May 29, 2015

The Honorable Anthony R. Foxx

Secretary of Transportation

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue SE

Washington, DC 20590-0001

The Honorable John F. Kerry

Secretary of State

U.S. Department of State (State)

2201 C Street NW

Washington, DC 20520

The Honorable Penny Pritzker

Secretary of Commerce

U.S. Department of Commerce (Commerce)

1401 Constitution Avenue, NW

Washington, DC 20230

Dear Secretary Kerry, Secretary Foxx and Secretary Pritzker:

The Southwest Airlines Pilots’ Association (SWAPA) represents the 8,000 pilots of Southwest Airlines

who operate more than 3,600 daily flights which transport 1 out of every 4 domestic airline passengers. 

After reviewing the evidence presented by American, Delta, and United Airlines, SWAPA believes that 

the US government must seek consultations to address the blatant subsidies received by the Gulf 

Carriers (Emirates, Etihad, and Qatar). 1

The evidence presented by American, Delta, and United is clear -- the Gulf Carriers have liberal, if not

limitless, access to free capital that is not available to the US airline industry or any true for-profit 

business. In addition to direct capital infusions, the Gulf Carriers also enjoy preferential government 

policy, such as the illegality of labor unions in the UAE, and reduced fundamental operating costs, e.g., 

airport fee exemptions. Moreover, the evidence shows that Emirates, in particular, benefits from 

management that includes government officials who actively control not just the airline itself, but also 

other related organizations, including the safety regulatory agencies and the Dubai airport operator. 

 

1 Open and Fair Skies Partnership White Paper and Presentation from 

http://www.openandfairskies.com/subsidies/ as accessed on May 25th 2015
The amalgamation of these factors enables the Gulf Carriers to have an artificially deflated cost 

structure. SWAPA submits that this creates a situation wherein no US airline, whether a network or 

even an ultra-low cost carrier, can be expected to compete, now, or in the future. The Gulf Carriers can 

effectively add unsustainable capacity into a given market and then proceed to offer below market fares 

for a period of time defined only by how quickly the other carriers are forced to abandon the given

market. 

Make no mistake, SWAPA firmly believes in the concept of US Open Skies and international air 

transportation policy.2In particular, SWAPA believes that Southwest Airlines has in the past, and will 

continue to in the future, benefit from this policy as the Company expands into the international 

markets. SWAPA strongly opposes any effort to use the issue of Gulf Carrier subsidies to make a change 

to the US Open Skies policy in such a way that it would limit the Company’s potential international 

growth. SWAPA also asserts that the Gulf Carrier issue is not related to US Open Skies policy despite 

claims to the contrary. The issue on the table is whether or not the Gulf Carrier home countries are 

complying with the agreements they signed with the US government. If the US government does not

seek consultations on this issue, the precedent will be set that the US government simply has no 

intention of enforcing any Open Skies treaty language. 

For the Southwest Airlines Pilots’ Association,

Captain Paul Jackson

President

 

2 http://www.gpo.gov/fdsys/pkg/FR-1994-11-07/html/94-27450.htm