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, 2010BEFORE 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 Hous ton Partnership (collectively, “Houston”
or the “Houston Parties”) respec tfully submit this answer in support of the applications of
Arik Air for authority to operate servic e 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 beg in 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 Inte rcontinental (IAH) – is one of the nation’s
premier international gateways. IAH r anked as the eighth-largest international passenger gateway in the U.S. in 2009, with more than 7.8 m illion 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 internat ional passenger traffic at IAH showing an

increase of 8.7% for the fi rst 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 t he busiest in West

Africa. 3 Lagos is by far Houston’s most im portant destination in Africa; in 2009
Houston-Lagos passenger traffi c exceeded that to Houst on’s next largest Africa
destination by more than 62%, and Houston- Nigeria air cargo ex ceeded traffic to
Houston’s next largest Africa destinati on by more than 40%. Currently, scheduled
passengers from Houston must travel to Af rica over circuitous one-stop and two-stop
connections; only fourteen per cent (14%) of Houston-Af rica passengers are able to
travel nonstop to their destinations. In 2009, 38,865 Houston-Af rica 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 futuregrowth for both cargo and passengers. Notably, in November 2009 HAS broke ground for a new, stateof-the-art replacement Terminal Ra dar Approach Control (“TRACON”) fa cility – responsibl e for controlling air traffic over some 16,000 square miles of airs pace and handling 900,000 individual aircraft operations; its larger size and state-of-the-art equipment w ill facilitate implementation of Next Generation technologies, further securing Houston’s position as o ne of the world’s most safe, secure and accessible airport destinations.

3 The Houston Parties also welcome the announcement m ade by Continental Airlines earlier this year that it plans to start its own flights between H ouston 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 prio r 12 month period.
Indeed, the Houston/Galveston Customs Distr ict ranks as Nigeria’s largest U.S.
gateway for international tr ade, and Houston’s trade value with Africa accounted for a staggering twenty-six percent ( 26%) of the total trade (by do llar 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 th an 4 million kilograms, with a value of more than $158 million. Data pr ovided by the Greater Houston Partnership
shows that 330 Houston companies have bu siness 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 main tains a trade and development office in

Houston.
West Africa is currently the top destinatio n 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 rece ssion; 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 stimul ation 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 t he 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 dynami c powerhouse that is critical
to the performance of the U.S. economy, especially in the cu rrent challenging times.

Much of Houston’s success is attributable to it s role as an international business center.
For example, Houston is today the headquarte rs 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 worl d’s “energy capital”, Houston offers its
international trading partners a diverse, aw ard-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 transportat ion and distribution, among other fields.
The Texas Manufacturers Register show s that between April 2009 and April 2010,

Houston had more manufacturi ng 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 Growi ng 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.Answer of the City of Houston andthe Greater Houston PartnershipPage 5WHEREFORE, the Houston Parties urge the Department to promptly grant thepending applications of Arik Air, so that Arik may commence service in the HoustonLagos market in 2011.Respectfully submitted,Rachel B. TrinderJol A. SilversmithZUCKERT, SCOUTT &RASENBERGER, L.L.P.888 Seventeenth Street, N.W.Washington, DC 20006-3309(202) 973-7927(202) 342-0683 (fax)rbtrinder@zsrlaw.comjasilversmith@zsrlaw.comCounsel for the City of Houstonand the Greater Houston PartnershipDated: December 3,2010CERTIFICATE OF SERVICEI certify that on this 3rd day of December 2010, a copy of the foregoing wasserved on the parties named below in accordance with the Department's Rules ofPractice.Jol A. SilversmithEvelyn D. SahrJennifer L. AndrewsCounsel for Arik Airesahr@eckertseamans.comjandrews@eckertseamans.comPierre MurphyCounsel for Arrow Air and USA 3000Airlinespmurphy@lopmurphy.comRobert P. SilverbergJeffrey JohnsonCounsel for ABX Airrsilverberg@sgbdc.comjjohnson@sgbdc.comSteven H. LachterCounsel for Astar Air Cargoslachter@lachter-ciements.comRussell E. PommerAtlas Airrpommer@atlasair.comThomas E. FoskoAir Transport Internationaltom.fosko@airtransport.ccMarshall S. SinickCounsel for Alaska Airlines andFlorida West International Airwaysmsinick@ssd.comJonathan BlankJ. Timothy HobbsCounsel for Capital CargoInternational Airlinesjonathan.blank@klgates.comtim.hobbs@klgates.comWilliam C. EvansJohn R. Mietus, Jr.Counsel for Centurion Air Cargo andTradewinds Airlinesbill@mietuslaw.comjohn@mietuslaw.comAaron GoerlichCounsel for Allegiant Air and RyanInternational Airlinesagoerlich@ggh-airlaw.comCarl B. Nelson, Jr.American Airlinescarl.nelson@aa.comHershel I. KamenDan WeissContinental Airlineshkamen@coair.comdan.weiss@coair.comJohn L. RichardsonCounsel for Amerijet Internationaljrichardson@johnlrichardson.comR. 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