# FEDERALAVIATION ADMINISTRATION UNITED STATES DEPARTMENT OF TRANSPORTATION 

# ----------------------------------------------------------------------------------)( UNITED AIRLINES, INC., Complainant,

v. 

# THE PORTAUTHORITY OF NEW YORK AND NEW JERSEY, Respondent. 

# ---------------------,------------------------------------------------------------)( DocketNo. FAA-16-14-13

MOTIONFORLEAVE TO INCLUDE SUPPLEMENTARYMATERIAL INTHE RECORD OFTHIS PROCEEDING 

# RECE\\110

JUN ' 'I

# ·t~\5 PART16

# oocdTS

Communications with respect to this docuJllent should be addressed to:



# Carlene V. Mcintyre Arnold D. Kolikoff Law Department The PortAuthority ofNew York and NewJersey 4 World Trade Center 25th Floor 150 Greenwich Street NewYork,N.Y. 10007 Telephone: (212) 435-3503 Attorneys for Respondent The Port Authority ofNewYork andNewJersey

# FEDERALAVIATION ADMINISTRATION UNITED STATES DEPARTMENT OF TRANSPORTATION 

# ----------------------------------------------------------------------------------)( UNITED AIRLINES, INC., Complainant,

v. 

# THE PORTAUTHORITY OF NEW YORK AND NEWJERSEY, Respondent. 

# ----------------------------------------------------------------------------------)( DocketNo. FAA-16-14-13

MOTIONFORLEAVE TO INCLUDE SUPPLEMENTARYMATERIAL IN THE RECORD OF THIS PROCEEDING 

# RespondentThe Port Authority ofNew York andNewJersey ("the PortAuthority"), hereby moves pursuantto 14 C.F.R. 

# § 16.19 (a) and 16.23 

# G) for leave to submitmaterial supplementary to its Answer andRebuttal herein. OnJune 16, 2015, one day afterthe PortAuthority filed its last scheduled pleading inthis
matter- its Rebuttalto the Reply ofUnited Airlines, Inc. ("United")- United issued a "news release" entitled "United Airlines Strengthens NewYork/New Jersey Hub with Move ofp.s. Transcontinental Service to Newark." A true and accurate copy ofthat document is attached hereto as anExhibit. By that news release, among other things, United announcedthat 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 thatto accomplish this action it planned, subject to regulatory approvals, to acquire EWR slots from DeltaAir Lines, Inc. and transfer United's JFK slots to DeltaAir Lines, Inc. In addition, United statedthat inconnection withthese actions, itwould be "making a multi-million dollar

# investmentto renovate United's Terminal C lobby and to bring its new airport lounge design conceptto all United Club locations atNewarkLiberty." The statements in United's June 16thnews release are relevantto the issues raised in United's Complaint, including: (I) United's claim that the EWRflight fee formula harms United's ability to compete in its NewYorkJNew Jersey EWRhub and places Unitedat a competitive disadvantageto carriers operating atJFK and (2) that the Port Authority's exercise ofmonopolypowerhas impacted United's ability to compete. Forthe foregoing reasons, the PortAuthority respectfully submits that good cause exists for the entry ofan Orderpermitting inclusion ofthe June 16thnews release intherecord ofthis proceeding. Dated: June 19, 2015

TO: Office ofthe ChiefCounsel Respectfully submitted,

Carlene V. 

# Mcintyre Arnold D. Kolikoff LawDepartment The Port Authority ofNewYork and NewJersey 4 World Trade Center 25th Floor 150 Greenwich Street NewYork, N.Y. 10007 Telephone: (212) 435-3503 Attorneys for Respondent The Port Authority ofNew York and NewJersey

Attention: FAA Part 16 Airport Proceedings Docket, AGC-600 Federal Aviation Administration 800 Independence Avenue, SW

2

# WashingtonD.C. 20591 Marc L. Warren Keith J. Harrison Gerald F. Murphy StevenJ. Seiden Crowell & 

# Moring LLP 1001 PennsylvaniaAvenue, NW Washington, DC 20004 (202) 624-2500 RobertS. Span Alan 

# K. Steinbrecher Sophy Chen Steinbrecher & 

# SpanLLP 1155 F Street, N.W., Suite 1050 Washington, DC 20004 (202) 559-8680 rspan@steinbrecherspan.com Attorneys for Complainant



# 3

# United Airlines StrengthensNewYork/New Jersey Hub withMove ofp.s. Transcontinent... Page 1 of2

ABOUT UNITED 

# I NEWS RELEASES PHOTOS 

### & VIDEOS 

# I AWARDS 

### & RECOGNITION


# News Releases

«

### Backto news releases 

# a SHfiRE (; tlii CJ ., 

## United Airlines Strengthens NewYork/NewJersey Hub with Move of p.s. Transcontinental Service to Newark Newarkflights to/f_rom San Francisco and Los Angeles to offer international-style inflightservice Premium-cabin customers to enjoythe NewYork area's best airportand inflightexperiences 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 mosttrans-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 NewYork hub at Newark Uberty International Airport in October. Beginning October25, 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 forcustomers in every row. To download the infoqraphic and additional photos of p.s. aircraftvisit 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, forthe first lime, enjoy flat-bed comfortfor their entirejourneywhen connecting to and from flights across United's extensive trans-Atlantic and trans-Pacific networks. United will cement its role asthe 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 lowerand western Manhattan, enjoy easy access to Newark Liberty, the most convenient ofthe three New York-area airports. While at Newark Uberty, p.s. customers will have access to the NewYork 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 frequentflyers, offering personalized check-in and travel services to members ofthe 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 theirconnecting flights. "The introduction of p.s. to Newark Liberty, the NewYork/Newark region's premierairport, offers LosAngeles 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 ofthe travel experience for ourcustomersour network, our product and ourfacilities." 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/2015-06-16-United-Airlines-Strengthens-New-York-New-Jer... 6/18/2015

# United Airlines Strengthens New York/NewJersey Hub withMove ofp.s. Transcontinent... Page 2 of2

PremierAccess check-in, security screening, boarding and baggage handling; 

### United Club access; up to 

### 6 feet, 

### 4 inches of sleeping space in a 180-degreeflat-bed seat; and pre-departure beverages, hottowel 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 numberofwidebody Boeing 767 aircraft on 

### trans-AI!anticflights, offering larger United BusinessFirst cabins and, on many flights, United Global First service. United has already announced plans to introduce widebody 767 service on Newarkflights to and from Barcelona, Madrid, Berlin and Hamburg. United: NewYork'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 mostto and from Latin America. The airline also offers the mostflat-bed seats and extra-legroom economy-class seating from the NewYork 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 ofthe 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 theirflights and orderfood and beverages for delivery to the gatewithin 15 minutes. With electronic payment technology, MileagePius members are able to use award miles forfood, beverage and other purchases with the nearly 6,000 iPadsto be deployed forcustomer 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 nearlytwo million flights carrying 138 million customers. United is proud to havethe world's most comprehensive route network, including U.S. mainland hubs in Chicago, Denver, Houston, Los Angeles, NewYork/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 aircraftto United Express. The airline is a founding memberof StarAlliance, 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 underthe symbol UAL. Photo- http;i/photos.prnewswire.com/prnhl20150616/223406- 

### !.NEQLogohttp:/lphotos.prnewswire.com/prnh/20130404JMM89155LOGO

SOURCE United Airlines 

# UNITED

Forfurther 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/2015-06-16-United-Airlines-Strengthens-New-York-New-Jer.
.. 6118/2015

# FEDERALAVIATION ADMINISTRATION UNITED STATES DEPARTMENT OF TRANSPORTATION 

# ----------------------------------------------------------------------------------)( UNITED AIRLINES, INC., Complainant,


# v. THE PORTAUTHORITY OF NEW YORKAND NEWJERSEY, Respondent. 

# ----------------------------------------------------------------------------------)( CERTIFICATE OF SERVICE 

# DocketNo. FAA-16-14-13

I hereby certify thatby Federal Express Overnight Delivery I have this day served the foregoing Motion For Leave To Include Supplementary Material In The Record OfThis Proceeding, and the Exhibit annexed thereto, on the offices and persons set forth below at the addresses indicated. Dated: June 19, 2015

StephenPeabody SeniorParalegal Specialist Addressees: Office ofthe ChiefCounsel Attention: FAA Part 16 AirportProceedings Docket, AGC-600 Federal Aviation Administration 800 Independence Avenue, SW Washington D.C. 20591 Marc 

# L. Warren Keith J. Harrison Gerald F. Murphy StevenJ. Seiden Crowell & 

# Moring LLP 1001 Pennsylvania Avenue, NW Washington, DC 20004 (202) 624-2500

# RobertS. Span Alan K. Steinbrecher Sophy Chen Steinbrecher & 

# SpanLLP 1155 F Street, N.W., Suite 1050 Washington, DC 20004 (202) 559-8680 rspan@steinbrecherspan.com Attorneys for Complainant

2