May 21 , 2015 The Honorabl e John F
. Kerry Secretary of State U
. S
. Depart ment of State 2201 C Street , N W Washington , DC 20520 The Honorable Anthony Foxx Secretary of Transportation U
. S
. Department of Transportation 1200 New J ersey Avenue , SE Washington , DC 20590 The Honorable Penny S
. Pritzker Secretary of Commerce U
. S
. Department of Commerce 1 401 Constitution Avenue , NW Washi ng ton, DC 20230 

### GREATER ORLANDO AVIATION AUTHORITY Orlando International Airport One Jeff Fuqua Boulevard Orlando , Florida 32827-4399



### RE: REQUEST FOR COMMENTS ON PRESERVING OPEN SKIES AND ENSURING COMPETITIVE CHOICE FOR CONSUMERS DOCKET NO . DOS-2015-0016 - DOCKET NO. DOT-OST-2015-0082 - DOCKET NO. DOC- 2015-0001 Dear Secret ary Kerry , Secretary Foxx and Secretary Pritzker : The Greater Orlando Aviation Authority (" GOAA" ) appreci ates the opportunity to comment on the im portance of the United States ' longstanding Open Skies policy to the customers we serve and Central Florida ' s economy. We commend the Obama Administration for seeking t he views of the broader stakeholder community. GOAA believes it is imperative t h e decision in this matter is guided by the national economic interest , not the narrow sel f-interest of a few companies
. Tourism is critical to Central Florida generating more than $60 billion i n economic activity and s upporting m ore than 390 , 000 jobs last year, representing over 1/3 of all jobs i n our region. Our airports serve as an engine for this tourism-related commercial activity. In 2014 , more than 4.3 million i nternational visitors relied on Orlando International Airport as their gateway to Cent ral Florida and, thanks to O pen Skies , we are seeing year- over- year growth in international passengers. Simply put , the abilit y of Orlando International Airport to attract int ernational passengers and so benefit the Central Florida economy is i nextricably l i nked to O pen Skies
. Any policy decis i on which limits or restricts Open Skies access to the US is unwi se i n our view
. Liter al l y , Open Ski es has enabl ed Orlando to become a global tourism and trade destina tion with non-stop air service links to Europe , Canada , Mexico , and Central and South America. In t he absence of this free air service trade policy , Orlando I nternational Airport would be unabl e to provide the access for international visitors that our l ocal tourism attractions require to sustain the area economy , support tensof thousands of jobs, and realize Central Florida ' s potential as the premier leisure destination in the world, . Rapidly expanding air service trade between Brazil and Orlando is an example of the power of Open Skies
. According to the US National Travel Tourism Office (NTTO), visitors from Brazil to Orlando have soared from 74,000 in 2004 to 7 68 , 000 in 2013 and accelerated exponentially after the US Open Skies with Brazi l was negotiated
. Earlier this week, another new Brazilian flight was announced that will provide the first

- ever non-stop service to Belo Horizonte. GOAA and Central Fl orida are direct and substantial stakeholders in this matter. In their April 17 letter to you , the CEOs of Delta Air Lines, United Airlines and American Airlines demanded that Emirates Airline ' s new Orlando-Dubai non-stop flight, scheduled to start on September 1, be prohibited. Specifically, for their narrow self-interest , they demanded a freeze on all new flights clearly authorized by the USUAE and US-Qatar Open Skies agreements retroactive to January 28, 20 15. This is nothing short of an invit ation for President Obama's Administration to breach internati onal agreements , send a signal to the world that the US does not keep its word when it agrees to open its air service market on a reciprocal basis , and put Delta, United and American's self

- interest ahead of the best interest of Central Florida that will receive more than $100 million in annual economic benefits from Orlando ' s first ever non- stop air service link to the Middle East
. That is an invitation the Administration should emphatically decline
. GOAA and the Central Florida economy, including tens of thousands of tourism-related jobs that depend on a free and unimpeded flow of international visitors through Orlando International , urge you to be guided by the broader national i nterest, not the parochial i nteres t s of a few
. We believe that focus will lead to the inescapable conclusion that Open Skies policy has produced and conti nues to produce enormous economic benefits for our country, and any attempt to limit or restrict existing Open Skies rights to protect US airlines ' record-breaking profits is unwise. Neither the US economy nor our economy i n Central Florida can afford the Open Skies policy departure that is being urged in this matter. The Orl ando area certainly cannot afford to l ose the more than $100 million in new annual economic activity Emirates' new Orlando-Dubai non-stop f light will generate , and the nearly 1,500 jobs it will support
. Thank you for considering our views in this extremely important matter. Sincerely,

Phillip N. Brown, AAE Executive Director Frank Kruppenbacher Chairman