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**~** DESTINATION EXCELLENCE

SENT VIA EMAIL May 8, 2015 Honorable Susan Kurland Assistant Secretary of Transportation Aviation and International Affairs US Department
of Transportation 1200 New Jersey Avenue SE Washington, DC 20590 Re: Request from the Department
of Transportation for comment regarding amending existing Open Skies Agreements with the Governments

of Qatar and the UAE Dear Ms. Kurland: We thank the Department for requesting comments from industry onthe above

-cited matter, and wish to take this opportunity
to provide our input to the Department onthis critical issue. As a long-established US Transportation Command, Civil Reserve Air Fleet carrier, multi-modal cargo, public charter, and now international flag passenger airline, weserve a truly global constituency. This unique position allows usto have aclear view of the financial and economic impact of various Open Skies polices versus restrictive bilateral agreements sooften considered necessary by other governments for the protection of their airline industry. However, aswearecertain the Department recognizes, there is only onetrue "protection" for any commercial enterprise
in this or anyother industry, and that is to produce high quality services at a reasonable cost with a high level of customer service. A number of countries, with whom the Department

is very familiar, have long histories of insulating their domestic air carriers from market-driven competitive forces through inequitable application
of restrictive agreements

,protective provisions, availability of gates, and airport landing rights (to name just afew of the more well-known methods currently being employed). All of these actions interfere with the operation of the free market and have driven the industry to attempt to counter them through actions such as alliances, mergers, cross-border equity investment, and code-sharing arrangements. Restrictive bilateralism and other protective provisions essentially act asbarriers

t o entry, and have an inordinate impact on industry participants

.They create anumbe

rof market distortions that are clearly not in the best interests of the air carrie

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- S. Kurland May 8, 2015 Page 2 and which foster an unhealthy relationship between industry participants and their governments. Fortunately, the Department recognized this issue early onand embraced the concepts of the free market in its policy to negotiate Open Skies agreements with anumber of nations, who then reciprocated with equal access. National Airlines recognizes that the Department has strongly supported these agreements

in the past, aswell astheir underlying philosophy. We question what in the current situation would require that the Department abandon

a proven trade policy that has become
a significant contributor
to our customer's level of international access,as well asournation's economic prosperity. These benefits arediffused across
ahost of subsidiary and supporting industries
in both nations participating

in the Open Skies process. Therefore, weare concerned that areversal of this support would set a dangerous precedent for more wide-ranging future actions which would have damaging consequences

to the American economy-an economy that is still recovering from one of the most devastating and wide-ranging downturns
of this century. As the Department's web site pageon Open Skies acknowledges,

" ...Open Skies agreements have vastly expanded international passenger and cargo flights to and from the United States, promoting increased travel and trade, enhancing productivity, and spurring high-quality job opportunities and economic growth. Open Skies agreements do this by eliminating government interference

in the commercial decisions of air carriers about routes, capacity, and pricing, freeing carriers to provide more affordable, convenient, and efficient air service for consumers." We couldn't have said it better ourselves. ,../-·- Edward M. Davidson President and COO National Air Cargo Group

,Inc., d/b/a National Airlines National Airlines Citadel

II Building www.GoNational

.com

5955 T. G. Lee Boulevard

,Ste

.500 Orlando, FL 32822 T 800 451 3174 F 407 313 2255 www

.NationaiAirlines

.com