y 

p

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 on the above-cited 

matter, and wish to take this opportunity to provide our input to the Department on this 

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, we serve 

a truly global constituency. This unique position allows us to have a clear view of the 

financial and economic impact of various Open Skies polices versus restrictive bilateral 

agreements so often considered necessary by other governments for the protection of 

their airline industry. 

However, as we are certain the Department recognizes, there is only one true 

"protection" for any commercial enterprise in this or any other 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 a few 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 as barriers to 

entry, and have an inordinate impact on industry participants. They create a number of 

market distortions that are clearly not in the best interests of the air carrier community, 

www.GoNational.com f)r..o ~ at'..l'> Pl.# 14tC'I t:-:- 18 :0'1 gg --- -....... ,__ .__ ,_,-·-- - / •-

National Airlines 

Citadel II Building 

5955 T. G. Lee Boulevard, Ste. 500 

Orlando, FL 32B22 

T 800 451 3174 F 407 313 2255 

www.NationaiAirlines.com 
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governments. Fortunately, the Department recognized this issue early on and embraced the concepts of the free market in its policy to negotiate Open Skies agreements with a number of nations, who then reciprocated with equal access. National Airlines recognizes that the Department has strongly supported these agreements in the past, as well as their 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 as our nation's economic prosperity. These benefits are diffused across a host of subsidiary and supporting industries in both nations participating in the Open Skies process. Therefore, we are concerned that a reversal 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 page on 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