BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

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Application of

ATLAS AIR, INC. Docket OST -2009-0267

for an Emergency Exemption

ANSWER OF THE CITY OF HOUSTON

AND THE GREATER HOUSTON PARTNERSHIP IN SUPPORT OF ATLAS AIR

EMERGENCY EXEMPTION APPLICATION

Communications with respect to this document should be sent to:

Mario C. Diaz

Director

Robert R. Wigington

Deputy Director

Department of Aviation

CITY OF HOUSTON

16930 John F. Kennedy Blvd.

Houston, TX 77032

(281) 233-3000

(281) 233-1859 (fax)

Jeff Moseley

Chief Executive Officer

GREATER HOUSTON PARTNERSHIP

1200 Smith Street, Suite 700

Houston, TX 77002

(713) 844-3600

(713) 844-0200 (fax)

Dated: May 24,2010
BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

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)

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)

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Application of

ATLAS AIR, INC. Docket OST -2009-0267

for an Emergency Exemption

ANSWER OF THE CITY OF HOUSTON

AND THE GREATER HOUSTON PARTNERSHIP IN SUPPORT OF ATLAS AIR

EMERGENCY EXEMPTION APPLICATION

The City of Houston and the Greater Houston Partnership (collectively, "Houston"

or the "Houston Parties") strongly support the application for an emergency exemption

filed by Atlas Air, Inc. ("Atlas"), and urge that it be granted immediately. Absent an

immediate grant of authority, the "Houston Express" service that has been operated for

nearly a decade between Houston and Luanda, Angola, and which is of significant

importance to Houston businesses, Houston passengers and the Houston economy, will

be halted, causing significant adverse impact. Public interest considerations favor

granting Atlas' application.

The Houston Express is a private international air charter organized by the U.S.-

Africa Energy Association ("USAEA") to provide critically needed flights between

Houston and Luanda for members and employees of USAEA entities - a group that

includes some 100 energy and energy-related entities in the Houston area, including

major Houston companies. The flights are an essential element in the ability of those

companies to manage significant energy-related projects in West Africa. Angola is one
Answer of the Houston Parties

Page 2

of Houston's key trading partners; more than 220 Houston companies report doing

business there, and at least fifteen Houston companies operate subsidiaries in Angola.

In 2009 the Houston Express parties selected Atlas to take over the operations

from another U.S. carrier starting in early 2010. Atlas filed its applications for authority

more than six months ago in October 2009, allowing ample time for agency processing

prior to the planned spring 2010 transfer of operations. On April 15, 2010, the

Department issued its Show Cause Order finding Atlas to be a U.S. citizen, and fit,

willing and able (DOT Order 2010-4-8); no objections were filed to that Order. Houston

understands that Atlas has provided the Department with all required documentation

necessary for issuance of final authority. The delay in issuing final authority to Atlas

threatens continuation of the Houston Express flights.

Should this service be interrupted, the adverse consequences to the Houston

area would be extensive. Many Houston passengers would likely be stranded in Angola,

and Houston businesses would suffer a damaging interruption to their operations. The

estimated economic impact from the Houston Express flights on the Houston region is

over $120 million annually. As the Department is aware, the Houston economy, which

has remained strong throughout the downturn, is a critical element of the U.S. economy,

with a GOP that exceeds that of many foreign nations. Houston is well known as the

world's "energy capital", and its energy-related businesses make a vital contribution to

ensuring the nation's energy supply. The public interest would not be served by

permitting this interruption, and as shown by Atlas, there is ample precedent for granting

an emergency exemption.
Answer of the Houston Parties

Page 3

WHEREFORE, the Houston Parties respectfully request that the Department

grant Atlas' application and issue an emergency exemption no later than May 26,2010.

Respectfully submitted,

M io C. Diaz

For e City of Houston and the

Greater Houston Partnership

Dated: May 24,2010
robert.cohn@hoganlovells.com

jeff.shane@hoganlovells.compatrick. rizzi@hoganlovells.com

adam.kokas@atlasair.com

rpommer@atlasair.com

wdean@thompsoncoburn.com

ebrown@thompsoncoburn.comsmcgowan@thompsoncoburn.com

mIbenge@zsrlaw.com

esta.rosenberg@dot.gov