BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. Application of ABC AEROLÍNEAS, S.A. de C.V. d/b/a Interjet for a Foreign Air Carrier Permit pursuant to 49 U.S.C. 41302 and for an Exemption pursuant to 49 U.S.C. 40109 to engage in Scheduled Foreign Air Transportation of Persons, Property, and Mail (U.S./Mexico) Docket DOT-OST-2008-0191 ANSWER OF THE CITY OF HOUSTON AND THE GREATER HOUSTON PARTNERSHIP Communications with respect to this document should be sent to: Richard M. Vacar Director Robert R. Wigington Deputy Director Department of Aviation CITY OF HOUSTON 16930 John F. Kennedy Blvd. Houston, TX 77032 (281) 233-3000 (281) 233-1859 (fax) Jeff Moseley Chief Executive Officer GREATER HOUSTON PARTNERSHIP 1200 Smith Street, Suite 700 Houston, TX 77002 (713) 658-2488 (713) 844-0200 (fax) Rachel B. Trinder ZUCKERT, SCOUTT & RASENBERGER, L.L.P. 888 Seventeenth Street, N.W. Washington, DC 20006-3309 (202) 298-8660 (202) 342-0683 (fax) rbtrinder@zsrlaw.com jasilversmith@zsrlaw.com Counsel for the City of Houston and the Greater Houston Partnership Dated: July 2, 2008
BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. Application of ABC AEROLÍNEAS, S.A. de C.V. d/b/a Interjet for a Foreign Air Carrier Permit pursuant to 49 U.S.C. 41302 and for an Exemption pursuant to 49 U.S.C. 40109 to engage in Scheduled Foreign Air Transportation of Persons, Property, and Mail (U.S./Mexico) Docket DOT-OST-2008-0191 ANSWER OF THE CITY OF HOUSTON AND THE GREATER HOUSTON PARTNERSHIP The City of Houston and the Greater Houston Partnership (collectively, Houston or the Houston Parties ) respectfully submit this answer in support of the application of ABC Aerolíneas, S.A. de. C.V. ( Interjet ) for a permit and exemption authorizing it to operate Mexico-U.S. services, including services between Houston and three points in Mexico starting later this year or in 2009 (Toluca, Guadalajara, and Monterrey). The Houston Parties welcome Interjet s plans for these services, strongly support the application, and urge that it be granted promptly by the Department. Mexico is one of Houston s most significant economic and cultural partners and is, overall, Houston s largest international passenger market. Houston s flagship airport, George Bush Intercontinental ( IAH the nation s overall eighth largest international passenger gateway, according to ACI-NA data) is the #1 U.S. gateway measured by Mexican destinations served by non-stop scheduled flights, and #2 measured by U.S.-
Answer of the City of Houston and the Greater Houston Partnership Page 2 Mexico passengers. Interjet s new services would build on these important links by expanding the options available for passengers destined to and from three key destinations in Mexico. Not only would passengers from the Greater Houston area and throughout the U.S. enjoy new travel choices, but approval of the application would enable the introduction of a new low cost carrier ( LCC ) in the market, consistent with the U.S. government s ongoing efforts to liberalize and expand the opportunities available to carriers pursuant to the U.S.-Mexico air transport agreement. Trade between Houston and Mexico plays a critical role in the City s vibrant and growing economy, driving demand for additional air service. The Greater Houston Partnership s Business Houston: Gateway to Global Markets 2007 data indicates that more than 900 Houston companies trade goods and services with Mexico, and more than 100 have subsidiaries in Mexico, while at least 17 Mexican companies maintain offices in Houston. Mexico also maintains a consulate in Houston, including a special trade section. Notably, the Greater Houston area is home to the fifth-largest Hispanic population in the U.S. Forty-two percent of the population of the City of Houston is Hispanic, according to 2006 data from the Bureau of the Census. Houston s air service ties with Mexico are strong and abundant, with significant and increasing demand for passenger services and more flights than any other U.S. gateway to Mexico. More than 515 weekly flights were scheduled between Houston and Mexico in July 2008, and nearly 54 percent of all international flights from Houston are destined for Mexico; Interjet s services will build on this successful base and further strengthen Houston s Mexico air transportation network. Houston also has a booming air cargo trade relationship with Mexico, which was valued at more than $128 million in
Answer of the City of Houston and the Greater Houston Partnership Page 3 2007, with exports accounting for more than 98% of the traffic. The total cargo trade between Houston and Mexico grew 5.5% between 2006 and 2007 (based on Commerce Department data), and Mexico is Houston s largest foreign trade partner in Latin America and worldwide. At a time when many carriers are being forced to cut services due to rising fuel costs, Interjet s new service proposal is especially welcome. With access to more than 70 international and over 120 domestic destinations, and its state-of-the-art federal inspection services facilities, Houston stands ready to provide all appropriate support for the new flights. WHEREFORE, the Houston Parties urge the Department to grant the authority sought by Interjet so that it may commence services between Houston and Toluca in November 2008 and thereafter between Houston and both Guadalajara and Monterrey. Respectfully submitted, Dated: July 2, 2008 Rachel B. Trinder ZUCKERT, SCOUTT & RASENBERGER, L.L.P. 888 Seventeenth Street, N.W. Washington, DC 20006-3309 (202) 298-8660 (202) 342-0683 (fax) rbtrinder@zsrlaw.com jasilversmith@zsrlaw.com Counsel for the City of Houston and the Greater Houston Partnership
CERTIFICATE OF SERVICE I certify that on this 2nd day of July 2008, a copy of the foregoing Answer of the City of Houston and the Greater Houston Partnership was served on the parties named below in accordance with the Department s Rules of Practice: Lee A. Bauer Roller & Bauer, PLLC Counsel for ABC Aerolíneas d/b/a Interjet airlaw@rollerbauer.com Edward P. Faberman Ungaretti & Harris Counsel for AirTran Airways Counsel for Frontier Airlines Counsel for Ryan International Airlines epfaberman@uhlaw.com Marshall S. Sinick Squire, Sanders & Dempsey, LLP Counsel for Alaska Airlines msinick@ssd.com Carl B. Nelson American Airlines carl.nelson@aa.com R. Bruce Keiner, Jr. Counsel for Continental Airlines Crowell & Moring, LLP rbkeiner@crowell.com Hershel I. Kamen Dan Weiss Rebecca Cox Continental Airlines hkamen@coair.com dan.weiss@coair.com rebecca.cox@coair.com Sametta C. Barnett D. Scott Yohe J. Scott McClain Delta Air Lines sametta.klinetob@delta.com donald.s.yohe@delta.com scott.mcclain@delta.com Jonathan Hill Dow Lohnes Counsel for JetBlue Airways jhill@dowlohnes.com Brian S, Gillman Mesa Air Group brian.gillman@mesa-air.com Malcolm L. Benge Counsel for North American Airlines mlbenge@zsrlaw.com Alexander Van der Bellen Northwest Airlines sascha.vanderbellen@nwa.com Joanne W. Young Kirstein & Young, PLLC Counsel for Spirit Airlines jyoung@yklaw.com John Fredericksen Sun Country Airlines john.fredericksopn@suncountry.com Jonathan Moss Wilmer, Cutler & Pickering Counsel for United Airlines jonathan.moss@wilmerhale.com Howard Kass US Airways howard_kass@usairways.com Pierre Murphy Law Offices of Pierre Murphy Counsel for USA 3000 Airlines pmurphy@lopumrphy.com