FEDERAL AVIATION ADMINISTRATION 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

----------------------------------------------------------------------------------)( 

UNITED AIRLINES, INC., 

Complainant, 

v. 

THE PORT AUTHORITY OF NEW YORK AND NEW JERSEY, 

Respondent. 

---------------------,------------------------------------------------------------)( 

Docket No. 

FAA-16-14-13 

MOTION FOR LEAVE TO INCLUDE SUPPLEMENTARY MATERIAL 

IN THE RECORD OF THIS PROCEEDING 

RECE\\110 

JUN ' 'I ·t~\5 

PART 16 oocdTS 

Communications with respect to this docuJllent should be addressed to: 

Carlene V. Mcintyre 

Arnold D. Kolikoff 

Law Department 

The Port Authority of New York and New Jersey 

4 World Trade Center 

25th Floor 

150 Greenwich Street 

NewYork,N.Y. 10007 

Telephone: (212) 435-3503 

Attorneys for Respondent 

The Port Authority of New York and New Jersey 
FEDERAL AVIATION ADMINISTRATION 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

----------------------------------------------------------------------------------)( 

UNITED AIRLINES, INC., 

Complainant, 

v. 

THE PORT AUTHORITY OF NEW YORK AND NEW JERSEY, 

Respondent. 

----------------------------------------------------------------------------------)( 

Docket No. 

FAA-16-14-13 

MOTION FOR LEAVE TO INCLUDE SUPPLEMENTARY MATERIAL 

IN THE RECORD OF THIS PROCEEDING 

Respondent The Port Authority of New York and New Jersey ("the Port Authority"), 

hereby moves pursuant to 14 C.F.R. § 16.19 (a) and 16.23 G) for leave to submit material 

supplementary to its Answer and Rebuttal herein. 

On June 16, 2015, one day after the Port Authority filed its last scheduled pleading in this 

matter- its Rebuttal to the Reply of United Airlines, Inc. ("United")- United issued a "news 

release" entitled "United Airlines Strengthens New York/New Jersey Hub with Move of p.s. 

Transcontinental Service to Newark." A true and accurate copy of that document is attached 

hereto as an Exhibit. 

By that news release, among other things, United announced that effective October 25, 

2015, it would cease its operations at John F. Kennedy International Airport ("JFK"), and shift 

those operations to Newark Liberty International Airport ("EWR"). United stated that to 

accomplish this action it planned, subject to regulatory approvals, to acquire EWR slots from 

Delta Air Lines, Inc. and transfer United's JFK slots to Delta Air Lines, Inc. In addition, United 

stated that in connection with these actions, it would be "making a multi-million dollar 
investment to renovate United's Terminal C lobby and to bring its new airport lounge design 

concept to all United Club locations at Newark Liberty." 

The statements in United's June 16th news release are relevant to the issues raised in 

United's Complaint, including: (I) United's claim that the EWR flight fee formula harms 

United's ability to compete in its New YorkJNew Jersey EWR hub and places United at a 

competitive disadvantage to carriers operating at JFK and (2) that the Port Authority's exercise 

of monopoly power has impacted United's ability to compete. 

For the foregoing reasons, the Port Authority respectfully submits that good cause exists 

for the entry of an Order permitting inclusion of the June 16th news release in the record of this 

proceeding. 

Dated: June 19, 2015 

TO: 

Office of the Chief Counsel 

Respectfully submitted, 

Carlene V. Mcintyre 

Arnold D. Kolikoff 

Law Department 

The Port Authority of New York and New Jersey 

4 World Trade Center 

25th Floor 

150 Greenwich Street 

New York, N.Y. 10007 

Telephone: (212) 435-3503 

Attorneys for Respondent 

The Port Authority of New York and New Jersey 

Attention: FAA Part 16 Airport Proceedings Docket, AGC-600 

Federal Aviation Administration 

800 Independence Avenue, SW 

2 
Washington D.C. 20591 

Marc L. Warren 

Keith J. Harrison 

Gerald F. Murphy 

Steven J. Seiden 

Crowell & Moring LLP 

1001 Pennsylvania Avenue, NW 

Washington, DC 20004 

(202) 624-2500 

RobertS. Span 

Alan K. Steinbrecher 

Sophy Chen 

Steinbrecher & Span LLP 

1155 F Street, N.W., Suite 1050 

Washington, DC 20004 

(202) 559-8680 

rspan@steinbrecherspan.com 

Attorneys for Complainant 

3 
United Airlines Strengthens New York/New Jersey Hub with Move of p.s. Transcontinent... Page 1 of 2 

ABOUT UNITED I NEWS RELEASES PHOTOS & VIDEOS I AWARDS & RECOGNITION 

News Releases 

« Back to news releases a SHfiRE (; tlii CJ ., 

United Airlines Strengthens New York/New Jersey Hub with Move of p.s. 

Transcontinental Service to Newark 

Newark flights to/f_rom San Francisco and Los Angeles to offer international-style inflightservice 

Premium-cabin customers to enjoy the New York area's best airport and inflight experiences 

p.s. service repositioning from JFK to Newark Liberty 

Airline will add trans-Atlantic 757s to p.s. fleet and replace them with Boeing 767s on most trans-Atlantic routes 

June 16, 2015 

NEWARK, N.J., June 16, 2015/PRNewswire/- Unlled Airlines, the U.S. airline industry's transcontinental leader, will 

bring the airtine's "p.s." Premium Service to its New York hub at Newark Uberty International Airport in October. 

Beginning October 25, all regularly scheduled Newark-Los Angeles and Newark-San Francisco flights will offer: 

flat-bed seats in the United BusinessFirst cabin; 

premium in-flight service; 

more extra-legroom Economy Plus seats than any other carrier; and 

modem interiors with in-flight Wi-Fi and personal on-demand entertainment with individual seatback monitors 

and power ports for customers in every row. 

To download the infoqraphic and additional photos of p.s. 

aircraft visit United's newsroom. 

With the addition of p.s. service at Newark Uberty, United customers 

flying on transcontinental flights to and from Newark in the 

BusinessFirst cabin will, for the first lime, enjoy flat-bed comfort for 

their entire journey when connecting to and from flights across 

United's extensive trans-Atlantic and trans-Pacific networks. 

United will cement its role as the leader in transcontinental flying with 

more than 1,250 daily flat-bed seats- the most in the New York 

market- and a 44 percent increase in flat-bed seats year-over-year. 

The airline will fly up to 17 daily round trips Newark-San Francisco 

and up to 15 daily round trips Newark-Los Angeles, leading the 

industry with a total of up to 10,000 round-trip seats offered per day 

on the two combined key transcontinental routes. 

Tr<mscon: a new crloice 

for premium service 

.;:· 

'It 

• LAX "'"~'' 

Manhattan business travelers, particularly those who work on Wall Street and throughout lower and western Manhattan, 

enjoy easy access to Newark Liberty, the most convenient of the three New York-area airports. 

While at Newark Uberty, p.s. customers will have access to the New York area's best airport experience. The company 

also announced today that it is making a multi-million dollar investment to renovate United's Terminal C lobby and to 

bring its new airport lounge design concept to all United Club locations at Newark Uberty. United already has invested 

more than $2 billion to build a world-class gateway at Newark Uberty where, with its airport partners, the airline is 

offering chef-driven restaurants, redesigned lounge-like gate areas and improved United Club locations. 

At Newark Uberty, the airline offers a full range of premium services, including a new United Global Services recepllon 

lobby for its top frequent flyers, offering personalized check-in and travel services to members of the airline's invitationonly Global Services program and to customers traveling on long-haul international flights in United Global First. United 

also offers its Mercedes-Benz tarmac transportation service, and when feasible, representatives meet Global Services 

and United Global First customers with applicable itineraries who may have tight connections and will drive them across 

the tarmac to their connecting flights. 

"The introduction of p.s. to Newark Liberty, the New York/Newark region's premier airport, offers Los Angeles and San 

Francisco travelers the highest levels of service in the air and on the ground," said Jim Compton, United's vice chairman 

and chief revenue officer. "We are investing in the three critical components of the travel experience for our customersour network, our product and our facilities." 

With its launch of p.s. services at Newark Liberty, United will cease operations at Kennedy International Airport on Oct. 

25. United has entered into two separate transactions: Delta Air Lines plans to acquire United's JFK slots, and United 

plans to acquire slots from Delta in Newark. Each transaction is subject to regulatory approval. 

The p.s. Experience: International-Style Domestic Travel 

United's p.s. Premium Service offers transcontinental travelers the features and comfort of long-haul international flights. 

Customers enjoy modern aircraft interiors with all-new seats, inflight Wi-Fi, free personal on-demand entertainment at 

every seat, in-seat power and USB ports. 

For p.s. customers booked in United BusinessFirst, United also provides: 

Search News 

!Keyword Search 

Search I 

http:/ /newsroom. united.com/20 15-06-16-United-Airlines-Strengthens-New-York-New-J er. .. 6/18/2015 
United Airlines Strengthens New York/New Jersey Hub with Move of p.s. Transcontinent... Page 2 of 2 

Premier Access check-in, security screening, boarding and baggage handling; 

United Club access; 

up to 6 feet, 4 inches of sleeping space in a 180-degree flat-bed seat; and 

pre-departure beverages, hot towel service, multi-course meals and a pre-arrival snack. 

Trans-Atlantic Services: More Seats, More Comfort 

In launching p.S. service at Newark Liberty, United will move several Boeing 757-200 aircraft currently allocated to transAtlantic markets to p.s. flights. As it does so, the airline will increase the number of widebody Boeing 767 aircraft on 

trans-AI!antic flights, offering larger United BusinessFirst cabins and, on many flights, United Global First service. 

United has already announced plans to introduce widebody 767 service on Newark flights to and from Barcelona, 

Madrid, Berlin and Hamburg. 

United: New York's Leading Airline 

United offers nearly 500 daily departures from the region to more than 150 destinations- the most in North America, the 

most across the Atlantic, the most across the Pacific and the most to and from Latin America. 

The airline also offers the most flat-bed seats and extra-legroom economy-class seating from the New York area. The 

airline offers frequent daily service from the New York-area airports to top business travel markets including Boston, 

Chicago, Houston, Los Angeles and San Francisco. 

United also maintains a significant presence at LaGuardia Airport, where the airline flies 37 daily departures to several of 

its domestic hubs, including Chicago, Denver, Houston and Washington Dulles. 

Newark Liberty Terminal C: Terminal for Today's Connected Traveler 

United Airlines is partnering with OTG Management to transform the shopping and dining experience in Terminal C, 

already one of the most modem airline terminals in the country, with high-end restaurants designed by internationally 

and regionally acclaimed chefs and gate areas updated with custom seating and tables. 

In gate areas, United customers will be able to use iPads to track their flights and order food and beverages for delivery 

to the gate within 15 minutes. 

With electronic payment technology, MileagePius members are able to use award miles for food, beverage and other 

purchases with the nearly 6,000 iPads to be deployed for customer use throughout the terminal. 

About United 

United Airlines and United Express operate an average of nearly 5,000 flights a day to 373 airports across six 

continents. In 2014, United and United Express operated nearly two million flights carrying 138 million customers. United 

is proud to have the world's most comprehensive route network, including U.S. mainland hubs in Chicago, Denver, 

Houston, Los Angeles, New York/Newark, San Francisco and Washington, D.C. United operates nearly 700 mainline 

aircraft, and this year, the airline anticipates taking delivery of34 new Boeing aircraft, including the 787-9 and the 737-

900ER. United is also welcoming 49 new Embraer E175 aircraft to United Express. The airline is a founding member of 

Star Alliance, which provides service to 193 countries via 27 member airlines. More than 84,000 United employees 

reside in every U.S. state and in countries around the world. For more information, visit united.com, follow @United on 

Twitter or connect on Facebook. The common stock of Unlted's parent, United Continental Holdings, Inc., is traded on 

the NYSE under the symbol UAL. 

Photo- http;i/photos.prnewswire.com/prnhl20150616/223406-

!.NEQ 

Logohttp:/lphotos.prnewswire.com/prnh/20130404JMM89155LOGO 

SOURCE United Airlines 

UNITED 

For further information: United Airlines Worldwide Media Relations, +1-872-825-8640, media.relations@united.com 

t] SHARE l[l ·# Cl .. 

About United 

Newsroom 

Investor Relations 

united.com 

© 2010 United Continental Holdings, Inc. All rights reserved. 

http://newsroom.united.com/20 15-06-16-United-Airlines-Strengthens-New-York-N ew-Jer. .. 6118/2015 
FEDERAL AVIATION ADMINISTRATION 

UNITED STATES DEPARTMENT OF TRANSPORTATION 

----------------------------------------------------------------------------------)( 

UNITED AIRLINES, INC., 

Complainant, 

v. 

THE PORT AUTHORITY OF NEW YORK AND NEW JERSEY, 

Respondent. 

----------------------------------------------------------------------------------)( 

CERTIFICATE OF SERVICE 

Docket No. 

FAA-16-14-13 

I hereby certify that by Federal Express Overnight Delivery I have this day served the 

foregoing Motion For Leave To Include Supplementary Material In The Record Of This 

Proceeding, and the Exhibit annexed thereto, on the offices and persons set forth below at the 

addresses indicated. 

Dated: June 19, 2015 

Stephen Peabody 

Senior Paralegal Specialist 

Addressees: 

Office of the Chief Counsel 

Attention: FAA Part 16 Airport Proceedings Docket, AGC-600 

Federal Aviation Administration 

800 Independence Avenue, SW 

Washington D.C. 20591 

Marc L. Warren 

Keith J. Harrison 

Gerald F. Murphy 

Steven J. Seiden 

Crowell & Moring LLP 

1001 Pennsylvania Avenue, NW 

Washington, DC 20004 

(202) 624-2500 
RobertS. Span 

Alan K. Steinbrecher 

Sophy Chen 

Steinbrecher & Span LLP 

1155 F Street, N.W., Suite 1050 

Washington, DC 20004 

(202) 559-8680 

rspan@steinbrecherspan.com 

Attorneys for Complainant 

2