Administration Office 

7770 Milton E. Proby Parkway, Suite 50 

Colorado Springs, CO 80916-4961 

COLORADO - l\rAS 

SPRINGS vvww.flycos.com 

AIRPORT ^^^_,^_^^^^.^_^..__,^_^-^^^_ . 

March 12, 2010 

The Honorable Raymond H. LaHood 

Secretary 

United States Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, B.C. 20590 

Docket DOT OST 2010-MV 

Dear Secretary LaHood: 

We are writing in support of the application for anti-trust immunity and the proposed joint 

business agreement filed by American Airlines (AA) and Japan Airlines (JAL). US Department 

of Transportation (USDOT) approval of the proposed alliance is essential to the maintenance of a 

competitive balance between the oneworld, Star and Skyteam alliances. 

Approval of the A/V/JAL alliance will have a positive impact on air travel by offering customers 

more service, scheduling and pricing options and will help ensure that customers continue to 

enjoy the benefit of having three competitive airline alliances to choose from. The increased 

competition will also promote the goals of DOT's Open Skies policy - first by solidifying U.S.-

Japan Open Skies, then by serving as a catalyst for further liberalization across the Asian 

continent. 

USDOT has consistently supported international alliances that enhance consumer welfare through 

increased competition, and that permit domestic carriers to improve the efficiency of their 

networks. It is our belief that the authority sought by American Airlines and Japan Airlines is 

fiilly consistent with this policy, as well as past grants of immunity by USDOT. 

We ask that you consider expeditious approval of the AA/JAL application-. Your leadership in 

this matter is greatly appreciated. 

Mar&t«rie^ 

Du«ctor of Aviation 

Colorado Springs Airport 

7770 Milton E Proby Parkway 

Colorado Springs, CO 80916 

mearle(g).springsgov.com 
Antitrust Immuni uals More Choice 

American Airlines (AA) and Japan Airlines (JAL) have proposed a Joint Business Agreement (JBA) that will improve 

customer choices with enhanced and improved service to oneworld's nearly 700 destinations, in almost 150 

countries, with 7,800 daily departures. As a key first step, the two carriers have applied for antitrust immunity (ATI) 

with the U.S. Department of Transportation to expand their cooperation and more tightly integrate their services to 

deliver more benefits to customers than is possible today. 

The joint business agreement - for which American and JAL must secure antitrust immunity - allows the airlines to 

share revenue on certain flights regardless of which airline operates the aircraft. While the two airlines would 

continue to codeshare, the Joint Business Agreement differs from a codesharing agreement where one airline bears 

all the costs but another airline might get a share of the revenue for booking a customer on a flight. 

Interalliance Competition is Necessary For 

Consumers To Receive The IMaximum Benefits 

From Open Sides 

The proposed alliance between AA and JAL is vital for the 

oneworld alliance to compete effectively with the Star and 

SkyTeam alliances. This increased interalliance competition 

will in tum enhance the benefits of the U.S. DOT's Open 

Skies policy - first by solidifying the U.S.-Japan Open Skies 

Accord, then by serving as a foundation for further 

liberalization across Asia. 

Today, SkyTeam operates connecting hubs at Tokyo Narita 

using Delta's incumbent status and at Seoul with Korean 

Airiines which already has ATI with Delta. Similariy, Star 

Alliance members. United and Continental, have jointly 

applied for antitrust immunity with their alliance partner ANA, 

in Tokyo; while. Star Alliance also operates a connecting hub 

at Seoul with its antitrust immunized partner Asiana. 

AA/JAL's application will ensure that a competitive balance 

exists in Tokyo and throughout the North American-Asia 

marketplace by allowing oneworld to compete on a level 

playing field with SkyTeam and Star alliances. 

The Proposed Alliance Will Create Expanded and 

Enhanced Route and Schedule Options 

With a dosely integrated alliance and immunizedjoint 

business, AA and JAL will have greater opportunities to 

launch new sen/ice and enhance their existing route and 

schedule options. New trans-pacific routes will be possible, 

making oneworld more competitive with Star and SkyTeam. 

Existing trans-pacific service can be optimized to provide 

more value to both local and connecting passengers as well. 

Competition in behind/beyond routes will be enhanced too, 

as oneworld's integration will create new competition against the existing Star and SkyTeam trans-pacific networks. 

Antitrust immunity will allow AA and JAL to offer lower fares and an improved product to the more than 11 million 

annual passengers traveling between the U.S. and Asia, including those flying between the over 15,000 new global 

airport pairs that will be added to oneworld's immunized network. 

Under an immunized agreement, American and JAL will coordinate planning efforts in order to offer customers a 

wider choice of travel options at competitive prices, optimize aircraft capacity and ground facilities, and to enhance 

connecting opportunities between their respective networks. This process will require that American and JAL jointly 

assess their U.S.-Japan schedules and connecting opportunities in order to build a more integrated network for their 

customers traveling between, and beyond and behind, their respective trans-pacific gateways in the U.S. and Japan. 

Elements of planned schedule coordination Include: 

• Co-location of flights in the same airport tenninals 

where possible (and where possible, increasing the 

number of opportunities to make connections to other 

services offered by AA and JAL without changing 

terminals); 

• Retiming of flights to ensure that AA and JAL provide 

a complementary choice of schedules and reduced 

connection times; and 

• Optimization of aircraft capacity, configurations, and 

schedules to better meet customer preferences and 

achieve efficiencies. 

American and JAL anticipate the consumer benefits 

from these changes to include Improved choice of 

flights. Increased seat availability on flights during 

peak hours, increased ability for AA and JAL to 

reduce prices and over time add flights and routes 

as a result of efficiencies, increased connecting traffic 

flows, and more connecting opportunities and 

convenient transfers. 

AA j$x.