BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

In the matter of the application of 

CONCESIONARIA VUELA COMPAŇÍA DE 

AVIACIÓN, S.A.P.I. DE C.V. d/b/a VOLARIS 

for an exemption from 49 U.S.C. § 41301 

Docket DOT-OST-2014-0167

ANSWER OF THE CITY OF HOUSTON 

Communications with respect to this document should be sent to:

Mario C. Diaz 

 Director 

Ian Wadsworth 

 Chief Commercial Officer 

Department of Aviation 

CITY OF HOUSTON 

16930 John F. Kennedy Blvd. 

Houston, TX 77032 

(281) 233-3000 

(281) 233-1859 (fax) 

Rachel B. Trinder 

Jol A. Silversmith 

ZUCKERT, SCOUTT & 

 RASENBERGER, L.L.P. 

888 Seventeenth Street, N.W. 

Washington, D.C. 20006-3309 

(202) 973-7927 

(202) 342-0683 (fax) 

rbtrinder@zsrlaw.com

jasilversmith@zsrlaw.com

For the City of Houston 

Dated: October 6, 2014 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

In the matter of the application of 

CONCESIONARIA VUELA COMPAŇÍA DE 

AVIACIÓN, S.A.P.I. DE C.V. d/b/a VOLARIS 

for an exemption from 49 U.S.C. § 41301 

Docket DOT-OST-2014-0167

ANSWER OF THE CITY OF HOUSTON 

The City of Houston (“Houston” or the “City”) respectfully submits this answer in 

support of the application filed on September 22, 2014 by Concesionaria Vuela 

Compaňía de Aviación, S.A.P.I. de C.V. d/b/a Volaris (“Volaris”) for authority to operate 

scheduled foreign air transportation between Houston and Guadalajara. 

Houston is fortunate that multiple carriers – from the U.S. and from Mexico – 

recognize the tremendous opportunities that the Houston region offers for providing 

additional services between the City and Mexico. Already the nation’s largest U.S.-

Mexico air services gateway, since the year 2000 the number of international 

passengers in Houston has increased by a phenomenal 60%; international traffic 

volume in 2014 is already up 10% over 2013. 

This growth reflects Houston’s role as one of the key engines of the U.S. 

economy. If the City of Houston were a State, it would rank 36th in population – ahead 

of New Mexico. The area’s gross product was $533 billion in 2013 – exceeding the 

GDP of all but 21 foreign countries. Houston is home to the headquarters of 26 of the 
Answer of the City of Houston 

Page 2

2 

2014 Fortune 500 companies and 28 of the 2014 Forbes Global 2000 companies,1 and 

is the leading job creator among U.S. cities.2 This remarkable economic strength 

provides opportunities for carriers, passengers and shippers, and ever-growing potential 

for additional air services to meet the community’s increasing needs. 

Houston’s strong and growing relationship with Mexico is a key component in the 

impressive traffic expansion being experienced at the City’s airports. Mexico is the 

greater Houston area’s largest foreign trade partner, with the annual transborder trade 

valued at $28.4 billion. Since 2000, Houston-Mexico trade has grown at an annual 

compound rate of 9.5 percent. Houston-Mexico 2014 air traffic is projected to increase 

by year’s end by 17 percent over that for 2013. When the new Federal Inspection 

Facility at Houston’s William P. Hobby Airport (“Hobby”) opens in the fall of 2015, 

enabling new international services in competition with international services at 

Houston’s Bush Intercontinental Airport, even more growth is expected. Houston 

strongly supports the ongoing efforts of the U.S. Government to secure additional 

liberalization of bilateral opportunities for U.S.-Mexico air service, and hopes that this 

can be accomplished by the end of 2014 so that carriers have the lead time they need 

for new service start-up planning. 

The new services proposed by Volaris will provide the greater Houston 

community with additional competition and air service options; Houston understands 

 

1 Additionally, according to Greater Houston Partnership data, more than 1200 Houston companies 

currently do business with Mexico; 44 have subsidiaries in Mexico; and numerous Mexican companies 

have subsidiaries in Houston. 

2 See, e.g., “18 Facts That Make Houston The Best City In America”, http://www.businessinsider.com/ 

houston-best-city-in-america-2014-6 (July 1, 2014) (noting that among the twenty most populous U.S. 

MSAs, Houston has – by far – achieved the highest percentage of jobs recovered since the end of the 

economic downturn. 
Answer of the City of Houston 

Page 3

3 

that the required designation by the Government of Mexico has already been 

transmitted to the U.S. Government. 

Accordingly, Houston welcomes and strongly supports the application of Volaris 

for Houston-Guadalajara authority, and asks that it be granted promptly by the 

Department. 

Respectfully submitted, 

Rachel B. Trinder 

Jol A. Silversmith 

ZUCKERT, SCOUTT & 

 RASENBERGER, L.L.P. 

888 Seventeenth Street, N.W. 

Washington, D.C. 20006-3309 

(202) 973-7927 

(202) 342-0683 (fax) 

rbtrinder@zsrlaw.com

jasilversmith@zsrlaw.com

For the City of Houston 

Dated: October 6, 2014 
CERTIFICATE OF SERVICE 

I certify that on this 6th day of October 2014, a copy of the foregoing was served 

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

 

Jol A. Silversmith 

rsilverberg@sgbdc.com, 

jjohnson@sgbdc.com, and 

mgoldman@sgbdc.com 

(Counsel for ABX Air) 

chuck.hill@airtransport.cc

(Air Transport International) 

msinick@ssd.com

(Counsel for Alaska Airlines) 

agoerlich@ggh-airlaw.com 

(Counsel for Allegiant Air) 

robert.wirick@aa.com, 

francis.heil@aa.com, and 

howard.kass@aa.com

(American Airlines) 

jcanny@amerijet.com

(Amerijet) 

jrichardson@johnlrichardson.com 

(Counsel for Amerijet) 

rpommer@atlasair.com

(Atlas Air) 

john@mietuslaw.com

(Counsel for Centurion Air Cargo) 

sascha.vanderbellen@delta.com, 

chris.walker@delta.com, and 

sametta.c.barnett@delta.com

(Delta Air Lines) 

cefelts@fedex.com

nssparks@fedex.com

(Federal Express) 

stephen.lachter@lachterlaw.com 

(Counsel for Frontier) 

jhill@cooley.com and 

perkmann@cooley.com

(Counsel for JetBlue Airways) 

matwood@cozen.com

(Counsel for Kalitta Air) 

kevin.montgomery@polaraircargo.com

and peter.beckett@polaraircargo.com

(Polar Air Cargo) 

robert.cohn@hoganlovells.com and 

patrick.rizzi@hoganlovells.com

(Counsel for Republic Airlines) 

ethan.blank@rjet.com

(Republic Airlines) 

temerson@skywest.com

(SkyWest Airlines) 

bob.kneisley@wnco.com and 

leslie.abbott@wnco.com

(Southwest Airlines) 

dkirstein@yklaw.com and 

jyoung@yklaw.com

(Counsel for Spirit Airlines) 

john.fredericksen@suncountry.com and 

thomas.ting@suncountry.com

(Sun Country) 

hershel.kamen@united.com, 

dan.weiss@united.com, 

steve.morrissey@united.com, 

thomas.bolling@united.com, and 
abby.bried@united.com

(United Airlines) 

sseiden@crowell.com and 

gmurphy@crowell.com

(Counsel for United Airlines) 

anita.mosner@hklaw.com and 

jennifer.nowak@hklaw.com

(Counsel for UPS) 

dsmalls@ups.com

(UPS) 

john.varley@virginamerica.com and 

barbara.russell@virginamerica.com

(Virgin America) 

charles.donley@squirepb.com

(Counsel for Volaris) 

paul.gretch@dot.gov, 

brian.hedberg@dot.gov, 

brett.kruger@dot.gov, 

reese.davidson@dot.gov, 

todd.homan@dot.gov, 

peter.irvine@dot.gov, 

laura.remo@dot.gov, and 

robert.finamore@dot.gov

(DOT) 

john.s.duncan@faa.gov

(FAA) 

ronald.williams@ustranscom.mil 

(USTRANSCOM) 

englets@state.gov and 

cristinasa@state.gov 

(State Department) 

info@airlineinfo.com