OST-97-3273
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OST-97-3273
Continental Airlines, Inc. (Houston-Brazil)
OST-97-3273 | December 19, 1997
Certificate of public convenience and necessity to perform scheduled foreign air transportation of persons, property and mail between Houston and Sac Paulo, Rio de Janeiro, Belo Horizons" Brasilia, Curitiba and Porto Alegre and to combine service between these points with service at other points Continental is authorized to serve by certificates or exemptions, consistent with applicable international agreements, and award Continental seven U.S.-Brazil combination frequencies
Continental plans to operate daily nonstop Houston-Sao Paulo service beginning October 1, 1998 or 120 days after receipt of all necessary governmental authority, whichever is later. Continental is planning to use DC-10 aircraft to institute nonstop Houston-Sao Paulo services, but it may substitute B-767 or B-777 aircraft in the future as those aircraft are delivered to Continental.
Continental is also filing shortly an application for authority to code share with VASP which will allow it to offer service at these Brazilian cities in conjunction with its Newark services, and Continental seeks authority here to offer such service in conjunction with its Houston service.
Counsel: Continental and Crowell Moring, Bruce Keiner, 202-624-2500
Continental Airlines, Inc. / American Airlines, Inc. (US-Brazil)
OST-97-3273 | OST-97-3269 | January 2, 1998
Consolidated
Answer of United Air Lines
United opposes the-applications of Continental and American. United has proposed to use the new frequencies to offer the first U.S. carrier nonstop service in the Los Angeles-Sao Paulo market. Los Angeles is the largest U.S. gateway to Brazil that lacks U.S. carrier nonstop service. The Los Angeles-Sao Paulo market is currently the preserve of several foreign flag carriers. U.S. carrier competition is clearly required in a major market of this size as a matter of priority over services in markets such as those which Continental and American propose to serve.
Counsel: United and Ginsburg Feldman, Joel Burton, 202-637-9130
Continental Airlines, Inc. / Delta Air Lines, Inc. (US-Brazil)
OST-97-3273 | OST-97-3151 | January 2, 1998
Answer of The
City of Houston and The Greater Houston Partnership
The growth of Continental's network from Houston to Latin America has both reflected and further stimulated Houston's ties to the region. Now, Continental's expansion into Brazil promises to enable Houston to tap the full potential of those ties, while providing travelers and shippers both in and behind Houston with vastly more efficient access to Sao Paulo and other Brazilian points and beyond. Houston submits that the introduction of a new U.S.-Brazil routing through Houston is in the public interest and is consistent with DOT policy and enhanced ties between the U.S. and Brazil.
Counsel: Zuckert Scoutt, Raymond Rasenberger, 202-298-6660
Continental Airlines, Inc. / United Air Lines, Inc. / American Airlines, Inc. (US-Brazil)
OST-97-3273 | OST-97-3271 | OST-97-3269 | January 2, 1998
Consolidated
Answer of Delta Air Lines
Delta urges the Department promptly to institute a case to consider the allocation of the seven additional weekly frequencies available under the U.S.-Brazil bilateral agreement. Delta wants to be in a position to obtain authority well in advance of the October 1998 start-up date under the MOC to permit it adequately to promote and market the proposed new services.
Counsel: Delta and Shaw Pittman, Robert Cohn, 202-663-8060
Continental Airlines, Inc. / Delta Air Lines, Inc. / American Airlines, Inc. / Continental Airlines, Inc. (US-Brazil)
OST-97-3271 | OST-97-3151 | OST-97-3269 | OST-97-3273 | January 2, 1998
Answer of Continental
Airlines to Motion to Consolidate
Continental believes the merits of its proposal to serve Houston so far outweigh any merits of the other proposals that its application should be granted immediately, but the Department is constrained by the Ashbacker doctrine and its own policies to institute a proceeding to consider the competing applications. American and Continental have sought consolidation of their applications with Delta's, while United has indulged in some wishful thinking about Brazil's potential willingness to offer more frequencies to the U.S. and failed to submit a motion seeking consolidation. Clearly, the American and Continental motions to consolidate should be granted whether United formally seeks consolidation or not.
Counsel: Continental and Crowell Moring, Bruce Keiner, 202-624-2615
Motion of United
Air Lines to Consolidate
Each of the captioned applications requests allocation of seven (7) V.S.-Brazil frequencies. A total of 28 frequencies are requested. Under the US/Brazil bilateral air services agreement, only seven (7) additional frequencies are available for allocation during 1998. Unless the U.S. and Brazil agree to increase the number of frequencies available, the captioned applications are mutually exclusive and must be consolidated for adjudication in a contemporaneous carrier selection proceeding.
Counsel: United and Ginsburg Feldman, Joel Burton, 202-637-9130
American Airlines, Inc. / Continental Airlines, Inc. / United Air Lines, Inc. (US-Brazil Frequency Allocation)
OST-97-3269 | OST-97-3273 | OST-97-3271 | January 5, 1998
Motion for
Leave to File One Day Late and Motion to Consolidate of American Airlines
American will demonstrate that grant of its application to provide Miami-Manaus service is in the public interest. No U.S.-flag carrier presently operates service to Manaus, the largest city in the Amazon region of Brazil and a growing center of economic activity due to its status as a free port. American will provide substantial benefits in the local market (in competition with operations by Varig and Lloyd Aereo Boliviano), and in dozens of beyond markets that will receive convenient on-line connections at Miami.
Counsel: American, Carl Nelson, 202-496-5647, carl_nelson@amrcorp.com
American Airlines, Inc. / United Air Lines, Inc. (US-Brazil Frequency Allocation)
OST-97-3269 | OST-97-3271 | January 5, 1998
Consolidated
Answer of Continental to Applications of American and United
Continental opposes any award of frequencies to either American or United which would preclude Continental from instituting daily Houston-Brazil service.
Counsel: Continental and Crowell Moring, Bruce Keiner, 202-624-2500
1998 US-Brazil Combination Service Case
Order 98-5-27 | OST-98-3863 | OST-97-3269 | OST-97-3271 | OST-97-3273 | OST-97-3151 | Issued and Served May 20, 1998
By this order we institute the 1998 U.S.-Brazil Combination Service Case, Docket OST-98- 3863, to select a carrier to operate the seven weekly frequencies available for U.S.-Brazil combination services effective October l, 1998. We consolidate the frequency applications of American Airlines, Inc. and United Air Lines, Inc. and the certificate/frequency applications of Continental Airlines, Inc. and Delta Air Lines, Inc. into this proceeding.
Appendix A - Evidence Request
By: Charles Hunnicutt
1998 U.S.-Brazil Combination Service Proceeding / Continental Airlines, Inc.
| OST-98-3863 OST-97-3273 |
November 16, 1998 | Motion of Continental
Airlines for Leave to File an Otherwise Unauthorized Document and Request to
Amend Start-Up Conditions |
US-Brazil Combination |
Continental has been reviewing its plans for Brazil service and has concluded it cannot economically commence Houston-Sao Paulo service for 18 months. Because Brazil has experienced a severe economic downturn since the Department served Order 98-5-27 on May 20, 1998, new Brazil service cannot become economically viable within the required 90 days. Thus, Continental cannot achieve the substantial public benefits of Continental's Houston-Sao Paulo proposal within 90 days. Continental anticipates Brazil's economy will be on the upswing within 18 months and, thus, it will be possible to institute economically viable Brazil service within that period of time.
Counsel: Continental and Crowell Moring, Lorraine Halloway, 202-624-2500
1998 U.S.-Brazil Combination Service Proceeding
| OST-98-3863 OST-97-3273 |
November 24, 1998 | Reply of Continental
Airlines |
Continental is now planning to institute Houston-Sao Paulo service in the beginning of the Winter 1999 season, and Continental is committed to institute such service no later than the end of 1999. Thus, Continental agrees with Delta that a 12-month start-up condition would be appropriate. Because instituting service at Houston, a new hub gateway, will provide far more public benefits than increasing frequencies at the well-served existing gateways at New York/Newark (JFK) and Los Angeles, however, Continental urges the Department to award Continental Houston- Sao Paulo authority and to deny the applications of Delta, Massport and United.
Counsel: Crowell & Moring LLP, R. Bruce Keiner, Jr. and Lorraine Halloway for Continental Airlines, 202.624.2500
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