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CONTENTS
Consolidated Answer of American Airlines, Inc.
Supporting Testimony from Tessie Aral, President of ABC Charters, Inc.
Letter of Support from Mike Fernandez, Chairman of MBF Healthcare Partners, L.P.
Rebuttal Exhibits
BEFORE THE
U.S. DEPARTMENT OF TRANSPORTATION
WASHINGTON, D.C.
____________________________________
)
Application of
)
)
AMERICAN AIRLINES, INC.
)
)
in the matter of 2016 U.S.-Cuba Frequency )
Allocation Proceeding
)
____________________________________)
Docket DOT-OST-2016-0021
Paul T. Denis
Steven G. Bradbury
William B. Sohn
Robert A. Wirick
Managing Director
Regulatory and International Affairs
DECHERT LLP
1900 K Street NW
Washington, D.C. 20006
(202) 261-3300
paul.denis@dechert.com
steven.bradbury@dechert.com
william.sohn@dechert.com
John B. Williams
Senior Analyst
Regulatory and International Affairs
AMERICAN AIRLINES, INC.
1101 17th Street, NW
Washington, D.C. 20036
(202) 326-5153
howard.kass@aa.com
robert.wirick@aa.com
john.b.williams@aa.com
March 14, 2016
Charles A. Hunnicutt
Brent Connor
THOMPSON HINE LLP
1919 M Street NW, Suite 700
Washington, D.C. 200036
(202) 331-8800
charles.hunnicutt@thompsonhine.com
brent.connor@thompsonhine.com
TABLE OF CONTENTS
Executive Summary ...................................................................................................................... 1
Discussion....................................................................................................................................... 4
I.
II.
III.
IV.
V.
A.
B.
C.
Only Americans Proposed Service from MIA Maximizes Public Benefits ........ 9
MIA Has Long Been the Preferred Airport for U.S.-Cuba Service ................... 12
B.
FLL is Not Convenient for Most South Florida Cuban Americans .................. 15
TPA Is the Only Other Florida Airport that Might Merit Scheduled Service
to HAV, and Its Award Should Not Exceed One Daily Frequency ............................ 17
A.
B.
B.
C.
D.
E.
F.
G.
H.
I.
J.
K.
L.
Conclusion ................................................................................................................................... 29
BEFORE THE
U.S. DEPARTMENT OF TRANSPORTATION
WASHINGTON, D.C.
____________________________________
)
Application of
)
)
AMERICAN AIRLINES, INC.
)
)
in the matter of 2016 U.S.-Cuba Frequency )
Allocation Proceeding
)
____________________________________)
Docket DOT-OST-2016-0021
American is the only airline to propose sufficient frequencies to meet the anticipated near-term
growth in demand for U.S.-Cuba travel by the Miami-Dade Cuban-American community
nearly half the Cuban-American population of the entire United States.
And Americans
proposed schedule is the only proposal that will fully satisfy the Administrations objective
underlying this proceeding.
First, Americans proposed service lays the strongest foundation for connecting the
Miami-Dade Cuban-American community with Cuba. An allocation of frequencies based purely
on either (1) the distribution of Cuban Americans among the population centers served by the
airports for which the applicants have requested U.S.-Cuba frequencies, or (2) the originating
airports for U.S.-Cuba charter flights in 2015, supports the allocation of ten HAV frequencies to
American at MIA.
This proposed allocation still leaves ample room for frequencies for
scheduled service to and through other connecting hubs, while ensuring the needs of MiamiDade Cuban Americans are met.
Americans proposed service is superior due to Americans unmatched presence at MIA and
The Applications of Other Carriers Confirm that MIA is the Necessary Starting
Point for Successfully Restoring and Growing U.S.-Cuba Scheduled Service
This route allocation proceeding is the most contested case in the Departments history.
The thirteen applicants here far exceed the number of applicants in any other case before the
Department, and combined they have requested 397 weekly frequencies from the United States
to Havana, when just 140 are available. 1 Despite this fierce competition for these limited
resources, however, the applicants have reached a remarkable consensus on the realities of U.S.Cuba travel that must govern the allocation. The applicants generally agree that:
U.S.-Cuba traffic will largely be limited to those visiting family and relatives in Cuba,
and to those traveling for other reasons permissible under current OFAC sanctions. 2
The demand for U.S.-Cuba travel will therefore be strongest in Miami-Dade County,
Florida, where nearly half the Cuban-American population resides. 4
Critically, no applicant disputes that Cuban Americans will account for the surest demand for
U.S.-Cuba scheduled service for the foreseeable future. 5
The combined requests for non-HAV frequencies are less than the total number of non-HAV frequencies
authorized by the MOU. To best advance the Presidents objective to resume U.S.-Cuba scheduled service, the nonHAV frequencies requested should all be expeditiously granted so that U.S. carriers can soon begin service to Cuba.
2
See, e.g., Application of Alaska Airlines, Inc., at 8; Application of Frontier Airlines, Inc., at 6;
Application of JetBlue Airways Corp., at 18; Application of Silver Airways Corp., at 9; Application of Spirit
Airlines, Inc., and Ex. NK-CU-6.
3
See, e.g., Application of Alaska Airlines, Inc., at 6 n. 5; Application of JetBlue Airways Corp., at 9;
Application of Southwest Airlines Co., at 6; Application of Spirit Airlines, Inc., at Ex. NK-CU-6.
4
5
See, e.g., Application of Delta Air Lines, Inc., at 45; Application of Frontier Airlines, Inc., at 6.
See, e.g., Application of JetBlue Airways Corp., at 9 (travel will remain fundamentally restricted to
cities with strong Cuban familial and cultural ties for the foreseeable future.); Application of Southwest Airlines
ties with Cuba are the strongest in Miami-Dade County, and Americans ten requested MIAHAV frequencies are firmly supported by the factors most indicative of near-term demand for
U.S.-Cuba travel:
Nearly 84 percent of all charter flights between the U.S. and HAV in 2015 originated
from MIAalmost 11 times more than from the next U.S. airport. Ex. AA-R-111.
Indeed, other applicants have requested MIA-HAV frequencies despite having a minimal
presence in Miami-Dade County and minimal service at MIA, because demand for U.S.-Cuba
travel from MIA dwarfs the demand from any other airport.
applicants on the principles governing U.S.-Cuba travel fully supports Americans proposed
schedule. Only Americans proposed schedule, which makes MIA the cornerstone of U.S.-Cuba
scheduled service, lays the strongest possible foundation for the future growth of U.S.-Cuba
cultural and economic ties.
Co., at 56 (Naturally the communities with ties to Cuba will have the greatest interest and need to travel to Cuba
under the 12 OFAC categories.).
6
Remarks of Senator Jeff Flake (Mar. 10, 2016). See Ex. AA-R-201.
Letter from Mike Fernandez to Secretary Anthony Foxx (Mar. 14, 2016).
Americans Proposed Schedule Offers the Strongest Foundation for Service from
MIA, While Providing Sufficient Frequencies for Scheduled Service to and Through
Other Connecting Hubs
Americans proposed schedule is the only proposal that meets the needs of the Miami-
frequencies proposed by American, which matches current demand and anticipated near-term
growth. 8
Anything less than ten daily MIA-HAV frequencies leaves a shortage of seats for the
residents of Miami-Dade County, and falls short of the Departments long-standing practice of
allocating scarce resources in a manner that best suits the overall needs of the traveling public.
Failing to meet the needs of Miami-Dade would seriously undermine the Presidents and,
necessarily, the Departments policy towards Cuba.
community is at the core of renewed U.S.-Cuba engagement, and any barrier to its ability to
enjoy adequate scheduled service to Cuba from MIA threatens the Administrations broader
goals. Americans unparalleled presence and commitment to both MIA and Cuba enable it to
provide superior service for linking MIA with Cuba, and its extensive network from MIA
enables it simultaneously to connect those with Cuban ties across the United States with Cuba.
No other airline can do the same.
A.
Comparing each applicants requests to the distribution of Cuban Americans and U.S.Cuba charter flights shows that Americans proposed schedule is most aligned with these
metricsthe two most reliable metrics of near-term demand for U.S.-Cuba scheduled service. In
8
As American explained in its Application, the average number of reported MIA-HAV charter flights in
2015 was 7.3 per day, a 14 percent increase from 2014. Application of American Airlines, Inc., at 4. This number
is understated because many U.S.-Cuba flights are not subject to the reporting requirements. At this rate of growth,
which will accelerate when scheduled service arrives, there will be demand for ten daily MIA-HAV frequencies by
2017, if not earlier.
Under this formula, MIA would receive 12 daily frequencies to HAV, and no other airport would
receive more than a single daily frequency. This should come as no surprise, since Miami-Dade
County has ten times the Cuban-American population as any other county in Florida and any
other U.S. state besides Florida. 9
Both graphs demonstrate that Americans application is reasonable under the Departments
standards and should therefore be fulfilled.
actual demand for U.S.-Cuba scheduled service where that demand is actually located, and only
Americans proposed schedule maximizes the public benefits of the Departments allocations.
B.
Americans proposed schedule is not only tailored to the demand from MIA; it leaves
sufficient frequencies to serve those communities with ties to Cuba besides Miami-Dade County.
Appropriate frequencies may be allocated to other major U.S. hubs, such as Charlotte (CLT),
Among the airlines proposing service from MIA, none provide anywhere near the level of
public benefits that Americans offers. The MIA-HAV service proposals of Delta, Eastern, and
Frontier are inferior for many reasons. Delta and Frontier have little to no MIA presence,
connectivity at MIA, and experience with Cuba, which suggests their proposed service is not
10
Americans proposal also accommodates sufficient frequencies for cargo service, though as discussed in
the part of this Answer addressing FedExs application, the fact that cargo service from HAV to MIA would not be
economically viable calls into question the need for allocating U.S.-Cuba frequencies solely to cargo at this time.
disqualifying issues. First, Eastern lacks the necessary authority to engage in foreign scheduled
air transportation to Cuba. Ex. AA-R-103. Second, Eastern lacks the ability to sell scheduled
tickets over the Internet; it has no online booking portal. Ex. AA-R-103. Until both of these
fundamental issues are cured, Easterns profile with respect to U.S.-Cuba operations should be
that of a charter service provider only.
connects 50 U.S. cities (and 7 other cities in Canada and Europe) with Cuba through MIA, ex.
AA-R-207, and it builds on a history of service to HAV that includes more than 600 charter
flights between the U.S. and HAV in 2015 alone.
Ex. AA-R-219.
Americans unrivaled
experience of 25 years with Cuban ground operations, other unique local conditions, and aviation
authorities will enable it to offer and maintain the best service for the traveling and shipping
public. Instituting Order at 2. From its hub at MIA, American will offer the best service to the
Miami-Dade Cuban-American community, while connecting those with Cuban ties across the
United States to the island nation.
The Administrations objectives are too important to rely on airlines with little Miami
presence and no appropriate experience to provide consistent, reliable service to link the MiamiDade Cuban-American population with Cuba. The public benefits at stake here go well beyond
parochial aviation interests. Should the Department disperse MIA-HAV frequencies among
airlines with no commitment to Cuba and no experience with its unique aviation requirements,
the Administrations goals of growing U.S.-Cuba cultural and economic ties could be lost. The
future growth of U.S.-Cuba engagement depends on frequent and reliable scheduled service
between Miami-Dade County and Cuba, and only American can provide it.
III.
airport in this proceeding relative to passenger demand. Contrary to the assertions by some
applicants, the concentration of Cuban Americans residing near MIA does not justify the award
of multiple daily frequencies from FLL, unless the guiding standard for allocating frequencies is
MIA Has Long Been the Preferred Airport for U.S.-Cuba Service
Those providing U.S.-Cuba charter service strongly favor MIA over FLL, and that has
been the case for decades. In 1980, the U.S. Customs Service originally designated FLL rather
than MIA as the only airport authorized for U.S.-Cuba flights, 12 but the Customs Service soon
realized that this decision was suboptimal, and replaced FLL with MIA. The Customs Service
explained in 1987 that in addition to favorable Customs staffing at MIA, MIA was the preferred
airport for airlines offering U.S.-Cuba service and for their passengers:
11
See Application of JetBlue Airways Corp., at 21 (Ft. Lauderdale/South Florida and New York City are
two of the three largest and most important markets for Cuba charter air service because of their large Cuban
populations. . . .); Application of Southwest Airlines Co., at 4 (The High Concentration of Cuban Americans in
South Florida Justifies a Majority of the Frequency Allocations in That Area.); Application of Spirit Airlines, Inc.,
at 3 (Spirit base fares will be particularly attractive to . . . the approximately 1 million residents of Cuban descent
in South Floridas tri-county area. . . .).
12
2,918 HAV-bound charter flights (83.3% of all U.S. flights to HAV) originated from
MIA in 2015. Just 69 (2.0%) originated from FLL. Put another way, 42 times as
many HAV-bound flights originated from MIA as from FLL. Ex. AA-R-202, 407.
The average number of HAV-bound flights in 2015 was more than seven per day
from MIA, and less than two per week from FLL.
There were 1,430 flights from MIA to non-Havana Cuba destinations in 2015. From
FLL, there was only one. 14
Comparing the total requested frequencies to HAV from MIA and FLL, to an allocation
keyed to the proportion of charter flights flown to HAV from both airports in 2015, shows just
how over-requested FLL-HAV frequencies are in this proceeding:
13
14
This is undoubtedly the result of demographics. Figure 4 below, which compares the
total requested frequencies to HAV from MIA and FLL to an allocation keyed to the CubanAmerican population surrounding each airport, looks remarkably similar:
The concentration of Cuban Americans near MIA plainly matters. The resumption of U.S.-Cuba
scheduled service cannot change this demographic reality, and it would only inconvenience
passengers and diminish public benefits to award excessive frequencies to FLL.
B.
The Cuban Americans in these communities are much better served from MIA than from FLL.
The two airports cannot be considered equals for the surrounding Cuban-American communities.
These practical realities make travel to FLL undesirable for U.S.-Cuba travel, as Tessie Aral, the
President of one of the largest providers of U.S.-Cuba charter flights, explains in her testimony.
Ex. AA-R-T-1.
The journey to FLL from Hialeah, Florida illustrates the disparity between MIA and FLL.
Located immediately north of MIA, Hialeah is home to more than 170,000 Cuban Americans
almost double the entire Cuban-American population of Broward County. MIA is just a few
minutes away for Hialeah residents, whereas FLL is far to the north. 15 The Cuban Americans
residing south and southwest of MIA face an even longer trip to FLL, since they must drive
directly past MIA and continue for nearly thirty miles to reach FLL.
15
The shortest route to FLL from Hialeah requires taking the I-95 express lanes, which are subject to tolls
as high as $10.50 and are often heavily congested. Michael Turnbell, $10.50 Tolls Fail to Keep I-95 Express Lanes
Moving, Sun-Sentinel (Feb. 26, 2015), http://www.sun-sentinel.com/local/broward/fl-95-express-toll-congestion20150226-story.html.
TPA Is the Only Other Florida Airport that Might Merit Scheduled Service to
HAV, and Its Award Should Not Exceed One Daily Frequency
The Department should also decline the service proposals of some applicants to award
multiple daily frequencies to TPA, MCO, and other Florida cities. TPA and MCO each received
a combined four daily frequency requests from other applicants, third among all U.S. airports.
16
The relatively recent authorization of FLL for U.S.-Cuba flights cant be blamed. TPA was approved
for U.S.-Cuba flights at the same time, yet nearly five times as many U.S.-Cuba flights originated from TPA as from
FLL in 2015. And the growth in reported MIA-HAV flights between 2014 and 2015an average of nearly one
additional flight per dayfar surpasses the total number of 2015 FLL-HAV flights. New demand for travel to Cuba
sparked by warming U.S.-Cuba relations remains heavily concentrated at MIA. And again, if there was demand for
FLL-HAV service at the level of more than one per week, one of the FLL applicants surely would have flown these
charters, as JetBlue did at TPA.
Whether TPA can support even one daily flight to HAV is questionable, and there is no
basis to assume local demand will support more. TPAs low ranking by both JetBlue and
Southwest 17 confirms its relative unimportance as a source for U.S.-Cuba traffic, and raises the
question of whether it should receive a daily frequency in this phase of U.S.-Cuba frequency
allocations.
Demographic and charter traffic data show that JetBlues and Southwests separate
requests for two TPA-HAV frequencies both substantially surpass anticipated demand. The
award of even one daily HAV frequency to TPA (365 annual flights) represents a significant
increase over 2015 TPA-HAV charter traffic (267 annual flights)almost 40 percent. And
unlike MIA, there is only minimal connecting traffic at TPA. Traffic to Cuba from TPA is
almost entirely limited to the Cuban-American population in Hillsborough County, which is only
about 85,000less roughly 10 percent of the Cuban-American population of Miami-Dade. Ex.
AA-R-429.
population near the airports requested for U.S.-Cuba service (an appropriate measure of analysis
here given the lack of connecting traffic through TPA), TPA would receive just one daily
17
JetBlue ranked TPA-HAV as its fourth gateway priority, and Southwest ranked TPA-HAV as its nextto-last frequency priority out of 9.
There is no basis for the Department to award HAV frequencies to Orlando, Fort Myers,
West Palm Beach, Key West, and Jacksonville.
regions is small, and few charter flights to Cuba have originated from these airports. These cities
do not merit scheduled service to HAV in this first phase of U.S.-Cuba frequency allocations,
and their near-term needs can be met with one-stop scheduled service and charter service.
As to Orlando, demographics and charter traffic data show that a daily scheduled MCOHAV frequency would fly nearly empty.
flightsan average of 1 per week. Ex. AA-R-205. Daily scheduled service would be a gigantic
increase from this level. The lack of charter traffic should be no surprise, since there are just
30,000 Cuban Americans in Orange County, where MCO is located. Ex. AA-R-425. An overall
allocation of scheduled frequencies based purely on local Cuban-American population or keyed
to the proportion of 2015 Cuba charter traffic that originated at MCO would yield close to zero
HAV frequencies at MCO. 18 That combined with the negligible connecting traffic through MCO
shows MCO does not deserve scheduled service to HAV.
Americans proposed single plane service through MIA) and charter service meet Orlandos
needs. Despite the four daily scheduled MCO-HAV frequencies requested, the low ranking of
18
At most, two weekly frequencies, not two daily frequencies as JetBlue requested, or even one daily
frequency as Delta and Southwest requested. See Figure 1, Figure 2.
proceeding. The allocation of these scarce frequencies is not supported by the local CubanAmerican population and/or the 2015 charter traffic data, which are the best indicators of nearterm demand. These flaws, as well as other problems with the various proposals, are described
in detail below. 21
19
JetBlue ranked MCO-HAV 5th and 11th out of 15. Southwest and Delta both ranked MCO-HAV last.
20
Key West shows more charter flights, but all of these flights are operated with smaller aircraft with only
a minimal number of seats.
21
In addition, many of the connections proposed by the other applicants suffer from numerous
deficiencies: they show insufficient connect times; they include one-way connections; they use a connecting window
beyond the customary four hours; and they do not exclude cities for which circuity is in excess of 155 percent. The
descriptions of the other applicants realistic connections are included below, which are adjusted based on the same
methodology American used to determine its own connections created by its proposed service.
between FLL and HAV, yet it proposes four daily scheduled flights between FLL and HAV.
This vastly surpasses current demand, as described above in Part III of this Answer. JetBlues
request is particularly surprising because its weekly FLL-HAV charter flight has historically had
a load factor of around 50 percent. By comparison, Americans MIA-HAV charter flights have
had load factors of around 75 percent. Ex. AA-R-415. And JetBlues proposed FLL-HAV
service will have only 15 connections in both directions. Ex. AA-R-410. Whether JetBlue can
support even one daily FLL-HAV flight is doubtful, and its request for four daily FLL-HAV
flights lacks any foundation.
New York (JFK): JetBlue currently operates just two weekly JFK-HAV charters, so its
proposed two daily JFK-HAV frequencies represent a seven-fold increase in JFK-HAV flights
(assuming no Delta JFK-HAV flights). Ex. AA-R-418. How JetBlue plans to support these
flights is unclear, when the load factor on its two weekly charter flights has been mediocre. To
attain an average load factor of 60 percent on its proposed daily JFK-HAV flights, JetBlue would
require that demand be stimulated by nearly 900 percent. Ex. AA-R-420. This is outside the
22
frequencies based on demographic and charter traffic data. The charter traffic from MCO to
HAV in 2015 was around the level of one flight per week. The tiny Cuban-American population
in Orlando, combined with JetBlues five connections to HAV through MCO, ex. AA-R-426,
will not support anywhere near the level of one daily MCO-HAV scheduled flight, let alone two.
Tampa (TPA): Similar to JetBlues proposed daily service from JFK, JetBlue offers no
answer as to how it plans to go from operating two weekly TPA-HAV charter flights to two daily
TPA-HAV scheduled frequencies.
frequencies create only four connections to HAV through TPA, ex. AA-R-430, there is zero
basis to assume that demand for service from TPA will suddenly skyrocket to support two daily
TPA-HAV frequencies.
Newark (EWR): JetBlues requested daily EWR-HAV service must be considered an
extreme reach. JetBlue does not have a hub at EWR, and its proposed EWR-HAV service
creates no connections in both directions. Ex. AA-R-436. Especially when considered alongside
the other requests from JFK and EWR, there is no reason for the Department to award this
requested frequency.
Boston (BOS): JetBlues proposed daily BOS-HAV service is aspirational at best. The
Cuban-American population of Boston is just 11,000, and there have never been any BOS-HAV
charter flights. Ex. AA-R-437, 438. Connecting traffic through BOS to HAV will also be
miniscule given its extreme Northeast geographic location.
Ex. AA-R-439.
Boston was
The nine HAV frequencies requested by Southwest cover three of the U.S. gateways also
requested by JetBlue, and these requests suffer from the same flaw: They are divorced from
demographic and charter traffic reality. Moreover, Southwests minimal international operations
from Florida and lack of experience in operating charter flights to Cuba make it particularly
unsuited for its requested HAV frequencies.
Fort Lauderdale (FLL): The six daily FLL-HAV frequencies proposed by Southwest
would amount to 4,380 flights annuallya 6,348 percent increase over the 69 FLL-HAV charter
flights flown in 2015. Ex. AA-R-507. The absurdity of this result speaks for itself.
Tampa (TPA): As described earlier in this Answer, TPA might support one daily flight
to HAV at most. Southwests request for two TPA-HAV frequencies is therefore excessive.
Orlando (MCO):
There are many reasons to doubt that Delta can successfully operate its proposed MIAHAV and MCO-HAV daily frequencies, neither of which originate from a Delta hub. Deltas
two recent attempts to operate international service from non-hubs, including MIA, suggest that
Delta cannot sustain this service. Delta operated MIA-LHR service for just 13 months before
terminating it, and Deltas PHL-LHR service, another non-hub international route which was
inaugurated in April 2015, reached a peak load factor of just 55 percent in August before
Frontiers proposed service suffers from three glaring flaws. First, the first two of
Frontiers proposed MIA-HAV daily frequencies are conditioned on Frontier receiving a daily
DEN-HAV frequency, and there is no basis for the Department to award nonstop service
between Denver and Havana. Ex. AA-R-701. The Cuban-American population of Denver is
approximately 3,500far from sufficient to support even one weekly scheduled flight. Ex. AA-
Spirit only proposes service to HAV from FLL, and as discussed above, there is limited
demand for FLL-HAV service. The Broward County Cuban-American population is only 10
percent as large as Miami-Dade Countys, and historically, FLL has supported barely more than
a single weekly charter flight to HAV. Spirits request for two daily FLL-HAV frequencies is
excessive, especially given Spirits lack of experience in Cuba and that its proposed service
would create only ten connections through FLL in both directions. Ex. AA-R-806.
F.
Several problems with Uniteds proposed weekly service from IAD, IAH, and ORD arise
from the poor geographic position of its EWR hub relative to these airports. On Saturdays,
travelers from these airports will enjoy nonstop service, but on every other day of the week, they
will have to endure substantially longer connecting flights through Uniteds EWR hub to travel
between the United States and Cuba. For instance, a HAV-EWR-IAH flight has extreme circuity
and a travel time of nearly ten hours, compared to a nonstop travel time of under three hours
between IAH and HAV. Ex. AA-R-904. Likewise, the travel time for connecting flights
through EWR to ORD and IAH is double the nonstop travel time. Ex. AA-R-905, 906. This
effectively forces travelers on Uniteds proposed service from IAD, IAH, and EWR to travel to
and from Cuba exclusively on Saturdays, and this constraint makes Uniteds proposed service
Alaskas request for two daily LAX-HAV frequencies bears no relationship to anticipated
demand. American currently provides a weekly charter flight between LAX and HAV, and
knows the potential demand in the LAX-HAV market better than any other airline. If LAX
could support more than one weekly frequency to HAV, American would have applied for more.
The lack of LAX-HAV demand is demonstrated by the fact that the weekly charter flight
American operates has a load factor of under 50 percent. 23 Ex. AA-R-1002. Alaska must
stimulate demand by over 600 percent to support a 50 percent load factor on just one of its two
proposed daily LAX-HAV frequencies, ex. AA-R-1003, and Alaska offers no explanation for
how it plans to do so. The three connecting flights Alaskas proposed service creates will hardly
increase traffic over current levels or improve travel times. Ex. AA-R-1004, 1005. LAX is best
served, for now, with the weekly scheduled service to HAV proposed by American, not the daily
service proposed by Alaska.
H.
The two daily frequencies Sun Country proposes to operate to HAV from both Fort
Myers (RSW) and Minneapolis St. Paul (MSP) lack any support from demographic and
charter traffic data. The Cuban-American population in both cities is scant, as was the charter
traffic to Cuba that originated from both airports in 2015. Ex. AA-R-1101, 1103. There were
nine RSW-HAV charter flights and one MSP-HAV charter flight in 2015. 24
Cuba.
Finally, Sun
23
Americans contract with the charter company prohibits American from disclosing the actual load factor.
24
This was a one-off charter flight operated by Delta to transport the Minneapolis Symphony to and from
The cargo service proposed by FedEx raises two issues. First, FedExs proposed service
from HAV to Mrida, Mexico (MID) is arguably outside the scope of the U.S.-Cuba MOU.
The MOU provides that [t]he permission to perform scheduled and charter services between
any point or points in the United States and any point or points in Cuba, and merely allows for
stops for non-traffic purposes within or outside the territory of either country. 25 Ex. AA-R1201. Whether this permits FedExs proposed MIA-HAV-MID-MIA frequency is unclear, and
the Department must resolve this question before granting FedEx any scheduled frequencies.
Second, FedEx admits that it must fly from HAV to MID so that the flights can be economically
viable. 26 This raises another important question: Is now the right time to award a scarce HAV
scheduled frequency purely for cargo, when there is insufficient demand for cargo service from
HAV to MIA? At this time, charter flights may be more appropriate for U.S.-Cuba cargo
service.
J.
Dynamics
proposal deprives the public of valuable frequencies until nearly December 2016, when it plans
to start service to Cuba. 27 And Dynamic may need to further delay startup, as this period is the
minimum time it needs to make its proposed service viable. 28 The proposal also deprives a
25
26
27
28
Id.
Dynamic has not provided a clear timeline indicating when it will satisfy the
conditions of receiving effective authority, and when the Department will complete its review of
recent safety and delay incidents. 29 Second, the foreign scheduled air transportation authority
Dynamic will have if its certificate becomes effective is limited to two points, one in China and
one in Guyana. Dynamic proposes a substantial change in operations that more than doubles the
certificate authority it might receive and substantially alters the operating costs upon which the
Department based its latest fitness finding for Dynamic. But Dynamic has not shown that it has
sufficient resources to cover the pre-operating costs and operating costs related to these routes.
Third, Dynamic has no experience operating to Cuba.
restrictions on passengers, the large size of Dynamics equipment, and Dynamics proposed U.S.
gateways, Dynamic likely will not be able to sustain this service. No other airline has proposed
operating U.S.-Cuba service with 280-seat aircraft, and for good reason: These planes will most
likely fly at load factors that make such service economically disastrous.
K.
Eastern is not fit and able to perform its proposed Cuba operations.
By its own
admission, it does not possess sufficient safety authority from the FAA to operate the
29
Id. at 3. In December 2015, Dynamic reported to the DOT various incidents, including an engine fire
during taxi on October 29, 2015, and a lengthy tarmac delay. Letter from Jason E. Maddux, Counsel, Garofalo
Goerlich Hainbach PC, to Lauralyn Remo, Chief, Air Carrier Fitness Division, DOT (Dec. 30, 2015) (on file at
www.regulations.gov). In February 2016, Dynamic reported mysterious damage to an aileron. Letter from Jason E.
Maddux, Counsel, Garofalo Goerlich Hainbach PC, to Lauralyn Remo, Chief, Air Carrier Fitness Division, DOT
(Feb. 9, 2016) (on file at www.regulations.gov).
Silvers proposed use of 34-seat turboprop planes would drastically underutilize the
available frequencies to HAV. This equipment is far too small to serve anticipated U.S.-Cuba
traffic, and Silver should not be awarded any frequencies to Cuba when many carriers, such as
American, have proposed service using planes that can seat five times as many passengers.
There are far too few frequencies available in this proceeding to allocate even one to a carrier
proposing to operate it with a small, turboprop plane.
Conclusion
The applications filed in this proceeding make clear that connecting the Miami-Dade
Cuban-American community with Cuba is of paramount importance. Among all applicants,
Americans proposed schedule best matches demand and traffic patterns from Miami-Dade
County and the rest of the nation, and lays the strongest foundation for the growth of U.S.-Cuba
cultural and economic ties. The success of these scheduled frequencies will impact U.S.-Cuba
relations for years to come, and will be an extraordinary achievement for the Presidents legacy.
30
Respectfully submitted,
________________________
Howard Kass
Vice President
Regulatory Affairs
Paul T. Denis
Steven G. Bradbury
William B. Sohn
Robert A. Wirick
Managing Director
Regulatory and International Affairs
DECHERT LLP
1900 K Street NW
Washington, D.C. 20006
(202) 261-3300
paul.denis@dechert.com
steven.bradbury@dechert.com
william.sohn@dechert.com
John B. Williams
Senior Analyst
Regulatory and International Affairs
AMERICAN AIRLINES, INC.
1101 17th Street, NW
Washington, D.C. 20036
(202) 326-5153
howard.kass@aa.com
robert.wirick@aa.com
john.b.williams@aa.com
March 14, 2016
Charles A. Hunnicutt
Brent Connor
THOMPSON HINE LLP
1919 M Street NW, Suite 700
Washington, D.C. 200036
(202) 331-8800
charles.hunnicutt@thompsonhine.com
brent.connor@thompsonhine.com
CERTIFICATE OF SERVICE
I certify that, on March 14, 2016, I caused to be served a copy of the foregoing
Consolidated Answer of American Airlines, Inc. by email upon those addressees listed below:
brian.hedberg@dot.gov (Dept. of Transportation)
todd.homan@dot.gov (Dept. of Transportation)
peter.irvine@dot.gov (Dept. of Transportation)
brett.kruger@dot.gov (Dept. of Transportation)
dan.weiss@united.com (United)
steve.morrissey@united.com (United)
gmurphy@crowell.com (Counsel for United)
mwarren@crowell.com (Counsel for United)
sseiden@crowell.com (Counsel for United)
robert.land@jetblue.com (JetBlue)
esahr@eckertseamans.com (Counsel for JetBlue)
dderco@eckertseamans.com (Counsel for JetBlue)
perkmann@cooley.com (Counsel for Hawaiian)
john.varley@virginamerica.com (Virgin America)
mlbenge@zsrlaw.com (Counsel for Virgin America)
jhfoglia@zsrlaw.com (Counsel for Virgin America)
megan.ouellette@alaskaair.com (Alaska)
john.kirby@alaskaair.com (Alaska)
jeremy.ross@alaskaair.com (Alaska)
dheffernan@cozen.com (Counsel for Alaska)
rwelford@cozen.com (Counsel for Alaska)
jyoung@yklaw.com (Counsel for Spirit)
dkirstein@yklaw.com (Counsel for Spirit)
john.fredericksen@suncountry.com (Sun Country)
thomas.ting@suncountry.com (Sun Country)
matwood@cozen.com (Counsel)
slachter@cozen.com (Counsel)
rpommer@atlasair.com (Atlas)
jmaddux@ggh-airlaw.com (Counsel for Dynamic)
anita.mosner@hklaw.com (Counsel for UPS)
jennifer.nowak@hklaw.com (Counsel for UPS)
kevin.montgomery@polaraircargo.com (Polar)
matthew.danaher@cityofchicago.org (ORD)
________________________
John B. Williams
Testimony
Testimony
AA-R-T-1
#aacuba
ABC Charters
1125 SW 87 AVE
MIAMI FL 33174
TM
A BETTER CHOICE
Its no surprise that most of the regions Cuban Americans prefer MIA to FLL for short U.S.Cuba flights.
The preference of Cuban-American travelers is reflected in data on U.S.-Cuba charter
flights. Flights to Cuba have been allowed from FLL for nearly five years, yet in 2015, 83
percent of all flights from the United States to Havanas Jos Mart International Airport
(HAV) originated from MIA, and just 2 percent originated from FLL. On average there were
over seven flights per day from MIA to HAV in 2015, and less than two flights per week from
FLL to HAV. Indeed, of the more than eight hundred charter flights that my company flew to
Cuba in 2015, just one was from FLL, and Ive only been asked to provide 3 private group
charter flights to Cuba from FLL in the past five years. If demand for flights from FLL to HAV
were greater, surely more charter service providers such as mine would have initiated service to
Cuba from FLL, but that hasnt happened. Instead, Ive observed weak demand for the few FLL
to HAV charter flights offered since 2011, only being able to sustain one rotation per week. The
Miami-Dade Cuban American population strongly favors MIA, and there is not enough local
demand in Fort Lauderdale/Broward County to support daily FLL-HAV charter flights.
There is also smaller demand for charter flights to Cuba from other airports. My company
provided no charter flights to Cuba from any other Florida airport in 2015 except for the three
weekly flights from Tampa to Havana.
Since 2011, we have not received any requests for
charters to Cuba from MCO, RSW, PBI, EYW and JAX. With the flights arranged from Tampa
and those from Miami, it covers all the demand in the state of Florida. Accorss the entire
charter industry, just 115 flights were flown from EYW in 2015 (all with very small airplanes,
not regional or mainline jets), 65 from MCO, 9 from RWS and none from PBI and JAX.
Consistent with demographics, top demand for U.S.-Cuba flights continue to be centered on
MIA.
Theres no reason to expect anything different when U.S.-Cuba scheduled service arrives.
Scheduled service wont change demographics. Cuban Americans, who are concentrated in
areas near MIA, will continue to prefer their neighborhood airport for U.S.-Cuba travel. The
frequencies allocated by the Department should therefore be mostly allocated to MIA, not FLL
and other airports. Failure to do so would greatly harm the Cuban Americans of Miami-Dade
County, who are the largest portion of U.S.-Cuba travelers and who have by far the greatest
demand for U.S.-Cuba scheduled service.
ABC Charters shares Americans commitment to connecting the U.S. and Cuban people
via commercial air service, and I believe that this service must primarily originate from MIA to
best meet the needs of passengers who have both the ability as well as the desire to travel to
Cuba.
Respectfully submitted,
Maria T.Aral
Letter of Support
Letter of Support
#aacuba
Rebuttal Exhibits
Title
AA-R-101
AA-R-102
AA-R-103
AA-R-104
Applicants in This Proceeding Agree That the Overwhelming Source of Traffic to Havana Will Be the U.S. CubanAmerican Population
AA-R-105
Data Point #1: U.S. Cuban-American Population - MIA is, Unquestionably, the U.S. Gateway with the Largest U.S.
Cuban-American Population, and, Thus, Has the Most Proven Need for HAV Frequencies
AA-R-106
Allocating U.S.-Havana Frequencies in This Proceeding Based on the Size and Location of Cuban-American
Population, MIA Should Receive 12 U.S.-Havana Frequencies of the 20 Available
AA-R-107
A Comparison of the Frequency Allocation Based on the U.S. Gateways Proposed in This Proceeding with the
Frequencies Requested at Each U.S. Gateway Shows that the MIA-HAV "Asks" Were in Line with Historical Demand
AA-R-108
FLL Has the Largest Difference Between Its Proportionate Share of U.S.-Havana Frequencies and the Number of
U.S.-Havana Frequencies Requested
AA-R-109
Based on Percentages, MIA Has the Smallest Difference Between Its Proportionate Share of U.S.-Havana
frequencies and the Frequencies Requested at MIA of Any Gateway for Which Daily Service Is Proposed
AA-R-110
Date Point #2: Historical Information on U.S.-Cuba Charter Flights - The Overwhelming Number of Charter Operated
From The U.S. Gateways Proposed in This Proceeding to Cuba Originated at MIA in 2015 - Over 86%
AA-R-111
Data Point #3: Historical Information on U.S.-Havana Charter Flights - Close to 84% of All Charters Between the U.S.
and Havana in 2015 Originated At MIA
#aacuba
Title
AA-R-112
Allocating U.S.-Havana Frequencies in This Proceeding Based on the Number of U.S.-Havana Charter Flights
Operated in 2015 Proportionately to Each U.S. Gateway, MIA Should Receive 17 of the 20 Available U.S.-Havana
Frequencies
AA-R-113
A Comparison of the Frequency Allocation Based on 2015 Charter Flights Operated with the Frequencies Proposed
at Each U.S. Gateway Shows that MIA's, and Only MIA's, Request for HAV Service Is Less Than Its Proportionate
Share of Historical Charter Flights
AA-R-114
Several Applicants Did Not Build Realistic Connections to Their Proposed U.S.-Havana Services
AA-R-115
Several Applicants Included "Connecting" Flights with Maximum Connection Times Exceeding Four Hours and
Minimum Connecting Times on the Outbound Flight of Less Than 55 Minutes
AA-R-116
Adjusting the Applicants' Claimed Connections for the Same Connections Methodology Used by American Shows:
AA-R-201
AA-R-202
MIA Is the Home of Almost 50% of the U.S. Cuban-American Population and the Epicenter of U.S.-Havana Flights
and Passenger Demand
AA-R-203
American's MIA-HAV Request Is Less Than MIA's Proportionate Share of U.S.-Havana Frequency Allocations
AA-R-204
AA-R-205
American's Request for Ten Miami-Havana Frequencies Only Matches -- Actually "Under-Requests" -- Existing
Charter Demand
AA-R-206
American's request for Daily CLT Frequencies Provides a Combination of Service to the Charlotte Cuban-American
Community and, Together with MIA, the Largest and Most Efficient Connecting Gateway Combination to HAV for the
Entire U.S.
#aacuba
Title
AA-R-207
American's Request for Daily DFW Frequencies Enables service to the Local Dallas/Fort Worth Cuban-American
Community and Further Complements the Domestic Coverage of MIA and CLT
AA-R-208
American's Request for Once Weekly ORD Frequency Meets the Demand of the Local Chicago Cuban-American
Community. More Than Twice Weekly Service Would Be Excessive to the Current and Anticipated Demand in the
ORD-HAV Market
AA-R-209
American's Request for Once Weekly Service from LAX Is Consistent with Existing and Anticipated LAX-HAV
Demand
AA-R-210
AA-R-211
American Serves More Than 3x the Number of Domestic U.S. Destinations from MIA Than the Other Three
Applicants for MIA-HAV Services Combined
AA-R-212
American's Domestic Service Share at MIA Far Outstrips the Share of the Other Three MIA-HAV Applicants
Combined
AA-R-213
American Operates Almost 6x as Many Domestic Departures at MIA as the Other Three MIA-HAV Applicants
Combined
AA-R-214
Of All the MIA-HAV Applicants, American Accounts for 85% of All the MIA Domestic Departures
AA-R-215
American Flies More Than 83% of the Domestic Seats at MIA - More Than All of the Other MIA-HAV Applicants
Combined
AA-R-216
American Flies More Than 5x the Number of Domestic Seats from MIA as the Other Three MIA-HAV Applicants
Combined
AA-R-217
American Flew More Than Five Times the Number of Domestic Passengers at MIA Than the Three Other MIA-HAV
Applicants Combined
#aacuba
Title
AA-R-218
Of All the MIA-HAV Applicants, American Accounted for 84.5% of All MIA Domestic Passengers
AA-R-219
American Has the Longest and Deepest Experience in U.S.-Cuba Flights and Operational Know-How in the Unique
Cuba Market
AA-R-220
The Importance of Knowing the Unique Cuba Aviation Structure Was Highlighted on the Floor of the U.S. Senate
AA-R-301
A Comparison of the Frequency Allocation Based on the U.S. Gateway Proposed in This Proceeding with the
Frequencies Requested at Each U.S. Gateway
AA-R-302
American Airlines' Request for 10 Daily MIA-HAV Flights Is Less Than MIA's Proportionate Share - Even Before
Adjusting for Any Growth, Which Will Be Greater at MIA Than Anywhere Else
AA-R-303
In Contrast to American's MIA-HAV Frequency Request, JetBlue's Requests for U.S.-HAV Freuencies Are Excessive
to Current and Anticipated Demand from JetBlue's Requested U.S. Gateways
AA-R-304
In Contrast to American's MIA-HAV Frequency Request, Southwest's Requests for U.S.-HAV Freuencies Are
Excessive to Current and Anticipated Demand from Southwest's Requested U.S. Gateways
AA-R-305
In Contrast to American's MIA-HAV Frequency Request, Alaska's Requests for U.S.-HAV Freuencies Are Excessive
to Current and Anticipated Demand from Alaska's Requested U.S. Gateways
AA-R-306
In Contrast to American's MIA-HAV Frequency Request, Spirit's Requests for U.S.-HAV Freuencies Are Excessive to
Current and Anticipated Demand from Spirit's Requested U.S. Gateways
AA-R-307
There Is More Cuban-American Population per Requested HAV Frequency at MIA Than Any Other Requested U.S.
Gateway
AA-R-308
There Is More Cuban-American Population per Requested HAV Frequency at MIA Than Any Other Requested
Florida Gateway
#aacuba
Title
AA-R-309
Service to MCO Ranked No Higher Than 5th In Any Applicant's Prioritization of Havana Routes
AA-R-310
Service to TPA Ranked NO Higher Than 6th In Any Applicant's Prioritization of Havana Routes
AA-R-311
The "FLL Applicants" Attempt to Claim MIA's and Miami-Dade County's 856,007 Cuban-Amerians as Their Own is
Patently False
AA-R-312
FLL MIA
AA-R-313
Several Gateways Claim Broad U.S. Coverage to Cuba, But Only 4 Carrier Gateways Can Legitimately Provide
Connections to Most of the U.S.
AA-R-401
JetBlue's Request for Four Daily FLL-HAV Flights Greatly Exceeds FLL-HAV's Proportionate Share of the Total U.S.HAV Frequency Allocation
AA-R-402
And, When Combined with the Requests of All Other FLL Applicants, the FLL-HAV Frequency Request Is "Off The
Charts" Excessive
AA-R-403
The Cuban-American Population of Broward Count (FLL's Home) Is Miniscule Compared to Miami-Dade County
(MIA's Home)
AA-R-404
JetBlue Tries to Claim that MIA's Traffic and Demand Are "Also" FLL's, But It Just Isn't So
AA-R-405
AA-R-406
And One Applicant, Which Did Not Apply for FLL-HAV Service, Admitted That FLL's Catchment Area Is One-Tenth
the Size of MIA's
#aacuba
Title
AA-R-407
Historical Data Proves That MIA-HAV Demand Far Outstrips FLL-HAV Demand
AA-R-408
Havana Arriving Flights Involve a Change of Terminals at FLL and Either a Walk Outside Between Terminals or a
Connector Bus
AA-R-409
While American's Havana Arriving Flights Are All Under "One Roof"
AA-R-410
JetBlue's FLL-HAV Will Have Only a Small Number of Connections to HAV in Both Directions
AA-R-411
AA-R-412
JetBlue's FLL-HAV Charter Experience Is Not Comparable or Even Close to American's MIA-HAV Charter
Experience
AA-R-413
JetBlue's FLL-HAV Charters Have Experienced Load Factors That Have Been, Well, Let Us Just Say, Challenging
AA-R-414
AA-R-415
As Demonstrated, JetBlue's FLL-HAV Charters' Load Factors Cannot Compare to American's MIA-HAV Charters'
Load Factors
AA-R-416
JetBlue's Double Daily JFK-HAV Request Exceeds JFK-HAV's Proportionate Share of U.S.-Cuba Frequency
Allocation
AA-R-417
JetBlue's Double Daily JFK-HAV Request, When Combined with Delta's Single Daily JFK-HAV Request, Would
Allocate Far Greater Frequencies to JFK-HAV Than Demand Warrants
#aacuba
Title
AA-R-418
JetBlue Has Been Operating Charters in the JFK-HAV Market Since 2015But Only Twice Weekly. If JFK-HAV
Demand Existed for a Daily or Double Daily Flight, Why Hasn't JetBlue Increased the Frequency?
AA-R-419
The Reason JetBlue Has Not Increased JFK-HAV Frequencies: JetBlue's JFK-HAV Load Factors Have Been
Mediocre with Only Two Weekly Flights
AA-R-420
So One Could Imagine What the Load Factor Would Be With a Seven-Fold Increase in Service
AA-R-421
And This Would Be Without the Benefit of Significant JetBlue Connections at JFK
AA-R-422
The Modest Demand for JFK-HAV Service Is Not Surprising Given the Size of the Cuban-American Popuation and
the Historical Demand for JFK-HAV Service
AA-R-423
JetBlue's request for Double Daily MCO-HAV Service Greatly Exaggerates the Size of the MCO-HAV Market
AA-R-424
JetBlue's Exaggerated MCO-HAV Request Is Made Worse by the Requests of Southwest and Delta. When
Combined, the Total MCO-HAV Requests Bear No Relationship to the Needs of or Demand in the MCO-HAV Market
AA-R-425
AA-R-426
JetBlue Would Provide Only 5 Connections in Both Directions For its Mco-HAV Flight
AA-R-427
JetBlue's TPA-HAV Request for Double Daijly Service Over-Asks Based on the Demand in the Market
AA-R-428
When Combined with Southwest's Double Daily TPA-HAV Request, the Total TPA-HAV Frequency Request Is
Grossly Oversubscribed
#aacuba
Title
AA-R-429
AA-R-430
JetBlue Would Have Only 4 Connections in Both Directions for Its TPA-HAV Service
AA-R-431
AA-R-432
TPA's Charter Flight History to Havana Demosntrates That Even a Single Daily Scheduled TPA-HAV Service Is Not
Warranted
AA-R-433
To Go from a 71% Load Factor on Two Weekly Flights to a 71% Load Factor on 14 Weekly Flights Requires a
Staggering 700% Stimulation
AA-R-434
AA-R-435
EWR-HAV Is JetBlue's Next to Last Gateway Priority Among Its Six Proposed U.S. Gateways to Havana (the Most of
Any Applicant in This Proceeding)
AA-R-436
JetBlue Would Have No Connections in Both Directions for Its EWR-HAV Service
AA-R-437
JetBlue's BOS-HAV request for a Daily Service Is, at Best, Aspirational, Not Realistic Now
AA-R-438
AA-R-439
JetBlue Would Have Only 1 Connection in Both Directions for Its BOS-HAV Service, and That Would Be to JFK
#aacuba
Title
AA-R-440
AA-R-441
AA-R-442
JetBlue Touts Its Customer Service "Advantages," But American's Advantages Are More Meaningful and Important to
Cuba-Destined U.S. Passengers
AA-R-501
Southwest's FLL-HAV Request for Six Daily Frequencies Vastly Exceeds FLL-HAV's Proportionate Share of the U.S.Havana Frequency Allocation
AA-R-502
Southwest's FLL-HAV Request for Six Daily Frequencies, When Combined with the Other FLL Applicants' Requests,
Would Result in FLL Having Almost as Many Havana Flights as MIA an Absurd Result
AA-R-503
Southwest's Request for Six Daily FLL-HAV Frequencies Is Far Above and Beyond Current Demand and Any
Reasonable Forecast of Expected Demand
AA-R-504
AA-R-505
AA-R-506
Southwest Has Never Operated a Single Flight to Cuba, let Alone Any Flights in the FLL-HAV Market
AA-R-507
In Order to Operate Six Daily Flights at Just 70% Load Factor (Well Below Its Average Load Factor), Southwest
Would Have to "Stimulate" the FLL-HAV Market by 4,860%, Assuming All 2015 FLL-HAV Charter Flights Operated at
a 100% Load Factor
AA-R-508
Southwest's Request for Double Daily TPA-HAV Frequencies Exceeds TPA-HAV's Proportionate Share of U.S.Havana Frequency Allocation
#aacuba
Title
AA-R-509
Southwest's TPA-HAV Double Daily Request, When Combined with JetBlue's Double Daily TPA-HAV request, Is
Excessive to TPA-HAV's Proportionate Share of U.S.-HAV Frequency Allocation
AA-R-510
Southwest's TPA-HAV Double Daily Request Severely Exceeds Historical, Current and Expected Demand in the
TPA-HAV Market
AA-R-511
AA-R-512
AA-R-513
AA-R-514
TPA-HAV Was Southwest's Second to Last Priority Out of Nine Proposed HAV Service
AA-R-515
Southwest's MCO-HAV Request for a Daily Frequency Allocation, When Combined with the Other Requests, Greatly
Exceeds MCO-HAV's Proportionate Share of U.S.-HAV Frequency Allocation
AA-R-516
AA-R-517
AA-R-518
AA-R-519
AA-R-520
MCO-HAV Was Southwest's Last Priority Out of Nine Proposed HAV Services
AA-R-521
AA-R-522
Southwest's Use of Canada MIDT Data in Its Forecast Is Just Plain Wrong
#aacuba
Title
AA-R-523
AA-R-601
ATL, Like CLT (and DFW), Provides Broad Coverage of the U.S.-HAV Markets Not Served by American Over MIA
AA-R-602
Delta's Request for a Daily JFK-HAV Frequency Allotment Is Proportionate to the U.S.-Cuba Frequency Allocation for
JFK, but Three JFK Daily Requests to Havana Are Excessive to Both Demand and Historical Traffic
AA-R-603
AA-R-604
AA-R-605
AA-R-606
Delta's Other Attempt to Operate a Non-Hub International Flight at MIA Did Not Go Well or Last Long
AA-R-607
And Delta's Current Non-Hub International Flight at PHL Is Not Going Well
AA-R-608
Delta's MCO-Havana Proposed Daily Service, When Combined with the Other MCO-HAV Requests, Is Extremely
Excessive to Any Current or Even Medium-Term Real or Aspirational Demand
AA-R-609
AA-R-610
AA-R-611
MCO-HAV Has Experienced Very Little Charter Activity, and Nothing Compared to MIA-HAV
AA-R-612
AA-R-613
AA-R-614
While No Forecast Was Required, and Any Forecast in the U.S.-Cuba Market Is Fraught with Unknowns, Delta's
Forecast Is at Best a Guesstimate with no Basis in Fact or Data
#aacuba
Title
AA-R-701
Frontier's Request for the First Two of Its Three Proposed Daily MIA-HAV Flights Is Tied to Frontier Also Receiving
DEN-HAV Frequencies, and There Is No Basis - or Demand - for DEN-HAV Service
AA-R-702
DEN-HAV's Proportionate Share of U.S.-Havana Frequency Allocation Is Zero, yet Frontier Requests a Daily DENHAV Frequency
AA-R-703
AA-R-704
AA-R-705
AA-R-706
Frontier's MIA-HAV and DEN-HAV Flights Would Have Only a Single Connection in Both Directions
AA-R-801
Spirit's Request for Two Daily FLL-HAV Frequencies Exceeds FLL's Proportionate Share of the U.S.-Havana
Frequency Allocation
AA-R-802
Spirit's Request, Combined with the Other FLL-HAV Requests, Is "Off the Chart" Excessive Compared to Actual
Current Demand and Any Expectation of Future Demand
AA-R-803
AA-R-804
AA-R-805
There Has Been Miniscule Demand for Charter Flights from FLL to HAV or Anywhere in Cuba That's Highly
Probative of Future Demand
AA-R-806
AA-R-901
United's Request for a Daily EWR-HAV Service Is in Line with Its Proportionate Share of U.S.-Havana Frequencies
#aacuba
Title
AA-R-902
But United's EWR-HAV Request Plus JetBlue's Daily EWR-HAV Service Request Exceeds EWR's Proportionate
Share of the U.S. EWR-HAV Frequency Allocation
AA-R-903
United's EWR-HAV Service Offers Only 25 Connecting in Both Direction, Compared to 68 Provided by American at
CLT, 58 at MIA and 52 at DFW
AA-R-904
United's Once Weekly Request for IAH Does Not Permit IAH-Originating Travelers to Go to or Return from Havana
on Any of the Other Six Days without Extreme Circuity and Unbearable Elapsed Times
AA-R-905
United's Once Weekly Request for IAD Does Not Permit IAD-Originating Travelers to Go to or Return from Havana
on Any of the Other Six Days without Doubling Their Travel Time
AA-R-906
United Once Weekly Request for ORD Does Not Permit ORD-Originating Travlers to Go to or Return from Havana
on Any of the Other Six Days without Doubling Their Elapsed Travel Time
AA-R-907
AA-R-1001
Alaska Airlines Request for Double Daily LAX-HAV Frequencies Is Excessive in the Extreme and Bears No
Rational Relationship to Historical, Current or Future Demand
AA-R-1002
American Knows the LAX-HAV Market, Current Operates LAX-HAV Charters (at less than 50% Load Factor) and, if
There were Sufficient Demand to Warrant Inreasing Its Single Weekly Service, American Would Have Done
Soand It Has Not
AA-R-1003
If Once-Weekly LAX-HAV Charter Flight Current Operated by American Has Experienced a Load Factor of Less
Than 50% from the Start of the Service to Date, Can Anyone Believe That a Daily or Double Daily Service Will Be a
Viable or Prudent Use of Scarce Havana Frequency Allocations?
AA-R-1004
#aacuba
Title
AA-R-1005
Of the 3 Connections Alaska Has to Its LAX-HAV Flight, One - SEA - Actually Has Better Connect Times on
American
AA-R-1006
Alaska States an Estimated LAX-HAV Market Size but Without Attempting to Explain it, Source it, or Justify it
AA-R-1101
Sun Country's Proposed RSW-HAV Service Would Greatly Exceed the Historical Demand for RSW-HAV
AA-R-1102
AA-R-1103
Sun Country's Proposed Twice-Weekly MSP-HAV Service Would Greatly Exceed MSP-HAV's Proportionate Share
of U.S.-Havana Frequency Allocation
AA-R-1104
Sun Country's Proposed Twice-Weekly MSP-HAV Service Would Greatly Exceed Historical Demand
AA-R-1105
Sun Country's MSP-HAV Service Would Have Only a Single Connection in Both Directions
AA-R-1106
Sun Country's MSP-HAV Passengers Would Have No Way to Return from HAV on Sun Country on the Five Days
of the Week on Which Sun Country Does Not Operate
AA-R-1201
FedEx Is Right That It Is Not "Asking For Much" (FedEx Argument, p.1), But Is the Authority It Seeks Consistent
with the U.S.-Cuba MOU?
AA-R-1202
FedEx Proposes the HAV-MID Blind Sector Because of the Lack of HAV-MIA Traffic, So Is Now the Right Time to
Award Any Scarce and Highly In-Demand U.S.-Cuba Frequencies for a Cargo Service That Has Not Yet
Materialized?
#aacuba
Series 100:
General Rebuttal Exhibits
of American Airlines
Gateways to Havana
MIA
FLL
MCO
TPA
JFK
LAX
EWR
PBI
RSW
CLT
DFW
BOS
DEN
ATL
ORD
EYW
JAX
MSP
IAH
IAD
#aacuba
120
117
100
91
80
60
40
28
20
28
24
19
15
14
MIA
PBI RSW CLT DFW BOS DEN ATL ORD EYW JAX MSP IAH
IAD
#aacuba
Relevant Applicants
Silver Airways
Eastern Airlines
#aacuba
Carrier
Southwest
JetBlue
Frontier
Silver
Comments
. . . [t]he distribution of Cuban American
population [will be] the most likely major centers
for travel from the U.S. . . .
(Application, Page 3)
. . . [F]amilial, cultural and educational travel . . .
will be the primary drivers of United States-Cuba
traffic until Congress takes further steps to
rescind the embargo.
(Application, Page 18)
. . . [T]he largest population eligible to travel to
Cuba are those permitted to do so to visit closer
relatives there. (Application, Page 18)
. . . Cuban Americans comprise the vast
majority of likely Cuba travelers.
(Application, Page 9)
#aacuba
1,400,000
1,213,438
1,200,000
1,000,000
800,000
600,000
400,000
200,000
88,607
83,362
70,803
46,541
25,048
22,541
21,459
18,079
17,930
Texas
Georgia
Illinois
Nevada
North
Carolina
Pennsylvania
0
Florida
California
New Jersey
New York
#aacuba
14
12
12.2
10
2
1.2
1.2
0.9
0.7
0.7
0.6
0
MIA
EWR
FLL
TPA
LAX
JFK
PBI
0.4
0.3
0.3
0.3
0.3
0.2
0.2
0.2
RSW
MCO
ORD
IAH
ATL
IAD
DFW
BOS
0.1
EYW
0.1
JAX
0.1
CLT
Note:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds application (Exhibit UA-112).
0.0
DEN
0.0
MSP
#aacuba
16
15.0
14
13.0
12
12.2
10
4.0
4.0
3.0
2.1
2.1
2.0
1.3
1.2
1.2
0.9
0.7
0.7
0.6
0
MIA
EWR
FLL
TPA
LAX
JFK
PBI
1.0
0.3
0.4
0.3
0.3
RSW
MCO
ORD
0.1
0.3
0.3
IAH
ATL
1.0
1.0
0.2
0.2
0.2
IAD
DFW
BOS
0.7
0.1
0.1
EYW
1.0
1.0
0.3
0.1
JAX
0.3
0.1
CLT
Note:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds application (Exhibit UA-112).
0.0
DEN
0.0
MSP
#aacuba
FLL Has the Largest Difference Between Its Proportionate Share of U.S.-Havana
Frequencies and the Number of U.S.-Havana Frequencies Requested
U.S. Gateway
Allocation of Available
Total Daily Frequencies
20 U.S.-Havana
Requested by U.S. Carriers
Daily Frequencies Based on
at Each Proposed U.S.
Cuban-American Population
Gateway
Frequency
Difference
FLL
1.2
13
(11.8)
MCO
0.3
(3.7)
TPA
0.9
(3.1)
MIA
12.2
15
(2.8)
JFK
0.7
(2.3)
LAX
0.7
2.1
(1.4)
PBI
0.6
(1.4)
DEN
0.0
(1.0)
EWR
1.2
2.1
(0.9)
RSW
0.4
1.3
(0.9)
CLT
0.1
(0.9)
DFW
0.2
(0.8)
BOS
0.2
(0.8)
ATL
0.3
(0.7)
Note:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx). Minimum daily service proposed.
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the allocation
described in Uniteds application (Exhibit UA-112).
#aacuba
Allocation of Available 20
U.S. -Havana Daily Frequencies
Based on Cuban-American
Population
(1)
% Difference
Between U.S.-HAV
Allocation and Request
of All Applicants
(2) (1)
MIA
12.2
(2.8)
23%
EWR
1.2
(0.9)
77%
LAX
0.7
(1.4)
202%
PBI
0.6
(1.4)
226%
RSW
0.4
(0.9)
261%
ATL
0.3
(0.7)
297%
TPA
0.9
(3.1)
329%
JFK
0.7
(2.3)
339%
DFW
0.2
(0.8)
518%
BOS
0.2
(0.8)
533%
CLT
0.1
(0.9)
872%
FLL
1.2
(11.8)
989%
MCO
0.3
(3.7)
1145%
DEN
0.0
(1.0)
1911%
U.S. Gateway
Note:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx). Minimum daily service proposed.
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds application (Exhibit UA-112).
#aacuba
5,000
4,500
4,348
MIA: Almost 13x larger than next largest U.S. gateway to Cuba
4,000
3,500
3,000
2,500
2,000
1,500
1,000
500
338
115
70
70
65
MIA TPA EYW JFK FLL MCO RSW LAX BOS MSP ATL CLT DFW DEN EWR IAD IAH JAX ORD PBI
#aacuba
3,500
3,000
2,918
MIA: Almost 11x larger than next largest U.S. gateway to Cuba
2,500
2,000
1,500
1,000
500
267
86
70
69
65
MIA TPA EYW JFK FLL MCO RSW LAX BOS MSP ATL CLT DFW DEN EWR IAD IAH JAX ORD PBI
#aacuba
16.7
16.0
14.0
12.0
10.0
8.0
6.0
4.0
2.0
1.5
0.5
0.4
0.4
0.4
EYW
JFK
FLL
MCO
MIA
TPA
0.1
RSW
0.0
LAX
0.0
BOS
0.0
ATL
0.0
MSP
0.0
EWR
0.0
PBI
0.0
CLT
0.0
DFW
0.0
DEN
0.0
ORD
0.0
JAX
0.0
IAD
0.0
IAH
#aacuba
A Comparison of the Frequency Allocation Based on 2015 Charter Flights Operated with the
Frequencies Proposed at Each U.S. Gateway Shows that MIAs, and Only MIAs, Request for
HAV Service Is Less Than Its Proportionate Share of Historical Charter Flights
Total Daily Frequencies Requested by U.S. Carriers at Each Proposed U.S. Gateway
16.7
16
14
12
10
2
1.5
0.5
0.4
0.4
0.4
EYW
JFK
FLL
MCO
MIA
TPA
0.1
RSW
0.0
LAX
0.0
BOS
0.0
ATL
0.0
MSP
0.0
EWR
0.0
PBI
0.0
CLT
0.0
DFW
0.0
DEN
0.0
ORD
0.0
JAX
0.0
IAD
0.0
IAH
#aacuba
Applicants without Cuba experience did not augment the standard Minimum
Connecting Times (MCTs) at their gateway airports to account for the need to process
unique OFAC-required paperwork for Cuba flights to assure passenger and airline
compliance with categories of permissible travel to Cuba (American added 15 minutes to its
standard MCTs)
Included one way connects, instead of just connects in both directions (American
displayed and enumerated connects only in both directions)
Did not exclude cities for which circuity was in excess of 155%
#aacuba
Route
MIA-HAV
CLT-HAV
DFW-HAV
ORD-HAV
LAX-HAV
HAV-LAX
HAV-FLL
HAV-JFK
HAV-MCO
HAV-TPA
HAV-BOS
HAV-JFK
HAV-ATL
HAV-MIA
HAV-MCO
HAV-MIA
HAV-DEN
HAV-FLL
HAV-DEN
HAV-RSW
HAV-EWR
HAV-IAH
HAV-IAD
HAV-ORD
HAV-FLL
HAV-TPA
HAV-MCO
Note: Frontier (F9) only included schedule data for through flights; a full schedule of connecting flights was not provided.
Source: Airline Applications
#aacuba
Route
MIA-HAV
CLT-HAV
DFW-HAV
ORD-HAV
LAX-HAV
LAX-HAV
FLL-HAV
JFK-HAV
MCO-HAV
TPA-HAV
BOS-HAV
JFK-HAV
ATL-HAV
MIA-HAV
MCO-HAV
MIA-HAV
DEN-HAV
FLL-HAV
DEN-HAV
RSW-HAV
EWR-HAV
IAH-HAV
IAD-HAV
ORD-HAV
FLL-HAV
TPA-HAV
MCO-HAV
Note: Frontier (F9) only included schedule data for through flights; a full schedule of connecting flights was not provided.
Source: Airline Applications
#aacuba
Route
Delta
American
American
American
United
Southwest
JetBlue
Southwest
Spirit
Southwest
JetBlue
JetBlue
Silver
JetBlue
Alaska
Delta
Delta
Delta
JetBlue
Frontier
Frontier
JetBlue
Sun Country
ATL-HAV
CLT-HAV
MIA-HAV
DFW-HAV
EWR-HAV
FLL-HAV
FLL-HAV
TPA-HAV
FLL-HAV
MCO-HAV
JFK-HAV
MCO-HAV
FLL-HAV
TPA-HAV
LAX-HAV
MCO-HAV
JFK-HAV
MIA-HAV
BOS-HAV
DEN-HAV
MIA-HAV
EWR-HAV
RSW-HAV
Proposed
Frequencies
7x
7x
70x
7x
8x
42x
28x
14x
14x
7x
14x
14x
7x
14x
14x
7x
7x
14x
7x
7x
21x
7x
7x
Stated
Connections
152
68
58
52
50
27
N/A
34
19
33
N/A
N/A
N/A
N/A
4
11
19
10
N/A
N/A
N/A
N/A
N/A
Connections
(Both Ways)
71
68
58
52
25
20
15
15
10
10
6
5
4
4
3
3
2
2
1
1
1
0
0
Notes: Viable connections based on (a) 4 hour maximum connect time each way; (b) 55 minute domestic to Cuba connection time based on shortest connection time used by
American Airlines; (c) 75 minute Cuba to domestic connection time based on shortest connection time used by American Airlines; (d) circuity less than 155%; (e) minimum of 5x weekly
connecting flights.
JetBlue included in its exhibits connecting itineraries, but it did not state the number of connections
Source: Connecting schedules contained in carrier submissions where possible. For airlines that did not provide connecting schedules, June 2016 OAG or Diio schedules were used.
#aacuba
Series 200:
American Airlines Request for
U.S.-Havana Frequencies
While I ardently support everyones right to travel to Cuba, key to the success
will be ensuring that the initial flights being awarded by the Department of
Transportation provide for the continued and expanded ability of the Cuban
American community to travel to the island via regular air service.
This should include adequate regular service to accommodate the growing
demand from the largest and closest Cuban American population located in
Miami-Dade County.
#aacuba
1,785,547
Other
0.9%
EYW
2.5% TPA
7.6%
856,007
MIA
83.3%
Total U.S.
Miami-Dade County
(MIA)
Note: Other includes: RSW, SJU, BWI, LAX, MSP, ATL, MSY, and BOS.
Source: Havanatur 2015 charter data; American Airlines; U.S. Census data (2010)
#aacuba
12.2
12
10
10
8
6
4
2
0
Daily Frequencies per % of Cuban-American
Population
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation (U.S.-Cuba Air Service Arrangement)
multiplied by % of Cuban-American population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds application (Exhibit UA-112).
#aacuba
10
10
9.5
3,000 2,922
8
7
3,500
8.3
2,500
7.3
6
2,000
5
1,500
4
3
1,000
2
500
267
70
2015
2016*
2017*
AA MIA-HAV
Request
Note: MIA-HAV charter demand for 2016 and 2017 is annualized based on 14% of YoY growth rate.
(Jan-Feb 2016 vs. Jan-Feb 2015) without assuming any stimulation.
Source: Havanatur charter flight data (2015)
69
65
MIA TPA JFK FLL MCO RSW LAX ATL BOS MSP
#aacuba
Americans Request for Once Weekly ORD Frequency Meets the Demand of the Local
Chicago Cuban-American Community More Than Twice Weekly Service
Would Be Excessive to the Current and Anticipated Demand in the ORD-HAV Market
Americans proposed once weekly ORD
frequency to Havana versus weekly
frequencies as per % share of
Cuban-American Population
2.5
. . . and American could provide efficient onestop connections every day of the week to
ORD passengers
through MIA, CLT and DFW
2.1x
weekly
2.0
1.5
1.0x
weekly
1.0
0.5
0.0
American's ORD-HAV
Request
American and United each proposed one weekly service in the ORD-HAV market on the
same day. To provide the maximum benefits to Chicago, American would be prepared to
accept its once weekly service on Sunday instead of Saturday.
#aacuba
0.8
0.7
0.7
0.6
0.5
0.4
0.3
0.2
0.1
0.1
0.0
American's LAX-HAV
Request
#aacuba
Sources: American Airlines, Miami International Airport, Miami-Dade County Beacon Council
#aacuba
#aacuba
American Serves More Than 3x the Number of Domestic U.S. Destinations from
MIA Than the Other Three Applicants for MIA-HAV Services Combined
54
50
40
30
20
10
10
6
0
American
Delta
Frontier
Eastern
Source: OAG schedule data accessed March 3, 2016 for June 2016
#aacuba
Americans Domestic Service Share at MIA Far Outstrips the Share of the Other
Three MIA-HAV Applicants Combined
Eastern
0.0%
Delta
14.3%
American
77.1%
Source: OAG schedule data accessed March 3, 2016 for June 2016
#aacuba
5,601
5,000
4,000
3,000
2,000
829
1,000
149
Frontier
Eastern
American
Delta
Source: OAG schedule data accessed March 3, 2016 for June 2016
#aacuba
Eastern
0.0%
Delta
12.6%
American
85.1%
Source: OAG schedule data accessed March 3, 2016 for June 2016
#aacuba
Eastern
0.0%
Delta
13.8%
American
83.5%
Source: OAG schedule data accessed March 3, 2016 for June 2016
#aacuba
American Flies More Than 5x the Number of Domestic Seats from MIA as the
Other Three MIA-HAV Applicants Combined
737,931
700,000
600,000
500,000
400,000
300,000
200,000
121,650
100,000
24,592
American
Delta
Frontier
Eastern
Source: OAG schedule data accessed March 3, 2016 for June 2016
#aacuba
American Flew More Than Five Times the Number of Domestic Passengers at
MIA Than the Three Other MIA-HAV Applicants Combined
Domestic Passengers
Year End November 2015
18,000,000
16,851,872
16,000,000
14,000,000
12,000,000
10,000,000
8,000,000
6,000,000
4,000,000
2,481,327
2,000,000
604,301
American
Delta
Frontier
Eastern
#aacuba
Eastern
0.0%
Delta
12.4%
American
84.5%
#aacuba
25 years of continuous service almost twice as long as next U.S. airline more years than Delta,
Southwest, Frontier, Alaska, and Sun Country combined
American
Sun
Country
Eastern
jetBlue
JetBlue
Delta
Southwest
Silver
Frontier
Alaska
Spirit
United
Dynamic
FedEx
#aacuba
The Importance of Knowing the Unique Cuba Aviation Structure Was Highlighted
on the Floor of the U.S. Senate
[h]aving traveled to Cuba multiple times over the years, I hope that the
Department closely evaluates the complexity of operating there and ensures
that those selected to operate these routes are up to the taskthose with
experience.
#aacuba
Series 300:
Exhibits of American Airlines
with Respect to the U.S. Gateways
Proposed by Applicants in This Proceeding
16
15.0
14
13.0
12
12.2
10
4.0
4.0
3.0
2.1
2.1
2.0
1.3
1.2
1.2
0.9
0.7
0.7
0.6
0
MIA
EWR
FLL
TPA
LAX
JFK
PBI
1.0
0.3
0.4
0.3
0.3
RSW
MCO
ORD
0.1
0.3
0.3
IAH
ATL
1.0
1.0
0.7
0.1
0.2
0.2
0.2
IAD
DFW
BOS
0.1
EYW
1.0
1.0
0.3
0.1
JAX
0.3
0.1
CLT
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds Application (Exhibit UA-112).
0.0
DEN
0.0
MSP
#aacuba
15
14
12.2
American under-requests
MIA-HAV frequencies by 20%
12
10
10
8
6
4
2
0
Total Daily MIA-HAV
Frequencies Requested by All
Applicants
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds Application (Exhibit UA-112).
#aacuba
13.0
12
11
10
9
7
Daily Frequencies per Cuban-American Population Share
6
5
4.0
4.0
3.0
3
2
1
4.0
2.0
1.2
2.0
1.0
0.3
FLL
Total
B6
TPA
Total
B6
MCO
Total
B6
2.0
0.7
JFK
Total
B6
2.1
1.2
1.0
1.0
1.0
0.2
EWR
Total
B6
BOS
Total
B6
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds Application (Exhibit UA-112).
#aacuba
13.0
12
11
10
9
8
Total Frequencies Proposed
6.0
6
5
4.0
4.0
2.0
2
1
1.2
FLL
Total
1.0
0.9
0.3
TPA
WN
Total
MCO
WN
Total
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds Application (Exhibit UA-112).
WN
#aacuba
3.0
2.5
2.1
2.0
2.0
1.5
1.0
0.7
0.5
0.0
LAX
Total
AS
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds Application (Exhibit UA-112).
#aacuba
15
14
13.0
13
12
11
10
9
8
7
6
5
4
3
2.0
2
1
1.2
0
FLL
Total
NK
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds Application (Exhibit UA-112).
#aacuba
9,000
8,152
8,000
7,000
6,000
5,675
5,000
4,000
3,313
3,074
3,000
2,778
2,521
2,338
2,280
2,000
1,621
1,582
1,031
1,000
920
805
498
MIA
EWR
LAX
PBI
RSW
ATL
TPA
JFK
DFW
BOS
CLT
FLL
MCO
Notes: The higher the number, the more potential demand based on Cuban-American population, so a higher number means that relevant to other requested gateways, there
would be a shortage of frequencies at that gateway compared to other gateways. The lower number means an excess of frequencies compared to other requested gateways
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways. 2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority
(FedEx). 3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on
the allocation described in Uniteds application (Exhibit UA-112).
DEN
#aacuba
9,000
8,000
7,000
6,000
5,000
4,000
3,074
3,000
2,778
2,338
2,000
1,000
920
805
FLL
MCO
MIA
PBI
RSW
TPA
Notes: The higher the number, the more potential demand based on Cuban-American population, so a higher number means that relevant to other requested gateways, there
would be a shortage of frequencies at that gateway compared to other gateways. The lower number means an excess of frequencies compared to other requested gateways
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways. 2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority
(FedEx). 3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on
the allocation described in Uniteds application (Exhibit UA-112).
#aacuba
In Rebuttal to Delta Application at page 2, JetBlue Application at page 29, Southwest Application at page 16
JetBlue
Southwest
The fact that MCO was ranked so low in the prioritization of the only three airlines which applied
for MCO-HAV frequency allocation demonstrates that the market demand does not warrant daily
service and could be best served by charter flights and one-stop service over MIA
Source: Carrier applications Delta (page 2), JetBlue (page 29) and Southwest (page 16)
#aacuba
Southwest
The fact that TPA was ranked so low in the prioritization of the only two airlines which applied
for TPA-HAV frequency allocation demonstrates that the market demand does not warrant daily
service and could be best served by charter flights and one-stop service over MIA
Source: Carrier applications JetBlue (page 29) and Southwest (page 16)
#aacuba
The FLL Applicants Attempt to Claim MIAs and Miami-Dade Countys 856,007
Cuban-Americans as Their Own Is Patently False
# of Usages
27
12
The Reality
MIA is Miami-Dade Countys home airport (AA-609)
MIA is the home airport to Miami-Dade Countys
Cuban-American population (AA-607, AA-608, AA-609,
AA-610 )
FLL MIA
MIA, and MIA alone, is the home airport
for almost 50% of the entire
U.S. Cuban-American population and the
origin of 86% of the U.S. charter flights to Cuba
#aacuba
Several Gateways Claim Broad U.S. Coverage to Cuba, But Only 4 Carrier
Gateways Can Legitimately Provide Connections to Most of the United States
All U.S. Gateways Proposed in This Proceeding
and Carriers Proposing That Service
SY
B6
MSP
BOS
2D
AA
UA
B6
UA
ORD
2D
B6
DL
EWR JFK
UA
F9
IAD
DEN
AA
2D
AA
AS
CLT
LAX
DL
ATL
AA
DFW
B6
DL
WN
UA
IAH
B6
WN
3M
SY
3M
JAX
3M
MCO
PBI
TPA
RSW
FLL
MIA
EYW
HAV
3M
B6
DL
WN
3M
B6
NK
AA
WN
DL
EA
F9
FX
#aacuba
To Cuba, Several Gateways Claim Broad U.S. Coverage, But Only 4 Carrier
Gateways Can Legitimately Provide Connections to Most of the United States
Gateways Remaining After Elimination of Proposals Offering Less than Daily Service
(and, Thus, Not Providing Comprehensive Coverage)
B6
BOS
B6
UA
B6
DL
EWR JFK
F9
DEN
AA
AS
CLT
LAX
DL
ATL
AA
DFW
B6
DL
WN
B6
WN
JAX
3M
MCO
PBI
TPA
FLL
MIA
Eliminated: AA/ORD (1x); AA/LAX (1x); 3M/EYW (5x); 3M/RSW (2x); UA/ORD (1x); UA/IAH (1x);
UA/IAD (1x); SY/RSW (2x); SY/MSP (2x); 2D/LAX (4x); 2D/ORD (4x); 2D/JFK (3x); FX/MIA (5x)
3M
B6
DL
WN
3M
B6
NK
AA
WN
DL
EA
F9
HAV
#aacuba
Several Gateways Claim Broad U.S. Coverage to Cuba, But Only 4 Carrier
Gateways Can Legitimately Provide Connections to Most of the United States
AA
CLT
DL
ATL
AA
DFW
MIA
Eliminated: B6/JFK (6); B6/EWR (0); B6/TPA (4); DL/JFK (2); DL/MCO (3); DL/MIA (2); F9/DEN (1);
F9/MIA (1); NK/FLL (15); SY/RSW (0); WN/MCO (10); WN/TPA (15); WN/FLL (20); UA/EWR (25)
AA
HAV
#aacuba
SEA
YUL
MSP
FSD
SLC
SFO
GRI
COS
DRO
LAS
LAX
PHX
SAN
SAF
ABQ
ELP
GCK
AMA
ROW
TUS
LBB
ABI
GRK
AUS
Carrier
Hub
# of Connections in
Both Directions with
Less Than 155% Circuity
DL
ATL
71
AA
CLT
68
AA
DFW
58
AA
MIA
52
MFE
BVT
MHT
ALB
BDL
HPN
EWR
LGA
JFK
ABE
PHL
MDT
BUF
DTW
CLE
PIT
ORD SBN
DSM
MDW FWA CMH CAK
PIA
IND
DAY
BWI
BMI
CVG
IAD
DCA SBY
CRW
MHK
SPI
HTS
CHO
LEX
MCI
RIC PHF
STL
LYH
SDF
ORF
COU
ROA
ICT
JLN
GSO
SGF
TRI
BNA
RDU EWN
TYS
OAJ
FAY
TUL
CLT
GSP AVL
XNA
MEM
ILM
CLT
CHA
OKC
GSP
HSV
LIT
CAE MYR
ATL
GTR
AGS
CHS
CHS
TXK
JAN MGM
DFW
MLU
SAV
SHV
JAX
PNS
TLH
AEX
IAH
SAT
LRD
YYZ
LNK
OMA
DEN
GJT
GRB
ATW
MKE
GRR
MSN
MSY
GNV
TPA
BRO
BDA
EUROPE
LHR London Heathrow, UK
CDG Paris, France
MCO
MIA
CRP
BOS
PVD
EYW
HAV
#aacuba
Series 400:
American Airlines Rebuttal Exhibits
to JetBlue Airways
1.2
1
Note:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
13.0
12
10
8
6
4
2
1.2
Note:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
Cuban-American Population
900,000
856,007
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000
83,713
Broward County
(FLL)
Miami-Dade County
(MIA)
#aacuba
JetBlue Tries to Claim that MIAs Traffic and Demand Are Also FLLs,
But It Just Isnt So
JetBlues Attempts
to Lump FLL and MIA
Cuban-American Population,
Traffic and Demand
The Reality
#aacuba
JetBlue Tries to Claim that MIAs Traffic and Demand Are Also FLLs,
But It Just Isnt So
JetBlues Attempts
to Lump FLL and MIA
Cuban-American Population,
Traffic and Demand
The Reality
#aacuba
JetBlue Tries to Claim that MIAs Traffic and Demand Are Also FLLs,
But It Just Isnt So
JetBlues Attempts
to Lump FLL and MIA
Cuban-American Population,
Traffic and Demand
The Reality
JetBlue operated only a single weekly FLLHAV charter flight (while operating 54% more
from TPA). If greater FLL-HAV demand
existed, JetBlue (and others too) would have
operated more charter flights from FLL.
#aacuba
Delta:
Frontier:
(Application, Page 6)
#aacuba
And One Applicant, Which Did Not Apply for FLL-HAV Service,
Admitted That FLLs Catchment Area Is One-Tenth the Size of MIAs
850,000
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000
85,000
FLL
MIA
#aacuba
Historical Data Proves That MIA-HAV Demand Far Outstrips FLL-HAV Demand
In Rebuttal to JetBlue Application at page 21
3,000
2,500
2,000
1,500
1,000
500
69
0
FLL-HAV
MIA-HAV
#aacuba
JetBlue
Domestic/
International
Departures
Here
#aacuba
While Americans Havana Arriving Flights Are All Under One Roof
In Rebuttal to Exhibit B6-102
#aacuba
BOS
SWF
EWR
JFK
DTW
LGA
PIT
BWI
SFO
DCA
LAS
LAX
SAN
CHS
JAX
FLL
HAV
#aacuba
SEA
YUL
ORD
DEN
EWR
JFK
CLE
BWI
IAD
CVG
MCI
LAS
GSO
BNA
MEM
LAX
PHX
PNS
SAT
RDU
CLT
BHM
IAH
ORF
ATL
CHS
DFW
AUS
DCA
RIC
SDF
STL
PHL
PIT
CMH
IND
SAN
BDL
LGA
DTW
SLC
SFO
BOS
YYZ
MSP
JAX
TLH
MSY
EUROPE
LHR London Heathrow, UK
GNV
TPA
BDA
MCO
MIA
EYW
HAV
#aacuba
B6 FLL-HAV
14,000
AA MIA-HAV
12,000
10,000
8,000
6,000
4,000
2,000
0
Jan 2014
Apr 2014
Jul 2014
Oct 2014
Jan 2015
Apr 2015
Source: JetBlue Application Exhibit B6-101 deconstructed by American to estimate flights operated and passengers
carried by B6 (herein after referred to as JetBlue Exhibit B6-101 Adjusted); American Airlines internal data
Jul 2015
Oct 2015
Jan 2016
#aacuba
54.4%
60%
50%
47.7%
46.8%
40%
30%
20%
10%
0%
2014
2015
While
Source: JetBlue Exhibit B6-101 Adjusted
#aacuba
82.8%
75.8%
76.3%
2014
2015
70%
60%
50%
40%
30%
20%
10%
0%
#aacuba
75.8%
AA LF
Better By:
+59% and +28.1
LF Points
76.3%
AA LF
Better By:
+40% and +21.9
LF Points
82.8%
AA LF
Better By:
+77% and +36.0
LF Points
70%
60%
50%
54.4%
47.7%
46.8%
40%
30%
20%
10%
0%
JetBlue American
FLL-HAV MIA-HAV
2014
JetBlue American
FLL-HAV MIA-HAV
2015
JetBlue American
FLL-HAV MIA-HAV
2016 (Jan-Feb)
#aacuba
1.5
1.0
1.0
0.7
0.5
0.0
Note:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
3.0
2.5
2.0
1.5
1.0
0.7
0.5
0.0
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
2 Weekly Flights
14 Weekly Flights
#aacuba
67.4%
70%
60%
53.8%
50%
40%
30%
20%
10%
0%
2015
2016
#aacuba
58.5%
8,674
14,827
897%
#aacuba
SYR
BOS
ROC
BUF
JFK
OAK
Notes: Based on Summer (June 2016) Schedule from OAG; Maximum connection time is
4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%
#aacuba
The Modest Demand for JFK-HAV Service Is Not Surprising Given the Size of
the Cuban-American Population and the Historical Demand for JFK-HAV Service
Cuban-American Population
900,000
856,007
3,000
2,918
800,000
2,500
700,000
600,000
2,000
500,000
1,500
400,000
300,000
1,000
200,000
500
100,000
47,880
70
0
Miami-Dade
MIA-HAV
JFK-HAV
#aacuba
1.5
1.0
0.5
0.3
0.0
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on
UnitedsAapplication (Exhibit UA-112).
#aacuba
JetBlues Exaggerated MCO-HAV Request Is Made Worse by the Requests of Southwest and
Delta. When Combined, the Total MCO-HAV Requests Bear No Relationship to the Needs of or
Demand in the MCO-HAV Market
In Rebuttal to Exhibit B6-101
2.0
2.0
1.5
1.0
1.0
1.0
0.5
0.3
0.0
MCO-HAV
Proportionate Share
of U.S.-HAV
Frequency
Allocation
Delta MCO-HAV
Reqeust
JetBlue MCO-HAV
Request
All MCO-HAV
Requests
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
900,000
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000
30,000
MCO
MIA
#aacuba
BOS
LGA
EWR
JFK
DCA
MCO
Notes: Based on Summer (June 2016) Schedule from OAG; Maximum connection time is
4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%
HAV
#aacuba
0.9
1.0
0.8
0.6
0.4
0.2
0.0
JetBlue
TPA-HAV Request
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
3.0
2.0
0.9
1.0
0.0
JetBlue + Southwest
TPA-HAV Request
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
850,000
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000
85,000
TPA
MIA
#aacuba
BOS
LGA
EWR
JFK
TPA
Notes: Based on Summer (June 2016) Schedule from OAG; Maximum connection time is
4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%
HAV
#aacuba
Cuban-American Population
900,000
856,007
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000
65,451
Hillsborough County
Miami-Dade County
#aacuba
16
Historical Demand
Current Demand
(as measured by
2015 charter flights)
JetBlue
TPA-HAV Request
14.0
14
12
10
8
6
4
2.6
2.0
2
0
#aacuba
Step 1:
Step 2:
324
Step 3:
230
Step 4:
2,268
Step 5:
1,620
Step 6:
700%
#aacuba
#aacuba
EWR-HAV Is JetBlues Next to Last Gateway Priority Among Its Six Proposed
U.S. Gateways to Havana (the Most of Any Applicant in This Proceeding)
1
1
2
1
3
4
2
1
5
#aacuba
JetBlue Would Have No Connections in Both Directions for Its EWR-HAV Service
In Rebuttal to Exhibit B6-103
EWR
0 Connections
Notes: Based on Summer (June 2016) Schedule from OAG; Maximum connection time is
4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%
HAV
#aacuba
BOS-HAV is JetBlues last priority among its six requested U.S. gateways
#aacuba
85,120 83,713
MIA
EWR
FLL
65,451
TPA
LAX
JFK
PBI
MCO
ORD
IAH
ATL
IAD
DFW
BOS
#aacuba
BOS
JFK
Notes: Based on Summer (June 2016) Schedule from OAG; Maximum connection time is
4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%
HAV
#aacuba
1
1
2
1
3
4
2
1
5
6
#aacuba
9.0
76.5%
76%
8.9
8.9
75%
74.1%
8.8
74%
73%
8.7
72%
8.6
71%
8.5
70%
American
jetBlue
American - MIA
Source: Diio Mi Fleet Data (as of March 8, 2016) / U.S. DOT On-Time Performance data via Diio Mi
* Average age of fleet: In-service fleet type of American (737-800 and A319) and JetBlue (A320/321) for Cuba service.
JetBlue - FLL
#aacuba
JetBlue
Wi-Fi
House wine, beer and spirits
Light snacks as well as coffee, specialty coffee
drinks, tea and soft drinks
Personal use computers with Internet access
Cyber-cafes
Power outlets to help you stay connected
Work areas with access to copiers and printers
Shower suites
Childrens play areas
Personal travel assistance with your reservations
Business Class
#aacuba
Series 500
American Airlines Rebuttal Exhibits
to Southwest Airlines
6.0
6
1.2
1
Proportionate Share of
FLL-HAV Frequency Allocation
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
15.0
14
13.0
12
10.0
10
1.2
Proportionate Share of
FLL-HAV Frequency
Allocation
All FLL-Applicants
Requests For FLL-HAV
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
Southwests Request for Six Daily FLL-HAV Frequencies Is Far Above and
Beyond Current Demand and Any Reasonable Forecast of Expected Demand
4,500
4,000
3,500
3,000
2,500
2,000
1,500
1,000
500
69
0
#aacuba
ALB
MKE
MDW
PVD
ISP
PIT
CMH
BWI
DCA
DEN
MCI
STL
RDU
ATL
PHX
DAL
AUS
HOU
MSY
TPA
FLL
Notes: Based on Summer (June 2016) Schedule from OAG; Maximum connection time is
4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%
HAV
#aacuba
900,000
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000
85,000
FLL
MIA
#aacuba
Southwest Has Never Operated a Single Flight to Cuba, Let Alone Any
Flights in the FLL-HAV Market
In Rebuttal to Southwest Application at page 17
0 Charter Flights
to Cuba
0Charter Flights
to Havana
0 Charter Flights
FLL-HAV
#aacuba
In Order to Operate Six Daily Flights at Just 70% Load Factor (Well Below Its Average
Load Factor), Southwest Would Have to Stimulate the FLL-HAV Market by 4,860%,
Assuming All 2015 FLL-HAV Charter Flights Operated at a 100% Load Factor*
In Rebuttal to Southwest Appendix 1
Step 1:
69
Step 2:
11,040
Step 3:
11,040
Step 4:
766,500
Step 5:
536,550
Step 6:
4,860%
* The required stimulation would be larger if the load factors were less than 100%.
#aacuba
0.9
1.0
0.8
0.6
0.4
0.2
0.0
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
0.9
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
16
14
Historical Demand
Current Demand
(as measured by
2015 charter flights)
Southwest
TPA-HAV Request
14.0
12
10
8
6
4
2.6
2.0
2
0
#aacuba
0 Charter Flights
to Cuba
0Charter Flights
to Havana
0 Charter Flights
TPA-HAV
#aacuba
BDL
PVD
ISP
MDW
CMH
CAK
IND
MCI
PHL
BWI
SDF
RDU
BHM
ATL
HOU
Notes: Based on Summer (June 2016) Schedule from OAG; Maximum connection time is
4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%
TPA
HAV
#aacuba
900,000
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000
85,000
TPA
MIA
#aacuba
1
1
1
1
1
1
2
2
3
#aacuba
4.0
Southwest
1
Delta
1
2
JetBlue
2
0.3
0
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
MKE
PVD
PIT
MCI
STL
PHL
SDF
ATL
HOU
MSY
Notes: Based on Summer (June 2016) Schedule from OAG; Maximum connection time is
4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%
MCO
HAV
#aacuba
0 Charter Flights
to Cuba
0Charter Flights
to Havana
0 Charter Flights
MCO-HAV
#aacuba
900,000
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000
30,000
MCO
MIA
#aacuba
3,000
2,500
2,000
1,500
1,000
569
500
65
0
#aacuba
MCO-HAV Was Southwests Last Priority Out of Nine Proposed HAV Services
In Rebuttal to Southwest Application at page 16
1
1
1
1
1
1
2
2
3
#aacuba
#aacuba
Southwests Use of Canada MIDT Data in Its Forecast Is Just Plain Wrong
In Rebuttal to Southwest Appendix 1
American Comment:
Southwest used Canada MIDT passenger
data to Cuba as a surrogate for U.S.-Cuba
data. However, Canada MIDT data
includes leisure/tourism passengers that
U.S. carriers are prohibited from taking to
Cuba, and leisure/tourism passengers are
the overwhelming majority of Canadian
passengers to Cuba. Therefore, the
methodology is totally flawed, and the
forecast is not credible.
#aacuba
2015 Charters
4,000
1,200,000
1,026,720
1,000,000
3,505
1,005,327
3,500
3,000
800,000
2,500
600,000
2,000
1,500
400,000
1,000
200,000
500
26
FLL/MIA-VRA Total
Passengers
FLL/MIA-HAV Total
Passengers
VRA
HAV
American Comment:
Incredibly, Southwest forecasts more Varadero passengers than Havana passengers. That result discredits completely the
methodology. The fact that, in 2015, 135 times more charters operated to HAV than VRA (3,505 flights to 26) puts this point to
rest. However, if Southwest believes its own forecast, it should apply for FLL/MCO/TPA-VRA frequencies instead of HAV
frequencies.
Source: Southwest Application; Havanatur charter data
#aacuba
Series 600:
General Rebuttal Exhibits
to Delta Air Lines
ATL, Like CLT and DFW, Provides Broad Coverage of the U.S.-HAV Markets
Not Served by American Over MIA
Deltas ATL-HAV
Connections
Americans CLT-HAV
Connections
Notes: Based on Summer (June 2016) Schedule from OAG; Maximum connection time is
4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%.
#aacuba
ATL, Like CLT and DFW, Provides Broad Coverage of the U.S.-HAV Markets
Not Served by American Over MIA
Deltas ATL-HAV
Connections
Americans DFW-HAV
Connections
MSP
SLC
GJT
DRO
LAS
PHX
TUS
GRI OMA
DEN
COS
SAF
ABQ
ROW
ELP
GCK
AMA
LBB
ABI
DSM
PIA
BMI
MHK
SPI
MCI
STL
ICT JLNCOU
SGF
TUL XNA
OKC
LIT
DFW
TXK
SHVMLU
AEX
GRK
LCHLFT
BTRMSY
AUS IAH BPT
HOU
SAT
LRD
CRP
MFE BRO
HAV
Notes: Based on Summer (June 2016) Schedule from OAG; Maximum connection time is
4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%.
#aacuba
5.1
5
3.0
3
1.9
1.0
1
0.7
JFK Proportionate
Share
JFK/EWR
Proportionate Share
JFK/EWR Frequency
Requests
#aacuba
BOS
JFK
PHL
Notes: Based on Summer (June 2016) Schedule from OAG; Maximum connection time is
4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%.
HAV
#aacuba
3,000
2,918
2,500
2,000
1,500
1,000
500
70
0
MIA-HAV
JFK-HAV
#aacuba
#aacuba
LGA
ATL
MIA
Notes: Based on Summer (June 2016) Schedule from OAG and Delta Application; Maximum
connection time is 4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%.
HAV
#aacuba
MIA-LHR:
#aacuba
And Deltas Current Non-Hub International Flight at PHL Is Not Going Well
In Rebuttal to Delta Application at pages 4-5 and page 7
100%
90%
80%
70%
60%
48%
50%
51%
55%
38%
36%
40%
30%
20%
19%
10%
0%
Apr-15
May-15
Jun-15
Jul-15
Aug-15
Sep-15
#aacuba
4.0
4.0
3.5
3.0
2.5
2.0
1.5
1.0
1.0
0.5
0.3
0.0
Proportionate Share of
MCO-HAV Frequency Allocation
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
SLC
RDU
ATL
MCO
Notes: Based on Summer (June 2016) Schedule from OAG and Delta Application; Maximum
connection time is 4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%.
HAV
#aacuba
900,000
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000
30,000
MCO
MIA
#aacuba
2,918
2,500
2,000
1,500
1,000
500
65
0
MIA-HAV
MCO-HAV
#aacuba
569
500
400
300
200
100
0
0
AA MIA-HAV
DL MCO-HAV
#aacuba
#aacuba
No share methodology
No base traffic data assumption
No stimulation assumptions
#aacuba
Series 700:
American Airlines Rebuttal Exhibits
to Frontier Airlines
Frontiers Request for the First Two of Its Three Proposed Daily
MIA-HAV Flights Is Tied to Frontier Also Receiving DEN-HAV
Frequencies, and There Is No Basis or Demand for DEN-HAV Service
Frontier says
United and Southwest, both substantially larger at DEN than Frontier and
with huge DEN connecting complexes, did not request DEN-HAV authority
#aacuba
1.0
1.0
0.8
0.6
0.4
0.2
0
0.0
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
2015
By All Applicants
#aacuba
Cuban-American Population
2010
1,000,000
900,000
856,007
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000
49,702
20,633
11,350
7,217
3,487
ORD
DFW
CLT
DEN
Miami-Dade (MIA)
LAX
#aacuba
Frontier operates only 35 weekly flights to MIA from 6 cities and not all are daily service
ORD: 3x weekly
PHL: 4x weekly
LAS: Daily
LGA: Daily
DEN: Daily
ATL: Daily
None of these flights connect to proposed MIA-HAV service
Frontier has little, if any, frequent flier presence in MIA
#aacuba
SLC
DEN
MIA
Notes: Based on Summer Schedule provided in JetBlue Application; Maximum connection time is 4 hours; Minimum connection time
is 55 minutes; Maximum circuity is 155%.
HAV
#aacuba
Series 800:
American Airlines Rebuttal Exhibits
to Spirit Airlines
2.0
2.0
1.5
1.2
1.0
0.5
And
0.0
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
13.0
12.2
12
10.0
10
8
6
4
1.2
2
0
All Applicants' FLL-HAV
Requests
("FLL Applicants")
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
900,000
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000
85,000
FLL
MIA
#aacuba
2,500
2,500
2,000
2,000
1,500
1,500
1,000
1,000
500
500
2,327
0
0
Inception
2015
Spirit
American
#aacuba
4,348
4,500
2,918
3,000
4,000
2,500
3,500
2,000
3,000
2,500
1,500
2,000
1,000
1,500
1,000
500
500
70
54
Spirit
Other
Applicants
FLL
MIA
MIA
#aacuba
LGA
DTW
ORD
ACY
BWI
MYR
ATL
DFW
TPA
MCO
FLL
Notes: Based on Summer Schedule provided in JetBlue Application; Maximum connection time is 4 hours; Minimum connection time
is 55 minutes; Maximum circuity is 155%.
HAV
#aacuba
Series 900:
American Airlines Rebuttal Exhibits
to United Airlines
In Rebuttal to United Application at page 1, Exhibits UA-116, UA-120, and UA-130 to UA-137
1.3
1.2
1.2
1.2
1.1
1.1
1
1.0
1.0
0.9
United's Request
#aacuba
But Uniteds EWR-HAV Request Plus JetBlues Daily EWR-HAV Service Request
Exceeds EWRs Proportionate Share of the U.S. EWR-HAV Frequency Allocation
2.1
2.0
1.5
1.2
1.1
1.0
0.5
0.0
EWR-HAV
Proportionate
EWR-HAV
Proportionate
Share of United's Full EWR-HAV Request
Share
of U.S.-HAV
U.S.-HAV
Frequency
Allocation
Frequency Allocation
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
68
70
58
60
52
50
40
30
25
20
10
AA @ CLT
AA @ MIA
AA @ DFW
UA @ EWR
#aacuba
EWR
IAH
HAV
IAH
290% Circuity
HAV
#aacuba
IAD
EWR
IAD
HAV
Note: Northbound connects to UA EWR-IAD Flight 4900 departing at 19:37 with a layover of 1:24; Southbound
begins with UA IAD-EWR Flight 4933 arriving at 7:31 with a layover of 2:47.
Source: OAG June 2016 Schedule.
HAV
#aacuba
ORD
ORD
EWR
HAV
Note: Northbound connects to UA EWR-ORD Flight 3305 departing at 19:30 with a layover of 1:17; Southbound
begins with UA ORD-EWR Flight 1626 arriving at 8:58 with a layover of 1:20.
Source: OAG June 2016 Schedule
HAV
#aacuba
1,084
1,000
800
600
400
200
0
0
American
United
#aacuba
Series 1000:
American Airlines Rebuttal Exhibits
to Alaska Airlines
2.0
2.0
1.5
1.0
0.7
0.5
0.1
0.0
LAX-HAV
Proportionate Share
of U.S.-Havana
Frequency Allocation
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
80%
72%
70%
60%
<50%
50%
40%
30%
20%
10%
0%
#aacuba
The amount of simulation required to reach a 70% load factor on a twice daily LAX-HAV flight
(AS request) is 602% - 2,060%
Frequency of Service
Load Factor
Annual Passengers
Required Stimulation
1x Weekly
<50%
8,330
1x Daily
<50%
58,400
602%
2x Daily
<50%
116,800
1,304%
1x Daily
70.0%
81,760
980%
2x Daily
70.0%
163,520
2,060%
If there were greater demand in the LAX-HAV market, American would have increased its
frequencies from one weekly
There are and will be multiple ways to get to Havana from Los Angeles after this proceeding
Alaskas scant connecting points (SEA, PDX and ANC) provide little Cuban-American population
support for its proposed service
Cuban-American Population: SEA (4,027), PDX (4,199), SLC (1,114), and ANC (622)
LAX, for now, is best served as it is once (or maybe twice) weekly
#aacuba
SEA
PDX
LAX
HAV
#aacuba
Of the 3 Connections Alaska Has to Its LAX-HAV Flight, One SEA Actually
Has Better Connect Times on American
Alaska
Route
Elapsed Time
American
Elapsed Time
Southbound
SEA-LAX-HAV
Southbound
535 min
537 min
SEA-MIA-HAV
+ 2 min
Northbound
Northbound
HAV-LAX-SEA
Route
Alaska
better / (worse)
than American
675 min
565 min
HAV-DFW-SEA
(110) min
#aacuba
159,000
140,000
120,000
100,000
80,000
49,702
60,000
40,000
20,000
0
Forecast Local Pax
#aacuba
Series 1100:
American Airlines Rebuttal Exhibits
to Sun Country Airlines
RSW-HAV Flights
2015 Charter versus SY Proposed
120
104
100
80
60
40
20
9
0
#aacuba
= 2,753% Increase
612
2015 Charter Seats
#aacuba
MSP
RSW
Notes: Based on Sun Country application; Maximum connection time is 4 hours; Minimum
connection time is 55 minutes; Maximum circuity is 155%; Minimum of 5x weekly flights.
HAV
#aacuba
1.5
1.0
0.5
0.3
0.0
Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation (U.S.-Cuba Air Service Arrangement)
multiplied by % of Cuban-American population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).
#aacuba
104
1
2015 Charter Flight
Operated on MSP-HAV*
#aacuba
MSP
SFO
Notes: Based on Sun Country application; Maximum connection time is 4 hours; Minimum
connection time is 55 minutes; Maximum circuity is 155%; Minimum of 5x weekly flights.
HAV
#aacuba
MSP
No Flights
No Connections
HAV
#aacuba
Series 1200:
American Airlines Rebuttal Exhibits
to Federal Express
FedEx Is Right That It Is Not Asking For Much (FedEx Argument, p.1),
But Is the Authority It Seeks Consistent with the U.S.-Cuba MOU?
In Rebuttal to FedEx Argument at page 1
Section 1
Grant of Permissions
1. The permission to perform scheduled
and charter services between any point or
points in the United States and any point or
points in Cuba .
Miami (MIA)
Havana (HAV)
Mrida (MID)
FedEx Proposes the HAV-MID Blind Sector Because of the Lack of HAV-MIA
Traffic, So Is Now the Right Time to Award Any Scarce and Highly In-Demand
U.S.-Cuba Frequencies for a Cargo Service That Has Not Yet Materialized?
It Proposes to Operate
Miami (MIA)
Miami (MIA)
Havana (HAV)
Havana (HAV)
Mrida (MID)
#aacuba