Regulatory Affairs

American Airlines, Inc.

Benjamin T. Slocum 1101 17th Street, NW

Director, Legal and Washington, DC 20036

 Government Affairs

Robert A. Wirick

US Airways, Inc. Managing Director, Regulatory and

1401 H Street, NW, Suite 1075 International Affairs

Washington, DC 20005 American Airlines, Inc.

(202) 326-5153 P.O. Box 619616, MD 5434

howard.kass@usairways.com DFW Airport, Texas 75161

benjamin.slocum@usairways.com robert.wirick@aa.com

Francis C. Heil

Senior Attorney

American Airlines, Inc.

1101 17th Street, NW

Washington, DC 20036

francis.heil@aa.com

NOTICE: The Joint Applicants request that this Joint Application be processed 

pursuant to the expedited non-hearing procedures in Subpart B of the 

Department’s Procedural Regulations. Any person who wishes to support 

or oppose this application must file an answer by May 8, 2013, and must 

serve that answer on the Joint Applicants and all persons served with this 

Joint Application.

April 17, 2013
 

TABLE OF CONTENTS

Overview.............................................................................................2

Introduction.........................................................................................3

I. EXECUTIVE SUMMARY.........................................................................7

II. THE JOINT APPLICANTS.....................................................................12

III. THE AA-US AIRWAYS ROUTE TRANSFER MEETS THE STATUTORY 

CRITERIA AND DEPARTMENT PRECEDENT FOR APPROVAL.................14

A. Applicable Statutory Standards and Policy Objectives.........................14

B. The Proposed Route Transfer Is In the Public Interest Because 

It Will Produce Substantial and Important Public Benefits.....................15

1. Public Benefits from New American Are Based on the Combination 

of US Airways’ and AA’s Complementary Route Structures and 

Aircraft Fleets....................................................................15

a. New American Combines Complementary International 

Route Networks Without Any Overlapping Nonstop 

Routes....................................................................16

b. New American’s Comprehensive Fleet Mix Will Allow Far 

Greater Scheduling Flexibility.......................................18

2. Enhanced Global Network Competition from New American Is a 

Significant Public Benefit......................................................21

3. The Route Transfer Will Enhance Trans-Pacific Competition 

Creating Additional Public Benefits.........................................25

4. The Route Transfer Will Significantly Benefit Consumers by Giving 

Them Increased Connectivity and More Options for Travel Between 

the United States and Central and South America.....................26

5. The Route Transfer Will Enhance Trans-Atlantic Competition and 

Create Significant Public Benefits..........................................27

IV. THE ROUTE TRANSFER WILL MAKE NEW AMERICAN A MORE VIABLE 

CARRIER THAN STAND-ALONE AA OR US AIRWAYS.............................32

V. THE ROUTE TRANSFER WILL ENHANCE DOMESTIC AIRLINE 

COMPETITION....................................................................................34

A. Domestic Competition in the Airline Industry is Intense........................34

B. The Transaction Will Enhance Domestic Competition .........................37

VI. THE ROUTE TRANSFER WILL HAVE A POSITIVE EFFECT ON THE TRADE 

POSITION OF THE UNITED STATES IN THE INTERNATIONAL AIR 

TRANSPORTATION MARKET ...............................................................40

VII. THE MERGER WILL BENEFIT AA AND US AIRWAYS EMPLOYEES...........40

VIII. APPROVAL OF THE JOINT APPLICATION WILL FURTHER ADVANCE THE 

OBJECTIVES OF U.S. INTERNATIONAL AVIATION POLICY.....................41

IX. TRANSFER OF ANTITRUST IMMUNITIES...............................................43
TABLE OF FIGURES

FIGURE 1: New American Forges the Networks of AA and US Airways into a 

Single, World-Class Global Network ..............................................................16

FIGURE 2(a): AA and US Airways Have No Nonstop Overlapping Routes Between 

the United States and Central and South America or Asia.................................17

FIGURE 2(b): AA and US Airways Have No Nonstop Overlapping Routes Between 

the United States and Europe/the Middle East.................................................18

FIGURE 3(a): New American’s Fleet Will Allow it to Place the Right Aircraft in the 

Right Place At the Right Time........................................................................19

FIGURE 3(b): New American Fleet Will Allow it to Precisely Match Aircraft Sizes 

with Short-Haul International Routes..............................................................20

FIGURE 3(c): New American’s Fleet Will Allow it to Precisely Match Regional 

Aircraft Sizes on Smaller International Routes.................................................21

FIGURE 4: Travelers on New American Will Receive Enhanced Access to 192

Cities Previously Only Served by One of the Joint Applicants.......................... 22

FIGURE 5: New American Facilitates Balanced Competition Among Three Global 

Alliances....................................................................................................24

FIGURE 6: New American Will Enhance Trans-Atlantic Alliance Competition 

Between the East Coast and Europe..............................................................29

FIGURE 7: New American Will Give oneworld Enhanced Penetration in the 

Eastern and Central United States.................................................................30

FIGURE 8: New American Enhances oneworld’s Ability to Compete for 

Connecting Revenue Between the East Coast and Europe................................31

FIGURE 9: New American Will Produce Over $1 Billion in Annual Network and 

Cost Synergies............................................................................................33

FIGURE 10: LCCs Have Continued to Grow While the Rest of the Industry is 

Shrinking...................................................................................................36

FIGURE 11: The Joint Applicants Only Have 12 Overlapping Nonstop Domestic 

Airport-to-Airport Routes............................................................................ 38

FIGURE 12: The Joint Applicants Will Provide the Most Service in the Eastern and 

Central United States While Having a Significant Presence in the West.............39
BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

___________________________________________

Joint Application of )

)

 AMERICAN AIRLINES, INC. ) 

 US AIRWAYS, INC. ) Docket DOT-OST-2013-____

 AMERICAN EAGLE AIRLINES, INC. )

 PSA AIRLINES, INC. ) April 17, 2013

 PIEDMONT AIRLINES, INC. )

 )

for approval of the transfer of international route )

authorities pursuant to 49 U.S.C. § 41105 )

___________________________________________)

JOINT APPLICATION OF AMERICAN AIRLINES, INC., US AIRWAYS, INC., 

AMERICAN EAGLE AIRLINES, INC., PSA AIRLINES, INC., AND PIEDMONT 

AIRLINES, INC. FOR APPROVAL OF THE TRANSFER OF INTERNATIONAL ROUTE

AUTHORITIES 

American Airlines, Inc. (“AA”) and US Airways, Inc. (“US Airways”) have reached 

agreement for a merger that will create a third U.S. airline with a global reach (“New 

American”). In order to implement this merger agreement, and achieve all of its benefits 

and synergies, AA, US Airways, American Eagle Airlines, Inc. (“Eagle”), PSA Airlines, 

Inc. (“PSA”), and Piedmont Airlines, Inc. (“Piedmont”) (collectively, the “Joint 

Applicants”)1 seek approval of the de facto route transfer that will occur when AA’s 

corporate parent, AMR Corp. (“AMR”), becomes the parent company of US Airways’ 

corporate parent, US Airways Group, Inc. (“USAG”), as the result of the merger. 

 1 Executive Airlines, Inc. ceased operations on March 31, 2013, and intends to surrender its FAA 

Operating Certificate on April 30, 2013.
Joint Application for Transfer 

of International Route Authorities

 

2

Overview

The purpose of this pleading is to seek the Department’s approval of the de facto

transfer of US Airways’, PSA’s, and Piedmont’s route authority to AA/Eagle, and the 

reissuance of the route authorities of all the carriers in order to comply with the 

applicable aviation statutes. 

This pleading is organized into nine sections that, taken as a whole, demonstrate 

why the Department should quickly approve the joint application. 

Section I provides an Executive Summary of pleading. Section II provides a legal 

description of the Parties. Section III sets forth the applicable standards that the 

Department applies in reviewing de facto transfer cases. In this case, the Joint 

Applicants meet all of the statutory and policy requirements and demonstrate that the 

requested transfer is clearly within the public interest. Importantly, the carriers have no 

international nonstop overlapping routes and the move of US Airways into the oneworld 

alliance significantly improves the competitive position of oneworld.

Demonstration of the benefits of the AA-US Airways combination continues in 

Section IV with a focus on the benefits that will result from the creation of New 

American, including a conservatively projected set of synergies in excess of $1 billion. 

Moreover, New American will be a stronger, more viable competitor, better able to 

successfully manage through the peaks and valleys of the airline industry. 

Section V demonstrates that New American will also have a positive impact on 

domestic competition given only a handful of nonstop overlaps. More importantly, the 

new American will expand passenger choice by having a route network that competes 

with the already developed route networks of Delta Air lines, Inc. (“Delta”), United 
Joint Application for Transfer 

of International Route Authorities

 

3

Airlines, Inc. (“United”), and Southwest Airlines Co. (“Southwest”). A well-developed 

domestic network provides the foundation for strengthening the position of the United 

States in international aviation and Section VI amplifies that point. 

As the carriers have said publicly, this merger benefits all stakeholders including 

employees, and Section VII discusses those benefits. Finally, Sections VIII and IX 

explain why the combination of US Airways and AA, with the expansion of AA’s existing 

antitrust immunity, is fully consistent with the governing principles of long-stated U.S. 

International Aviation Policy.

In short, this combination is squarely within the public interest and either meets 

or exceeds all of the statutory, regulatory and policy criteria that the Department 

considers in reviewing a joint transfer application. 

Introduction

This combination is strongly in the public interest as it creates substantial public 

benefits for consumers, employees and the communities that will be served by New 

American. Benefits for all constituencies flow from combining two highly 

complementary route systems into an integrated network offering passengers more and 

better ways to get where they want to go, when they want to travel. The New American 

network will compete on a global basis with the now larger networks of Delta and 

United, as well as other large international airlines. 

This end-to-end combination will be pro-competitive and pro-consumer. New 

American will be a financially more resilient airline that can provide expanded travel 

opportunities and more choices for travelers, invest in new aircraft and innovative 
Joint Application for Transfer 

of International Route Authorities

 

4

products, provide new opportunities and better compensation for employees, and better 

withstand cyclical economic conditions and volatile fuel prices. 

Consumer demand is the driver of this combination and the combined global 

network is the response to that demand. New American expects to continue to operate 

all nine hubs currently operated by AA and US Airways, and to serve all destinations 

currently served by either AA or US Airways, including small and medium-sized 

communities. Upon closing of the merger, New American will operate over 1,500 

aircraft to 336 cities around the world. Within the United States alone, the combination 

of US Airways and AA creates over 1,300 new online connecting opportunities to link 

communities throughout the United States with single carrier service through New 

American’s hubs.2 Furthermore, US Airways will join AA as a member of oneworld, 

expanding the reach of that alliance, by providing, for the first time, connecting hubs in 

the Northeastern and Southeastern U.S. to the oneworld partners. This will create a 

more solid foundation for additional international service by New American and the 

oneworld partner airlines, and increase alliance competition with Star Alliance and 

SkyTeam.

The combination is expected to generate over $1 billion in annual net synergies 

largely as the result of new passengers moving to take advantage of New American’s 

expanded and more competitive network. Passengers will also benefit from 

membership in AAdvantage, which will become the world’s largest frequent flyer 

program. Members of this program will have improved opportunities to earn and 

redeem miles across the much larger combined network. 

 2 Analysis limited to airport pairs with at least 50 passengers per week. The Joint Applicants presently 

have no plans to cease flying to any of the EAS communities they currently serve.
Joint Application for Transfer 

of International Route Authorities

 

5

Employees will benefit through a financially more resilient airline that provides 

greater job security, improved career opportunities, better pay, and a path to 

compensation and benefits comparable to those enjoyed by their counterparts at Delta 

and United. In a historical new precedent for airline labor/management partnerships, 

the Allied Pilots Association (“APA”), Association of Professional Flight Attendants 

(“APFA”), Transport Workers Union (“TWU”), and US Airline Pilots Association 

(“USAPA”) have agreed to new terms that take effect upon closing of the merger, and 

the Association of Flight Attendants (“AFA”) has reached a tentative agreement that 

includes support for the merger. Furthermore, AA’s pilot and flight attendant unions, 

APA and APFA, have started working with their US Airways counterparts, USAPA and 

AFA, to resolve representation and single agreement issues. 

Finally, communities will benefit. Each of New American’s hubs will be made 

stronger, and hub community travelers will benefit from expanded online travel 

opportunities and, over time, expansion of service. Non-hub communities will similarly 

benefit from the combination. US Airways has historically provided extensive air service 

to small and medium communities and the merger will extend that focus to the AA 

system. Indeed, many of the new online connections created by the merger of AA and 

US Airways involve smaller communities. The broader network created by the merger 

will enable heightened levels of service to those communities that neither carrier could 

afford to provide individually. 

In short, this merger benefits all stakeholders – consumers, employees, and 

communities. It combines two great airlines and puts them on a path to creating a truly 

exceptional global airline.
Joint Application for Transfer 

of International Route Authorities

 

6

Accordingly, pursuant to 49 U.S.C. § 41105 and Subpart B of the Department of 

Transportation’s (“Department” or “DOT”) Rules of Practice, AA, US Airways, Eagle, 

PSA, and Piedmont hereby jointly apply for approval of the de facto route transfer that 

will occur when AA’s corporate parent AMR becomes the parent company of USAG as 

the result of the merger. Following completion of that transaction, AA and US Airways 

will be commonly owned and controlled, but will initially continue to operate as separate 

air carriers, each holding authority from DOT and the Federal Aviation Administration 

(“FAA”).3

 The parties’ plan is for the two airlines’ operations subsequently to be 

conducted by a single entity known as “American” and to maintain the “AA” designator 

code, after a transition period providing time for a smooth integration of operations, 

employees, and route networks.4

 

Specifically, the Joint Applicants request that the Department: (1) approve the de 

facto transfer to AA all of the certificates of public convenience and necessity, 

exemptions, statements of authorization, frequency allocations, designations, grants of 

antitrust immunity, and any other related international route authorities (collectively, 

“International Route Authorities”)5 held by US Airways, PSA, and Piedmont that will 

 3 The Joint Applicants will abide by the provisions of the aviation agreements between the United States 

and foreign countries involved, as well as the Department’s standard conditions regarding route 

integration in limited-entry markets.

4 No decisions have been made regarding the corporate and operating structures of Eagle, PSA, or 

Piedmont, which remain presently unchanged. If changes are planned in the future, the Department will 

be notified appropriately in order that their certificates can be amended as needed.

5 AA has grants of antitrust immunity with British Airways, Finnair, Iberia, and Royal Jordanian (see DOT 

Order 2010-7-8); LAN Airlines and LAN Peru (see DOT Order 2005-10-8, DOT Order 1999-9-9); and 

Japan Airlines (see DOT Order 2010-11-10); as well as a Joint Business Agreement with Qantas (see 

DOT Order 2011-11-12). The parties seek the reissuance of these antitrust immunities to include US 

Airways, in the same manner that United and Continental transferred their antitrust immunities. In 

approving the extension of Continental’s antitrust immunity with Copa to include United, and extending 

United’s antitrust immunity with Air New Zealand and Asiana to include Continental, the Department 

found that the “changes offer benefits to the public, and, in light of the [United-Continental] merger, are 

required by the public interest.” (DOT Order 2011-3-14, p.7.)
Joint Application for Transfer 

of International Route Authorities

 

7

result from AMR’s acquisition of the outstanding shares of USAG; (2) reissue the 

International Route Authorities issued to US Airways, PSA, and Piedmont6 in the names 

of the current holders and/or AA and Eagle; and (3) reissue the International Route 

Authorities issued to AA and Eagle,7 in the names of the current holders and/or US 

Airways, PSA, and Piedmont. 

As part of the reissuance of the US Airways, PSA, and Piedmont International 

Route Authorities, the Joint Applicants also request the Department’s approval of the 

final transfer on international authority that will occur upon the ultimate merger of AA 

and US Airways.8

I. EXECUTIVE SUMMARY

On February 14, 2013, AMR, the corporate parent of AA, entered into an 

agreement (“Merger Agreement”) whereby, as the result of the merger of USAG into a 

wholly owned subsidiary of AMR, AMR will become the parent corporation of USAG, the 

parent corporation of US Airways.9 Following the completion of that transaction, which 

is currently under review by the Department of Justice (“DOJ”), AA and US Airways will 

initially continue to operate as separate airlines. US Airways eventually will be fully 

integrated with AA, following a transition period to permit adequate time for a seamless 

combination of operations, employees, and route networks.

 6 US Airways’, PSA’s, and Piedmont’s International Route Authorities are listed in Exhibit A.

7 AA’s and Eagle’s International Route Authorities are listed in Exhibit B. 

8 The Joint Applicants are concurrently filing a Joint Application for an interim exemption from 49 U.S.C. § 

41105 to permit the Joint Applicants to consummate the merger upon (i) completion of the pre-merger 

review procedures by the Department of Justice under the Hart-Scott-Rodino Antitrust Improvements Act 

of 1976 and (ii) receipt of necessary shareholder approvals.

9 A redacted copy of the Merger Agreement is attached as Exhibit C.
Joint Application for Transfer 

of International Route Authorities

 

8

The proposed merger of AA and US Airways will be completed pursuant to a plan 

of reorganization confirmed in AMR’s bankruptcy proceeding and is expected to occur in 

the third quarter of 2013. Background with respect to the proposed merger and its 

relationship to the bankruptcy proceeding is provided in the attached Joint Statement of 

Doug Parker, CEO of US Airways and Tom Horton, CEO of American Airlines, on 

March 19, 2013, before the Senate Judiciary Committee Subcommittee on Antitrust, 

Competition Policy and Consumer Rights;10 as well as the attached Statements of 

Stephen L. Johnson, Executive Vice President, Corporate and Government Affairs of 

US Airways, Inc., and Gary F. Kennedy, Senior Vice President, General Counsel and 

Chief Compliance Officer of American Airlines, Inc., on February 26, 2013, before the

United States House of Representatives Committee on the Judiciary, Subcommittee on 

Regulatory Reform, Commercial and Antitrust Law.11 

The Department’s de facto transfer doctrine provides that “when two or more 

carriers each holding international route authority come under common ownership and 

control, a de facto transfer of authority has taken place under section 41105 of the 

Statute.”12 In light of the Merger Agreement and the plans to combine the carriers, the 

Joint Applicants request that the Department: (1) approve the de facto transfer to AA of 

all International Route Authorities held by US Airways, PSA, and Piedmont; (2) reissue 

the International Route Authorities issued to US Airways, PSA, and Piedmont in the 

names of the current holders and/or AA and Eagle; and (3) reissue the International

 10 A copy of Mr. Parker’s and Mr. Horton’s Joint Statement is attached as Exhibit D.

11 Copies of Mr. Johnson’s and Mr. Kennedy’s Statements are attached as Exhibits E and F, respectively.

12 DOT Order 2009-1-8 (Delta/Northwest), p.3 (citing DOT Order 2001-12-15, p.8 (Atlas/Polar)). See also

DOT Order 2011-11-17, p.2 (Southwest/AirTran); DOT Order 2011-3-14, p.5, fn10 (United/Continental/Air 

Micronesia/Continental Micronesia); DOT Order 2000-9-4, p.2, fn3 (Delta/Comair); and DOT Order 1989-

3-21, p.2, fn.2 (Federal Express/Flying Tiger Line).
Joint Application for Transfer 

of International Route Authorities

 

9

Route Authorities issued to AA and Eagle in the names of the current holders and/or US 

Airways, PSA, and Piedmont. 

The de facto transfer to American of the International Route Authorities held by 

US Airways, PSA, and Piedmont is fully consistent with the public interest standards 

under 49 U.S.C. § 41105. New American will become one of the world’s premier 

airlines by combining two complementary end-to-end networks with no nonstop 

overlapping international routes, and only 12 overlapping domestic airport pairs. The 

merger, and the transfer to AA and Eagle of US Airways’, PSA’s, and Piedmont’s

International Route Authorities, will generate substantial and important consumer and 

competitive benefits for U.S. passengers and shippers. With critical gaps in its route 

network filled, New American will compete vigorously against Delta and United, as well 

as foreign carriers.

The public interest benefits created by New American are substantial, and clearly 

warrant granting the Joint Application: 

• AA’s and US Airways’ networks are highly complementary, and include no 

overlaps on international city pairs.

• The combination will provide consumers and communities with the following 

substantial benefits:

o More robust network offering more nonstop flights to more 

destinations

o Ability to connect more passengers to more places across a more 

efficient network

o No hub closures

o Expanded global access for small and medium-sized communities

o More efficient passenger routings leading to shortened consumer 

travel times 

o Optimized fleet utilization enabling the carrier to match aircraft type 

to consumer demand and length of flight, thereby increasing fuel 

efficiency and enhancing service
Joint Application for Transfer 

of International Route Authorities

 

10

o A single airline that can more successfully compete with the largest 

U.S. carriers including Delta, United, and Southwest

o Enhanced competition among the three large airlines alliances 

(oneworld, SkyTeam, and Star Alliance)

o Best-in-class elite frequent flyer program, with more ways to earn 

and redeem miles from a global network of routes and partnerships

o Additional investments in products and services to improve the 

travel experience

• The combination will remedy gaps in each of AA’s and US Airways’ current 

networks – gaps difficult to fill through organic growth – producing substantial 

consumer and competitive benefits:

o Internationally, New American’s broader domestic foundation will 

provide a broader, more diversified airline that spans nearly every 

region of the world, including:

 A well-developed network serving 30 cities in Central and 

South America

 A growing Trans-Pacific network – including service to 

Beijing, Shanghai, Tokyo, and, starting May 9, service to 

Seoul – that is better able to compete against Delta and 

United (which both enjoy historical advantages in providing 

air service to this region), while also creating a strong 

platform for growth in Asia – both from U.S. gateways and to 

new Asian destinations

 A broader Trans-Atlantic presence that offers service to 21 

destinations in Europe and the Middle East over 52 city pair 

routes13 

 A oneworld alliance with presence to act as a true third 

competitor to SkyTeam and Star Alliance

 Unique opportunities for New American to offer new 

international nonstop flights that neither AA’s or US Airways’ 

stand-alone traffic could support

o Domestically, New American will combine two end-to-end networks, 

giving it a significant presence throughout the entire United States, 

serving 218 destinations,14 including:

 Service to over 150 small and medium-sized community 

airports, more than any other airline, giving these points 

 13 Source: Diio 2013 published schedules as of January 25, 2013.

14 Source: Diio 2013 published schedules as of January 25, 2013.
Joint Application for Transfer 

of International Route Authorities

 

11

expanded service to both domestic and international 

destinations15

 New connections for many cities in the Central United States 

to US Airways’ hubs along the East Coast, and new 

connections for many cities in the Eastern United States to 

AA hubs in the Midwest and Texas

 Expanded service options, improved connectivity, additional 

routes, and shortened overall elapsed travel times 

throughout New American’s entire domestic network:

o Improved access between Eastern and Central U.S. 

cities

o Improved North-South connectivity between cities on 

the East Coast

o More efficient transcontinental routings 

o A more effective competitor with presence in the 

West/Southwest

 Expanded options among domestic hubs and routes thus 

increasing passenger convenience

 Increased ability to accommodate passengers during 

irregular operations scenarios

 Further growth of new nonstop domestic routes that neither 

carrier’s stand-alone traffic could support

• The merger will improve the viability of New American and make it a premier 

global carrier with:

o Substantial synergies creating financial strength and flexibility, 

resulting in a secure company able to withstand unstable conditions 

in the global economy and volatile fuel prices

o Opportunities in both the short- and long-term to expand its global 

services

o Enhanced competition against Delta, United, and other carriers for 

global corporate accounts

• Employee benefits from a financially more resilient carrier include:

o Historic new precedent for labor-management partnership within 

the airline industry

o Job security and greater career opportunities

o Better pay and a path to compensation and benefits comparable to 

those enjoyed by employee counterparts at Delta and United

o Pilots, flight attendants, mechanics, and fleet service unions 

partnering with their counterparts to determine representation and 

single agreement protocols

 15 Source: Diio peak day March 2013, small-hub/non-hub airport list from FAA based on 2011 

enplanements.
Joint Application for Transfer 

of International Route Authorities

 

12

o Labor agreements in effect for six years post-closing

• The transaction will enhance the overall U.S. trade position in the 

international air transportation marketplace, and further advance the 

international aviation policy objectives of the United States.

For the foregoing reasons, as presented in more detail below, the Department 

should promptly grant the relief that the Joint Applicants are requesting.

II. THE JOINT APPLICANTS

AA is a corporation organized and existing under the laws of the State of 

Delaware, with its principal office at 4333 Amon Carter Boulevard, Fort Worth, Texas 

76155. AA is a citizen of the United States within the meaning of 49 U.S.C. § 

40102(a)(15)(C), is a U.S.-certificated air carrier, and is fit, willing, and able to provide 

the services contemplated by this Joint Application. AA holds various International 

Route Authorities to provide foreign air transportation of persons, property, and mail.

Eagle is a corporation organized and existing under the laws of the State of 

Delaware, with its principal office at 4333 Amon Carter Boulevard, Fort Worth, Texas 

76155. Eagle is a citizen of the United States within the meaning of 49 U.S.C. § 

40102(a)(15)(C), is a U.S.-certificated air carrier, and is fit, willing, and able to provide 

the services contemplated by this Joint Application. Eagle holds various International 

Route Authorities to operate provide air transportation of persons, property, and mail.

US Airways is a corporation organized and existing under the laws of the State 

of Delaware, with its principal office at 111 West Rio Salado Parkway, Tempe, Arizona 

85281. US Airways is a citizen of the United States within the meaning of 49 U.S.C. § 

40102(a)(15)(C), is a U.S.-certificated air carrier, and is fit, willing, and able to provide 
Joint Application for Transfer 

of International Route Authorities

 

13

the services contemplated by this Joint Application. US Airways holds various 

International Route Authorities to operate provide air transportation of persons, 

property, and mail.

PSA is a corporation organized and existing under the laws of the State of 

Pennsylvania, with its principal office at 3400 Terminal Drive, Vandalia, Ohio 45377. 

PSA is a citizen of the United States within the meaning of 49 U.S.C. § 40102(a)(15)(C), 

is a U.S.-certificated air carrier, and is fit, willing, and able to provide the services 

contemplated by this Joint Application. PSA holds various International Route 

Authorities to provide foreign air transportation of persons, property, and mail.

Piedmont is a corporation organized and existing under the laws of the State of 

Maryland, with its principal office at 5443 Airport Terminal Road, Salisbury, Maryland 

21804. Piedmont is a citizen of the United States within the meaning of 49 U.S.C. § 

40102(a)(15)(C), and is registered as an Air Taxi Operator and Commuter Air Carrier 

under part 298 of the Regulations of the Department of Transportation.

Upon consummation of the merger, the Joint Applicants will continue to be 

citizens of the United States, and will remain fit, willing and able to perform the air 

transportation authorized by their respective authorities. Pursuant to Rule 24 of the 

Department’s Rules of Practice, the Joint Applicants request that the Department take 

official notice of all information previously filed to establish their fitness, as well as the 

information the Joint Applicants will submit to the Fitness Division.
Joint Application for Transfer 

of International Route Authorities

 

14

III. THE AA-US AIRWAYS ROUTE TRANSFER MEETS THE STATUTORY 

CRITERIA AND DEPARTMENT PRECEDENT FOR APPROVAL.

A. Applicable Statutory Standards and Policy Objectives.

“A certificate may be transferred under section 41105 of the statute if the 

Department determines that the transfer is in the public interest.”16 In making this public 

interest determination, the Department considers whether the certificate transfer would 

“conflict with important international aviation policy objectives, whether the surviving 

entities are U.S. citizens, and whether they will be fit to hold their authority.”17 

Furthermore, section 41105(b) “requires the Department to analyze the impact of the 

transaction on the viability of the carriers involved, on competition in the domestic airline 

industry, and on the trade position of the United States in the international air 

transportation market.”18 

The Department has consistently recognized a presumption in favor of approving 

route transfer applications, such as the one at hand, provided that, “they do not conflict 

with important international aviation policy objectives and are not otherwise inconsistent 

with the public interest.”19 Indeed, the Department has observed that since deregulation 

“the marketplace is generally a far better allocator and provides a far more efficient 

solution in the long term than does government interference.”20

 16 DOT Order 2011-11-17, p.3 (Southwest/AirTran); DOT Order 2011-3-14, p.4 (United/Continental/Air 

Micronesia/Continental Micronesia); and DOT Order 2009-1-8, p.4 (Delta/Northwest).

17 Id. 18 Id (citing DOT Order 2000-9-4, p.2 (Delta/Comair)).

19 DOT Order 2006-9-25, p.3-4 (Delta/United), DOT Order 2000-6-7, p.3 and fn.4 (UPS/Challenge). See 

also DOT Order 2000-9-4, p. 2 (Delta/Comair) and DOT Order 2000-8-5, p.3 and fn.4 (Fine/Arrow). The 

Department’s statutory jurisdiction is limited to the review of the transfer of international route authority 

under the public interest standards set forth in 49 U.S.C. § 41105 and to the continuing fitness of the Joint 

Applicants. (See DOT Order 1989-3-21, p.7-8 (Federal Express/Flying Tiger Line).

20 DOT Order 1992-4-33, p.20 (Delta/Pan American).
Joint Application for Transfer 

of International Route Authorities

 

15

As the following discussion, as well as separate responses into citizenship and 

fitness, will show the requested transfer of International Route Authorities will advance 

important international aviation policy objectives, and New American will continue to be 

a U.S. citizen and fit to hold the authority. Thus, the Joint Application fully satisfies the 

statutory public interest standards for Department approval under 49 U.S.C. § 41105. 

Furthermore, granting the Joint Application will enhance domestic competition, improve 

New American’s long term viability, and benefit the carrier’s employees; while 

simultaneously having a positive impact on the U.S. trade position for international air 

transportation. 

B. The Proposed Route Transfer Is In the Public Interest Because 

It Will Produce Substantial and Important Public Benefits.

The creation of New American is in the public interest because it will generate 

important and substantial public benefits for U.S. passengers, shippers, communities, 

and airline workers. New American will offer greatly expanded domestic and 

international options for travelers, competing globally with U.S. and foreign carriers, and 

enhancing competition among global alliances.

1. Public Benefits from New American Are Based on the Combination 

of US Airways’ and AA’s Complementary Route Structures and 

Aircraft Fleets.

As stand-alone carriers, the Joint Applicants have complementary route 

networks. When these networks are joined end-to-end as New American, a world-class 

global network is created, leading to substantial public benefits. Combining the AA and 

US Airways fleets will significantly increase New American’s ability to match capacity 

with demand, leading to even greater public benefits.
Joint Application for Transfer 

of International Route Authorities

 

16

a. New American Combines Complementary International Route 

Networks Without Any Overlapping Nonstop Routes.

The complementary route structures of the Joint Applicants are depicted in 

Figure 1 below, as is the world-class global network that is created through formation of 

New American.

Figure 1: New American Forges the Networks of AA and US Airways into a Single, 

World-Class Global Network

Only international routes shown.

Source: Diio 2013 published schedules as of January 25, 2013.

The complementary coverage of the existing AA and US Airways networks mesh 

neatly together, with AA bringing service throughout Central and South America, as well 

as service to Europe and Asia; while US Airways significantly grows the number of 

destinations served in Europe and the Middle East. Both carriers also provide nonoverlapping short-haul international service. The result is an enhanced network that is 

far better positioned to compete in the global marketplace. 
Joint Application for Transfer 

of International Route Authorities

 

17

AA and US Airways have no international nonstop overlapping routes, as shown 

in Figures 2(a) and 2(b).

Figure 2(a): AA and US Airways Have No Nonstop Overlapping Routes 

Between the United States and Central and South America or Asia

Source: July, 2013 OAG, includes seasonal and weekend-only services.

AA’s broad Latin American network operates from Dallas/Ft. Worth, Miami, and 

New York (all sources of local traffic); while its Trans-Pacific flights operate from New 

York, Chicago, Dallas/Ft. Worth and Los Angeles. US Airways’ Latin American system 

consists of four flights: between Charlotte and San Jose, Costa Rica; Belize City, Belize; 

Sao Paulo (beginning June 8, 2013) and Rio de Janeiro, Brazil; and between Phoenix 

and San Jose, Costa Rica. US Airways does not operate any Trans-Pacific flights. 
Joint Application for Transfer 

of International Route Authorities

 

18

Figure 2(b): American and US Airways Have No Nonstop Overlapping Routes 

Between the United States and Europe/the Middle East

Source: July, 2013 OAG, includes seasonal and weekend-only services.

AA and US Airways utilize different U.S. gateways for their Trans-Atlantic 

services. AA operates Trans-Atlantic service from seven gateways: Boston, Chicago, 

Dallas/Ft. Worth, Los Angeles, Miami, New York, and Raleigh/Durham. US Airways 

concentrates its Europe and Middle East flying at its well-positioned hubs in Charlotte, 

and Philadelphia. There are no nonstop overlapping routes anywhere on the two 

carriers’ international networks.

b. New American’s Comprehensive Fleet Mix Will Allow Far 

Greater Scheduling Flexibility.

The AA and US Airways fleets also complement each other by offering a full 

spectrum of aircraft sizes for long-haul, short-haul, and regional international services, 

as shown in Figures 3(a)-3(c). As a result, New American will have greater ability to 

match seat capacity with passenger demand and length of flight.

As Figure 3(a) shows, New American will not only have a wide range of seating 

capacities among its long-haul international aircraft; but will have aircraft with seat 
Joint Application for Transfer 

of International Route Authorities

 

19

capacities consistently spaced throughout this range that it can offer on any given longhaul international route.

Figure 3(a): New American’s Fleet Will Allow it to Place the Right Aircraft in the 

Right Place At the Right Time

Aircraft numbers include scheduled deliveries for 2013.

Source: usairways.com and AA Form 10-Q for Q3 2012

US Airways’ A330-200/300 aircraft fill the capacity gap between AA’s 777-200 and 777-

300 aircraft, while AA’s 767-300 and 777-200 aircraft provide a bridge between US 

Airways’ 767 and A330 aircraft. Filling these gaps gives New American far greater 

flexibility to place the right size aircraft on long-haul international routes, and 

dynamically adjust the allocation of these aircraft to meet seasonal changes in demand.

In the same manner, New American will have the right size aircraft on short-haul 

international routes. As shown in Figure 3(b), the US Airways E190, A319, and A321 

aircraft significantly broaden the range of capacities that New American can match with 

demand, including seasonal fluctuations.

14

102

58 47

5

24

10

12

9

0

20

40

60

80

100

120

140

151- 175

(AA B767-200)

176-200

(B757-200)

201-225

(AA B767-300

US B767-200)

226-250

(B777-200)

251-275

(A330-200)

276-300

(A330-300)

>300

(B777-300)

US Airways

AA

Number of 

Aircraft in 

Fleet

Number of Seats

(Equipment Type)
Joint Application for Transfer 

of International Route Authorities

 

20

Figure 3(b): New American Fleet Will Allow it to Precisely Match Aircraft 

Sizes with Short-Haul International Routes

Source: usairways.com and AA Form 10-Q for Q3 2012

Finally, New American’s ability to match aircraft size with demand will extend to 

trans-border routes to Canada and Mexico (and the Caribbean) many of which are 

served with regional aircraft. As Figure 3(c) shows, New American will have a mix of 

turboprop and regional jet aircraft with seating capacity evenly spaced over a wide 

range. 

190 186

20

93

32 72

79

0

50

100

150

200

250

300

<100

(E190)

100-124

(A319)

125-149

(AA S80

US B737)

150-174

(AA B737

US A320)

>175

(A321)

US Airways

AA

Number of 

Aircraft in 

Fleet

Average Number of Seats

(Equipment Type)
Joint Application for Transfer 

of International Route Authorities

 

21

Figure 3(c): New American’s Fleet Will Allow it to Precisely Match Regional 

Aircraft Sizes on Smaller International Routes

Average Number 

of Seats

Aircraft Types Offered

By AA

Aircraft Types Offered 

By US Airways

<40 ERJ-135 Dash-8 100/200

40-49 ERJ-140 --

50-59 ERJ-145, CRJ-200 ERJ-145, CRJ-200, Dash-8 300

60-69 CRJ-700, ATR-72 CRJ-700, ERJ-170

70-79 ERJ-175 CRJ-900

80-89 -- ERJ-175

Includes aircraft operated by regional partner carriers, and recently announced capacity purchase 

agreements.

Source: aa.com and usairways.com

New American’s fleet will facilitate an expanded online network, with the flexibility to 

adapt to changing market conditions, both seasonal and economic. This network will 

offer travelers a greater number of frequencies, more flexible scheduling, and more 

destinations. By providing these benefits to travelers, New American will enhance 

competition with other major U.S. carriers and their international alliance partners. 

Moreover, when combined with American’s new aircraft order which includes B-777 and 

B-787, as well as Airbus aircraft, the opportunity for additional international routes 

increases dramatically. 

2. Enhanced Global Network Competition from New American Is a 

Significant Public Benefit.

The addition of US Airways service to the oneworld alliance will enhance global 

network competition and create significant public benefits with no loss of existing 

competition. New American will link two complementary, non-overlapping international 

route networks in a way that substantially increases global network competition and 

expands competitive online service options. Indeed, as Figure 4 shows, integrating the 
Joint Application for Transfer 

of International Route Authorities

 

22

AA and US Airways networks will give travelers across the combined network enhanced 

access to 192 destinations around the world that were previously served by one of the 

Joint Applicants but not both. The creation of new on-line connections is a significant 

public benefit.

Figure 4: Travelers on New American Will Receive Enhanced Access to 192 Cities 

Previously Only Served by One of the Joint Applicants

Source: Diio 2013 published schedules as of January 25, 2013
Joint Application for Transfer 

of International Route Authorities

 

23

As a member of oneworld, New American will also generate enhanced interalliance competition with rivals SkyTeam21 and Star Alliance.22 SkyTeam and Star 

Alliance both generate immense traffic flows from destinations around the world, over 

extensive, multi-carrier networks.23 These alliances also benefit from grants of antitrust 

immunity. United enjoys antitrust immunity with six European carriers and Air 

Canada,24 COPA (Panama),25 Air New Zealand,26 ANA (Japan),27 and Asiana 

(Korea)28. Delta has antitrust immunity with four European carriers,29 four 

Australia/New Zealand carriers,30 and Korean Airlines.31 New American will give 

oneworld better coverage throughout the United States, particularly in Eastern region, 

creating a robust third competitor for international travelers among global alliances, as 

shown in Figure 5.

 21 The following carriers as part of SkyTeam: Aeroflot, Aerolineas Argentinas, Aeromexico, Air Europa, Air 

France, Alitalia, China Airlines, China Eastern, China Southern, Czech Airlines, Delta Air Lines, Kenya 

Airways, KLM, Korean Air, Middle East Airlines, Saudia, TAROM, Vietnam Airlines, Xiamen Air. (See 

http://www.skyteam.com/en/About-us/Our-members)

22 The following carriers as part of Star Alliance: Adria, Aegean, Air Canada, Air China, Air New Zealand, 

ANA, Asiana Airlines, Austrian, Avianca-TACA, Brussels Airlines, Copa, Croatia Airlines, EgyptAir, 

Ethiopian, LOT, Lufthansa, SAS, Shenzhen Airlines, Singapore Airlines, South African Airways, Swiss, 

TAM, TAP, Thai, Turkish Airlines, and United. (See http://www.staralliance.com/en/)

23 These network continue to grow. For example, Delta’s recent purchase of a 49% ownership stake in 

Virgin Atlantic and intent to seek antitrust immunity. (See “Virgin Deal to Boost Delta's Trans-Atlantic 

Reach”, Susan Carey and Jack Nicas, The Wall Street Journal, December 11, 2012 available at 

http://online.wsj.com/article/SB10001424127887324478304578173003312916158.html.)

24 See DOT Orders 2007-2-16 and 2006-12-17.

25 See DOT Orders 2001-5-1 (transferred to United by DOT Order 2011-3-14).

26 See DOT Orders 2001-4-2.

27 See DOT Order 2010-11-10.

28 See DOT Order 2003-5-18.

29 See DOT Order 2008-5-32 and DOT Order 2008-4-17 (Air France, Alitalia, Czech Airlines, and KLM)

30 See DOT Order 2011-6-9 (Virgin Australia, Virgin Blue, Pacific Blue (Australia) and Pacific Blue (New 

Zealand)).

31 See DOT Order 2002-6-18.
Joint Application for Transfer 

of International Route Authorities

 

24

Figure 5: New American Facilitates Balanced Competition 

Among Three Global Alliances

Source: Diio 2013 published schedules as of January 25, 2013.

In short, New American will promote the Department’s objective of enhancing 

global network competition both among carriers and among global alliances.32 

Enhancing global network competition is a key objective of the Department’s 

international aviation policy:

[W]e believe it is... important to recognize that the rapid growth and 

development of global airline alliance networks requires an additional 

perspective on competitive impact – the perspective of a worldwide 

aviation market in which travelers have multiple competing options for 

reaching destinations over multiple intermediate points... Thus a 

significant element in antitrust analysis is the extent to which facilitating 

airline integration (through antitrust immunity or otherwise) can enhance 

overall competitive conditions.

 32 See DOT Order 2010-2-8, p.14 (oneworld show cause order), and DOT Order 2005-2-14, p.19 (U.S.-

China Air Service case).
Joint Application for Transfer 

of International Route Authorities

 

25

DOT Order 1996-5-26, p.18-19 (Delta/Swissair/Sabena/Austrian).

Transfer of the US Airways, PSA, and Piedmont International Route Authorities 

to AA and Eagle will offer consumers “multiple competing options for reaching 

destinations over multiple intermediate points”,33 and create a global competitor rivaling 

Delta and United. New American will also compete more effectively against large, 

profitable foreign carriers, such as Star alliance member Lufthansa (which now owns 

Austrian, Brussels Airlines, and Swiss) and SkyTeam member Air France/KLM, as well 

as the rapidly expanding Gulf carriers.

3. The Route Transfer Will Enhance Trans-Pacific Competition 

Creating Additional Public Benefits.

New American will connect AA’s existing Trans-Pacific network with a broader 

integrated domestic network. This expanded domestic network, which includes service 

to 48 new cities in the East not served by AA, will provide increased traffic feed from 

more points in the United States. This increased traffic will support New American’s 

existing Trans-Pacific network and open the door to growth at additional Asia-Pacific 

destinations, thereby creating additional public benefit. This significant public benefit 

comes with no loss of competition on nonstop routes as US Airways and American have 

no nonstop overlaps on Trans-Pacific routes. 

This domestic network support is critical given the historical advantages United 

(via its acquisition of Pan Am’s Pacific Division in 1985) and Delta (via its acquisition of 

Northwest in 2008) have enjoyed in the region as unrestricted incumbents under the 

1998 U.S.-Japan Memorandum of Consultations. This status has allowed United and 

 33 DOT Order 1996-5-26, p.18 (Delta/Swissair/Sabena/Austrian).
Joint Application for Transfer 

of International Route Authorities

 

26

Delta not only to provide numerous flights to/from Japan, but also to develop extensive 

beyond-Japan networks within the Asia-Pacific region.

With its domestic network supporting Asia services, New American will 

significantly increase the availability of service options for travelers and shippers 

between the United States and Asia, and compete more effectively against rival 

alliances and their member carriers with operations across the Pacific. 

4. The Route Transfer Will Significantly Benefit Consumers by Giving 

Them Increased Connectivity and More Options for Travel Between 

the United States and Central and South America.

AA currently offers extensive service between the United States and Central and 

South America, providing flights from Dallas/Ft. Worth, Miami, and New York. Each of 

these hubs not only provides connections to Central and South America, but are strong 

sources of local traffic in their own right. By contrast, US Airways’ Latin American 

system consists of only five flights: between Charlotte and Belize City, Belize; Rio de 

Janeiro and Sao Paulo (beginning June 8, 2013), Brazil; and San Jose, Costa Rica; and 

between Phoenix and San Jose, Costa Rica.34 

AA and US Airways do not provide overlapping nonstop service on any 

international route between the U.S. and Central/South America. Accordingly, the 

proposed transfer will not result in any reduction of competition on nonstop routes. 

Instead, by integrating AA’s existing network in the Midwest and Texas with US Airways’ 

East Coast network, US Airways passengers and communities in particular will benefit 

from having access to three new Latin American gateways, and a much broader choice 

of destinations throughout Central and South America.

 34 US Airways also provides Saturday-only service between Charlotte and Liberia, Costa Rica.
Joint Application for Transfer 

of International Route Authorities

 

27

New American will provide improved connectivity for all of its customers between 

the United States and Central/South America, with consumers able to choose the 

routing and gateway that is most convenient for them. In total, New American will offer 

service on the greatest number of routes, to the largest number of Central and South 

American destinations. Supported by a broader domestic network than either US 

Airways or AA could offer, New American will provide this service from five gateways 

covering five regions of the United States: the Southeast (Charlotte), the South Atlantic 

(Miami), the Northeast (New York), Texas (Dallas/Ft. Worth), and the Southwest 

(Phoenix). 

5. The Route Transfer Will Enhance Trans-Atlantic Competition and 

Create Significant Public Benefits.

New American will be a much more effective Trans-Atlantic competitor than the 

Joint Applicants on a stand-alone basis. The combined carrier will offer service to 21 

destinations in Europe and the Middle East. This service will be primarily provided from 

four East Coast Trans-Atlantic gateways in Boston, Charlotte, New York, and 

Philadelphia. All four of these gateways will draw on New American’s broader 

integrated domestic network, especially in the Eastern United States, to feed traffic.35 

This improved service will be a significant public benefit.

New American will also provide Trans-Atlantic service from Chicago, Dallas/Ft. 

Worth, Los Angeles, Miami, and Raleigh-Durham. Beyond simply having high levels of 

local demand, these gateways will similarly benefit from New American’s extensive 

network in both the Eastern and Central and Midwest, augmenting the traffic Chicago 

 35 For example, Charlotte currently connects to 108 U.S. points, while Philadelphia connects to 86 

domestic points. (See US Airways Q1 2013 Fact Sheet Updated Jan. 1, 2013, available at 

www.usairways.com; and Diio, Peak Day March 2013.)
Joint Application for Transfer 

of International Route Authorities

 

28

and Dallas/Ft. Worth already draw via their established domestic networks (99 and 140 

connections in the contiguous U.S., respectively36).

New American will also provide customers of both AA and US Airways with an 

expanded choice of Trans-Atlantic destinations. Indeed, 12 of the 21 Trans-Atlantic 

destinations served by New American will be cities that were served by only one of AA 

or US Airways.37 

With nine Trans-Atlantic gateways, a robust domestic network, and a wider range 

of Trans-Atlantic destinations, the end result for consumers is increased choice. 

Consumers will be able to select the gateway, destination, routing, itinerary, and flight 

times that best meet their needs.

Trans-Atlantic alliance competition will be similarly strengthened. Relative 

shares among the three major carrier alliances will become more balanced as oneworld 

members and their passengers benefit from the addition of the broader East Coast 

network of US Airways. Currently, Star Alliance receives over 50 percent of the 

revenue from flights between the Eastern U.S. and Europe; SkyTeam roughly one-third, 

and oneworld less than 15 percent.38 However, as Figure 6 shows, with New American 

in oneworld, the three alliances will become much more competitive with each other.39

 36 Source: Diio peak day March 2013.

37 Current AA customers will receive new access to Amsterdam, Athens, Brussels, Glasgow, Lisbon, 

Munich, Shannon, Tel Aviv, and Venice; while current US Airways customers will receive new access to 

Dusseldorf, Helsinki, and Milan. 

38 Source: FY 2011 Superset Revenue for U.S. carriers.

39 oneworld would remain the smallest alliance by revenue share, still receiving less than 30% between 

the Eastern U.S. and Europe.
Joint Application for Transfer 

of International Route Authorities

 

29

Figure 6: New American Will Enhance Trans-Atlantic Alliance Competition

Between the East Coast and Europe

Source: FY11 Superset Revenue, U.S. carriers only

Alliance competition will also benefit as New American increases the overall 

number of destinations served in the U.S. by oneworld. New York (JFK) is the largest 

O&D city in the world. As such, AA successfully relies on local traffic to support its 

Trans-Atlantic service, without needing a broad network of connecting cities behind it. 

Indeed, AA currently serves only 10 Eastern U.S. cities with connections at New York 

(JFK) that are not also served nonstop by oneworld alliance partner, British Airways.40

While JFK is a fantastic airport from which to serve the local New York market, 

infrastructure constraints make it less optimal as a connecting hub for traffic to the 

interior United States. Thus, American and its oneworld partners have been at a 

disadvantage to the connecting gateways of Star Alliance at Newark and Washington; 

and SkyTeam in Atlanta. As a result, oneworld currently receives just over 5 percent of 

 40 Source: Diio Mi March 2012, Peak Day Schedule.
Joint Application for Transfer 

of International Route Authorities

 

30

the total alliance connecting revenue flowing over East Coast Trans-Atlantic 

gateways.41 

By contrast, US Airways’ Philadelphia and Charlotte gateway hubs are designed 

and scheduled to support Trans-Atlantic services by maximizing connections with 

broad, behind-gateway networks that cover much of the eastern half of the United 

States. As a result, New American will add nearly 100 connecting cities in the Eastern 

and Central United States served by US Airways from its Philadelphia and Charlotte 

gateways, that are not served nonstop by British Airways.42 This will increase 

oneworld’s penetration in the Eastern and Central United States ten-fold, as depicted in 

Figure 7.

Figure 7: New American Will Give oneworld Enhanced Penetration in the 

Eastern and Central United States

Source: Diio Mi March 2012 Peak Day Schedule

 41 Source: Superset Connecting Revenue, FY 2011.

42 Source: Diio Mi March 2012, Peak Day Schedule.
Joint Application for Transfer 

of International Route Authorities

 

31

With New American serving many more domestic cities, oneworld will offer online connections on a level competitive with the other alliances. The result will be more 

balanced, three-way allocation of Trans-Atlantic connecting revenue among the three 

carrier alliances, as shown in Figure 8.

Figure 8: New American Enhances oneworld’s Ability to Compete for Connecting 

Revenue Between the U.S. and Europe

Source: FY2011 Superset Connecting Revenue

The creation of New American will enhance Trans-Atlantic competition among 

both carriers and alliances. New American will offer Trans-Atlantic service to 21 points 

in Europe and the Middle East – more than either of the Joint Applicants could offer on 

their own – from nine gateways43, including five on the East Coast. Travelers will 

receive expanded choice in destinations, with 12 European and Middle Eastern cities 

previously served by only AA or US Airways; as well as expanded choice of routings, 

itineraries, and flight times. New American’s extensive domestic network will ensure the 

 43 The nine U.S. gateways are: Boston, Charlotte, Chicago, Dallas/Ft. Worth, Los Angeles, Miami, New 

York (JFK), Philadelphia, and Raleigh-Durham.
Joint Application for Transfer 

of International Route Authorities

 

32

sustainability of these services, and fuel opportunities for network expansion. At the 

same time, inter-alliance competition will be enhanced – oneworld’s increased U.S. 

presence will enable it to provide connecting services that compete with those offered 

by Star Alliance and SkyTeam, making oneworld a true third competitor for connecting 

passenger revenue. 

IV. THE ROUTE TRANSFER WILL MAKE NEW AMERICAN A MORE VIABLE 

CARRIER THAN STAND-ALONE AA OR US AIRWAYS.

The synergies driven by the creation of New American, and the enhanced 

service offering to passengers, will positively affect the viability of the Joint Applicants 

as soon as AA and US Airways are commonly controlled. Even greater benefits will 

accrue as AA and US Airways integrate, and eventually consolidate under a single 

operating certificate. 

New American is compelling because the end-to-end combination of AA and US 

Airways will produce over $1 billion in net annual cost and network synergies. As 

shown in Figure 9 below, the total expected synergies from the creation of New 

American is over $1.4 billion, offset by approximately $400 million which we have 

agreed to share with our employees through increased compensation.
Joint Application for Transfer 

of International Route Authorities

 

33

Figure 9: New American Will Produce Over $1 Billion 

in Annual Network and Cost Synergies

Synergies

(millions)

Network Revenue Synergies $900

Cost Synergies $550

Labor Harmonization ($400)

Total Synergies in 2015 $1,050

These synergies will create a more financially secure company with additional 

resources to weather increases in fuel prices and uncertain economic conditions. One 

of New American’s largest synergies will be from the elimination of gaps in AA’s and US 

Airways’ current international route networks, as discussed above. Indeed, the 

Department has previously held that route transfers “have a beneficial impact” on carrier 

viability where the routes to be transferred fill a “critical gap”.44 

These synergies will enable New American to compete vigorously and efficiently 

against U.S. and foreign air carriers in the intensely competitive global air transportation 

arena. Enhancing the financial position of the carriers will also generate opportunities 

for the combined carrier to expand the international services it offers, and reinvest in 

new products and services to benefit consumers. 

 44 See DOT Order 2006-9-25, p.4 (Delta/United)(citing the transfer of a New York-London route as filling a 

“critical gap” in Delta’s international network at JFK).
Joint Application for Transfer 

of International Route Authorities

 

34

V. THE ROUTE TRANSFER WILL ENHANCE DOMESTIC AIRLINE 

COMPETITION.

The Department’s review of the effect of the proposed international route transfer 

on domestic competition is limited, and does not include responsibility for evaluating the 

domestic competition implications of an airline merger, as Congress has assigned that 

task to the Department of Justice. DOT has acknowledged that Congress 

“narrowed [the] scope of [DOT’s] public interest inquiry” such that the Department’s 

“focus is on international aviation policy issues” while antitrust issues are considered 

more properly addressed by the Department of Justice as they are “beyond the scope of 

inquiry under Section 401(h)”.45 As such, the Department’s review is limited to the 

transfer of routes over which it has jurisdiction under 49 U.S.C. § 41105,46 while any 

domestic competition concerns are primarily addressed by the Department of Justice. 

Nevertheless, the approval of the de facto route transfer from US Airways to AA will 

position New American to better compete in this dynamic domestic marketplace, but not 

at the expense of competition.

A. Domestic Competition in the Airline Industry is Intense.

Competition in the airline industry has never been more intense. Through recent 

mergers, United/Continental, Delta/Northwest and Southwest/AirTran have developed 

and expanded their networks in a quest to deliver passengers what they want. These 

 45 DOT Order 1989-3-21, p.7-8 (Federal Express/Flying Tiger Line). See also DOT Order 2000-9-4, p.3, 

fn5 (Delta/Comair) and DOT Order 1998-8-16, p.16 (AIA/Kitty Hawk Aircargo).

46 See DOT Order 1991-9-53, p.23 (Delta/Pan American)(admitting DOT has “no section [41105]

jurisdiction” over purely domestic competition issues, but stating: “[t]he consequences of the transaction 

other than the route transfer at issue here are relevant to our competitive analysis for only one purpose –

to define further the present competitive environment upon which we must evaluate the effect of the 

transfer of the routes that is at issue here” (emphasis in original)).
Joint Application for Transfer 

of International Route Authorities

 

35

carriers provide more choices and better service for passengers today than before their 

mergers.

Domestic competition will remain vigorous. Upon closing of the merger, New 

American will have a 24.5 percent share of domestic available seats miles. New 

American will compete against the nationwide networks of Delta with a 20 percent 

share, United with an 18 percent share, and Southwest with an 18 percent share.47 

New American will also compete against a host of lower cost carriers (“LCCs”), 

including Allegiant, Frontier, JetBlue, Southwest, Spirit, and Virgin America. LCCs have 

continued to refine their business models and exert significant competitive pressure on 

the U.S. airline industry. LCCs have also diversified their services to attract corporate 

travelers, offering preferred boarding and seating. As a group, LCCs have grown in 

each of the last three years, while the rest of the U.S. airline industry has shrunk, as 

shown in Figure 10. 

 47 Source: OAG, 2nd Week of July, 2012.
Joint Application for Transfer 

of International Route Authorities

 

36

Figure 10: LCCs Have Continued to Grow While the Rest of the Industry is 

Shrinking

End of Year Year Over Year Changes in:

LCC Seats Rest of Industry Seats LCC ASMs Rest of Industry ASMs

2010 0.7% (0.7%) 3.1% 1.1%

2011 3.7% (1.0%) 6.1% (0.8%)

2012 0.9% (2.0%) 3.4% (1.0%)

Average 1.8% (1.2%) 4.2% (0.2%)

Source: Diio, YE 2012-2012 

Southwest, for example, has grown rapidly from a regional player to become the 

largest domestic carrier measured by enplanements, serving over 100 million customers 

annually.48 Southwest is a formidable force in the industry and other LCCs have 

emulated Southwest’s practices with success. Today, LCCs offer nearly 29% of all 

available domestic seats,49 and about 33% of all ASMs on U.S. domestic flights. In 

doing so, LCCs have garnered 23% of total revenues in the domestic marketplace.50 

Furthermore, LCCs are continuing to grow, both domestically and internationally. 

Spirit has been expanding its service at Dallas/Ft. Worth and has opened both crew and 

maintenance bases there;51 and in 2014, the Wright Amendment will expire thus ending 

any remaining limits on Southwest’s operations at nearby Love Field. JetBlue is 

reported to be considering expanding operations at Fort Lauderdale, “with most of that 

 48 Source: DOT’s BTS Statistics for 2012.

49 Source: Diio, FY 2012. LCCs include: Allegiant, Frontier, JetBlue, Southwest, Spirit, Sun Country and 

Virgin America.

50 Source: U.S. Value Carrier Financial Results by Region (Third Quarter 2012), Aviation Daily, p.7, 

February 6, 2013, data provided by Oliver Wyman. (Results include: Allegiant, JetBlue, Southwest, Spirit, 

Sun Country and Virgin America.)

51 See “Spirit Airlines’ Strategy: Grow in D/FW but Don’t Get Greedy”, Terry Maxon, Dallas Morning News, 

July 4, 2012 available at http://www.dallasnews.com/business/airline-industry/20120704-spirit-airlinesstrategy-grow-in-dfw-but-dont-get-greedy.ece and “Spirit Airlines to Open D/FW Crew base for Pilots, 

Flight Attendants”, Terry Maxon, Dallas Morning News, October 9, 2012 available at

http://aviationblog.dallasnews.com/2012/10/spirit-airlines-to-open-dfw-crew-base-for-pilots-flightattendants.html/.
Joint Application for Transfer 

of International Route Authorities

 

37

expansion designated for... the Caribbean and Latin America”;52 while Southwest has 

made clear its intent to expand its international service in the future.53 

LCCs have had a profound impact on the domestic airline industry. LCCs will 

continue to challenge the network carriers in major U.S. cities, and that will continue to 

be the case after the Joint Application is approved. Indeed, New American will compete 

for passenger traffic with multiple LCCs in each of its hubs. 

B. The Transaction Will Enhance Domestic Competition.

The combination of the complementary operations of US Airways and AA will 

create a world-class global network, offering consumers more destinations and flight 

options than either could offer separately. New American plans to retain all of the 

merging carriers’ existing hubs and offer service on 682 domestic routes to 218 

destinations. But across this vast array of routes and city-pairs, US Airways and AA 

overlap on only 12 nonstop domestic airport-to-airport routes, shown in Figure 11 

below.54 

 52 “JetBlue Considering Major Capacity Growth at Fort Lauderdale-Hollywood”, Aviation Daily, p.7, 

February 6, 2013.

53 See “Domestic Giant Southwest Sticks Nose Into International Air”, Charisse Jones, USA Today, may 

23, 2012 available at http://travel.usatoday.com/flights/story/2012-05-23/Domestic-giant-Southweststicks-nose-into-international-air/55174412/1.

54 The twelve airport-airport overlaps are: CLT – DFW/LGA/MIA/ORD; DCA – BNA/RDU; PHL –

DFW/MIA/ORD; and PHX-DFW/LAX/ORD
Joint Application for Transfer 

of International Route Authorities

 

38

Figure 11 – The Joint Applicants Only Have 12 Overlapping Nonstop Domestic 

Airport-to-Airport Routes

Source: Diio 2013 published schedules as of January 25, 2013

The limited number of these nonstop domestic overlaps compares favorably with 

the three most recent large airline mergers – Delta/Northwest in 2008 (11 overlaps), 

United/Continental in 2010 (13 overlaps), and Southwest/AirTran in 2011 (23 

overlaps).55 Each of these mergers was cleared after Justice Department antitrust 

review, and each was granted relief similar to what the Joint Applicants request herein. 

 55 Source: OAG, second week of July 2012. 
Joint Application for Transfer 

of International Route Authorities

 

39

Domestic competition will be enhanced by combining the complementary route

structures of the Joint Applicants. New American will have the largest service offering 

of any carrier in the Eastern and Central United States, while also offering broader 

coverage in the west than either of the joint applicants could offer separately. 

Figure 12 – The Joint Applicants Will Provide the Most Service in the Eastern and 

Central United States While Having a Significant Presence in the West

Source: FY 2011 Superset Domestic Revenue

As noted above, internationally, US Airways and AA have zero overlapping 

nonstop international flights; and among AA’s immunized partners, US Airways has only 

one nonstop international overlap, Philadelphia-London, which is also served by British 

Airways. Regardless of how competition may be measured, this is a merger of highly 

complementary operations in a highly competitive marketplace. Indeed, it is because 

the operations of US Airways and American are so complementary and overlap so little 

that the merger delivers such powerful passenger benefits. 
Joint Application for Transfer 

of International Route Authorities

 

40

VI. THE ROUTE TRANSFER WILL HAVE A POSITIVE EFFECT ON THE TRADE 

POSITION OF THE UNITED STATES IN THE INTERNATIONAL AIR 

TRANSPORTATION MARKET.

The proposed route transfer will foster U.S.-flag competition on a worldwide 

basis, and in particular geographic regions, by enabling the creation of a more effective 

and more expansive global U.S.-flag competitor. Accordingly, the trade position of the 

United States in international air transportation markets will be enhanced by the creation 

of New American.

New American will have a route network serving over 325 worldwide 

destinations,56 including key capitals, business centers, and tourist destinations in 

Europe and the Middle East, Central and South America, Mexico, Canada, the 

Caribbean, and Asia. Moreover, the substantial domestic traffic feed generated by the 

combined domestic route networks of the Joint Applicants will provide the foundation on 

which New American can continue to develop existing international routes and 

gateways on a scale that the Joint Applicants could not achieve on their own. This 

enhanced international gateway development will provide new travel options for U.S. 

and foreign travelers. This, in turn, will enable the combined carrier to more effectively 

compete in the global marketplace, with the results of New American’s enhanced ability 

to compete positively affecting the trade position of the United States.

VII. THE MERGER WILL BENEFIT AA AND US AIRWAYS EMPLOYEES.

The creation of New American and resulting transfer of the international routes at 

issue in this proceeding will benefit the Joint Applicants’ employees. The Joint 

Applicants are committed to fair and equitable integration of each carrier’s labor forces. 

 56 Source: OAG Schedules Peak Day Thursday July 2012.
Joint Application for Transfer 

of International Route Authorities

 

41

Indeed, in a historic new precedent for labor/management partnership in the airline 

industry, an integration process has already been agreed to by the pilot and flight 

attendant unions of both AA and US Airways, while mechanics and fleet service unions 

are working with their counterparts to determine representation and single agreement 

protocols.

Employees of New American will be part of a financially more secure airline that 

is better positioned to weather industry economic cycles and high fuel costs, providing 

employee job security, as well as industry competitive compensation and benefits. 

Moreover, with over $1 billion in annual synergies expected from the creation of New 

American, including the integration of the Joint Applicants’ complementary route 

networks and the fact that no hubs will be closed, New American is expected to 

generate additional opportunities for international and domestic service expansion. 

Workers at the combined company will benefit from job growth opportunities that follow 

these service expansions.

VIII. APPROVAL OF THE JOINT APPLICATION WILL FURTHER ADVANCE THE 

OBJECTIVES OF U.S. INTERNATIONAL AVIATION POLICY.

In its Statement of U.S. International Aviation Policy, the Department announced:

[O]ur overall goal continues to be to foster safe, affordable, convenient 

and efficient air service for consumers. We continue to believe that the 

best way to achieve this goal is to rely on the marketplace and 

unrestricted fair competition to determine the variety, quality, and price of 

air service.

60 Fed. Reg., at 21841, May 3, 1995 

The Department further stated that its international aviation strategy is designed 

to achieve the following objectives, among others:
Joint Application for Transfer 

of International Route Authorities

 

42

• Increase the variety of price and service options available to consumers

• Enhance the access of U.S. cities to the international air transportation 

system

• Provide carriers with unrestricted opportunities to develop types of service 

and systems based on their assessment of marketplace demand

• Encourage the development of the most cost-effective and productive air 

transportation industry that will be best equipped to compete in the global 

aviation marketplace at all levels and with all types of service

See, id., at 21844.

The substantial public benefits and competitive advantages described in this 

Joint Application, resulting from the route transfers requested herein, apply with equal 

force to the goals articulated in the Department’s Statement of U.S. International 

Aviation Policy. Accordingly, rather than reiterate those arguments in this section, the 

Joint Applicants incorporate them by reference. In short, the transfer to AA of US 

Airways’ International Route Authorities will:

• Increase the variety of price and service options offered to consumers 

between the U.S. and destinations throughout the world, particularly 

Europe and the Middle East, Central and South America, and Asia

• Expand the access of U.S. cities, including over 150 small communities, to 

worldwide destinations as a result of the integration of the complementary 

AA and US Airways networks

• Cause the marketplace identity and competitive strength offered by New 

American to enhance the role of the U.S. aviation industry in global air 

service markets

The proposed route transfer is a marketplace-driven transaction which furthers 

the goals of the Department’s Statement of U.S. International Aviation Policy.
Joint Application for Transfer 

of International Route Authorities

 

43

IX. TRANSFER OF ANTITRUST IMMUNITIES

The International Route Authorities to be transferred are identified in Exhibits A 

and B, and include AA’s three antitrust immunities (“ATIs”) and joint business 

agreement approval. These International Route Authorities of AA and US Airways are 

listed under the following headings: certificates, exemptions, frequency allocations, 

statements of authorization, designations, and antitrust immunity. These are the same 

categories of authority that the Department transferred in the Delta/Northwest merger in 

2008 and in the United/Continental merger in 2010.

AA has three separate ATIs: one with British Airways, Iberia, Finnair, and Royal 

Jordanian; one with LAN Airlines and LAN Peru; and one with Japan Airlines. In 

addition, the Department approved a joint business agreement between AA and Qantas 

without granting immunity. US Airways does not have any immunized relationships or 

other approved joint business agreements.

Adding US Airways to the LAN/LAN Peru and Japan Airlines ATIs, and to the 

approved joint business agreement with Qantas, does not present any competition 

issues. US Airways does not operate to Chile, Peru, Japan, or Australia. In the 

United/Continental route transfer, the Department summarily approved the addition of 

Continental to United’s ATIs with Air New Zealand and Asiana, and the addition of 

United to Continental’s ATI with Copa. As the Department found:

“The Department finds no reason to not extend the antitrust immunity 

originally granted to Continental in Order 2001-5-1 to United for 

cooperation with Copa as set forth in the alliance agreements. Because 

United does not currently serve the U.S.-Panama market, there are no 

anti-competitive effects associated with this change. With respect to Air 

New Zealand and Asiana, the Department, again, finds no reason to not 

extend the antitrust immunity originally granted to United in Orders 2001-

4-2 and 2003-5-18 to Continental.”
Joint Application for Transfer 

of International Route Authorities

 

44

Order 2011-3-14, p.7

Given the lack of any competitive issue, and in the interest of efficiency, the 

same summary approval should be granted to the Joint Applicants. 

Nor should the Department find reason not to also extend to US Airways the 

immunity held by AA, British Airways, Iberia, Finnair, and Royal Jordanian. Today, 

substantial numbers of passengers enjoy the benefits of the three immunized TransAtlantic joint businesses and competition among the alliances. The oneworld joint 

business carries roughly 33,000 customers between Europe and North America every 

day. However, oneworld is still the smallest of the three alliances. The addition of US 

Airways to the existing ATI will be pro-competitive and allow even more consumers to 

benefit from increased connectivity, as well as other enhancements. Indeed, the 

integration of US Airways into oneworld is one of the major synergies of the AA/US 

Airways merger itself, which will increase, not diminish, Trans-Atlantic competition. AA 

shares no common nonstop Trans-Atlantic routes with US Airways; and as between US 

Airways and the numerous carriers currently party to the ATI (AA, British Airways, 

Iberia, Finnair, Royal Jordanian), British Airways is the only one that shares a common 

nonstop Trans-Atlantic service with US Airways, Philadelphia-London. 

Moreover, the Department has extended ATIs in the past where the additional 

domestic carrier seeking inclusion to the existing ATI operated overlapping nonstop 

service with the other existing immunized alliance members. In its Show Cause Order 

2009-4-5, tentatively approving the addition of Continental to United’s ATI with 

Lufthansa and other members of the Star Alliance, the Department found that 

Continental and United had no “nonstop overlaps in international markets,” but did 
Joint Application for Transfer 

of International Route Authorities

 

45

identify “fourteen city-pair markets in which Continental’s services overlap on a nonstop 

basis with those of the other existing immunized alliance partners. Six such routes 

involv[ing] transatlantic markets”.57 Likewise, AA shares no common nonstop TransAtlantic routes with US Airways, and the one nonstop Trans-Atlantic route that US 

Airways and British Airways overlap on is much less than the six in Star Alliance matter.

In approving the addition of Continental to United’s ATI, the Department 

recognized that “when global network carriers combine network operations, nonstop 

overlaps are common, especially on hub to hub routes”.58 But more importantly, the 

Department has emphasized that the maximum benefits flowing from metal neutral joint 

businesses can only accrue when these fully integrated joint ventures are allowed to 

operate as a whole. Thus, the Department has avoided taking remedial action that 

undermines the ability of the collaboration to achieve full metal neutrality.

“In transatlantic markets, the affected city pairs are subject to close 

cooperation under a comprehensive joint venture ... [which] covers all 

transatlantic routes, regardless of whether they are served on a nonstop 

or connecting basis. By bringing all their capacity within the joint venture, 

participants seek to achieve true integrative benefits and efficiencies that 

will be passed on to consumers in the form of improved, more affordable 

travel options.... We would not expect the applicants to be able to achieve 

those efficiencies, or to pass on those cost savings, if they were prevented 

from coordinating the full range of their services under the joint venture.... 

For this reason, we will not impose new carve outs in transatlantic 

markets. Further, we will remove the two existing carve outs that are 

subject to cooperation under the joint venture” 

DOT Order 2009-4-5, p.12. 

Similarly, when the Department considered the ATI application in SkyTeam II, it 

was noted that carve outs are “fundamentally inconsistent with the integrative goal” of 

immunized joint business because they “impose duplicative costs, undermine the 

 57 DOT Order 2009-4-5, p.10.

58 Id., at 10-11.
Joint Application for Transfer 

of International Route Authorities

 

46

alignment of economic incentives, and destroy revenue and cost efficiencies”.59 Where 

the parties to the joint business seek to maintain an integrated joint venture covering all 

of the participants’ capacity in Trans-Atlantic markets, as is the case with the oneworld 

joint business, the “public benefits depend to a large extent upon revenue and cost 

efficiencies” attaching to full integration.60 For example, the exclusion of US Airways 

from the existing ATI, or even just the Philadelphia-London service from the ATI, would 

undermine the full metal neutrality that the joint business has achieved. 

Accordingly, the Department has understood that the parties cannot “realize 

those efficiencies if they were prevented from coordinating the full range of their 

services.”61 Because carve outs could undermine the effectiveness of the joint business 

and jeopardize the public benefits, the Department has previously found that “the 

potential risks of imposing carve outs ... outweigh the potential benefits.”62 Here, where 

the current carriers under the existing ATI have no overlap other than one shared US 

Airways and British Airways nonstop Trans-Atlantic service, the Department should 

extend the ATI to US Airways and not disturb the tight integration present in the 

oneworld joint business that has produced substantial consumer benefits since its 

launch.

In the period since its launch in October 2010, the oneworld joint business has 

grown total capacity by more than 9%. The integration between the carriers has also 

allowed the oneworld joint business to add new routes. A total of nine new TransAtlantic routes have been launched thus far, with one more to be added in the very near 

 59 DOT Order 2008-4-17, p.10.

60 Id.

61 Id.

62 Id.
Joint Application for Transfer 

of International Route Authorities

 

47

future. Customers are deriving benefits not just from increased capacity and new 

routes, they are enjoying both additional frequencies and coordinated schedules on 

oneworld joint business routes. For example, from New York, Chicago, Miami, and 

Boston a wider choice of flight times is now offered. From JFK, there are 15 daily 

oneworld services between London and New York in an aligned schedule. With the 

addition of OpenSkies (a British Airways subsidiary) into the joint business, customers 

now have a choice of up to four oneworld services linking New York with Paris. 

The extensive codesharing implemented among the Parties has substantially 

increased behind and beyond connectivity, and allowed oneworld customers to travel to 

significantly more destinations with greater ease. This can be observed by the 

increasing number of customers using joint business products. From a British Airways 

metal standpoint, the total percentage of customers using a joint business product 

increased from 6% in Q3 2010 to 23% by Q2 2012. The equivalent numbers for AA 

metal are seen increasing from 15% to 39%. The addition of the US Airways network 

will allow for even more improvements in connectivity for oneworld joint business 

travelers. 

For all of the above reasons, the Department should extend to US Airways the 

three ATIs currently held by AA, along with the approval of AA’s joint business 

agreement with Qantas.

* * *

The proposed de facto transfer of US Airways’, PSA’s and Piedmont’s 

International Route Authorities to AA arising from AMR’s acquisition of USAG meets all 

of the statutory criteria for approval under 49 U.S.C. § 41105 and corresponding 
Joint Application for Transfer 

of International Route Authorities

 

48

Department precedent. As the transfer is fully consistent with the public interest and the 

Department’s international aviation policies, the Department’s consistently recognized 

presumption in favor of approving route transfer applications, such as the one at hand, 

applies. Moreover, the proposed transfer will provide substantial public benefits, 

enhance the long-term viability of the Joint Applicants, increase competition in the 

international and domestic airline industry, improve the trade position of the United 

States, and benefit carrier employees.
Joint Application for Transfer 

of International Route Authorities

 

49

WHEREFORE, on the basis of the foregoing, the Joint Applicants request the 

Department: (1) approve the de facto transfer to AA all of the International Route 

Authorities held by US Airways, PSA, and Piedmont, that will result from AMR’s 

acquisition of the outstanding shares of USAG; (2) reissue the International Route 

Authorities issued to US Airways, PSA, and Piedmont in the names of the current 

holders and/or American and American Eagle; and (3) reissue the International Route 

Authorities issued to American and American Eagle in the names of the current holders 

and/or US Airways, PSA, and Piedmont. The Joint Applicants also request the 

Department’s approval of the final transfer on international authority that will occur upon 

the ultimate merger of AA and US Airways. The Joint Applicants further request that the 

Department grant them such other relief as it considers to be consistent with this Joint 

Application and the public interest.

Respectfully submitted this 17th day of April 2013,

______________________ ________________________

Howard Kass Francis C. Heil 

Vice President, Legal and Senior Attorney 

 Government Affairs American Airlines 

1101 17th Street NW, Suite 600

Benjamin T. Slocum Washington, DC 20036

Director, Legal and (202) 496-5642

 Government Affairs francis.heil@aa.com

US Airways, Inc.

1401 H Street, NW, Suite 1075

Washington, DC 20005

(202) 326-5153

howard.kass@usairways.com

benjamin.slocum@usairways.com
Exhibit A

US AIRWAYS, PSA, AND PIEDMONT INTERNATIONAL ROUTE AUTHORITIES

I. US AIRWAYS, INC.

A. Certificates of Public Convenience and Necessity

Route # Route Description Order(s)

None Blanket Route Integration Order 2010-12-24

839 Blanket Open Skies Route Authority Order 2007-4-20

Route 87-F Atlanta, GA/Miami, FL/Tampa, FL/Washington, 

DC/Baltimore, MD/New York, NY/ Newark, 

NJ/New Orleans, LA/Dallas/Ft. Worth, TX – Belize

Charlotte, NC/Baltimore, MD/Tampa, FL –

Nassau, Bahamas

Tampa, FL/Washington, DC/Baltimore, 

MD/Charlotte, NC – Cayman Islands

(Note: Routes superseded by Order 2007-4-20 not listed.)

Order 1997-7-2

Route 97-F Baltimore, MD/New York, NY/ Newark, NJ/ 

Boston, MA/Philadelphia, PA – Bermuda

Syracuse, NY/Cleveland, OH/Cincinnati, OH/ 

Philadelphia, PA/Pittsburgh, PA/ Baltimore, MD –

Freeport, George Town, Great Harbor Cay, Marsh 

Harbor, Nassau, Rock Sound, Treasure Cay and 

West End, Bahamas

(Note: Routes superseded by Order 2007-4-20 not listed.)

Order 1997-7-2

B. Exemption Authorities

Route Description Order/NOAT Docket

U.S. – Antigua NOAT April 21, 2006 

(timely renewal filed –

pending)

DOT-OST-2001-9932

U.S. – Buenos Aires, Argentina; 

Buenos Aires, Argentina –

Montevideo, Uruguay

NOAT October 11, 

2012

DOT-OST-2003-

14650

U.S. – China (pursuant to 

codeshare arrangements with 

United and Air China)

NOAT May 3, 2010 

(timely renewal filed –

pending)

DOT-OST-2008-0139
 

2

U.S. – Bahamas NOAT October 26, 

2011

DOT-OST-2001-9766

U.S. – Barbados NOAT August 17, 2011 DOT-OST-2001-9769

U.S. – St. Lucia NOAT August 17, 2011 DOT-OST-2001-9767

U.S. – Belize NOAT August 22, 2011 DOT-OST-2002-

12259

Charlotte, NC/Chicago, IL/

Washington, DC – Bermuda

NOAT April 20, 2011 DOT-OST-2001-

11152

Orlando, FL – Hamilton, Bermuda NOAT January 26, 

2006 (timely renewal 

filed – pending)

DOT-OST-2004-

16899

U.S. – Brazil (pursuant to 

codeshare arrangement with TAM)

NOAT May 16, 2012 DOT-OST-2003-

14651

Charlotte, NC – Rio de Janeiro and 

Sao Paulo, Brazil

NOAT March 2, 2011 

(timely renewal filed –

pending)

DOT-OST-2009-0003

U.S. – British Virgin Islands

(pursuant to codeshare 

arrangement with Caribbean Sun 

Airlines)

NOAT June 18, 2003 

(timely renewal filed –

pending)63

DOT-OST-2003-

15254

Philadelphia, PA – Grand Cayman, 

Cayman Islands

NOAT August 22, 2011 DOT-OST-1997-2721

U.S. – Colombia (codeshare only 

pursuant to arrangement with 

Avianca or other authorized carrier)

NOAT November 16, 

2012

DOT-OST-2012-0155

U.S. – Dominica

U.S. – Haiti

NOAT May 29, 2012 DOT-OST-2004-

18346

U.S. – Dominican Republic NOAT November 6, 

2012

DOT-OST-2000-7340

U.S. – Grenada NOAT July 22, 2011 DOT-OST-2001-

10588

U.S. – Fiji, and beyond to New 

Zealand

NOAT April 15, 2013 DOT-OST-2007-

29026

U.S. – Hong Kong (codeshare 

service)

NOAT August 20, 2007 

(timely renewal filed –

pending)

DOT-OST-2003-

14303

U.S. – Moscow and St. Petersburg, 

Russia (under a third-country 

codeshare arrangement)64

Order 2008-11-5 and 

NOAT August 13, 2012

DOT-OST-2008-0283

Boston, MA/Charlotte, NC/

Philadelphia, PA – Cancun Mexico

NOAT July 12, 2011 DOT-OST-2002-

13855

 63 This renewal application technically remains pending; however, US Airways’ no longer codeshares with 

Caribbean Sun Airlines.

64 US Airways is currently authorized by DOT to codeshare with Swiss International Air Lines, for 

codeshare service on these routes over Zurich, Switzerland (ZRH).
 

3

Charlotte, NC – Cozumel, Mexico NOAT November 6, 

2012

DOT-OST-2001-9768

Charlotte, NC – Mexico City, 

Mexico

NOAT February 28, 

2011 (timely renewal 

filed – pending)

DOT-OST-2003-

14575

Washington, DC – Mexico City, 

Mexico

NOAT August 22, 2011 DOT-OST-2003-

15310

U.S. – Saba

U.S. – St. Eustatius

U.S. – St. Barthelemy (pursuant to 

codeshare arrangement with 

Winward Islands Airways)

NOAT December 16, 

2002 (timely renewal 

filed – pending)

DOT-OST-2002-

13705

U.S. – St. Kitts and Nevis NOAT February 16, 

2006 (timely renewal 

filed – pending)

DOT-OST-2001-

10589

U.S. – St. Vincent and the 

Grenadines (pursuant to 

codeshare arrangement with 

Caribbean Sun Airlines)

NOAT May 19, 2004 

(timely renewal filed –

pending)65

DOT-OST-2003-

16061

U.S. – Turks and Caicos NOAT February 28, 

2011 (timely renewal 

filed – pending)

DOT-OST-2002-

12208

Phoenix, AZ – Cancun, Mexico NOAT July 28, 2011 DOT-OST-2006-

24613

Phoenix, AZ – Guadalajara, 

Mexico

NOAT August 22, 2011 DOT-OST-2007-0025

Phoenix, AZ – Hermosillo, Mexico 

(codeshare only)

NOAT August 22, 2011 

(timely renewal filed –

pending)66

DOT-OST-2005-

22645

Phoenix, AZ – Mexico City/ 

Mazatlan/Puerto Vallerta/San Jose 

del Cabo/

Ixtapa-Zihuatanejo/

Manzanillo, Mexico

NOAT May 26, 2011 

(timely renewal filed –

pending)

DOT-OST-2007-

29308

Los Angeles, CA/San Francisco, 

CA – Cancun, Mexico

Los Angeles, CA – San Jose del 

Cabo, Mexico

NOAT July 6, 2011 DOT-OST-2009-0172

Charlotte, NC – San Jose del 

Cabo, Mexico

NOAT October 27, 

2011

DOT-OST-2010-0040

 65 This renewal application technically remains pending; however, US Airways’ no longer codeshares with 

Caribbean Sun Airlines.

66 In its renewal application, US Airways notified DOT that it has ceased offering Phoenix-Guaymas 

service.
 

4

U.S. – Abijan, Cote d’Ivoire/ 

Bujumbura, Burundi/ Conakry, 

Guinea/Kinshasa, Democratic 

Republic of Congo/Freetown, 

Sierra Leone/ Luanda, Angola/ 

Lome, Togo

NOAT February 7, 2012 DOT-OST-2010-0043

U.S. – Johannesburg/Cape 

Town/Durban/East London/Port 

Elizabeth, South Africa

NOAT December 4, 

2012

DOT-OST-2012-0189

C. Frequency Allocations

Number of

Frequencies Route Description Order/NOAT

7 Charlotte – Rio de Janeiro, Brazil Order 2009-4-6

7 Charlotte – Sao Paulo, Brazil (via temporary 

reallocation of frequencies)

NOAT August 2, 2010

D. Codesharing Statements of Authorization

Airline

Partner(s) Route Description

NOAT/

Department Action Docket

TAP Air Portugal Blanket Statements of 

Authorization for 

reciprocal codesharing

Department Action 

May 17, 2006

DOT-OST-2006-

24670

Royal Jordanian Statements of 

Authorization to display 

“RJ” Designator Code 

NOAT March 1, 

2007

DOT-OST-2007-

27347

Virgin Atlantic Statement of 

Authorization to display 

“VS” Designator Code

Department Action 

February 26, 2009 

and August 29, 

201267

DOT-OST-2007-

27349

EVA Airways Blanket Statement of 

Authorization to display 

“BR” designator code 

Department Action 

January 8, 2010

DOT-OST-2007-

27352

 67 Virgin Atlantic has terminated this codeshare arrangement. US Airways and Virgin Atlantic intend to 

formally notify the Department of this termination closer to the last date of service.
 

5

Singapore Airlines Blanket Statements of 

Authorization for 

reciprocal codesharing

Department Action 

August 20, 2007

Joint Notice of 

Blanket 

Codesharing filed 

March 18, 2009

DOT-OST-2007-

28084

Asiana Airlines Blanket Statements of 

Authorization for 

reciprocal codesharing

Department Action 

November 30, 

2007

Joint Notice of 

Blanket 

Codesharing filed 

March 31, 2009

DOT-OST-2007-

0059

Air New Zealand Blanket Statements of 

Authorization for 

reciprocal codesharing 

Department Action 

September 11, 

2007

Joint Notice of 

Blanket 

Codesharing filed 

July 13, 2009

DOT-OST-2007-

29024

Swiss International 

Airlines

Blanket Statements of 

Authorization for 

reciprocal codesharing 

Department Action 

April 8, 2008

Joint Notice of 

Blanket 

Codesharing filed 

March 9, 2009

Notice of Russia 

codesharing filed 

May 21, 2012

DOT-OST-2008-

0101

Air China Statements of 

Authorization for 

reciprocal codesharing 

NOAT June 5, 

2008

DOT-OST-2008-

0139

TACA/LACSA/

TACA-Peru

Blanket Statements of 

Authorization for 

reciprocal codesharing 

NOAT November 

12, 2009

DOT-OST-2009-

0261

TAM Blanket Statements of 

Authorization for 

reciprocal codesharing 

NOAT June 15, 

2010

DOT-OST-2010-

0127

Turkish Airlines Blanket Statements of 

Authorization for 

reciprocal codesharing

Department Action 

July 29, 2010

DOT-OST-2010-

0184

Qatar Airways Blanket Statements of 

Authorization for 

Department Action 

May 6, 2009

DOT-OST-2009-

0079
 

6

reciprocal codesharing 

Aegean Airlines Statements of 

Authorization for 

reciprocal codesharing 

Department Action 

July 12, 2011

DOT-OST-2011-

0120

ANA and Air Japan Blanket Statements of 

Authorization for 

reciprocal codesharing 

Department Action 

September 14, 

2009

DOT-OST-2009-

0181

Brussels Airlines Blanket Statements of 

Authorization for 

reciprocal codesharing 

NOAT March 18, 

2010

DOT-OST-2010-

0042

Lufthansa Statements of 

Authorization for 

reciprocal codesharing 

NOAT October 10, 

2003 (amended 

October 16, 2003 

and January 11, 

2005)

Joint Notice of 

Blanket 

Codesharing filed 

July 27, 2009

DOT-OST-2003-

15946

Avianca Statements of 

Authorization for 

reciprocal codesharing 

NOAT November 

16, 2012

DOT-OST-2012-

0155

South African 

Airways

Statements of 

Authorization for 

reciprocal codesharing 

NOAT December 

4, 2012

DOT-OST-2012-

0189

Croatia Airlines Blanket Statements of 

Authorization for 

reciprocal codesharing 

NOAT June 6, 

2012

DOT-OST-2012-

0084

E. Small Aircraft Codeshare Designation Notifications

None

F. Antitrust Immunity Grants

None
 

7

II. PSA AIRLINES, INC.

A. Certificates of Public Convenience and Necessity

Route # Route Description Order(s)

None U.S. – Canada Order 2004-5-22 

B. Exemption Authorities

Route Description Order/NOAT Docket

U.S. – Bahamas NOAT June 1, 2012 DOT-OST-2004-

18017

U.S. – Turks and Caicos NOAT April 20, 2012 DOT-OST-2004-

18811
Exhibit B

1

AMERICAN AND AMERICAN EAGLE INTERNATIONAL ROUTE AUTHORITIES

I. AMERICAN AIRLINES, INC.

A. Certificates of Public Convenience and Necessity

Route # Route Description Order(s)

835 Open Skies Order 2007-4-2

None Blanket route integration Order 2010-12-24

137 U.S.-Caribbean/Bahamas/Bermuda/

Central America/Europe/Near East/

Far East/Chile/New Zealand

Order 1996-5-9

147 Europe/Middle East/Asia (acquired from TWA)

(Timely renewal filed – pending)

Order 2001-4-7 

389 Named U.S. points-Panama City, Panama; 

Barranquilla, Bogota, and Cali, Colombia; Quito 

and Guayaquil, Ecuador; Lima, Peru; Montevideo,

Uruguay; La Paz, Bolivia; Asuncion, Paraguay; 

Buenos Aires, Argentina; Santiago, Chile

(Timely renewal filed – pending)

Order 1990-5-5

542 Puerto Rico-Caracas

(Timely renewal filed – pending)

Order 1988-5-42 

543 Miami/New York/Newark-Caracas/

Maracaibo Venezuela

(Timely renewal filed – pending) 

Order 1990-5-5 

602 Europe/Middle East/Asia

(Timely renewal filed – pending)

Order 1996-5-9

628 Dallas/Ft. Worth-Acapulco

Dallas/Ft. Worth-Mexico City

Dallas/Ft. Worth-Monterrey

Chicago-Mexico City

Order 1992-5-20

794 New York-Cancun

St. Louis-Cancun

(Timely renewal filed – pending)

Order 2001-4-7

826 Chicago-Shanghai

(Timely renewal filed – pending)

Order 2005-3-40 

826 Chicago-Beijing (amended) Order 2007-12-26 

903 U.S.-Mexico certificate (consolidating various 

exemptions)

Order 2011-6-11

B. Exemption Authorities

Route Description Order/NOAT Docket

Miami-Valencia, Venezuela NOAT February 4, 2013 DOT-OST-2006-

26387

Broad Brazil authority NOAT February 4, 2013 DOT-OST-1996-1353
2

Miami-Santa Cruz/La Paz, Bolivia NOAT October 11, 

2011

DOT-OST-1997-2302

DFW-Caracas, Venezuela NOAT July 13, 2012 DOT-OST-1997-2527

Los Angeles-Shanghai, China NOAT July 31, 2012 DOT-OST-2010-0245

U.S.-South Africa for codesharing

on British Airways

NOAT January 28, 

1998 (timely renewal 

filed – pending)

DOT-OST-1998-3401

U.S.-Vietnam for codesharing on 

Japan Airlines

NOAT February 4, 2013 DOT-OST-2002-

12496

U.S.-Hong Kong for codesharing 

on Cathay Pacific

NOAT February 4, 2013 DOT-OST-2000-6824

U.S.-Argentina points for 

codesharing on LAN Argentina

NOAT February 4, 2013 DOT-OST-2007-0034

U.S.-Pacific points for codesharing 

on Air Pacific

NOAT November 30, 

2011

DOT-OST-2011-0197

U.S.-Ecuador for codesharing on 

LAN Ecuador

NOAT December 31, 

2011

DOT-OST-2011-0210

U.S.-China points for codesharing

on Hainan Airlines

NOAT February 15, 

2012

DOT-OST-2011-0228

Additional Argentina points 

codesharing on LAN

NOAT April 12, 2012 DOT-OST-2006-

24194

Blanket exemption authority for 

codesharing

NOAT February 28, 

2013

DOT-OST-2009-0337

Mexico transborder routes via 

codesharing on Alaska

NOAT July 19, 2012 DOT-OST-2010-0222

U.S.-Brazil points for codesharing 

on TAM

NOAT January 25, 

2013

DOT-OST-2012-0209

C. Frequency Allocations

Number of

Frequencies Route Description Order/NOAT

9 Argentina – Acquired from Eastern in 1990 Order 1990-5-5

5 Argentina Order 1995-2-23

7 Argentina – Above 14 increased to 21

when the 1 to 1.5 narrowbody/

widebody formula was abolished

3 Argentina Order 2003-8-14

4 Dallas/Ft. Worth – Buenos Aires, Argentina DOT-OST-2003-

15384, January 2, 

2004

4 Miami – Buenos Aires DOT-OST-2010-0178, 

July 12, 2010 

(seasonal)

7 Brazil – Acquired from Eastern in 1990 Order 1990-5-5

3 Brazil Automatic increase effective 4/1/91 Order 1991-2-15

4 Brazil Order 1991-2-15
3

6 New York (JFK) – Sao Paulo, Brazil Order 1991-6-5

1 New York (JFK) – Sao Paulo, Brazil Order 1991-8-25

7 Miami – Sao Paulo, Brazil DOT-OST-1996-1356, 

June 1, 1998

3 Dallas/Ft. Worth – Sao Paulo, Brazil Order 1995-1-27

11 Various Order 1995-10-25

2 Miami – Sao Paulo, Brazil DOT-OST-2003-

15965, August 14, 

2003

3 Miami – Sao Paulo, Brazil DOT-OST-2004-

17139, February 24, 

2004

10 Brazil Regional DOT-OST-2008-0229, 

August 8, 2008

1 Brazil Regional Order 2008-11-21

3 Dallas/Ft. Worth – Rio de Janeiro, Brazil DOT-OST-2010-0179, 

June 16, 2010

7 New York (JFK) – Rio de Janeiro, Brazil DOT-OST-2010-0088, 

August 6, 2010

4 Miami – Brasilia, Brazil DOT-OST-2010-0088, 

August 6, 2010

10 Brazil Regional DOT-OST-2011-0086, 

April 28, 2011

3 Miami - Manaus, Brazil DOT-OST-2011-0086, 

February 8, 2012

14 Miami – Rio de Janeiro, Brazil 

(7 to backfill Miami – Rio de Janeiro, Brazil,

that AA transferred to Sao Paulo , Brazil, 7 for 

Miami – Rio de Janeiro, Brazil #2)

DOT-OST-2012-0079

3 Brazil Regional DOT-OST-2012-0079

7 Chicago – Shanghai, China Order 2005-3-40

7 Chicago – Beijing, China Order 2007-12-26

7 Los Angeles – Shanghai, China DOT-OST-2010-0245

19.5 Ecuador Order 1992-10-43

1.5 Ecuador DOT-OST-2002-

12000, July 12, 2002

3 Ecuador DOT-OST-2009-0220, 

10/8/09

4 Ecuador DOT-OST-2009-0220, 

January 30, 2013

7 Dallas/Ft. Worth – Tokyo, Japan (NRT) Order 1986-10-16

7 New York (JFK) – Tokyo, Japan (NRT) Order 1998-5-17

7 Chicago – Tokyo, Japan (NRT) Order 1998-5-17

4 Dallas/Ft. Worth – Tokyo, Japan (NRT) DOT-OST-2002-

11266, March 20, 

2002

7 Los Angeles – Tokyo, Japan (NRT) DOT-OST-2002-

12554, July 17, 2002
4

1 Dallas/Ft. Worth – Tokyo, Japan (NRT) DOT-OST-1998-3419, 

September 13, 2002

(initially 3 but 2 lapsed 

as dormant; see AA 

application on 

September 21, 2004)

1 Dallas/Ft. Worth – Tokyo, Japan (NRT) DOT-OST-1998-3419, 

September 27, 2004

1 Dallas/Ft. Worth – Tokyo, Japan (NRT) DOT-OST-1998-3419, 

January 20, 2005

7 New York (JFK) – Tokyo, Japan (HND) Order 2010-7-2

D. Codesharing Statements of Authorization

Airline

Partner(s) Homeland

Order/NOAT/

Department Action Docket

Gulf Air Bahrain Department 

Action, August 4, 

2008

DOT-OST-2008-

0195

Qantas Australia Department 

Action, May 23, 

2008

DOT-OST-2008-

0138

China Airlines 

(mail)

Taiwan Department 

Action, October 5, 

2000

DOT-OST-1999-

6687

Iberia Spain Department 

Action, February 

13, 2008

DOT-OST-2008-

0044

Finnair Finland Department 

Action, January 7, 

2000

DOT-OST-1999-

6544

Japan Airlines Japan Department 

Action, February 

18, 2010

DOT-OST-1999-

4994

Lan Chile Department 

Action, January 7, 

2000

DOT-OST-1999-

6546

Addition of TWA 

LLC and 

American

Eagle to prior

statements of 

authorization

n/a Department 

Action, November 

8, 2001

DOT-OST-2000-

7057

Singapore Airlines 

(mail)

Singapore Department 

Action, April 23, 

2002

DOT-OST-2002-

12089
5

Cathay Pacific Hong Kong Department 

Action, January 8, 

2002

DOT-OST-2000-

6824

British Airways United Kingdom Orders 2003-5-33 

and 2010-7-8

Lan Peru Peru Department 

Action, February

16, 2007

DOT-OST-2004-

19965

Royal Jordanian Jordan Department 

Action, October 

24, 2007

DOT-OST-2006-

26716

Jet Airways 

(India)

India Department 

Action, January 7, 

2008

DOT-OST-2007-

0078

El Al Israel Department 

Action, March 28, 

2008

DOT-OST-2007-

0095

Lan Argentina Argentina Department 

Action, June 11, 

2009

DOT-OST-2007-

0034

Etihad U.A.E Department 

Action, July 24, 

2009

DOT-OST-2009-

0154

Jetstar (intra-New 

Zealand)

Australia Department 

Action, July 31, 

2012

DOT-OST-2010-

0265

Kingfisher India Department 

Action, March 8, 

2011

DOT-OST-2010-

0288

WestJet Canada Department 

Action, March 10, 

2011

DOT-OST-2011-

0040

Air Pacific Fiji Department 

Action, November 

30, 2011

DOT-OST-2011-

0197

Lan Ecuador Ecuador Department 

Action, December 

13, 2011

DOT-OST-2011-

0210

Hainan Airlines China Department 

Action, February 

15, 2012

DOT-OST-2011-

0228

Air Tahiti French Polynesia Department 

Action, July 5, 

2012

DOT-OST-2012-

0092

TAM Brazil Department 

Action, January 5, 

2013

DOT-OST-2012-

0209
6

LAN Colombia Colombia Department 

Action, January 

25, 2013

DOT-OST-2012-

0208

Qatar Airways Qatar Department 

Action, February 

20, 2013

DOT-OST-2013-

0007

Malaysia Airlines Malaysia Department 

Action, February 

28, 2013

DOT-OST-2013-

0022

E. Third Country Codeshare Designations

Airline

Partner(s) Country

Order/NOAT/

Department Action Docket

British Airways Flights to/from South 

Africa

Department 

Action, September 

20, 2003

DOT-OST-2002-

12193

F. Antitrust Immunity Grants

Airline Partner(s) Order/NOAT Docket

LAN Chile Order 1999-9-9 DOT-OST-1997-3285

LAN Peru and LAN Airlines Order 2005-10-8 DOT-OST-2004-

19964

British Airways, Iberia, Finnair, and 

Royal Jordanian

Order 2010-7-8 DOT-OST-2008-0252

Japan Airlines Order 2010-11-10 DOT-OST-2010-0059

Qantas (approval of agreement 

without antitrust immunity)

Order 2011-11-12 DOT-OST-2011-0111
7

II. AMERICAN EAGLE AIRLINES, INC.

A. Certificates of Public Convenience and Necessity

Route # Route Description Order(s)

537 U.S.-Caribbean Order

1998-5-12

905 Open Skies Order 2011-8-9

906 U.S.-Mexico Order 2011-11-19

B. Small Aircraft Codeshare Designation Notifications

DOT-OST-2011-0076

DFW-Aguascalientes

DFW-Hermosillo

DFW-Leon

DFW-Mazatlan

DFW-Morelia

DFW-Puebla

DFW-Queretaro

DFW-Veracruz

DFW-Zacatecas
CERTIFICATE OF SERVICE

I certify that, on April 17, 2013 I caused to be served a copy of the foregoing Joint 

Application by email upon those addressees listed below:

urskr@state.gov (Department of State)

paul.gretch@dot.gov (Department of Transportation)

esta.rosenberg@dot.gov (Department of Transportation)

todd.homan@dot.gov (Department of Transportation)

brian.hedberg@dot.gov (Department of Transportation)

brett.kruger@dot.gov (Department of Transportation)

john.allen@faa.gov (Federal Aviation Administration)

dan.weiss@united.com (United)

steve.morrissey@united.com (United)

karine.faden@united.com (United)

jonathan.linde@united.com (United)

sascha.vanderbellen@delta.com (Delta)

jhill@dowlohnes.com (Counsel for JetBlue and Hawaiian)

perkmann@dowlohnes.com (Counsel for JetBlue and Hawaiian)

robert.land@jetblue.com (JetBlue)

msinick@ssd.com (Counsel for Alaska)

jyoung@yklaw.com (Counsel for Spirit)

dkirstein@yklaw.com (Counsel for Spirit)

bob.kneisley@wnco.com (Southwest)

leslie.abbott@wnco.com (Southwest)

ethan.blank@rjet.com (Republic)

robert.cohn@hoganlovells.com (Counsel for Republic)

patrick.rizzi@hoganlovells.com (Counsel for Republic)

john.fredericksen@suncountry.com (Sun Country)

rpommer@atlasair.com (Atlas)

anita.mosner@hklaw.com (Counsel for UPS)

jennifer.nowak@hklaw.com (Counsel for UPS)

cefelts@fedex.com (FedEx)

nssparks@fedex.com (FedEx)

kevin.montgomery@polaraircargo.com (Polar)

matwood@cozen.com (Counsel for Kalitta)

_________________________

Benjamin T. Slocum