OST-98-3765
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OST-98-3765
American Airlines, Inc. (Route Designation, San Jose-London Gatwick)
OST-98-3765 | April 20, 1998
American proposes to institute daily nonstop service between San Jose and London/ Gatwick, effective April 15, 1999, using 207-seat B767-300ER aircraft.
Answers are due by April 27, 1998
Counsel: American, Carl Nelson, 202-496-5647, carl_nelson@amrcorp.com
American Airlines, Inc. - (San Jose-London (Gatwick) Service) / Continental Airlines, Inc. (Cleveland-London)
OST-98-3765 | Undocketed | April 27, 1998
By all relevant measures, San Jose should be selected over Cleveland as a new nonstop gateway to London. San Jose's catchment area has a far larger population base; San Jose has far greater potential to generate traffic in the local market; and San Jose has far stronger economic indicators. Moreover, while Cleveland would provide on-line connections for beyond markets, almost all of those markets already have connecting service to London on Continental via Newark, or on Northwest (Continental's worldwide alliance partner) via the nearby Detroit gateway.
Counsel: American, Carl Nelson, 202-496-5647, carl_nelson@amrcorp.com
Answer of Continental Airlines
By traditional carrier-selection criteria, Continental and Cleveland clearly should be selected for the one remaining London designation over American and San Jose. Cleveland generates three times the O&D London passengers San Jose generates. Introducing nonstop Cleveland-London service has long been a shared goal of Continental and Cleveland, and Continental's proposal to offer Cleveland its only nonstop U.S.-Europe service will provide important public benefits to Cleveland, Ohio and the points served through Continental's Cleveland hub. Both Cleveland and San Jose-London services would require flow traffic to support them, but American provides San Jose service at only five U.S. points (Austin, Boston, Dallas/Ft. Worth, Los Angeles and Chicago) and one foreign point (Tokyo) all of which have far better access to London on other routings.2 In sharp contrast, Continental and Continental Express serve 64 cities at Cleveland, more than ten times the number of cities American serves at San Jose.
Re: Letters in Support of Continental's Cleveland-London
Designation
Counsel: Continental and Crowell Moring, Bruce Keiner, 202-624-2615
Answer of the City of San Jose and the
San Jose International Airport in Support
San Jose welcomes and enthusiastically supports American's application and that carrier's continued recognition of the importance of the Silicon Valley area and economy to which the San Jose airport is a gateway for international and domestic transportation.
Counsel: Hewes Gelband, Theodore Seamon, 202.337.6200
U.S.-London Gatwick Service / American Airlines, Inc.
OST-98-3765 | April 30, 1998
Enclosed are letters supporting designation of American Airlines, Inc. to serve between San Jose, California and London/Gatwick, submitted on behalf of Senator Barbara Boxer and Representatives Tom Campbell, Anna Eshoo, Ellen Tauscher, Juanita Millender-McDonald, and Pete Stark.
Counsel: American, Carl Nelson, 202-496-5647
United States-London (Gatwick) Air Services / Continental Airlines, Inc. / American Airlines, Inc.
Undocketed | Undocketed | OST-98-3765 | June 15, 1998
Motion of Continental Airlines for Expedition
American's application is in keeping with its continuing pattern of applying for authority as a spoiler to delay or prevent Continental's entry whenever Continental has sought to operate additional flights in competition with American's service between the U.S. and foreign countries where American already holds more U.S.-flag authority than any other airline. If American's true motive is delaying Continental's ability to compete at Cleveland with American's four daily Chicago-London flights, American has already succeeded -- Continental's designation has already been delayed for over three months. Unless the Department acts promptly, American may succeed in precluding Continental from instituting service for want of slots at Gatwick, just as its would-be partner, British Airways, has benefited at Charlotte by the lack of US Airways service.
Counsel: Continental and Crowell Moring, Bruce Keiner, 202-624-2500
Undocketed | OST-98-3765 | Undocketed | June 17, 1998
Answer of American Airlines, Inc. to Motion of
Continental Airlines, Inc. for Expedition
The Department should not be swayed by Continental's transparent attempt to circumvent a selection proceeding by now claiming that it would start service on February 19, 1999, rather than on April 30, 1999 as it had initially proposed. If it had truly wanted to operate Cleveland-London service during the 1998-1999 winter traffic season, Continental would have specified a winter traffic season startup date in its original proposal, which it submitted less than four months ago.
We also note that Continental has not merely changed its proposed start-up date; it has also surfaced a decidedly inferior service plan, proposing to use narrow-body 183-seat B757s instead of the DC10s it initially proposed. This is an admission that Cleveland-London market demand is much weaker than Continental had anticipated. American will offer the San Jose-London market 13 percent more daily capacity with its 207-seat B767-300ER aircraft, representing a much more productive use of valuable limited-entry route authority.
Counsel: Carl Nelson, Jr. for American, 202.496.5647
Undocketed | Undocketed | OST-98-3765 | July 14, 1998
Re: Letter in Support of Application of Continental
Airlines, Inc. | Joint Letter of Support from
Eight Congresspersons
Enclosed for filing in the above-referenced proceedings is a letter from members of Ohio's Congressional delegation in support of Continental's request for a Cleveland-London Gatwick designation. To the extent necessary, Continental requests leave to file the enclosed letter out of time. Acceptance will provide the Department with a more complete record.
Counsel: Crowell Moring, Lorraine Halloway, 202.624.2538
Order 98-7-25 | OST-96-1642 | OST-98-3765 | Undocketed | Issued July 31, 1998 | Served August 4, 1998
Order to Show Cause - Corrected
By this order, we propose to (1) restore the selection of Cleveland as a new U S. gateway on U. S. Route 1; (2) renew Continental Airlines' certificate authority to provide combination services in the Cleveland-London (Gatwick) market; and (3) select American Airlines' San Jose-London (Gatwick) proposal as a backup to Continental's services.
By: Patrick Murphy
Continental Airlines, Inc. / American Airlines, Inc. (US-London Gatwick Designation)
OST-96-1642 | Undocketed | OST-98-3765 | August 11, 1998
Objections of American Airlines to Order
98-7-25
As we show below, the proposed decision is procedurally deficient, as the Department failed to provide for the submission of evidentiary exhibits, contrary to longstanding precedent in carrier-selection proceedings. The Department should immediately vacate Order 98-7-25, and issue an expedited procedural schedule calling for information responses, direct exhibits, rebuttal exhibits, and briefs. In its exhibits, American will show why its proposal for San Jose-London nonstop service should be preferred over Continental's for Cleveland-London.
Counsel: American, Carl Nelson, 202-496-5647, carl_nelson@amrcorp.com
Objection of the City of San Jose and the San Jose
International Airport
The City of San Jose, California and the San Jose International Airport ("San Jose") hereby strongly object to Order 98-7-25. The Show Cause Order is procedurally flawed and violates San Jose's due process rights. The tentative decision is also substantively without merit and is premised on findings that are not supported by substantial evidence. San Jose urges the Department to reconsider its tentative decision and instead follow its well-established policy and procedures in contested limited-designation cases and institute a carrier selection proceeding so that American and San Jose will be allowed to submit the evidence necessary for the Department to consider fairly both carriers' service/gateway proposals and make an informed decision on the merits of the proposals before it, based on the substantial evidence.
Counsel: Shaw Pittman, Robert Cohn, 202-663-8060
U.S.-London Gatwick Designation / American Airlines, Inc. / Continental Airlines, Inc.
OST-98-3765 | OST-96-1642 | Undocketed | August 17, 1998
Consolidated Answer of The City of Cleveland to
Objections
As the Department found, San Jose is located within the catchment area of San Francisco International Airport, just 30 miles to the north. Three carriers, United, British Airways and Virgin, already provide a total of five daily nonstop flights between San Francisco and London, as well as numerous connecting flights. Exhibit 3. Thus, local traffic estimates and projected stimulation for San Jose should be reduced because potential passengers in San Jose already have access to direct service from San Francisco International Airport. In contrast, Cleveland Hopkins International Airport, which serves local passengers from throughout northeast Ohio, is not located within the catchment area of any other airport providing scheduled nonstop international service, and first-ever London service at Cleveland can be expected to stimulate additional local traffic.
Counsel: Cleveland, Sylvester Summers
Consolidated Answer of Continental Airlines to
Objections
American has already delayed restoration of Continental's designation beyond the IATA slot conference for next winter, and further delay would inhibit Continental's ability to participate effectively in slot trading at the August 21 slot exchange meeting. American's seeking even further delay is clearly aimed at preventing Continental from securing suitable Gatwick slots to institute Cleveland-London service in competitive time slots which would enable Continental to compete effectively with American services.
Counsel: Continental and Crowell Moring, Bruce Keiner, 202-624-2500
Answer of The City of San Jose and The San Jose
International Airport
The Department's competition analysis is flawed because it fails to examine the comparative regional competition impacts. American at San Jose will inject for more significant competition and online benefits than Continental at Cleveland. If American and San Jose were able to submit evidentiary exhibits and briefs, the record would have established that American's San Jose service would provide intragateway competition in the Bay area and intergateway competition as a result of American's enhanced interline agreement with Reno Air at San Jose. Continental's proposal would offer no additional intragateway competition and minimal intergateway competition. especially In light of Northwest's acquisition of a substantial Continental equity position. Furthermore, American's San Jose - London(Gatwick) proposal would be the first service to Gatwick. Gatwick is a key European hub in its own right because it offers connecting service to dozens of points, including Africa, that are not served at London (Heathrow). Finally, Continental's recent Cleveland-London service default and its proposal to downgrade equipment to a narrowbody aircraft (which would be the only narrow body flight to London) cast serious doubt on its commitment to serve aggressively the Cleveland route.
Counsel: Shaw Pittman, Robert Cohn, 202-663-8060
Continental Airlines, Inc. and American Airlines, Inc.
| Order 98-10-19 OST-96-1642 OST-98-3765 Undocketed |
October 19, 1998 | Final Order |
Cleveland U.S. Gateway Route 1 - Continental, Certificate Cleveland -
London American Airlines, San Jose-London |
 HTML |
| Experimental Certificate of Public Convenience and Necessity | ||||
| Terms, Conditions, and Limitations |
1. We issue, in the form attached, authority to Continental Airlines, Inc., in Docket OST-96-1642, to provide scheduled foreign air transportation of persons, property, and mail in the Cleveland-London (Gatwick) market;
2. We restore the selection of Cleveland, Ohio, as a U. S. gateway under section 6 of Annex I to the current United States-United Kingdom Air Services Agreement;
3. We select Arnencan.Airlines, Inc, for backup authority for one year from the date of service of this order to provide scheduled foreign combination air services in the San Jose-London (Gatwick) market;
By: Patrick V. Murphy
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