BEFORETHEDEPARTMENTOFTRANSPORTATIONOFFICEOFTHESECRETARYWASIDNGTON,DCJointApplicationofALASKAAIRLINES,INC.andAMERICANAIRLINES,INC.fortransferofinternationalrouteauthoritypursuantto49U.S.C.§§40109,41105)))))))))_________________________________)ApplicationofALASKAAIRLINES,INC.foramendmentofexemption))))))_________________________________)ApplicationofAMERICANAIRLINES,INC.foramendmentofexemption))))))_________________________________)JOINTREPLYOFDocketDOT-OST-2015-0025DocketDOT-OST-2005-20406DocketDOT-OST-2010-0222ALASKAAIRLINES,INC.ANDAMERICANAIRLINES,INC.TOANSWEROFDELTAAIRLINES,INC.Communicationswithrespecttothisdocumentshouldbeaddressedto:JeremyRossSeniorAttorney,LitigationandRegulatoryandDirector,LegalAlaskaAirlines,Inc.I9300InternationalBoulevardSeattle,Washington98I88jeremy.ross@alaskaair.comDavidHeffernanCozenO'ConnorTheArmy&NavyClubBuilding1627IStreet,N.W.Suite1I00Washington,D.C.20006(202)463-2537dheffernan@cozen.comCounselforAlaskaAirlines,Inc.DATED:March6,20I5HowardKassVicePresident-RegulatoryAffairsRobertA.WirickManagingDirector,RegulatoryandInternationalAffairsAbigailDonovanDirector,CongressionalandFederalAffairsAmericanAirlines,Inc.IIOI17thStreet,N.W.Washington,D.C.20036(202)326-5153howard.kass@aa.comrobert.wirick@aa.comabigail.donovan@aa.comBEFORETHEDEPARTMENTOFTRANSPORTATIONOFFICEOFTHESECRETARYWASHINGTON,DCJointApplicationofALASKAAIRLINES,INC.andAMERICANAIRLINES,INC.fortransferofinternationalrouteauthoritypursuantto49U.S.C.§§40109,41105)))))))))_______________________________)ApplicationofALASKAAIRLINES,INC.foramendmentofexemption))))))______________________________)ApplicationofAMERICANAIRLINES,INC.foramendmentofexemption))))))_______________________________)DATED:March6,2015JOINTREPLYOFDocketDOT-OST-2015-0025DocketDOT-OST-2005-20406DocketDOT-OST-2010-0222ALASKAAIRLINES,INC.ANDAMERICANAIRLINES,INC.TOANSWEROFDELTAAIRLINES,INC.AlaskaAirlines,Inc.("Alaska")andAmericanAirlines,Inc.("American")(collectively,the"JointApplicants")herebyjointlyreplytotheanswerofDeltaAirLines,Inc.("Delta")filedinresponsetotheJointApplicants'requestthattheDepartmentapprovethetransfertoAmericanof

### Joint Reply of Alaska Airlines, Inc. and America

n Airlines, Inc

. international route authority held by Alaska authorizing

sc heduled foreign air transportation

of persons, property and mail between Los Angeles, California, and Mexico City, Mexico.

1 

### American plans
to commence double-daily nonstop service on the route on June 4, 2015. Alaska will remain an active competitor

on the route by codesharing

on American's
Los Angeles-Mexico

City flights. No party other than Delta filed an answer

to the joint app lication

. 2 

### Delta's answer

is nothing more than

a spurious effort
to obstruct and delay implementation of American's new nonstop service on the Los Angeles-Mexico

City route.

3 

### The Joint Applicants' agreement

to transfer the route authority

is the type of market-based transaction that the Department has routinely approved without consolidating applications from other carriers. There
is no legal or practical scenario whatsoever

in which the authority

at issue will be transferred,

or awarded,

to Delta.
If the Department fails to promptly approve the ro ut e transfer application, Alaska (which has consistently operated the route either on
a once- or twice-daily basis in full compliance with the The Joint Applicants also requested that

t h e Department amend their current exe m ption authorities

in

t h e captioned dockets

to (i) allow American

to serve the Los Angeles-Mexico
City route with its own aircraft, and (ii) permit Alaska
to display
its two-letter designator code on American's
flig ht s between Los Angeles and Mexico City. Alaska holds an exemption authorizing

it to engage

in scheduled foreign air transportation

of persons, property and mail between Los Angeles and Mexico City. Notice of Actio

n Taken dated Aug

. 25, 2014 (DocketDOT-OST2005-20406). American hold

s an exemption authorizing

it to hold out codeshare service only between Los Angeles and Mexico City

. Notice of Action Taken dated July 19, 2012 (Docket DOT-OST-2010-0222); renewal currently pending. The Joint Applicants requested that both exemptions

be reissued for
a two-year period. In addition

to answering
the joint application, Delta filed

a n Application

for Exemption

(in DocketDOT-OST2015-0042)

. The Joint Applicants hereby reserve the right to file

a separate answer
to Delta
's application

. The Joi n t Applicants will not address here that continge

n t application's
lack of comparative merit because the Department's rejection
of Delta's answer and prompt approva

l of the joint application would render moot Delta's application.

I n fact, Delta's app lic ation

is not only contingent
but wholly theoretical because,

as discussed above

in text, either

t h e Department
will promptly approve the Joint Applicants'

rout
e transfer application

or the Joint Applicants will withdraw the app licati on and Alaska will contin

u e to ope

r ate the Los An ge

l es-Mexico City route. Of course,

if the Department approves the joint appl ication before the 15 calendar day period for filing answers

to the Delta application expires, the Joint Applicants will have no need to submit
an answer
to the Delta application. It shou ld be noted that Delta once held the authority

to serve Los Angeles-Mexico

City but returned

it to the Department, which ultimately
led to Alaska securing the route. 

### See Order 2005-2-8, Feb.

I 4, 2005,
at 2
. In the Los Ange

l es-Mexico

C it y market, two U.S. carriers, Delta and United Air Lines, Inc

. ("United"), held underlying a uthority and designation under the U.S.

- M e xico bilateral agreement

to provide dir ec
t carrier (own aircraft) serv

i ces. How ever, by letter submitted January 21, 2005, Delta notified the Department that
it would terminate service

in this market on January 31, 2005.



### 2

### Joint Reply of Alaska Airlines, Inc. and American Airlines, Inc. terms of the authority) will continue

to operate the route. As demonstrated below, Delta's opposition

to the Joint Applicants' route transfer application

is wholly without merit and provides no basis for delaying

its approval.

4 

### The Joint Applicants further reply to Delta's answer

as follows: 1. The Department generally defers
to and approves market-based transactions such as this one without opening

a carrier selection proceeding under the statutory standard for approving certificate transfers.

5 

### Despite the Department's longstanding practice, Delta argues that the Joint Applicants' route transfer application should not be reviewed under this standard and the Department must initiate

a proceeding whereby Delta and other carriers would receive comparative consideration

of alternative proposals

to use the route authority,
for the sole reason that Alaska holds exemption (not certificate) authority

to serve the Los Angeles-Mexico

City route.
In fact, the Department
has both the statutory authority and discretion

to approve the route transfer application, which meets both the route transfer and public interest tests for approval.

6 

### 2. Delta's argument

is predicated

on nothing more than inapplicable language excerpted from

a single DOT Order from 1997. That 

## case-1997 US-Argentina All-Cargo Frequency Proceeding

- involved the transfer
of under-utilized,

if not dormant, cargo frequencies, and not the transfer
of fully utilized exe mption authority involving passenger service,

as is the case Delta'

s efforts should be seen for what they are: anti-consumer.

I f Delta

w e r e to receive

th e A la ska designation, both Alaska and American would be forced
to exit the route and the number
of competitors would be reduced
by two

. Answer
of Delta Air Lines, Feb. 26,2015 (Docket DOT-OST-2015-0025)

, at 1-2. 

### See Joint Application

of Alaska Airlines, Inc. and American Airlines

, In c. for T ransfer of Int erna tional Route Authority, Feb.

I I, 20
I 5 (Docket DOT -OST-20

I 5-0025),

at 3-8. 

## 3

# Joint Reply of Alaska Airlines, Inc. and American Airlines, Inc. with the Joint Applicants' route transfer application. There, the Department initiated

a carrier selection proceeding

to reallocate unused
or significantly underutilized route authority.

7 

# The Department cited that case in its recent decision

to hold

a carrier selection proceeding

in light of Delta's failure
to adequately utilize its valuable Seattle- Tokyo (Haneda) slot pair. There, the Department stated that due to Delta's "extensive winter-season cutbacks,"
the public interest required that the Department make

a "fresh examination"

of Delta's use of its Seattle-Haneda slot pair to determine

if the public interest would be better served by reallocating

theunderutilized slot pair to another carrier.

8 

# Those utilization concerns

do not apply
in this case because Alaska has fully and consistently used its Los Angeles-Mexico

City authority

to operate single-daily

or twice-daily service for many years. Significantly, Delta never alleges any deficiency

in Alaska's utilization

of the Los Angeles-Mexico

City route authority, because Delta knows that no such deficiency exists.

9 

# See Order 97-11-35, Nov. 20, 1997,
at 6 ("(t]he various submissions

we have received

on the issue of Argentina service indicate

a substantial evolution

in the position and operations

of a number
of U.S. carriers with frequency allocations

for Argentina from the time that we issued their respective authorizations").

One of the incumbent carriers, Challenge
Air Cargo, objected that DOT should include the frequency allocations

of all of the U.S. carrier incumbents within the scope of the carrier selection proceeding. Significantly, however, DOT refused to do so; rather, DOT only included

in the proceeding unused
or underutilized frequency allocations.


# See Order 97- 12-19, Dec

. 12, 1997,
at 3 ("[n]or are we persuaded that the public interest warrants expanding
the scope of this proceeding

to include the frequency allocations

of other incumbent carriers. [They] are using their frequencies fully, and no party has presented any evidence that would question the use by these carriers
of their frequency allocations or otherwise warrant our placing those allocations

in issue

. "). Similarly,

in this case, Alaska has been fully using its Los Angeles-Mexico

City route authority and Delta has not presented any evidence that would warrant subjecting the authority

to a carrier selection proceeding. 

# See Petition
of Delta Air Lines, Inc. in the Matter
of U

. S.-Haneda Combination Services Allocation Proceeding, Order 2015-1-14,
Jan

. 15,2015,

at 4. Delta also cited an unrelated statutory provision explicitly prohibiting
the transfer
of slot exemptions

at Ronald Reagan Washington National Airport ("DCA") where the transaction

is not part of an airline merger
or acquisition

. That statutory provision, however, applies exclusively

to DCA exemption slots:

it does not, and was never intended

to, limit the Department's authority and discretion

to approve the transfer
of other forms of exemptions
and other operating authorities, such as Alaska's Los Angeles-Mexico

City authority and even other slots at DCA. Had Congress intended

to create
an explicit prohibition

on non-certificate route transfers occurring outside
of mergers

or acquisitions,

it would have done so

. 

# 4JointReplyofAlaskaAirlines,Inc.andAmericanAirlines,Inc.3.ThereisampleprecedentforDOTapprovalofroutetransferswithouttheneedforacarrierselectionproceedingincasesthatdonotinvolveanairlinemergeroracquisition.Forexample,in1990,NorthwestAirlines,Inc.("Northwest")andHawaiianAirlines,Inc.("Hawaiian")jointlyappliedforapprovaltotransfertwoofHawaiian'sPacificroutestoNorthwest.IndismissingDelta'sargumentsforacarrier selectionproceedinginthatcase,theDepartmentstatedthatit"wasundernoobligationtoconsidercompetingapplications..."andthatithada"longstandingpolicynottoconvertaroutetransferproposalintoasection401(d)proceedingunlesstherearestrongpublic policyreasonsforreviewingtheserviceneedsandstatusofamarket."10Nosuchpolicyreasonsarepresenthere.Similarly,intheHorizonAir("Horizon")-SanJuanAirlines("SanJuan")routetransfercase,UnitedExpress,likeDeltahere,opposedthetransferbySanJuanofitsU.S.-CanadatransbordercommuterauthorityandrelateddesignationtoHorizonandcalledontheDepartmenttoholdacarrierselectionproceeding.Notably,thiscasedidnotinvolvethetransferofcertificateauthority(andwasnotrelatedtoanairlinemergeroracquisition),yettheDepartmentdeniedUnitedExpress'srequest,andinsteadapprovedtheroutetransferapplicationpursuanttothepredecessorstatutoryprovisionto49U.S.C.§41105.IndenyingUnitedExpress'srequestforacarrierselectionproceedingundertheAshbackerdoctrine,11theDepartmentconcludedthatitwas"nototherwiserequiredbylawtoconsolidateroutetransferapplicationswithcompetingapplicationsfor10JointApplicationofNorthwestAirlines,Inc.andHawaiianAirlines,Inc.forCertificateTransfer,Order91-3-20,Mar.11,1991,at7-8.11AshbackerRadioCorp.v.FCC,326U.S.327(1945).DOThasrecognizedthat,inorderfortheAshbackerdoctrinetoapply,applicationsmustbemutuallyexclusive,sothatthegrantofonewouldpreclude"realisticconsideration"andgrantoftheother.Order95-2-28,Feb.I0,1995,at5.Ashbacker,however,doesnotapplytoapplicationsseekingdifferentreliefunderdifferentstatutoryprovisions.Forexample,applicationsforroutetransfersandapplicationsfornewoperatingauthorityare"notsufficientlyparalleltotriggerAshbackerconstraints."Order92-3-49,Mar.23,I992,atII.5

### Joint Reply of Alaska Airlines, Inc

. and American Airlines, Inc

. the same authority."

12 

### In its order transferring non-certificate authority

to Horizon, the Department recognized that Congress

" intended that route transfers
be treated separately" under section 401 (h), the predecessor statute

to 49 U.S.C.

§ 41105, from awards ofroute authority under 401(d).

13 

### The Department
also recognized that the route transfer

at issue in the Horizon-San Juan case was "the result of arm's-length bargaining between Horizon and San Juan; that
it [would] not affect the number
of carriers on the subject trans-border routes or the utilization

of available U.S. carrier route rights; and that the service proposed

by Horizon [was] consistent with the [bilateral agreement]."

14 

### All of these

e l ements apply
to the Joint Applicants' proposed route transfer application
and support the Department's prompt dismissal

of Delta's arg uments

in favor of a carrier
se lection proceedin

g.

15 

### Likewise,

w h en Pan American World Airways ("Pan Am") and United applied for approval of Pan Am's transfer
of its Pacific routes
to United

- an arrangement
that

a l so did not involve

a merger-the Department dismissed Continental Airlines' assertions that the Ashbacker 

### doctrine required the Department

to institute

a carrier
se
l ection proceeding.
The Department stated that "there [was] no basis for awarding Pan Am's Pacific authority

to another carrier," and that the app
li cation of Ashbacker 

### would

"i nj ect issues of public convenience
and necessity that are different from the standards
for approval
of a route transfer" thereby "chang[ing]
the nature of [the] case."

16 12 Joint Request
of Horizon Air Ind ustries, Inc. d/b/a
H orizon Air

a n d San Juan Airlines, Inc

. to Transfer Trans border Commuter Designations
and Related Authority

(U .S. -Can ada), Order 89-5-14

, May 4, 1989,
at 4. 

### !d. 1 4 

### ld.at3

. 15 Just as Delta filed an app licat ion for Los Ange

l es-Mexico

C it y operating authority

in the hope of triggering a carr ier selection proceeding, United Express had

a lso concurrently filed applications

for operating authority

in the markets

at is sue in the Horizon-San Juan route transfer. The Department should dismiss Delta's intervention

in this case, just as it did United Express's app lic ations

in the Hori zon -S an Juan route transfer proceeding. 1 6 Pacific Division Transfer Case, Order 85-6-44, June 13, 1985,
at 10

. 

## 6JointReplyofAlaskaAirlines,Inc.andAmericanAirlines,Inc.Delta'sAshbackerargumenthaspreviouslybeenraisedintheLosAngeles-MexicoCitycontextbyAlaska,whenitattemptedtopersuadetheDepartmenttoholdacarrierselectionproceedingratherthanapprovethetransferofLosAngeles-MexicoCitycertificateauthorityfromPanAmtoUnitedin1992.Inthatcase,theDepartmentrejectedAlaska'sargumentforacarrierselectionproceedingeventhoughPanAmwasfailingtooperatetherouteandUnitedheldadominantpositionintheWestCoast-Mexicomarkets.TheDepartmentstatedthatitspolicywas"nottoentertaincompetingapplicationsforrouteauthoritythatisthesubjectofaproposedroutetransfer."17TheDepartment'sreasonsforrefusingtoinitiateacomparativecarrierselectionproceedinginthatcaseareequallyvalidhere:1)American,thecarriertowhichtherouteisbeingtransferred,willprovide extensiveserviceontherouteand"intendstousetherouterightstofulladvantage";2)Americanwill"provideon-lineconnectingserviceatLosAngelesfromanumberofpoints"initsnetwork;3)competitionwillbeenhancedandAmerican's"competitiveinfluenceshouldprovepositive,bothbetweenU.S.andforeigncarriersandamongU.S.carriersinthewesternU.S.-Mexicomarkets";4)Americanwill"bringastrongpresencetoamarketnowdominatedbyforeigncarriers";and5)theroutetransferwillresultina"strongU.S.carrier,withsubstantialbehindgatewayfeed...significantlyimprov[ing]U.S.-flagpresenceinthismarketwheremoretrafficisnowcarriedonforeigncarriers."18IfAshbackerdidnotapplyintheNorthwest-HawaiianandtheHorizon-SanJuancases,orinthePanAm-Unitedcase(wherethefactsinsupportofcarrierselectionweremuchmorecompelling),itcertainlyshouldnotapplyhere,whereAlaskaisfullyoperatingtheroute.17JointApplicationofUnitedAirLines,Inc.andPanAmericanWorldAirways,Inc.forCertificateTransfer,Order92-3-49,Mar.23,1992,at7.18!d.at8-9.7

### Joint Reply of Alaska Airlines, Inc. and American Airlines, Inc. The Department also has denied requests for Ashbacker 

### carrier selection when

a restricted bilateral market

is due to be liberalized,

as is now the case with U.S.-Mexico.

19 

### This
is only logical: why hold

a burdensome and time-consuming carrier selection proceeding when Delta will soon have an opportunity

to enter this route under

a liberalized bilateral regime? 4. Delta's argument that exemptions cannot be transferred

is further contradicted

by the Department's longstanding certificate streamlining policy (DOT-OST-2005-22228), pursuant

to which the Department
has consolidated U.S.-Mexico exemptions into U.S.-Mexico certificates

in response

to carrier requests. For example,
by Order 2010-3-12,
the Department converted more than 40 U.S.-Mexico exemptions held by Delta and Northwest into certificate authority

at the request
of Delta. Thus, today, carriers typically hold various U.S.-Mexico routes
in the forms of exemptions
and certificates.
The distinction between certificate and exemption authority
for U.S.- Mexico routes has all but disappeared, thereby invalidating

the sole basis for Delta's claim that the Department lacks authority and discretion

to promptly approve the Joint Applicants' route transfer application.

5. Delta's "form over substance" argument about the transferability

of certificates
but not exemptions

is also undercut
by the fact that the Department, pursuant

to 49 U.S.C.

§ 

### 41105, has repeatedly approved the transfer
of exemptions, frequencies,
and statements

of authorization when bundled with certificate authority.

20 

### There

is no logical basis for arguing that the statute permits the 19 

### See Application ofNorthwest Airlines,
Inc

. for Exemption

(U

. S

. -Australia)

, Order 91-8-30

, Aug. 16, 1991, a t 4 (in dismissin

g D e lta's contention that DO T wa
s required

to hold

a carrier selection proceeding, DOT stat
e d that "[i]n any case

..

. the designation limitations will no longer apply, and the United States will be entitled

to designate additional carriers for U.S.-Australia services

. Thus, the award of authority

to Northwest will not preclude the grant of authority

to others

. ")

. 2 0 

### See,

e. g., Joint Application

of Continental Airlines,
Inc
., Continental Micronesia,

In c

. , Air Micronesia,
Inc. and United Air Lines, Inc., Order 2011-3-14,
Feb

. 3, 201

I (Docket DOT-OST

- 2010-0163); Joint Application

of Southwest Airlines Co. and AirTran Airways,

In c

. , Order

2 011

- 11-1

7 , Sept.
15

, 2011 (Docket DOT

- OST

- 2011

- 0051); Joint Application

of Delta Air Lines, Inc., Northwest Airlines, Inc., Compass Airlines, Inc. and Mesaba Aviation, Inc., Order 2009-1-8, Dec. 29,2008 (Docket DOT-OST-2008-0162)

. 

## 8

# Joint Reply of Alaska Airlines, Inc. and American Airlines, Inc. Department

to transfer these types of authorities when bundled with certificate authority (as, e.g., the Department

did when

it approved
the transfer
of Northwest Airlines' exemptions
and frequencies along with certificates

to Delta
as part of the Delta/Northwest merger), but does not permit the transfer
of a stand-alone exemption.

21 

# 6.
If the Department were to grant Delta's request for
a carrier selection proceeding,

it would set
a dangerous precedent
for allowing carriers

to challenge
the right of incumbents

to continue

to operate their services

in limited-entry markets where they are fully utilizing the operating rights but
a challenger claims its service somehow would generate

a public benefit.

It 

# is undisputed that Alaska has consistently utilized
its Los Angeles-Mexico

City route authority
for at least once-daily service. Alaska's agreement

to transfer the route
to American,
and the related application

the Joint Applicants have submitted

to the Department, provide
no basis for Delta
to claim

a right to a carrier selection proceeding.

In addition, grant of Delta's request would place
at risk competition

in the Los Angeles-Mexico

City market: rather than adding American

as a potent competitor
and allowing Alaska

to continue

in the market, those two options for consumers would be totally excluded from the market

in place of Delta

. Fortunately, both existing law and common sense support the swift rejection
of Delta's objection and the confirmation

of existing policy by means ofthe Department's prompt approval
of the joint application. In conclusion, Delta has not raised any valid basis for the Department

to initiate

a carrier selection proceeding

in this case. The Joint Applicants have demonstrated
that the proposed transfer to American

of Alaska's authority

to serve the Los Angeles-Mexico

City market meets the 2 1 

# The Department
also has broad authority

to approve the Joint Applicants' application

as being
in the public interest under 49 U.S.C.

§ 40109

. See 

# Joint Application

of Alaska Airlines,
Inc

. and American Airlines, Inc. for Transfer
of International Route Authority, Feb

. II, 2015 (Docket DOT-OST-2015-0025),

at 4-5. The Department has approved transfers
of non-certificate authority without invoking
49 U .S.C.

§ 

# 41105
or initiating

a carrier selection proceeding

. See,

e

. g.
, Notice of Action Taken dated Aug

. 2, 20
I 0 (approving temporary transfer
of Brazil frequencies from United

to US Airways and amending
US Airways' exemption authority under 49 U.S

. C. § 

# 40109) (DocketDOTOST -20

I 0-0183

) .



# 9

### Joint Reply of Alaska Airlines

, Inc. and American Airlines, Inc. standards under both the route

/ certificate transfer test and the public interest test. Therefore

, the Joint Applicants respectfully request that the Department dismiss Delta's objection and promptly approve the route transfer application

so that American can implement

its new double-daily nonstop service
as planned
on June 4, 2015. Respectfully submitted, Jeremy Ross

Howard Kass Senior Attorney, Litigation and Regulatory

Vice President

- Regulatory Affairs and Director, Legal Alaska Airlines, Inc. 19300 International Boulevard Seattle

, Washington 98188 j er e m y. ro ss@ alaskaair.com David Heffernan Cozen 0' Connor The Army



### & Navy Club Building 1627

I Street, N.W. Suite 1100 Washington, D.C. 20006 (202) 463-2537 dheffernan

(@, cozen.com Counsel for Alaska Airlines

, Inc. DATED: March

6, 2015

10 Robert A. Wirick Managing Director, Regulatory
and International Affairs Abigail Donovan Director, Congressional

and Federal Affairs American Airlines, Inc

. 1101

1 

# ih Street, N.W. Washington, D.C. 20036 (202) 326-5153 howard.kass

@, aa.com robert. wi1ick
@ aa.com abigail.donovan

( W,aa.comCERTIFICATEOFSERVICEIcertifythatonMarch6,2015,IservedbyelectronicmailacopyoftheforegoingJointReplyuponthoseaddresseeslistedbelow:englets@state.gov(DepartmentofState)cristinasa@state.gov(DepartmentofState)brian.hedberg@dot.gov(DepartmentofTransportation)todd.homan@dot.gov(DepartmentofTransportation)peter.irvine@dot.gov(DepartmentofTransportation)laura.remo@dot.gov(DepartmentofTransportation)brett.kruger@dot.gov(DepartmentofTransportation)john.s.duncan@faa.gov(FederalAviationAdministration)dan.weiss@united.com(United)steve.morrissey@united.com(United)gmurphy@crowell.com(CounselforUnited)sascha.vanderbellen@delta.com(Delta)chris.walker@delta(Delta)patrick.rizzi@hoganlovells.com(Republic)bob.kneisley@wnco.com(Southwest)jhill@cooley.com(JetBlue)dkirstein@yklaw.com(Spirit)barbara.russell@virginamerica.com(Virgin)matwood@cozen.com(Frontier)Thomas.ting@suncountry.com(SunCountry)KennethC.Hines