OST-00-7194 / US-Vietnam Third-Country Codesharing Opportunities / Reply of American Airlines / April 18, 2000

American Airlines, Inc., pursuant to the Department's Notice of April 5, 2000, hereby replies to the answers submitted on April 14, 2000 by United Air Lines, Inc., Northwest Airlines, Inc., and Delta Air Lines, Inc. These carriers, along with American, are seeking limited-entry U.S.-Vietnam third-country codesharing designation and frequencies. As we show below, American should receive one of the three available designations, along with frequencies to serve between the U.S. and Ho Chi Minh City with Swissair via Zurich three days a week.

United. For all its claims of superiority, United's proposal to serve Vietnam with Thai Airways International via Bangkok suffers from a fatal flaw. United and Thai would. provide no same-day connections to Vietnam from the U.S., and virtually none from Vietnam to the U.S.

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In its answer, United finally gets around to admitting this fact on page 5, stating that "existing schedules create connections that involve layovers at Bangkok." To offset this deficiency, United offers to provide "overnight accommodations," but only to first, business, and full fare economy passengers (id.).

American, by contrast, will offer same-day connections between the U.S. and Vietnam for all its codeshare passengers with Swissair in both directions. The Department should not favor United's overnight proposal over American's same-day proposal, even if United's high-end passengers will be given hotel rooms in Bangkok. The purpose of codesharing is to provide an expedited and seamless travel itinerary, and not to subject passengers to overnight hotel stays because of misconnecting schedules.

Northwest. In its answer, Northwest summarily asserts that its proposal "will provide a more efficient and convenient service" than American's (P. 3). As shown in American's answer, that is simply not true. Northwest's twice-a-week proposal to serve Hanoi with Malaysia Airlines via Kuala Lumpur would require overnight connections in both directions, and its four-days-a-week service to Ho Chi Minh City would have only a few viable same-day connections.

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Clearly, American will provide a more efficient and convenient codesharing service between the U.S. and Vietnam than Northwest.

Delta. Delta's proposal is similar to American's. Delta would serve Vietnam with Air France via Paris, and offer same-day connections in both directions. Delta, however, fails to state whether Air France's flights to Vietnam, which operate via Singapore or Bangkok, overfly Afghanistan. If they do, Delta would be required to enter into discussions with Air France to change such a routing before codesharing service could be operated.

For the foregoing reasons, American should receive one of the three designations available for third-country codesharing between the U.S. and Vietnam.

Respectfully submitted,

CARL B. NELSON, JR.

Associate General Counsel

American Airlines, Inc.

April 18, 2000