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Consolidated Answer, Testimony, and Rebuttal Exhibits

of American Airlines in Support of


American Airlines U.S.-Cuba Scheduled Service
Docket DOT-OST-2016-0021
March 14, 2016

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: Americans 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

BEFORE THE
U.S. DEPARTMENT OF TRANSPORTATION
WASHINGTON, D.C.

____________________________________
)
Application of
)
)
AMERICAN AIRLINES, INC.
)
)
in the matter of 2016 U.S.-Cuba Frequency )
Allocation Proceeding
)
____________________________________)

Docket DOT-OST-2016-0021

CONSOLIDATED ANSWER OF AMERICAN AIRLINES, INC.


Communications with respect to this document should be addressed to:
Howard Kass
Vice President
Regulatory Affairs

Paul T. Denis
Steven G. Bradbury
William B. Sohn

Robert A. Wirick
Managing Director
Regulatory and International Affairs

DECHERT LLP
1900 K Street NW
Washington, D.C. 20006
(202) 261-3300
paul.denis@dechert.com
steven.bradbury@dechert.com
william.sohn@dechert.com

John B. Williams
Senior Analyst
Regulatory and International Affairs
AMERICAN AIRLINES, INC.
1101 17th Street, NW
Washington, D.C. 20036
(202) 326-5153
howard.kass@aa.com
robert.wirick@aa.com
john.b.williams@aa.com
March 14, 2016

Charles A. Hunnicutt
Brent Connor
THOMPSON HINE LLP
1919 M Street NW, Suite 700
Washington, D.C. 200036
(202) 331-8800
charles.hunnicutt@thompsonhine.com
brent.connor@thompsonhine.com

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.

Americans Proposed Schedule Offers the Strongest Foundation for Service


from MIA, While Providing Sufficient Frequencies for Scheduled Service to
and Through Other Connecting Hubs ............................................................................ 6

III.

IV.

V.

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 Americans Proposed Service from MIA Maximizes Public Benefits ........ 9

MIA Is Superior to FLL for Serving the Miami-Centered Cuban-American


Community in South Florida ......................................................................................... 11
A.

MIA Has Long Been the Preferred Airport for U.S.-Cuba Service ................... 12

B.

FLL is Not Convenient for Most South Florida Cuban Americans .................. 15

TPA Is the Only Other Florida Airport that Might Merit Scheduled Service
to HAV, and Its Award Should Not Exceed One Daily Frequency ............................ 17
A.

TPA Is No Carriers First, Second, or Third Choice ......................................... 18

B.

No Other Florida Airport Should Receive Scheduled Frequencies to HAV


at the Present Time .............................................................................................. 19

Americans Specific Responses to the Other Airlines Applications.......................... 20


A.

Application of JetBlue Airways Corp. ................................................................. 21

B.

Application of Southwest Airlines Co. ................................................................ 23

C.

Application of Delta Air Lines, Inc. .................................................................... 23

D.

Application of Frontier Airlines, Inc. ................................................................. 24

E.

Application of Spirit Airlines, Inc. ...................................................................... 25

F.

Application of United Airlines, Inc. .................................................................... 25

G.

Application of Alaska Airlines, Inc. .................................................................... 26

H.

Application of Sun Country Airlines ................................................................... 26

I.

Application of Federal Express Corp. ................................................................. 27

J.

Application of Dynamic International Airways, LLC ........................................ 27

K.

Application Eastern Air Lines Group, Inc. ......................................................... 28

L.

Application of Silver Airways Corp. .................................................................... 29

Conclusion ................................................................................................................................... 29

BEFORE THE
U.S. DEPARTMENT OF TRANSPORTATION
WASHINGTON, D.C.

____________________________________
)
Application of
)
)
AMERICAN AIRLINES, INC.
)
)
in the matter of 2016 U.S.-Cuba Frequency )
Allocation Proceeding
)
____________________________________)

Docket DOT-OST-2016-0021

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 Administrations policy of restoring and growing scheduled service
to Cuba over the long term.

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 Americans proposed schedule:

The largest share of scheduled frequencies to Havana (HAV) should be


allocated to Americans 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 Administrations 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 Americans

proposed schedule is the only proposal that will fully satisfy the Administrations objective
underlying this proceeding.
First, Americans proposed service lays the strongest foundation for connecting the
Miami-Dade Cuban-American community with Cuba. An allocation of frequencies based purely
on either (1) the distribution of Cuban Americans among the population centers served by the
airports for which the applicants have requested U.S.-Cuba frequencies, or (2) the originating
airports for U.S.-Cuba charter flights in 2015, supports the allocation of ten HAV frequencies to
American at MIA.

This proposed allocation still leaves ample room for frequencies for

scheduled service to and through other connecting hubs, while ensuring the needs of MiamiDade Cuban Americans are met.

Among all applicants requesting frequencies from MIA,

Americans proposed service is superior due to Americans unmatched presence at MIA and

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. AAR-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 Americans Answer explains in detail. To advance the
Presidents objectives effectively and maximize public benefits, the Department should allocate

Consolidated Answer of American Airlines, Inc.


Page 4 of 30
frequencies to match anticipated traffic and demand. These considerations compel the award of
Americans 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 Departments history.

The thirteen applicants here far exceed the number of applicants in any other case before the
Department, and combined they have requested 397 weekly frequencies from the United States
to Havana, when just 140 are available. 1 Despite this fierce competition for these limited
resources, however, the applicants have reached a remarkable consensus on the realities of U.S.Cuba travel that must govern the allocation. The applicants generally agree that:

U.S.-Cuba traffic will largely be limited to those visiting family and relatives in Cuba,
and to those traveling for other reasons permissible under current OFAC sanctions. 2

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

The combined requests for non-HAV frequencies are less than the total number of non-HAV frequencies
authorized by the MOU. To best advance the Presidents objective to resume U.S.-Cuba scheduled service, the nonHAV frequencies requested should all be expeditiously granted so that U.S. carriers can soon begin service to Cuba.
2

See, e.g., Application of Alaska Airlines, Inc., at 8; Application of Frontier Airlines, Inc., at 6;
Application of JetBlue Airways Corp., at 18; Application of Silver Airways Corp., at 9; Application of Spirit
Airlines, Inc., and Ex. NK-CU-6.
3

See, e.g., Application of Alaska Airlines, Inc., at 6 n. 5; Application of JetBlue Airways Corp., at 9;
Application of Southwest Airlines Co., at 6; Application of Spirit Airlines, Inc., at Ex. NK-CU-6.
4
5

See, e.g., Application of Delta Air Lines, Inc., at 45; Application of Frontier Airlines, Inc., at 6.

See, e.g., Application of JetBlue Airways Corp., at 9 (travel will remain fundamentally restricted to
cities with strong Cuban familial and cultural ties for the foreseeable future.); Application of Southwest Airlines

Consolidated Answer of American Airlines, Inc.


Page 5 of 30
These realities all support Americans proposed schedule. As U.S. Senator Jeff Flake (RAZ) 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 Senators observation. 7

Family, cultural, and commercial

ties with Cuba are the strongest in Miami-Dade County, and Americans ten requested MIAHAV frequencies are firmly supported by the factors most indicative of near-term demand for
U.S.-Cuba travel:

Nearly 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 MIAalmost 11 times more than from the next U.S. airport. Ex. AA-R-111.

Indeed, other applicants have requested MIA-HAV frequencies despite having a minimal
presence in Miami-Dade County and minimal service at MIA, because demand for U.S.-Cuba
travel from MIA dwarfs the demand from any other airport.

The near unanimity among

applicants on the principles governing U.S.-Cuba travel fully supports Americans proposed
schedule. Only Americans proposed schedule, which makes MIA the cornerstone of U.S.-Cuba
scheduled service, lays the strongest possible foundation for the future growth of U.S.-Cuba
cultural and economic ties.

Co., at 56 (Naturally the communities with ties to Cuba will have the greatest interest and need to travel to Cuba
under the 12 OFAC categories.).
6

Remarks of Senator Jeff Flake (Mar. 10, 2016). See Ex. AA-R-201.

Letter from Mike Fernandez to Secretary Anthony Foxx (Mar. 14, 2016).

Consolidated Answer of American Airlines, Inc.


Page 6 of 30
II.

Americans Proposed Schedule Offers the Strongest Foundation for Service from
MIA, While Providing Sufficient Frequencies for Scheduled Service to and Through
Other Connecting Hubs
Americans proposed schedule is the only proposal that meets the needs of the Miami-

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 Departments long-standing practice of
allocating scarce resources in a manner that best suits the overall needs of the traveling public.
Failing to meet the needs of Miami-Dade would seriously undermine the Presidents and,
necessarily, the Departments policy towards Cuba.

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 Administrations broader
goals. Americans unparalleled presence and commitment to both MIA and Cuba enable it to
provide superior service for linking MIA with Cuba, and its extensive network from MIA
enables it simultaneously to connect those with Cuban ties across the United States with Cuba.
No other airline can do the same.
A.

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 Americans proposed schedule is most aligned with these
metricsthe two most reliable metrics of near-term demand for U.S.-Cuba scheduled service. In
8

As American explained in its Application, the average number of reported MIA-HAV charter flights in
2015 was 7.3 per day, a 14 percent increase from 2014. Application of American Airlines, Inc., at 4. This number
is understated because many U.S.-Cuba flights are not subject to the reporting requirements. At this rate of growth,
which will accelerate when scheduled service arrives, there will be demand for ten daily MIA-HAV frequencies by
2017, if not earlier.

Consolidated Answer of American Airlines, Inc.


Page 7 of 30
contrast to Americans 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

Application of American Airlines, Inc., at ex. AA-602, 603.

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 Americans application is reasonable under the Departments
standards and should therefore be fulfilled.

Americans proposal is right-sized to meet the

actual demand for U.S.-Cuba scheduled service where that demand is actually located, and only
Americans proposed schedule maximizes the public benefits of the Departments allocations.
B.

Awarding American Ten Daily MIA-HAV Frequencies Leaves Ample


Frequencies for Fulfilling Other Objectives

Americans proposed schedule is not only tailored to the demand from MIA; it leaves
sufficient frequencies to serve those communities with ties to Cuba besides Miami-Dade County.
Appropriate frequencies may be allocated to other major U.S. hubs, such as Charlotte (CLT),

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, Americans 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.

Americans 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
Americans proposed service achieves this primary goal.
C.

Only Americans Proposed Service from MIA Maximizes Public Benefits

Among the airlines proposing service from MIA, none provide anywhere near the level of
public benefits that Americans offers. The MIA-HAV service proposals of Delta, Eastern, and
Frontier are inferior for many reasons. Delta and Frontier have little to no MIA presence,
connectivity at MIA, and experience with Cuba, which suggests their proposed service is not

10
Americans proposal also accommodates sufficient frequencies for cargo service, though as discussed in
the part of this Answer addressing FedExs application, the fact that cargo service from HAV to MIA would not be
economically viable calls into question the need for allocating U.S.-Cuba frequencies solely to cargo at this time.

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 2015. 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. Deltas 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 Frontiers proposed MIA-HAV service.
First, Frontiers 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:

Easterns 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, Easterns profile with respect to U.S.-Cuba operations should be
that of a charter service provider only.

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 Americans proposal.

Americans 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.

Americans unrivaled

experience of 25 years with Cuban ground operations, other unique local conditions, and aviation
authorities will enable it to offer and maintain the best service for the traveling and shipping
public. Instituting Order at 2. From its hub at MIA, American will offer the best service to the
Miami-Dade Cuban-American community, while connecting those with Cuban ties across the
United States to the island nation.
The Administrations objectives are too important to rely on airlines with little Miami
presence and no appropriate experience to provide consistent, reliable service to link the MiamiDade Cuban-American population with Cuba. The public benefits at stake here go well beyond
parochial aviation interests. Should the Department disperse MIA-HAV frequencies among
airlines with no commitment to Cuba and no experience with its unique aviation requirements,
the Administrations goals of growing U.S.-Cuba cultural and economic ties could be lost. The
future growth of U.S.-Cuba engagement depends on frequent and reliable scheduled service
between Miami-Dade County and Cuba, and only American can provide it.
III.

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

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 11an 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 Floridas tri-county area. . . .).
12

45 Fed. Reg. 72,64647 (1980).

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 2015. Just 69 (2.0%) originated from FLL. Put another way, 42 times as
many HAV-bound flights originated from MIA as from FLL. Ex. AA-R-202, 407.

The average number of HAV-bound flights in 2015 was more than seven per day
from MIA, and less than two per week from FLL.

There were 1,430 flights from MIA to non-Havana Cuba destinations in 2015. From
FLL, there was only one. 14

Comparing the total requested frequencies to HAV from MIA and FLL, to an allocation
keyed to the proportion of charter flights flown to HAV from both airports in 2015, shows just
how over-requested FLL-HAV frequencies are in this proceeding:

13

52 Fed. Reg. 24,29192 (1987).

14

Application of American Airlines, Inc., at ex. AA-711.

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 CubanAmerican population surrounding each airport, looks remarkably similar:

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 Americans 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:

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), http://www.sun-sentinel.com/local/broward/fl-95-express-toll-congestion20150226-story.html.

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. Americans 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 cant be blamed. TPA was approved
for U.S.-Cuba flights at the same time, yet nearly five times as many U.S.-Cuba flights originated from TPA as from
FLL in 2015. And the growth in reported MIA-HAV flights between 2014 and 2015an average of nearly one
additional flight per dayfar surpasses the total number of 2015 FLL-HAV flights. New demand for travel to Cuba
sparked by warming U.S.-Cuba relations remains heavily concentrated at MIA. And again, if there was demand for
FLL-HAV service at the level of more than one per week, one of the FLL applicants surely would have flown these
charters, as JetBlue did at TPA.

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 Carriers 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. TPAs low ranking by both JetBlue and
Southwest 17 confirms its relative unimportance as a source for U.S.-Cuba traffic, and raises the
question of whether it should receive a daily frequency in this phase of U.S.-Cuba frequency
allocations.
Demographic and charter traffic data show that JetBlues and Southwests separate
requests for two TPA-HAV frequencies both substantially surpass anticipated demand. The
award of even one daily HAV frequency to TPA (365 annual flights) represents a significant
increase over 2015 TPA-HAV charter traffic (267 annual flights)almost 40 percent. And
unlike MIA, there is only minimal connecting traffic at TPA. Traffic to Cuba from TPA is
almost entirely limited to the Cuban-American population in Hillsborough County, which is only
about 85,000less roughly 10 percent of the Cuban-American population of Miami-Dade. Ex.
AA-R-429.

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.

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 MCOHAV frequency would fly nearly empty.

In 2015 there were just 65 MCO-HAV charter

flightsan average of 1 per week. Ex. AA-R-205. Daily scheduled service would be a gigantic
increase from this level. The lack of charter traffic should be no surprise, since there are just
30,000 Cuban Americans in Orange County, where MCO is located. Ex. AA-R-425. An overall
allocation of scheduled frequencies based purely on local Cuban-American population or keyed
to the proportion of 2015 Cuba charter traffic that originated at MCO would yield close to zero
HAV frequencies at MCO. 18 That combined with the negligible connecting traffic through MCO
shows MCO does not deserve scheduled service to HAV.

One-stop service (including

Americans proposed single plane service through MIA) and charter service meet Orlandos
needs. Despite the four daily scheduled MCO-HAV frequencies requested, the low ranking of

18

At most, two weekly frequencies, not two daily frequencies as JetBlue requested, or even one daily
frequency as Delta and Southwest requested. See Figure 1, Figure 2.

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 2015. 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.

Americans 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 CubanAmerican population and/or the 2015 charter traffic data, which are the best indicators of nearterm demand. These flaws, as well as other problems with the various proposals, are described
in detail below. 21

19

JetBlue ranked MCO-HAV 5th and 11th out of 15. Southwest and Delta both ranked MCO-HAV last.

20

Key West shows more charter flights, but all of these flights are operated with smaller aircraft with only
a minimal number of seats.
21

In addition, many of the connections proposed by the other applicants suffer from numerous
deficiencies: they show insufficient connect times; they include one-way connections; they use a connecting window
beyond the customary four hours; and they do not exclude cities for which circuity is in excess of 155 percent. The
descriptions of the other applicants realistic connections are included below, which are adjusted based on the same
methodology American used to determine its own connections created by its proposed service.

Consolidated Answer of American Airlines, Inc.


Page 21 of 30
A.

Application of JetBlue Airways Corp.

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 JetBlues 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. JetBlues
request is particularly surprising because its weekly FLL-HAV charter flight has historically had
a load factor of around 50 percent. By comparison, Americans MIA-HAV charter flights have
had load factors of around 75 percent. Ex. AA-R-415. And JetBlues proposed FLL-HAV
service will have only 15 connections in both directions. Ex. AA-R-410. Whether JetBlue can
support even one daily FLL-HAV flight is doubtful, and its request for four daily FLL-HAV
flights lacks any foundation.
New York (JFK): JetBlue currently operates just two weekly JFK-HAV charters, so its
proposed two daily JFK-HAV frequencies represent a seven-fold increase in JFK-HAV flights
(assuming no Delta JFK-HAV flights). Ex. AA-R-418. How JetBlue plans to support these
flights is unclear, when the load factor on its two weekly charter flights has been mediocre. To
attain an average load factor of 60 percent on its proposed daily JFK-HAV flights, JetBlue would
require that demand be stimulated by nearly 900 percent. Ex. AA-R-420. This is outside the

22

Application of JetBlue Airways Corp., at 89.

Consolidated Answer of American Airlines, Inc.


Page 22 of 30
realm of possibility, especially since JetBlues proposed JFK-HAV service creates only six
connections in both directions. Ex. AA-R-421.
Orlando (MCO): JetBlues 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 JetBlues five connections to HAV through MCO, ex. AA-R-426,
will not support anywhere near the level of one daily MCO-HAV scheduled flight, let alone two.
Tampa (TPA): Similar to JetBlues proposed daily service from JFK, JetBlue offers no
answer as to how it plans to go from operating two weekly TPA-HAV charter flights to two daily
TPA-HAV scheduled frequencies.

Especially given that JetBlues 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): JetBlues requested daily EWR-HAV service must be considered an
extreme reach. JetBlue does not have a hub at EWR, and its proposed EWR-HAV service
creates no connections in both directions. Ex. AA-R-436. Especially when considered alongside
the other requests from JFK and EWR, there is no reason for the Department to award this
requested frequency.
Boston (BOS): JetBlues proposed daily BOS-HAV service is aspirational at best. The
Cuban-American population of Boston is just 11,000, and there have never been any BOS-HAV
charter flights. Ex. AA-R-437, 438. Connecting traffic through BOS to HAV will also be
miniscule given its extreme Northeast geographic location.

Ex. AA-R-439.

Boston was

Consolidated Answer of American Airlines, Inc.


Page 23 of 30
JetBlues last priority among its six requested U.S. gateways, and it should be last on the
Departments 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, Southwests minimal international operations
from Florida and lack of experience in operating charter flights to Cuba make it particularly
unsuited for its requested HAV frequencies.
Fort Lauderdale (FLL): The six daily FLL-HAV frequencies proposed by Southwest
would amount to 4,380 flights annuallya 6,348 percent increase over the 69 FLL-HAV charter
flights flown in 2015. Ex. AA-R-507. The absurdity of this result speaks for itself.
Tampa (TPA): As described earlier in this Answer, TPA might support one daily flight
to HAV at most. Southwests request for two TPA-HAV frequencies is therefore excessive.
Orlando (MCO):

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 MIAHAV and MCO-HAV daily frequencies, neither of which originate from a Delta hub. Deltas
two recent attempts to operate international service from non-hubs, including MIA, suggest that
Delta cannot sustain this service. Delta operated MIA-LHR service for just 13 months before
terminating it, and Deltas PHL-LHR service, another non-hub international route which was
inaugurated in April 2015, reached a peak load factor of just 55 percent in August before

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.
Deltas proposed service to HAV from ATL creates comparable connectivity to
Americans proposed service to HAV from CLT and DFW. Ex. AA-R-601. But Delta has
almost no experience operating flights to Cuba, whereas Americans 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. Deltas lack of
a hub at MIA means that there are few residents of Miami-Dade County with Deltas frequent
flier membership, and Deltas operations from MIA in 2015 were tiny compared to Americans,
in terms of both domestic departures and domestic passengers carried. Ex. AA-R-213, 214, 217,
218, 605. As to Deltas proposed MCO-HAV daily frequency, Orlandos Cuban-American
population of 30,000 and Deltas 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. Deltas proposed MIA-HAV and
MCO-HAV frequencies should therefore be rejected.
D.

Application of Frontier Airlines, Inc.

Frontiers proposed service suffers from three glaring flaws. First, the first two of
Frontiers proposed MIA-HAV daily frequencies are conditioned on Frontier receiving a daily
DEN-HAV frequency, and there is no basis for the Department to award nonstop service
between Denver and Havana. Ex. AA-R-701. The Cuban-American population of Denver is
approximately 3,500far from sufficient to support even one weekly scheduled flight. Ex. AA-

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, Frontiers
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 Countys, and historically, FLL has supported barely more than
a single weekly charter flight to HAV. Spirits request for two daily FLL-HAV frequencies is
excessive, especially given Spirits lack of experience in Cuba and that its proposed service
would create only ten connections through FLL in both directions. Ex. AA-R-806.
F.

Application of United Airlines, Inc.

Several problems with Uniteds proposed weekly service from IAD, IAH, and ORD arise
from the poor geographic position of its EWR hub relative to these airports. On Saturdays,
travelers from these airports will enjoy nonstop service, but on every other day of the week, they
will have to endure substantially longer connecting flights through Uniteds EWR hub to travel
between the United States and Cuba. For instance, a HAV-EWR-IAH flight has extreme circuity
and a travel time of nearly ten hours, compared to a nonstop travel time of under three hours
between IAH and HAV. Ex. AA-R-904. Likewise, the travel time for connecting flights
through EWR to ORD and IAH is double the nonstop travel time. Ex. AA-R-905, 906. This
effectively forces travelers on Uniteds proposed service from IAD, IAH, and EWR to travel to
and from Cuba exclusively on Saturdays, and this constraint makes Uniteds proposed service

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 Americans network.
G.

Application of Alaska Airlines, Inc.

Alaskas request for two daily LAX-HAV frequencies bears no relationship to anticipated
demand. American currently provides a weekly charter flight between LAX and HAV, and
knows the potential demand in the LAX-HAV market better than any other airline. If LAX
could support more than one weekly frequency to HAV, American would have applied for more.
The lack of LAX-HAV demand is demonstrated by the fact that the weekly charter flight
American operates has a load factor of under 50 percent. 23 Ex. AA-R-1002. Alaska must
stimulate demand by over 600 percent to support a 50 percent load factor on just one of its two
proposed daily LAX-HAV frequencies, ex. AA-R-1003, and Alaska offers no explanation for
how it plans to do so. The three connecting flights Alaskas proposed service creates will hardly
increase traffic over current levels or improve travel times. Ex. AA-R-1004, 1005. LAX is best
served, for now, with the weekly scheduled service to HAV proposed by American, not the daily
service proposed by Alaska.
H.

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 2015. Ex. AA-R-1101, 1103. There were
nine RSW-HAV charter flights and one MSP-HAV charter flight in 2015. 24

Cuba.

Finally, Sun

23

Americans contract with the charter company prohibits American from disclosing the actual load factor.

24

This was a one-off charter flight operated by Delta to transport the Minneapolis Symphony to and from

Consolidated Answer of American Airlines, Inc.


Page 27 of 30
Countrys network would create only one connection in both directions at each airport. Ex. AAR-1102, 1105. 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, FedExs proposed service
from HAV to Mrida, Mexico (MID) is arguably outside the scope of the U.S.-Cuba MOU.
The MOU provides that [t]he permission to perform scheduled and charter services between
any point or points in the United States and any point or points in Cuba, and merely allows for
stops for non-traffic purposes within or outside the territory of either country. 25 Ex. AA-R1201. Whether this permits FedExs proposed MIA-HAV-MID-MIA frequency is unclear, and
the Department must resolve this question before granting FedEx any scheduled frequencies.
Second, FedEx admits that it must fly from HAV to MID so that the flights can be economically
viable. 26 This raises another important question: Is now the right time to award a scarce HAV
scheduled frequency purely for cargo, when there is insufficient demand for cargo service from
HAV to MIA? At this time, charter flights may be more appropriate for U.S.-Cuba cargo
service.
J.

Application of Dynamic International Airways, LLC

Awarding frequencies to Dynamic would not be in the public interest.

Dynamics

proposal deprives the public of valuable frequencies until nearly December 2016, when it plans
to start service to Cuba. 27 And Dynamic may need to further delay startup, as this period is the
minimum time it needs to make its proposed service viable. 28 The proposal also deprives a

25

U.S.-Cuba MOU, at 1, 2.d (emphasis added).

26

Application of Federal Express Corp., at 5.

27

Application of Dynamic International Airways, LLC, at 4.

28

Id.

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.
Dynamics 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 Dynamics equipment, and Dynamics proposed U.S.
gateways, Dynamic likely will not be able to sustain this service. No other airline has proposed
operating U.S.-Cuba service with 280-seat aircraft, and for good reason: These planes will most
likely fly at load factors that make such service economically disastrous.
K.

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
www.regulations.gov). In February 2016, Dynamic reported mysterious damage to an aileron. Letter from Jason E.
Maddux, Counsel, Garofalo Goerlich Hainbach PC, to Lauralyn Remo, Chief, Air Carrier Fitness Division, DOT
(Feb. 9, 2016) (on file at www.regulations.gov).

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 Easterns 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.

Silvers proposed use of 34-seat turboprop planes would drastically underutilize the
available frequencies to HAV. This equipment is far too small to serve anticipated U.S.-Cuba
traffic, and Silver should not be awarded any frequencies to Cuba when many carriers, such as
American, have proposed service using planes that can seat five times as many passengers.
There are far too few frequencies available in this proceeding to allocate even one to a carrier
proposing to operate it with a small, turboprop plane.
Conclusion
The applications filed in this proceeding make clear that connecting the Miami-Dade
Cuban-American community with Cuba is of paramount importance. Among all applicants,
Americans proposed schedule best matches demand and traffic patterns from Miami-Dade
County and the rest of the nation, and lays the strongest foundation for the growth of U.S.-Cuba
cultural and economic ties. The success of these scheduled frequencies will impact U.S.-Cuba
relations for years to come, and will be an extraordinary achievement for the Presidents legacy.

30

Application of Eastern Airlines Group, Inc., at 45.

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

Paul T. Denis
Steven G. Bradbury
William B. Sohn

Robert A. Wirick
Managing Director
Regulatory and International Affairs

DECHERT LLP
1900 K Street NW
Washington, D.C. 20006
(202) 261-3300
paul.denis@dechert.com
steven.bradbury@dechert.com
william.sohn@dechert.com

John B. Williams
Senior Analyst
Regulatory and International Affairs
AMERICAN AIRLINES, INC.
1101 17th Street, NW
Washington, D.C. 20036
(202) 326-5153
howard.kass@aa.com
robert.wirick@aa.com
john.b.williams@aa.com
March 14, 2016

Charles A. Hunnicutt
Brent Connor
THOMPSON HINE LLP
1919 M Street NW, Suite 700
Washington, D.C. 200036
(202) 331-8800
charles.hunnicutt@thompsonhine.com
brent.connor@thompsonhine.com

CERTIFICATE OF SERVICE
I certify that, on March 14, 2016, I caused to be served a copy of the foregoing
Consolidated Answer of American Airlines, Inc. by email upon those addressees listed below:
brian.hedberg@dot.gov (Dept. of Transportation)
todd.homan@dot.gov (Dept. of Transportation)
peter.irvine@dot.gov (Dept. of Transportation)
brett.kruger@dot.gov (Dept. of Transportation)
dan.weiss@united.com (United)
steve.morrissey@united.com (United)
gmurphy@crowell.com (Counsel for United)
mwarren@crowell.com (Counsel for United)
sseiden@crowell.com (Counsel for United)
robert.land@jetblue.com (JetBlue)
esahr@eckertseamans.com (Counsel for JetBlue)
dderco@eckertseamans.com (Counsel for JetBlue)
perkmann@cooley.com (Counsel for Hawaiian)
john.varley@virginamerica.com (Virgin America)
mlbenge@zsrlaw.com (Counsel for Virgin America)
jhfoglia@zsrlaw.com (Counsel for Virgin America)
megan.ouellette@alaskaair.com (Alaska)
john.kirby@alaskaair.com (Alaska)
jeremy.ross@alaskaair.com (Alaska)
dheffernan@cozen.com (Counsel for Alaska)
rwelford@cozen.com (Counsel for Alaska)
jyoung@yklaw.com (Counsel for Spirit)
dkirstein@yklaw.com (Counsel for Spirit)
john.fredericksen@suncountry.com (Sun Country)
thomas.ting@suncountry.com (Sun Country)
matwood@cozen.com (Counsel)
slachter@cozen.com (Counsel)
rpommer@atlasair.com (Atlas)
jmaddux@ggh-airlaw.com (Counsel for Dynamic)
anita.mosner@hklaw.com (Counsel for UPS)
jennifer.nowak@hklaw.com (Counsel for UPS)
kevin.montgomery@polaraircargo.com (Polar)
matthew.danaher@cityofchicago.org (ORD)

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

Testimony

DOT Docket OST-2016-0021


List of Testimony
Page 1 of 1

Testimony of American Airlines

Testimony

AA-R-T-1

Testimony of Tessie Aral

#aacuba

ABC Charters

1125 SW 87 AVE
MIAMI FL 33174

TM

A Better Choice Travel

Tel: (305) 263 - 6555


Fax: (305) 263 - 6801
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 2000. 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. Ive 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 CubanAmerican population.
Thats why ABC Charters flies to Cuba mostly from MIA, which is located in MiamiDade County, home to nearly half the nations 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 awayfar closer than
any other airportand 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 dont 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. Its also in less familiar
territoryMIA 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. FLLs 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

Its no surprise that most of the regions Cuban Americans prefer MIA to FLL for short U.S.Cuba flights.
The preference of Cuban-American travelers is reflected in data on U.S.-Cuba charter
flights. Flights to Cuba have been allowed from FLL for nearly five years, yet in 2015, 83
percent of all flights from the United States to Havanas Jos Mart International Airport
(HAV) originated from MIA, and just 2 percent originated from FLL. On average there were
over seven flights per day from MIA to HAV in 2015, and less than two flights per week from
FLL to HAV. Indeed, of the more than eight hundred charter flights that my company flew to
Cuba in 2015, just one was from FLL, and Ive only been asked to provide 3 private group
charter flights to Cuba from FLL in the past five years. If demand for flights from FLL to HAV
were greater, surely more charter service providers such as mine would have initiated service to
Cuba from FLL, but that hasnt happened. Instead, Ive observed weak demand for the few FLL
to HAV charter flights offered since 2011, only being able to sustain one rotation per week. The
Miami-Dade Cuban American population strongly favors MIA, and there is not enough local
demand in Fort Lauderdale/Broward County to support daily FLL-HAV charter flights.
There is also smaller demand for charter flights to Cuba from other airports. My company
provided no charter flights to Cuba from any other Florida airport in 2015 except for the three
weekly flights from Tampa to Havana.
Since 2011, we have not received any requests for
charters to Cuba from MCO, RSW, PBI, EYW and JAX. With the flights arranged from Tampa
and those from Miami, it covers all the demand in the state of Florida. Accorss the entire
charter industry, just 115 flights were flown from EYW in 2015 (all with very small airplanes,
not regional or mainline jets), 65 from MCO, 9 from RWS and none from PBI and JAX.
Consistent with demographics, top demand for U.S.-Cuba flights continue to be centered on
MIA.
Theres no reason to expect anything different when U.S.-Cuba scheduled service arrives.
Scheduled service wont change demographics. Cuban Americans, who are concentrated in
areas near MIA, will continue to prefer their neighborhood airport for U.S.-Cuba travel. The
frequencies allocated by the Department should therefore be mostly allocated to MIA, not FLL
and other airports. Failure to do so would greatly harm the Cuban Americans of Miami-Dade
County, who are the largest portion of U.S.-Cuba travelers and who have by far the greatest
demand for U.S.-Cuba scheduled service.
ABC Charters shares Americans commitment to connecting the U.S. and Cuban people
via commercial air service, and I believe that this service must primarily originate from MIA to
best meet the needs of passengers who have both the ability as well as the desire to travel to
Cuba.

Respectfully submitted,

Maria T.Aral

Letter of Support

DOT Docket OST-2016-0021


List of Letters of Support
Page 1 of 1

Letter of Support of American Airlines

Letter of Support

Letter from Mike Fernandez

#aacuba

Rebuttal Exhibits

DOT Docket OST-2016-0021


List of Rebuttal Exhibits
Page 1 of 14

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. CubanAmerican Population

AA-R-105

Data Point #1: U.S. Cuban-American Population - MIA is, Unquestionably, the U.S. Gateway with the Largest U.S.
Cuban-American Population, and, Thus, Has the Most Proven Need for HAV Frequencies

AA-R-106

Allocating U.S.-Havana Frequencies in This Proceeding Based on the Size and Location of Cuban-American
Population, MIA Should Receive 12 U.S.-Havana Frequencies of the 20 Available

AA-R-107

A Comparison of the Frequency Allocation Based on the U.S. Gateways Proposed in This Proceeding with the
Frequencies Requested at Each U.S. Gateway Shows that the MIA-HAV "Asks" Were in Line with Historical Demand

AA-R-108

FLL Has the Largest Difference Between Its Proportionate Share of U.S.-Havana Frequencies and the Number of
U.S.-Havana Frequencies Requested

AA-R-109

Based on Percentages, MIA Has the Smallest Difference Between Its Proportionate Share of U.S.-Havana
frequencies and the Frequencies Requested at MIA of Any Gateway for Which Daily Service Is Proposed

AA-R-110

Date Point #2: Historical Information on U.S.-Cuba Charter Flights - The Overwhelming Number of Charter Operated
From The U.S. Gateways Proposed in This Proceeding to Cuba Originated at MIA in 2015 - Over 86%

AA-R-111

Data Point #3: Historical Information on U.S.-Havana Charter Flights - Close to 84% of All Charters Between the U.S.
and Havana in 2015 Originated At MIA

#aacuba

DOT Docket OST-2016-0021


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.

#aacuba

DOT Docket OST-2016-0021


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

#aacuba

DOT Docket OST-2016-0021


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

#aacuba

DOT Docket OST-2016-0021


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

#aacuba

DOT Docket OST-2016-0021


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

#aacuba

DOT Docket OST-2016-0021


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 2015But Only Twice Weekly. If JFK-HAV
Demand Existed for a Daily or Double Daily Flight, Why Hasn't JetBlue Increased the Frequency?

AA-R-419

The Reason JetBlue Has Not Increased JFK-HAV Frequencies: JetBlue's JFK-HAV Load Factors Have Been
Mediocre with Only Two Weekly Flights

AA-R-420

So One Could Imagine What the Load Factor Would Be With a Seven-Fold Increase in Service

AA-R-421

And This Would Be Without the Benefit of Significant JetBlue Connections at JFK

AA-R-422

The Modest Demand for JFK-HAV Service Is Not Surprising Given the Size of the Cuban-American Popuation and
the Historical Demand for JFK-HAV Service

AA-R-423

JetBlue's request for Double Daily MCO-HAV Service Greatly Exaggerates the Size of the MCO-HAV Market

AA-R-424

JetBlue's Exaggerated MCO-HAV Request Is Made Worse by the Requests of Southwest and Delta. When
Combined, the Total MCO-HAV Requests Bear No Relationship to the Needs of or Demand in the MCO-HAV Market

AA-R-425

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

#aacuba

DOT Docket OST-2016-0021


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

#aacuba

DOT Docket OST-2016-0021


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

#aacuba

DOT Docket OST-2016-0021


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

#aacuba

DOT Docket OST-2016-0021


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

#aacuba

DOT Docket OST-2016-0021


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 DENHAV 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

#aacuba

DOT Docket OST-2016-0021


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
Soand It Has Not

AA-R-1003

If Once-Weekly LAX-HAV Charter Flight Current Operated by American Has Experienced a Load Factor of Less
Than 50% from the Start of the Service to Date, Can Anyone Believe That a Daily or Double Daily Service Will Be a
Viable or Prudent Use of Scarce Havana Frequency Allocations?

AA-R-1004

Alaska's Proposed LAX-HAV Services Would Have Only 3 Connections

#aacuba

DOT Docket OST-2016-0021


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?

#aacuba

Series 100:
General Rebuttal Exhibits
of American Airlines

DOT Docket OST-2016-0021


Exhibit AA-R-101
Page 1 of 1

Summary of Applicants and Proposed U.S. Gateways For Havana Service

13 applicants for U.S.-Cuba


Frequency Allocations
397 U.S.-Havana weekly
frequencies requested

Total Weekly Frequencies


by All Applicants
117
91
28
28
24
19
15
14
9
7
7
7
7
7
6
5
2
2
1
1

Gateways to Havana
MIA
FLL
MCO
TPA
JFK
LAX
EWR
PBI
RSW
CLT
DFW
BOS
DEN
ATL
ORD
EYW
JAX
MSP
IAH
IAD

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-102
Page 1 of 1

U.S. Carrier Applicant Proposed Frequencies to Havana by Gateway


Weekly Frequencies
140

120

117

100

91

80

60

40

28
20

28

24

19

15

14

MIA

FLL TPA MCO JFK EWR LAX

PBI RSW CLT DFW BOS DEN ATL ORD EYW JAX MSP IAH

IAD

Source: Carrier Applications

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-103
Page 1 of 1

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, Americans 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.

#aacuba

Applicants In This Proceeding Agree That the Overwhelming


Source of Traffic to Havana Will Be the U.S. Cuban American Population

Carrier

Southwest

JetBlue

Frontier

Silver

DOT Docket OST-2016-0021


Exhibit AA-R-104
Page 1 of 1

Comments
. . . [t]he distribution of Cuban American
population [will be] the most likely major centers
for travel from the U.S. . . .
(Application, Page 3)
. . . [F]amilial, cultural and educational travel . . .
will be the primary drivers of United States-Cuba
traffic until Congress takes further steps to
rescind the embargo.
(Application, Page 18)
. . . [T]he largest population eligible to travel to
Cuba are those permitted to do so to visit closer
relatives there. (Application, Page 18)
. . . Cuban Americans comprise the vast
majority of likely Cuba travelers.
(Application, Page 9)

#aacuba

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

DOT Docket OST-2016-0021


Exhibit AA-R-105
Page 1 of 1

Top 10 States Cuban-American Population

1,400,000

1,213,438
1,200,000

1,000,000

800,000

Miami-Dade (MIA): 856,007

600,000

400,000

200,000

88,607

83,362

70,803

46,541

25,048

22,541

21,459

18,079

17,930

Texas

Georgia

Illinois

Nevada

North
Carolina

Pennsylvania

0
Florida

California

New Jersey

New York

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)
Source: U.S. Census Bureau

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-106
Page 1 of 1

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
Allocation of 20 U.S.-Havana Daily Frequencies
Based on Cuban-American Population
at Proposed U.S. Gateway Cities

14

12

12.2

10

2
1.2

1.2

0.9

0.7

0.7

0.6

0
MIA

EWR

FLL

TPA

LAX

JFK

PBI

0.4

0.3

0.3

0.3

0.3

0.2

0.2

0.2

RSW

MCO

ORD

IAH

ATL

IAD

DFW

BOS

0.1
EYW

0.1
JAX

0.1
CLT

Note:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds application (Exhibit UA-112).

0.0
DEN

0.0
MSP

#aacuba

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

DOT Docket OST-2016-0021


Exhibit AA-R-107
Page 1 of 1

16

15.0
14

13.0
12

12.2

10

4.0

Total Daily Frequencies Requested by U.S. Carriers


at Each Proposed U.S. Gateway

4.0

Allocation of Available 20 U.S.-Havana Daily


Frequencies Based on Cuban-American Population

3.0
2.1

2.1

2.0

1.3
1.2

1.2

0.9

0.7

0.7

0.6

0
MIA

EWR

FLL

TPA

LAX

JFK

PBI

1.0
0.3

0.4

0.3

0.3

RSW

MCO

ORD

0.1
0.3

0.3

IAH

ATL

1.0

1.0

0.2

0.2

0.2

IAD

DFW

BOS

0.7

0.1
0.1
EYW

1.0

1.0

0.3
0.1
JAX

0.3
0.1
CLT

Note:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds application (Exhibit UA-112).

0.0
DEN

0.0
MSP

#aacuba

FLL Has the Largest Difference Between Its Proportionate Share of U.S.-Havana
Frequencies and the Number of U.S.-Havana Frequencies Requested

U.S. Gateway

Allocation of Available
Total Daily Frequencies
20 U.S.-Havana
Requested by U.S. Carriers
Daily Frequencies Based on
at Each Proposed U.S.
Cuban-American Population
Gateway

DOT Docket OST-2016-0021


Exhibit AA-R-108
Page 1 of 1

Frequency
Difference

FLL

1.2

13

(11.8)

MCO

0.3

(3.7)

TPA

0.9

(3.1)

MIA

12.2

15

(2.8)

JFK

0.7

(2.3)

LAX

0.7

2.1

(1.4)

PBI

0.6

(1.4)

DEN

0.0

(1.0)

EWR

1.2

2.1

(0.9)

RSW

0.4

1.3

(0.9)

CLT

0.1

(0.9)

DFW

0.2

(0.8)

BOS

0.2

(0.8)

ATL

0.3

(0.7)

Note:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx). Minimum daily service proposed.
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the allocation
described in Uniteds application (Exhibit UA-112).

#aacuba

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

DOT Docket OST-2016-0021


Exhibit AA-R-109
Page 1 of 1

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%

U.S. Gateway

Note:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx). Minimum daily service proposed.
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-110
Page 1 of 1

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%
2015 Charter Flights to Cuba
From U.S. Gateways Proposed in This Proceeding
By All Carriers (Including Non-Applicants)

5,000
4,500

4,348

MIA: Almost 13x larger than next largest U.S. gateway to Cuba
4,000
3,500
3,000
2,500
2,000
1,500
1,000
500

338
115

70

70

65

MIA TPA EYW JFK FLL MCO RSW LAX BOS MSP ATL CLT DFW DEN EWR IAD IAH JAX ORD PBI

Source: Havanatur Cuba Charter Data (2015)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-111
Page 1 of 1

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
2015 Charter Flights to Havana
From U.S. Gateways Proposed in This Proceeding
By All Carriers (Including Non-Applicants)

3,500

3,000

2,918

MIA: Almost 11x larger than next largest U.S. gateway to Cuba
2,500

2,000

1,500

1,000

500

267
86

70

69

65

MIA TPA EYW JFK FLL MCO RSW LAX BOS MSP ATL CLT DFW DEN EWR IAD IAH JAX ORD PBI

Source: Havanatur Cuba Charter Data (2015)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-112
Page 1 of 1

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

Allocation of 20 U.S.-Havana Daily Frequencies


Based On Charters Flown in U.S.-Havana Markets in 2015

16.7
16.0

14.0

12.0

10.0

8.0

6.0

4.0

2.0
1.5
0.5

0.4

0.4

0.4

EYW

JFK

FLL

MCO

MIA

TPA

0.1
RSW

0.0
LAX

0.0
BOS

0.0
ATL

0.0
MSP

0.0
EWR

0.0
PBI

0.0
CLT

0.0
DFW

0.0
DEN

0.0
ORD

0.0
JAX

0.0
IAD

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).

0.0
IAH

#aacuba

A Comparison of the Frequency Allocation Based on 2015 Charter Flights Operated with the
Frequencies Proposed at Each U.S. Gateway Shows that MIAs, and Only MIAs, Request for
HAV Service Is Less Than Its Proportionate Share of Historical Charter Flights

DOT Docket OST-2016-0021


Exhibit AA-R-113
Page 1 of 1

Total Daily Frequencies Requested by U.S. Carriers at Each Proposed U.S. Gateway
16.7
16

Allocation of Available 20 U.S.-Havana Daily Frequencies Based on 2015 U.S.-HAV Charter


Operation s

14

12

10

2
1.5
0.5

0.4

0.4

0.4

EYW

JFK

FLL

MCO

MIA

TPA

0.1
RSW

0.0
LAX

0.0
BOS

0.0
ATL

0.0
MSP

0.0
EWR

0.0
PBI

0.0
CLT

0.0
DFW

0.0
DEN

0.0
ORD

0.0
JAX

0.0
IAD

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).

0.0
IAH

#aacuba

Several Applicants Did Not Build Realistic Connections


to Their Proposed U.S.-Havana Services

DOT Docket OST-2016-0021


Exhibit AA-R-114
Page 1 of 1

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%

#aacuba

Several Applicants Included Connecting Flights with Maximum


Connection Times Exceeding Four Hours

DOT Docket OST-2016-0021


Exhibit AA-R-115
Page 1 of 2

Northbound HAV-XXX Connections


Airline
American
American
American
American
American
Alaska
JetBlue
JetBlue
JetBlue
JetBlue
JetBlue
Delta
Delta
Delta
Delta
Frontier
Frontier
Spirit
Sun Country
Sun Country
United
United
United
United
Southwest
Southwest
Southwest

Route
MIA-HAV
CLT-HAV
DFW-HAV
ORD-HAV
LAX-HAV
HAV-LAX
HAV-FLL
HAV-JFK
HAV-MCO
HAV-TPA
HAV-BOS
HAV-JFK
HAV-ATL
HAV-MIA
HAV-MCO
HAV-MIA
HAV-DEN
HAV-FLL
HAV-DEN
HAV-RSW
HAV-EWR
HAV-IAH
HAV-IAD
HAV-ORD
HAV-FLL
HAV-TPA
HAV-MCO

Minimum Connection Max Connection Time


Time (minutes)
(minutes)
95
240
75
240
80
240
90
240
90
240
120
Not included
104
538
107
397
93
464
114
461
106
264
90
434
85
438
95
544
60
545
90
Not included
105
Not included
Not included
Not included
Not included
Not included
Not included
Not included
72
377
110
220
86
425
95
250
120
240
120
240
120
240

Note: Frontier (F9) only included schedule data for through flights; a full schedule of connecting flights was not provided.
Source: Airline Applications

#aacuba

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

DOT Docket OST-2016-0021


Exhibit AA-R-115
Page 2 of 2

Southbound XXX-HAV Connections


Airline
American
American
American
American
American
Alaska
JetBlue
JetBlue
JetBlue
JetBlue
JetBlue
Delta
Delta
Delta
Delta
Frontier
Frontier
Spirit
Sun Country
Sun Country
United
United
United
United
Southwest
Southwest
Southwest

Route
MIA-HAV
CLT-HAV
DFW-HAV
ORD-HAV
LAX-HAV
LAX-HAV
FLL-HAV
JFK-HAV
MCO-HAV
TPA-HAV
BOS-HAV
JFK-HAV
ATL-HAV
MIA-HAV
MCO-HAV
MIA-HAV
DEN-HAV
FLL-HAV
DEN-HAV
RSW-HAV
EWR-HAV
IAH-HAV
IAD-HAV
ORD-HAV
FLL-HAV
TPA-HAV
MCO-HAV

Minimum Connection Max Connection Time


Time (minutes)
(minutes)
60
240
55
240
55
240
60
240
60
240
60
Not included
39
478
35
475
33
479
55
509
34
180
60
526
40
250
66
465
44
271
Not included
Not included
Not Included
Not included
Not included
Not included
Not included
Not included
Not included
Not included
41
321
30
300
42
84
36
260
60
240
60
240
60
240

Note: Frontier (F9) only included schedule data for through flights; a full schedule of connecting flights was not provided.
Source: Airline Applications

#aacuba

Adjusting the Applicants Claimed Connections for the Same Connections


Methodology Used by American Shows:

DOT Docket OST-2016-0021


Exhibit AA-R-116
Page 1 of 1

Market Analysis on an Apples to Apples Comparison


For Proposed Daily (or More) Services
Airline

Route

Delta
American
American
American
United
Southwest
JetBlue
Southwest
Spirit
Southwest
JetBlue
JetBlue
Silver
JetBlue
Alaska
Delta
Delta
Delta
JetBlue
Frontier
Frontier
JetBlue
Sun Country

ATL-HAV
CLT-HAV
MIA-HAV
DFW-HAV
EWR-HAV
FLL-HAV
FLL-HAV
TPA-HAV
FLL-HAV
MCO-HAV
JFK-HAV
MCO-HAV
FLL-HAV
TPA-HAV
LAX-HAV
MCO-HAV
JFK-HAV
MIA-HAV
BOS-HAV
DEN-HAV
MIA-HAV
EWR-HAV
RSW-HAV

Proposed
Frequencies
7x
7x
70x
7x
8x
42x
28x
14x
14x
7x
14x
14x
7x
14x
14x
7x
7x
14x
7x
7x
21x
7x
7x

Stated
Connections
152
68
58
52
50
27
N/A
34
19
33
N/A
N/A
N/A
N/A
4
11
19
10
N/A
N/A
N/A
N/A
N/A

Connections
(Both Ways)
71
68
58
52
25
20
15
15
10
10
6
5
4
4
3
3
2
2
1
1
1
0
0

Notes: Viable connections based on (a) 4 hour maximum connect time each way; (b) 55 minute domestic to Cuba connection time based on shortest connection time used by
American Airlines; (c) 75 minute Cuba to domestic connection time based on shortest connection time used by American Airlines; (d) circuity less than 155%; (e) minimum of 5x weekly
connecting flights.
JetBlue included in its exhibits connecting itineraries, but it did not state the number of connections
Source: Connecting schedules contained in carrier submissions where possible. For airlines that did not provide connecting schedules, June 2016 OAG or Diio schedules were used.

#aacuba

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

DOT Docket OST-2016-0021


Exhibit AA-R-201
Page 1 of 1

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 everyones right to travel to Cuba, key to the success
will be ensuring that the initial flights being awarded by the Department of
Transportation provide for the continued and expanded ability of the Cuban
American community to travel to the island via regular air service.
This should include adequate regular service to accommodate the growing
demand from the largest and closest Cuban American population located in
Miami-Dade County.

Note: Emphasis added.

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-202
Page 1 of 1

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
Cuban-American Population
Miami-Dade County versus Total U.S.

Charter Flights to Havana by U.S. Origin


2015
JFK MCO
FLL 2.0% 1.9%
2.0%

1,785,547

Other
0.9%

EYW
2.5% TPA
7.6%

856,007

MIA
83.3%

Total U.S.

Miami-Dade County
(MIA)

Note: Other includes: RSW, SJU, BWI, LAX, MSP, ATL, MSY, and BOS.
Source: Havanatur 2015 charter data; American Airlines; U.S. Census data (2010)

Total flights to Havana: 3,505

#aacuba

Americans MIA-HAV Request Is Less Than MIAs Proportionate Share of


U.S.-Havana Frequency Allocations

DOT Docket OST-2016-0021


Exhibit AA-R-203
Page 1 of 1

Americans Proposed MIA-HAV Daily Frequencies Are Less Than MIAs


Proportionate Share of Cuban-American Population
14

12.2
12

10

10
8
6
4
2
0
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 Uniteds application (Exhibit UA-112).

#aacuba

In Addition, Americans MIA-HAV Service Provides


Comprehensive Domestic U.S. Coverage

DOT Docket OST-2016-0021


Exhibit AA-R-204
Page 1 of 1

Americans MIA-HAV Connections Cover the Entire U.S.

58 connections in both directions


(50 Domestic U.S. connections)
#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-205
Page 1 of 1

Americans Request for 10 Miami-Havana Frequencies Only Matches


Actually Under-Requests Existing Charter Demand

MIA-HAV Daily Frequencies


versus Americans Request

2015 MIA-HAV Charter Flights Operated


by Gateway

10

10
9.5

3,000 2,922

8
7

3,500

8.3

MIA was the origin of 84%


of U.S.-HAV charter flights =
16.7% of 20 U.S.-Havana daily
frequencies available

2,500

7.3

6
2,000
5
1,500

4
3

1,000

2
500

267
70

2015

2016*

2017*

AA MIA-HAV
Request

Note: MIA-HAV charter demand for 2016 and 2017 is annualized based on 14% of YoY growth rate.
(Jan-Feb 2016 vs. Jan-Feb 2015) without assuming any stimulation.
Source: Havanatur charter flight data (2015)

69

65

MIA TPA JFK FLL MCO RSW LAX ATL BOS MSP

#aacuba

Americans Request for 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.

DOT Docket OST-2016-0021


Exhibit AA-R-206
Page 1 of 1

CLT and MIA Connections

68 CLT connections in both directions


+34 unique CLT connections added to MIA
#aacuba

Americans 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

DOT Docket OST-2016-0021


Exhibit AA-R-207
Page 1 of 1

DFW, CLT, and MIA Connections

52 DFW connections in both directions


+37 unique DFW connections added to CLT and MIA
#aacuba

Americans Request for Once Weekly ORD Frequency Meets the Demand of the Local
Chicago Cuban-American Community More Than Twice Weekly Service
Would Be Excessive to the Current and Anticipated Demand in the ORD-HAV Market
Americans proposed once weekly ORD
frequency to Havana versus weekly
frequencies as per % share of
Cuban-American Population
2.5

DOT Docket OST-2016-0021


Exhibit AA-R-208
Page 1 of 1

. . . and American could provide efficient onestop connections every day of the week to
ORD passengers
through MIA, CLT and DFW

2.1x
weekly

2.0

1.5

1.0x
weekly
1.0

0.5

0.0

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.
#aacuba

Americans Request for Once Weekly Service from LAX Is


Consistent with Existing and Anticipated LAX-HAV Demand
Americans Proposed LAX-HAV daily
frequencies to Havana versus daily
frequencies as per % share of CubanAmerican Population

DOT Docket OST-2016-0021


Exhibit AA-R-209
Page 1 of 1

. . . and American could provide efficient


one-stop connections every day of the week
through MIA, CLT and DFW
to meet additional demand

0.8

0.7
0.7
0.6
0.5
0.4
0.3
0.2

0.1
0.1
0.0

Daily Frequencies per %


of Cuban-American
Population

American's LAX-HAV
Request

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-210
Page 1 of 2

American Airlines Is Miamis Hometown Airline


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

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-210
Page 2 of 2

American Airlines Is Miamis Hometown Airline


Americans Community Involvement

#aacuba

American Serves More Than 3x the Number of Domestic U.S. Destinations from
MIA Than the Other Three Applicants for MIA-HAV Services Combined

DOT Docket OST-2016-0021


Exhibit AA-R-211
Page 1 of 1

Domestic Destinations Served


June 2016
60

54
50

40

30

20

10

10

6
0

American

Delta

Frontier

Eastern

Source: OAG schedule data accessed March 3, 2016 for June 2016

#aacuba

Americans Domestic Service Share at MIA Far Outstrips the Share of the Other
Three MIA-HAV Applicants Combined

DOT Docket OST-2016-0021


Exhibit AA-R-212
Page 1 of 1

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

#aacuba

American Operates Almost 6x as Many Domestic Departures at MIA as the Other


Three MIA-HAV Applicants Combined

DOT Docket OST-2016-0021


Exhibit AA-R-213
Page 1 of 1

Domestic Total Departures


June 2016
6,000

5,601

5,000

4,000

3,000

2,000

829

1,000

149

Frontier

Eastern

American

Delta

Source: OAG schedule data accessed March 3, 2016 for June 2016

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-214
Page 1 of 1

Of All the MIA-HAV Applicants, American Accounts for


85% of All the MIA Domestic Departures
Domestic Total Departures
June 2016
Frontier
2.3%

Eastern
0.0%

Delta
12.6%

American
85.1%

Source: OAG schedule data accessed March 3, 2016 for June 2016

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-215
Page 1 of 1

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
Frontier
2.8%

Eastern
0.0%

Delta
13.8%

American
83.5%

Source: OAG schedule data accessed March 3, 2016 for June 2016

#aacuba

American Flies More Than 5x the Number of Domestic Seats from MIA as the
Other Three MIA-HAV Applicants Combined

DOT Docket OST-2016-0021


Exhibit AA-R-216
Page 1 of 1

Domestic Departing Seats


June 2016
800,000

737,931

700,000
600,000
500,000
400,000
300,000
200,000

121,650
100,000

24,592

American

Delta

Frontier

Eastern

Source: OAG schedule data accessed March 3, 2016 for June 2016

#aacuba

American Flew More Than Five Times the Number of Domestic Passengers at
MIA Than the Three Other MIA-HAV Applicants Combined

DOT Docket OST-2016-0021


Exhibit AA-R-217
Page 1 of 1

Domestic Passengers
Year End November 2015
18,000,000

16,851,872

16,000,000
14,000,000
12,000,000
10,000,000
8,000,000
6,000,000
4,000,000

2,481,327
2,000,000

604,301

American

Delta

Frontier

Eastern

Source: U.S. DOT T-100

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-218
Page 1 of 1

Of All the MIA-HAV Applicants, American Accounted for


84.5% of All MIA Domestic Passengers
Domestic Passengers
Year End November 2015
Frontier
3.0%

Eastern
0.0%

Delta
12.4%

American
84.5%

Source: U.S. DOT T-100

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-219
Page 1 of 1

American Has the Longest and Deepest Experience in U.S.-Cuba


Flights and Operational Know-How in the Unique Cuba Market

25 years of continuous service almost twice as long as next U.S. airline more years than Delta,
Southwest, Frontier, Alaska, and Sun Country combined

More charter flights than any other applicant


628

2015 U.S.-Havana Charter Flights


383
329
169

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 Cubas 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

#aacuba

The Importance of Knowing the Unique Cuba Aviation Structure Was Highlighted
on the Floor of the U.S. Senate

DOT Docket OST-2016-0021


Exhibit AA-R-220
Page 1 of 1

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 taskthose with
experience.

#aacuba

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

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

DOT Docket OST-2016-0021


Exhibit AA-R-301
Page 1 of 1

16

15.0
14

13.0
12

12.2

10

4.0

Total Daily Frequencies Requested by U.S. Carriers


at Each Proposed U.S. Gateway

4.0

Allocation of Available 20 U.S.-Havana Daily


Frequencies Based on Cuban-American Population

3.0
2.1

2.1

2.0

1.3
1.2

1.2

0.9

0.7

0.7

0.6

0
MIA

EWR

FLL

TPA

LAX

JFK

PBI

1.0
0.3

0.4

0.3

0.3

RSW

MCO

ORD

0.1
0.3

0.3

IAH

ATL

1.0

1.0

0.7

0.1
0.2

0.2

0.2

IAD

DFW

BOS

0.1
EYW

1.0

1.0

0.3
0.1
JAX

0.3
0.1
CLT

Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds Application (Exhibit UA-112).

0.0
DEN

0.0
MSP

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-302
Page 1 of 1

American Airlines Request for 10 Daily MIA-HAV Flights Is Less Than


MIAs Proportionate Share Even Before Adjusting for Any Growth,
Which Will Be Greater at MIA Than Anywhere Else

Proposed Daily Frequencies to Havana vs.


Daily Frequencies as per Proportionate Share of Cuban-American Population
16

15

14

12.2

American under-requests
MIA-HAV frequencies by 20%

12

10
10
8
6
4
2
0
Total Daily MIA-HAV
Frequencies Requested by All
Applicants

Daily MIA-HAV Frequencies per


% of Cuban-American
Population

American's Request for MIAHAV 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 Uniteds Application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-303
Page 1 of 1

In Contrast to Americans MIA-HAV Frequency Request, JetBlues


Requests for U.S.-HAV Frequencies Are Excessive to Current and
Anticipated Demand from JetBlues Requested U.S. Gateways
In Rebuttal to Exhibit B6-101

Proposed Daily Frequencies to Havana vs.


Daily Frequencies as per Proportionate Share of Cuban-American Population
15
14
13

13.0

12

Space between red line and


top of B6 bar represents
B6s excess ask over
proportionate share of U.S.HAV frequency allocation

11
10
9

Total Frequencies Proposed

JetBlue (B6) Requests

7
Daily Frequencies per Cuban-American Population Share

6
5

4.0

4.0

3.0

3
2
1

4.0
2.0

1.2

2.0

1.0
0.3

FLL
Total

B6

TPA
Total
B6

MCO
Total
B6

2.0
0.7
JFK
Total
B6

2.1
1.2

1.0

1.0

1.0

0.2
EWR
Total
B6

BOS
Total
B6

Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds Application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-304
Page 4 of 4

In Contrast to Americans MIA-HAV Frequency Request, Southwests


Requests for U.S.-HAV Frequencies Are Excessive to Current and
Anticipated Demand from Southwests Requested U.S. Gateways
In Rebuttal to Southwest Application at page 2

Proposed Daily Frequencies to Havana vs.


Daily Frequencies as per Proportionate Share of Cuban-American Population
15
14
13

13.0

12
11
10
9
8
Total Frequencies Proposed

6.0

6
5

Daily Frequencies per Cuban-American Population Share

4.0

4.0

2.0

2
1

Southwest (WN) Requests

1.2

FLL
Total

1.0

0.9

0.3
TPA

WN

Total

MCO
WN

Total

Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds Application (Exhibit UA-112).

WN

#aacuba

In Contrast to Americans MIA-HAV Frequency Request, Alaskas


Requests for U.S.-HAV Frequencies Are Excessive to Current and
Anticipated Demand from Alaskas Requested U.S. Gateway

DOT Docket OST-2016-0021


Exhibit AA-R-305
Page 1 of 1

In Rebuttal to Alaska Application at page 4

3.0

Proposed Daily Frequencies to Havana vs.


Daily Frequencies as per Proportionate Share of Cuban-American Population
Total Frequencies Proposed

2.5

Alaskas (AS) Request

Daily Frequencies per Cuban-American Population Share

2.1

2.0

2.0

1.5

1.0

0.7
0.5

0.0
LAX
Total

AS

Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds Application (Exhibit UA-112).

#aacuba

In Contrast to Americans MIA-HAV Frequency Request, Spirits


Requests for U.S.-HAV Frequencies Are Excessive to Current and
Anticipated Demand from Spirits Requested U.S. Gateway

DOT Docket OST-2016-0021


Exhibit AA-R-306
Page 1 of 1

In Rebuttal Spirit Application at page 1

15

Proposed Daily Frequencies to Havana vs.


Daily Frequencies as per Proportionate Share of Cuban-American Population

14

13.0

13
12

Total Frequencies Proposed

11

Spirit (NK) Request

Daily Frequencies per Cuban-American Population Share

10
9
8
7
6
5
4
3

2.0

2
1

1.2

0
FLL
Total

NK

Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on the
allocation described in Uniteds Application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-307
Page 1 of 1

There Is More Cuban-American Population per Requested HAV Frequency at


MIA Than Any Other Requested U.S. Gateway

9,000

8,152
8,000

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

3,313

3,074

3,000

2,778

2,521

2,338

2,280

2,000

1,621

1,582
1,031

1,000

920

805
498

MIA

EWR

LAX

PBI

RSW

ATL

TPA

JFK

DFW

BOS

CLT

FLL

MCO

Notes: The higher the number, the more potential demand based on Cuban-American population, so a higher number means that relevant to other requested gateways, there
would be a shortage of frequencies at that gateway compared to other gateways. The lower number means an excess of frequencies compared to other requested gateways
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways. 2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority
(FedEx). 3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on
the allocation described in Uniteds application (Exhibit UA-112).

DEN

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-308
Page 1 of 1

There Is More Cuban-American Population per Requested HAV


Frequency at MIA Than Any Other Requested Florida Gateway

9,000

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)

8,000
7,000
6,000
5,000
4,000

3,074
3,000

2,778
2,338

2,000
1,000

920

805

FLL

MCO

MIA

PBI

RSW

TPA

Notes: The higher the number, the more potential demand based on Cuban-American population, so a higher number means that relevant to other requested gateways, there
would be a shortage of frequencies at that gateway compared to other gateways. The lower number means an excess of frequencies compared to other requested gateways
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways. 2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority
(FedEx). 3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on
the allocation described in Uniteds application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-309
Page 1 of 1

Service to MCO Ranked No Higher Than 5th in Any Applicants


Prioritization of Havana Routes

In Rebuttal to Delta Application at page 2, JetBlue Application at page 29, Southwest Application at page 16

Three Airlines Applied for MCO Service


Delta

JetBlue

Southwest

MCO was last on Deltas


prioritization list

Two other U.S. gateways


prioritized before MCO on
JetBlues list

MCO was last on Southwests


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)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-310
Page 1 of 1

Service to TPA Ranked No Higher Than 6th In Any Applicants


Prioritization of Havana Routes
In Rebuttal to JetBlue Application at page 29 and Southwest Application at page 16

Only Two Airlines Applied for TPA Service


JetBlue

5 other HAV routes prioritized before TPA

Southwest

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)

#aacuba

The FLL Applicants Attempt to Claim MIAs and Miami-Dade Countys 856,007
Cuban-Americans as Their Own Is Patently False

DOT Docket OST-2016-0021


Exhibit AA-R-311
Page 1 of 1

In Rebuttal to JetBlue Application, Southwest Application, and Spirit Application

The FLL Applicants Attempt to Enlarge Their Small Traffic Base


Should Be Rejected Out of Hand
The FLL Applicants Gloss Over Attempts
Number of Citations in the Applications
The Gloss
Over Language
South Florida
Ft. Lauderdale/Miami

# of Usages
27
12

The Reality
MIA is Miami-Dade Countys home airport (AA-609)
MIA is the home airport to Miami-Dade Countys
Cuban-American population (AA-607, AA-608, AA-609,
AA-610 )

Miami-Dade Countys Cuban-American population


does not travel to FLL (Testimony of Tessie Aral)

MIAs catchment area is 10x larger than FLLs (AA-611)


The historical demand for Cuba charter flights has
been in MIA, not FLL (Testimony of Tessie Aral, AA704, and AA-705)

If there were demand at FLL, charters would have


Source: Applications of JetBlue, Southwest and Spirit

operated there, but only few charters have done so


(Testimony of Tessie Aral )
#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-312
Page 1 of 1

FLL MIA
MIA, and MIA alone, is the home airport
for almost 50% of the entire
U.S. Cuban-American population and the
origin of 86% of the U.S. charter flights to Cuba

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-313
Page 1 of 4

Several Gateways Claim Broad U.S. Coverage to Cuba, But Only 4 Carrier
Gateways Can Legitimately Provide Connections to Most of the United States
All U.S. Gateways Proposed in This Proceeding
and Carriers Proposing That Service

SY

B6
MSP

BOS

2D
AA
UA

B6
UA
ORD

2D
B6
DL

EWR JFK

UA

F9

IAD

DEN

AA
2D
AA
AS

CLT

LAX

DL
ATL

AA
DFW

B6
DL
WN

UA
IAH

B6
WN

3M
SY
3M

JAX

3M

MCO
PBI

TPA

RSW

FLL
MIA

EYW

HAV

3M

B6
DL
WN

3M
B6
NK
AA
WN
DL
EA
F9
FX

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-313
Page 2 of 4

To Cuba, Several Gateways Claim Broad U.S. Coverage, But Only 4 Carrier
Gateways Can Legitimately Provide Connections to Most of the United States

Gateways Remaining After Elimination of Proposals Offering Less than Daily Service
(and, Thus, Not Providing Comprehensive Coverage)

B6
BOS

B6
UA

B6
DL

EWR JFK

F9
DEN

AA

AS

CLT

LAX

DL
ATL

AA
DFW

B6
DL
WN
B6
WN

JAX

3M

MCO
PBI

TPA

FLL
MIA

Eliminated: AA/ORD (1x); AA/LAX (1x); 3M/EYW (5x); 3M/RSW (2x); UA/ORD (1x); UA/IAH (1x);
UA/IAD (1x); SY/RSW (2x); SY/MSP (2x); 2D/LAX (4x); 2D/ORD (4x); 2D/JFK (3x); FX/MIA (5x)

3M

B6
DL
WN

3M
B6
NK
AA
WN
DL
EA
F9

HAV

#aacuba

Several Gateways Claim Broad U.S. Coverage to Cuba, But Only 4 Carrier
Gateways Can Legitimately Provide Connections to Most of the United States

DOT Docket OST-2016-0021


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

Eliminated: B6/JFK (6); B6/EWR (0); B6/TPA (4); DL/JFK (2); DL/MCO (3); DL/MIA (2); F9/DEN (1);
F9/MIA (1); NK/FLL (15); SY/RSW (0); WN/MCO (10); WN/TPA (15); WN/FLL (20); UA/EWR (25)

AA

HAV

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-313
Page 4 of 4

The Result: Only 4 Carrier/Gateways That Can Legitimately Claim


Comprehensive U.S. Coverage Combinations

SEA

YUL

MSP
FSD

SLC
SFO

GRI

COS

DRO

LAS
LAX
PHX

SAN

SAF
ABQ

ELP

GCK

AMA

ROW

TUS

LBB
ABI
GRK
AUS

Carrier

Hub

# of Connections in
Both Directions with
Less Than 155% Circuity

DL

ATL

71

AA

CLT

68

AA

DFW

58

AA

MIA

52

MFE

BVT
MHT
ALB

BDL
HPN
EWR
LGA
JFK
ABE
PHL
MDT

BUF

DTW
CLE
PIT
ORD SBN
DSM
MDW FWA CMH CAK
PIA
IND
DAY
BWI
BMI
CVG
IAD
DCA SBY
CRW
MHK
SPI
HTS
CHO
LEX
MCI
RIC PHF
STL
LYH
SDF
ORF
COU
ROA
ICT
JLN
GSO
SGF
TRI
BNA
RDU EWN
TYS
OAJ
FAY
TUL
CLT
GSP AVL
XNA
MEM
ILM
CLT
CHA
OKC
GSP
HSV
LIT
CAE MYR
ATL
GTR
AGS
CHS
CHS
TXK
JAN MGM
DFW
MLU
SAV
SHV
JAX
PNS
TLH
AEX
IAH

SAT
LRD

YYZ

LNK
OMA

DEN

GJT

GRB
ATW
MKE
GRR
MSN

BPTLCH LFT BTR


HOU

MSY

GNV
TPA

BRO

Three of the Four


Gateways Are
American Hubs

BDA
EUROPE
LHR London Heathrow, UK
CDG Paris, France

MCO

MAD Madrid, Spain


BCN Barcelona, Spain

MIA

CRP

BOS
PVD

MXP Milan, Italy

EYW

HAV

Source: American Airlines, Diio June Schedules

#aacuba

Series 400:
American Airlines Rebuttal Exhibits
to JetBlue Airways

JetBlues Request for Four Daily FLL-HAV Flights Greatly Exceeds


FLL-HAVs Proportionate Share of the Total U.S.-HAV Frequency Allocation

DOT Docket OST-2016-0021


Exhibit AA-R-401
Page 1 of 1

In Rebuttal to JetBlue Application at page 18 and Exhibit B6-101

FLL-HAV Daily Frequencies


4.0
4

1.2
1

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 Uniteds
Application (Exhibit UA-112).

#aacuba

And, When Combined with the Requests of All Other FLL


Applicants, the FLL-HAV Frequency Request Is Off The Charts Excessive

DOT Docket OST-2016-0021


Exhibit AA-R-402
Page 1 of 1

In Rebuttal to JetBlue Application at page 18 and Exhibit B6-101

FLL-HAV Daily Frequencies


14

13.0

12
10
8
6
4
2

1.2

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 Uniteds
Application (Exhibit UA-112).

#aacuba

The Cuban-American Population of Broward County (FLLs Home)


Is Miniscule Compared to Miami-Dade Country (MIAs Home)

DOT Docket OST-2016-0021


Exhibit AA-R-403
Page 1 of 1

In Rebuttal to JetBlue Application at page 21

Cuban-American Population
900,000

856,007

800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000

83,713

Broward County
(FLL)

Miami-Dade County
(MIA)

Source: U.S. Census (2010)

#aacuba

JetBlue Tries to Claim that MIAs Traffic and Demand Are Also FLLs,
But It Just Isnt So

DOT Docket OST-2016-0021


Exhibit AA-R-404
Page 1 of 3

In Rebuttal to JetBlue Application at page 21

JetBlues Attempts
to Lump FLL and MIA
Cuban-American Population,
Traffic and Demand

South Floridas 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 . . . .

Furthermore, notwithstanding its proximity to


Miami International Airport (MIA), South
Florida locals generally prefer flying from
FLL. . .

The Reality

The people on the ground say it isnt so:

Miami International Airport has been and will


continue to be the principal gateway between
the U.S. and Cuba. Testimony of Alberto
Ibargen, AA Testimony T-5, p.2

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-2016-0021, March 14, 2016

Source: JetBlue Application (page 21)

#aacuba

JetBlue Tries to Claim that MIAs Traffic and Demand Are Also FLLs,
But It Just Isnt So

DOT Docket OST-2016-0021


Exhibit AA-R-404
Page 2 of 3

In Rebuttal to JetBlue Application at page 21

JetBlues Attempts
to Lump FLL and MIA
Cuban-American Population,
Traffic and Demand

South Floridas 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 Reality

The historical demand demonstrates it isnt


so:

69 FLL-HAV charter flights in 2015

2,918 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)

#aacuba

JetBlue Tries to Claim that MIAs Traffic and Demand Are Also FLLs,
But It Just Isnt So

DOT Docket OST-2016-0021


Exhibit AA-R-404
Page 3 of 3

In Rebuttal to JetBlue Application at page 21

JetBlues Attempts
to Lump FLL and MIA
Cuban-American Population,
Traffic and Demand

South Floridas 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 Reality

And JetBlues experience shows it isnt so:

JetBlue operated only a single weekly FLLHAV charter flight (while operating 54% more
from TPA). If greater FLL-HAV demand
existed, JetBlue (and others too) would have
operated more charter flights from FLL.

Furthermore, notwithstanding its proximity to


Miami International Airport (MIA), South
Florida locals generally prefer flying from
FLL. . .

Source: JetBlue Application (page 21)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-405
Page 1 of 1

And Other Applicants (Non-FLL Applicants) Have Said It Isnt So:


In Rebuttal to JetBlue Application at page 21

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)

. . . 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 . . .

. . . Fort Lauderdale and Miami are not


perfect substitutes, . . .
(Application, Page 5)
Miami is the preferred international
airport for South Florida
(DL Exhibit DL-405)

(Application, Page 6)
#aacuba

And One Applicant, Which Did Not Apply for FLL-HAV Service,
Admitted That FLLs Catchment Area Is One-Tenth the Size of MIAs

DOT Docket OST-2016-0021


Exhibit AA-R-406
Page 1 of 1

In Rebuttal to JetBlue Application at page 21


Airport Catchment Estimates
900,000

850,000

800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000

85,000

FLL

MIA

FLL = 10% of MIA

Source: Excerpts from Silver Airways Direct Exhibits (3M-11)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-407
Page 1 of 1

Historical Data Proves That MIA-HAV Demand Far Outstrips FLL-HAV Demand
In Rebuttal to JetBlue Application at page 21

2015 Charter Flights


2,918

3,000

2,500

2,000

1,500

1,000

500

69
0

FLL-HAV

MIA-HAV

Source: Havanatur charter data

#aacuba

JetBlues Havana Arriving Flights Involve a Change of Terminals at FLL


and Either a Walk Outside Between Terminals or a Connector Bus

DOT Docket OST-2016-0021


Exhibit AA-R-408
Page 1 of 1

In Rebuttal to Exhibit B6-102

JetBlue Fort Lauderdale-Hollywood International Airport

JetBlue
Domestic/
International
Departures
Here

Source: JetBlue / Fort Lauderdale-Hollywood International Airport

JetBlues HAV-FLL Arrivals Here

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-409
Page 1 of 1

While Americans Havana Arriving Flights Are All Under One Roof
In Rebuttal to Exhibit B6-102

American - Miami International Airport

Source: American Airlines

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-410
Page 1 of 1

JetBlues 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

BOS
SWF
EWR
JFK

DTW

LGA

PIT
BWI

SFO

DCA

LAS
LAX
SAN
CHS

JAX

FLL

15 Connections 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%.

HAV

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-411
Page 1 of 1

JetBlues 15 FLL-HAV Connections Cannot Compare to Americans


58 MIA-HAV Connections
In Rebuttal to Exhibit B6-103
American Airlines MIA-HAV Service
Will Connect to 58 Cities in Both Directions

SEA

YUL

ORD

DEN

EWR
JFK

CLE
BWI
IAD

CVG
MCI

LAS

GSO

BNA
MEM

LAX
PHX

PNS

SAT

RDU

CLT
BHM

IAH

ORF

ATL
CHS

DFW

AUS

DCA

RIC

SDF

STL

PHL

PIT

CMH

IND

SAN

BDL
LGA

DTW

SLC

SFO

BOS

YYZ

MSP

JAX

TLH

MSY

EUROPE
LHR London Heathrow, UK

GNV
TPA

BDA

CDG Paris, France

MCO

MAD Madrid, Spain


BCN Barcelona, Spain

MIA

MXP Milan, Italy

EYW

58 Connections in Both Directions


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

HAV

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-412
Page 1 of 1

JetBlues FLL-HAV Charter Experience Is Not Comparable or Even


Close to Americans MIA-HAV Charter Experience
In Rebuttal to Exhibit B6-101

FLL-HAV JetBlue vs. MIA-HAV American


January 2014 February 2016 Passengers Flown
18,000
16,000

B6 FLL-HAV

14,000

AA MIA-HAV

12,000
10,000
8,000
6,000
4,000
2,000
0

Jan 2014

Apr 2014

Jul 2014

Oct 2014

Jan 2015

Apr 2015

Source: JetBlue Application Exhibit B6-101 deconstructed by American to estimate flights operated and passengers
carried by B6 (herein after referred to as JetBlue Exhibit B6-101 Adjusted); American Airlines internal data

Jul 2015

Oct 2015

Jan 2016

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-413
Page 1 of 1

JetBlues 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


2014 2016
100%
90%
80%
70%

54.4%

60%
50%

47.7%

46.8%

40%
30%
20%
10%
0%

2014

2015

Jan - Feb 2016

While
Source: JetBlue Exhibit B6-101 Adjusted

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-414
Page 1 of 1

Americans MIA-HAV Charters Have Enjoyed Strong Load Factors


In Rebuttal to Exhibit B6-101

American Airlines MIA-HAV Load Factor


2014 February 29, 2016
100%
90%
80%

82.8%
75.8%

76.3%

2014

2015

70%
60%
50%
40%
30%
20%
10%
0%

Jan - Feb 2016

Source: American Airlines

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-415
Page 1 of 1

As Demonstrated, JetBlues FLL-HAV Charters Load Factors


Cannot Compare to Americans MIA-HAV Charters Load Factors
In Rebuttal to Exhibit B6-102
100%
90%
80%

75.8%

AA LF
Better By:
+59% and +28.1
LF Points

76.3%

AA LF
Better By:
+40% and +21.9
LF Points

82.8%

AA LF
Better By:
+77% and +36.0
LF Points

70%
60%
50%

54.4%
47.7%

46.8%

40%
30%
20%
10%
0%

JetBlue American
FLL-HAV MIA-HAV
2014

JetBlue American
FLL-HAV MIA-HAV
2015

JetBlue American
FLL-HAV MIA-HAV
2016 (Jan-Feb)

Source: American Airlines; Deconstruction of JetBlue Exhibit B6-101

#aacuba

JetBlues Double Daily JFK-HAV Request Exceeds JFK-HAVs


Proportionate Share of U.S.-Cuba Frequency Allocation

DOT Docket OST-2016-0021


Exhibit AA-R-416
Page 1 of 1

In Rebuttal to Exhibit B6-101

JFK-HAV Daily Frequencies


2.0
2.0

1.5

1.0
1.0

0.7
0.5

0.0

JetBlue Double Daily Request JFK- JFK-HAV Proportionate Share of


HAV
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 Uniteds
Application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-417
Page 1 of 1

JetBlues Double Daily JFK-HAV Request, When Combined with


Deltas Single Daily JFK-HAV Request, Would Allocate Far Greater
Frequencies to JFK-HAV Than Demand Warrants
In Rebuttal to Exhibit B6-101

JFK-HAV Daily Frequencies


3.0

3.0

2.5

2.0

1.5

1.0

0.7
0.5

0.0

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 Uniteds
Application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-418
Page 1 of 1

JetBlue Has Been Operating Charters in the JFK-HAV Market


Since 2015 . . . But Only Twice Weekly. If JFK-HAV Demand for a Daily or
Double Daily Flight Existed, Why Hasnt JetBlue Increased the Frequency?
In Rebuttal to JetBlue Application at page 30
JetBlues Current JFK-HAV
Charter Flight Schedule

JetBlues Current JFK-HAV


Charter Flight Schedule

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)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-419
Page 1 of 1

The Reason JetBlue Has Not Increased JFK-HAV Frequencies:


JetBlues JFK-HAV Load Factors Have Been Mediocre with
Only Two Weekly Flights
In Rebuttal to Exhibit B6-101

JetBlue JFK-HAV Load Factor


100%
90%
80%

67.4%

70%
60%

53.8%

50%
40%
30%
20%
10%
0%

2015

2016

Sources: JetBlue Application Direct Exhibit (B6-101) / American Airlines analysis

#aacuba

. . . So One Could Imagine What the Load Factor Would Be With


a Seven-Fold Increase in Service

DOT Docket OST-2016-0021


Exhibit AA-R-420
Page 1 of 1

In Rebuttal to Exhibit B6-101

Unattainable Stimulation Would


Be Required to Achieve Just a
60% Load Factor
2015-2016
JetBlue JFK-HAV Results
Load Factor:
Passengers:
Seats:

58.5%
8,674
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

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-421
Page 1 of 1

And This Would Be Without the Benefit of Significant JetBlue


Connections at JFK
In Rebuttal to Exhibit B6-103

JetBlues JFK-HAV Flight Would Have


Only 6 Connections in Both Directions
SEA

SYR
BOS

ROC
BUF

JFK

OAK

6 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%

#aacuba

The Modest Demand for JFK-HAV Service Is Not Surprising Given the Size of
the Cuban-American Population and the Historical Demand for JFK-HAV Service

DOT Docket OST-2016-0021


Exhibit AA-R-422
Page 1 of 1

In Rebuttal to JetBlue Application at pages 22-24

2015 Charter Flights to Havana


All Carriers

Cuban-American Population
900,000

856,007
3,000

2,918

800,000
2,500

700,000
600,000

2,000
500,000
1,500

400,000
300,000

1,000

200,000
500
100,000

47,880

70
0

Miami-Dade

New York State

MIA-HAV

JFK-HAV

Source: U.S. Census (2010) / Havanatur charter data / American Airlines

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-423
Page 1 of 1

JetBlues Request for Double Daily MCO-HAV Service Greatly


Exaggerates the Size of the MCO-HAV Market
In Rebuttal to Exhibit B6-101

Daily MCO-HAV Frequencies


2.0
2.0

1.5

1.0

0.5

0.3

0.0

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
UnitedsAapplication (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-424
Page 1 of 1

JetBlues Exaggerated MCO-HAV Request Is Made Worse by the Requests of Southwest and
Delta. When Combined, the Total MCO-HAV Requests Bear No Relationship to the Needs of or
Demand in the MCO-HAV Market
In Rebuttal to Exhibit B6-101

MCO-HAV Daily Frequencies


4.0
4.0
3.5
3.0
2.5

2.0
2.0
1.5

1.0

1.0

1.0
0.5

0.3

0.0

MCO-HAV
Proportionate Share
of U.S.-HAV
Frequency
Allocation

Delta MCO-HAV
Reqeust

Southwest MCOHAV 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 Uniteds
Application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-425
Page 1 of 1

MCOs Catchment Area Is 3.5% the Size of MIAs


In Rebuttal to JetBlue Application at page 25
Cuban American Population
850,000

900,000
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000

30,000

MCO

MIA

MCO = 3.5% of MIA

Source: Excerpt from Silver Airways Direct Exhibits (3M-11)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-426
Page 1 of 1

JetBlue Would Provide Only 5 Connections in Both Directions


For its MCO-HAV Flight
In Rebuttal to Exhibit B6-103

BOS
LGA
EWR
JFK

DCA

MCO

5 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%

HAV

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-427
Page 1 of 1

JetBlues TPA-HAV Request for Double Daily Service Over-Asks


Based on the Demand in the Market
In Rebuttal to Exhibit B6-101

TPA-HAV Daily Frequencies


2.0
2.0
1.8
1.6
1.4
1.2

0.9

1.0
0.8
0.6
0.4
0.2
0.0

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 Uniteds
Application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-428
Page 1 of 1

When Combined with Southwests Double Daily TPA-HAV Request,


the Total TPA-HAV Frequency Request Is Grossly Oversubscribed
In Rebuttal to Exhibit B6-101

TPA-HAV Daily Frequencies


4.0
4.0

3.0

2.0

0.9

1.0

0.0

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 Uniteds
Application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-429
Page 1 of 1

TPAs Catchment Area Is 10% the Size of MIAs


In Rebuttal to JetBlue Application at page 26
Cuban American Population
900,000

850,000

800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000

85,000

TPA

MIA

TPA = 10% of MIA

Source: Silver Airways Direct Exhibits (3M-11)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-430
Page 1 of 1

JetBlue Would Have Only 4 Connections in Both Directions for


Its TPA-HAV Service
In Rebuttal to Exhibit B6-103

BOS
LGA
EWR
JFK

TPA

4 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%

HAV

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-431
Page 1 of 1

TPAs Cuban-American Population (Hillsborough County)


Is a Fraction of MIAs (Miami-Dade County)
In Rebuttal to JetBlue Application at page 26

Cuban-American Population
900,000

856,007

800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000

65,451

Hillsborough County

Miami-Dade County

Source: U.S. Census (2010)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-432
Page 1 of 1

TPAs 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

16

Historical Demand

Current Demand

(as measured by
2015 charter flights)

(as measured by JetBlues


charter operation)

JetBlue
TPA-HAV Request

14.0

14
12
10
8
6
4

2.6

2.0

2
0

2015 Flights per Week

Current Charter Flights per


Week

JetBlue Proposed Flights per


Week

Source: Havanatur charter data

#aacuba

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

DOT Docket OST-2016-0021


Exhibit AA-R-433
Page 1 of 1

In Rebuttal to JetBlue Application at page 26 and Exhibit B6-101

Step 1:

Current JetBlue TPA-HAV Charter Flights per Week

Step 2:

Seats per Week on Current TPA-HAV Charter Flights

324

Step 3:

Passengers on TPA-HAV Charter Flights


(at 71% Load Factor)

230

Step 4:

Seats per Week on JetBlues Proposed 2x Daily


TPA-HAV Flights

2,268

Step 5:

Passengers on JetBlues Proposed 2x Daily


TPA-HAV Flights @ 71% Load Factor

1,620

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.

#aacuba

JetBlues Proposed EWR-HAV Service Must Be Considered an Extreme Reach


by JetBlue

DOT Docket OST-2016-0021


Exhibit AA-R-434
Page 1 of 1

In Rebuttal to JetBlue Application at pages 26-27

Scarce U.S.-Havana frequencies available


Uniteds proposed service + Uniteds 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

#aacuba

EWR-HAV Is JetBlues Next to Last Gateway Priority Among Its Six Proposed
U.S. Gateways to Havana (the Most of Any Applicant in This Proceeding)

DOT Docket OST-2016-0021


Exhibit AA-R-435
Page 1 of 1

In Rebuttal to JetBlue Application at page 29

1
1
2
1
3
4
2
1
5

Source: JetBlue Application (page 29)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-436
Page 1 of 1

JetBlue Would Have No Connections in Both Directions for Its EWR-HAV Service
In Rebuttal to Exhibit B6-103

EWR

0 Connections

Notes: Based on Summer (June 2016) Schedule from OAG; Maximum connection time is
4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%

HAV

#aacuba

JetBlues BOS-HAV Request for a Daily Service Is, at Best,


Aspirational, Not Realistic Now

DOT Docket OST-2016-0021


Exhibit AA-R-437
Page 1 of 1

In Rebuttal to JetBlue Application at pages 27-28

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 JetBlues last priority among its six requested U.S. gateways

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-438
Page 1 of 1

Bostons Cuban-American Population Is Small


In Rebuttal to JetBlue Application at pages 27-28
856,007

85,120 83,713

MIA

EWR

FLL

65,451

TPA

49,702 47,880 43,038

LAX

JFK

PBI

25,000 22,528 20,633 19,130 17,648 14,527 11,350 11,073


RSW

MCO

ORD

IAH

ATL

IAD

DFW

BOS

Source: U.S. Census (2010)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-439
Page 1 of 1

JetBlue Would Have Only 1 Connection in Both Directions for Its


BOS-HAV Service, and That Would Be to JFK
In Rebuttal to Exhibit B6-103

BOS
JFK

1 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

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-440
Page 1 of 1

BOS-HAV Is The Last of the Six JetBlue U.S. Gateway Priorities


In Rebuttal to JetBlue Application at page 29

1
1
2
1
3
4
2
1
5
6

Source: JetBlue Application (page 29)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-441
Page 1 of 1

Notwithstanding JetBlues Self-Laudatory Claims, American Outshines JetBlue


In Rebuttal to Exhibit B6-102
Americans Average Fleet Age for Cuba
Service Is Younger Than JetBlues*
9.0

9.0

American Has a Better On-Time Performance


at MIA Than JetBlue does at FLL and a
Much Larger Operation
77%

76.5%

76%
8.9

8.9

75%

74.1%

8.8

74%
73%

8.7

72%
8.6
71%
8.5

70%

American

jetBlue

American - MIA

Source: Diio Mi Fleet Data (as of March 8, 2016) / U.S. DOT On-Time Performance data via Diio Mi
* Average age of fleet: In-service fleet type of American (737-800 and A319) and JetBlue (A320/321) for Cuba service.

JetBlue - FLL

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-442
Page 1 of 1

JetBlue Touts Its Customer Service Advantages, But Americans 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
American

JetBlue

Wi-Fi
House wine, beer and spirits
Light snacks as well as coffee, specialty coffee
drinks, tea and soft drinks
Personal use computers with Internet access
Cyber-cafes
Power outlets to help you stay connected
Work areas with access to copiers and printers
Shower suites
Childrens play areas
Personal travel assistance with your reservations

Business Class

Premium Economy Cabin*


Lounge(s) at MIA (AA)
and FLL (B6)
Complimentary Amenities
at Lounges

Sources: Company websites


* Premium cabin denotes Main Cabin Extra for American and Even More Space for JetBlue.

#aacuba

Series 500
American Airlines Rebuttal Exhibits
to Southwest Airlines

Southwests FLL-HAV Request for Six Daily Frequencies Vastly Exceeds


FLL-HAVs Proportionate Share of the U.S.-Havana Frequency Allocation

DOT Docket OST-2016-0021


Exhibit AA-R-501
Page 1 of 1

In Rebuttal to Southwest Application at page 2

FLL-HAV Daily Frequencies

6.0
6

1.2
1

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 Uniteds
Application (Exhibit UA-112).

#aacuba

Southwests 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

DOT Docket OST-2016-0021


Exhibit AA-R-502
Page 1 of 1

In Rebuttal to Southwest Application at page 2

FLL-HAV Daily Frequencies


16

15.0

14

13.0

12

10.0
10

1.2

Proportionate Share of
FLL-HAV Frequency
Allocation

All FLL-Applicants
Requests For FLL-HAV

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 Uniteds
Application (Exhibit UA-112).

#aacuba

Southwests Request for Six Daily FLL-HAV Frequencies Is Far Above and
Beyond Current Demand and Any Reasonable Forecast of Expected Demand

DOT Docket OST-2016-0021


Exhibit AA-R-503
Page 1 of 1

In Rebuttal to Southwest Application at page 2

FLL-HAV 2015 Charter Flights vs.


2017 Proposed Southwest FLL-HAV Flights
4,380

4,500
4,000
3,500
3,000
2,500
2,000
1,500
1,000
500

69
0

2015 Total FLL-HAV Charter Flights

2017 Southwest FLL-HAV Flights (6 Daily)

Source: Havanatur charter data

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-504
Page 1 of 1

Southwests FLL-HAV Service Would Have Only 20 Connections


in Both Directions
In Rebuttal to Exhibit WN-102

ALB

MKE

MDW

PVD
ISP

PIT
CMH
BWI
DCA

DEN
MCI

STL
RDU
ATL

PHX
DAL

AUS

HOU

MSY
TPA

FLL

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%

HAV

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-505
Page 1 of 1

FLLs Catchment Area Is 10% the Size of MIAs


In Rebuttal to Exhibit WN-201 and WN-202

900,000

Airport Catchment Estimates


850,000

800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000

85,000

FLL

MIA

FLL = 10% of MIA

Source: Excerpts from Silver Airways Direct Exhibits (3M-11)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-506
Page 1 of 1

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

Southwests Historical Presence in Cuba and FLL

0 Charter Flights
to Cuba

0Charter Flights
to Havana

0 Charter Flights
FLL-HAV

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-507
Page 1 of 1

In Order to Operate Six Daily Flights at Just 70% Load Factor (Well Below Its Average
Load Factor), Southwest Would Have to Stimulate the FLL-HAV Market by 4,860%,
Assuming All 2015 FLL-HAV Charter Flights Operated at a 100% Load Factor*
In Rebuttal to Southwest Appendix 1

Step 1:

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


(assuming 100% Load Factor)

11,040

Step 4:

Seats on Southwests Proposed 6 Daily FLL-HAV


Flights

766,500

Step 5:

Passengers on Southwests Proposed 6 Daily


FLL-HAV Flights @ 70% Load Factor

536,550

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%.

#aacuba

Southwests Request for Double Daily TPA-HAV Frequencies


Exceeds TPA-HAVs Proportionate Share of U.S.-Havana Frequency Allocation

DOT Docket OST-2016-0021


Exhibit AA-R-508
Page 1 of 1

In Rebuttal to Southwest Application at page 2

TPA-HAV Daily Frequencies


2.0
2.0
1.8
1.6
1.4
1.2

0.9

1.0
0.8
0.6
0.4
0.2
0.0

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 Uniteds
Application (Exhibit UA-112).

#aacuba

Southwests TPA-HAV Double Daily Request, When Combined with


JetBlues Double Daily TPA-HAV Request, Is Excessive to TPA-HAVs
Proportionate Share of U.S.-HAV Frequency Allocation

DOT Docket OST-2016-0021


Exhibit AA-R-509
Page 1 of 1

In Rebuttal to Southwest Application at page 2

TPA-HAV Daily Frequencies


4.0
4

0.9

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 Uniteds
Application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-510
Page 1 of 1

Southwests 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

16
14

Historical Demand

Current Demand

(as measured by
2015 charter flights)

(as measured by JetBlues


charter operation)

Southwest
TPA-HAV Request

14.0

12
10
8
6
4

2.6

2.0

2
0

2015 Flights per Week

Current Charter Flights per Week

Southwest Proposed Flights per


Week

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-511
Page 1 of 1

Southwest Has No Experience in the TPA-HAV Market


In Rebuttal to Southwest Application at page 17

Southwests Historical Presence in Cuba and TPA

0 Charter Flights
to Cuba

0Charter Flights
to Havana

0 Charter Flights
TPA-HAV

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-512
Page 1 of 1

Southwests TPA-HAV Service Would Have Only


15 Connections in Both Directions
In Rebuttal to Exhibit WN-104

BDL

PVD

ISP
MDW

CMH

CAK

IND
MCI

PHL
BWI

SDF
RDU

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%

TPA

HAV

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-513
Page 1 of 1

TPAs Catchment Area Is 10% the Size of MIAs


In Rebuttal to Exhibit WN-201 and WN-202
Cuban American Population
850,000

900,000
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000

85,000

TPA

MIA

TPA = 10% of MIA

Source: Excerpts from Silver Airways Direct Exhibits (3M-11)

#aacuba

TPA-HAV Was Southwests Second to Last Priority Out of Nine


Proposed HAV Services

DOT Docket OST-2016-0021


Exhibit AA-R-514
Page 1 of 1

In Rebuttal to Southwest Application at page 16

1
1
1
1
1
1
2
2
3

Source: Southwest Application (page 16)

#aacuba

Southwests MCO-HAV Request for a Daily Frequency Allocation,


When Combined with the Other Requests, Greatly Exceeds MCO-HAVs
Proportionate Share of U.S.-HAV Frequency Allocation

DOT Docket OST-2016-0021


Exhibit AA-R-515
Page 1 of 1

In Rebuttal to Southwest Application at page 2

MCO-HAV Daily Frequencies


4

4.0
Southwest
1

Delta
1
2

JetBlue
2

0.3
0

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 Uniteds
Application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-516
Page 1 of 1

Southwests MCO-HAV Service Would Provide Only 10 Connections


in Both Directions
In Rebuttal to Exhibit WN-106

MKE

PVD
PIT

MCI

STL

PHL

SDF

ATL

HOU

MSY

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%

MCO

HAV

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-517
Page 1 of 1

Southwest Has No Experience in the MCO-HAV Market


In Rebuttal to Southwest Application at page 17

Southwests Historical Presence in Cuba and MCO

0 Charter Flights
to Cuba

0Charter Flights
to Havana

0 Charter Flights
MCO-HAV

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-518
Page 1 of 1

MCOs Catchment Area Is 3.5% the Size of MIAs


In Rebuttal to Exhibit WN-201 and WN-202

900,000

Cuban American Population


850,000

800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000

30,000

MCO

MIA

MCO = 3.5% of MIA

Source: Excerpts from Silver Airways Direct Exhibits (3M-11)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-519
Page 1 of 1

MCO-HAV Had Only 65 Charter Flights In 2015


In Rebuttal to Exhibit WN-201

MCO-HAV vs. MIA-HAV Operated Charter Flights


2015
2,918

3,000

2,500

2,000

1,500

1,000

569
500

65
0

MCO-HAV Charter Flights

AA Operated MIA-HAV Charter Flights

MIA-HAV Charter Flights

Source: Havanatur charter data / American Airlines

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-520
Page 1 of 1

MCO-HAV Was Southwests Last Priority Out of Nine Proposed HAV Services
In Rebuttal to Southwest Application at page 16

1
1
1
1
1
1
2
2
3

Source: Southwest Application (page 16)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-521
Page 1 of 1

Southwests 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 wont.
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 Ill concoct a forecast to show
that methodology requires that this
forecast be discarded because it is
entirely discredited.

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-522
Page 1 of 1

Southwests Use of Canada MIDT Data in Its Forecast Is Just Plain Wrong
In Rebuttal to Southwest Appendix 1

American Comment:
Southwest used Canada MIDT passenger
data to Cuba as a surrogate for U.S.-Cuba
data. However, Canada MIDT data
includes leisure/tourism passengers that
U.S. carriers are prohibited from taking to
Cuba, and leisure/tourism passengers are
the overwhelming majority of Canadian
passengers to Cuba. Therefore, the
methodology is totally flawed, and the
forecast is not credible.

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-523
Page 1 of 1

Southwests Forecast for Proposed FLL-VRA Service Is Filled with Flaws


In Rebuttal to Southwest Appendix 1
Southwest Forecast Passengers

2015 Charters
4,000

1,200,000

1,026,720
1,000,000

3,505
1,005,327

3,500
3,000

800,000
2,500
600,000

2,000
1,500

400,000

1,000
200,000
500

26

FLL/MIA-VRA Total
Passengers

FLL/MIA-HAV Total
Passengers

VRA

HAV

American Comment:
Incredibly, Southwest forecasts more Varadero passengers than Havana passengers. That result discredits completely the
methodology. The fact that, in 2015, 135 times more charters operated to HAV than VRA (3,505 flights to 26) puts this point to
rest. However, if Southwest believes its own forecast, it should apply for FLL/MCO/TPA-VRA frequencies instead of HAV
frequencies.
Source: Southwest Application; Havanatur charter data

#aacuba

Series 600:
General Rebuttal Exhibits
to Delta Air Lines

ATL, Like CLT and DFW, Provides Broad Coverage of the U.S.-HAV Markets
Not Served by American Over MIA

DOT Docket OST-2016-0021


Exhibit AA-R-601
Page 1 of 2

In Rebuttal to Delta Application at page 4, Exhibits DL-303, DL-304, and DL-305

Deltas ATL-HAV
Connections

Americans 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%.

#aacuba

ATL, Like CLT and DFW, Provides Broad Coverage of the U.S.-HAV Markets
Not Served by American Over MIA

DOT Docket OST-2016-0021


Exhibit AA-R-601
Page 2 of 2

In Rebuttal to Delta Application at page 4, Exhibits DL-303, DL-304, and DL-305

Deltas ATL-HAV
Connections

Americans DFW-HAV
Connections

MSP
SLC
GJT
DRO

LAS
PHX
TUS

GRI OMA

DEN
COS

SAF
ABQ
ROW
ELP

GCK
AMA
LBB
ABI

DSM

PIA
BMI
MHK
SPI
MCI
STL
ICT JLNCOU
SGF
TUL XNA
OKC
LIT

DFW

TXK
SHVMLU
AEX

GRK
LCHLFT
BTRMSY
AUS IAH BPT
HOU
SAT
LRD
CRP
MFE BRO

HAV

71 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%.

52 Connections in Both Directions

#aacuba

Deltas 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

DOT Docket OST-2016-0021


Exhibit AA-R-602
Page 1 of 1

In Rebuttal to Delta Application at pages 2-3 and Exhibit DL-205

Deltas JFK Request Versus


All JFK Requests and All JFK/EWR Requests
6

5.1
5

3.0
3

1.9

1.0
1

0.7

Delta JFK Request

JFK Proportionate
Share

Total JFK Requests

JFK/EWR
Proportionate Share

JFK/EWR Frequency
Requests

Note: Excludes Dynamic

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-603
Page 1 of 1

Deltas 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

Notes: Based on Summer (June 2016) Schedule from OAG; Maximum connection time is
4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%.

HAV

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-604
Page 1 of 1

Deltas Daily JFK-HAV Request Is Excessive to Historical


JFK-HAV Charter Demand
In Rebuttal to Delta Application at pages 2-3

Charter Demand (Calendar Year 2015)


MIA-HAV vs. JFK-HAV
3,500

3,000

2,918

2,500

2,000

1,500

1,000

500

70
0

MIA-HAV

JFK-HAV

Sources: Havanatur 2015 charter data / American Airlines

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-605
Page 1 of 2

Deltas 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
Deltas frequent flyer membership in Miami-Dade County is significantly smaller
than Americans

SkyTeam does not have a significant presence at MIA


Delta connects to only 2 U.S. cities in both directions versus Americans 58

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-605
Page 2 of 2

Deltas 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

Notes: Based on Summer (June 2016) Schedule from OAG and Delta Application; Maximum
connection time is 4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%.

HAV

#aacuba

Deltas Other Attempt to Operate a Non-Hub International


Flight at MIA Did Not Go Well or Last Long

DOT Docket OST-2016-0021


Exhibit AA-R-606
Page 1 of 1

In Rebuttal to Delta Application at pages 4-5 and page 7

MIA-LHR:

Inaugurated: March 2011


Terminated: April 2012
Duration: ~13 months

Source: OAG Schedules

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-607
Page 1 of 1

And Deltas Current Non-Hub International Flight at PHL Is Not Going Well
In Rebuttal to Delta Application at pages 4-5 and page 7

Delta PHL-LHR Load Factor

100%
90%
80%
70%
60%

48%

50%

51%

55%
38%

36%

40%
30%
20%

19%

10%
0%

Apr-15

May-15

Jun-15

Jul-15

Aug-15

Sep-15

Source: U.S. DOT T-100

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-608
Page 1 of 1

Deltas 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

MCO-HAV Daily Frequencies


4.5

4.0
4.0
3.5
3.0
2.5
2.0
1.5

1.0
1.0
0.5

0.3

0.0

Proportionate Share of
MCO-HAV Frequency Allocation

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 Uniteds
Application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-609
Page 1 of 1

Deltas 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

Notes: Based on Summer (June 2016) Schedule from OAG and Delta Application; Maximum
connection time is 4 hours; Minimum connection time is 55 minutes; Maximum circuity is 155%.

HAV

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-610
Page 1 of 1

MCOs Catchment Area Is 3.5% the Size of MIAs


In Rebuttal to Delta Application at pages 5-6 and Exhibit DL-502, DL-503
Cuban American Population
850,000

900,000
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000

30,000

MCO

MIA

MCO = 3.5% of MIA

Source: Excerpt from Silver Airways Direct Exhibits (3M-11)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-611
Page 1 of 1

MCO-HAV Has Experienced Very Little Charter Activity,


and Nothing Compared to MIA-HAV
In Rebuttal to Delta Application at page 6

2015 Charter Flights to Havana


3,000

2,918

2,500

2,000

1,500

1,000

500

65
0

MIA-HAV

MCO-HAV

Sources: Havanatur charter data / American Airlines

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-612
Page 1 of 1

Delta Has Operated No Charter to Havana from MCO


In Rebuttal to Delta Application at page 6

2015 Charter Flights to Havana


600

569

500

400

300

200

100

0
0

AA MIA-HAV

DL MCO-HAV

Sources: Havanatur charter data / American Airlines

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-613
Page 1 of 1

MCO-HAV Was Deltas Last Priority Among Proposed Routes


In Rebuttal to Delta Application at page 2

Source: Delta Application (page 2)

#aacuba

While No Forecast Was Required, and Any Forecast in the


U.S.-Cuba Market Is Fraught with Unknowns, Deltas Forecast
Is at Best a Guesstimate with No Basis in Fact or Data

DOT Docket OST-2016-0021


Exhibit AA-R-614
Page 1 of 1

In Rebuttal to Delta Exhibit DL-601, DL-602, DL-603, DL-604, and DL-605

No share methodology
No base traffic data assumption
No stimulation assumptions

#aacuba

Series 700:
American Airlines Rebuttal Exhibits
to Frontier Airlines

Frontiers Request for the First Two of Its Three Proposed Daily
MIA-HAV Flights Is Tied to Frontier Also Receiving DEN-HAV
Frequencies, and There Is No Basis or Demand for DEN-HAV Service

DOT Docket OST-2016-0021


Exhibit AA-R-701
Page 1 of 1

In Rebuttal to Frontier Application at page 8 and Exhibit A

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)

#aacuba

DEN-HAVs Proportionate Share of U.S.-Havana Frequency


Allocation Is Zero, Yet Frontier Requests a Daily DEN-HAV Frequency

DOT Docket OST-2016-0021


Exhibit AA-R-702
Page 1 of 1

In Rebuttal to Frontier Application at pages 1, 7, and 8

DEN-HAV Daily Frequencies


2.0
1.8
1.6
1.4
1.2

1.0
1.0
0.8
0.6
0.4
0.2

0
0.0

Frontier DEN-HAV Request

DEN-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 Uniteds
Application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-703
Page 1 of 1

Frontier Has Never Operated Charter Flights to Cuba


In Rebuttal to Frontier Application at page 2

Frontiers Historical Presence in Cuba

2015
By All Applicants

January 1, 2014 February 29, 2016


By Frontier

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-704
Page 1 of 1

Cuban-American Population in Denver


In Rebuttal to Frontier Application at page 7

Cuban-American Population
2010

1,000,000
900,000

856,007

800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000

49,702

20,633

11,350

7,217

3,487

ORD

DFW

CLT

DEN

Miami-Dade (MIA)

LAX

Source: U.S. Census Bureau (201)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-705
Page 1 of 1

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)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-706
Page 1 of 1

Frontiers 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

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%.

HAV

#aacuba

Series 800:
American Airlines Rebuttal Exhibits
to Spirit Airlines

Spirits Request for Two Daily FLL-HAV Frequencies Exceeds FLLs


Proportionate Share of the U.S.-Havana Frequency Allocation

DOT Docket OST-2016-0021


Exhibit AA-R-801
Page 1 of 1

In Rebuttal to Spirit Application at page 2 and Exhibit NK-CU-1

FLL-HAV Daily Frequencies


2.5

2.0
2.0

1.5

1.2
1.0

0.5

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 Uniteds
Application (Exhibit UA-112).

#aacuba

Spirits Request, Combined with the Other FLL-HAV Requests,


Is Off the Chart Excessive Compared to Actual Current Demand
and Any Expectation of Future Demand

DOT Docket OST-2016-0021


Exhibit AA-R-802
Page 1 of 1

In Rebuttal to Spirit Application at page 2 and Exhibit NK-CU-1


Spirits FLL-HAV Request Is
>1.5x Greater than FLL-HAVs Proportionate
Share and All FLL-HAV Applicants Requests Are
11x More Than FLL-HAVs Proportionate Share
14

13.0

Americans MIA-HAV Request Is Less Than


MIA-HAVs Proportionate Share

12.2

12

10.0
10
8
6
4

1.2

2
0
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 Uniteds
Application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-803
Page 1 of 1

FLLs Catchment Area Is 10% the Size of MIAs


In Rebuttal to Spirit Application at pages 2-3 and Exhibit NK-CU-1

900,000

Airport Catchment Estimates


850,000

800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000

85,000

FLL

MIA

FLL = 10% of MIA

Source: Excerpts from Silver Airways Direct Exhibits (3M-11)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-804
Page 1 of 1

Spirit Has No Cuba Experience


In Rebuttal to Spirit Application at pages 3-4

Spirit Charter Flights to Cuba


From Spirits Inception 2015

Charter Flights to Cuba


Jan 1, 2014 Feb 29, 2016

2,500

2,500

2,000

2,000

1,500

1,500

1,000

1,000

500

500

2,327

0
0

Inception

2015

Spirit

American

Source: American Airlines / Havanatur charter data / U.S. DOT T-100

#aacuba

There Has Been Miniscule Demand for Charter Flights from


FLL to HAV or Anywhere in Cuba Thats Highly Probative of Future Demand

DOT Docket OST-2016-0021


Exhibit AA-R-805
Page 1 of 1

In Rebuttal to Spirit Application at pages 3-4

2015 Charter Flights


MIA/FLL-HAV

2015 Charter Flights


U.S.-Cuba

4,348

4,500

2,918

3,000

4,000
2,500
3,500
2,000

3,000
2,500

1,500
2,000
1,000

1,500
1,000

500
500

70

54

Spirit

Other
Applicants

FLL

MIA

MIA

Source: American Airlines / Havanatur charter data

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-806
Page 1 of 1

Spirits 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

LGA

DTW
ORD

ACY
BWI

MYR

ATL
DFW

TPA

MCO

FLL

10 Connections 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%.

HAV

#aacuba

Series 900:
American Airlines Rebuttal Exhibits
to United Airlines

Uniteds Request for a Daily EWR-HAV Service Is in Line with


Its Proportionate Share of U.S.-Havana Frequencies

DOT Docket OST-2016-0021


Exhibit AA-R-901
Page 1 of 1

In Rebuttal to United Application at page 1, Exhibits UA-116, UA-120, and UA-130 to UA-137

Uniteds EWR-HAV Service


7 Weekly Frequencies (Not 8)

United at EWR Would Provide


Modest Connectivity to 25 Connections
in Both Directions

1.3

1.2
1.2
1.2
1.1
1.1

1
1.0
1.0
0.9

Daily Frequencies per %


of Cuban-American
Population

United's Request

25 Connections in Both Directions

#aacuba

But Uniteds EWR-HAV Request Plus JetBlues Daily EWR-HAV Service Request
Exceeds EWRs Proportionate Share of the U.S. EWR-HAV Frequency Allocation

DOT Docket OST-2016-0021


Exhibit AA-R-902
Page 1 of 1

In Rebuttal to United Application at page 1, Exhibit UA-116, and UA-120

All EWR-HAV Requests vs. Proportionate Share of EWR-HAV Allocation


2.5

2.1
2.0

1.5

1.2

1.1

1.0

0.5

0.0

All EWR-HAV Requests

EWR-HAV
Proportionate
EWR-HAV
Proportionate
Share of United's Full EWR-HAV Request
Share
of U.S.-HAV
U.S.-HAV
Frequency
Allocation
Frequency Allocation

Notes:
1/ Daily frequencies per % of Cuban-American population were calculated based on total 20 daily frequencies to Havana for allocation multiplied by % of Cuban-American
population in each proposed U.S. gateways.
2/ Excludes carriers without necessary scheduled foreign authority (Eastern and Dynamic) and requested cargo-only authority (FedEx).
3/ Cuban-American population: U.S. Census (2010) - County (FL gateways), MSA (Other gateways), MSA population distribution between EWR and JFK based on Uniteds
Application (Exhibit UA-112).

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-903
Page 1 of 1

Uniteds 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
80

68

70

58

60

52
50

40

30

25

20

10

AA @ CLT

Source: American Airlines analysis

AA @ MIA

AA @ DFW

UA @ EWR

#aacuba

Uniteds 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

DOT Docket OST-2016-0021


Exhibit AA-R-904
Page 1 of 1

In Rebuttal to Exhibits UA-117 and UA-121


Saturday

Monday, Tuesday, Wednesday, Thursday, Friday, and Sunday

EWR

IAH

HAV

IAH

2:50 Elapsed Time (Northbound)

290% Circuity

2:30 Elapsed Time (Southbound)

9:51 Elapsed Time (Northbound)

HAV

17:03 Elapsed Time (Southbound)


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.

#aacuba

Uniteds 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

DOT Docket OST-2016-0021


Exhibit AA-R-905
Page 1 of 1

In Rebuttal to Exhibits UA-118 and UA-122


Saturday

Monday, Tuesday, Wednesday, Thursday, Friday, and Sunday

IAD

EWR
IAD

HAV

3:00 Elapsed Time (Northbound)

6:20 Elapsed Time (Northbound)

3:10 Elapsed Time (Southbound)

7:53 Elapsed Time (Southbound)

Note: Northbound connects to UA EWR-IAD Flight 4900 departing at 19:37 with a layover of 1:24; Southbound
begins with UA IAD-EWR Flight 4933 arriving at 7:31 with a layover of 2:47.
Source: OAG June 2016 Schedule.

HAV

#aacuba

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

DOT Docket OST-2016-0021


Exhibit AA-R-906
Page 1 of 1

In Rebuttal to Exhibits UA-119 and UA-123


Saturday

Monday, Tuesday, Wednesday, Thursday, Friday, and Sunday

ORD

ORD

EWR

HAV

3:35 Elapsed Time (Northbound)

7:16 Elapsed Time (Northbound)

3:30 Elapsed Time (Southbound)

6:53 Elapsed Time (Southbound)

Note: Northbound connects to UA EWR-ORD Flight 3305 departing at 19:30 with a layover of 1:17; Southbound
begins with UA ORD-EWR Flight 1626 arriving at 8:58 with a layover of 1:20.
Source: OAG June 2016 Schedule

HAV

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-907
Page 1 of 1

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
1,000

800

600

400

200

0
0

American

United

Source: U.S. DOT T-100 (Non-scheduled passenger flights) / American Airlines

#aacuba

Series 1000:
American Airlines Rebuttal Exhibits
to Alaska Airlines

DOT Docket OST-2016-0021


Exhibit AA-R-1001
Page 1 of 1

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-1
2.5

2.0
2.0

1.5

1.0

0.7
0.5

0.1
0.0

LAX-HAV
Proportionate Share
of U.S.-Havana
Frequency Allocation

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 Uniteds
Application (Exhibit UA-112).

#aacuba

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

DOT Docket OST-2016-0021


Exhibit AA-R-1002
Page 1 of 1

80%

72%
70%

60%

<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: Alaskas load factor is based on its forecast of annual passenger traffic of 190,000 and calculated annual seat capacity of 264,260 (181-seat B737-900ER aircraft).
* American is prevented from disclosing the exact LAX-HAV load factor by its contract with the charter operator.

#aacuba

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?

DOT Docket OST-2016-0021


Exhibit AA-R-1003
Page 1 of 1

In Rebuttal to Exhibit AS-1


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%

58,400

602%

2x Daily

<50%

116,800

1,304%

1x Daily

70.0%

81,760

980%

2x Daily

70.0%

163,520

2,060%

If there were greater demand in the LAX-HAV market, American would have increased its
frequencies from one weekly

There are and will be multiple ways to get to Havana from Los Angeles after this proceeding
Alaskas scant connecting points (SEA, PDX and ANC) provide little Cuban-American population
support for its proposed service
Cuban-American Population: SEA (4,027), PDX (4,199), SLC (1,114), and ANC (622)

LAX, for now, is best served as it is once (or maybe twice) weekly
#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-1004
Page 1 of 1

Alaskas 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

#aacuba

Of the 3 Connections Alaska Has to Its LAX-HAV Flight, One SEA Actually
Has Better Connect Times on American

DOT Docket OST-2016-0021


Exhibit AA-R-1005
Page 1 of 1

In Rebuttal to Exhibit AS-5

Alaska
Route

Elapsed Time

American
Elapsed Time

Southbound
SEA-LAX-HAV

Southbound
535 min

537 min

SEA-MIA-HAV

+ 2 min

Northbound

Northbound
HAV-LAX-SEA

Route

Alaska
better / (worse)
than American

675 min

565 min

HAV-DFW-SEA

(110) min

Total Roundtrip Elapsed Time: (108) min

Source: American Airlines analysis

#aacuba

Alaska States an Estimated LAX-HAV Market Size but Without Attempting to


Explain it, Source it, or Justify it

DOT Docket OST-2016-0021


Exhibit AA-R-1006
Page 1 of 1

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)
Los Angeles Forecast Local Passengers vs.
LAX Cuban-American Population
180,000
160,000

159,000

140,000
120,000
100,000
80,000

49,702

60,000
40,000
20,000
0
Forecast Local Pax

LAX Cuban-American Population

Source: U.S. Census 2010

#aacuba

Series 1100:
American Airlines Rebuttal Exhibits
to Sun Country Airlines

Sun Countrys Proposed RSW-HAV Service Would Greatly Exceed the


Historical Demand for RSW-HAV

DOT Docket OST-2016-0021


Exhibit AA-R-1101
Page 1 of 2

In Rebuttal to Sun County Application at pages 1 and 4

RSW-HAV Flights
2015 Charter versus SY Proposed

120

104
100

80

60

40

20

9
0

2015 Annual Chater Flights

Sun Country's Proposed Annual Flights to


RSW-HAV

Source: Sun Country Application / Havanatur charter data

#aacuba

Sun Countrys Proposed RSW-HAV Service Would Greatly Exceed the


Historical Demand for RSW-HAV

DOT Docket OST-2016-0021


Exhibit AA-R-1101
Page 1 of 2

In Rebuttal to Sun County Application at pages 1 and 4

Annual Seats on RSW-HAV


16,848

= 2,753% Increase
612
2015 Charter Seats

68 seats per flight


(Swift Air)
Note: RSW-HAV charter flights were operated by 68-seat aircraft.
Sources: Sun Country Application / Havanatur charter data

Seats on Sun Country Propsoed RSWHAV Flights on Annual Basis

162 seats per flight


(Sun Country)

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-1102
Page 1 of 1

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

Notes: Based on Sun Country application; Maximum connection time is 4 hours; Minimum
connection time is 55 minutes; Maximum circuity is 155%; Minimum of 5x weekly flights.

HAV

#aacuba

Sun Countrys Proposed Twice-Weekly MSP-HAV Service


Would Greatly Exceed MSP-HAVs Proportionate Share of U.S.-Havana
Frequency Allocation

DOT Docket OST-2016-0021


Exhibit AA-R-1103
Page 1 of 1

In Rebuttal to Sun County Application at page 3

MSP-HAV Weekly Frequencies


2.0
2.0

1.5

1.0

0.5

0.3
0.0

Sun Country's MSP-HAV TwiceWeekly 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 Uniteds
Application (Exhibit UA-112).

#aacuba

Sun Countrys Proposed Twice-Weekly MSP-HAV Service


Would Greatly Exceed Historical Demand

DOT Docket OST-2016-0021


Exhibit AA-R-1104
Page 1 of 1

In Rebuttal to Sun County Application at page 3

MSP-HAV Annual Frequencies

104

To the extent there is


MSP-HAV demand,
it is, for now,
best served by charters

1
2015 Charter Flight
Operated on MSP-HAV*

* DL one off charter for Minneapolis Orchestra

Sun Country's TwiceWeekly MSP-HAV Service


on Annual Basis

#aacuba

DOT Docket OST-2016-0021


Exhibit AA-R-1105
Page 1 of 1

Sun Countrys 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

#aacuba

Sun Countrys 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

DOT Docket OST-2016-0021


Exhibit AA-R-1106
Page 1 of 1

In Rebuttal to Sun County Application at page 3 and Exhibit Schedule


Saturday / Sunday

Monday, Tuesday, Wednesday, Thursday, and Friday

MSP

No Flights
No Connections

HAV

#aacuba

Series 1200:
American Airlines Rebuttal Exhibits
to Federal Express

DOT Docket OST-2016-0021


Exhibit AA-R-1201
Page 1 of 1

FedEx Is Right That It Is Not Asking For Much (FedEx Argument, p.1),
But Is the Authority It Seeks Consistent with the U.S.-Cuba MOU?
In Rebuttal to FedEx Argument at page 1

FedExs Proposed Service Includes a Routing Through Mexico


U.S.-Cuba Air Service MOU
Description of Authorized Routings

FedExs Proposed Routing

Section 1
Grant of Permissions
1. The permission to perform scheduled
and charter services between any point or
points in the United States and any point or
points in Cuba .

Miami (MIA)

Havana (HAV)

2. Any airline of a Country holding all


necessary authorizations and licenses, [sic]
should be permitted on any or all flights and at
its option, to:
d. Make stops for non-traffic purposes
within or outside the territory of either
Country;

Mrida (MID)

While HAV-MID is a blind sector, it is uncertain


whether FedExs proposed routing is permitted
under the U.S.-Cuba MOU
#aacuba

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?

DOT Docket OST-2016-0021


Exhibit AA-R-1202
Page 1 of 1

In Rebuttal to FedEx Application at page 4 and 5

If FedEx Were to Operate:

It Proposes to Operate

Miami (MIA)
Miami (MIA)

Havana (HAV)
Havana (HAV)

Mrida (MID)

There would be no/little HAV-MIA


freight so

Because as that freight is needed to


provide the proper revenue basis so that the
flights can be economically viable . . .

Can the current demand for freight be accommodated


on the 20 daily passenger flights or by charters?
Source: FedEx Application (page 5)

#aacuba