Consolidated Answer, Testimony, and Rebuttal Exhibits

Transcription

1 Consolidated Answer, Testimony, and Rebuttal Exhibits of American Airlines in Support of American Airlines U.S.-Cuba Scheduled Service Docket DOT-OST March 14, 2016

2 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 Section 1: General Overview Section 2: American s Request Section 3: Gateway Comparisons Section 4: Rebuttal to JetBlue Section 5: Rebuttal to Southwest Section 6: Rebuttal to Delta Section 7: Rebuttal to Frontier Section 8: Rebuttal to Spirit Section 9: Rebuttal to United Section 10: Rebuttal to Alaska Section 11: Rebuttal to Sun Country Section 12: Rebuttal to FedEx

3 BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. ) Application of ) ) AMERICAN AIRLINES, INC. ) Docket DOT-OST ) in the matter of 2016 U.S.-Cuba Frequency ) Allocation Proceeding ) ) CONSOLIDATED ANSWER OF AMERICAN AIRLINES, INC. Communications with respect to this document should be addressed to: Howard Kass Vice President Regulatory Affairs Robert A. Wirick Managing Director Regulatory and International Affairs John B. Williams Senior Analyst Regulatory and International Affairs AMERICAN AIRLINES, INC th Street, NW Washington, D.C (202) howard.kass@aa.com robert.wirick@aa.com john.b.williams@aa.com March 14, 2016 Paul T. Denis Steven G. Bradbury William B. Sohn DECHERT LLP 1900 K Street NW Washington, D.C (202) paul.denis@dechert.com steven.bradbury@dechert.com william.sohn@dechert.com Charles A. Hunnicutt Brent Connor THOMPSON HINE LLP 1919 M Street NW, Suite 700 Washington, D.C (202) charles.hunnicutt@thompsonhine.com brent.connor@thompsonhine.com

4 TABLE OF CONTENTS Executive Summary... 1 Discussion... 4 I. The Applications of Other Carriers Confirm that MIA is the Necessary Starting Point for Successfully Restoring and Growing U.S.-Cuba Scheduled Service... 4 II. American s Proposed Schedule Offers the Strongest Foundation for Service from MIA, While Providing Sufficient Frequencies for Scheduled Service to and Through Other Connecting Hubs... 6 A. Demographic and Charter Traffic Data Conclusively Demonstrate that MIA Deserves No Less than the Ten Daily MIA-HAV Frequencies Proposed by American... 6 B. Awarding American Ten Daily MIA-HAV Frequencies Leaves Ample Frequencies for Fulfilling Other Objectives... 8 C. Only American s Proposed Service from MIA Maximizes Public Benefits... 9 III. MIA Is Superior to FLL for Serving the Miami-Centered Cuban-American Community in South Florida A. MIA Has Long Been the Preferred Airport for U.S.-Cuba Service B. FLL is Not Convenient for Most South Florida Cuban Americans IV. TPA Is the Only Other Florida Airport that Might Merit Scheduled Service to HAV, and Its Award Should Not Exceed One Daily Frequency A. TPA Is No Carrier s First, Second, or Third Choice B. No Other Florida Airport Should Receive Scheduled Frequencies to HAV at the Present Time V. American s Specific Responses to the Other Airlines Applications A. Application of JetBlue Airways Corp B. Application of Southwest Airlines Co C. Application of Delta Air Lines, Inc D. Application of Frontier Airlines, Inc

5 E. Application of Spirit Airlines, Inc F. Application of United Airlines, Inc G. Application of Alaska Airlines, Inc H. Application of Sun Country Airlines I. Application of Federal Express Corp J. Application of Dynamic International Airways, LLC K. Application Eastern Air Lines Group, Inc L. Application of Silver Airways Corp Conclusion... 29

6 BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. ) Application of ) ) AMERICAN AIRLINES, INC. ) Docket DOT-OST ) in the matter of 2016 U.S.-Cuba Frequency ) Allocation Proceeding ) ) CONSOLIDATED ANSWER OF AMERICAN AIRLINES, INC. American Airlines, Inc. ( American ) submits the following Consolidated Answer in response to the Applications of Alaska Airlines, Inc. ( Alaska ), Delta Air Lines, Inc. ( Delta ), Dynamic International Airways, LLC ( Dynamic ), Eastern Air Lines Group, Inc. ( Eastern ), Federal Express Corp. ( FedEx ), Frontier Airlines, Inc. ( Frontier ), JetBlue Airways Corp. ( JetBlue ), Silver Airways Corp. ( Silver ), Southwest Airlines Co. ( Southwest ), Spirit Airlines, Inc. ( Spirit ), Sun Country Airlines ( Sun Country ), and United Airlines, Inc. ( United ). Executive Summary In this first ever U.S.-Cuba frequency allocation proceeding, the Department must ensure that the expected near-term demand for scheduled service to Cuba is satisfied, first and foremost, at Miami International Airport ( MIA ). That is the essential first step to maximizing the prospects of success for the Administration s policy of restoring and growing scheduled service to Cuba over the long term.

7 Consolidated Answer of American Airlines, Inc. Page 2 of 30 The applications filed do not dispute that the greatest demand for U.S.-Cuba travel comes from the Miami-Dade Cuban-American community, and this supports the fundamental premises of American s proposed schedule: The largest share of scheduled frequencies to Havana ( HAV ) should be allocated to American s flights out of MIA, in order to match the availability of scheduled passenger service to the existing demand for HAV service at MIA. The success of the Administration s objective of promoting U.S.-Cuba engagement depends on the allocated frequencies being concentrated where demand and traffic currently exist, and no airline has proposed an allocation more tailored to demand and traffic than American. 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 American s proposed schedule is the only proposal that will fully satisfy the Administration s objective underlying this proceeding. First, American s 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 Miami- Dade Cuban Americans are met. Among all applicants requesting frequencies from MIA, American s proposed service is superior due to American s unmatched presence at MIA and

8 Consolidated Answer of American Airlines, Inc. Page 3 of 30 throughout Miami-Dade County, its experience with Cuba, and its network of connections to Cuba through MIA. Second, the excessive frequencies requested to Cuba from Fort Lauderdale ( FLL ) do not meet the needs of Miami-Dade Cuban Americans. These proposals are based on the premise that hundreds of thousands of Cuban Americans living in Miami-Dade County should be inconvenienced by having to travel to Broward County for scheduled service to Cuba. Decades of experience with U.S.-Cuba charter flights establishes beyond doubt that these passengers prefer MIA, as the president of one of the largest U.S-Cuba charter companies has testified. AA- R-T-1. There has never been more than one or two weekly charter flights from FLL to anywhere in Cuba, and there is no basis to assume that multiple daily scheduled frequencies to HAV at FLL will create demand where very little has ever existed. Third, the volume of daily frequencies proposed to HAV from other Florida airports far surpasses any realistic level of demand. These airports, including Tampa ( TPA ) and Orlando ( MCO ), serve minimal local demand and offer almost no connectivity. Were the overall allocation of frequencies based purely on local Cuban-American population or 2015 charter traffic, TPA might economically support one daily frequency to HAV, and the other Florida airports none. That is the appropriate allocation given the near absence of connectivity through these airports. The local needs of these communities can be served through one-stop flights and charter service. Most other applicants in this proceeding have asked for frequencies that are untethered to demand and largely aspirational, as American s Answer explains in detail. To advance the President s objectives effectively and maximize public benefits, the Department should allocate

9 Consolidated Answer of American Airlines, Inc. Page 4 of 30 frequencies to match anticipated traffic and demand. These considerations compel the award of American s proposed frequencies. Discussion I. 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 Department s 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 Tourism has no place in this proceeding, because tourism-related travel to Cuba remains prohibited under U.S. law. 3 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 1 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 President s objective to resume U.S.-Cuba scheduled service, the non- HAV 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 See, e.g., Application of Delta Air Lines, Inc., at 4 5; Application of Frontier Airlines, Inc., at 6. 5 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

10 Consolidated Answer of American Airlines, Inc. Page 5 of 30 These realities all support American s proposed schedule. As U.S. Senator Jeff Flake (R- AZ) recently explained on the Senate floor, U.S.-Cuba scheduled service should include adequate regular service to accommodate the growing demand from the largest and closet Cuban-American population located in Miami-Dade County. 6 Prominent members of the Miami-Dade Cuban-American community, including Mike Fernandez, the Chairman of MBF Healthcare Partners, agree with the Senator s observation. 7 Family, cultural, and commercial ties with Cuba are the strongest in Miami-Dade County, and American s ten requested MIA- HAV frequencies are firmly supported by the factors most indicative of near-term demand for U.S.-Cuba travel: Nearly half the Cuban-American population resides in Miami-Dade County. Based on the size and location of the Cuban-American population near MIA, MIA would receive more than half of the frequencies were this allocation made purely on the distribution of Cuban Americans among the population centers served by the airports for which applicants have requested U.S.-Cuba frequencies. Ex. AA-R-107. Nearly 84 percent of all charter flights between the U.S. and HAV in 2015 originated from MIA almost 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. The near unanimity among applicants on the principles governing U.S.-Cuba travel fully supports American s proposed schedule. Only American s 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 5 6 ( 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 Letter from Mike Fernandez to Secretary Anthony Foxx (Mar. 14, 2016).

11 Consolidated Answer of American Airlines, Inc. Page 6 of 30 II. American s Proposed Schedule Offers the Strongest Foundation for Service from MIA, While Providing Sufficient Frequencies for Scheduled Service to and Through Other Connecting Hubs American s proposed schedule is the only proposal that meets the needs of the Miami- Dade Cuban-American community. This community requires the ten daily MIA-HAV 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 Department s 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 President s and, necessarily, the Department s policy towards Cuba. The Miami-Dade Cuban-American 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 Administration s broader goals. American s 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. Demographic and Charter Traffic Data Conclusively Demonstrate that MIA Deserves No Less than the Ten Daily MIA-HAV Frequencies Proposed by American Comparing each applicants requests to the distribution of Cuban Americans and U.S.- Cuba charter flights shows that American s proposed schedule is most aligned with these metrics the 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 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.

12 Consolidated Answer of American Airlines, Inc. Page 7 of 30 contrast to American s demand-matched proposal from MIA, the other applicants proposed schedules are largely out of sync with these metrics. Figure 1 below shows how an allocation of frequencies to HAV would look if it were based on the distribution of the Cuban-American population at each of the population centers served by the airports for which applicants have requested frequencies, and then compares that allocation to the frequencies actually requested by applicants at those airports. Figure 1: All Requested HAV Frequencies Compared to an Allocation Based on Local Cuban-American Population (Ex. AA-R-107) 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 9 Application of American Airlines, Inc., at ex. AA-602, 603.

13 Consolidated Answer of American Airlines, Inc. Page 8 of 30 Comparing the requested frequencies to HAV to an allocation keyed to the proportion of charter flights flown to HAV from each of the airports in the United States in 2015 produces a similar outcome, as Figure 2 below shows: Figure 2: All Requested HAV Frequencies Compared to an Allocation Based on 2015 U.S.-Cuba Charter Traffic (Ex. AA-R-113) Both graphs demonstrate that American s application is reasonable under the Department s standards and should therefore be fulfilled. American s proposal is right-sized to meet the actual demand for U.S.-Cuba scheduled service where that demand is actually located, and only American s proposed schedule maximizes the public benefits of the Department s allocations. B. Awarding American Ten Daily MIA-HAV Frequencies Leaves Ample Frequencies for Fulfilling Other Objectives American s 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 ),

14 Consolidated Answer of American Airlines, Inc. Page 9 of 30 Atlanta ( ATL ), Dallas/Fort-Worth ( DFW ), and Chicago ( ORD ), which are well situated and have routes and connectivity to serve communities and businesses with Cuban ties across the United States. Indeed, American s proposed scheduled service from CLT and DFW would connect more than 70 cities not connected through MIA with Cuba, providing blanket coverage throughout the United States. Ex. AA-R-206, 207. American s proposal also allows the Department to allocate sufficient frequencies to serve other Cuban-American population centers. 10 But the Department has little room to spare, and the proposed daily frequencies to HAV not justified by demand and/or connectivity cannot be awarded without (a) denying MIA the necessary frequencies and thereby harming those who most demand travel to Cuba, or (b) leaving the Department with insufficient frequencies to fulfill the objectives described above. The requests by other applicants for these scarce frequencies are simply not justified by current demand, and are merely aspirational at this point. Perhaps these requests can be fulfilled in the future as the U.S.-Cuba aviation market evolves. The Department must ensure the needs of the Cuban-American community, and particularly those residing near MIA, are met, and only American s proposed service achieves this primary goal. C. Only American s Proposed Service from MIA Maximizes Public Benefits Among the airlines proposing service from MIA, none provide anywhere near the level of public benefits that American s 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 American s proposal also accommodates sufficient frequencies for cargo service, though as discussed in the part of this Answer addressing FedEx s 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.

15 Consolidated Answer of American Airlines, Inc. Page 10 of 30 sustainable. The service proposed by Eastern and Frontier also contains deficiencies that should be disqualifying. These flaws are described below: Delta: There is no basis to assume Delta will adequately serve the Miami market. Delta has no hub at MIA, its frequent flyer membership in Miami-Dade County is minimal, and it carried far fewer passengers than American from MIA in Ex. AA-R-605. Moreover, Delta only connects two cities in both directions with Cuba via MIA. Ex. AA-R-605. There is good reason to believe Delta cannot successfully operate an international flight from MIA. Thinking it could, Delta inaugurated MIA-LHR nonstop service in March 2011, and the service was terminated in April 2012, barely more than a year later. Ex. AA-R-606. Delta s failure suggests the Department should exercise caution before allowing Delta to experiment with such scarce resources as the HAV frequencies. Frontier: There are at least two reasons to reject Frontier s proposed MIA-HAV service. First, Frontier s first two MIA-HAV frequencies are linked to Frontier also receiving a frequency between Denver ( DEN ) and HAV, and there is no basis for the Department to award nonstop DEN-HAV service. Ex. AA-R-701. Second, Frontier has practically no presence at MIA and no experience in Cuba, having never flown even one charter flight to Cuba. Ex. AA-R-703. Eastern: Eastern s proposed service is deficient and suffers from two glaringly 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, Eastern s profile with respect to U.S.-Cuba operations should be that of a charter service provider only.

16 Consolidated Answer of American Airlines, Inc. Page 11 of 30 The public benefits created by these applicants proposed MIA frequencies are illusory, in contrast to the benefits created by American s proposal. American s proposed service 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. American s 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 Administration s objectives are too important to rely on airlines with little Miami presence and no appropriate experience to provide consistent, reliable service to link the Miami- Dade 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 Administration s 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. MIA Is Superior to FLL for Serving the Miami-Centered Cuban-American Community in South Florida The 13 requested FLL-HAV frequencies make FLL by far the most over-requested 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

17 Consolidated Answer of American Airlines, Inc. Page 12 of 30 to maximize passenger inconvenience, and one believes in a build it and they will come philosophy. The applicants requesting multiple daily frequencies from FLL ignore demographics and the demand for U.S.-Cuba travel shown by charter flight data, which demonstrates that Cuban Americans in the Miami area prefer MIA over FLL. The Cuban-American population is not evenly distributed throughout the region of South Florida 11 an area 110 miles long. Instead, the Cuban-American population in South Florida is concentrated in Miami-Dade County and particularly in several communities surrounding MIA. Tellingly, if there is in fact demand from FLL, then any (or all) of the applicants now touting FLL would have met that demand by flying charters as, notably, JetBlue has done at TPA and JFK. FLL has never supported even one daily charter flight to Cuba, ex. AA-R-404, and the Department should decline the invitation to award FLL so many scheduled frequencies utterly disconnected from actual demand. A. 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 Florida s tri-county area.... ) Fed. Reg. 72, (1980).

18 Consolidated Answer of American Airlines, Inc. Page 13 of 30 Also, review of the requests for authorization to land elsewhere than at Ft. Lauderdale reveals that most of the requests are to use Miami International Airport. This is apparently because most airlines willing to offer services to and from Cuba are based in Miami and their passengers, in most cases, are Cuban resident aliens or U.S. citizens of Cuban birth living in Miami. When an aircraft flies into or out of Ft. Lauderdale-Hollywood International Airport instead of Miami International Airport, it increases the cost for all involved parties. 13 The same reality still holds today, if not more so. U.S.-Cuba flights from FLL have been authorized since 2011, yet the charter flight data from 2015 shows a stark preference among airlines for MIA: 2,918 HAV-bound charter flights (83.3% of all U.S. flights to HAV) originated from MIA in 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 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: Fed. Reg. 24, (1987). 14 Application of American Airlines, Inc., at ex. AA-711.

19 Consolidated Answer of American Airlines, Inc. Page 14 of 30 Figure 3: All MIA-HAV and FLL-HAV Frequencies Requested Compared to an Allocation Based on 2015 U.S.-Cuba Charter Flights 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 Cuban- American population surrounding each airport, looks remarkably similar:

20 Consolidated Answer of American Airlines, Inc. Page 15 of 30 Figure 4: All MIA-HAV and FLL-HAV Frequencies Requested Compared to an Allocation Based on Local Cuban-American Population 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. FLL is Not Convenient for Most South Florida Cuban Americans JetBlue, Southwest, and Spirit amalgamate the enormous Miami-Dade Cuban-American population with the scant Cuban-American population of Broward County, where FLL is located. Roughly ten times as many Cuban Americans reside in Miami-Dade County as reside in Broward County. As American s exhibits show, the ten U.S. communities with the largest population of residents born in Cuba are all located in Miami-Dade County, next door to MIA:

21 Consolidated Answer of American Airlines, Inc. Page 16 of 30 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), story.html.

22 Consolidated Answer of American Airlines, Inc. Page 17 of 30 The requests by JetBlue, Southwest, and Spirit for a combined 12 daily frequencies between FLL and HAV are therefore meritless. The alleged advantages of FLL over MIA touted by these carriers fall away when experience demonstrates that the hundreds of thousands of Cuban Americans living near MIA do not drive to FLL for flights to Cuba. In contrast to the numerous daily flights to Cuba from MIA operated by American, JetBlue currently operates just one weekly Cuba-bound flight from FLL, ex. AA-R-404, 407, and Southwest and Spirit operate exactly zero. None of these airlines offers any practical explanation or plans to support multiple daily FLL-HAV frequencies when there has never been anywhere near that level of demand for Cuba-bound charter flights from FLL. 16 The absence of any evidentiary support should be fatal to these applications. Treating MIA and FLL as fungible for U.S.-Cuba flights defies decades of experience, and the Department should not award an allocation of Cuba frequencies to FLL so out of line with current demand. American s service proposal leaves adequate frequencies to serve the actual modest demand from FLL. But any such frequencies certainly should not be awarded in place of frequencies from MIA. IV. 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 can t 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 And the growth in reported MIA-HAV flights between 2014 and 2015 an average of nearly one additional flight per day far 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.

23 Consolidated Answer of American Airlines, Inc. Page 18 of 30 But demographics and charter flight data show that TPA deserves only one daily frequency at most, and that no other Florida airport deserves consideration for scheduled service to HAV in this first phase of frequency allocations. The limited connections available at these airports make them poor candidates for scheduled service, and they are better served through one-stop scheduled service and charter service, which remains unlimited in the U.S.-Cuba air service arrangement. A. TPA Is No Carrier s First, Second, or Third Choice Whether TPA can support even one daily flight to HAV is questionable, and there is no basis to assume local demand will support more. TPA s 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 JetBlue s and Southwest s 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 85,000 less roughly 10 percent of the Cuban-American population of Miami-Dade. Ex. AA-R-429. Were the allocation of frequencies based purely on local Cuban-American 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.

24 Consolidated Answer of American Airlines, Inc. Page 19 of 30 scheduled frequency to HAV. Ex. AA-R-427. In light of all the requested frequencies given priority over TPA-HAV, this frequency may not be merited now. B. No Other Florida Airport Should Receive Scheduled Frequencies to HAV at the Present Time There is no basis for the Department to award HAV frequencies to Orlando, Fort Myers, West Palm Beach, Key West, and Jacksonville. The Cuban-American population in these 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 MCO- HAV frequency would fly nearly empty. In 2015 there were just 65 MCO-HAV charter flights an 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. One-stop service (including American s proposed single plane service through MIA) and charter service meet Orlando s 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.

25 Consolidated Answer of American Airlines, Inc. Page 20 of 30 these frequencies by the applicants 19 shows that this service is not a priority, and the Department should not squander any of the limited HAV frequencies on this airport. As to the other Florida airports, any argument for scheduled service to HAV is even weaker. An overall allocation of HAV frequencies based on Cuban-American population or on 2015 charter traffic would show that these airports all deserve no scheduled service. See Figure 1, Figure 2. Indeed, other than Key West ( EYW ), 20 fewer than ten charter flights to Cuba originated from any of these airports in all of Ex. AA-R-205. And connecting traffic through these airports would be nearly non-existent. These airports are best served with one-stop or charter service. There are not enough available HAV frequencies in this proceeding for the Department to award them to small, regional airports with minimal local demand, and the Department should decline the requests to do so. V. American s Specific Responses to the Other Airlines Applications There are many flaws with the service proposals by the other applicants in this proceeding. The allocation of these scarce frequencies is not supported by the local Cuban- American 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 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.

26 A. Application of JetBlue Airways Corp. Consolidated Answer of American Airlines, Inc. Page 21 of 30 The frequencies proposed by JetBlue have no relation to demand. JetBlue accurately states that international frequency allocations to cities without sufficient markets for service can lead to squandered public benefits and are certainly not in the public interest. 22 But among all the airlines proposed schedules, this is most applicable to JetBlue. There is insufficient market demand for JetBlue s proposed level of service at all six of its proposed U.S. gateways to Havana (the most of any applicant in this proceeding). Fort Lauderdale (FLL): JetBlue currently operates just one weekly charter flight 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. JetBlue s request is particularly surprising because its weekly FLL-HAV charter flight has historically had a load factor of around 50 percent. By comparison, American s MIA-HAV charter flights have had load factors of around 75 percent. Ex. AA-R-415. And JetBlue s 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 Application of JetBlue Airways Corp., at 8 9.

27 Consolidated Answer of American Airlines, Inc. Page 22 of 30 realm of possibility, especially since JetBlue s proposed JFK-HAV service creates only six connections in both directions. Ex. AA-R-421. Orlando (MCO): JetBlue s request for two daily MCO-HAV frequencies again finds no basis in demand. As described in Part IV of this Answer, MCO deserves no scheduled 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 JetBlue s 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 JetBlue s 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. Especially given that JetBlue s proposed TPA-HAV 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): JetBlue s 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): JetBlue s 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

28 Consolidated Answer of American Airlines, Inc. Page 23 of 30 JetBlue s last priority among its six requested U.S. gateways, and it should be last on the Department s list as well. Ex. AA-R-440. B. Application of Southwest Airlines Co. 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, Southwest s 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 annually a 6,348 percent increase over the 69 FLL-HAV charter flights flown in 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. Southwest s request for two TPA-HAV frequencies is therefore excessive. Orlando (MCO): The average of one weekly MCO-HAV charter flight and small Orlando Cuban-American population supports the award of no scheduled HAV frequencies to MCO, as described earlier in this Answer. C. Application of Delta Air Lines, Inc. There are many reasons to doubt that Delta can successfully operate its proposed MIA- HAV and MCO-HAV daily frequencies, neither of which originate from a Delta hub. Delta s 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 Delta s 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

29 Consolidated Answer of American Airlines, Inc. Page 24 of 30 plummeting to 38 percent the next month (the last month for which DOT T-100 data is available). Ex. AA-R-606, 607. Delta s proposed service to HAV from ATL creates comparable connectivity to American s proposed service to HAV from CLT and DFW. Ex. AA-R-601. But Delta has almost no experience operating flights to Cuba, whereas American s 25 years of experience is first among all applicants. The steep learning curve required for reliably operating flights to and from Cuba make American the best choice to provide comprehensive coverage to the entire United States for U.S.-Cuba service. Delta will likely struggle to attract passengers from both MIA and MCO. Delta s lack of a hub at MIA means that there are few residents of Miami-Dade County with Delta s frequent flier membership, and Delta s operations from MIA in 2015 were tiny compared to American s, in terms of both domestic departures and domestic passengers carried. Ex. AA-R-213, 214, 217, 218, 605. As to Delta s proposed MCO-HAV daily frequency, Orlando s Cuban-American population of 30,000 and Delta s 3 connections (in both directions) through MCO to HAV cannot support a daily flight, when U.S.-Cuba charter traffic from MCO to HAV in 2015 was little more than a single weekly flight. Ex. AA-R-609, 611. Delta s proposed MIA-HAV and MCO-HAV frequencies should therefore be rejected. D. Application of Frontier Airlines, Inc. Frontier s proposed service suffers from three glaring flaws. First, the first two of Frontier s 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 3,500 far from sufficient to support even one weekly scheduled flight. Ex. AA-

30 Consolidated Answer of American Airlines, Inc. Page 25 of 30 R-704. Second, Frontier has almost no MIA presence. Ex. AA-R-705. And third, Frontier s proposed MIA-HAV and DEN-HAV frequencies both have only a single connection in both directions. Ex. AA-R-706. There is no basis to award service with such little demand and connectivity, to an airline with limited potential to serve the Cuban-American community and no experience in Cuba. E. Application of Spirit Airlines, Inc. 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 County s, and historically, FLL has supported barely more than a single weekly charter flight to HAV. Spirit s request for two daily FLL-HAV frequencies is excessive, especially given Spirit s 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. Application of United Airlines, Inc. Several problems with United s 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 United s 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 United s proposed service from IAD, IAH, and EWR to travel to and from Cuba exclusively on Saturdays, and this constraint makes United s proposed service

31 Consolidated Answer of American Airlines, Inc. Page 26 of 30 inferior to the quick, every-day-of-the-week one-stop flights between these airports and Cuba through MIA created by American s network. G. Application of Alaska Airlines, Inc. Alaska s 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 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 Alaska s proposed service creates will hardly increase traffic over current levels or improve travel times. Ex. AA-R-1004, LAX is best served, for now, with the weekly scheduled service to HAV proposed by American, not the daily service proposed by Alaska. H. Application of Sun Country Airlines 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 Ex. AA-R-1101, There were nine RSW-HAV charter flights and one MSP-HAV charter flight in Finally, Sun 23 American s contract with the charter company prohibits American from disclosing the actual load factor. Cuba. 24 This was a one-off charter flight operated by Delta to transport the Minneapolis Symphony to and from

32 Consolidated Answer of American Airlines, Inc. Page 27 of 30 Country s network would create only one connection in both directions at each airport. Ex. AA- R-1102, There is no reason for either of these requested frequencies to be awarded. I. Application of Federal Express Corp. The cargo service proposed by FedEx raises two issues. First, FedEx s proposed service from HAV to Mérida, 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-R Whether this permits FedEx s 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. Application of Dynamic International Airways, LLC Awarding frequencies to Dynamic would not be in the public interest. Dynamic s 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 U.S.-Cuba MOU, at 1, 2.d (emphasis added). 26 Application of Federal Express Corp., at Application of Dynamic International Airways, LLC, at Id.

33 Consolidated Answer of American Airlines, Inc. Page 28 of 30 substantial portion of the country from the benefits of the requested frequencies, because Dynamic does not serve behind-gateway traffic. Dynamic s proposal is also not viable. First, despite having issued an order granting Dynamic scheduled air-transportation authority, the Department has not made this authority effective. 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. And fourth, given current OFAC restrictions on passengers, the large size of Dynamic s equipment, and Dynamic s 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. Application Eastern Air Lines Group, Inc. 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 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

34 Consolidated Answer of American Airlines, Inc. Page 29 of 30 frequencies. 30 And it does not possess adequate economic authority to use the frequencies. Any grant of exemption authority by the Department cannot cure Eastern s lack of FAA authority. Eastern also does not appear able to perform the basic task of issuing a ticket and accepting payment via its website. And as a charter carrier, Eastern likely lacks the reservations and customer-service team necessary to handle scheduled passenger traffic. Eastern does not need its requested MIA-HAV frequencies to continue serving this route via charter flights, and until Eastern cures these deficiencies, it should not receive consideration for one of the limited frequencies to HAV available in this proceeding. L. Application of Silver Airways Corp. Silver s 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, American s 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 President s legacy. 30 Application of Eastern Airlines Group, Inc., at 4 5.

35 Consolidated Answer of American Airlines, Inc. Page 30 of 30 For the reasons stated above, American respectfully requests that the Department of Transportation grant its application to operate 22 scheduled frequencies between the United States and Cuba. Respectfully submitted, Howard Kass Vice President Regulatory Affairs Robert A. Wirick Managing Director Regulatory and International Affairs John B. Williams Senior Analyst Regulatory and International Affairs AMERICAN AIRLINES, INC th Street, NW Washington, D.C (202) March 14, 2016 Paul T. Denis Steven G. Bradbury William B. Sohn DECHERT LLP 1900 K Street NW Washington, D.C (202) paul.denis@dechert.com steven.bradbury@dechert.com william.sohn@dechert.com Charles A. Hunnicutt Brent Connor THOMPSON HINE LLP 1919 M Street NW, Suite 700 Washington, D.C (202) charles.hunnicutt@thompsonhine.com brent.connor@thompsonhine.com

36 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 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) englets@state.gov (Dept. of State) cristinasa@state.gov (Dept. of State) sami.teittinen@silverairways.com (Silver) bryan.winters@silverairways.com (Silver) john@mietuslaw.com (Counsel for Eastern) chris.walker@delta.com (Delta) alex.krulic@delta.com (Delta) bob.kneisley@wnco.com (Southwest) leslie.abbott@wnco.com (Southwest) howard.diamond@flyfrontier.com (Frontier) foont@foontlaw.com (Counsel for Frontier) cefelts@fedex.com (FedEx) nssparks@fedex.com (FedEx) jackerman@dfwairport.com (DFW) bdcagle@cltairport.com (CLT) dflint@lawa.org (LAWA) kpyatt@miami-airport.com (MIA) rbtrinder@zsrlaw.com (IAH) jasilversmith@zsrlaw.com (IAH) mgoldman@sgbdc.com info@airlineinfo.com John B. Williams

37 Testimony

38 Testimony of American Airlines Testimony AA-R-T-1 Testimony of Tessie Aral List of Testimony

39 ABC Charters TM A Better Choice Travel 1125 SW 87 AVE MIAMI FL Tel: (305) Fax: (305) Toll Free: (866) 4ABC - AIR Testimony of Tessie Aral President ABC Charters, Inc. March 14, 2016 My name is Maria T Aral, and I am the President of ABC Charters, Inc. ABC Charters holds a General License from the Office of Foreign Assets Control ( OFAC ) to provide charter air service between the United States and Cuba, and has provided regular U.S.-Cuba charter service since ABC Charters currently provides more than 800 annual flights to Cuba, the overwhelming number of which originate at Miami International Airport ( MIA ) and are operated by American Airlines, Inc. ( American ). We also provide charter flights operated by other airlines as well. I ve worked with American for many years, and my testimony will focus on the need for extensive U.S.-Cuba scheduled frequencies from MIA, as American proposes. Cuba is unique among international destinations due to the current restrictions on U.S.- Cuba travel. In general there are three types of international travelers: (1) leisure travelers; (2) travelers visiting family and relatives; and (3) business travelers. But U.S. law currently prohibits leisure travel to Cuba, and U.S.-Cuba trade is also limited by law, meaning that those visiting family and relatives in Cuba comprise most of the U.S.-Cuba traffic. This will not change until the existing sanctions are lifted. It follows that charter service to Cuba, and the scheduled service to come, must primarily originate at airports that can best serve the Cuban- American population. That s why ABC Charters flies to Cuba mostly from MIA, which is located in Miami- Dade County, home to nearly half the nation s Cuban-American population, and is surrounded by the largest Cuban-American communities in the United States, such as Hialeah, Homestead, and Westchester. For these Cuban Americans, MIA is just a few minutes away far closer than any other airport and is the overwhelming favorite for charter flights to Cuba. There is no other airport that can sustain anywhere near the number of U.S.-Cuba flights as MIA. In my decades of experience in the Miami market, Miami-Dade Cuban Americans generally don t travel to Fort Lauderdale-Hollywood International Airport ( FLL ) for charter flights to Cuba. FLL is much further away, and getting there typically requires paying a high toll to use the I-95 express lanes and/or dealing with heavy traffic. It s also in less familiar territory MIA is in the same neighborhood as most Miami-Dade Cuban Americans, whereas FLL is well to the north in Broward County, which has just ten percent of the Cuban-American population as Miami-Dade. FLL s distance from most Cuban Americans is particularly impractical because many traveling to Cuba bring oversized baggage (such as televisions, refrigerators, and other appliances), and are often sent off by throngs of family and friends. A BETTER CHOICE

40 It s no surprise that most of the region s 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 Havana s José Martí 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 I ve 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 hasn t happened. Instead, I ve 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. There s no reason to expect anything different when U.S.-Cuba scheduled service arrives. Scheduled service won t 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 American s 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

41 Letter of Support

42 Letter of Support of American Airlines Letter of Support Letter from Mike Fernandez List of Letters of Support

43

44

45 Rebuttal Exhibits

46 List of Rebuttal Exhibits 4 Rebuttal Exhibits of American Airlines Exhibit Number Title AA-R-101 Summary of Applicants and Proposed U.S. Gateways For Havana Service AA-R-102 U.S. Carrier Applicant Proposed Frequencies to Havana by Gateway AA-R-103 Some Threshold "Disqualifying" Issues AA-R-104 Applicants in This Proceeding Agree That the Overwhelming Source of Traffic to Havana Will Be the U.S. Cuban- American 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 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

47 List of Rebuttal Exhibits Page 2 of 14 Rebuttal Exhibits of American Airlines Exhibit Number 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 Remarks of U.S. Senator Jeff Flake on Senate Floor 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 In Addition, American's MIA-HAV Service Provides Comprehensive Domestic U.S. Coverage 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.

48 List of Rebuttal Exhibits Page 3 of 14 Rebuttal Exhibits of American Airlines Exhibit Number 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 American Airlines Is "Miami's Hometown Airline" 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

49 List of Rebuttal Exhibits Page 4 of 14 Rebuttal Exhibits of American Airlines Exhibit Number 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

50 List of Rebuttal Exhibits Page 5 of 14 Rebuttal Exhibits of American Airlines Exhibit Number 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 And Other Applicants (Non-FLL Applicants) Have Said It Isn't So: 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

51 List of Rebuttal Exhibits Page 6 of 14 Rebuttal Exhibits of American Airlines Exhibit Number 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 JetBlue's 15 FLL-HAV Connections Cannot Compare to American's 58 MIA-HAV Connections 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 American's MIA-HAV Charters Have Enjoyed Strong Load Factors 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

52 List of Rebuttal Exhibits Page 7 of 14 Rebuttal Exhibits of American Airlines Exhibit Number Title AA-R-418 JetBlue Has Been Operating Charters in the JFK-HAV Market Since 2015 But 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 MCO's Catchment Area is 3.5% the Size of MIA's 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

53 List of Rebuttal Exhibits Page 8 of 14 Rebuttal Exhibits of American Airlines Exhibit Number Title AA-R-429 TPA's Catchment Area Is 10% the Size of MIA's AA-R-430 JetBlue Would Have Only 4 Connections in Both Directions for Its TPA-HAV Service AA-R-431 TPA's Cuban-American Population (Hillsborough County) Is a Fraction of MIA's (Miami-Dade County) 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 JetBlue's Proposed EWR-HAV Service Must Be Considered an Extreme Reach by JetBlue 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 Boston's Cuban-American Population Is Small AA-R-439 JetBlue Would Have Only 1 Connection in Both Directions for Its BOS-HAV Service, and That Would Be to JFK

54 List of Rebuttal Exhibits Page 9 of 14 Rebuttal Exhibits of American Airlines Exhibit Number Title AA-R-440 BOS-HAV Is The Last of the Six JetBlue U.S. Gateway Priorities AA-R-441 Notwithstanding JetBlue's Self-Laudatory Claims, American Outshines JetBlue 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 Southwest's FLL-HAV Service Would Have Only 20 Connections in Both Directions AA-R-505 FLL's Catchment Area Is 10% the Size of MIA's 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

55 List of Rebuttal Exhibits Page 10 of 14 Rebuttal Exhibits of American Airlines Exhibit Number 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 Southwest Has No Experience in the TPA-HAV Market AA-R-512 Southwest's TPA-HAV Service Would Have Only 15 Connections in Both Directions AA-R-513 TPA's Catchment Area Is 10% the Size of MIA's 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 Southwest's MCO-HAV Service Would Provide Only 10 Connections in Both Directions AA-R-517 Southwest Has No Experience in the MCO-HAV Market AA-R-518 MCO's Catchment Area Is 3.5% the Size of MIA's AA-R-519 MCO-HAV Had Only 65 Charter Flights In 2015 AA-R-520 MCO-HAV Was Southwest's Last Priority Out of Nine Proposed HAV Services AA-R-521 Southwest's HAV Forecasts Are a Result in Search of a Justification AA-R-522 Southwest's Use of Canada MIDT Data in Its Forecast Is Just Plain Wrong

56 List of Rebuttal Exhibits Page 11 of 14 Rebuttal Exhibits of American Airlines Exhibit Number Title AA-R-523 Southwest's Forecast for Proposed FLL-VRA Service Is Filled with Flaws 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 Delta's JFK-HAV Service Would Provide Only 2 Connections in Both Directions AA-R-604 Delta's Daily JFK-HAV Request Is Excessive to Historical JFK-HAV Charter Demand AA-R-605 Delta's MIA-HAV Proposed Service Has No Basis to Operate Successfully 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 Delta's MCO-HAV Service Would Provide Only 3 Connections in Both Directions AA-R-610 MCO's Catchment Area is 3.5% the Size of MIA's AA-R-611 MCO-HAV Has Experienced Very Little Charter Activity, and Nothing Compared to MIA-HAV AA-R-612 Delta Has Operated No Charter to Havana from MCO AA-R-613 MCO-HAV Was Delta's Last Priority Among Proposed Routes 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

57 List of Rebuttal Exhibits Page 12 of 14 Rebuttal Exhibits of American Airlines Exhibit Number 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 DEN- HAV Frequency AA-R-703 Frontier Has Never Operated Charter Flights to Cuba AA-R-704 Cuban-American Population in Denver AA-R-705 Frontier Has No Meaningful Presence in MIA 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 FLL's Catchment Area Is 10% the Size of MIA's AA-R-804 Spirit Has No Cuba Experience 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 Spirit's FLL-HAV Service Would Have only 10 Connections in Both Directions AA-R-901 United's Request for a Daily EWR-HAV Service Is in Line with Its Proportionate Share of U.S.-Havana Frequencies

58 List of Rebuttal Exhibits Page 13 of 14 Rebuttal Exhibits of American Airlines Exhibit Number 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 United Has Operated No Charter Flights to Cuba Since 2013 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 So and 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 Alaska's Proposed LAX-HAV Services Would Have Only 3 Connections

59 List of Rebuttal Exhibits Page 14 of 14 Rebuttal Exhibits of American Airlines Exhibit Number 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 Sun Country Would Have a Single Connection at RSW in Both Directions 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?

60 Series 100: General Rebuttal Exhibits of American Airlines

61 Exhibit AA-R-101 Summary of Applicants and Proposed U.S. Gateways For Havana Service 13 applicants for U.S.-Cuba Frequency Allocations Total Weekly Frequencies by All Applicants Gateways to Havana 397 U.S.-Havana weekly frequencies requested 117 MIA 91 FLL 28 MCO 28 TPA 24 JFK 19 LAX 15 EWR 14 PBI 9 RSW 7 CLT 7 DFW 7 BOS 7 DEN 7 ATL 6 ORD 5 EYW 2 JAX 2 MSP 1 IAH 1 IAD

62 Exhibit AA-R-102 U.S. Carrier Applicant Proposed Frequencies to Havana by Gateway 140 Weekly Frequencies MIA FLL TPA MCO JFK EWR LAX PBI RSW CLT DFW BOS DEN ATL ORD EYW JAX MSP IAH IAD Source: Carrier Applications

63 Exhibit AA-R-103 Some Threshold Disqualifying Issues Issue Relevant Applicants Lack of current necessary authority to engage in foreign scheduled air transportation Dynamic International Airways Eastern Airlines Application based on use of small, propeller aircraft (34 seats only) for allocation of highly scarce, heavily in-demand U.S.-Havana frequencies Silver Airways Lack of ability to sell scheduled tickets No online booking portal Eastern Airlines For these reasons, American s Rebuttal Exhibits will focus on the service proposals of the other applicants in this proceeding Note: American uses disqualifying in the sense of clearly not maximizing the public benefits.

64 Applicants In This Proceeding Agree That the Overwhelming Source of Traffic to Havana Will Be the U.S. Cuban American Population Exhibit AA-R-104 Carrier Comments Southwest... [t]he distribution of Cuban American population [will be] the most likely major centers for travel from the U.S.... (Application, Page 3) JetBlue... [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) Frontier... [T]he largest population eligible to travel to Cuba are those permitted to do so to visit closer relatives there. (Application, Page 18) Silver... Cuban Americans comprise the vast majority of likely Cuba travelers. (Application, Page 9)

65 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 Exhibit AA-R-105 1,400,000 Top 10 States Cuban-American Population 1,200,000 1,213,438 1,000, ,000 Miami-Dade (MIA): 856, , , , ,607 83,362 70,803 46,541 25,048 22,541 21,459 18,079 17,930 Florida California New Jersey New York Texas Georgia Illinois Nevada North Carolina Pennsylvania Source: U.S. Census Bureau Miami-Dade County represents almost half (47.9%) of the entire U.S. Cuban-American population more than any county, city, MSA, or State (other than Florida)

66 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 Exhibit AA-R Allocation of 20 U.S.-Havana Daily Frequencies Based on Cuban-American Population at Proposed U.S. Gateway Cities MIA EWR FLL TPA LAX JFK PBI RSW MCO ORD IAH ATL IAD DFW BOS EYW JAX CLT DEN MSP 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 United s application (Exhibit UA-112).

67 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 Exhibit AA-R Total Daily Frequencies Requested by U.S. Carriers at Each Proposed U.S. Gateway Allocation of Available 20 U.S.-Havana Daily Frequencies Based on Cuban-American Population MIA EWR FLL TPA LAX JFK PBI RSW MCO ORD IAH ATL IAD DFW BOS EYW JAX CLT DEN MSP 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 United s application (Exhibit UA-112).

68 FLL Has the Largest Difference Between Its Proportionate Share of U.S.-Havana Frequencies and the Number of U.S.-Havana Frequencies Requested Exhibit AA-R-108 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 (11.8) MCO (3.7) TPA (3.1) MIA (2.8) JFK (2.3) LAX (1.4) PBI (1.4) DEN (1.0) EWR (0.9) RSW (0.9) CLT (0.9) DFW (0.8) BOS (0.8) ATL (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 United s application (Exhibit UA-112).

69 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 Exhibit AA-R-109 U.S. Gateway Allocation of Available 20 U.S. -Havana Daily Frequencies Based on Cuban-American Population (1) Total Daily Frequencies Requested by U.S. Carriers at Each Proposed U.S. Gateway (2) % 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% 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 United s application (Exhibit UA-112).

70 Data 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% Exhibit AA-R-110 5,000 4,500 4,000 4, Charter Flights to Cuba From U.S. Gateways Proposed in This Proceeding By All Carriers (Including Non-Applicants) MIA: Almost 13x larger than next largest U.S. gateway to Cuba 3,500 3,000 2,500 2,000 1,500 1, MIA TPA EYW JFK FLL MCO RSW LAX BOS MSP ATL CLT DFW DEN EWR IAD IAH JAX ORD PBI Source: Havanatur Cuba Charter Data (2015)

71 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 Exhibit AA-R-111 3, Charter Flights to Havana From U.S. Gateways Proposed in This Proceeding By All Carriers (Including Non-Applicants) 3,000 2,918 MIA: Almost 11x larger than next largest U.S. gateway to Cuba 2,500 2,000 1,500 1, MIA TPA EYW JFK FLL MCO RSW LAX BOS MSP ATL CLT DFW DEN EWR IAD IAH JAX ORD PBI Source: Havanatur Cuba Charter Data (2015)

72 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 Exhibit AA-R Allocation of 20 U.S.-Havana Daily Frequencies Based On Charters Flown in U.S.-Havana Markets in MIA TPA EYW JFK FLL MCO RSW LAX BOS ATL MSP EWR PBI CLT DFW DEN ORD JAX IAD IAH Source: Havanatur charter data (2015) Note: 1/ Daily frequencies per % of 2015 charter flights operated were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of 2015 charter flights in each proposed U.S. gateways. 2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).

73 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 Exhibit AA-R Total Daily Frequencies Requested by U.S. Carriers at Each Proposed U.S. Gateway Allocation of Available 20 U.S.-Havana Daily Frequencies Based on 2015 U.S.-HAV Charter Operation s MIA TPA EYW JFK FLL MCO RSW LAX BOS ATL MSP EWR PBI CLT DFW DEN ORD JAX IAD IAH Source: Havanatur charter data (2015) Note: 1/ Daily frequencies per % of 2015 charter flights operated were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of 2015 charter flights in each proposed U.S. gateways. 2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).

74 Several Applicants Did Not Build Realistic Connections to Their Proposed U.S.-Havana Services Exhibit AA-R-114 Problems revealed by Direct Exhibits General: 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) Connections at proposed U.S. Gateways: Showed insufficient connect times Included one way connects, instead of just connects in both directions (American displayed and enumerated connects only in both directions) Displayed connecting flights beyond the customary four-hour maximum connect window (American eliminated from its list of all connections beyond 4 hours) Did not exclude cities for which circuity was in excess of 155%

75 Several Applicants Included Connecting Flights with Maximum Connection Times Exceeding Four Hours Northbound HAV-XXX Connections Airline Route Minimum Connection Time (minutes) Max Connection Time (minutes) American MIA-HAV American CLT-HAV American DFW-HAV American ORD-HAV American LAX-HAV Alaska HAV-LAX 120 Not included JetBlue HAV-FLL JetBlue HAV-JFK JetBlue HAV-MCO JetBlue HAV-TPA JetBlue HAV-BOS Delta HAV-JFK Delta HAV-ATL Delta HAV-MIA Delta HAV-MCO Frontier HAV-MIA 90 Not included Frontier HAV-DEN 105 Not included Spirit HAV-FLL Not included Not included Sun Country HAV-DEN Not included Not included Sun Country HAV-RSW Not included Not included United HAV-EWR United HAV-IAH United HAV-IAD United HAV-ORD Southwest HAV-FLL Southwest HAV-TPA Southwest HAV-MCO Note: Frontier (F9) only included schedule data for through flights; a full schedule of connecting flights was not provided. Source: Airline Applications Exhibit AA-R-115 Page 1 of 2

76 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 Southbound XXX-HAV Connections Airline Route Minimum Connection Time (minutes) Max Connection Time (minutes) American MIA-HAV American CLT-HAV American DFW-HAV American ORD-HAV American LAX-HAV Alaska LAX-HAV 60 Not included JetBlue FLL-HAV JetBlue JFK-HAV JetBlue MCO-HAV JetBlue TPA-HAV JetBlue BOS-HAV Delta JFK-HAV Delta ATL-HAV Delta MIA-HAV Delta MCO-HAV Frontier MIA-HAV Not included Not included Frontier DEN-HAV Not Included Not included Spirit FLL-HAV Not included Not included Sun Country DEN-HAV Not included Not included Sun Country RSW-HAV Not included Not included United EWR-HAV United IAH-HAV United IAD-HAV United ORD-HAV Southwest FLL-HAV Southwest TPA-HAV Southwest MCO-HAV Note: Frontier (F9) only included schedule data for through flights; a full schedule of connecting flights was not provided. Source: Airline Applications Exhibit AA-R-115 Page 2 of 2

77 Adjusting the Applicants Claimed Connections for the Same Connections Methodology Used by American Shows: Exhibit AA-R-116 Market Analysis on an Apples to Apples Comparison For Proposed Daily (or More) Services Airline Route Proposed Frequencies Stated Connections Connections (Both Ways) Delta ATL-HAV 7x American CLT-HAV 7x American MIA-HAV 70x American DFW-HAV 7x United EWR-HAV 8x Southwest FLL-HAV 42x JetBlue FLL-HAV 28x N/A 15 Southwest TPA-HAV 14x Spirit FLL-HAV 14x Southwest MCO-HAV 7x JetBlue JFK-HAV 14x N/A 6 JetBlue MCO-HAV 14x N/A 5 Silver FLL-HAV 7x N/A 4 JetBlue TPA-HAV 14x N/A 4 Alaska LAX-HAV 14x 4 3 Delta MCO-HAV 7x 11 3 Delta JFK-HAV 7x 19 2 Delta MIA-HAV 14x 10 2 JetBlue BOS-HAV 7x N/A 1 Frontier DEN-HAV 7x N/A 1 Frontier MIA-HAV 21x N/A 1 JetBlue EWR-HAV 7x N/A 0 Sun Country RSW-HAV 7x N/A 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.

78 Series 200: American Airlines Request for U.S.-Havana Frequencies

79 Exhibit AA-R-201 Remarks of U.S. Senator Jeff Flake on Senate Floor Excerpt of Remarks of U.S. Senator Jeff Flake (R-AZ) March 10, 2016 While I ardently support everyone s 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. Note: Emphasis added.

80 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 Exhibit AA-R-202 Cuban-American Population Miami-Dade County versus Total U.S. Charter Flights to Havana by U.S. Origin ,785,547 FLL 2.0% EYW 2.5% TPA 7.6% JFK MCO 2.0% 1.9% Other 0.9% 856,007 MIA 83.3% Total U.S. Miami-Dade County (MIA) Total flights to Havana: 3,505 Note: Other includes: RSW, SJU, BWI, LAX, MSP, ATL, MSY, and BOS. Source: Havanatur 2015 charter data; American Airlines; U.S. Census data (2010)

81 American s MIA-HAV Request Is Less Than MIA s Proportionate Share of U.S.-Havana Frequency Allocations Exhibit AA-R-203 American s Proposed MIA-HAV Daily Frequencies Are Less Than MIA s Proportionate Share of Cuban-American Population Daily Frequencies per % of Cuban-American Population American's Request for MIA-HAV Frequencies 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 United s application (Exhibit UA-112).

82 In Addition, American s MIA-HAV Service Provides Comprehensive Domestic U.S. Coverage American s MIA-HAV Connections Cover the Entire U.S. 58 connections in both directions (50 Domestic U.S. connections) Exhibit AA-R-204

83 American s Request for 10 Miami-Havana Frequencies Only Matches Actually Under-Requests Existing Charter Demand Exhibit AA-R-205 MIA-HAV Daily Frequencies versus American s Request 2015 MIA-HAV Charter Flights Operated by Gateway ,500 3,000 2,500 2,000 2,922 MIA was the origin of 84% of U.S.-HAV charter flights = 16.7% of 20 U.S.-Havana daily frequencies available 4 1, * 2017* AA MIA-HAV Request 1, MIA TPA JFK FLL MCO RSW LAX ATL BOS MSP 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)

84 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. CLT and MIA Connections 68 CLT connections in both directions +34 unique CLT connections added to MIA Exhibit AA-R-206

85 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 DFW, CLT, and MIA Connections 52 DFW connections in both directions +37 unique DFW connections added to CLT and MIA Exhibit AA-R-207

86 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 Exhibit AA-R-208 American s proposed once weekly ORD frequency to Havana versus weekly frequencies as per % share of Cuban-American Population... and American could provide efficient onestop connections every day of the week to ORD passengers through MIA, CLT and DFW x weekly x weekly Weekly Frequencies per % of Cuban-American Population 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.

87 American s Request for Once Weekly Service from LAX Is Consistent with Existing and Anticipated LAX-HAV Demand Exhibit AA-R-209 American s Proposed LAX-HAV daily frequencies to Havana versus daily frequencies as per % share of Cuban- American Population... and American could provide efficient one-stop connections every day of the week through MIA, CLT and DFW to meet additional demand Daily Frequencies per % of Cuban-American Population American's LAX-HAV Request

88 American Airlines Is Miami s Hometown Airline Exhibit AA-R-210 Page 1 of 2 American is the largest carrier at Miami International Airport, operating on average more than 9,800 departures per month 74% of all departures to more than 120 destinations in the U.S., Canada, Caribbean, Central America, Europe, Mexico, and South America In 2015, American carried 26.8 million passengers through MIA, more than 10x the next largest airline American is the third largest private employer in Miami-Dade County, employing more than 11,000 people MIA offers more flights to the Caribbean and Latin America than any other U.S. airport and is the port of entry for 70% of all international visitors to Florida Sources: American Airlines, Miami International Airport, Miami-Dade County Beacon Council

89 American Airlines Is Miami s Hometown Airline American s Community Involvement Exhibit AA-R-210 Page 2 of 2

90 American Serves More Than 3x the Number of Domestic U.S. Destinations from MIA Than the Other Three Applicants for MIA-HAV Services Combined Exhibit AA-R-211 Domestic Destinations Served June American Delta Frontier Eastern 0 Source: OAG schedule data accessed March 3, 2016 for June 2016

91 American s Domestic Service Share at MIA Far Outstrips the Share of the Other Three MIA-HAV Applicants Combined Domestic Destinations Served June 2016 Frontier 8.6% Eastern 0.0% Delta 14.3% American 77.1% Source: OAG schedule data accessed March 3, 2016 for June 2016 Exhibit AA-R-212

92 American Operates Almost 6x as Many Domestic Departures at MIA as the Other Three MIA-HAV Applicants Combined Exhibit AA-R-213 Domestic Total Departures June ,000 5,601 5,000 4,000 3,000 2,000 1, American Delta Frontier Eastern Source: OAG schedule data accessed March 3, 2016 for June 2016

93 Of All the MIA-HAV Applicants, American Accounts for 85% of All the MIA Domestic Departures Domestic Total Departures June 2016 Frontier 2.3% Delta 12.6% American 85.1% Source: OAG schedule data accessed March 3, 2016 for June 2016 Eastern 0.0% Exhibit AA-R-214

94 American Flies More Than 83% of the Domestic Seats at MIA More Than All of the Other MIA-HAV Applicants Combined Domestic Departing Seats June 2016 Delta 13.8% Frontier 2.8% Eastern 0.0% American 83.5% Source: OAG schedule data accessed March 3, 2016 for June 2016 Exhibit AA-R-215

95 American Flies More Than 5x the Number of Domestic Seats from MIA as the Other Three MIA-HAV Applicants Combined Exhibit AA-R-216 Domestic Departing Seats June , , , , , , , , , ,650 24,592 0 American Delta Frontier Eastern Source: OAG schedule data accessed March 3, 2016 for June 2016

96 American Flew More Than Five Times the Number of Domestic Passengers at MIA Than the Three Other MIA-HAV Applicants Combined Exhibit AA-R-217 Domestic Passengers Year End November ,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 2,000, ,481, ,301 0 American Delta Frontier Eastern Source: U.S. DOT T-100

97 Of All the MIA-HAV Applicants, American Accounted for 84.5% of All MIA Domestic Passengers Domestic Passengers Year End November 2015 Delta 12.4% Frontier 3.0% Eastern 0.0% American 84.5% Source: U.S. DOT T-100 Exhibit AA-R-218

98 American Has the Longest and Deepest Experience in U.S.-Cuba Flights and Operational Know-How in the Unique Cuba Market Exhibit AA-R years of continuous service almost twice as long as next U.S. airline more years than Delta, Southwest, Frontier, Alaska, and Sun Country combined More charter flights than any other applicant U.S.-Havana Charter Flights American Sun Country Eastern JetBlue jetblue Delta Southwest Silver Frontier Alaska Spirit United Dynamic FedEx Extensive knowledge of unique passenger processing requirements mandated by OFAC regulations Long-standing appreciation of challenges of doing business at Cuba s airports and dealing with the airport and government aviation officials All allowing American to inaugurate scheduled service on day one without any learning curve or hiccups, but with an unequalled ability to deliver quality performance and to maximize the public U.S. benefits of new U.S. service to Cuba

99 The Importance of Knowing the Unique Cuba Aviation Structure Was Highlighted on the Floor of the U.S. Senate Exhibit AA-R-220 Excerpt of Remarks of U.S. Senator Jeff Flake (R-AZ) March 10, 2016 [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 task those with experience.

100 Series 300: Exhibits of American Airlines with Respect to the U.S. Gateways Proposed by Applicants in This Proceeding

101 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 Exhibit AA-R Total Daily Frequencies Requested by U.S. Carriers at Each Proposed U.S. Gateway Allocation of Available 20 U.S.-Havana Daily Frequencies Based on Cuban-American Population MIA EWR FLL TPA LAX JFK PBI RSW MCO ORD IAH ATL IAD DFW BOS EYW JAX CLT DEN MSP 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 United s Application (Exhibit UA-112).

102 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 Exhibit AA-R-302 Proposed Daily Frequencies to Havana vs. Daily Frequencies as per Proportionate Share of Cuban-American Population American under-requests MIA-HAV frequencies by 20% Total Daily MIA-HAV Frequencies Requested by All Applicants Daily MIA-HAV Frequencies per % of Cuban-American Population American's Request for MIA- HAV Frequencies 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 United s Application (Exhibit UA-112).

103 In Contrast to American s MIA-HAV Frequency Request, JetBlue s Requests for U.S.-HAV Frequencies Are Excessive to Current and Anticipated Demand from JetBlue s Requested U.S. Gateways In Rebuttal to Exhibit B 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 United s Application (Exhibit UA-112). Exhibit AA-R-303 Proposed Daily Frequencies to Havana vs. Daily Frequencies as per Proportionate Share of Cuban-American Population FLL Total B6 Space between red line and top of B6 bar represents B6 s excess ask over proportionate share of U.S.- HAV frequency allocation 2.0 TPA Total B MCO Total B6 Total Frequencies Proposed JFK Total B6 JetBlue (B6) Requests Daily Frequencies per Cuban-American Population Share EWR Total B BOS Total B6

104 In Contrast to American s MIA-HAV Frequency Request, Southwest s Requests for U.S.-HAV Frequencies Are Excessive to Current and Anticipated Demand from Southwest s Requested U.S. Gateways In Rebuttal to Southwest Application at page 2 Exhibit AA-R-304 Page 4 of 4 Proposed Daily Frequencies to Havana vs. Daily Frequencies as per Proportionate Share of Cuban-American Population Total Frequencies Proposed Southwest (WN) Requests Daily Frequencies per Cuban-American Population Share FLL Total WN 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 the allocation described in United s Application (Exhibit UA-112). 2.0 TPA Total WN MCO Total WN

105 In Contrast to American s MIA-HAV Frequency Request, Alaska s Requests for U.S.-HAV Frequencies Are Excessive to Current and Anticipated Demand from Alaska s Requested U.S. Gateway In Rebuttal to Alaska Application at page Exhibit AA-R-305 Proposed Daily Frequencies to Havana vs. Daily Frequencies as per Proportionate Share of Cuban-American Population Total Frequencies Proposed Alaska s (AS) Request 2.5 Daily Frequencies per Cuban-American Population Share 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 United s Application (Exhibit UA-112).

106 In Contrast to American s MIA-HAV Frequency Request, Spirit s Requests for U.S.-HAV Frequencies Are Excessive to Current and Anticipated Demand from Spirit s Requested U.S. Gateway In Rebuttal Spirit Application at page Exhibit AA-R-306 Proposed Daily Frequencies to Havana vs. Daily Frequencies as per Proportionate Share of Cuban-American Population Total Frequencies Proposed Spirit (NK) Request Daily Frequencies per Cuban-American Population Share 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 United s Application (Exhibit UA-112). 2.0 FLL Total NK

107 There Is More Cuban-American Population per Requested HAV Frequency at MIA Than Any Other Requested U.S. Gateway Exhibit AA-R-307 9,000 8,000 8,152 Cuban-American Population per Proposed Weekly Frequencies to Havana (The Higher the Cuban-American Population per Proposed Weekly Frequencies at Each Gateway, the Greater the Need for More Frequencies) 7,000 6,000 5,675 5,000 4,000 3,000 3,313 3,074 2,778 2,521 2,338 2,280 2,000 1,000 1,621 1,582 1, MIA EWR LAX PBI RSW ATL TPA JFK DFW BOS CLT FLL MCO DEN 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 United s application (Exhibit UA-112).

108 There Is More Cuban-American Population per Requested HAV Frequency at MIA Than Any Other Requested Florida Gateway Exhibit AA-R-308 9,000 8,000 Cuban-American Population per Proposed Weekly Frequencies to Havana (The Higher the Cuban-American Population per Proposed Weekly Frequencies at Each Gateway, 8,152 the Greater the Need for More Frequencies) 7,000 6,000 5,000 4,000 3,000 3,074 2,778 2,338 2,000 1, MIA PBI RSW TPA 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 United s application (Exhibit UA-112).

109 Service to MCO Ranked No Higher Than 5th in Any Applicant s Prioritization of Havana Routes Three Airlines Applied for MCO Service Exhibit AA-R-309 In Rebuttal to Delta Application at page 2, JetBlue Application at page 29, Southwest Application at page 16 Delta JetBlue Southwest MCO was last on Delta s prioritization list Two other U.S. gateways prioritized before MCO on JetBlue s list MCO was last on Southwest s prioritization list last of nine priorities 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)

110 Service to TPA Ranked No Higher Than 6th In Any Applicant s Prioritization of Havana Routes In Rebuttal to JetBlue Application at page 29 and Southwest Application at page 16 Exhibit AA-R-310 Only Two Airlines Applied for TPA Service JetBlue Southwest 5 other HAV routes prioritized before TPA 6 FLL-HAV prioritized before TPA-HAV 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)

111 The FLL Applicants Attempt to Claim MIA s and Miami-Dade County s 856,007 Cuban-Americans as Their Own Is Patently False In Rebuttal to JetBlue Application, Southwest Application, and Spirit Application Exhibit AA-R-311 The FLL Applicants Attempt to Enlarge Their Small Traffic Base Should Be Rejected Out of Hand The FLL Applicants Gloss Over Attempts The Reality Number of Citations in the Applications The Gloss Over Language # of Usages South Florida 27 Ft. Lauderdale/Miami 12 MIA is Miami-Dade County s home airport (AA-609) MIA is the home airport to Miami-Dade County s Cuban-American population (AA-607, AA-608, AA-609, AA-610 ) Miami-Dade County s Cuban-American population does not travel to FLL (Testimony of Tessie Aral) MIA s catchment area is 10x larger than FLL s (AA-611) The historical demand for Cuba charter flights has been in MIA, not FLL (Testimony of Tessie Aral, AA- 704, and AA-705) Source: Applications of JetBlue, Southwest and Spirit If there were demand at FLL, charters would have operated there, but only few charters have done so (Testimony of Tessie Aral )

112 Exhibit AA-R-312 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

113 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 F9 DEN SY MSP 2D AA UA ORD UA B6 UA EWR JFK IAD BOS B6 2D B6 DL AA 2D AA AS LAX AA DL ATL CLT DFW UA IAH B6 DL WN B6 WN 3M SY 3M JAX MCO TPA PBI FLL RSW MIA EYW 3M HAV 3M AA DL EA F9 FX B6 DL WN 3M B6 NK WN Exhibit AA-R-313 Page 1 of 4

114 To Cuba, Several Gateways Claim Broad U.S. Coverage, But Only 4 Carrier Gateways Can Legitimately Provide Connections to Most of the United States Exhibit AA-R-313 Page 2 of 4 Gateways Remaining After Elimination of Proposals Offering Less than Daily Service (and, Thus, Not Providing Comprehensive Coverage) B6 B6 UA EWR JFK BOS B6 DL F9 DEN AA CLT LAX AS DL ATL AA 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) DFW B6 WN B6 DL WN JAX MCO TPA PBI FLL MIA 3M HAV 3M AA DL EA F9 B6 DL WN 3M B6 NK WN

115 Several Gateways Claim Broad U.S. Coverage to Cuba, But Only 4 Carrier Gateways Can Legitimately Provide Connections to Most of the United States Exhibit AA-R-313 Page 3 of 4 Gateways Eliminated Which Would Offer 25 or Less Connections in Both Directions (and, Thus, Not Providing Comprehensive Coverage) AA CLT DL ATL AA DFW MIA AA 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) HAV

116 The Result: Only 4 Carrier/Gateways That Can Legitimately Claim Comprehensive U.S. Coverage Combinations SEA YUL SFO Carrier Hub LAX SAN LAS PHX # of Connections in Both Directions with Less Than 155% Circuity DL ATL 71 TUS SLC GJT DRO DEN COS SAF ABQ AMA ELP ROW LBB GCK ABI LRD GRI GRK AUS SAT MFE BVT MHT MSP GRB YYZ ALB ATW BDL FSD MKE BUF HPN MSN GRR EWR DTW LGA CLE ORD PIT ABE JFK LNK DSM SBN MDW CMH CAK MDT PHL OMA FWA PIA IND BMI DAY BWI CVG MHK IAD DCA SBY SPI CRW HTS CHO MCI LEX STL RIC SDF LYH PHF COU ROA ORF ICT JLN GSO SGF BNA TRI RDU EWN TYS OAJ TUL FAY XNA MEM GSP CLT CHA AVL CLT ILM OKC LIT HSV GSP ATL CAE GTR MYR AGS CHS TXK CHS JAN MGM DFW MLU SHV SAV PNS TLH JAX AEX CRP BRO IAH BPT LCH LFT BTR HOU MSY GNV MCO TPA EYW MIA AA CLT 68 AA DFW 58 AA MIA 52 Three of the Four Gateways Are American Hubs HAV Source: American Airlines, Diio June Schedules BOS PVD Exhibit AA-R-313 Page 4 of 4 BDA EUROPE LHR London Heathrow, UK CDG Paris, France MAD Madrid, Spain BCN Barcelona, Spain MXP Milan, Italy

117 Series 400: American Airlines Rebuttal Exhibits to JetBlue Airways

118 JetBlue s Request for Four Daily FLL-HAV Flights Greatly Exceeds FLL-HAV s Proportionate Share of the Total U.S.-HAV Frequency Allocation In Rebuttal to JetBlue Application at page 18 and Exhibit B6-101 Exhibit AA-R-401 FLL-HAV Daily Frequencies JetBlue FLL-HAV Request FLL-HAV Proportionate Share of U.S.- HAV Frequency Allocation 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 United s Application (Exhibit UA-112).

119 And, When Combined with the Requests of All Other FLL Applicants, the FLL-HAV Frequency Request Is Off The Charts Excessive In Rebuttal to JetBlue Application at page 18 and Exhibit B6-101 Exhibit AA-R-402 FLL-HAV Daily Frequencies All FLL-HAV Requests FLL-HAV Proportionate Share of U.S.-HAV Frequency Allocation 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 United s Application (Exhibit UA-112).

120 The Cuban-American Population of Broward County (FLL s Home) Is Miniscule Compared to Miami-Dade Country (MIA s Home) In Rebuttal to JetBlue Application at page 21 Cuban-American Population 900, , , , , , , , , ,000 83,713 0 Broward County (FLL) Miami-Dade County (MIA) Source: U.S. Census (2010) Exhibit AA-R-403

121 JetBlue Tries to Claim that MIA s Traffic and Demand Are Also FLL s, But It Just Isn t So In Rebuttal to JetBlue Application at page 21 Exhibit AA-R-404 Page 1 of 3 JetBlue s Attempts to Lump FLL and MIA Cuban-American Population, Traffic and Demand The Reality South Florida s leading low fare airport, FLL, is centrally located in a large metropolitan area encompassing Dade, Broward, and Palm Beach counties that is often called the Capital of the Americas.... The people on the ground say it isn t so: Miami International Airport has been and will continue to be the principal gateway between the U.S. and Cuba. Testimony of Alberto Ibargüen, AA Testimony T-5, p.2 Furthermore, notwithstanding its proximity to Miami International Airport (MIA), South Florida locals generally prefer flying from FLL... Most Americans who fly to Cuba today do so on charter flights originating at MIA, and MIA must remain the gateway for U.S.-Cuba travel as we transition to scheduled service. Mike Fernandez Letter of Support filed in Docket OST , March 14, 2016 Source: JetBlue Application (page 21)

122 JetBlue Tries to Claim that MIA s Traffic and Demand Are Also FLL s, But It Just Isn t So In Rebuttal to JetBlue Application at page 21 Exhibit AA-R-404 Page 2 of 3 JetBlue s Attempts to Lump FLL and MIA Cuban-American Population, Traffic and Demand The Reality South Florida s leading low fare airport, FLL, is centrally located in a large metropolitan area encompassing Dade, Broward, and Palm Beach counties that is often called the Capital of the Americas.... The historical demand demonstrates it isn t so: 69 FLL-HAV charter flights in ,918 MIA-HAV charter flights in 2015 Furthermore, notwithstanding its proximity to Miami International Airport (MIA), South Florida locals generally prefer flying from FLL... Source: JetBlue Application (page 21)

123 JetBlue Tries to Claim that MIA s Traffic and Demand Are Also FLL s, But It Just Isn t So In Rebuttal to JetBlue Application at page 21 Exhibit AA-R-404 Page 3 of 3 JetBlue s Attempts to Lump FLL and MIA Cuban-American Population, Traffic and Demand The Reality South Florida s leading low fare airport, FLL, is centrally located in a large metropolitan area encompassing Dade, Broward, and Palm Beach counties that is often called the Capital of the Americas.... And JetBlue s experience shows it isn t so: JetBlue operated only a single weekly FLL- HAV 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. Furthermore, notwithstanding its proximity to Miami International Airport (MIA), South Florida locals generally prefer flying from FLL... Source: JetBlue Application (page 21)

124 And Other Applicants (Non-FLL Applicants) Have Said It Isn t So: In Rebuttal to JetBlue Application at page 21 Exhibit AA-R-405 Delta: Frontier: The Miami [-Dade County] area has the highest concentration of Cuban Americans in the U.S., with over 50% of the population. (Application, Page 4)... Fort Lauderdale and Miami are not perfect substitutes,... (Application, Page 5) Miami is the preferred international airport for South Florida (DL Exhibit DL-405)... 55% of the total Cuban American population live in Miami-Dade Country, where Miami International Airport is located. Offering service where the population that is likely to desire it lives will ensure the most successful operation and best use of the limited frequencies authorized in the MOU, in particular to Havana. * * * *... [t]he population of Cuban Americans living in Miami-Dade County is over ten (10) times higher than even the Cuban American population in the county with the second largest population, its neighbor, Broward County. (citation omitted) This makes Miami International Airport the most important airport for award and utilization of the frequencies to Cuba... (Application, Page 6)

125 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 In Rebuttal to JetBlue Application at page 21 Exhibit AA-R-406 Airport Catchment Estimates 900, , , , , , , , , ,000 85,000 0 FLL MIA FLL = 10% of MIA Source: Excerpts from Silver Airways Direct Exhibits (3M-11)

126 Historical Data Proves That MIA-HAV Demand Far Outstrips FLL-HAV Demand In Rebuttal to JetBlue Application at page 21 3, Charter Flights 2,918 2,500 2,000 1,500 1, FLL-HAV MIA-HAV Source: Havanatur charter data Exhibit AA-R-407

127 JetBlue s Havana Arriving Flights Involve a Change of Terminals at FLL and Either a Walk Outside Between Terminals or a Connector Bus In Rebuttal to Exhibit B6-102 JetBlue Fort Lauderdale-Hollywood International Airport JetBlue Domestic/ International Departures Here Source: JetBlue / Fort Lauderdale-Hollywood International Airport JetBlue s HAV-FLL Arrivals Here Exhibit AA-R-408

128 While American s Havana Arriving Flights Are All Under One Roof In Rebuttal to Exhibit B6-102 American - Miami International Airport Exhibit AA-R-409 Source: American Airlines

129 JetBlue s FLL-HAV Will Have Only a Small Number of Connections to HAV in Both Directions In Rebuttal to Exhibit B6-103 Despite Touting Its FLL Prowess and Presence, When All Is Said and Done, JetBlue Will Have Only 15 Connections in Both Directions for Its FLL-HAV Services Exhibit AA-R-410 BOS SFO DTW PIT BWI SWF EWR JFK DCA LGA LAS LAX SAN CHS JAX FLL 15 Connections in Both Directions HAV 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%.

130 JetBlue s 15 FLL-HAV Connections Cannot Compare to American s 58 MIA-HAV Connections In Rebuttal to Exhibit B6-103 SEA American Airlines MIA-HAV Service Will Connect to 58 Cities in Both Directions YUL MSP YYZ SFO LAS SLC DEN MCI STL ORD IND DTW CVG SDF BNA CMH CLE GSO PIT BWI LGA EWR PHL IAD DCA RIC RDU JFK ORF LAX MEM CLT SAN PHX ATL BHM CHS DFW PNS TLH JAX AUS MSY IAH SAT GNV MCO TPA MIA EYW 58 Connections in Both Directions HAV Notes: (1) Schedules as of Feb. 12, 2016 as filed Jun. 16, 2016 sample date; (2) Only daily service considered; (3) Maximum connect time: 4 hours; (4) Minimum connect time: international to domestic is 1 hour 30 minutes and domestic to international is 60 minutes Source: American Airlines BDL BOS Exhibit AA-R-411 BDA EUROPE LHR London Heathrow, UK CDG Paris, France MAD Madrid, Spain BCN Barcelona, Spain MXP Milan, Italy

131 JetBlue s FLL-HAV Charter Experience Is Not Comparable or Even Close to American s MIA-HAV Charter Experience In Rebuttal to Exhibit B ,000 FLL-HAV JetBlue vs. MIA-HAV American January 2014 February 2016 Passengers Flown Exhibit AA-R ,000 14,000 B6 FLL-HAV 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 Jul 2015 Oct 2015 Jan 2016 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

132 JetBlue s FLL-HAV Charters Have Experienced Load Factors That Have Been, Well, Let Us Just Say, Challenging In Rebuttal to Exhibit B6-101 JetBlue FLL-HAV Load Factor % 90% 80% 70% 60% 50% 54.4% 47.7% 46.8% 40% 30% 20% 10% 0% Jan - Feb 2016 Source: JetBlue Exhibit B6-101 Adjusted Exhibit AA-R-413 While

133 American s MIA-HAV Charters Have Enjoyed Strong Load Factors In Rebuttal to Exhibit B6-101 American Airlines MIA-HAV Load Factor 2014 February 29, % 90% 80% 82.8% 75.8% 76.3% 70% 60% 50% 40% 30% 20% 10% 0% Jan - Feb 2016 Source: American Airlines Exhibit AA-R-414

134 As Demonstrated, JetBlue s FLL-HAV Charters Load Factors Cannot Compare to American s MIA-HAV Charters Load Factors In Rebuttal to Exhibit B6-102 Exhibit AA-R % 90% 80% AA LF Better By: +59% and LF Points 75.8% 76.3% AA LF Better By: +40% and LF Points 82.8% AA LF Better By: +77% and LF Points 70% 60% 54.4% 50% 47.7% 46.8% 40% 30% 20% 10% 0% JetBlue American FLL-HAV MIA-HAV 2014 JetBlue FLL-HAV 2015 American MIA-HAV JetBlue American FLL-HAV MIA-HAV 2016 (Jan-Feb) Source: American Airlines; Deconstruction of JetBlue Exhibit B6-101

135 JetBlue s Double Daily JFK-HAV Request Exceeds JFK-HAV s Proportionate Share of U.S.-Cuba Frequency Allocation In Rebuttal to Exhibit B JFK-HAV Daily Frequencies Exhibit AA-R JetBlue Double Daily Request JFK- HAV JFK-HAV Proportionate Share of U.S.-HAV Frequency Allocation Delta Single Daily Request JFK-HAV 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 United s Application (Exhibit UA-112).

136 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 In Rebuttal to Exhibit B JFK-HAV Daily Frequencies Exhibit AA-R JetBlue JFK-HAV Requests + Delta JFK-HAV Proportionate Share of U.S.-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 United s Application (Exhibit UA-112).

137 JetBlue Has Been Operating Charters in the JFK-HAV Market Since But Only Twice Weekly. If JFK-HAV Demand for a Daily or Double Daily Flight Existed, Why Hasn t JetBlue Increased the Frequency? In Rebuttal to JetBlue Application at page 30 Exhibit AA-R-418 JetBlue s Current JFK-HAV Charter Flight Schedule JetBlue s Current JFK-HAV Charter Flight Schedule S M T W T F S S M T W T F S 2 Weekly Flights 14 Weekly Flights A Seven-Fold Increase in JFK-HAV Flights (Assumes No Delta JFK-HAV Flights) Source: JetBlue Application (page 30)

138 The Reason JetBlue Has Not Increased JFK-HAV Frequencies: JetBlue s JFK-HAV Load Factors Have Been Mediocre with Only Two Weekly Flights In Rebuttal to Exhibit B % JetBlue JFK-HAV Load Factor 90% 80% 70% 67.4% 60% 53.8% 50% 40% 30% 20% 10% 0% Sources: JetBlue Application Direct Exhibit (B6-101) / American Airlines analysis Exhibit AA-R-419

139 ... So One Could Imagine What the Load Factor Would Be With a Seven-Fold Increase in Service In Rebuttal to Exhibit B6-101 Unattainable Stimulation Would Be Required to Achieve Just a 60% Load Factor Exhibit AA-R JetBlue JFK-HAV Results Load Factor: 58.5% Passengers: 8,674 Seats: 14,827 Stimulation Needed for JetBlue to Attain Just a 60% Load Factor on Double Daily JFK-HAV Service 897% Source: American Airlines analysis Note: Average seat configuration per flight assumed at 160 for current 2x weekly charter service and 200 for JFK-HAV proposed service

140 And This Would Be Without the Benefit of Significant JetBlue Connections at JFK In Rebuttal to Exhibit B6-103 SEA JetBlue s JFK-HAV Flight Would Have Only 6 Connections in Both Directions ROC BUF OAK 6 Connections in Both Directions 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% SYR HAV JFK BOS Exhibit AA-R-421

141 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 In Rebuttal to JetBlue Application at pages Exhibit AA-R , ,000 Cuban-American Population 856,007 3, Charter Flights to Havana All Carriers 2, ,000 2, ,000 2, , ,000 1, ,000 1, , ,000 47,880 0 Miami-Dade New York State 0 70 MIA-HAV JFK-HAV Source: U.S. Census (2010) / Havanatur charter data / American Airlines

142 JetBlue s Request for Double Daily MCO-HAV Service Greatly Exaggerates the Size of the MCO-HAV Market In Rebuttal to Exhibit B Daily MCO-HAV Frequencies Exhibit AA-R JetBlue MCO-HAV Request MCO-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 United saapplication (Exhibit UA-112).

143 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 In Rebuttal to Exhibit B MCO-HAV Daily Frequencies Exhibit AA-R MCO-HAV Proportionate Share of U.S.-HAV Frequency Allocation Delta MCO-HAV Reqeust Southwest MCO- HAV Request 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 United s Application (Exhibit UA-112).

144 MCO s Catchment Area Is 3.5% the Size of MIA s In Rebuttal to JetBlue Application at page 25 MCO = 3.5% of MIA Source: Excerpt from Silver Airways Direct Exhibits (3M-11) 900, , , , , , , , ,000 0 Exhibit AA-R-425 Cuban American Population 850,000 30,000 MCO MIA

145 JetBlue Would Provide Only 5 Connections in Both Directions For its MCO-HAV Flight In Rebuttal to Exhibit B Connections in Both Directions 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 LGA EWR JFK DCA HAV BOS Exhibit AA-R-426

146 JetBlue s TPA-HAV Request for Double Daily Service Over-Asks Based on the Demand in the Market In Rebuttal to Exhibit B TPA-HAV Daily Frequencies Exhibit AA-R JetBlue TPA-HAV Request TPA-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 United s Application (Exhibit UA-112).

147 When Combined with Southwest s Double Daily TPA-HAV Request, the Total TPA-HAV Frequency Request Is Grossly Oversubscribed In Rebuttal to Exhibit B TPA-HAV Daily Frequencies Exhibit AA-R JetBlue + Southwest TPA-HAV Request TPA-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 United s Application (Exhibit UA-112).

148 TPA s Catchment Area Is 10% the Size of MIA s In Rebuttal to JetBlue Application at page , , , , , , , , ,000 0 TPA = 10% of MIA Source: Silver Airways Direct Exhibits (3M-11) Exhibit AA-R-429 Cuban American Population 850,000 85,000 TPA MIA

149 JetBlue Would Have Only 4 Connections in Both Directions for Its TPA-HAV Service In Rebuttal to Exhibit B Connections in Both Directions 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 LGA EWR JFK HAV BOS Exhibit AA-R-430

150 TPA s Cuban-American Population (Hillsborough County) Is a Fraction of MIA s (Miami-Dade County) In Rebuttal to JetBlue Application at page ,000 Cuban-American Population 856, , , , , , , , ,000 65,451 0 Hillsborough County Miami-Dade County Source: U.S. Census (2010) Exhibit AA-R-431

151 TPA s Charter Flight History to Havana Demonstrates That Even a Single Daily Scheduled TPA-HAV Service Is Not Warranted In Rebuttal to JetBlue Application at page 26 Exhibit AA-R Historical Demand (as measured by 2015 charter flights) Current Demand (as measured by JetBlue s charter operation) JetBlue TPA-HAV Request Flights per Week Current Charter Flights per Week JetBlue Proposed Flights per Week Source: Havanatur charter data

152 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 In Rebuttal to JetBlue Application at page 26 and Exhibit B6-101 Step 1: Current JetBlue TPA-HAV Charter Flights per Week 2 Step 2: Seats per Week on Current TPA-HAV Charter Flights 324 Step 3: Passengers on TPA-HAV Charter Flights 230 (at 71% Load Factor) Step 4: Seats per Week on JetBlue s Proposed 2x Daily 2,268 TPA-HAV Flights Step 5: Passengers on JetBlue s Proposed 2x Daily 1,620 TPA-HAV 71% Load Factor Step 6: Stimulation Required To Attain 70% Load Factor 700% Source: American Airlines analysis Note: Average seat configuration per flight assumed at 162 for current 2x weekly charter service and for TPA-HAV proposed service. Exhibit AA-R-433

153 JetBlue s Proposed EWR-HAV Service Must Be Considered an Extreme Reach by JetBlue In Rebuttal to JetBlue Application at pages Scarce U.S.-Havana frequencies available United s proposed service + United s Hub/Connectivity JetBlue asks for JFK, too JetBlue is a non-hub carrier at EWR JetBlue provides no connectivity at EWR Next to last JetBlue gateway priority out of six U.S. gateways Exhibit AA-R-434

154 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) In Rebuttal to JetBlue Application at page Source: JetBlue Application (page 29) Exhibit AA-R-435

155 JetBlue Would Have No Connections in Both Directions for Its EWR-HAV Service In Rebuttal to Exhibit B6-103 EWR 0 Connections 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% Exhibit AA-R-436

156 JetBlue s BOS-HAV Request for a Daily Service Is, at Best, Aspirational, Not Realistic Now In Rebuttal to JetBlue Application at pages Exhibit AA-R-437 There have never been BOS-HAV public charter flights The Boston Cuban-American population is small JetBlue has very limited connectivity in both directions at BOS, given its extreme Northeast geographic location BOS-HAV is JetBlue s last priority among its six requested U.S. gateways

157 Exhibit AA-R-438 Boston s Cuban-American Population Is Small In Rebuttal to JetBlue Application at pages ,007 85,120 83,713 65,451 49,702 47,880 43,038 25,000 22,528 20,633 19,130 17,648 14,527 11,350 11,073 MIA EWR FLL TPA LAX JFK PBI RSW MCO ORD IAH ATL IAD DFW BOS Source: U.S. Census (2010)

158 JetBlue Would Have Only 1 Connection in Both Directions for Its BOS-HAV Service, and That Would Be to JFK In Rebuttal to Exhibit B Connection in Both Directions 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 JFK BOS Exhibit AA-R-439

159 BOS-HAV Is The Last of the Six JetBlue U.S. Gateway Priorities In Rebuttal to JetBlue Application at page Source: JetBlue Application (page 29) Exhibit AA-R-440

160 Exhibit AA-R-441 Notwithstanding JetBlue s Self-Laudatory Claims, American Outshines JetBlue In Rebuttal to Exhibit B American s Average Fleet Age for Cuba Service Is Younger Than JetBlue s* % American Has a Better On-Time Performance at MIA Than JetBlue does at FLL and a Much Larger Operation 76.5% % 75% 74% 74.1% % 72% % % American jetblue American - MIA JetBlue - FLL 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 ( and A319) and JetBlue (A320/321) for Cuba service.

161 JetBlue Touts Its Customer Service Advantages, But American s Advantages Are More Meaningful and Important to Cuba-Destined U.S. Passengers In Rebuttal to Exhibit B6-102 Products and Services Comparison American vs. JetBlue Exhibit AA-R-442 American JetBlue Business Class Premium Economy Cabin* Lounge(s) at MIA (AA) and FLL (B6) 3 0 Complimentary Amenities at Lounges 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 Children s play areas Personal travel assistance with your reservations Sources: Company websites * Premium cabin denotes Main Cabin Extra for American and Even More Space for JetBlue.

162 Series 500 American Airlines Rebuttal Exhibits to Southwest Airlines

163 Southwest s FLL-HAV Request for Six Daily Frequencies Vastly Exceeds FLL-HAV s Proportionate Share of the U.S.-Havana Frequency Allocation In Rebuttal to Southwest Application at page 2 Exhibit AA-R FLL-HAV Daily Frequencies Proportionate Share of FLL-HAV Frequency Allocation Southwest FLL-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 United s Application (Exhibit UA-112).

164 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 In Rebuttal to Southwest Application at page 2 16 FLL-HAV Daily Frequencies 15.0 Exhibit AA-R Proportionate Share of FLL-HAV Frequency Allocation All FLL-Applicants Requests For FLL-HAV AA's MIA-HAV Request All Applicants' MIA-HAV Passenger 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 United s Application (Exhibit UA-112).

165 Southwest s Request for Six Daily FLL-HAV Frequencies Is Far Above and Beyond Current Demand and Any Reasonable Forecast of Expected Demand In Rebuttal to Southwest Application at page 2 FLL-HAV 2015 Charter Flights vs Proposed Southwest FLL-HAV Flights Exhibit AA-R-503 4,500 4,380 4,000 3,500 3,000 2,500 2,000 1,500 1, Total FLL-HAV Charter Flights 2017 Southwest FLL-HAV Flights (6 Daily) Source: Havanatur charter data

166 Southwest s FLL-HAV Service Would Have Only 20 Connections in Both Directions In Rebuttal to Exhibit WN-102 MKE MDW CMH DEN MCI STL PHX ATL DAL MSY AUS HOU 20 Connections in Both Directions 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% PIT TPA BWI DCA RDU FLL HAV ALB ISP PVD Exhibit AA-R-504

167 FLL s Catchment Area Is 10% the Size of MIA s In Rebuttal to Exhibit WN-201 and WN-202 FLL = 10% of MIA Source: Excerpts from Silver Airways Direct Exhibits (3M-11) 900, , , , , , , , ,000 0 Exhibit AA-R-505 Airport Catchment Estimates 850,000 85,000 FLL MIA

168 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 Exhibit AA-R-506 Southwest s Historical Presence in Cuba and FLL 0 Charter Flights to Cuba 0 Charter Flights to Havana 0 Charter Flights FLL-HAV

169 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 Exhibit AA-R-507 Step 1: Charter Flights Operated in 2015 in FLL-HAV 69 Step 2: Seats on 2015 FLL-HAV Charter Flights 11,040 Step 3: Passengers on 2015 FLL-HAV Charter Flights 11,040 (assuming 100% Load Factor) Step 4: Seats on Southwest s Proposed 6 Daily FLL-HAV 766,500 Flights Step 5: Passengers on Southwest s Proposed 6 Daily 536,550 FLL-HAV 70% Load Factor Step 6: Stimulation Required To Attain 70% Load Factor 4,860% The absurdity of the result speaks for itself especially in a market as small as FLL-HAV * The required stimulation would be larger if the load factors were less than 100%.

170 Southwest s Request for Double Daily TPA-HAV Frequencies Exceeds TPA-HAV s Proportionate Share of U.S.-Havana Frequency Allocation In Rebuttal to Southwest Application at page TPA-HAV Daily Frequencies Exhibit AA-R Southwest TPA-HAV Request TPA-HAV Propotionate Share of U.S.-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 United s Application (Exhibit UA-112).

171 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 In Rebuttal to Southwest Application at page 2 Exhibit AA-R-509 TPA-HAV Daily Frequencies Southwest + JetBlue TPA-HAV Request TPA-HAV Propotionate Share of U.S.-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 United s Application (Exhibit UA-112).

172 Southwest s TPA-HAV Double Daily Request Severely Exceeds Historical, Current and Expected Demand in the TPA-HAV Market In Rebuttal to Southwest Application at page 2 Exhibit AA-R Historical Demand (as measured by 2015 charter flights) Current Demand (as measured by JetBlue s charter operation) Southwest TPA-HAV Request Flights per Week Current Charter Flights per Week Southwest Proposed Flights per Week

173 Exhibit AA-R-511 Southwest Has No Experience in the TPA-HAV Market In Rebuttal to Southwest Application at page 17 Southwest s Historical Presence in Cuba and TPA 0 Charter Flights to Cuba 0 Charter Flights to Havana 0 Charter Flights TPA-HAV

174 Southwest s TPA-HAV Service Would Have Only 15 Connections in Both Directions In Rebuttal to Exhibit WN-104 MDW CMH IND MCI SDF BHM ATL HOU 15 Connections in Both Directions 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% CAK TPA BWI RDU HAV PHL BDL ISP PVD Exhibit AA-R-512

175 TPA s Catchment Area Is 10% the Size of MIA s In Rebuttal to Exhibit WN-201 and WN-202 TPA = 10% of MIA Source: Excerpts from Silver Airways Direct Exhibits (3M-11) 900, , , , , , , , ,000 0 Exhibit AA-R-513 Cuban American Population 850,000 85,000 TPA MIA

176 TPA-HAV Was Southwest s Second to Last Priority Out of Nine Proposed HAV Services In Rebuttal to Southwest Application at page Source: Southwest Application (page 16) Exhibit AA-R-514

177 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 In Rebuttal to Southwest Application at page MCO-HAV Daily Frequencies Exhibit AA-R-515 Southwest 1 3 Delta JetBlue All MCO-HAV Frequency Requests MCO-HAV Proportionate Share of U.S.-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 United s Application (Exhibit UA-112).

178 Southwest s MCO-HAV Service Would Provide Only 10 Connections in Both Directions In Rebuttal to Exhibit WN-106 MKE PIT MCI STL SDF ATL HOU MSY MCO 10 Connections in Both Directions 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% PHL HAV PVD Exhibit AA-R-516

179 Exhibit AA-R-517 Southwest Has No Experience in the MCO-HAV Market In Rebuttal to Southwest Application at page 17 Southwest s Historical Presence in Cuba and MCO 0 Charter Flights to Cuba 0 Charter Flights to Havana 0 Charter Flights MCO-HAV

180 MCO s Catchment Area Is 3.5% the Size of MIA s In Rebuttal to Exhibit WN-201 and WN-202 MCO = 3.5% of MIA Source: Excerpts from Silver Airways Direct Exhibits (3M-11) 900, , , , , , , , ,000 0 Exhibit AA-R-518 Cuban American Population 850,000 30,000 MCO MIA

181 Exhibit AA-R-519 MCO-HAV Had Only 65 Charter Flights In 2015 In Rebuttal to Exhibit WN-201 3,000 MCO-HAV vs. MIA-HAV Operated Charter Flights ,918 2,500 2,000 1,500 1, MCO-HAV Charter Flights AA Operated MIA-HAV Charter Flights MIA-HAV Charter Flights Source: Havanatur charter data / American Airlines

182 MCO-HAV Was Southwest s Last Priority Out of Nine Proposed HAV Services In Rebuttal to Southwest Application at page Source: Southwest Application (page 16) Exhibit AA-R-520

183 Exhibit AA-R-521 Southwest s HAV Forecasts Are a Result in Search of a Justification In Rebuttal to Southwest Appendix 1 Southwest claims a 60% share of the FLL and MIA markets. There is no evidence to suggest that could happen and much evidence to suggest it won t. Claiming a 60% share of MIA makes this forecast unbelievable. Southwest started with the result it wanted 85% load factor and reverse engineered the numbers to get that result. The passenger numbers in line 5 are plug numbers to reach the 85% load factor. The tell me the result you want first and I ll concoct a forecast to show that methodology requires that this forecast be discarded because it is entirely discredited.

184 Exhibit AA-R-522 Southwest s 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.

185 Exhibit AA-R-523 Southwest s Forecast for Proposed FLL-VRA Service Is Filled with Flaws In Rebuttal to Southwest Appendix 1 Southwest Forecast Passengers 1,200,000 4, Charters 1,000,000 1,026,720 1,005,327 3,500 3,505 3, ,000 2, ,000 2, ,000 1, ,000 0 FLL/MIA-VRA Total Passengers FLL/MIA-HAV Total Passengers 1, 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

186 Series 600: General Rebuttal Exhibits to Delta Air Lines

187 ATL, Like CLT and DFW, Provides Broad Coverage of the U.S.-HAV Markets Not Served by American Over MIA In Rebuttal to Delta Application at page 4, Exhibits DL-303, DL-304, and DL-305 Exhibit AA-R-601 Page 1 of 2 Delta s ATL-HAV Connections American s CLT-HAV Connections 71 Connections in Both Directions 68 Connections in Both Directions 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%.

188 ATL, Like CLT and DFW, Provides Broad Coverage of the U.S.-HAV Markets Not Served by American Over MIA In Rebuttal to Delta Application at page 4, Exhibits DL-303, DL-304, and DL-305 Exhibit AA-R-601 Page 2 of 2 Delta s ATL-HAV Connections American s DFW-HAV Connections MSP DSM SLC GRI OMA PIA BMI GJT DEN MHK SPI COS MCI DRO GCK STL COU LAS ICT JLN SGF SAF TUL ABQ AMA OKC XNA LIT PHX LBB ROW TUS TXK ELP ABI DFW MLU GRK AUS SAT LRD MFE CRP BRO BPT IAH HOU SHV AEX LCH LFT BTR MSY HAV 71 Connections in Both Directions 52 Connections in Both Directions 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%.

189 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 In Rebuttal to Delta Application at pages 2-3 and Exhibit DL Delta s JFK Request Versus All JFK Requests and All JFK/EWR Requests Delta JFK Request JFK Proportionate Share Total JFK Requests JFK/EWR Proportionate Share Note: Excludes Dynamic Exhibit AA-R JFK/EWR Frequency Requests

190 Exhibit AA-R-603 Delta s JFK-HAV Service Would Provide Only 2 Connections in Both Directions In Rebuttal to Delta Application at pages 2-3, Exhibits DL-203, DL-703, DL-704, DL-705, and DL-706 BOS JFK PHL 2 Connections in Both Directions 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%.

191 Delta s Daily JFK-HAV Request Is Excessive to Historical JFK-HAV Charter Demand In Rebuttal to Delta Application at pages 2-3 3,500 Charter Demand (Calendar Year 2015) MIA-HAV vs. JFK-HAV 3,000 2,918 2,500 2,000 1,500 1, MIA-HAV JFK-HAV Sources: Havanatur 2015 charter data / American Airlines Exhibit AA-R-604

192 Exhibit AA-R-605 Page 1 of 2 Delta s MIA-HAV Proposed Service Has No Basis to Operate Successfully In Rebuttal to Delta Application at pages 4-5, Exhibits DL-404, DL-711, DL-712, DL-713, DL-714 Delta Will Not Penetrate The Local Market Delta has no hub at MIA Delta s frequent flyer membership in Miami-Dade County is significantly smaller than American s SkyTeam does not have a significant presence at MIA Delta connects to only 2 U.S. cities in both directions versus American s 58

193 Delta s MIA-HAV Service Would Provide Only 2 Connections in Both Directions In Rebuttal to Delta Application Exhibit DL-404 LGA ATL MIA 2 Connections in Both Directions HAV 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%. Exhibit AA-R-605 Page 2 of 2

194 Delta s Other Attempt to Operate a Non-Hub International Flight at MIA Did Not Go Well or Last Long In Rebuttal to Delta Application at pages 4-5 and page 7 Exhibit AA-R-606 MIA-LHR: Inaugurated: March 2011 Terminated: April 2012 Duration: ~13 months Source: OAG Schedules

195 Exhibit AA-R-607 And Delta s Current Non-Hub International Flight at PHL Is Not Going Well In Rebuttal to Delta Application at pages 4-5 and page 7 100% Delta PHL-LHR Load Factor 90% 80% 70% 60% 50% 55% 51% 48% 40% 36% 38% 30% 20% 19% 10% 0% Apr-15 May-15 Jun-15 Jul-15 Aug-15 Sep-15 Source: U.S. DOT T-100

196 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 In Rebuttal to Exhibits DL-502 and DL-503 Exhibit AA-R MCO-HAV Daily Frequencies Proportionate Share of MCO-HAV Frequency Allocation Delta MCO-HAV Request All MCO-HAV Frequency 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 United s Application (Exhibit UA-112).

197 Exhibit AA-R-609 Delta s MCO-HAV Service Would Provide Only 3 Connections in Both Directions In Rebuttal to Delta Application at page 6 and Exhibits DL-502, DL-715, DL-716, DL-717, DL-718 SLC RDU ATL MCO 3 Connections in Both Directions HAV 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%.

198 Exhibit AA-R-610 MCO s Catchment Area Is 3.5% the Size of MIA s In Rebuttal to Delta Application at pages 5-6 and Exhibit DL-502, DL ,000 Cuban American Population 850, , , , , , , , , ,000 MCO MIA MCO = 3.5% of MIA Source: Excerpt from Silver Airways Direct Exhibits (3M-11)

199 MCO-HAV Has Experienced Very Little Charter Activity, and Nothing Compared to MIA-HAV In Rebuttal to Delta Application at page Charter Flights to Havana 3,000 2,918 2,500 2,000 1,500 1, MIA-HAV MCO-HAV Sources: Havanatur charter data / American Airlines Exhibit AA-R-611

200 Delta Has Operated No Charter to Havana from MCO In Rebuttal to Delta Application at page Charter Flights to Havana AA MIA-HAV DL MCO-HAV 0 Sources: Havanatur charter data / American Airlines Exhibit AA-R-612

201 MCO-HAV Was Delta s Last Priority Among Proposed Routes In Rebuttal to Delta Application at page 2 Source: Delta Application (page 2) Exhibit AA-R-613

202 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 In Rebuttal to Delta Exhibit DL-601, DL-602, DL-603, DL-604, and DL-605 Exhibit AA-R-614 No share methodology No base traffic data assumption No stimulation assumptions

203 Series 700: American Airlines Rebuttal Exhibits to Frontier Airlines

204 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 In Rebuttal to Frontier Application at page 8 and Exhibit A Exhibit AA-R-701 Frontier says There is no demand for DEN-HAV service No public DEN-HAV charter flights ever operated (Exhibit AA-R-703) Denver has a very tiny Cuban-American population (Exhibit AA-R-704) United and Southwest, both substantially larger at DEN than Frontier and with huge DEN connecting complexes, did not request DEN-HAV authority Source: Frontier Application (page 8)

205 DEN-HAV s Proportionate Share of U.S.-Havana Frequency Allocation Is Zero, Yet Frontier Requests a Daily DEN-HAV Frequency In Rebuttal to Frontier Application at pages 1, 7, and 8 Exhibit AA-R DEN-HAV Daily Frequencies Frontier DEN-HAV Request DEN-HAV Propotionate Share of U.S.-HAV Frequency Allocation 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 United s Application (Exhibit UA-112).

206 Exhibit AA-R-703 Frontier Has Never Operated Charter Flights to Cuba In Rebuttal to Frontier Application at page 2 Frontier s Historical Presence in Cuba 2015 By All Applicants January 1, 2014 February 29, 2016 By Frontier

207 Exhibit AA-R-704 Cuban-American Population in Denver In Rebuttal to Frontier Application at page 7 1,000,000 Cuban-American Population , , , , , , , , , , ,702 20,633 11,350 7,217 3,487 Miami-Dade (MIA) LAX ORD DFW CLT DEN Source: U.S. Census Bureau (201)

208 Exhibit AA-R-705 Frontier Has No Meaningful Presence in MIA In Rebuttal to Frontier Application at pages 6-7 and Exhibit C 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 Source: Innovata scheduled data (as of June 2016)

209 Frontier s MIA-HAV and DEN-HAV Flights Would Have Only a Single Connection in Both Directions In Rebuttal to Frontier Application at pages 6-7, Exhibit A, and Exhibit C SLC DEN MIA-HAV-MIA: 1 connection in both directions DEN-HAV-DEN: 1 connection in both directions 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%. MIA HAV Exhibit AA-R-706

210 Series 800: American Airlines Rebuttal Exhibits to Spirit Airlines

211 Spirit s Request for Two Daily FLL-HAV Frequencies Exceeds FLL s Proportionate Share of the U.S.-Havana Frequency Allocation In Rebuttal to Spirit Application at page 2 and Exhibit NK-CU-1 Exhibit AA-R FLL-HAV Daily Frequencies And 0.0 Spirit FLL-HAV Request FLL-HAV Proportionate Share of U.S.-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 United s Application (Exhibit UA-112).

212 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 In Rebuttal to Spirit Application at page 2 and Exhibit NK-CU-1 Exhibit AA-R Spirit s FLL-HAV Request Is >1.5x Greater than FLL-HAV s Proportionate Share and All FLL-HAV Applicants Requests Are 11x More Than FLL-HAV s Proportionate Share 13.0 American s MIA-HAV Request Is Less Than MIA-HAV s Proportionate Share All Applicants' FLL-HAV Requests ("FLL Applicants") FLL-HAV Proportionate Share of U.S.-HAV Frequency Allocation MIA-HAV Proportionate Share of U.S.-HAV Frequency Allocation AA Request for MIA-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 United s Application (Exhibit UA-112).

213 FLL s Catchment Area Is 10% the Size of MIA s In Rebuttal to Spirit Application at pages 2-3 and Exhibit NK-CU-1 900, , , , , , , , ,000 0 FLL = 10% of MIA Source: Excerpts from Silver Airways Direct Exhibits (3M-11) Exhibit AA-R-803 Airport Catchment Estimates 850,000 85,000 FLL MIA

214 Spirit Has No Cuba Experience In Rebuttal to Spirit Application at pages 3-4 Spirit Charter Flights to Cuba From Spirit s Inception ,500 2,000 1,500 1, Inception 2015 Source: American Airlines / Havanatur charter data / U.S. DOT T-100 2,500 2,000 1,500 1, Exhibit AA-R-804 Charter Flights to Cuba Jan 1, 2014 Feb 29, ,327 0 Spirit American

215 There Has Been Miniscule Demand for Charter Flights from FLL to HAV or Anywhere in Cuba That s Highly Probative of Future Demand In Rebuttal to Spirit Application at pages 3-4 4, Charter Flights U.S.-Cuba 4,348 3, Charter Flights MIA/FLL-HAV 4,000 3,500 2,500 3,000 2,000 2,500 2,000 1,500 1,500 1,000 1, FLL MIA Spirit Other Applicants Source: American Airlines / Havanatur charter data Exhibit AA-R-805 2,918 MIA

216 Spirit s FLL-HAV Service Would Have Only 10 Connections in Both Directions In Rebuttal to Spirit Application at pages 2-3, Exhibit NK-CU-1, and Exhibit NK-CU-5 DTW ORD BWI ATL MYR DFW MCO TPA FLL 10 Connections in Both Directions HAV 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%. LGA ACY Exhibit AA-R-806

217 Series 900: American Airlines Rebuttal Exhibits to United Airlines

218 United s Request for a Daily EWR-HAV Service Is in Line with Its Proportionate Share of U.S.-Havana Frequencies In Rebuttal to United Application at page 1, Exhibits UA-116, UA-120, and UA-130 to UA-137 Exhibit AA-R-901 United s EWR-HAV Service 7 Weekly Frequencies (Not 8) United at EWR Would Provide Modest Connectivity to 25 Connections in Both Directions Daily Frequencies per % of Cuban-American Population United's Request 25 Connections in Both Directions

219 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 In Rebuttal to United Application at page 1, Exhibit UA-116, and UA-120 Exhibit AA-R-902 All EWR-HAV Requests vs. Proportionate Share of EWR-HAV Allocation EWR-HAV Proportionate Share of U.S.-HAV Frequency Allocation All EWR-HAV Requests EWR-HAV Proportionate Share of U.S.-HAV Frequency Allocation United's Full EWR-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 United s Application (Exhibit UA-112).

220 United s EWR-HAV Service Offers Only 25 Connecting in Both Directions, Compared to 68 Provided by American at CLT, 58 at MIA and 52 at DFW In Rebuttal to Exhibits UA-116, UA-120, UA-130 to UA-137 Exhibit AA-R CLT MIA DFW EWR Source: American Airlines analysis

221 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 In Rebuttal to Exhibits UA-117 and UA-121 Exhibit AA-R-904 Saturday Monday, Tuesday, Wednesday, Thursday, Friday, and Sunday IAH EWR HAV IAH 2:50 Elapsed Time (Northbound) 2:30 Elapsed Time (Southbound) 290% Circuity 9:51 Elapsed Time (Northbound) 17:03 Elapsed Time (Southbound) HAV Note: Northbound connects to UA EWR-IAH Flight 760 departing at 20:30 with a layover of 2:17; Southbound begins with UA IAH-EWR Flight 704 arriving at 00:28 with a layover of 9:50. Source: OAG June 2016 Schedule.

222 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 In Rebuttal to Exhibits UA-118 and UA-122 Exhibit AA-R-905 Saturday Monday, Tuesday, Wednesday, Thursday, Friday, and Sunday IAD EWR IAD HAV 3:00 Elapsed Time (Northbound) 3:10 Elapsed Time (Southbound) 6:20 Elapsed Time (Northbound) 7:53 Elapsed Time (Southbound) 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.

223 United Once Weekly Request for ORD Does Not Permit ORD-Originating Travelers to Go to or Return from Havana on Any of the Other Six Days without Doubling Their Elapsed Travel Time In Rebuttal to Exhibits UA-119 and UA-123 Exhibit AA-R-906 Saturday Monday, Tuesday, Wednesday, Thursday, Friday, and Sunday ORD ORD EWR HAV 3:35 Elapsed Time (Northbound) 3:30 Elapsed Time (Southbound) 7:16 Elapsed Time (Northbound) 6:53 Elapsed Time (Southbound) 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

224 United Has Operated No Charter Flights to Cuba Since 2013 In Rebuttal to United Application at page 6 U.S.-Havana Charter Flights (2015) 1,200 1,084 1, American United 0 Source: U.S. DOT T-100 (Non-scheduled passenger flights) / American Airlines Exhibit AA-R-907

225 Series 1000: American Airlines Rebuttal Exhibits to Alaska Airlines

226 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 In Rebuttal to Exhibit AS Exhibit AA-R LAX-HAV Proportionate Share of U.S.-Havana Frequency Allocation Current LAX-HAV Charter Operated (by AA 1x weekly) Alaska Request for Double Daily LAX-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 United s Application (Exhibit UA-112).

227 American Knows the LAX-HAV Market, Currently Operates LAX-HAV Charters (at less than 50% Load Factor*) and, if There Were Sufficient Demand to Warrant Increasing Its Single Weekly Service, American Would Have Done so... and It Has Not In Rebuttal to Exhibit AS-1 80% 70% 72% Exhibit AA-R % 50% <50% 40% 30% 20% 10% 0% American's Load Factor on a Single Weekly LAX-HAV Flight AS "Forecast" Load Factor on Double Daily LAX-HAV Flight Sources: American Airlines / Alaska Airline Application (page 2) Note: Alaska s load factor is based on its forecast of annual passenger traffic of 190,000 and calculated annual seat capacity of 264,260 (181-seat B ER aircraft). * American is prevented from disclosing the exact LAX-HAV load factor by its contract with the charter operator.

228 If Once-Weekly LAX-HAV Charter Flight Currently 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? In Rebuttal to Exhibit AS-1 Exhibit AA-R-1003 The amount of stimulation required to reach just 50% load factor on a single daily flight is simply unachievable in the near-term 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, % 2x Daily <50% 116,800 1,304% 1x Daily 70.0% 81, % 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 Alaska s 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

229 Alaska s Proposed LAX-HAV Services Would Have Only 3 Connections In Rebuttal to Exhibit AS-5 ANC SEA PDX LAX 3 Connections in Both Directions HAV Exhibit AA-R-1004

230 Of the 3 Connections Alaska Has to Its LAX-HAV Flight, One SEA Actually Has Better Connect Times on American In Rebuttal to Exhibit AS-5 Alaska American Route Elapsed Time Elapsed Time Route Alaska better / (worse) than American Southbound Southbound SEA-LAX-HAV 535 min 537 min SEA-MIA-HAV + 2 min Northbound Northbound HAV-LAX-SEA 675 min 565 min HAV-DFW-SEA (110) min Total Roundtrip Elapsed Time: (108) min Source: American Airlines analysis Exhibit AA-R-1005

231 Alaska States an Estimated LAX-HAV Market Size but Without Attempting to Explain it, Source it, or Justify it In Rebuttal to Alaska Application at page 2 Passenger demand between Los Angeles and Cuba is estimated at 159,000 local passengers annually and up to 190,000 when connecting passenger are included (Alaska Application, Page 2) 180, ,000 Los Angeles Forecast Local Passengers vs. LAX Cuban-American Population 159, , , ,000 80,000 60,000 49,702 40,000 20,000 Source: U.S. Census Forecast Local Pax LAX Cuban-American Population Exhibit AA-R-1006

232 Series 1100: American Airlines Rebuttal Exhibits to Sun Country Airlines

233 Sun Country s Proposed RSW-HAV Service Would Greatly Exceed the Historical Demand for RSW-HAV In Rebuttal to Sun County Application at pages 1 and 4 Exhibit AA-R-1101 Page 1 of RSW-HAV Flights 2015 Charter versus SY Proposed Annual Chater Flights Sun Country's Proposed Annual Flights to RSW-HAV Source: Sun Country Application / Havanatur charter data

234 Sun Country s Proposed RSW-HAV Service Would Greatly Exceed the Historical Demand for RSW-HAV In Rebuttal to Sun County Application at pages 1 and 4 Exhibit AA-R-1101 Page 1 of 2 Annual Seats on RSW-HAV 16,848 = 2,753% Increase Charter Seats Seats on Sun Country Propsoed RSW- HAV Flights on Annual Basis 68 seats per flight (Swift Air) 162 seats per flight (Sun Country) Note: RSW-HAV charter flights were operated by 68-seat aircraft. Sources: Sun Country Application / Havanatur charter data

235 Sun Country Would Have a Single Connection at RSW in Both Directions In Rebuttal to Sun County Application at page 2 and Exhibit Schedule MSP RSW 1 Connection in Both Directions HAV 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. Exhibit AA-R-1102

236 Sun Country s Proposed Twice-Weekly MSP-HAV Service Would Greatly Exceed MSP-HAV s Proportionate Share of U.S.-Havana Frequency Allocation In Rebuttal to Sun County Application at page MSP-HAV Weekly Frequencies 2.0 Exhibit AA-R Sun Country's MSP-HAV Twice- Weekly Flights MSP-HAV's 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 (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 United s Application (Exhibit UA-112).

237 Sun Country s Proposed Twice-Weekly MSP-HAV Service Would Greatly Exceed Historical Demand In Rebuttal to Sun County Application at page 3 MSP-HAV Annual Frequencies Charter Flight Operated on MSP-HAV* Sun Country's Twice- Weekly MSP-HAV Service on Annual Basis * DL one off charter for Minneapolis Orchestra Exhibit AA-R-1104 To the extent there is MSP-HAV demand, it is, for now, best served by charters

238 Sun Country s MSP-HAV Service Would Have Only a Single Connection in Both Directions In Rebuttal to Sun Country Application at page 3 and Exhibit Schedule MSP SFO 1 Connection in Both Directions 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 Exhibit AA-R-1105

239 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 In Rebuttal to Sun County Application at page 3 and Exhibit Schedule Exhibit AA-R-1106 Saturday / Sunday Monday, Tuesday, Wednesday, Thursday, and Friday MSP No Flights No Connections HAV

240 Series 1200: American Airlines Rebuttal Exhibits to Federal Express