May 14, 2015

The Honorable Anthony R. Foxx

Secretary of Transportation

US Department of Transportation

1200 New Jersey Ave SE

Washington, DC 20590

Re: Request for comments on preserving Open Skies and ensuring competitive choice for consumers

Docket No. DOT-OST-2015-0082 

Dear Secretary Foxx:

I am writing on behalf of the U.S. – U.A.E. Business Council in response to your request for 

comments on preserving Open Skies and ensuring competitive choice for consumers. Our members –

including nearly 100 large, medium, and small U.S. companies – are very concerned that this issue between 

competing global airlines will prove harmful to the vital bilateral relationship between the U.S. and the U.A.E.

and ultimately undermine U.S. interests in free trade and regional stability. Moreover, we find that the 

accusations being made by American, Delta, and United airlines regarding alleged subsidies to the Gulf 

carriers are misleading and threaten to undo the substantial economic benefits that Open Skies has provided 

to the U.S. economy, to U.S. airlines, and to the U.S. aviation industry at-large.

According to U.S. government data, the United States has negotiated 114 Open Skies agreements 

since 1992 with countries from around the world. These agreements have expanded the global footprint of 

U.S. carriers and provided tremendous economic benefits to their hub cities across the U.S. – including but 

not limited to, Dallas-Fort Worth, Detroit, Memphis, Minneapolis, and Salt Lake City – each of which had 

virtually no international flights prior to 1992. In this regard, the U.S. has benefited more from Open Skies 

than the U.A.E. To wit, 2014 operating profits for the U.S. airline industry amounted to $12 billion, with 

American Airlines alone recording over $4.1 billion in net income. 

As a result of this success, the U.S. – U.A.E. Business Council firmly believes that increased capacity 

and choice is good for all consumers. As a result, American passengers are choosing to fly U.A.E. airlines 

and have come to value the better service and more convenient connections. According to Skytrax, a 

research firm, U.A.E. airlines ranked in the top 5 among passengers while the highest placed U.S. airline was 

Delta, at 49th. Emirates, meanwhile, competes with U.S. carriers on only two routes. It’s no surprise, 

therefore, that passengers directly benefit from the Gulf carriers’ global connectivity all across Asia, Africa, 

and the Middle East while also enjoying the premium service that is often neglected by the Big 3. 

The U.S. and the U.A.E. meanwhile share an absolutely critical bilateral defense and security 

partnership. The U.A.E. is the only Arab country to participate in six coalition actions with the U.S. since the 

First Gulf War, including the ongoing campaign against the Islamic State in Syria and Iraq. More than 2,000 

American military personnel are based in the U.A.E., mostly with the U.S. Air Force’s 380th Expeditionary 

Wing stationed at Al Dhafra Air Base. This deep defense relationship and the effectiveness of this 

partnership are critical in promoting regional security and stability at a time when it is very much needed. 

Therefore, the U.A.E. is not only a consumer of security goods and services – it is increasingly a provider of 

security.

This is a relationship based not only on high-level defense cooperation however, but also in 25 

billion dollars of two-way trade. The U.S. exported over $22 billion dollars in goods and services to the 

U.A.E. in 2014, making the U.A.E. the single largest American export destination in the Middle East –

including more than India, Turkey, and Israel – for the last six years. These considerable export numbers 

mean real jobs for everyday Americans. In sum, this is a fast-growing and dynamic bilateral trade relationship 

with overwhelming benefit to the U.S. 
Among the considerable amount of goods exported to the U.A.E. every year from U.S. companies, 

commercial aviation-related products are the largest subset. According to a 2013 study commissioned by the 

U.S. – U.A.E. Business Council and enclosed as an addendum to this letter, U.A.E. airlines generate $16 

billion of U.S. economic activity annually that now supports nearly half a million jobs. A subsequent 2014 

Business Council report on the commercial aviation relationship between the two countries (also enclosed for 

your review) highlights over $130 billion in sales of Boeing aircraft and GE engines at the 2013 Dubai Air 

Show alone – all by U.A.E. carriers. Emirates alone has recently committed to acquiring 300 GE 9X engines 

for its new 777X fleet, worth more than $20 billion in list price, not including new engines for existing 777s 

on order. The 150 Boeing 777X aircraft order valued at $76 billion (with purchase rights of an additional 50 

planes) is the largest aircraft order by value in the history of U.S. commercial aviation. 

The Big 3 U.S. airlines meanwhile are attacking Gulf carriers for receiving subsidies while ignoring 

the enormous amount of direct U.S. government aid that they themselves receive and have received for 

decades. Since 2001, U.S. carriers have received some $15 billion in direct cash payments and loan guarantees 

from the U.S. government. According to reports, U.S. Big 3 partners such as Air France-KLM, meanwhile,

are gifted with 46 million euros from France as the country looks to increase its ever expanding stake and 

influence in the airline. Such government aid over the years includes pension fund bailouts and war risk 

insurance, as well as state or local tax breaks on jet fuel, office construction, and airport leases. In addition, 

since 2005, U.S. airlines have been consolidating at a rapid clip: America West with U.S. Airways, Northwest 

with Delta, Continental with United, AirTran with Southwest, and then, most recently, U.S. Airways with 

American (a merger that prompted a Justice Department antitrust lawsuit). Today, as a result of these 

consolidations, only four carriers handle 80 percent of U.S. airline seat capacity. 

We believe that the accusations being made by the Big 3 are in-fact a cover for fair competition, 

which is what truly threatens to reduce their market share. By actively lobbying against foreign carriers from 

gaining permits to establish footholds in the U.S., domestic Carriers have been able to reap massive gains 

from consumers by placing a monopolistic premium on ticket sales – directly hurting customers. This has inturn also affected international gateway airports within the U.S., who would otherwise stand to benefit from 

direct flights to other markets. 

In conclusion, what the Big 3 are calling for is short sighted, protectionist, and hurts American 

consumers, American companies, and American jobs. The U.S. – U.A.E. Business Council urges you, 

therefore, to carefully consider the views of all stakeholders in this debate and to refrain from taking actions 

that limit competition in global aviation and undermine broader U.S. interests across the Middle East. In 

doing so, we urge you to stand with virtually every other stakeholder in U.S. commercial aviation – from U.S. 

airports and the communities they serve, to travel and hospitality companies, to tourist and business travelers, 

to express delivery providers and cargo airlines. 

Thank you for your commitment, time, and attention to this important matter. 

 Sincerely,

 Danny E. Sebright

 President
“Hot Air at 30,000 Feet” – What the Big 3 U.S. Airlines 

Aren’t Telling You about Open Skies

“Stop Complaining and Start Competing”

The “Big 3” U.S. airlines’ campaign against “Open Skies” is designed to distract attention from their 

control over 80% of all international flights, including their major international alliances, and the Big 

3’s attempts to stop real competition in global air services. Simply put, U.S. airlines should stop 

complaining and start competing.

Since facts do matter, the U.S. – U.A.E. Business Council wanted to share some important truths 

about the Open Skies debate.

“Clueless in Atlanta” - The World is Changing but U.S. Airlines Are Not

Global travel and trade patterns are shifting dramatically. The fastest growing regions now are 

Africa, Asia and the Middle East. The U.A.E. sits right in the middle – an 8 hour flight to 5.5 billion 

people. In 1993, more than 73% of global air traffic was on European or U.S. airlines but by 2033 

that proportion will sink to 38%.

A 2014 report by the International Air Transport Association (IATA), which forecasts air travel 

growth over the next 20 years, made the following conclusions:

 India and Indonesia will be two of the five fastest growing markets in terms of additional 

passenger demand.

 Eight of the ten fastest-growing markets in percentage terms will be in Africa.

 Asian and South American destinations will see the fastest “country pair” segment growth. 

UAE airlines, with hubs in Dubai and Abu Dhabi, are uniquely positioned – geographically and 

strategically with their long-range fleets of wide-body aircraft – to take advantage of this shift in 

passenger demand.

The Big 3 ignored this opportunity, focusing instead on building their U.S. oligopoly and gaining 

record profits. Instead of competing for these passengers directly, U.S. airlines decided to feed 

millions of passengers a year to their European partners, where they can collectively fix fares and 

control capacity with anti-trust immunity provided by the U.S. and EU.

“Looking in all the Wrong Places” - The Biggest Subsidies are on the U.S. Airlines Own 

Balance Sheets

Before complaining about government support for international competitors, the Big 3 may first 

want to check their own balance sheets. Since 2006 alone, the Big 3 have transferred billions of 

dollars of pension liabilities directly to Uncle Sam while leaving creditors holding the bag for billions 

more through multiple bankruptcies. They received billions of dollars in cash payments and 

guaranteed loans in a direct government bailout while enjoying the advantages of antitrust immunity 

to fix transatlantic fares with their European partners.
“Who’s Afraid of Some Real Competition?” - Protectionism is the Biggest Subsidy of All

The Big 3 U.S. airline oligopoly has built a fortress around the U.S. market, the world’s largest. 

International airlines can’t fly between two U.S. cities, can’t buy majority stakes in U.S. airlines and 

have very limited rights to fly passengers between the U.S. and a third country. For U.S. consumers, 

this means less choice, worse service and higher prices. For U.S. airlines, this means record profits. 

“Complaining All the Way to the Bank” - U.S. Airlines Make Record Profits 

This month, the Big 3 U.S. carriers all reported record earnings. The U.S. airlines kept their planes 

full as they reaped the benefits of lower fuel prices and their years-long drive to consolidate the 

industry into fewer, bigger carriers. As the New York Times reported, “For passengers, 

the downside was that airlines are reaching these records by also increasing fares, packing flights and 

increasing revenue via baggage and other fees.”

Low fuel costs have been a windfall for the nation's airlines. But their passengers get virtually none 

of the savings. As CNN reported, “The four major [U.S.] carriers saved a combined $3.4 billion on 

fuel in the first three months of the year according to their financial reports . . . lower fuel prices 

shaved their cost by 33%, when compared to last year. . .But the average fare paid to fly... in the 

quarter fell only 66 cents to $192.39.” 

“Service Matters” – Passengers Rate U.A.E. Airlines among the Best, U.S. Airlines among 

the Worst 

Passengers are choosing U.A.E. airlines because of better service and more convenient connections. 

According to Skytrax, a research firm, the U.A.E. airlines both ranked in the top 5 among 

passengers. The highest placed U.S. airline was Delta at 49th. 

“Where the Jobs Are” – Part 1 

According to a 2013 study commissioned by the U.S.-U.AE. Business Council, U.A.E. airlines 

generate $16 billion of U.S. economic activity annually that supports over 100,000 American jobs. 

In addition, since 2000 the U.A.E. airlines have been the largest international buyers of American 

commercial aircraft, with deliveries and orders valued at more than $200 billion, which directly 

supports hundreds of thousands of jobs in the American aerospace industry. 

“Where the Jobs Are” – Part 2 

The U.A.E. has been the largest export market for U.S. in the MENA region for six years straight. 

In 2014 the U.S. had a trade surplus of over $19 billion with the U.A.E., exports that support more 

than 220,000 American jobs.

“Who Cares?” – U.S. Airports, Hotels, Travel Leaders, Passengers and Cargo Carriers 

The Big 3 are spending more than $10 million on their disinformation campaign, but take a careful 

look at who has lined up against them: U.S. airports, U.S. travel and tourism leaders, U.S. cargo 

carriers, U.S. fliers and even other U.S. passenger airlines like JetBlue. 

“They [the Big 3] believe they have little to risk by limiting foreign carrier access to U.S. markets. 

What they want is for the U.S. government to protect them from competition from able, attractive 

new entrants.” — David Bronczek, FedEx President and CEO 

“Against the backdrop of America’s windfall of increased flights bringing overseas visitors and 

generating economic activity and US travel and tourism jobs. The views of the three complaining US 

carriers, one of which, Delta, ironically enjoys a tremendous fifth-freedom franchise of its own in 
Japan, do not represent the views of entire US aviation industry.” —Robin Hayes, JetBlue President 

and CEO

“Who Pays?” - Higher Fares, Worse Service, Fewer Choices for Consumers

“Make no mistake: If American, Delta and United succeed in limiting Open Skies in one market, it 

will destroy the very foundation of Open Skies around the world. Then we’d be back to an era of 

regulated aviation, higher fares and fewer consumer choices.” — Roger Dow, president and CEO, 

U.S. Travel Association

“Friends Matter” – U.S. and U.A.E. Security Ties 

The U.A.E has fought with U.S. forces in six coalition campaigns—including fighting terrorists in 

Afghanistan for more than 12 years—and thousands of U.S. troops are stationed in the U.A.E. 

“...it goes without saying that they [the U.A.E.] are really one of our most important, closest 

partners today in the region. And they have been there in every important significant international 

security operation going back more than 20 years... So that part of the relationship is superb.” 

—U.S. Ambassador to the U.A.E., Barbara Leaf

“Their many contributions to collective defense and their close military ties over decades mark 

U.A.E. as one of our strongest friends within the region, deserving of our continued close 

engagement and tangible FMS support.” —Gen. James Mattis, Marine Corps Commander, U.S. 

Central Command

“Open Skies, Closed Case” – U.S. Airlines Have No Claim to Review Open Skies

The U.S.-U.A.E. Open Skies Agreement addresses air traffic landing rights and lowering regulatory 

burdens on airlines. It does not address sources of airline financing or government support. For 

example, there is nothing in the agreement prohibiting U.S. government-granted antitrust immunity, 

bankruptcy protection or pension relief for U.S. airlines.

The Big 3 U.S. airlines would also mistakenly apply World Trade Organization definitions of 

subsidies to a bilateral aviation agreement. But aviation rights and air services are explicitly excluded 

from the WTO under the GATS treaty – a position strongly supported by both the U.S. airlines and 

the U.S. government. 
U.S.-U.A.E. Business Council releases 2014 Update on U.S.-U.A.E. Commercial Aviation Ties

June 4, 2014

The U.S.-U.A.E. Business Council is pleased to announce the release of the ‘U.S.-U.A.E. Commercial Aviation

Update: Flying Higher’ report in conjunction with the launch of non-stop Etihad Airways service between Abu Dhabi 

International Airport (AUH) and Los Angeles International Airport (LAX). The two-page document expands on the 

findings of the Council’s ‘U.S.-U.A.E. Commercial Aviation: Taking Flight’ report, released in March 2013. Since 

the last report, Dubai’s Emirates Airline has launched service to Washington, D.C. and Boston, Massachusetts, with 

plans to open its new Chicago route in August. Since last March, Abu Dhabi’s Etihad Airways has launched its own 

service to Washington, D.C., started flights to LAX this month, and plans to open its new route to Dallas in December.

The 2014 ‘U.S.-U.A.E. Commercial Aviation Update: Flying Higher‘ report focuses on key developments 

underpinning bilateral commercial aviation trade and commerce over the last year, including landmark sales of Boeing 

aircraft – many with General Electric engines – to U.A.E. global carriers Emirates Airline, Etihad Airways, and regional 

flydubai during last November’s Dubai Airshow. The report also provides new data on the economic potential of new 

Emirati carrier route launches to markets around the U.S. and commercial opportunities for American companies in the 

U.A.E. The report delves further to explore burgeoning technical partnerships between American and Emirati 

companies set to service the aerospace supply chain with skills and products, infrastructure development and 

requirements ahead of the World Expo 2020 in Dubai, and modernization projects underway in the Northern Emirates 

to boost national commercial aviation offerings.

To view the full report, please click HERE or below.

- See more at: http://usuaebusiness.org/2014/06/u-s-u-a-e-business-council-releases-2014-update-on-u-s-u-a-ecommercial-aviation-ties/#sthash.ljUv3ANf.dpuf

Report: Growing U.S.-U.A.E. Commercial Aviation Relationship Supports 100,000 American 

Jobs; Contributes Over $16 Billion to U.S. Economy

March 27, 2013

182 nonstop flights from nine U.S. gateways expected to carry 2.4 million passengers in 2013; highlighting the U.A.E.’s emergence as a

regional hub for commerce and transportation

Washington, D.C. (March 27, 2013) – A new report, released today by the U.S.-U.A.E. Business Council, finds that the 

increased nonstop commercial airline service between the United Arab Emirates and United States is the fastest growing 

bilateral aviation relationship in the world. According to the report, flights between the United Arab Emirates (U.A.E.) 

and United States (U.S.) increased 1,500 percent since 2004. This increase is fueled by the rapid growth of the U.A.E.’s 

international airlines, Emirates and Etihad Airways, and new nonstop flights from U.S. cities to Abu Dhabi and Dubai.

The report, “U.S.-U.A.E. Commercial Aviation: Taking Flight,” analyzes the economic impact of the bilateral 

commercial aviation relationship between the two countries. The report found that in 2012 alone, Emirates and Etihad 

Airways’ procurement of American-made commercial aircraft and parts in tandem with the launch of nonstop routes to 

and from U.S. cities, contributed more than $16 billion to the U.S. economy and supported approximately 100,000 jobs.

The full report can be downloaded here: http://usuaebusiness.org/wp-content/uploads/2013/03/US-UAE-aviationreport_Published.pdf

- See more at: http://usuaebusiness.org/2013/03/report-growing-u-s-u-a-e-commercial-aviation-relationshipsupports-100000-american-jobs-contributes-over-16-billion-to-u-s-economy/#sthash.NkRRfQlQ.dpuf
Business Council Membership 

Founding: 

Abu Dhabi Investment Authority (ADIA)

Abu Dhabi National Oil Company (ADNOC)

Abu Dhabi Ports Company (ADPC)

Advanced Technology Investment Company (ATIC)

AECOM

Bechtel

The Boeing Company

BP

CH2M HILL

DC Capital Partners

DLA Piper

DP World

DynCorp International

Emirates Airline

Emirates Nuclear Energy Corporation (ENEC)

Etihad Airways

Etihad Rail

Exxon Mobil

First Gulf Bank

Fluor Corporation

General Electric

Goldman Sachs

Hillwood

International Golden Group

Jumeirah Group

Lockheed Martin

Masdar

Mohebi Group

Morgan Stanley

Mubadala

National Bank of Abu Dhabi (NBAD)

Northrop Grumman

Occidental

Parsons

Raytheon

Senaat

Corporate: 

Accenture

Aerojet Rocketdyne

AIG Property Casualty

Akin Gump Strauss Hauer & Feld

Alcoa

Allen & Shariff

Baker Botts

Booz Allen Hamilton

The Carlyle Group

CDM Smith

C3 Energy

Citi

Coca-Cola

The Cohen Group

Cubic Corporation

Dentons

DMCC

Dow Chemical

DRS

Du

Dubai Economic Council (DEC)

Dubai FDI

Dubai International Financial Centre (DIFC)

Electro Motive Diesel

Eli Lilly

FedEx

FLIR Systems

General Atomics

Google

Grosvenor Capital Management

Guardian Industries

Gulftainer

The Harbour Group

Harris Corporation

Honeywell International

IBM

Jet Aviation

Latham & Watkins

L-3

Merck

Merrick & Company

MetLife

Orbital ATK

Oshkosh Corporation

PepsiCo

Pfizer

Polaris Wireless, Inc.

Ras Al Khaimah Free Trade Zone (RAK FTZ)

Rockwell Collins

Sahouri Insurance

Sharaf Group

Sikorsky Aircraft Corporation

Squire Patton Boggs

STS Consulting

TenCate

Textron Systems

Thuraya Telecommunications Company

Truven Health Analytics

Tyco

Unison Agency

UPS

USAA Real Estate Company

Viceroy Hotel Group

Visa

Westinghouse Electric Company

Yahoo! Inc 
Associate:

American Center for GI Health and Wellness

AMIDEAST

Children’s Hospital of Philadelphia

Children's National Medical Center

Cleveland Clinic

Houston Methodist Global Healthcare Services

Mayo Clinic

New York Institute of Technology

New York University – Abu Dhabi

SAH Global

St. Jude Children’s Research Hospital

Honorary: 

Abu Dhabi Chamber of Commerce & Industry

AmCham Abu Dhabi

American Business Council of Dubai & the Northern Emirates 

Dubai Chamber of Commerce and Industry

The Emirates Business Women Council

Sharjah Chamber of Commerce and Industry