January 2, 2015 BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion and Application of AMERICAN AIRLINES, INC. Motion of HAWAIIAN AIRLINES, INC. in the matter of 2010 U.S.

- Haneda Combination Services Allocation Proceeding Docket DOT

- OST

- 2010

- 0018

ANSWER OF AMERICAN AIRLINES, INC. TO PETITION FOR RECONSIDERATION

Howard Kass Vice President

– Regulatory Affairs Robert A. Wirick Managing Director, Regulatory and International Affairs Abigail Donovan Director, Congressional and Federal Affairs American Airlines, Inc. 1101 17th Street, N.W. Washington, DC 20036 (202) 326

- 5153 howard.kass@aa.com robert.wirick@aa.com abigail.donovan@aa.com Charles A. Hunnicutt Patricia N. Snyder Thompson Hine LLP 1919 M Street, NW Suite 700 Washington, DC 20036

- 1600 (202) 263

- 4189 charles.hunnicutt@thompsonhine.com patricia.snyder@thompsonhine.comJanuary 2, 2015 BEFORE THE DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

Motion and Application of AMERICAN AIRLINES, INC. Motion of HAWAIIAN AIRLINES, INC. in the matter of 2010 U.S.

- Haneda Combination Services Allocation Proceeding Docket DOT

- OST

- 2010

- 0018

ANSWER OF AMERICAN AIRLINES, INC. TO PETITION FOR RECONSIDERATION American Airlines, Inc. (“American”) fully supports the Department’s decision in Order 2014

- 12

- 9 to conduct a fresh examination of the best use of the U.S.

- Haneda slot pair currently being used on a Seattle

- Haneda route by Delta Air Lines (“Delta”). American will show in that examination that the Department should reallocate the slot pair to American to serve the Los Angeles

- Haneda market, which has strong, unsatisfied demand and requires an additi onal market participant. This proceeding involves the scarcest resource the Department has been forced to allocate in recent years. The U.S.

- Japan agreement allows for only four daily slot pairs between the United States and Haneda, a highly desirable mar ket. The Department, the public, and the airline community have a particularly acute interest in ensuring that those four opportunities are put to their highest and best use . A s the Department recognized inAnswer of American Airlines, Inc. To Petition for Reconsideration

Page 2 of 15

Order 2014

- 12

- 9 : “ [t] he principal objective in this proceeding will be to maximize public benefits with this scarce resource.” 1 Currently, Delta is using this scarce resource to operate 17 flights between October 2014 and March 2015, whereas it could have operated 182 flights during that time. With this degree of underuse, the Department has not just the right, but also the obligation, to review its decision to allocate one slot pair to Delta for use at Seattle. In its petition for r econsideration of Order 2014

- 12

- 9 , Delta resists this review. Delta knows that the Department’s examination will show that it has squandered the valuable U.S.

- Haneda slot pair, and that it has failed to provide the service on which the award of that slot pair was predicated. Delta has another pressing incentive to resist this review: each day of delay allows Delta to continue to preclude competitive entry into the U.S.

- Haneda market, where Delta holds two of the four valuable slot pairs. The Department s hould reject Delta’s petition and focus on the pleadings called for under the Carrier Selection Process of Order 2014

- 12

- 9. American will provide compelling evidence that its year

- round daily Los Angeles

- Haneda service will offer greater public benefits t han Delta’s
occasional Seattle

- Haneda service. This will be the fourth carrier

- selection proceeding to allocate U.S.

- Haneda slot pairs. Delta has competed for slot pairs in all but one. Delta has never before questioned the Department’s power to allocate or reallocate slot pairs. Instead, it did what it has

1 Order 2014

- 12

- 9 at 5. The Haneda slot pairs are an extremely scarce resource, in large part, because Delta made them so by resisting additional liberalization during the U.S.

- Japan negotiations unless it could move its substantial Narita operations to Haneda. Its strident oppo sition to liberalization made an agreement impossible, thus preventing a liberalization of access to Haneda for U.S. airlines.Answer of American Airlines, Inc. To Petition for Reconsideration

Page 3 of 15
always done and what every other carrier has always done: it competed in the carrier

selection proceeding. That same process is precisely what the Department is undertaking here. No changes or prece dent

- breaking actions. Simply, the same carrier

- selection process and long

- standing evidentiary requirements , all of which are well known to Delta . As in all such cases, this proceeding will afford Delta three rounds of pleadings to present its case
as t o the public benefits of the Seattle

- Haneda service. Delta nevertheless objects to even the idea of reviewing the best use of the U.S.

- Haneda slot pair. Delta asserts that the Department categorically lacks authority to determine whether the public intere st is being served ; that the Department should not and
cannot hold a carrier selection case to consider other options ; and , that the Department has no right to reallocate the slot pair it is currently operating. Delta’s conten tions are legally incorrect, a re contrary to the public interest, and depart from the course of conduct under which Delta has participated in other such proceedings. The Department should deny Delta’s Petition and develop a fresh record for determining which carrier will “maximize pub lic benefits with this scarce resource.” 2 American is confident that, with a complete and current record, the Department will recognize that reallocation of the slot pair that Delta is currently operating is required to fulfill this public interest object ive.

2 Order 2014

- 12

- 9 at 5.Answer of American Airlines, Inc. To Petition for Reconsideration

Page 4 of 15

1. The Department Has Inherent Power to Review Prior Decisions. “The power to reconsider is inherent in the power to decide.” 3 Delta does not acknowledge this obvious point, but in fact, the Department has from time to time exercised its lawful authority to review prior decisions. According to the U.S. Supreme Court in CAB v. Delta, 4 a case upon which Delta relies heavily, that authority applies even to effective, permanent certificates. There, the former Civil Aeronautics Board (“CAB”) had selected Delta to serve a route, but later withdrew the certificate, even though Delta was using the authority. The Supreme Court overturn ed the CAB’s action, but only because the CAB did not adhere to statutorily specified procedures. The Court repeatedly emphasized the CAB’s general authority to reconsider its prior decision, so long as the carrier is given notice and a hearing

. 5 The Dep artment has done exactly that here, giving Delta notice of its examination and an opportunity to show why the current allocation of the U.S.

- Haneda slot pair is in the public interest. CAB v. Delta thus fully supports the Department instituting this proce eding. Certainly, nothing in CAB v. Delta supports Delta’s contention that the Department cannot review the allocation merely because Delta is “in compliance with”

3 Albertson v. Federal Communications Comm’n., 182 F.2d 397, 399 (D.C.Cir. 1950) (holding that the FCC could reconsider a prior decision, so long as it granted petitioner notice and a fair opportunity to be heard). 4 Civil Aeronautics Board v. Delta Air Lines, Inc., 367 U.S. 316 at 329 (1961) (the CA B could reconsider an earlier decision, but “it must proceed in the manner authorized by statute”). Hereafter, the case is referred to as “ CAB v. Delta .”
5 See CAB v. Delta , 367 U.S. at 328 n.11 (“ Congress has shown no intent to preclude reconsideration, either judicial or administrative, after notice and hearing ”); id. at 329 (“ In the first place, it bears repetition that we are not deciding that the Board is barred from reconsidering its initial decision. All we hold is that, if the Board wishes to do s o, it must proceed in the manner authorized by statute. Thus, for example, the Board may reconsider an effective certificate at any time if it affords the certificated carrier notice and hearing prior to decision

. . . .”).Answer of American Airlines, Inc. To Petition for Reconsideration

Page 5 of 15
the dormancy condition by operating a few flights every 90 days. 6 Delta’s position would e ffectively eviscerate any public interest standard so long as technical dormancy conditions are met, and the Department could not even consider whether the existing allocation remains in the public interest. Delta unsurprisingly cites no regulatory or jud icial precedent even suggesting that a dormancy condition (or any other condition) can take precedence over the public interest of the United States. Delta next claims that it should enjoy the “security of route” described by the Supreme Court in CAB v. De lta , no matter how poorly it uses the valuable Haneda slot pair. 7 Delta reads the Court’s decision as extending the “security of route” to the CAB’s ability to withdraw the certificate in question in that case. As noted above, however, Delta simply misre ads the case: the Court unambiguously reaffirmed the CAB’s authority to withdraw the certificate with notice and hearing. See supra note 5. In other words, even if “security of route” is relevant to the substantive question of whether a certificate is w ithdrawn, it is not remotely relevant to the procedural question of how to withdraw a certificate, which simply requires proper notice and fair hearing. This case, of course, does not even involve a certificate, but the Department is providing notice and hearing, which is a ll that matters at this stage. Delta’s next argument is that, because the Department sometimes explicitly reserves the right to amend, modify, or revoke a frequency/slot pair or an exemption, it

6 Delta’s Petition at 2. The d ormancy condition operates to withdraw slot pairs without further process, enabling the Department to “authorize new services quickly should those services not materialize.” Order 96

- 2

- 17 at 13 (U.S.

- Russia)

. 7 Delta’s Petition at 6, citing CAB v. Delta Air Lines, 367 U.S. at 324.Answer of American Airlines, Inc. To Petition for Reconsideration

Page 6 of 15
can only exercise that authority where it has made that express reservation. This is patently wrong for two reasons. First, because the Department inherently has the power to revoke, 8 it is unnecessary to reserve that legal power explicitly. The redundant explicit language that the Department of

ten uses is a belt

- and

- suspenders approach to remind parties that their authorizations are subject to revocation. Second, the dormancy condition by its plain terms does not preclude the Department from reviewing the allocation to determine whether it remai ns in the public interest. In relevant part, the condition reads: The slot pair allocation will remain in effect indefinitely . . . provided further that the slot pair will become dormant and will revert automatically to the Department if it is not used for a period of 90 days (once inaugurated). 9 That language thus simply puts Delta on notice that failure to fulfill the allocation conditions will result in the “automatic[. . . ] ” revocation without any due process safeguard s , such as notice and an opportunity to be heard

. “Automatic” means

“ beginning when specific conditions are fulfilled, without the need for a decision or action .” 10 The Department’s use of the term “automatically” signals that the reversion

8 The Department has used that power to revoke exemption authority especially where changed circumstances exist. See, e.g., Application of Exec Express II, Inc. , Order 98

- 11

- 8 at 3 n.9 (issued Nov. 10, 1998) (u nlike certificat e authority, exemption authority may be revoked at any time without notice where circumstances warrant ) . See, also, Application of Covia Partnership For An Exemptio n , Order 94

- 8

- 5 at 14 (Aug. 3, 1994). There, the Department said: [W]e may reexamine the wisdom of an exemption after we grant it. If persons affected by the exemption believe that experience has shown that the exemption should be revoked or modified, it is appropriate for them to ask us to reexamine the exemption, particularly when their requ est for reexamination is based on an u nforeseen use of the exemption.
9 Order 2013

- 2

- 4 at 6, condition 3 (emphasis added).
10 Encarta Dictionary (English: North America). Accord : Merriam Webster on

- line: “ having a self

- acti ng or self

- regulating mechanism.”Answer of American Airlines, Inc. To Petition for Reconsideration

Page 7 of 15

will take place without further Department action. The provision thus does nothing to limit the Department’s authority to take further action to enforce and promote the public interest, with the usual procedural safeguards. Delta also misconstrues the term “i ndefinitely” as used in the same condition. In its view, Delta remains entitled to keep the slot pair forever, so long as it “complies with” the dormancy condition. But “indefinite” does not mean “forever.” Just the opposite: as the Department has alre ady determined, “indefinite” in the context of frequency allocations (in this case, slot allocation) means that the allocation continues in effect until it reverts automatically or the Department takes an action to change the status of the slot pair. 11 The term thus confirms, rather than abrogates, the Department’s inherent authority to take appropriate actions needed to protect the public interest. Exercising that authority, the Department has previously reviewed exemption authorities, even when they were being operated, to determine whether they were in the public interest. In the 2007/2008 U.S.

- Colombia frequency allocation proceeding, the Department did just that. 12 Although American had allowed the frequencies to become dormant, it had firm plans to us e the frequencies and had actually (re)started service. The Department nonetheless decided to reexamine the frequency allocation. Ultimately, the Department withdrew American’s slots and awarded them to other carriers. 13

11 Application of American Airlines (Dallas/Ft. Worth

- Buenos Aires Combination Frequencies) , Order 2003

- 8

- 4 at 6 n. 9 (stating that American’s award would be “indefinite” rather than permanent “ since the authority could i n fact be lost, whether by operation of the conditions themselves or by subsequent action of the Department ”)

. 12 2007/2008 U.S.

- Colombia Combination Frequency Allocation Proceeding , Order 2008

- 5

- 27 (2008) (hereafter “U.S.

- Colombia). 13 Id., a t 15, orderin g paragraph 2 (“We reallocate seven of American’s currently allocated U.S.

- Colombia scheduled combination frequen cies as described in this order ”)

.Answer of American Airlines, Inc. To Petition for Reconsideration

Page 8 of 15
Finally, Delta contends that, by i mposing an express dormancy condition on the slot pair, the Department cannot rely on its implied right to reconsider its decision. According to Delta, by expressly imposing the dormancy condition as a ground for revocation, the Department necessarily exc luded all other grounds, including the public interest. 14 As noted above, however, the dormancy condition by its terms only specifies the basis for automatic revocation

— it says nothing about other, non

- automatic grounds for revocation. Further, the auth ority Delta cites

— the D.C. Circuit’s National Mining decision

— is irrelevant to this case. National Mining holds only that an agency could not rely on its general statutory authority to undermine a specific congressional directive. It has nothing to d o with the construction of the Department’s own order specifying the grounds for automatic revocation, against the backdrop of its well

- settled, general authority to revoke for public interest reasons with notice and hearing. Nothing in Order
2013

- 2

- 4 sta tes, or remotely suggests, the Department’s intent to abandon its statutory responsibility to safeguard, pr otect, and e nsure the public interest, in favor of wooden adherence to a te chnical dormancy condition. Moreover, t he more recent Order 2014

- 12

- 9 car efully reviewed the pleadings and explained the basis for the Department’s legally
sound decision to institute a carrier

- selection proceeding. As the Supreme Court said, reconsideration involves the balancing of two opposing policies: “the desirability of finality” and “the public interest in reaching . . . the right result.” 15 In the present case, the Department has reasonably determined that

14 Delta’s Petition at 4, citing National Mining Ass’n v. U.S. Dept. of Interior, 105 F.3d 691, 694 (D.C. Cir. 1997).
15 CAB v. Delta Air Lines, Inc., 367 U.S. 316, 32 1 (1961).Answer of American Airlines, Inc. To Petition for Reconsideration

Page 9 of 15
balancing those two policies requires a review of the existing allocation. The Department awarded Delta this slo t pair nearly two years ago, relying upon a record that closed in November 2012. 16 Delta promised daily year

- round service, but it has not delivered on that promise. 17 The Department is correct as a matter of law and policy to re

- examine market conditions and reconsider how the public interest is best served. Indeed, as we show below, not only is the Department correct, but its responsibility to safeguard the public interest requires this fresh examination, especially when a scarce resource is involved.
2. Delta Has Severely Cut Back Or Eliminated Its Seattle
- Haneda Service and t he Department Is Right t o Hold a Carrier
- Selection Proceeding. Delta attempts to hide its squandering of the Seattle

- Haneda slot pair with an unfounded claim that the Department c annot re

- examine its own decisions unless it does so for all decisions in similar circumstances. Delta then asserts without explanation that circumstances in a 2008 U.S.

- Brazil case are similar to those in this proceeding. 18 Neither proposition is true. D elta cites multiple judicial decisions for the proposition that an agency acts arbitrarily and capriciously if it does not “treat similar cases in a similar manner” or if the agency reverses its position without adequately distinguishing the facts. 19 But t he whole point of the fresh examination is to assess the particular facts of this case. As Delta well knows, carrier

- selection proceedings are highly fact

- dependent and do not involve similar circumstances. Each proceeding

16 Order 2013

- 2

- 4, issued Feb. 5, 2013. 17 See , Exhibit AA

- 1 of our Oct 2, 2014 Motion & Application in this docket. 18 Delta’s Petition at 4

- 5. 19 Delta’s Peti tion at 5.Answer of American Airlines, Inc. To Petition for Reconsideration

Page 10 of 15

reflects different bilateral re gimes as well as dynamic economic circumstances. Each proceeding stands on its own. The Department considers numerous factors in deciding each case. The basic facts already established in this case illustrate the point: Delta’s

own conduct necessitated the need to re

- examine the strategically important U.S.

- Haneda market. Delta errs badly in analogizing this case to a 2008 case in which the Department had allocated 105 weekly U.S.

- Brazil frequencies to various points in Brazil among four U.S. carriers. 20 Delta does not and cannot show that the legal, political, economic, and even diplomatic dynamics of the U.S.

- Haneda slot pair situation equate to the complex bilateral relationship that governs U.S.

- Brazil frequencies. Indeed, the differences between the facts surrounding Brazil and Haneda could not be starker. In the Brazil matter, United Airlines, Inc. (“United”) held unused, fully unrestricted frequencies obtained through a route transfer and had no firm plans for those frequencies. No other carriers expressed an interest in using those frequencies either and there was no reason to hold a carrier

- selection proceeding. But when other carriers expressed interest, United did not object to reallocation and did not seek to prevent entry by another carrier

. 21 That situation is worlds apart from the current situation, where Delta is not using the frequencies effectively, yet is resisting the Department’s effort to assess the public interest and consider competitive options.

20 Delta’s Petition at 5, citing 2008 U.S.

- Brazil Combination Frequency Allocation Proceeding, Order 2008

- 10

- 20.
21 Order 2008

- 10

- 20 at 3 (noting that United had neither answered the applications nor challenged the applicants’ allegations regard ing its nonuse of the frequencies).Answer of American Airlines, Inc. To Petition for Reconsideration

Page 11 of 15
The complex Brazil frequency regi me also contrasts sharply with the basic U.S.

- Japan arrangement: the U.S.

- Japan bilateral in this situation gives the United States four daily round

- trip slot pairs for one airport in Japan

— Haneda. Haneda slot pairs are a highly valuable, highly desira ble, and highly sought after scarce resource. By contrast, the 2008 Brazil case involved more than one hundred frequencies with different sets of operating rights attached to different frequencies. Delta also complains that, because the Department took “no action for three and a half years” to revoke United’s Brazil frequencies, it is unfair to reallocate the underused slot pair Delta is using to operate Seattle

- Haneda service. 22 In fact, the Department is merely treating Delta’s effective abandonment of the slot pairs the same way it treated United’s unused frequencies. When American and Delta applied for the unused Brazil frequencies, United did not object and the Department reallocated the frequencies within three months. 23 The Department took action as soon as other carriers applied for the frequencies. It is doing the same thing here. With respect to Haneda, the Department granted 50 percent of the slot pairs (and
67 percent of the U.S. mainland slot pairs) to Delta. It then permitted Delta to move its failed Detroit

- Haneda service to Seattle after a carrier

- selection proceeding, 24 based on Delta’s new “Seattle Promises.” Thus, the Department has already excused Delta once
from an ill

- advised market selectio n that Delta made through its “Detroit Promises,” which Delta also could not fulfill. Delta knows that the Department would not move the

22 Delta’s Petition at 5 , citing Order 2008

- 10

- 20, 2008 U.S. Brazil Combination Frequency Allocation Proceeding (Oct. 21, 2008). 23 Order 2008

- 11

- 21

. 24 Order 2012

- 8

- 20.Answer of American Airlines, Inc. To Petition for Reconsideration

Page 12 of 15
authority yet again without another carrier

- selection proceeding; and that such a proceeding would expose Delta’s fail ure to fulfill its “Seattle Promises” and its
abandonment of the route for six months. Delta accordingly seeks to dispense with any public interest inquiry whatsoever and tries to hide behind technical dormancy rules to exclude any other carrier that migh t be able put the Haneda slot pair to far better competitive and public benefit use. 25

3. If Delta Has Firm Plans t o Fully Use t he Seattle
- Haneda Slot Pair , It Should Prove It i n t he Carrier Selection Proceeding. Delta contends that the Department cannot re view allocation of the U.S.

- Haneda slot pair because Delta has “firm plans” to use the Seattle

- Haneda slot pair. That assertion is irrelevant to its petition for reconsideration. The contention

— yet another Seattle Promise

— is premature: the place for Delta to make its case that its plans are firm and credible and that Delta can be relied on will be in the evidentiary phase of this proceeding. No doubt because Delta lacks confidence as to what the record will actually show about its “firm plans,” it i nsists that , by simply asserting its “firm plans,” it has insulated itself altogether from review of the Haneda slot pair. Putting aside the credibility of Delta’s “firm plans,” Delta knows that simply saying it does not make it so. Delta actively partic ipated in the U.S.

- Colombia case discussed above in which American not only had firm plans to use the frequencies, but actually started using the frequencies

25 Delta points to market seasonality to explain i ts underutilization of the Seattle authority. Such a defense is not credible. T okyo is not regarded as a seasona l market. All U.S. and Japanese airlines operating between Narita and the United States operate year

- round service. And, tellingly, Delta’s own Seattle

- Narita service operates year

- round.Answer of American Airlines, Inc. To Petition for Reconsideration

Page 13 of 15
during the pendency of the case, and the Department nonetheless withdrew them. 26 That case present ed reconsideration issues nearly identical to those raised by Delta, and the Department overruled American’s objections. Delta also claims that the Department is treating Delta differently from the carriers in two other U.S.

- Brazil frequency cases (different from the 2008 case discussed above) where carriers asserted firm plans to use frequencies. Delta is wrong. The 2005 case Delta cites actually proves the opposite point: the order actually did reallocate five of United’s unused frequencies to Delta, despite United’s asserted firm plans to use
them. 27 Delta says the order refused “to confiscate and reallocate to American ” the five frequencies, 28 but what matters is that the order did reallocate them

— only to Delta , not American. In the second case, the Department did refuse to reallocate United’s U.S.

- Brazil frequencies where United had firm plans to use the frequencies in question. 29 Delta will have every opportunity for yet a second time to show that it has firm plans to make effective use of the U.S.

- Haneda slot pair at issue here. 4. Delta Wrongly Accuses the Department of Refusing to Consider Alternative Options. Delta ’s final argument is that the Department refused to consider options other than reallocating the Haneda slot pairs. But of course alternative options are presumably

26 Order 2008

- 5

- 27. 27 Delta’s Petition at 6, citing Order 2005

- 4

- 13 at 3 n .5. The foot note records that American had an application for five weekly frequencies pending at the time in a different docket but it was never acted on. 28 Delta’s Petition at 6 (emphasis added) . In addition, the cited footnote does not seem to contain the quotation shown at the top of page 6, although something similar does appear in the text. 29 Order 95

- 3

- 52 at 4

.Answer of American Airlines, Inc. To Petition for Reconsideration

Page 14 of 15
just the kind of factor the Department would consider in its review of the existing alloca tion

— they are not a reason to avoid review altogether.
O rder 2014

- 12

- 9 itself makes the point clear. Delta contends that the Department has ignored its earlier proposal to revise the dormancy condition, which would better protect Delta’s “reliance int erests” than reallocation of the slot pairs. 30 But that order states clearly that the Department believes its standard conditions are sufficient, but that if any party holds a different view, “it will be free to argue its point on the record.” 31
There is c ertainly no reason for the Department to revise its standard dormancy condition in favor of a fair review of the proceeding. The Department has had almost twenty years of experience with its standard dormancy condition and it has served all parties well, including the traveling public, carriers, and other market participants. Concl us ion American respectfully urges the Department to deny Delta’s petition for reconsideration. The Department in this case is following decades of precedent and practice in pursuit of the public interest. The Department is acting reasonably in reviewing its decision of nearly two years ago, since Delta is not delivering on the promises it made to obtain the authority to use the scarce slot pair in the Seattle

- Haneda market. American will provide compelling evidence that its proposed Los Angeles

Haneda service will provide more U.S. consumers with a competitive service option that is substantially superior to Delta’s service, that American will provide greater

30 Delta’s Petition at 6

- 7. 31 Order 2014

- 12

- 9 at 6 n. 20.Answer of American Airlines, Inc. To Petition for Reconsideration

Page 15 of 15
competitive ben efits, and that American’s service will maximize the public benefits of
this scarce resource. Respectfully submitted,

Howard Kass Robert A. Wirick Abigail DonovanCERTIFICATE OF SERVICE
I, Abigail Donovan, certify that, on January 2, 2015, I ca us ed to be served a copy of the foregoing Answer of Ameri can Airlines, Inc. to Petition for Reconsideration by email upon those addressees listed below:
paul.gretch@dot.gov (DOT) brian.hedberg@dot.gov ( DOT) brett.kruger@dot.gov ( DOT) todd.homan@dot.gov (

DOT) peter.irvine@dot.gov ( DOT) EngleTS@ state.gov (

Dep’t of State ) cristinasa@state.gov ( Dep’t. of State ) eugene.alford@ita.doc.gov ( Dep’t. of Commerce) ejames@jamh off.com (

Allied Pilots Association ) seth.waxman@wilmerhale.com ( Delta ) sascha.vanderbellen@delta.com (Delta) chris.walker@delta.com (Delta) Mike.Donatelli@alpa.org ( Delta MEC/ALPA) john

. allen @faa.gov ( FAA ) jhill@cooley.com (Hawaiian) Perkmann@cooley.com ( Hawaiian) bberlin@cooley.com ( Hawaiian ) Robert.Lamansky@hawaiianair.com (Hawai ian) glindsey@lawa.org ( Los Angeles World Airports) ishiwata.k@portseattle.org ( Port of Seattle) safora.i@portseattle.org (P or t of Seattle) dan.weiss@united.com ( United) steve.Morrissey@united.com ( United) gmurphy@crowell.com ( United) sseiden@crowell.com ( United) iinfo@airlineinfo.com (AirlineInfo.com)

_________________________________

Abigail Donovan