ost995725

OST-99-5725

United Air Lines, Inc.

OST-99-5725	May 25, 1999	Application for an Exemption Scanned Copy	Denver-London Heathrow
		Exhibit UA-1: Proposed Service
		Exhibit UA-2: Map
		Exhibit UA-3: United's Denver Hub Offers 500 Daily Departures and 57,000 Seats to 103 Cities
		Service List

United requests exemption authority to operate daily nonstop services between Denver, Colorado, and London, England. United will operate such services commencing April 2, 2000, using B777 or other suitable equipment from its fleet or on order. United's proposed Denver-London service is supported by principles of comity and reciprocity. British Midland, a U.K.-flag carrier, has filed an application for exemption authority to operate between New York JFK and London Heathrow on an extrabilateral basis. See Docket OST-99-5671. British Midland proposes two daily New York-London services. To the extent the Department is prepared to authorize British Midland to operate New York-London service on an extrabilateral basis, it should also be prepared to authorize United to operate daily Denver-London services which should be accepted by the British government as the reciprocal of British Midland's services. United presently offers one-stop services between Denver and London. These one-stop services include daily single-plane and single-flight-number change-of-gauge operations via Chicago and Newark. Denver-London is presently a British Airways nonstop monopoly. U.S. carrier services between Denver and London were attempted by both Western Airlines, Inc., and Continental but were in both cases discontinued.

Counsel: United and Kirkland Ellis, Jeffrey Manley, 202-879-5161

United Air Lines, Inc.

OST-99-5725	May 26, 1999	Re: Corrected Exhibit UA-1	Denver-London Heathrow
		Exhibit UA-1: Proposed Service

Counsel: United and Kirkland Ellis, Jeffrey Manley, 202-879-5161

United Air Lines, Inc.

OST-99-5725

June 9, 1999

Answer of Continental Airlines

Scanned Copy

Denver-London Heathrow

Apparently afraid of missing out on a mini-deal despite the disclaimers of government officials that any such deal is under consideration, United has now applied for Denver-London Heathrow authority premised on the British Midland application for London Heathrow-New York/Newark (JFK) authority. Nonetheless, the principles espoused earlier by United should be adopted by the Department, and United's application for Denver-London Heathrow authority should be deferred, dismissed or denied until the skies are opened at London Heathrow at least sufficiently to meet the requirements of Continental, Newark, Houston and Cleveland for sufficient Heathrow access to mount competitive services.

Counsel: Continental and Crowell Moring, Bruce Keiner, 202-624-2500

OST-99-5725

June 9, 1999

Answer of Delta Air Lines

Scanned Copy

Denver-London Heathrow

Unlike United, which already enjoys the ability to serve London Heathrow, the Bermuda 2 bilateral agreement has precluded Delta from operating to London's premier airport. The Department is well aware that Delta has extremely important requirements for U.S.-London Heathrow service, including: New York JFK (four daily flights), Atlanta (three daily flights), Cincinnati (two daily flights), and Boston (two daily flights). Delta's proposed Heathrow services are essential to the development of a healthy competitive marketplace between the United States and London. Negotiations with the UK will resume soon. Delta strongly supports the Department's efforts to negotiate a comprehensive open skies agreement -including assurances of commercially viable Heathrow slots and facilities. Because Delta is currently without any Heathrow access, to the extent new opportunities become available, Delta's stated route requirements should receive priority over requests by incumbents, such as United's Denver-Heathrow application.

Counsel: Delta and Shaw Pittman, Robert Cohn, 202-663-8060

OST-99-5725

June 9, 1999

Answer of The City and County of Denver

Denver-London Heathrow

Since the Application involves Denver-London service, Denver has a direct interest in this proceeding that will not otherwise be adequately represented. Accordingly, Denver's intervention will assist the Department in developing a full record and Denver respectfully requests leave to participate in this proceeding.

Counsel: Denver and Thelen Reid Priest, Richard Leidl, 202-508-4000

OST-99-5725

June 9, 1999

Answer of Northwest Airlines

Denver-London Heathrow

Instead of pursuing piecemeal openings of the U.S.-U.K. market, Northwest believes that the U.S. Government must maintain its focus on obtaining a comprehensive, fully-liberalized agreement that provides multiple new opportunities for multiple U.S. carriers. On this basis, Northwest also opposed the recent applications of US Airways for extrabilateral Pittsburgh-London authority (Docket OST-99-5428) and American Airlines for extrabilateral San Jose-London authority (Docket OST-99-5527). Department precedent and policy mandate dismissal of United's application.

Counsel: Northwest and Zuckert Scoutt, Charles Simpson, 202-298-8660

OST-99-5725

June 9, 1999

Answer of The City of San Jose and The San Jose International Airport

Scanned Copy

Denver-London Heathrow

If the Department is prepared to consider United's application for extrabilateral authority, then the Department must give concurrent consideration to American's already pending application for San Jose-London nonstop authority.

Counsel: San Jose and Shaw Pittman, Robert Cohn, 202-663-8060

United Air Lines, Inc.

OST-99-5725

June 18, 1999

Reply of United Air Lines

Scanned Copy

Denver-London Heathrow

Denver-London is currently a British Airways monopoly route. Addressing this competitive imbalance must be a high priority item on the Department's agenda in seeking new access to London. Through its Denver hub, United would offer premium new B-777 nonstop service to London for residents of the underserved Intermountain West region, as well as the 103 cities receiving United's online connecting service through its Denver hub. If the Department decides to authorize British Midland's service, the public interest benefits that would be generated by United's Denver-London service compel the concurrent approval of United's application. United understands the desires of San Jose and the other U.S. carriers to obtain new access to London. Authorizing United to introduce nonstop U.S.-flag service between Denver and London on a daily basis would not preclude the Department from also granting other outstanding requests for new London authority. Because British Midland seeks to operate double daily service between London Heathrow and New York (JFK), the U.S. would have the opportunity to authorize multiple new U. S. carrier services to London under principles of comity and reciprocity.

Counsel: United and Kirkland Ellis, Jeffrey Manley, 202-879-5161