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OST-99-6323

U.S.- China Air Service (2001)

Carrier China Web Sites:  American | Federal Express | UPS

On April 8, 1999, representatives of the United States and the People's Republic of China signed a Protocol that amends the U.S.-China Air Transport Services Agreement. The Protocol provides for the expansion, in phases, of U.S.-carrier services in the market beyond the 27 weekly frequencies previously authorized. Under the first two phases, a total of 17 weekly additional frequencies were available either for immediate allocation or for allocation effective April 1, 2000, to the three U.S. carriers now designated to serve the U.S.-China market (Federal Express, Northwest, and United). By Order 99-8-9, dated August 12, 1999, the Department proceeded to finalize its allocations for those first two phases. Under the third phase, effective April 1, 2001, the United States may designate a fourth U.S. carrier. That newly designated carrier and the three previously designated U.S. carriers may operate a combined total of ten additional weekly frequencies. It is these opportunities that are the subject of this notice. The purpose of this notice is to invite applications, as set forth below, from carriers interested in using these opportunities. All four designated carriers will be eligible for allocation of the ten additional frequencies for services on Routes A and B of the agreement.  On Route A, any designated U.S. airline may operate combination and all-cargo services with full traffic rights between any point or points in the United States, via Tokyo or another point in Japan, to Shanghai, Guangzhou, Beijing and two additional points in China to be selected by the United States, from among Chinese airports open to scheduled international operations . On Route B, any designated U.S. airline may operate all-cargo services with full traffic rights between any point or points in the United States, via any intermediate points, to any point or points in China open to scheduled international operations, and beyond to points outside China.

Carriers interested in using the opportunities available April 1, 2001, should file applications within 21 calendar days from the service date of this notice. Answers to such applications should be filed within 14 calendar days from the application date. Replies to answers should be filed within 7 calendar days after the answer date.

By:  Bradley Mims

United Parcel Service Co.

Applies for a Certificate of Public Convenience and Necessity so as to authorize it to engage in the scheduled foreign air transportation of property and mail between any point or points in the United States via intermediate points to a point or points in the People’s Republic of China and to points beyond with full traffic rights between all points on the route. UPS requests that it be granted the fourth designation to serve China available on April 1, 2001, and that it be granted the ten weekly frequencies which also become available on that date. UPS further requests route integration authority enabling it to integrate services on the above-described route with services provided on other routes or under the various exemption authorities held by UPS. UPS proposes to initiate service between the U.S. and China on April 1, 2001, operating six weekly, year-round frequencies between Ontario, California; Anchorage, Alaska; and Beijing and Shanghai, China and four weekly, year-round frequencies between Newark, New Jersey; Anchorage, Alaska and Shanghai, China, over Tokyo, Japan. Other Asian and European markets will be served over Tokyo and Anchorage, and the balance of the U.S. as well as Latin America and eastern Canada will be served over UPS’s principal hub in Louisville, Kentucky. UPS will utilize B-747 freighter aircraft currently in its fleet.

Counsel:  Kelley Drye, David Vaughan, 202.955.9699, dvaughan@kelleydrye.com

U.S.- China Air Services 2001

Counsel:  American, Carl Nelson, 202.496.5647, carl_nelson@amrcorp.com

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

Counsel:  FedEx, M. Rush O'Keefe, 901.395.5189

Counsel:  Northwest, Elliott Seiden, 202.842.3193

Counsel:  Stephen Lachter, 202.862.4321

Counsel:  Kirkland Ellis, Jeffery Manley, 202.879.5161, jeffery_manley@kirklnad.com

U.S. China Air Services (2001)

Counsel:  American, Carl Nelson, 202.496.5647

Counsel:  City of Chicago

Counsel:  Shaw Pittman, Robert Cohn, 202.663.8060

Counsel:  Detroit Airport, David Katz, 734.942.3563

Counsel:  Federal Express, Rush O'Keefe, 901-395-5189

Counsel:  General Manager LIA, James Delong

Counsel:  Northwest, Meghan Rae Rosia, 202.842.3193

Counsel:  Airport Manager, Peter Drinkwater

Counsel:  Stephen Lachter, 202.862.4321

Counsel:  Port of Portland, Bill Alberger, 703.461.3790

Counsel:  GRAA, James Loomis

Counsel:  City/County of San Francisco

Counsel:  Kirkland Ellis, Jeffery Manley, 202.879.5161, jeffery_manley@kirkland.com

Counsel:  Kelley Drye, David Vaughan, 202.955.9600

U.S. China Air Services (2001)

Counsel:  Assistant Attorney General, John L. Steiner, 907.279.5832, John_Steiner@law.state.ak.us

U.S.- China Air Services (2001)

The IBT is requesting to participate as a party to this proceeding because it believes that the outcome is of extreme importance to its members employed by UPS, as well as to its members employed by other companies, and to the economy generally. The IBT members employed by UPS enjoy good wages and benefits under the terms of the collective bargaining agreements with that company. Those terms and conditions of employment not only benefit the employees and their families directly, but also benefit the communities in which they reside and pay taxes. Retention and expansion of these jobs and employment opportunities is of interest to the members, the IBT, and the general economy. All-cargo/express air service has a tremendous impact on businesses and employment outside the airline industry. New air service to China by UPS will have the greatest impact on U.S. economy, U.S. businesses, U.S. employees and the working men and women of UPS represented by the IBT.

Counsel:  IBT, Gary Witlen, 202.624.7466

U.S.-China Service Opportunities

Counsel:  American, Carl Nelson, 202.496.5647, carl_nelson@amrcorp.com

Counsel:  Alaska

Counsel:  Chicago, Eduardo M. Cotillas, (312) 744-6478, ecotillas@ci.chi.il.us

Counsel:  Shaw Pittman, Alexander Van der Bellen, 202.663.8060

Counsel:  FedEx, M. Rush O'Keefe, 901.395.5189

Counsel:  GRAA, James Loomis

Counsel:  Louisville Airport, James Delong

Counsel:  Northwest, Megan Rae Rosia, 202.842.3193

Counsel:  Stephen Lachter, 202.862.4321

Counsel: Port of Portland, Bill Alberger, 703.461.3790

Counsel:  San Francisco, Mara Rosales, (650) 794-5065

Counsel:  Kirkland Ellis, Jeffery Manley, 202.879.5200, jeffery_manley@kirkland.com

Counsel:  Kelley Drye, David Vaughan, 202.955.9600, dvaughan@kelleydrye.com

U.S.-China Service Opportunities

Counsel:  FedEx, Angeline N. Bird, 901.395.5189

U.S.- China Air Service (2001)

We have decided to institute the U.S.-China Air Service (2001) case to consider the selection of an additional U.S. carrier to serve the market and the allocation of 10 additional weekly frequencies to designated carriers to provide scheduled services in the market, effective April 1, 2001. By this order we also establish further procedures and a procedural schedule that will be used in the comparative selection proceeding. This proceeding will consider the applications of American, Delta, UPS, and Polar for the available U.S. carrier designation, and the applications of those carriers and Federal Express, Northwest, and United for allocation of some or all or tile 10 new weekly frequencies available for allocation.

By:  Bradley Mims

U.S.-China Air Services (2001)

Counsel:  Federal Express, M. Rush O'Keefe, 901-395-5189

Counsel: Northwest, Meghan Rae Rosia, 202.842.3193

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

U.S.- China Air Services (2001)

American Airlines, Inc. hereby petitions for reconsideration of Order' 2000-1-21, January 26, 2000, instituting the U.S.-China Air Services (2001) proceeding. On, reconsideration, the Department should state that it will provide the same routing flexibility to the newly designated carrier that is presently enjoyed by incumbent carriers to respond to changes in market demand. In addition, the Department should require each applicant carrier to respond to an additional information request on cargo shipments.

Counsel:  American, Carl Nelson, 202.496.5647, carl_nelson@amrcorp.com

U.S.- China Air Services (2001)

OST-99-6323	February 7, 2000	Answer of Federal Express to Petition for Reconsideration HTML Scanned Copy	U.S.-China Air Services 2001
		Service List

Federal Express agrees with American that complete historical data are necessary to develop a full evidentiary record. The requested information will enable the Department to assess the air service needs of the U.S.-China market accurately.

Counsel:  Federal Express, Rush O'Keefe, 901-395-5189

Northwest is particularly concerned that compliance with the information request proposed in Part 11 of American's Petition would be extremely problematic and could result in inconsistent and confusing information that would not be helpful to the parties or the Department in examining the issues in this case.

Counsel:  Northwest, Megan Rae Rosia, 202.842.3193

American has offered no support for its asserted definition of "express cargo" nor for the need for the requested data covering over four years. United has no detailed records of its cargo for the period requested by American that would enable it to identify shipments falling in to the ad hoc "express cargo" category proposed by American. If the Department intends to obtain data broken out into a distinct category such as that proposed by American, it would need to undertake a rulemaking proceeding subject to notice and comment. One of the issues that would be explored in such a proceeding is the appropriate definition of 44express cargo." Such a rulemaking, if adopted, would put carriers on notice of the need to retain records in the detail needed to provide such data and would give them adequate time to comply. It is unreasonable, however, to require carriers to undertake such reporting after the fact. United would have to search hundreds of thousands of U.S. -China cargo waybills to make the breakout American seeks and even then United cannot be confident that "express cargo" shipments can be properly identified. United strongly opposes American's untimely request for this additional information.

Counsel:  Kirkland Ellis, Jeffery Manley, 202.879.5161, jeffery_manley@kirkland.com

On a separate but related issue, UPS notes that in Order 2000-1-21, at the top of page five, the Department indicated that it would require all applicants to provide passenger traffic carried on any code-sharing partner's aircraft for both historical and forecast periods. However, in the Department's Evidence Request at Appendix C to that Order, the Department appears to have omitted this requirement. United Parcel Service Co. respectfully requests that the Petition for Reconsideration of American Airlines be denied and that the Department grant such other relief as may be deemed just and necessary.

Counsel:  Kelley Drye, David Vaughan, 202.955.9600, dvaughan@kelleydrye.com

U.S.- China Air Services (2001)

Northwest Airlines, Inc. submits this Reply to the Answer of Federal Express Corporation to the Petition of American Airlines, Inc. for Reconsideration of Order 2000-1-21. Because neither Order 2000-1-21 nor 14 C.F.R. § 302.37 contemplates the filing of replies to answers to petitions for reconsideration, Northwest respectfully requests leave to file this reply. As discussed below, although submitted in the form of an answer to American's Petition, Federal Express' pleading is in fact a separate and untimely petition for reconsideration, to which other parties should have an opportunity to respond.

In short, under the guise of filing an answer to American, Federal Express has submitted its own de facto petition for reconsideration. Order 2000-1-21 required the parties to file petitions for reconsideration within seven calendar days of the service of that order. If Federal Express wanted the Department to require the applicants to produce additional passenger data or additional cargo data, it could and should have submitted its request within that time frame. Federal Express' de facto petition, however, was filed well after the deadline expired. There is no legitimate justification for Federal Express' untimely request, and the Department should reject Federal Express' effort to have the Department impose new information requirements on the applicants.

Counsel:  Northwest, Megan Rae Rosia, 202.842.3193

U.S.- China Air Services (2001)

In short, the cargo data we have requested is highly relevant to the issues in this proceeding, and should be required in order to produce a complete record for the Department's consideration.

Counsel:  American, Carl Nelson, 202.496.5647, carl_nelson@amrcorp.com

Counsel:  FedEx, M. Rush O'Keefe, 901.395.5189

U.S.- China Air Services (2001)

The Department should reject American's, Federal Express's and Northwest's Unauthorized Replies and refuse to receive them for consideration in this case. The procedures set forth in the Instituting Order for this proceeding, as well as the DOT procedural rules generally, do not provide for Unauthorized Replies, and American, Federal Express and Northwest have made no showing why their Unauthorized Replies should be received here. The Department provided an excellent procedural schedule in the Instituting Order for this proceeding which allows the parties ample time for the presentation of fully documented cases without unduly delaying the decision to be made in this case.

Counsel:  Kelley Drye, David Vaughan, 202.955.9600, dvaughan@kelleydrye.com

U.S.- China Air Services (2001)

Federal Express continues to believe that this unique proceeding - which pits the interests of shippers against the interests of passengers - should be referred for decision to an administrative law-judge. The evidentiary issues here are precisely the types of issues that an experienced administrative law judge would routinely handle. The repeated rounds of motions, answers, and replies show why the appointment of an ALJ to handle the collection and analysis of the record would actually expedite this proceeding. An ALJ would have convened a brief pre-hearing conference to hear all parties' views of the issues and the information that they believe necessary to resolve them.

Counsel:  FedEx, M. Rush O'Keefe, 901.395.5189

U.S.-China Air Services (2001)

Federal Express respectfully moves the Department to grant it leave to file the attached answer responding to UPS's Objections filed on February 11, 2000. In its Objections, UPS asserts that American's petition for reconsideration of Order 2000-1-21, and Federal Express' answer to that petition, are procedurally defective, which is not true. Further, UPS's position that cargo carriers should not have to disclose the extent of their participation in the U.S.-China market is inconsistent with its prior position that the Department should require combination carriers to disclose the same information. Fairness and the public interest therefore dictate that the Department should receive and consider Federal Express' answer to UPS's objections. In addition, since this answer is being filed within one business day of the Objections to which it relates, granting this motion will not unfairly prejudice any applicant or unduly delay this proceeding.

Counsel:  Federal Express, Rush O'Keefe, 901-395-5189

U.S.- China Air Services (2001)

Counsel:  Shaw Pittman, Robert Cohn, 202.663.8060, robert.cohn@shawpittman.com

U.S.-China Air Services (2001)

By this order, we grant the petition for reconsideration of Order 2000-1-21 filed by American Airlines, and, on reconsideration, we will defer a decision on American's request with respect to the scope of authority to be awarded in this proceeding until we issue our tentative decision, and we will deny American's request with respect to requiring applicants to file additional historical cargo data.

As the parties have correctly noted, the Department's standard practice in carrier selection cases is to require the selected carrier to serve the city-pair market(s) that it proposed to serve. This is because that specific service pattern is often critical to the Department's decision to select one carrier over another for the available route rights. Nevertheless, we recognize that in a given situation there may be circumstances where the standard condition may not be appropriate. Given the particular facts and circumstances of the U.S.-China market, we believe that such a decision is better made in this case after the record has been fully developed and, specifically, after we are in a position to make a tentative decision as to which carrier, if any, to authorize for new service to China and how to allocate the available frequencies. By deferring a decision on the issue raised by American until we issue our tentative carrier selection decision, we will afford all parties and the Department the opportunity, based on a complete evidentiary record, to determine whether the Department's standard condition should be applied in this case. Parties that have not commented on the issue, but wish to do so, and parties that have commented and wish to supplement their comments will be free to do so at the various evidentiary stages of the case.

We have decided to deny American's petition to the extent that it requests that all applicants be required to provide additional evidence on their historical cargo traffic, with the data broken down into express cargo traffic and total cargo traffic.

We conclude that the evidence request attached to Order 2000-1-21 will result in sufficient historical cargo data to provide an adequate record for decision in this proceeding, including a decision on the precise issues raised by American. We have already released to the parties to this case the historical traffic data (cargo and passenger) collected by the Department for U.S. and foreign carriers serving the U.S.-China market. Furthermore, the evidence request attached to Order 2000-1-21 requires applicants to provide specific details on their traffic forecasts. As such, the applicants can be expected to provide considerable additional information regarding the cargo needs of the market in their direct and rebuttal exhibits, thereby further enhancing the record in this proceeding. Our evidentiary approach is consistent with that we have followed in other selection cases where we found the record adequate for decision. Against this background, we are not persuaded that the additional information requested by American, or as revised by Federal Express, would be of sufficient use in this case to justify the additional burden on the applicants required to produce it.

We also will not require applicants to provide historical data on code-share traffic. The evidence request already requires carriers to provide a full description of the code-share services provided in the U.S.-China market. In addition, as discussed above, applicants are required to provide specific details to support their forecasts of any code-share traffic and we are confident that the information supplied together with that already available will provide an adequate record on this matter.

By:  Bradley Mims

U.S.- China Air Services (2001)

Since Federal Express started serving the U.S.-China market, FPA pilots have experienced first hand China's explosive growth and its yet-untapped potential, China's demand for American products and technological assistance continues to rise and the Department must choose the air express/cargo carrier that can best help U.S. businesses to meet this demand. As the pre-eminent carrier of U.S. exports around the world, Federal Express has played a leading role in meeting the needs of U.S. businesses in China.

The Department should grant Federal Express the frequencies it needs to enhance and further develop its Chinese facilities for the benefit of U.S. exporters and other shippers. If given the opportunity, the FPA is convinced that the effect of expanding Federal Express' services in China will be similar to other situations where the introduction and expansion of Federal Express' services in foreign nations spurred competition in the U.S. economy and job creation. The Department should preserve and expand the creation of such jobs and their concomitant benefits for everyone involved. Equally important, under the contract signed between the FPA and Federal Express in February 1999, FPA pilots earn competitive salaries and receive one of the best retirement packages in the industry. These employment benefits have an effect on the FPA pilots' families, their local communities, and the national economy. Moreover, the FPA is dedicated to ensuring a safe and reliable operation, and to improving consumer service.

Counsel:  FedEx Pilots, Michael Stimson, 901.752.8749

U.S. China Air Services (2001)

Carrier China Web Sites:  American | Federal Express | UPS

Counsel:  Anchorage Airport, Morton Plumb

Counsel:  American, Carl Nelson, 202.496.5647

Counsel:  Winthrop Stimson, Kenneth Quinn, 202.775.9800

Counsel:  CNKIA, Robert Holscher, 606.767.3080

Counsel:  Shaw Pittman, Robert Cohn, 202.663.8060

Counsel:  Federal Express, Rush O'Keefe, 901-395-5189

Counsel: GRAA, James Loomis

Counsel:  IBT, Gary Withen

Counsel:  LAWA, Lydia Kennard

Counsel:  LRAA, James DeLong

Counsel:  RBP, Chip Hallock

Counsel:  Northwest, Meghan Rae Rosia, 202.842.3193

Counsel:  City of Ontario, Mary Jane Olhasso

Counsel:  Stephen Lachter, 202.862.4321

Counsel:  Winthrop Stimson, Kenneth Quinn, 202.775.9800

Counsel:  Wilmer Cutler, Jeffery Manley, 202.663.6000

Counsel:  GKMG, Morris Garfinkle, 202.342.5201

American Airlines, Inc.

Counsel: American, Carl Nelson, 202-496-5647, carl_nelson@amrcorp.com

U.S.- China Air Services 2001

Counsel:  American, Carl Nelson, 202.496.5647, carl_nelson@amrcorp.com

U.S.-China Service Opportunities

By:  Indianapolis International Airport

Counsel:  Northwest, Meghan Rae Rosia, 202.842.3193

U.S.-China Air Services (2001)

Counsel:  UPS and Kelly Drye, David Vaughan, 202-955-9600

U.S.- China Air Services (2001)

In reviewing the direct testimony and exhibits of UPS, Federal Express noted serious flaws in its submissions that made them impossible to analyze. Although there appeared to be many errors, we were especially concerned that the direct testimony referred to exhibits and exhibit pages that did not exist.  We therefore request that the Department ask both UPS and Northwest to supply by Monday, March 13, 2000, red-lined versions of all revised exhibits and testimony for the record. Further, we ask that the Department extend the time for filing rebuttal exhibits by 13 days to enable all parties to start afresh at the same time on March 13 with a clean set of exhibits. If granted, the Department should also extend the time for filing briefs by 13 days.

Counsel:  FedEx, Rush O'Keefe, 901.395.5189

U.S.- China Air Services (2001)

Delta Air Lines, Inc. supports Federal Express's request. Due process requires the Department to grant additional time to evaluate the substantial revisions submitted by UPS and Northwest. UPS's changes, in particular, go well beyond the bounds of standard Department practice with respect to the submission of errata. UPS's changes involve fundamental revisions to correct significant mistakes that were rampant throughout UPS's voluminous direct exhibit presentation. In addition, Delta did not receive timely service of UPS's direct exhibits on the due date established by the Department in the Instituting Order. Delta's counsel did not receive its copy of UPS's exhibits until the close of business on the day after direct exhibits were due. The copy of UPS's exhibits that were sent by UPS to Delta personnel in Atlanta were also not timely received and eventually were resent via Federal Express two days late. Delta also supports Federal Express's request to require UPS and Northwest to submit "redlined" versions of the revised exhibits in order to afford the Department's staff and other parties the ability to comprehend the full scope of the massive changes made, particularly by UPS, to its exhibits.

Counsel:  Shaw Pittman, Robert Cohn, 202.663.8060

Northwest Airlines, Inc. hereby Answers the Motion filed yesterday by Federal Express Corporation, wherein Federal Express requests a 13-day delay in the due dates for rebuttal exhibits and briefs in this proceeding, citing the filing by UPS and Northwest of revised exhibits. Northwest did file a handful of revised direct exhibit pages on March 7. Most of these revisions correct errors of a typographical character or involve stylistic edits (such as the addition of subheadings for the ease of readers), and none impact the substance of Northwest's direct case. There is nothing unusual about the filing of revised exhibits, indeed it occurs in almost every route proceeding of this nature. Northwest filed its revised exhibits 7 days after the direct exhibit due date, and served all parties by hand or overnight delivery, leaving a full three weeks for rebuttal. Northwest does not believe any delay in the remaining due dates in this proceeding is warranted under the circumstances.

Nevertheless, in an effort to facilitate prompt resolution of Federal Express' procedural objection, Northwest does not oppose a short extension of due dates. The 13-day extension sought by Federal Express, however, is excessive. Northwest believes a 7-day extension should be more than sufficient to dispose of Federal Express' Motion. This would cause rebuttals to be due on Tuesday, April 4, and Briefs on Tuesday, May 2. As for Federal Express' demand for "redlined" versions of revised exhibit pages, to Northwest's best recollection the Department has never required such redlining in a route proceeding. To do so here would be unwarranted and unduly burdensome. Northwest believes its revised exhibits are self-explanatory.

Counsel:  Northwest, Megan Rae Rosia, 202.842.3193

The vast majority of the changes made by UPS are merely corrections to Exhibit numbers in source references and corrections to typographical errors. UPS chose not to stipulate to Federal Express' requested extension because Federal Express is obviously intent on delaying this proceeding as much as possible. For example, Federal Express urged that the Department conduct an oral evidentiary hearing before an Administrative Law Judge, even though the Department had not held an oral evidentiary hearing procedure in years. Given the large number of parties to this proceeding, an oral evidentiary hearing, with all of its attendant procedural steps (e.g. briefs to the Administrative Law Judge, Recommended Decision, cross-examination etc.), would add many months to the procedural schedule. The Department rightly rejected this request.  Federal Express then requested a delay for the submission of further evidence by certain applicants.  Again the Department rejected the request. It is therefore not surprising to see Federal Express again suggesting a delay here.

UPS filed its corrections to its Exhibits six business days after the filing of the Exhibits - the day after Northwest filed its corrections - which is a normal time period for such filings. Nevertheless, although UPS does not think it necessary, UPS would not object to a oneweek extension in the submission date for Rebuttal Exhibits (if only to permit the Department to focus on reviewing the merits of the case as opposed to ensuring that every footnote is now correctly annotated).  With regard to Federal Express' Motion to Compel the filing of red-lined replacement pages, although UPS believes its previous filing was adequate and Federal Express has nowhere explained why it is entitled to red-lined versions, UPS is supplying red-lined versions of its substituted pages herewith to eliminate further debate.

Counsel:  UPS and Kelly Drye, David Vaughan, 202-955-9600

U.S.-China Air Services (2001)

We have decided to extend the due date for the filing of rebuttal exhibits and briefs by seven days-to April 4, 2000, and May 2, 2000, respectively. We have also decided not to compel Northwest Airlines to file a "red-lined" version of its revised direct exhibits.  We have reviewed the changes made by both Northwest and UPS in their corrected direct exhibits. While in both cases some of the changes revise various numbers presented in the exhibits or provide more detailed information, the majority of the changes involve non-substantive corrections to the exhibit material. In these circumstances, we believe that a one-week extension of both dates will give the parties sufficient time to deal with the revisions in preparing their rebuttal exhibits, as well as sufficient time to prepare their briefs, while still ensuring that the Department can continue to proceed in a timely manner in this case. Regarding the request for a "red-lined" version, our review of Northwest's corrections indicates that the vast majority of the changes made by Northwest are readily apparent and self-explanatory. Thus, we are not persuaded that compelling Northwest to provide a "red-lined" version of its changes is necessary in the circumstances presented.

By:  Bradley Mims

U.S.- China Air Services (2001)

Counsel:  GKMG, Anita Mosner, 703.312.0350, consult@gkmg.com 

Counsel:  American, Carl Nelson, 202-496-5647, carl_nelson@amrcorp.com

Counsel:  Winthrop Stimson, Kenneth Quinn, 202.775.9800

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

Counsel:  FedEx, David Glauber, 901.395.5189, daglaube@fedex.com 

Counsel:  GKMG, Anita Mosner, 703.312.0350, consult@gkmg.com 

Counsel:  GKMG, Anita Mosner, 703.312.0350, consult@gkmg.com 

Counsel:  GKMG, Anita Mosner, 703.312.0350, consult@gkmg.com 

Counsel:  Regional Business Partnership, Howard Kass, 973.242.4209

Counsel:  Northwest, Meghan Rae Rosia, 202.842.3193

Counsel:  GKMG, Anita Mosner, 703.312.0350, consult@gkmg.com 

Counsel:  Stephen Lachter, 202.862.4321

Counsel:  San Francisco International, Mara Rosales

Counsel:  Wilmer Cutler, Jeffery Manley, 202.663.6000, jmanley@wilmer.com 

Counsel:  Kelley Drye, David Vaughan, 202.955.9600