1 BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C.

___________________________________________ _____ )

Application of )

)

SOUTHWEST AIRLINES CO. )

) Docket DOT

- OST

- 2014

- 0223

For an exemption under 49 U.S.C. § 40109 to engage in )

fore ign scheduled air transportation of persons, property )

and mail between United States and Belize )

)

_________________________________ _______________

COMMENTS OF THE

SOUTHWEST AIRLINES PILOTS’ ASSO C I ATION

Communications with respect to this document should be addressed to:

Paul Jackson

Government Affairs

Southwest Airlines Pilots ’ Association

1450 Empire Central

Dallas, TX 75247 (800) 969

- 7972

pjackson@swapa.org2 I. COMMENTS

The Southwest Airlines Pilots ’ Association (“SWAPA”) is the exclusive b argaining

representative for almost 8,000 Southwest Airlines pilots

.

SWAPA strongly supports Southwest Airline’ s application for exemption to engage in

scheduled foreign air transportation between points in the United States and points in Belize.

The US

– Belize market currently lacks low fare competition with service to the US only

provided by American, Delta, a nd United Airlines. In fact over the past year ending October of

2014 the average one

- way net fare to/from the US was $333 for an average length of haul of

only 1,532 miles 1

. Net one

- way fares for the same period in similar domestic US markets with a

lo w fare competitor and a similar average length of haul were significantly lower. For example

in Chicago to Las Vegas the average net one

- way fare was $223

, Denver to Orlando $212

, Ft.

Lauderdale/Miami to Bogota $291, and Houston to Boston $218 1

. These are merely one off

examples that highlight how much higher US

– Belize fares are vs. the typical yield curve for

markets with low fare competition. The US

– Belize market also meets the US DOJ definition of

highly concentrated with a HHI score of 3

, 355 1 . SWAPA believes that Southwest’s entry into

the market will rectify this situation by leading to a decrease in fares and stimulation of demand

for both the passengers in the local Belize City

– Houston Market and in the up to 43 beyond

markets served over Houston. Additionally SWAPA believes that t he requested exemption

authority is fully consistent with the U.S.

– U.K. Air Services Agreement o f 1977 (“Bermuda II

Agreement”).

1 Based on Sabre Global Demand for the 12 months ending October of 2014.3

For the reasons stated above, SWAPA fully supports the Southwest application and

urges the Department to quickly grant Southwest an exemption to engage in scheduled foreign

air transportation between the United States and Belize.

Respectfully submitted,

_________________________________ Paul JacksonCERTIFICATE OF SERVI CE

I hereby certify that on December 23 , 2014, a copy of the foregoing was served via e

mail on the following persons:

msinick@ssd.com (Alaska Airlines)

howard.kass@aa.com (American Airlines)

robert.wirick@aa.com (American Airlines)

sascha.vanderbellen@delta.com (Delta Air Lines)

chris.walker@delta.com (Delta Air Lines)

matwood@cozen.com (Frontier Airlines)

stephen.lachter@cozen.com (Frontier Airlines)

robert.land@jetblue.com (j etBlue Airways)

jhill@cooley.com (j etBlue Airways)

perkmann@cooley.com (j etBlue Airways)

robert.cohn@hoganlovells.com (Republic Airways)

patrick.rizzi@hoganlovells.com (Republic Airways)

dkirstein@yklaw.com (Spirit Airlines)

jyoung@yklaw.com (Spirit Airlines)

bob.kneisley@wnco.com (Southwest Airlines)

leslie.abbott@wnco.com (Sout hwest Airlines)

thomas.ting@suncountry.com (Sun Country Airlines)

dan.weiss@united.com (United Airlines)

steve.morrissey@united.com (United Airlines)

gmurphy@crowell.com (United Airlines)

sseiden@crowell.com (United Airlines)

john.varley@virginamerica.com (Virgin America)

susan.kurland@dot.gov

brian.hedberg@dot.gov

brett.kruger@dot.gov

reese.davidson@dot.gov

todd.homan@dot.gov

peter.irvine@dot.gov

cristinasa@state.gov

info@airlineinfo.com

/ John Pepper /

__________________________