Mr. Larry Cohen \ THE SECRETARY OF TRANSPORTATION WASHINGTON, D.C. 20590 Aprill6, 2012 President, Communication Workers ofAmerica 501 Third StreetNW. Washington. DC 20001 DearMr. Cohen: Thank you for your letter, cosigned by Ms. Veda Shook ofthe AssociationofFlightAttendants, opposingthe applications ofVirgin America, Inc., and JetBlue Airways for beyond-perimeter slot exemptions at Ronald Reagan Washington National Airport(DCA). In your view, the awards should go to carriers with strongerlabor records. Under authority granted in the FAA Modenuzation and Refonn Act of2012, the U.S. Department ofTransportation will be awarding to new entrant or limited incumbent carriers atotal ofeight slot exemptions at DCA, whlch would support four daily round trips. We received timely applications from Air Canada, proposing one round trip to Vancouver, British Columbia; AlaskaAirlines. one round trip to Portland,**Oregon~** and one round trip to San Diego; FrontierAirlines, one round trip to Colorado Springs and beyond to San Diego; JetBlue, one round trip to San Juan, Puerto Rico, and one ro.und trip to Austin, Texas; Southwest**Airlines~** one round trip toAustin and San Diego beyond; Sun Country Airlines, one round trip to Las Vegas; and Virgin America, two round trips to San Francisco. As the matter is still pending, Icannot comment on the merits ofthe points raised in your letter. However. I can assure you that all applications the Department received 

### will be given full and fair consideration an.d will be evalualed againstthe selection criteria specified inthe statute. The Department's action on this matter is being administered through a public docket, which allows all intere.sted parties the opportunity to comment Following our not:mal practice, I am placing acopy ofyour letter and this response in docket number DOT·2012- 9. Asimilarresponse hasbeen sent t

. I appreciateyour interTHE SECRETARY OF TRANSPORTATION WASHINGTON, D.C. 20690

Ms.·veda Shook International President Association ofFlight Attendants-CWA 501 Third StreetNW. Washington,DC 20001 DearMs. Shook: Aprill6, 2012

Thank you for your letter, cosigned by Mr. Larry Cohen ofthe Communication Workers of America, opposing the applications ofVirgin America, Inc., and JetBlue Airways for beyqndperimeter slot exemptions at Ronald ReaganWashington National Airport (DCA). In your view, the awards should go to carriers with strongerlabor records. Under authority granted in the FAA Modernization and Reform Act of2012, the U.S. Department ofTransportation will be awarding to new entrant or limited incumbent carriers atotal ofeight slot exemptions at DCA, which would supportfour daily round trips. We received timely applications from·Air**Canada~** proposing one round trip to**Vancouver~** BritishColumbia; AlaskaAirlines, one round trip to Portland, Oregon, and one round trip to San Diego; FrontierAirlines, one round trip to Colorado Springs and beyond to 8&'1 Diego; JetBlue? oneround trip to San Juan. Puerto Rico, and one round trip to Austin, Texas; Southwest Airlines, oneround trip to Austin and San Diego beyond; Sun Country Airlines, one round trip to Las Vegas; and Virgin America, two round trips to San Francisco. As the matter is still pending. I caru1ot commentonthe n'lerits ofthe points raised in your letter. However. I can assure you that all applications the Department received will be given full and fair consideration and will be evaluated againstthe selectioncriteria specified in the statute. The Department's action on this matter is being administeredthrough apublic dockett which allows all interested parties the opportunit:>; comment. Following our 1 practice, I

### am placing acopy ofyour letter and this r .in docket number DO 029, Asimilarresponse has been se.•**(~)..,..,.** ASSOCIATION OF FLIGHT ATTENDANTS- CWA, AFL·CIO 

# : :r 501 ThirdStrl!(!l, NW, WasJriiiJ.:IOII, OC 20001-2797



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# ···--···--··- ---·--··--· ··-··---.------·--·-**~---------······-'"·-···'0···-·-----·**.................... . PH.ONE 202•434•130.0 FAX 202•434•1319

March 26, 2012 Secretary Ray LaHood United States Department ofTransportation 1200 New Jersey Ave, SE Washington, DC 20590 Dear SecretaryLaHood, We write to express our concern over Virgin America's application for two open perimeter slots as well as JetBlue's application for one open perimeter slot at Washington Reagan National Airport (DCA). Under49 U.S.C. § 41718(g)(2), the Department ofTranspo1•tation (DOT) considers seven factors in awarding slots to new entrant and limited incumbent carriers at DCA. I acknowledge thatunder factor (G) "to produce public benefits:• Congress specified for DOT to considet·lower fares, higher Cltpacity, and a variety ofservice options. However, this list is not exhaustive, and it is wholly consistent with this consunterprotection factor to also consider the impact on the local community itselfandjobs in the community. In the post-deregulation era, most airlines serving slot-controlled airports, like National, had to purchase the right to provide service. These newly created routes will be given to the airline selected by DOT. Granting these slots to Virgin and JetBlue would give them afinancial advantage over other airlines with stronger labor records that had to pay for their slots. The government should not reward bad actors by allowing them to expand their practice ofprofiting at the expense ofthe hard working famHies in these new markets. Moreover, both San Francisco and Washington, D.C. have traditions rich in the labor movement. San Francisco's legacy includes the 1934 massacre now known as "Bloody Thursday," Dolot•es Huerta's protests for farm worker rights, and one ofthe largest Occupy movements in the United States. In Washington, D.C., citizens in the community rallied against the corporate behemoth Walmart and supp01ted responsible, pro-worker investment. Further, consumers in San Francisco already enjoy significant competition between airlines, and San Francisco International Airport (SFO) is one ofthe most well-connected airports in the United States. The impact on these communities would be augmented by both Virgin America's and JetBlue's demoralizing employment practices. For instance, management at Virgin America reportedly changes policies regarding time off, scheduling, and other work 1Ules at wi11 1• Virgin also repmtedly uses inconsistent discipline2• At JetBlue, there is alleged age discrimination, sexual discrimination, and retaliation3

. Ifear that these practices are all too common at a carrier that stifles any opp01tunity for input from_its employees.

1http://www.bizjoumals.com/sanfrancisco/news/20 11/12/20/transport·workers-union-virgin-america.html zhttp://www.sfexaminer.com/local/20ll/1 0/virgin-nmerica-tlight-nttendants-may-unionize 3Gorzynskl v. JetBlueAirways Corporation, 596 F.3d 93 (2010)

INFLIGHT SAFETY PROFESSIONALSi At the Association ofFlight Attendants-CWAt our nearly 60,000 members are a testament to the fact that being uflight attendant is a**}:ll~ofession** and notjust ajob. Qunlityjobs with fair t)ny and comprehensive benefits are a tangible public benefit and should be considered when awarding such a valuable commodity as free take-offand landing rights ut National Ail-port. We need to protect these goodjobs that employees in San Francisco and Washington, D.C. already have and prevent bad actors in the industry from being granted such a privilege. Sincerely,

Larry Cohen President Communication Workers ofAmerica



## s'10-120329-029 Veda Shook International President Association ofFlight Attendants-CWA