Before the U.S

Home , JetBlue

BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, DC ______) Application of ) ) AMERICAN AIRLINES, INC. ) BRITISH AIRWAYS PLC ) OPENSKIES SAS ) IBERIA LÍNEAS AÉREAS DE ESPAÑA, S.A. ) Docket DOT-OST-2008-0252 FINNAIR OYJ ) AER LINGUS GROUP DAC ) ) under 49 U.S.C. §§ 41308 and 41309 for approval ) of and antitrust immunity for proposed joint ) business agreement ) ______)

ANSWER OF JETBLUE AIRWAYS CORPORATION

Communications with respect to this document should be sent to:

Robert C. Land Senior Vice President, Government Affairs and Associate General Counsel

Adam L. Schless Director Aircraft Transactions and International Counsel Reese Davidson Manager Staff Counsel International

JETBLUE AIRWAYS CORPORATION 1212 New York Avenue, NW Suite 1212 Washington, DC 20005 (202) 715-2565 [email protected] [email protected] [email protected] September 9, 2020 BEFORE THE U.S. DEPARTMENT OF TRANSPORTATION OFFICE OF THE SECRETARY WASHINGTON, DC ______) Application of ) ) AMERICAN AIRLINES, INC. ) BRITISH AIRWAYS PLC ) OPENSKIES SAS ) IBERIA LÍNEAS AÉREAS DE ESPAÑA, S.A. ) Docket DOT-OST-2008-0252 FINNAIR OYJ ) AER LINGUS GROUP DAC ) ) under 49 U.S.C. §§ 41308 and 41309 for approval ) of and antitrust immunity for proposed joint ) business agreement ) ______)

ANSWER OF JETBLUE AIRWAYS CORPORATION

JetBlue Airways Corporation (“JetBlue”) submits this Answer to address urgent concerns

about a fundamental predicate to DOT’s continuing approval and grant of antitrust immunity (ATI)

to the oneworld transatlantic alliance: the London Heathrow Airport (LHR) slot remedy condition.

Consistent with its previous filings in this and other dockets, JetBlue reiterates it is not opposed to

joint ventures or grants of ATI per se. JetBlue takes no position on the merits of the joint

applicants’ request to add Aer Lingus to the oneworld transatlantic joint venture, provided that

DOT maintain, or expand, the LHR remedies in place including the requirement that four LHR

slot pairs be made available to new entrants.

As an essential condition to granting ATI to the oneworld transatlantic alliance in 2010,

DOT required the reallocation of LHR slots as a “remed[y] to address harm to competition” from granting ATI.1 That slot remedy is due to expire in March 2021. JetBlue has firm plans to start serving LHR from Boston and New York (JFK) in 2021, but cannot do so without access to LHR slots at “commercially viable”2 times of the day. For the reasons set forth below, JetBlue requests

that DOT, in conjunction with the UK’s Competition and Markets Authority (CMA),3 extend the duration of the 2010 slot remedy and repurpose it to address current barriers to entry and competition in U.S.-LHR markets by reallocating at least four daily slot pairs to JetBlue. At a minimum, DOT should maintain the requirement that four slot pairs be available for new-entrants with two slot pairs dedicated for service at Boston and two “flex” slot pairs for service at any U.S. gateway. U.S.-LHR markets are far less competitive than in 2010 and timely DOT action is necessary to address this competitive problem.

I. JetBlue’s Independent Partnerships with Aer Lingus and American

JetBlue is pleased that the proposed expanded oneworld JV “preserves Aer Lingus’ ability to cooperate and codeshare with other carriers, including other value carriers and LCCs” and

“maintains Aer Lingus’ freedom to continue its existing codesharing with JetBlue.”4 Aer Lingus has been a valued partner of JetBlue since 2008 and JetBlue hopes that Aer Lingus will maintain and grow the partnership as JetBlue prepares to launch transatlantic service.

JetBlue recently announced a Northeast Alliance with American. This bilateral alliance

(which involves American but none of the other applicants in this proceeding) focuses on four

1 Order 2010-2-8, Feb. 13, 2010, at 25-27 (DOT-OST-2008-0252). DOT described the LHR slot remedy as “the best [way to] address the potential competitive harm in this case.” Id. at 26. 2 Id. at 26 & n.88.

3 DOT has stated that it is coordinating with the CMA, which has been conducting a two-year investigation into competitive conditions at LHR, “to address potential competition concerns regarding competition in transatlantic markets.” DOT Notice Establishing Procedural Schedule, Aug. 12, 2020 (Docket DOT-OST-2008-252) at 2. 4 Joint Motion to Amend Order 2010-7-8 for Approval of and Antitrust Immunity for Amended Joint Business Agreement, Dec. 21, 2018 (Docket DOT-OST-2008-0252) at 26 and 43.

airports in the northeastern U.S. where JetBlue and American operate primarily domestic

networks. This unique, but limited, alliance, which is currently undergoing regulatory review, will

aid JetBlue’s recovery from COVID-19 and help it to avoid pilot and other crewmember furloughs

by buttressing its fleet size above a level that depressed COVID-19 demand would otherwise

warrant.

For purposes of this ATI proceeding, it is important to note that JetBlue’s own-metal

transatlantic service is specifically excluded from the scope of its proposed new alliance with

American. JetBlue will be an independent, vigorous competitor in U.S.-LHR and other U.S.-

Europe markets. The American alliance has not altered JetBlue’s transatlantic plans; rather, it

bolsters and enhances JetBlue’s plans by providing increased passenger feed at BOS and JFK,

including for its new transatlantic flights. Because JetBlue will not be a party to the oneworld JV

(and has no plans to join it), JetBlue will remain an independent competitor of the oneworld JV,

without immunity from U.S. antitrust laws. It is in this context that JetBlue, as a vigorous,

independent competitor of the oneworld JV, urges DOT to establish a robust, repurposed LHR slot remedy as an essential competitive counterbalance to a continuing grant of ATI for the expanded oneworld JV alliance, which operates in far more anticompetitive conditions than when DOT granted ATI in 2010.

II. Competitive Conditions in U.S.-LHR Markets Have Fundamentally Changed Since 2010 and Warrant a Restructured Slot Remedy

Before the COVID-19 pandemic, the airline industry experienced an extended period of consolidation through mergers and grants of ATI for alliances. As a direct consequence, U.S.-

LHR markets have become excessively concentrated. Under the standard antitrust measure of

industry concentration, the HHI Index, the U.S.-LHR market has gone from 2,404 (moderately

concentrated) in June 2010 to a staggering 3,982 (highly concentrated) in June 2019.5

The oneworld and SkyTeam immunized alliances now collectively control approximately

70% of slots at LHR. Carriers that used to be new entrants and smaller non-aligned incumbents

such as Delta and Virgin Atlantic are now part of dominant immunized alliances. LCCs,

meanwhile, either have gone out of business, exited U.S.-London markets entirely, or serve the

U.S. from other London airports with no competitive effect on fares or service at LHR.6

“Competition” in U.S.-LHR markets is essentially limited to the three immunized mega alliances,

which operate similar business models and largely compete with each other only indirectly by

serving different U.S. hubs. In the largest U.S.-LHR market (New York-LHR), 100% of service

is operated by one of the three large immunized joint ventures. For these reasons, U.S.-LHR

markets are in desperate need of the benefits of disruptive competition from a new entrant. To

address these structural competitive problems, DOT should require a modified slot remedy that

provides meaningful access to LHR for new entrants such as JetBlue.

DOT has long recognized the need for new entrants to be able to obtain access to LHR.

When evaluating the proposed oneworld transatlantic JV in 2010, DOT warned of the alliance’s

potentially adverse effects on LHR access: “[w]ithout more and easier access to Heathrow slots,

competing carriers would find it difficult to introduce new services to compete with an immunized

oneworld.”7 In concert with the European Commission (DG-COMP), DOT conditioned immunity

5 Cirium schedule data. 6 Many carriers have exited the broad U.S.-Europe market in recent years, including Air Berlin, Air Italy, Primera, WOW and others. 7 Order 2010-2-8, Feb. 13, 2010, at 25 (DOT-OST-2008-0252).

for the JV on a LHR slot remedy to protect competition, including a requirement that two slot pairs

be “earmarked for the Boston-London Heathrow market.”8

Ten years later, the 2010 slot remedy needs to be restructured and repurposed to address

the lack of competition and access in U.S.-LHR markets. When DOT first granted ATI to the

oneworld transatlantic alliance (in this docket) a decade ago, those carriers controlled 45% of LHR slots. Since then, British Airways and Iberia merged and formed the International Airlines Group

(IAG). IAG subsequently acquired Vueling, Aer Lingus and LEVEL/OpenSkies (and its purchase of Air Europa is pending). These airlines control a significant number of LHR slots on their own

(including Aer Lingus, which was not analyzed by DOT in 2010) and have been methodical about increasing their respective and combined slot portfolios since 2010. They have acquired the former slot holdings of bmi, and earlier this year resumed control of approximately a dozen remedy slot pairs that Flybe had been using. The cumulative effect is that today these carriers now control approximately 60% of LHR slots.9 Even before COVID, the IAG carriers struggled with the

enviable problem of how to maintain the minimum level of usage necessary to retain their vast

LHR slot portfolio.

In addition to the oneworld immunized JV alliance’s 60% of LHR slots, the SkyTeam

immunized JV alliance – which includes Delta, Virgin Atlantic and Air France-KLM – have an

almost 10% share of LHR slots. In 2010, Delta was considered a new entrant at LHR, and received

8 Id. at 26. 9 In 2010, DOT predicted that “the proposed alliance would allow oneworld to control almost half of Heathrow’s available slots, making new entry even more difficult...” Order 2010-2-8, Feb. 13, 2010, at 2-3 (DOT-OST-2008- 0252) (emphasis added). DOT, however, did not anticipate the oneworld alliance holding 60% of all LHR slots.

a “starter kit”10 that included remedy slots.11 At the time, Delta asserted that LHR slots were “vital to Delta’s and SkyTeam’s efforts to provide a viable competitive challenge to American and

British Airways now that those carriers have joined forces and will be acting in concert, rather than competing.”12 Ten years later, Delta has long ceased to be a new entrant or limited incumbent; on the contrary, it (along with its alliance partners) is the second largest LHR incumbent slot holder. Thus, Delta no longer has a legitimate claim to retain remedy slots.

COVID-19 has had an unprecedented impact on services in the transatlantic market.

During the pandemic, the large incumbents have substantially scaled back their U.S.-LHR

operations in response to reduced demand and governmental restrictions on transatlantic air travel.

As a result, those carriers are not using a large portion of their LHR slot holdings and have no

plans to do so for the foreseeable future:

• American Airlines postponed its previously announced resumption of Boston-LHR service. In addition, American has cancelled flights between the following U.S. cities and LHR: Charlotte (2 daily flights); Los Angeles (2 daily flights); Philadelphia (2 daily flights); Phoenix (1 daily flight); and Raleigh-Durham (1 daily flight).13

• Delta-Virgin Atlantic have decided to exit the Portland-LHR and Salt Lake City-LHR markets. Delta recently announced that its Summer 2021 LHR schedule will consist of only seven daily

10 See Consolidated Joint Reply of the JV Parties, Feb. 15, 2019, at 14 (DOT-OST-2013-0068) (in which Delta criticized JetBlue for seeking a “starter kit” in the form of a similar allocation of LHR remedy slots to the one Delta received in 2010). Delta’s insinuation that JetBlue somehow is seeking favorable treatment from regulators in order to compete not only ignores Delta’s own history at LHR, but also DOT’s rationale for imposing a remedy slot condition: that new entry benefits consumers by intensifying competition, lowering fares, and increasing the range of available service options. Order 2010-2-8, Feb. 13, 2010, at 25 (Docket DOT-OST-2008-0252) (noting the Department of Justice’s view that “slot transfers could potentially protect consumers from the anticompetitive effects of the proposed [immunized] alliance” (emphasis added)). Thus, JetBlue’s entry will greatly benefit consumers, even if it denies Delta and its immunized JV partners the privilege of remaining insulated from competition from JetBlue behind a slot-based firewall. 11 Delta ceased operating one of its BOS-LHR remedy slot pairs in October 2011. Order 2013-8-21, Aug. 30, 2013, at 12 (DOT-OST-2013-0068). Delta also applied for one pair of LHR slots to operate daily year-round LHR-Miami service. Application of Delta Air Lines, Inc., Aug. 26, 2010, at 1 (Docket DOT-OST-2008-0252). 12 Business Plan of Delta Air Lines, Oct. 14, 2010, at 1 (DOT-OST-2008-0252) (emphasis added). 13 Routes Online, “American Airlines July-Oct 2020 Inter-continental operations as of 05JUL20,” July 5, 2020, available at https://www.routesonline.com/news/38/airlineroute/292314/american-airlines-july-oct-2020-inter- continental-operations-as-of-05jul20/?highlight=american%20airlines%20london. American has cancelled all of the services referenced above in text at least until October 23, 2020.

flights.14 In the meantime, Delta has also reduced utilization of its LHR slots for transatlantic service during the winter 2020/2021 season15 from: Boston (from 7 to 5 weekly flights); Detroit (cancelled); Minneapolis (cancelled); and New York-JFK (reduced from 3 to 1 daily).16 It remains to be seen how Virgin Atlantic’s bankruptcy will affect its transatlantic services in the future.

As a result, a reallocation of remedy slots to JetBlue or other new entrants will not affect

existing or planned services by incumbent slot holders. Moreover, even if they eventually were to

decide to resume a substantial portion of their prior U.S.-LHR services, those carriers and their

immunized alliance partners could do so without having to rely on remedy slots.17 Thus, the time

is long overdue and indeed ripe to reallocate remedy slots to JetBlue, which is committed to

entering U.S.-LHR markets in 2021, despite the effects of COVID-19.

III. JetBlue’s Plans to Serve London Remain On Track Despite COVID-19 Crisis

JetBlue, like every other airline in the world, has been deeply impacted by the global

COVID-19 pandemic and resulting economic crisis. Yet despite the extraordinary and

unprecedented crisis facing the industry, JetBlue is confident that it and the industry are on a path

to eventual recovery. The airline industry is simply too crucial to the fabric of the world economies

for the status quo to continue. JetBlue built its success on innovation, providing travelers the value

of an LCC and the service quality of one of the world’s best airlines. We celebrated the 20th

14 Delta Air Lines, “Delta brings back travel destinations across Atlantic and Pacific this winter and summer 2021,” Aug. 21, 2020, available at https://news.delta.com/delta-brings-back-travel-destinations-across-atlantic-and-pacific- winter-and-summer-2021. 15 Routes Online, “Delta NW20 Long-Haul operation changes as of 23AUG20,” Aug. 24, 2020, available at https://www.routesonline.com/news/38/airlineroute/293287/delta-nw20-long-haul-operation-changes-as-of- 23aug20/?highlight=delta. 16 Routes Online, “Delta NW20 Long-Haul operation changes as of 23AUG20,” Aug. 24, 2020, available at https://www.routesonline.com/news/38/airlineroute/293287/delta-nw20-long-haul-operation-changes-as-of- 23aug20/?highlight=delta. 17 With hubs at both LHR and BOS, the Delta-Virgin Atlantic immunized partnership has sufficient access to LHR slots to increase LHR-BOS service at any time and does not require remedy slots to do so. JetBlue, by contrast, has no other way of accessing LHR slots in order to enter the BOS-LHR (or JFK-LHR) route.

anniversary of our first flight in February 2020, just before the COVID-19 crisis struck. The

pandemic will not prevent our re-emergence and continued success in the next decade and beyond.

Despite all the challenges and setbacks of COVID-19, JetBlue’s plans remain on track to

inaugurate London service in summer 2021. Specially outfitted Airbus A321LR aircraft are due

to be delivered in approximately six months and JetBlue’s ETOPS certification program is well

underway. JetBlue crewmembers are finalizing Mint 2.0 product selections for our transatlantic

(and other key) routes.

JetBlue notes these details because it is crucial that DOT reach a decision in this case that will address competition beyond the current COVID-19 crisis. Even in these circumstances in which transatlantic travel has ground nearly to a halt, new entrants still cannot obtain LHR slots.

Incumbent carriers at LHR are currently operating at levels below the minimum LHR slot usage requirements, yet retain their slots based on a temporary waiver of those requirements, which is expected to extend through the upcoming winter IATA season. Thus, there is no prospect that

LHR slots will become available, despite JetBlue’s persistent attempts to obtain access, via the slot coordinator or in the secondary market. Time is of the essence. JetBlue plans to launch

London service in the summer 2021 IATA season, which begins approximately seven months from

now. It is thus imperative that DOT and the CMA ensure that slots be available for new entrants

in 2021, concurrent with the expiration of the 2010 slot remedy in March 2021.

IV. The Essential Competitive Issue In this Case is Lack of LHR Access for New Entrants

LHR is a slot-controlled airport where the two largest slot holders (the oneworld and

SkyTeam immunized JV alliances) collectively hold approximately 70% of all slots. Because the

LHR slot coordinator has no slots available for allocation to a new entrant such as JetBlue, the

airport (which is the essential London airport for business travelers and passengers connecting to

other cities in the UK, Europe, and around the world) remains effectively closed to new entry, as

it was in 2010.

Absent a slot remedy, the skies between the U.S. and LHR are “open” in name only (as a

legal/bilateral matter), but remain closed to meaningful consumer competition and the many consumer benefits of new entry. Only governmental action will pry LHR open sufficiently to enable JetBlue to enter and compete with the three mega alliances, which (in addition to the protection from competition that the LHR slot-based entry barrier provides them) continue to enjoy the extraordinary privilege of DOT-conferred immunity from U.S. antitrust laws. JetBlue urges

DOT to work closely with the CMA to expand and repurpose the 2010 slot remedy to enable

JetBlue to enter U.S.-LHR markets.

V. Only JetBlue Can Provide Much-Needed New Entrant U.S.-LHR Competition JetBlue is the only carrier that can currently provide much needed new entrant competition to both the American/oneworld and Delta/SkyTeam immunized alliances in U.S.-LHR markets.

As noted, JetBlue has confirmed plans to begin service from BOS and JFK to London in 2021 and has 26 Airbus A321LR/XLR aircraft on order capable of operating transatlantic service. JetBlue’s entry will disrupt the entrenched oneworld/SkyTeam immunized oligopoly in U.S.-LHR markets because JetBlue will offer a full-service product (including JetBlue’s lauded Mint service, with lie-flat beds in the premium cabin) at lower fares. JetBlue has also developed a strong network and hubs at BOS and JFK from which it can offer low-fare benefits in the transatlantic market and introduce U.S.-LHR competition in hundreds of city pairs. However, without an extended and restructured slot remedy to enable access to LHR, JetBlue (like any other new entrant) will be unable to enter, establish, and maintain a commercially viable level of service to compete with the immunized alliances in U.S.-LHR markets.

JetBlue’s proposed service will substantially benefit passengers in the BOS-LHR market

in particular, which suffers from a dearth of competition. The joint applicants claim that “BOS-

LHR is a highly competitive route,” citing competition on the route from Norwegian and JetBlue.18

This is demonstrably untrue. Neither carrier currently serves any U.S.-LHR route, nor can JetBlue

do so until it receives LHR slots. Norwegian served the BOS-LON market, but from LGW, not

LHR.19 Norwegian is facing a dire financial crisis, with its future uncertain. It suspended all of

its LGW-BOS services in March 2020 due to COVID-19, has repeatedly postponed plans for

resuming service, and now states that it will do so in late March 2021 at the earliest.20

JetBlue is in a very different position. It has the resources, quality product, recognized

brand and network to significantly transform “BOS-LHR [into] a highly competitive route,” but

requires access to slots at LHR to do so. The joint applicants cannot have it both ways, citing

JetBlue as a competitive alternative on the BOS-LHR (or any other U.S.-LHR) route while

opposing JetBlue’s request for the bare minimum number of slots in order to actually provide

meaningful competition. JetBlue will only be able to provide a meaningful competitive check on the immunized alliances if it receives a sufficient number of “commercially viable” LHR slots.

JetBlue therefore urges DOT, in concert with the CMA, to repurpose the existing LHR slot remedy to enable new entry and enhanced competition.

18 Response to Order Requesting Additional Information, Feb. 5, 2020, at 53 (DOT-OST-2008-0252). 19 DOT has acknowledged the LGW and LHR are not substitutes for U.S.-origin/destination passengers. Order 2010- 2-8, Feb. 13, 2010, at 19 (DOT-OST-2008-0252) (“Business passengers exhibit a strong preference for using Heathrow versus the international airports in London, based largely upon Heathrow’s location and pattern of service…. The counterargument – that Gatwick and other airports are true substitutes for Heathrow for transatlantic service – is not compelling.”). 20 “Norwegian Air UK Proposes December 2020 Long-Haul Resumption,” Routes Online, July 13, 2020, available at https://www.routesonline.com/news/38/airlineroute/292412/norwegian-air-uk-proposes-december-2020-long-haul- resumption/?highlight=norwegian%20boston; “Norwegian Air UK Extends Preliminary Schedule Into S21,” Routes Online, July 20, 2020, available at https://www.routesonline.com/news/38/airlineroute/292551/norwegian-air-uk- extends-preliminary-schedule-into-s21/?highlight=norwegian%20boston.

VI. Extension of the LHR Slot Remedy, Modified to Allocate Slots to New Entrants, is Essential to Promote Competition

A proposal to extend the four existing 2010 remedy slot pairs beyond March 2021, while

maintaining two of the four slot pairs on a one-stop flex basis, would be correct and comport with

the terms of DOT’s original grant of ATI to the oneworld transatlantic alliance in 2010. As noted

above, however, the oneworld and Delta-Virgin Atlantic JV carriers have more LHR slots than they need, for current or future planned use. The time is ripe for DOT, in coordination with the

CMA, to extend, expand and repurpose the expiring LHR slot remedy.

JetBlue requires at least four daily slot pairs to meaningfully serve the U.S.-LHR market and provide a desperately-needed competitive alternative to the oneworld and SkyTeam immunized JVs. JetBlue is the only current credible potential U.S.-LHR new entrant – and certainly the only one that has announced specific plans to enter the market. Despite COVID-19,

JetBlue remains committed to doing so next year. However, it will be incredibly difficult and expensive for JetBlue to open a station at LHR unless JetBlue is able to obtain, at a minimum, four daily commercially timed slot pairs. If JetBlue is only able to obtain fewer slots, then even if such service could be sustainable, its limited scale will deeply constrain its effectiveness as a means to provide competitive discipline to the oneworld and SkyTeam immunized JVs. If JetBlue could obtain additional slots, it would enhance competition by offering a more substantial and viable range of frequencies. This is particularly important for purposes of offering a meaningful competitive alternative for time-sensitive U.S.-LHR business passengers who require the flexibility of more-than-daily LHR service.

VII. DOT Should Act to Extend and Repurpose the 2010 LHR Slot Remedy Now

The future of the remedy slots is an appropriate issue to address in this proceeding, and delay (or extension of the existing slot remedy allocations) would all but guarantee that the current

transatlantic immunized oligopoly will remain in place for years to come. JetBlue is not asserting

that DOT should revoke any existing grant of ATI to a transatlantic alliance. DOT, however, has broad authority, based on evolved market dynamics over the last decade, to modify the terms and conditions under which it has previously granted ATI or to add new conditions before broadening

the scope of an ATI grant. Therefore, it would be entirely appropriate for DOT to require that the

2010 slot remedy be extended but modified to allow for reallocation of slots to JetBlue. Such

action by DOT is minimally necessary to provide a competitive check on the immunized alliances.

Just last year, DOT assured the Government Accountability Office that it closely monitors its slot-

related ATI conditions on a continuing basis, including with regard to market entry.21

As DOT, based on this diligent monitoring, must be acutely aware, slots that were allocated

10 years ago to enable new entry have become but a small part of the SkyTeam immunized alliance’s large portfolio of LHR slots (these carriers operated up to 50 daily departures in summer

2019), which is the very opposite of the remedy’s intent. DOT’s monitoring of how its slot condition is working is of little value if DOT is not prepared to act when such a condition is no longer serving its intended purpose. A reallocation of a few of those slots to enable new entry will honor the promise of open skies to remove barriers to new entry and competition. Since open skies is a prerequisite to granting (and maintaining) ATI, DOT should require an extension and modification of the LHR slot remedy condition to enable new entry by a non-aligned U.S. carrier.

* * *

In conclusion, JetBlue respectfully requests that DOT, in conjunction with the CMA, extend the duration of the 2010 LHR slot remedy and repurpose it to improve consumer benefits

21 U.S. Government Accountability Office, GAO Report 19-237 (Mar. 2019), “International Air Alliances: Greater Transparency Needed on DOT’s Efforts to Monitor the Effects of Antitrust Immunity,” at 20-22.

12 and address the current barriers to entry and competition at LHR by reallocating at least four daily slot pairs to JetBlue.

Respectfully submitted,

Robert C. Land Senior Vice President Government Affairs and Associate General Counsel JETBLUE AIRWAYS CORPORATION

September 9, 2020