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

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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 U nited 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 Carr iers have liberal, if not
limitl ess , 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, t he 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 operat or.

1 Open and Fair Sk ies Partnership White Paper and Presentation from http://www.openandfairskies.com/subsidies/ as accessed on May 25 th 2015T h e amalgamation of these factors enables the Gulf Carriers to have an artificially deflated cost

structure. SWAP A submits that this creates a situation where in 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 the n 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 p olicy. 2 In 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. S WAPA also asserts that the Gulf Carrier issue is not related to US Open Skies policy despite
claims to the cont rary. 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. I f 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

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