BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

ARIK AIR LIMITED 

For exemption authority pursuant to 49 

U.S.C. § 40109 and for a foreign air carrier 

permit pursuant to 49 U.S.C. § 41301 

Docket DOT-OST-2010-0279 

ANSWER OF THE CITY OF HOUSTON 

AND THE GREATER HOUSTON PARTNERSHIP

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) 

Jeff Moseley 

Chief Executive Officer 

GREATER HOUSTON PARTNERSHIP 

1200 Smith Street, Suite 700 

Houston, TX 77002 

(713) 844-3600 

(713) 844-0200 (fax) 

Rachel B. Trinder 

Jol A. Silversmith 

ZUCKERT, SCOUTT & 

RASENBERGER, L.L.P. 

888 Seventeenth Street, N.W. 

Washington, DC 20006-3309 

(202) 973-7927 

(202) 342-0683 (fax) 

rbtrinder@zsrlaw.com

jasilversmith@zsrlaw.com

Counsel for the City of Houston 

 and the Greater Houston Partnership 

Dated: December 3, 2010 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

ARIK AIR LIMITED 

For exemption authority pursuant to 49 

U.S.C. § 40109 and for a foreign air carrier 

permit pursuant to 49 U.S.C. § 41301 

Docket DOT-OST-2010-0279 

ANSWER OF THE CITY OF HOUSTON 

AND THE GREATER HOUSTON PARTNERSHIP

The City of Houston and the Greater Houston Partnership (collectively, “Houston” 

or the “Houston Parties”) respectfully submit this answer in support of the applications of 

Arik Air for authority to operate service between Houston and Lagos, Nigeria. The 

Houston Parties strongly support Arik Air’s applications, and urge that they be granted 

promptly so that Arik can begin its preparations for the new flights. Houston currently 

lacks nonstop scheduled service to Africa, and Arik’s proposed service would be an 

important first step towards satisfying this key need.1

 As the Department is aware, 

Houston’s flagship airport – George Bush Intercontinental (IAH) – is one of the nation’s 

premier international gateways. IAH ranked as the eighth-largest international 

passenger gateway in the U.S. in 2009, with more than 7.8 million passengers. Traffic 

 

1

 A “Houston Express” private charter program is operated between Houston and Luanda, Angola on 

behalf of the members of the U.S. - Africa Energy Association. 
Answer of the City of Houston and 

the Greater Houston Partnership 

Page 2

in 2010 is strong and growing, with international passenger traffic at IAH showing an 

increase of 8.7% for the first ten months of 2010 over the same period in 2009.2

The Houston Parties especially welcome Arik Air’s proposal since it will introduce 

new nonstop service to Lagos, one of the most important gateways in Africa; Lagos is 

the 7th busiest airport in Africa measured by passengers, and the busiest in West 

Africa.3 Lagos is by far Houston’s most important destination in Africa; in 2009 

Houston-Lagos passenger traffic exceeded that to Houston’s next largest Africa 

destination by more than 62%, and Houston-Nigeria air cargo exceeded traffic to 

Houston’s next largest Africa destination by more than 40%. Currently, scheduled 

passengers from Houston must travel to Africa over circuitous one-stop and two-stop 

connections; only fourteen percent (14%) of Houston-Africa passengers are able to 

travel nonstop to their destinations. In 2009, 38,865 Houston-Africa passengers were 

bound for Lagos; nonstop service will both benefit them and enhance the ability of 

passengers to travel more efficiently to other Nigerian and African points beyond Lagos. 

Despite the current lack of air services between Houston and Africa, the City has 

established significant links with both the continent in general and Nigeria in particular. 

Nigeria is Houston’s overall fourth-largest trading partner (third for seaborne trade and 

 

2

 Extensive additional infrastructure improvements at IAH are underway in anticipation of continued future 

growth for both cargo and passengers. Notably, in November 2009 HAS broke ground for a new, stateof-the-art replacement Terminal Radar Approach Control (“TRACON”) facility – responsible for controlling 

air traffic over some 16,000 square miles of airspace and handling 900,000 individual aircraft operations; 

its larger size and state-of-the-art equipment will facilitate implementation of Next Generation 

technologies, further securing Houston’s position as one of the world’s most safe, secure and accessible 

airport destinations. 

3

 The Houston Parties also welcome the announcement made by Continental Airlines earlier this year that 

it plans to start its own flights between Houston and Lagos beginning on November 10, 2011. 
Answer of the City of Houston and 

the Greater Houston Partnership 

Page 3

thirteenth for airborne trade), and current data shows significant market growth; for the 

year ending September 2010, the annual trade between Houston and Nigeria was 

valued at $9.3 billion, an increase of more than 35% over the prior 12 month period. 

Indeed, the Houston/Galveston Customs District ranks as Nigeria’s largest U.S. 

gateway for international trade, and Houston’s trade value with Africa accounted for a 

staggering twenty-six percent (26%) of the total trade (by dollar value) between the U.S. 

and Africa in 2009, and 43% of the trade with Nigeria. That same year, the airborne 

trade between Houston and Nigeria alone totaled more than 4 million kilograms, with a 

value of more than $158 million. Data provided by the Greater Houston Partnership 

shows that 330 Houston companies have business or trade connections with Nigeria, 

and 55 firms headquartered or with branches in Houston operate a total of 103 

subsidiaries in Nigeria. In recent years, Houston has hosted key Africa-focused events, 

such as the West and Central Africa Oil and Gas Conference and the Texas Africa 

Business Summit, and Nigeria’s Imo State maintains a trade and development office in 

Houston. 

West Africa is currently the top destination for Houston-Africa travelers; despite 

the lack of any non-stop service, there were 61,351 passengers in the market in 2009 –

an 4.3% increase over 2008, despite the recession; 44,715 of them (nearly 73%) were 

bound to/from points in Nigeria (primarily Lagos and Abuja). In the past, Houston has 

seen significant traffic stimulation in new intercontinental markets, sometimes by more 

than 200% in the first year of operation, as occurred after new services were launched 

between Houston and destinations such as Tokyo, São Paulo, and Buenos Aires. 
Answer of the City of Houston and 

the Greater Houston Partnership 

Page 4

Houston’s significant role in the nation’s air transportation network reflects the 

City’s overall importance to the U.S. economy. Houston is the nation’s fourth-largest 

city as well as the U.S.’s sixth-largest Metropolitan Statistical Area (“MSA”), with a 

population of more than 5.86 million. The City is a dynamic powerhouse that is critical 

to the performance of the U.S. economy, especially in the current challenging times. 

Much of Houston’s success is attributable to its role as an international business center. 

For example, Houston is today the headquarters of twenty-five Fortune 500 companies, 

and has the nation’s third-highest concentration of foreign consular and trade offices. 

While best known for its role as the world’s “energy capital”, Houston offers its 

international trading partners a diverse, award-winning global business community with 

world-class facilities for medical research and treatment (including the world’s largest 

medical center), aerospace manufacturing, financial investment, large-scale 

international conferences, and cargo transportation and distribution, among other fields. 

The Texas Manufacturers Register shows that between April 2009 and April 2010, 

Houston had more manufacturing jobs than any other U.S. city, while the Port of 

Houston ranks first in the U.S. for total foreign tonnage and second for total tonnage. 

Further, eight of the 2009 Fortune “100 Fastest Growing Companies” are headquartered 

in the Houston metropolitan area. The establishment of scheduled non-stop service 

between Houston and Lagos would represent a significant additional step in enhancing 

the city’s global transportation network and its future growth and prosperity. 
Respectfully submitted,Rachel B. Trinder

Jol A. Silversmith

ZUCKERT, SCOUTT &

RASENBERGER, L.L.P.

888 Seventeenth Street, N.W.

Washington, DC 20006-3309

(202) 973-7927(202) 342-0683 (fax)rbtrinder@zsrlaw.com

jasilversmith@zsrlaw.com

Counsel for the City of Houston

and the Greater Houston Partnership

Dated: December 3,2010
Jol A. Silversmith

Evelyn D. Sahr

Jennifer L. Andrews

Counsel for Arik Airesahr@eckertseamans.com

jandrews@eckertseamans.com

Pierre Murphy

Counsel for Arrow Air and USA 3000

Airlines

pmurphy@lopmurphy.com

Robert P. Silverberg

Jeffrey Johnson

Counsel for ABX Airrsilverberg@sgbdc.com

jjohnson@sgbdc.com

Steven H. LachterCounsel for Astar Air Cargoslachter@lachter-ciements.com

Russell E. Pommer

Atlas Air

rpommer@atlasair.com

Thomas E. Fosko

Air Transport International

tom.fosko@airtransport.cc

Marshall S. Sinick

Counsel for Alaska Airlines and

Florida West International Airwaysmsinick@ssd.com

Jonathan Blank

J. Timothy Hobbs

Counsel for Capital CargoInternational Airlines

jonathan.blank@klgates.com

tim.hobbs@klgates.com

William C. EvansJohn R. Mietus, Jr.

Counsel for Centurion Air Cargo and

Tradewinds Airlines

bill@mietuslaw.com

john@mietuslaw.com

Aaron Goerlich

Counsel for Allegiant Air and RyanInternational Airlines

agoerlich@ggh-airlaw.comCarl B. Nelson, Jr.

American Airlines

carl.nelson@aa.com

Hershel I. Kamen

Dan Weiss

Continental Airlines

hkamen@coair.com

dan.weiss@coair.com

John L. Richardson

Counsel for Amerijet International

jrichardson@johnlrichardson.com
R. Bruce Keiner, Jr. 

Lorraine B. Halloway 

Counsel for Continental Airlines

rbkeiner@crowell.com

lhalloway@crowell.com

Sascha Van der Bellen 

Jeff Morgan 

Samantha C. Barnett 

Delta Air Lines 

sascha.vanderbellen@delta.com

jeff.morgan@delta.com

sametta.c.barnett@delta.com

John Palo 

Evergreen International Airlines

john.palo@evergreenairlines.com

charters@evergreenairlines.com

Nancy S. Sparks 

Angeline Garbuzinski 

FedEx Express

nssparks@fedex.com

anbird@fedex.com

Robert E. Cohn 

Counsel for Frontier Airlines 

robert.cohn@hoganlovells.com

Jonathan B. Hill 

Counsel for Hawaiian Airlines and 

JetBlue Airways 

jhill@dowlohnes.com

Mark W. Atwood 

Counsel for Kalitta Air and Xtra 

Airways 

matwood@cozen.com

Malcolm L. Benge 

Counsel for North American Airlines 

and World Airways

mlbenge@zsrlaw.com

Kevin Montgomery 

Peter Beckett 

Polar Air Cargo

kevin.montgomery@polaraircargo.com

peter.beckett@polaraircargo.com

Thomas A. Gillies 

Southern Air 

tgillies@southernair.com

Joanne W. Young 

Counsel for Spirit Airlines 

jyoung@yklaw.com

John S. Fredericksen 

Sun Country Airlines 

john.fredericksen@suncountry.com

Jeffrey Manley 

United Air Lines 

jeffrey.manley@united.com

David L. Vaughan 

Danielle Fisher 

Counsel for United Parcel Service 

dvaughan@kelleydrye.com

dfisher@kelleydrye.com

Howard Kass 

US Airways

howard_kass@usairways.com

Esta Rosenberg 

Department of Transportation

esta.rosenberg@dot.gov

John M. Allen 

Federal Aviation Administration 

john.allen@faa.gov