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OST-96-1700

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OST-96-1700

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OST-96-1700

OST-96-1700

Served 7/31/97

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Attachment 2 - Documents Withholding Pending Reconsideration

Attachment 3 - Confidentiality Affidavits Submitted

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Heathrow Stand Demand - Graph

Proposed Alliance between BA and AA - Executive Summary

The Top Ten World Airports in 1996 - Table

Prospects for Growth in the Capacity of Heathrow Airport

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• Affidavit of Kathleen A. Soled - in Docket OST-97-2058
• Affidavit of Kathleen A. Soled - in Dockets OST-96-1700 & OST-97-3285
• Affidavit of Richard J. Fahy - in Dockets OST-96-1700 & OST-97-3285
• Affidavit of  Daniel S. Klein - in Dockets OST-96-1700 & OST-97-3285

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• Affidavit of Jay Kasner, Attorney with Skadden Arps
• Exhibit A:  Stipulation and Protective Order, SDNY, USAir v British Airways, 96 Civ. 5724, January 15, 1997
• Exhibit B:  Decision, US Airways v British Airways, SDNY, 96 Civ. 5724, December 29, 1997

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• Exhibit TW-1:  US-London Market is Highly Concentrated
• Exhibit TW-2:  AA/BA Alliance Would Drastically Increase Concentration on the US-London Market
• Exhibit TW-3:  JFK-Heathrow Comprises More than One-Fourth of the US-London Market
• Exhibit TW-4:  Breakdown of Routes EU/US
• Exhibit TW-5:  Alliances/Impact of Network Effect
• Exhibit TW-6:  Percent of Market Shares
• Exhibit TW-7:  Market Definition - Competition Between Hubs in Relation to London
• Exhibit TW-8:  BA has More US Gateways than Any Existing Alliance
• Exhibit TW-9:  The AA/BA Alliance Would Have More US Gateways than All of its Competitors Combined
• Exhibits TW-10 and TW-11:  Confidential
• Exhibit TW-12:  Even with Transfer of 350 Heathrow Slots to Competitors, an AA/BA Alliance would Drastically Increase Concentration in the US-London Market
• Exhibit TW-13:  Transfer of 350 Weekly Heathrow Slots from the Alliance to US-London Competitors Would be Insufficient to Preserve Competition

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• Exhibit UA-1:  US-UK Carrier Market Share
• Exhibit UA-2:  US-UK Markets in Which the AA/BA Alliance Would Have an Absolute Monopoly

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• Attachment A:  The Competitive Implications of The Proposed BA/AA Alliance, London Economics, Jan 10, 1997
• Attachment B:  American and British Airways Alliances with Other Carriers
• Attachment C:  Runway Histograms

• Re: American Airlines - 149 Letters from Elected Officials in Support - Letters will be available in due course
• Answer of Capital Region Airport Authority - Lansing, Michigan
• Answer of Fort Smith, Arkansas Airport Commission
• Answer of Northwest Arkansas Regional Airport Authority
• Answer of The Port of Seattle in Support
• Answer of San Jose International Airport
• Answer of Scramento County Department of Aviation

• Exhibit 1 - Re: American Airlines/British Airways DOT Docket OST-97-2058
• Exhibit 2 - Confidential British Airways Documents Cited in DOJ Comments to DOT 5/21/98

Confidentiality Affidavit for Paul Jasinski, Counsel for British Airways

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• Exhibit 1 - Alliance Market Shares
• Exhibit 2 - British Midland Media Information
• Exhibit 3 - Press Releases
• Exhibit 4 - Market Share Gap on Overlap Routes
• Exhibit 5 - More Than 300 Civic Parties, Businesses, and Individuals Submitted Answers and Letters Supporting the American/British Airways Alliance

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• Exhibit A - Environmental Constraints on the Development and Use of Heathrow Airport (May 1997)
• Exhibit B - Environmental Constraints on the Development and Use of Heathrow Airport [Further Comments (June 23, 1998)]

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• Exhibit Index
• DL-R-100    Delta Should Be Guaranteed A Minimum Of 140 Heathrow Slots At Commercially Viable Times 
• DL-R-101    Summary Of Minimum Heathrow Slot Requirements By Carrier   
• DL-R-102    Summary Of Minimum Heathrow Slot Requirements By Airport   
• DL-R-103 - Not Used   
  DL-R-109   
• DL-R-110    Delta Would Be The Strongest New York - Heathrow Competitor Against AA/BA   
• DL-R-111    Delta Operates More New York Flights Than TWA And United   
• DL-R-112    Only Delta Has The Route Structure At JFK to Compete With AA/BA's Huge Beyond LHR Flow   
• DL-R-113    Only Delta Has The Service Base At JFK To Compete With AA/BA's Huge Beyond LHR Flow   
• DL-R-114    Only Delta Has The Capacity At JFK To Compete With AA/BA's Huge Beyond LHR Flow   
• DL-R-115    Delta Has The Strongest JFK Feed Network
• DL-R-116 - Not Used   
  DL-R-119   
• DL-R- 120   TWA Would Not Be The Best Carrier To Provide JFK - LHR Competition Against AA/BA
• DL-R-121    TWA's Presence In New York Has Been Declining   
• DL-R-122    TWA's New York Passenger Base Has Been Eroding   
• DL-R-123    Trans World Airlines Has Sharply Reduced Service Between JFK And Europe   
• DL-R-124    TWA's Domestic JFK Service Has Been Declining Since 1992   
• DL-R-125 - Not Used   
  DL-R-129   
• DL-R-130   Delta's Atlanta Gateway Is The Oldest Continuously    Operated Gatwick - Restricted Service    
• DL-R-131   Delta's Atlanta Gateway Attracts More Passengers Than Any  Other Carrier's Gatwick Restricted City 
• DL-R-132   Delta's Atlanta Gateway Supports More Capacity Than Any Other Carrier's Gatwick Restricted City   
• DL-R-133   Delta's Atlanta Gateway Supports More Flights Than Any Other Carrier's Gatwick Restricted City   
• DL-R-134   Atlanta Has More Domestic Online Destinations Than Any Other Carrier's U.S. - Gatwick Gateway   
• DL-R-135   Atlanta Has Far Stronger Domestic Online Support Than Any Other Carrier's U.S. - Gatwick Gateway 
• DL-R-136   Delta At Atlanta Supports More Transatlantic Destinations Than Any Other Carrier's U.S. - Gatwick Gateway    
• DL-R-137   Delta At Atlanta Supports More Transatlantic Services Than Any Other Carrier's U.S. - Gatwick Gateway
• DL-R-138 - Not Used   
  DL-R- 140   
• DL-R-141   Delta Carries More London Passengers To/From U.S. Gateways Without Heathrow Service Than Any Other U.S. Carrier    
• DL-R-142   Delta Operates More London Trips To/From U.S. Gateways Without Heathrow Service Than Any Other U.S. Carrier    
• DL-R-143   Delta Offers More London Seats To/From U.S. Gateways Without Heathrow Service Than Any Other U.S. Carrier    
• DL-R-144   Delta's Cincinnati Hub Is An Established Gateway To Europe And Should Not Be Split From Delta's Proposed Atlanta/JFK - Heathrow Service   
• DL-R-145   Delta's Cincinnati Hub Is One Of The Largest In The U.S. And Should Not Be Split From Delta's Proposed Atlanta/JFK - Heathrow Service   
• DL-R-146   The DOJ Omission Of Cincinnati For Heathrow Slots Would Put Cincinnati At A Competitive Disadvantage   
• DL-R-147 - Not Used   
  DL-R-149   
• DL-R-150   Delta's Nonstop Destinations From Boston

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• Attachment A: Based on Experience at U.S. Slot Controlled Airports, It is Not Reasonable to Expect the Slots of the Dominant Carriers' at Heathrow to Decrease Assuming that Slot Transfers and Slot Sales are Permitted
• Attachment B: Virgin Atlantic Would Have Many More Route Opportunities in U.S.- London (Heathrow) Markets that Would Be Superior to Entering the DFW-London Market
• Attachment C: Delta Would Have Many More Route Opportunities in U.S.- London (Heathrow) Markets that Would Be Superior to Entering the DFW-London Market
• Attachment D: The Consultant Study Prepared for American Airlines Which Projects 45% Greater Economic Benefits For the Houston Area than the DFW Area is Not Valid or Credible

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• Exhibit 1 - Department of Justice Choices for Airline Changes at Heathrow
• Exhibit 2 - Hubs of US Airlines Seeking Heathrow Opportunities / Other US Airline Hub Cities
• Exhibit 3 - Possible New Entrant Airlines and Their Base Cities
• Exhibit 4 - Current Nonstop Gatwick Services that May Wish to be Switched to Heathrow
• Exhibit 5 - Major US Cities not Receiving Any Nonstop Airline Service to London

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• Exhibit JA-1:  Alliance Agreement dated as of June 11, 1996
• Exhibit JA-2:  British Midland Press Release, Feb 24, 1998
• Exhibit JA-3:  Alliance Market Share
• Exhibit JA-4:  Letters in Support
• Exhibit JA-5:  United Air Lines Press Release, Two Additional Airlines to Join Star Alliance, May 14, 1998
• Exhibit JA-6:  Global Alliance Comparison
• Exhibit JA-7:  CO, NW CEOs:  Shift in the Airline Power Structure, BTN Online

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• Exhibit BD-100: Route Network
• Exhibit BD-200: Limited Codeshare Partners
• Exhibit BD-300: Global Offline Sales Representation
• Exhibit BD-400: Service Awards Since 1990

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• Attachment 1: Proposed United Airlines Service at LHR
• Attachment 2: Proposed Timings for Proposed United Airlines Service at LHR/Expected Timings
• Attachment 3: United Facility Needs at LHR
• Attachment 4: Proposed LHR Network Service Plan for UA and Codeshare Partners

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• US-RT-1: Rebuttal Testimony and Exhibits
• Revised Direct Exhibits US-415 & US-416
• Rebuttal Exhibits US-701 to US-703

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• ALPA - Petition of Air Line Pilots Association for Leave to Intervene
• AA/BA - Joint Answer of American Airlines, Inc. and British Airways PLC to Motion on Hearing Procedures

• Joint Notice of Intent to Participate in Oral Hearing

• ATLANTA - Notice of Intent to Participate and Petition for Leave to Intervene - Georgia and Metro Atlanta Parties
• BRITISH MIDLAND - Notice of Intent of British Midland Airways Limited to Participate in Oral Hearing
• CHARLOTTE - Notice of the City of Charlotte of Intent to Participate in Oral Hearing and Contingent Petition for Leave to Intervene
• CINCINNATI - Notice of Intent to Participate and Petition for Leave to Intervene - City of Cincinnati
• CONTINENTAL - Re:  Joint Application of American Airlines and British Airways - Continental
• DFW - Notice of Intent and Proposed Questions of the Dallas/Ft. Worth International Airport
• DELTA - Notice of Delta Air Lines, Inc. of Intent to Participate in Oral Hearing
• DENVER - Petition of the City and County of Denver for Leave to Intervene
• DOJ - Notice from the Department of Justice of Intent to Participate in Oral Hearing
• HOUSTON - Notice of the City of Houston and the Greater Houston Partnership of Intent to Participate in Oral Hearing

• Answer of the City of Houston and the Greater Houston Partnership to Joint Motion on Procedures and Hearing

• MASSPORT - Notice of Massport of Intent to Participate in Oral Hearing
• PHILADELPHIA - City of Philadelphia, Division of Aviation's Notice of Intent to Participate
• QUEENS - Notice of Intent to Participate and Petition for Leave to Intervene - Queens County, City of New York
• ST LOUIS - Notice of the St. Louis Parties of Intent to Participate in Oral Hearing
• TWA - Notice of Trans World Airlines, Inc. Re:  Oral Argument
• UNITED - Notice of United Air Lines, Inc.
• US AIRWAYS - US Airways, Inc.'s Notice of Intent to Participate
  Re:  Docket OST-97-2058 - US Airways
  Motion for Confidential Treatment
  Confidentiality Affidavit
  
• VIRGIN - Notice of Intent to Participate in Hearing - Virgin Atlantic Airways

American Airlines, Inc. and British Airways PLC Motion for Confidential Treatment of Oneworld Agreement  

American Airlines, Inc. and British Airways PLC Joint Response Re Oneworld Alliance  

• Associated Industries of Massachusetts for Motion of Leave to File One Day Late
• Associated Industries of Massachusetts Notice of Intent to Participate and Petition for Leave to Intervene
• County of Allegheny, Department of Aviation for Motion for Leave to File One Day Late
• County of Allegheny, Department of Aviation, Notice of Intent to Participate and Petition for Leave to Intervene
• Regional Buisiness Partnership - Letter of Intent to Participate in Oral Hearing

• New Jersey Chamber of Commerce - Notice of Intent to Participate in Oral Hearing
• City of Cleveland - Notice of Intent to Participate in Oral Hearing
• Associated Industries of Massachusetts - Motion for Leave to File One Day Late | Notice of Intent (will be added 10/1)

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