BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Joint Application of 

UNITED AIRLINES, INC. and 

SKYWEST AIRLINES, INC. 

for an exemption pursuant to 49 U.S.C. § 40109 

and designations (Houston-Mexico City, Mexico)

Docket DOT-OST-2014-0129 

Docket DOT-OST-2014-0130

REPLY 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: August 21, 2014 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Joint Application of 

UNITED AIRLINES, INC. and 

SKYWEST AIRLINES, INC. 

for an exemption pursuant to 49 U.S.C. § 40109 

and designations (Houston-Mexico City, Mexico)

Docket DOT-OST-2014-0129 

Docket DOT-OST-2014-0130

REPLY OF THE CITY OF HOUSTON 

The City of Houston (“Houston” or the “City”) respectfully submits this reply to the 

joint application filed on July 30, 2014 by United Airlines, Inc. (“United”) and SkyWest 

Airlines, Inc. (“SkyWest”) (together, the “United carriers”), and the answer filed by 

Southwest Airlines Co. (“Southwest”) on August 14, 2014, regarding the exemption 

authority requested by the United carriers, namely a U.S.-Mexico operating carrier 

designation for SkyWest in the Houston-Mexico City market (replacing United affiliate 

ExpressJet Airlines), as well as a marketing carrier designation for United to allow it to 

display its “UA” designator code on SkyWest’s flights on that route. 

The City’s interest is in promoting additional services and competition, and in 

seeing that all carriers desirous of providing Mexico services from Houston receive the 

authority they need. As the nation’s largest U.S.-Mexico air services gateway, and with 

one of the strongest regional economies in the United States, Houston is experiencing 

ongoing demand for additional Mexico services, including interest from multiple U.S. 

and Mexican carriers in starting up competitive services. 
Reply of the City of Houston 

Page 2 

Recently, in connection with other requests for Houston-related Mexico authority, 

DOT has reaffirmed its willingness to consider designation reallocations when in the 

public interest (e.g., in its notices in dockets DOT-OST-2014-0058/DOT-OST-2014-

0059 and DOT-OST-2014-0100/DOT-OST-2014-0101). Houston welcomes this procompetitive stance. However, the City hopes very much that a bilateral agreement with 

Mexico can be reached before the end of 2014 that will obviate the need for any carrier 

to seek reallocation of designations held by another carrier. Both United and Southwest 

have made substantial facility funding commitments to the City to accommodate current 

and future growth, and major expansion and development projects are underway at 

both George Bush Intercontinental (“IAH”) and William P. Hobby (“HOU” or “Hobby”) 

airports. At IAH, a new concourse at Terminal B recently opened and a new 15 gate 

international terminal is being planned. At Hobby, a new international terminal will open 

in 2015, which will support new services between Houston and Mexico, the Caribbean, 

and northern South America. Furthermore, carriers from Mexico are seeking to add 

new service to Houston. 

In order for all affected carriers on both sides of the border to be able to provide 

the services that traffic demands, unlimited third and fourth passenger freedoms are 

essential. If this liberalization of the U.S.-Mexico bilateral agreement can be achieved 

on a timely basis, then the grant of transfer requests such as that of the United carriers 

in these dockets will become either unnecessary or merely routine, and will not impact 

the opportunities remaining for other carriers desirous of serving the same city-pair. 

Houston is very much aware that the U.S. Government over many years has 

diligently sought expanded opportunities with Mexico, and that various obstacles remain 
Reply of the City of Houston 

Page 3 

to complete liberalization. The City hopes that, at a minimum, an agreement providing 

unlimited third and fourth freedom designations can be achieved before the end of this 

year so that the United carriers, Southwest, and all other interested carriers have 

available to them the designations they need in order to meet current and future traffic 

demand. 

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: August 21, 2014 
CERTIFICATE OF SERVICE 

I certify that on this 21st day of August 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 

msinick@ssd.com

(Counsel for Alaska Airlines) 

rpommer@atlasair.com

(Atlas Air) 

robert.wirick@aa.com, 

benjamin.slocum@aa.com, 

francis.heil@aa.com, and howard.kass@aa.com

(American Airlines) 

sascha.vanderbellen@delta.com, 

chris.walker@delta.com, and 

sametta.c.barnett@delta.com

(Delta Airlines) 

cefelts@fedex.com and 

nssparks@fedex.com

(Federal Express) 

jhill@cooley.com and perkmann@cooley.com

(Counsel for JetBlue Airways) 

matwood@cozen.com

(Counsel for Kalitta Air) 

kevin.montgomery@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, 

karine.faden@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) 

paul.gretch@dot.gov, brian.hedberg@dot.gov, 

brett.kruger@dot.gov, reese.davidson@dot.gov, 

todd.homan@dot.gov, peter.irvine@dot.gov, and 

laura.remo@dot.gov

(DOT) 

john.s.duncan@faa.gov and john.allen@faa.gov

(FAA) 

ronald.williams@ustranscom.mil 

(USTRANSCOM) 

englets@state.gov and cristasa@state.gov 

(State Department) 

info@airlineinfo.com