271169 �,�`�' '-? �,�a
G ITY OF SAINT PAITL � ��
"�.eoa
a■.■aba■. OFFIGE OF THE MAYOg
���ep�r
34Z GITY HALL
SAINT PALTL, MINIVESOTA 55102
(612) 298^4�323
GEOAGE LATIME2?
MAYOA
May 11, 1978
T0: COUNCIL PRESIDENT ROBERT SYLVESTER�
MEMBERS OF CITY COUNCIL
FR: MAYOR GEORGE LATIME
RE: NORTHWEST AIRLINES S IKE
I have been contacted by W. Patrick Reaves and requested to join with
him in signing a petition to halt the flow of Mutual Aid Pact funds to
Northwest Airlines. I believe that the receipt of these funds by
Northwest does not provide the necessary incentive for meaningful labor
negotiations since it allows Northwest to sustain the strike by main-
taining a profit. At the same time, the strike is having a detrimental
affect on the region' s economy.
It is my understanding that the legality of the Mutual Aid Pact is
currently in question and the subject of hearings before the Civil
Aeronautics Board in Washington, D.C. Therefore, until the legality
is determined, I support Mr. Reaves ' position that Mutual Aid Pact
funds be suspended in order to promote legitimate labor negotiations .
Due to the urgency involved, I have agreed to sign the attached petition.
However, I don' t wish to act alone on this matter and ask you to consider
adopting a Council Resolution to further support this position.
CC: W. Patrick Reaves
City Clerk �
City Attorney ��f�
1�ttachment ��`� 1� S,�EN��
G`� p�v�S�ER
� �
GL:e j t C'��ER� ��
- O
. �'�� � ��
UNITED STATES OF AriERICA
CIVIL AERONAUTICS BOARD
WASHINGTON, D.C.
- - - - - - - - - - - - - -x
.
IN THE MATTER OF � Agreements CAB
� z�l.�.5, et al.
MUTUAL AID PACT :
INVESTIGATION DOCKET N0. 9977 .
.
.
- - - - - - - - - - - - - - -x (Renewal)
REQIIEST FOR SUSPENSION OF ALL PAYMENTS
AND TRANSFERENCE OF REVENUE BETWEEN
CARRIER MEMBERS OF THE AMENDED MUTUAL
AID PACT PENDING BOARD DECISIONS ON
RENEWAL APPLICATIO1d AND EVIDENTIARY
HEARINGS
MAYOR GEORGE LATIMER � Wjj,MER PATRICK REAVES
- CITY OF SAINT PAUL Route 2, Box j26
347 City Hall Rockford, Minnesota 55373
Saint Paul, Minnesota 55102 (692) If.7?-5555
(612) 298-4323
May 11 , 1978
� . � . ,
;. . _
• TABLE OF CONTENTS
Pa�e
, i
. Preliminary Statement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1. �
I. Since approving the �Amended Pact for
five years, Labor disputes and Air
service disruptions have increased
substantially, requiring a respite
pending final Board actian. . . . . . . . . . . . . . . . . . . . . . . . 4•
II. Pact Carrier Members do not suffer "
full economic consequences of a
strike, burden non-striking Carriers,
and negotiate un£airly as a result
of the unbalance of power. . . . . . . . . . . . . . . . . . . . . . . . . 5.
III. An Administr&tive restraining order
is needed to prevent economic damage
to other than struck Carrier Pact Members. . . . . . . . . 6.
The impact of Mutual Aid Pact Payments that were
a percentage of losses of Pact Members in 1975• • • • • • • • • • ?•
IV. An Administrative Order is needed
to prevent economic damage to
the Public. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8.
Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '10.
Appendix A
Appendix B
Appendix C -
Affidavit of Notification . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . 11 .
Statement of participation . . . . . . . . . . . . . . . . . . . . . .: . . . . . .. - 11 .
.
. , . . . .
UNITED STATES OF AT��RICA
CIVIL AERONAUTICS BOARD
- WASHINGTON, D. C.
----------------------------X �
IN THE MATTER OF , Agreements CAB
I�IUTIIAL AID PACT ' 21l�1+5, et al
INVESTIGATION . DOCKET N0. 9977
.
----------------------------X
_ (renewal)
r
REQIIEST FOR SIISPENSION OF ALL PAYMENTS
AND TRANSFERENCTy�OF REVENUE BETWEEN
CARRIER MEMBERS OF THE AMENDED. MUTUAL
AID PACT PENDING BOARD DECISIONS ON
RENEWAL APPLICATION AND EVIDENTIARY
HEARINGS
PRELIMINARY STATEMENT •
The rule forbidding judicial restrair�tts of pending admini-
• � strative proceedings is especially in force where a full and
adequate judicial review of the decision of the agency ia pro-
vided for by statute.Also, to obtain judicial relief before
the prescribed .administrative remedy has been exhausted, have •
been held to be contrary to the long settled rule of Judicial
administration. A litigant is required to exhaust the adminis-
�rative remedy and must depend on that agency to exercise the
utmost caution concerning the interest of all parties involved
and effected by a pending decision. Where a statue is not so
obviously violated, or that no sacrifice or total obliteration
of a right which a legislature has created to protect the inte�-
est of indivivals or the public is involved, then it must fall
upon the � administrative agency itself to effect its own relief _
in questionable cases before it until final litigation is re-
solved.
1.
� , ' _ . .
Irreparable injury is usually considered to be a ground for
injunctive relief, and continuance of the Carriers operating ,i�
under the amended Mutual Aid Pact to cause irreparable injury
to their employees and effected labor groups is not an impossi-
bility. Therefore it would not seem unusual for an administrative
a�ency to parallel�` a judicial form of injunctive relief with
the mandating of the status Quo. This should be especially
true where a preponderance of evidence has recently emerged .
that shoizld be evaluated to determine the Mutual Aid Pacts � effect
and injury to thousands of commercial aviation employees,the Public,
labor groups, and the Airlines themselves.
The Carriers have requested that the Board approve renewal
of the Amended Mutual Aid Pact, and insomuch as the expiration
date of February 27th, 1978 has passed without approval while .
request for full evidentiary hearings are pending, damage from
prolonged strikes may be avoided if s suspension of Mu�ual
Aid Pact benefits is granted. This suspension is asked to .
alleviate �damage_�to the public and the Airline employees, and
to encourage the Pact Members to negoiate in a neutral atmos-
phere existing before the 1958 Mut..ual Aid Pact approval.
Suspension of Pact benefits and the transfer of Revenue by
Pact Members are necessary for the following reasons ;
1 . In the past, all applications for renewa� of
the pact have been approved, or the payment
, under �he provisions of the Pact increased.
With evidence and arguments to be introduced,
and the large volume of evidence forthcoming
in requested hearings in oppasition to renewal
� of the Pact,, it would be in the Public in-
terest to exercise caution and grant relief
in the form of an administrative injunction
to pr�hibit ftzrther'-�se 'af� the �act until the
- � . � �.Board has rende'red a final .decision on renewal.
2. To prevent damage to the Airlines, employees,
and the public convenience, immediate relief
from the Pacts effects are required because
five of the member carriers of the Pact are
presently involved in application for mediation,
mediation under way, or a recession of inediation
in their labor contract negotiations. Member
2.
. � � r . . . .
. , _ . . .
. . , .
.
, . .
Carriers currently in direct negotiations
involve six carriers negotiating seven
contracts. These two facts indicate that
four of major trunk carriers could be in-
. involved in revenue exchange under the Pact
this year, and five feeder carrier me.mbers
in direct negotiations could gravitate to
the posture of utilizing the Pact �payments •
WITHIN ONE YEAR. The threatened use of the
pact on negotiations is de�rimental to fair
and meaningful negotiations and is clearly
an upset of the �bQlance of power between
. labor and management in light of curr•ent
Federal laws governing negotiations.
3.- Section 705 of the Administrative Proeedure
Act (amended by act of June 5th,1967, Public
Law 90-23, 81 St�t. 5!�) , entitled Relief
pending review, states that when justice so
requires, it ma.y "pospone the effective date
of action taken by it, pending judicial re-
_ _ , view". The postpanement of the operation
of Pact obligations by member carriers
is in the publics best interest, especially
in light of a past renewal date by the Board
pending review. An order restrainin.g Pact
� members from exchanging revenue under the pact
would be, at a minimum, fair, in the face
of evidence that the Pact can and did place
upon the public much harm and inconvenience
with an undue and excessive interuption of Air
Service.
.3•
. � . � . � � . � . . .
. � '. . . ' - . ' . .- . ^ . _ ' . .
I.
�
SINCE APPROVING THE AMENDED PACT ' �
FOR FIVE YEARS, LABOR DISPUTES
AND AIR SERVICE DISRUPTIQN HAVE ��
INCREASED SUBSTANTIALLY, REQUIRING
A RESPITE PENDING FINAL BOARD ACTION
Since. order no. 73-Z-110 (February 27,1973) aPProving
tYie amended pact for five years, eight carriers as meml�rs
of the Pact have been involved in 52l� days of strikes, with
a total exchange (estimated) of approximately $ 261 ,692,000.
in pact revenue. (see appendix A) Over a five year period �
this amounts to one ar.. more of the pact carriers under a
strike posture 29� of the time.
Since 1969, the year Pact paymenta were approved to
50� initial].y, an additional �b35 days of strikes can .bg_added
to the above total, with an additional $ � 34,185s000 0�
revenues exchanged. Since the Mutual Aid Pact, the traveling
public has suffered 6L.+. major shutdowns over labor disputes
lastin� an average of 37 dags. Prior to the pact, strikes
averaged about 15 days, and were generally of the type that
were of �'long duration" to gain basic rights and benefits
in a developing air industry.
The bureau of labor statistics showed that the average
length of airline strikes was 19.7 days during 1958-1968, but
more than doubled to an average of 51 .8 days during the 1969-
1974 Period when Mutual Aid Pact benefits were escalated to
their present high levels. (see appendix B) It is apparent
that the carrier members of the pact were willing to sustain
a strike posture, with full lrnowledge of its inherent harm
and inconvenience to the public, with such reserves of revenue
still payable to them via pact payments.
Two of the Carriers in the pact , Northwest and National
airlines, have accounted for a large share of the strike days
within the industry. Northwest, with a poor mediation record
4-
. . � � r . . . � .
� . -, . . _ . � � : , -
�
of seven strikes resulting from eight mediation attempts :
(this includes the present 30 day cooling off period follow-
a release from mediation March 29,1978 by the Natianal
Mediation Board with a strike dead7.ine set for April 29) ,
has had the longest s�rike in 19?0 of 163 days, with a
total of 261 days of strikes since 19?0. National holds
the record number of days on strike with a total of 3!}1
days since 1970.
With Northwest within a cooling off period under the �
provisions of the Railway Labor Act of 1926, and a strike
imminent, an order restraining the Pact carriers from
transferring revenue under the provisions of the pact is
of utmost importance and timeliness to protect the travel-
public from economic harm and extreme i:nconvenience.
II.
PACT CARRIER MEMBERS DO NOT
SUFFER FULL ECONOMIC CONSEQUENCES
OF A STRIKE, BURDEN �NON-STRIKING
CARRIERS, AND NEGOTIATE IINFAIRLY AS
THE RESULT OF THE UNBALANCE OF POWER.
In 1965-1975, the corporate rate of return for all major
II. S. carriers showed substantial profits in spite of long
shutdowna far struck carrzers. Northwest Airlines, in 19?0,
with a six month strike showed a 9.6� rate of return. In
1972, after drawing almost fifty milliora. dollars in MAP aid,
Northwest still returned 1.�..6� even after a three month strike.
ATa-�ional, with its six month strike in 197l�., returned 10.0�,
and in 1975, returned 7.3� . See Appendix C.
TWA suffered a strike in 1973 of !�l�. days duration and
returned 2.8�. American Airlines had a strike lasting three
weeks in �9?!.� and- ret�rned l�..b�. These are examples of almost
normal profits even in years after the fuel embargo when expenses
were higher than ever before. Corporate returns and profits
remained normal even though work stoppages of up to six months
occured.
, Utilizing the Railway Labor Act to delay the completion
of signing of a contract, with a profitable situation still
5.
, . - : .
possible af�er a fa�lure to negotiate meaningfully results
in a strike, gives the pact members little incentive to
expeditiously and fairly conclude a contract. A carrier,
drawing up to 50� of its operating expenses based on last
years revenues, plus windfall profits, could definitely
see an advantage in sustaining a strike for a certain
duration in a year of declining revenues to show a profit.
Traditionally, a strike is harmful to all parties con-
cerned, especially the employees and the communities involved.
This is also especially true in remote areas often served
in large part by one airline. In the past, before the pact,
labor and management exerted every effort to avoid a strike.
But is seems difficult to ignore the heavy increase in strike
events and duration since the founding of the pact. It is
evident that struck carriers sit back and delete service
to the public to draw often profitable pact payments. The
real power lies in an ability to take a strike without either
immediate or long range `economic harm to the capital structure
of the carrier. With tlli.s ability intact through the pact, a
clear unbalance of power has emerged , and can only be relieved
through an adrainistrative restraining order iriatructing the
pact to cease payments until a final board deci�ion on renewal
can be effected.
�
III.
An Administrative Restraining
order is needed to prevent economic
damage to other than struck carrier �
pact members.
Of the total of 28l.�, million dollars transferred through
MA,p payments up until 1975, two airlines have received 57� of
the total amounts. Northwest and National received 162 Million
dollars and of course, they were also the carriers that have
suffered the longest strikes, were the most financially able,
and in the case of Northwest, had a maderately non-competitive
route system. The Carriers who dealt with their labor problems
successfully however, were the losers, for they had to pay the
substantial Pact payments often to their own detriment.
6• -
• . . .. _ � . , �
In 1975, 115 million dollars chan�ed hands in I�LAP payments
alone amoung its 15 members. This was nearly 30� of all MAP payments '
�
paid since the Pacts creation. National Airlines received $54
Million during its 139 day stewradess strike , which increased
its MAP receipts to a total of $121 ,161 ,000. This put National
$425 Million ahead of Northwest Airlines in total MAP payments.
Therefore, National, which had paid in the lowest amount into
� �P payments, is the leader in net gains from receipts from MAP.
Its total gains are $121 Million. �
The losers bore the hardship of the payments at the same
time,however. IInited Airlines paid the largest share of all
MAP payments primarily because its route structure encompasses
almost the entite IInited States, thus making it liable to �
"windfall" profits to almost any carrier Pact member struck.
IInited paid out over $91� million total in MAP payments, but
in 1975 found itself in the unique position of both paying and
receiving MAP payments because of a 16 day International mach�-
nist Association strike. It paid $1 ,538,000 out and received
$1�8,OOO,Q00 that �ear.
In tlze post 1969 period, when the Pact payments were raised
to t�neir present high levels, National and Northwest had received
$221 .l� million , or 55� of the $400 million paid since the
amendments took force. This does not include the present payments .
being forwarded to Northwest airlines during its pilots strike
of 1978. P� �, in a financially weakened position9 . had no
strikes and drew no payments. But as a percent of 1975 losses,
Pan Am loss $1.�6 million and paid out $11 million in MAP payments,
or 25.2/ of its losses were MAP payments. �
The impact of losses and the percentage of those losses that
were MAP payments were �as follo�rs : year, 1975
100% 98.7�
85•5�
80%
60I
40% 48.8�
�5.� 2� .7�
20�b � t
i
0� Eas ern Pan Am TWA American Continental
7•
' : r .
� � � . � -
In 1975, of the years top contributing carriers, three
have been in financial trouble; Eastern, Pan Am, TWA. Those
carriers lost $182.1 million, and included in that loss was
$5�.6 million paid to other MAP carriers. In Januray, 1977,
Pan Am withdrew from the Pact.
The Air Transport Association (ATA) testified at the
October, 1975 hearin�s that the Pact is a tool that protects �
them from permanent damage financially, but had little response
when testimony was brought forward on how the employees of Pan
Am, TWA, and Eastern, took wage reductions to help their Airlines
out of financially bad times, much as a result of payments to
the Mutual Aid Pact by their carriers.
With deregulation legi�'lation pending and most major airlines _
attempting to reduce their fares as much as 50� in a new Adminis-
tration attempt to encourage competition, it is important that
all Mutual Aid Payments be suspended to prevent damage to
Pact members until all hearings are complete and a final decision
is rendered on the Pacts continuation by the Civil Aeronautics Board.
IV
An Administrative Order is
needed to prevent economic
damage to the Publico
The public suffers a loss in both services and revenue
from taxes and salaries when a Pact memb�r engages in a strike
of long duration while drawing large MAP payments. This is
especially true over relatively non-competitive routes. An
example of this effect is the financial chaos levied upon
States served by Northwest-Orient Airlines through the midwest
comprising Montana, North Dakota, South Dakota, Wisconsin, Oregon,
Washington, and PZinnesota. All these States suffered substantially
through strikes by Northwest Airlines since 1966, with Northwest
being one of the highest MAP payment receivers. In 19?8, the
Civil Aeronautics Board had to give emergency relief to those
states to a certain extent by certifying North Central Airlines
to operate along those routes during the 1978 Pilots strike.
8.
. � . � .
' . . .� _ : : . � � ,
Little relief can be given to an entire area however, for
a replacement Airline cannot be diverted or created overnight to the ;
stricken area. Airlines operate on optimum costs curves with
little or no excess equipment to spare due to high costs. There-b the
fore if service to an area is stopped due to a strike prolonged y
Mutual Aid Pact payment�, the public sector simply suffers
until the strike ends. North Dakota estimated it lost over
$3 million daily during the 1975 Northwest strike lasting three
months. Car$o space for large equipment is presently not
available to Minneapolis during the 1978 Pilots strike, and
cargo in general is backlogg�d two to t�.ree days on other
available carriers and charters for normal shipment sizes.
This economic loss is augmented by a total revenue loss to
Minnesota through salaries, Taxes, and as�saciated industry
income by approximately $75 million a month.
This sort of eeonomio damage can be reduced or prevented
if an administra�ive restraining o�der is issued to halt all
Mutual Aid Pact payments until final hearings are complete
by the Civil Aeronautics Board on sustaining the Pact. This
suspension of Pact payments will also encourage the Airlines
involved in MAP payment collections to bar�ain meaningfully
to end a st�ike by restoring the management-Labor balance of
power.
9.
. . - . � • .. .
Conclusion
For the foregoing reasons, the Board ahould order
suspension of all payments. and transference of revenue
between Carrier Pact members of the Amended rlutual Aid
Pact pendin� Board decision on renewal applications
and Evidentiary Hearings. -
Respectfully submitted
Wilmer Patrick Reaves
Rt. 2, sox 326
Rockford, Minnesota 55373
; (6� 2) 477-5555
'
�
Mayor eorge Latimer
City f Saint Paul
347 City Hall
Saint Paul, Minnesota 551Q2
(612) 298-4323
I�ia� 11,1978
10.
" , r .
__ y
STR�S ON MUriTUAL AID PACT '
� CARR.IE�tS AND EST��I�,TID ,
PAYMENTS (000) s�tcE 1.g69
�NDMF.NTS
►W�a7 QY.1:l.i1 3V 1JA-LS . . .
- Airline and � .
Estima.ted
ye� � Receipts Union Duration
___.__
1970 Ra�o9 6 A� 107 .
�� � ) ,
197� Northwest HRAC . 163
($�+7,268) . .
197a-'T�-
Mohaw:� ALPA ' 15�* �
(�6�582) �
1971 � Sta�h es Airwest AMFA 116
. ($$,�'23)
1972 Northwest ALPA � . 95 �
- �$�+3�926)
1973 oza�rk82 AMFA 7� -
(� �5 )
1y73 - �wA � Az.sS�,i � ;
�$?���3� . �
�
Io8 - ;
lgj1� ` National � �
� ($�+3,027) �
l�j,l�._75 Texas Int t l. . ATFA 12� .
� (�u�5��� .
19'T5-?6 i�tationzl ALPAJAFA - • 126
($5�,200) . ;
.
, ;
i
OTHER STRIKES �
I
197p - Tt�TA Al.ss�i ' 2 . �
�$2���� • . . �
1
�
�
l�PPEPIDI� A
. . ., ' _ ' .
r ,
- . -- . �'�����
�.irline and
Estimated Union Duration
Year Receipts
____�—
ALPA 1 i
197�+ ��b�� :
3 �
1975 Northwest �A '
,
��2,800) �:
. I� ° 16 �
1975 IInited �
(�1-�$,000) t
� i'2 (�.
1976 �A� ;
�$1,900) :
ALPA 2� ►
1976 Continental . . !
($16,000) , ,
� Mohaw� became eligible �or Psct membership a..fter the stri�e
_ began. _ -
Sources: 1�TYMB Re�orts, CAB reports and other available sources.
Di��erent agencies de�ine strike duration dif�erent].,y, but
variables are not si�3-fican� �°T P�Poses of this submissi�.
p ents for strikes since the 1971 haarings are est3,ma�ed.
�
' . . . ,
APPENDIX A �
_2_
- . , . .. _ -. - •
l
,
AVERAGE DURATION OF AIRLINE STRIKES (Days)
,
1958-1968 MAP Phases 1, 2 1969-1974 MAP Phase 3
source : Civil Aeronautics Board Eligible
non-MAP
all MAP all non carriers
carriers carriers MAP Carriers �
1958-1968 28 27 29 '17
1969-1974� 70 83 L�. 12
The Mutual Aid Pact causes longer strikes in the Airline Induatry.
The Air Transport Aasociation, which represents most 'U.S. Air-
lines, voices its popular argument that since 19l�b, the average
length of strikes against non-Pact ��arrs.e�s`"has been 1.�.3.6 days
compared to 38.5 days for Pact members. ATA fails to point out that
the Pact was not established until 1958; therefore, inclusion of
pre-1958 strikes is as misleading as it is erroneous.
The average strike length was 28 days during the 1958-� 968
period, and then jumped to 70 days for the 1969-1971{• Period, or
an increase of 1.�2 days with the amended Pact rules and increased
payments through the Pact.
In looking at the non-Map carriers which were eligible to
join but chose not to, the average strike len�th was shortened
(rather than lengthened) after 1969 to an average of 12 da9s
from the pre-1969 average of 17 days.
� Not all carriers are eligible to join
�.�. 1964, the year Pact benefita were raised to 50J initial
operating expense levels at the offset of a strike
APPENDIX S
� _ � • . .
— - . .r� r - ^--�--�---"--- ..c.....e... .. - _� . . ....-. .-- - � - ... .. .
�`l' � � � .. . .. . . . � � . . . :t
��` ry ��. l J ' I •• � ` • . �.
. r �• u f..'rs
, .� � l .i '� _ .� �v� V O C'7 r' '� IC? ��C'� � � �O �� . . ...
• � ,
',,��= ' ;� � — s � c 2°� ( c�i cv o r �i tv si �ci ui ,o c�i . F .. ,
. . �* ' •!1 � ^ 7 ti � !�' . . .. . - � . .R� ^.w� 4 y•�y � .
4 *}„`- � �`./ � � l. � �� . t.� - . . . :,�r f 1 ..�• " ..
- Q ... - CJ v ���"' '�` _ ,r .�4�+
. -�_ _ . , � ' � L.. 1�...
. a V '7 � w '.G 1� ' :. .: .. ' ,.�;,r��y%4��yr r �
. ,- ' o � � � �� 3 � r� ao .- ,o < <t ,o�v c� a o� �' ,N� �f ,� ..
.��,,: " , r r � 0 3 v �ri .- r� -- � ,o �o ev ev t� : ,�- e s.,,���'r .'� -
.� ' �rs �'= e- r- r � , '� �- e- . f�.`�,►"`Jr`�$'�ry , .ti? .
' '►i�',�-. �i � O C � . ' »!!� c.. �' .u � ' . �� ,:A��st,dr'•h..t�a'�' 2
. '•� �"a�-'.; C�J —T � �- O •L � ,-•� _ - � , i;#i�'1*�,�+-F.'��'�:� 'A _���
IT_ � '^ C _ � _ ' � .. � . ' '�`: % `?Y f�f--r
� .'j+�! .:d y C O C•�t .. ' . -. .,.' � f_ : - ._ .'�r`��'er;,. .te`�' .
�+ > a � � � . • ; •+r�,�� . t .
e°1.o a�i '^ ' G� �. ,,,, �- (V t`� CV C7 CV P �' � �O�3 - :i �'r = r�� '.��
� '�° � = o � � ' � Ot� P � �O C�1� �cOCH� : i � � ' � L F `=`.. �.:"{' '9�
+ � �t r 3' tg� r;' �y. <
� j O � ` y � .�� .� '�S,r. •�-t,S i . L�r..�b' Y .�t.. � �� .. .�'' } .�.._ ._,,
e0 V d Q .,` .. e�� yr ,.ati�����{'`pt'7"�+`-�r,�,l�t�j � ''��.� _a y��l.(I.�' �+�'f!✓ �s'� i �i.
I � � I _lfY� +'�/1r�{-�V}�f� , ��.4' +LF.,,! Ri'� y, x JI rK2�+'�v��'�/�,� �..
S ITi4^7[ �'9 . rtC M �'r P 1 "J��"' .�•
..��/ �� . �t � I � ."Z1��,"'•'Yt�i"• .�`!�'.e►';V! w: 'R�^.....�+'� C 1����"fF,S?. � � -v'�,� .:i''.�� : �^�s
�. . . � n. �a6...i" .'.0 WtE .2'y"�'� .,�`'�i,c'cT�°'�3: ,,�, .��pa��,�,f�� �i *„F.i�+^��P �'-°'i _� °
�. �!�+e�� . ,� . . -�Sy � • Y a ,�t� �. � •4`,. ��,� £�'h '�_.�-�c .
. ._{. _ �.� , I . _�y 'F� ,�i��7�?`'`+^t �"�r•`���` �"�� s.�. w�`� �.`.� * '"i �s�� ��tg ��'J�� .r�" �, _
s �.f
,� , 1�,."��`y.,.�.�y�.4.� .�.•{�Cs.q�.�s��+cs .�;.�: ` � �. ��.�',,��"3� ��.,�,� '.
° � " ��aY' :� '� O P 'f7 '(�`:�',�!I�{'+��r�"'•. � �t`� .7!'k��.��y ;:.��.rMM i.�•
'' � : �'-_ °;a,; k ' ''i�,°'' .,",�,f'� �.s�°$�;� ; '�, ' ``�
. y �, .N . � R+w� a..p�iS. x-"}�4.s,r�`-'�r��`�'�•- j 1'lC ��7�. -
; 3 Q '� a ; ._ . ,�s�",�Ta� �.+n,�,, { ,`'�,y' ; _�S �i �.
t � U .. > - , . . .c. ti,,,�:a+.:�.., - :7.: •t: -?T: -
vr � 6i C� � ; . . - • • .�. . -.•i: T,-r.�.R: t� • ' t .
��'� 'u ` �A: = � � � �O O CV C�l�O'��.,�:`Q Q , ,� 7 '' _ �
C A � � � �� �� r �
v+ ` � p � n C�► \7 O t� e"' ; w,-c.�'�'.,�N''Y` F� a, �...4 �A ;>r
� O C �L N � . �. : ' �- �rs T;,_ ���� '�.�v�.�;Jlir�?_�1 �*'t. ��'�-..1.� s,� ��, i . i
� C.0 3 d y� � .. ..;^ � �r�ipi•�� ,d�,�Y4 'I4'�� ` }y�as k��K'°�5�;
H /� h� �p��f+ Q
•� � �� � V V� ; . : �.( -.r����N ��i'�„�K,'�3�i4Y y�,� �'�.F���-�.sy.��,4'. �r �'x4�1 a�Ii� }}'0�
� p 'D C r+ V CJ '' . � ���x N},,. ,�"�rt�... '�J�i:.�-�.�,.'1. �.� ,a� s,:p';ra`�; �,.r� "•��-am.,;..�J�. ��
CJ 'O ��r � � .n ti Q W��
:,�+,' Q..y � � N t� a . � Q ap'p� 'tt''`Qs�'!�Q�*Q�=4��'� �.u��u J�, t;`�*�"�` ,,r�'s ' ���j�,..� 1
> > > � v.. ` � � ' � �.•r' c0 C'7 O O�*�}'��0►Q.l�^„+.`..'�',�,� ,'"r'r r "t:t'�.•-..�a . �.,�`�"��` �'}�"��tm" tIIOII�
�p O O �C �p �n Z �.� Z N CV �rta� s- .� ,�su^,ti.�r�4 t:,rs� ;i''�' f .,, ''�"'�'�1.:. ��l�c-•�'.i.�•�`7
C Q V C v� p . � . � 4..t'•. � �'4�.t.'•:.^,�'t{�-;�u Z T `-�+��.< �., -: t���. � " i ��10;.1�I$I�Q��{4
L 'tn LL� j 'O t! � � :�x��:' �"j+�r?r'�d nr'+etri,,�•t-. ',ti {R. ' "�Z��'a✓�' �P ��lA�jl II
, rp �p � � CJ d i �v y �.��'`��1+ �t'�,.� �+ .f,.�r �''� ,,,,,; a � -, a. �. .,��1
:: � � F- �o eCe 'i, � Q \ • ... �.�"'�{y .`• �}�'�..=� �x`':�x`'4'' S`*-f�"� .+a,N...f.'� .: .., � r�y��y��Q �l�[�
1 t ' ,{'�Kf � ;'.
' � u � n`o'� Y � �, o..v r � +��o:�rcv�o cs: ��,.�.;� � y ,� '1saEs8e•�on.!
,.. .. r:
i r �, , - 182 1Q
� Z Z -;�Q; ,� ,o c�+o� �- �-'o,o;o.�.�„� ,� :"' � *��:� ,: ..- :��.X (3
� � �.- �-:.- .. ;�;,.� �c •�� �-,�.,*, �. _ ,;� . g'�S�:.�suI888;
M � C C CC ;,.,", '4 r t .�u't, -�,�`` 'r i-•. � i SII
x Y '"'�`:�4� W h7t` ' ,�, .r� a. - .:s2a}j !�-t��
�;'
,-y, 4•=. 'O e[ C A , �'� ' r' '"�,;,£"��'�''�'� �+-�,�, ;Y�a •.�:e {: '' ; -�laatl IIOIIIIm
�
N � . _ � '.. .� .�.. , �;,;q , �� noi ua M
61 C�� RS 0! �. . � .' a -�-.-v,a +s .� �'f� . :.� ?' i �s iiTir s � j� ``i �',
�� ` ti � � � N O � J `p p''�p 1l7 Q '�"A�O'�'� ,;�r° � y r° � '. � u; jp; '-l��SL10Lii
� _ `o a � :� . Z � �i .o r�cv v �n:v �n ;�- �:�°= ., � �: . �e8s ,uo}tIl
% .� a .r- ,. . ":.. �:. : < � uo}i�ttt:8'£It.
Y c Q v a C � OC C , „�.;�' sesi'�,: � ^'� � .u' L:. i': .([ IO IIO
`p ta v 3 W � v _ �',.. �+ ,K ' �� Aa �: --. : .,+^'4" �' f p��
� 4.3 � ... C � � ,�t. t .rv S` .:�� � .. _ * .*.. "V. 1f��:.��; ��•�
a V1 � - t _ s
- 3 � � p 3 � ' ' � �i~ ",,'y " . , �
N �.- p .:_ ° �e� ' . , -�� ..�
i �n � � � �' = 4. J N c0 O` C� CV CV,V' r'.O`_'.�Q. � :: . ":
� o � •°: .� ,n° � 0 0 �r tn � if C7 N Q` CV �fl �A!`� " � ! % a �.3ZI3:��IIB�Bd
o� � C� 7 �, CV CV s�' �- e- �-., r.r-r ,p a ; ` �$�$I $3�
� � �'' � . '� ''� ro = 0 W � � :c.. '�` � ,h.� �
� � . ��,�.�#� u C1 •� `' � r3 �"'� t�.'� ' �_' '�!"'.F��.`. �t1 ���
� � � C � � 0�0 � � � � �_`� �'Y�F. � � a:. ����T ����'n.saQ*n(��n
' �� 61� R A d 1 i.,�., t . ij . �" � ^�` .�'�;��'`� ' '� �7l�iV .,
��__`�'�. ° a� � � W o v ao c? a r►.�,o � �o��i�cv �-� . yS _. ' ; � �..� .�jap:sanion�
�' �n � � E °u ~ ' � ►� �o c�i �n v u� ,o,u ,a aa v t--i ; � "�.``�;'� - ,
w � '-.� 'r ' .: u ' Q ' '_ � � Fit!m
� � �ry 4;N t� �l� � t W , ,� ^� snol�a.�d 8 a
; � a d ; ` p�"., ;z: �" �'�p�� ��
c O + ` .� . : . Su[3�els a�►�
L � � a c��n � O� c7 c0 �O c'� �O c7 �O �O}�O�O ~ � Q . : ._ ; �;.
' E �v :°. `. v o N c7 �Ci 1�•�O r') f� O� �- N P � � :
� ,� o y � v .- .- •- �- � :. . - I �� - g•SS �l �P�'
d L «. y � p i �"`�.r-'�.°� 'S8U)�1tB 29T!
� f- 'v � � � ��. ' : $ m ; ' ��',�'�s4ns ienum
; � • � 5 . �' ; :�,,�.�px8og s�i��.
� e � eu � N e0 t� �O a0 P �O e'� P ��A .Q � ; ;r 4°'�
� � O a. �¢ � O O U �O �O � c7 c7 I� tf � m I �'rx er�''�gi
—C CJ N �; . �.�- . . � . . o . -;�`3�,+n"FV:i . . �
. ` � •c n A � � . � .� ��. ._ pQ • . � � ..r;`r+u''XR� .. � �
.. � � � a � N � 11 ' � i �'�~���rr.: ���
_s; ts+ . � �O 1� c0 U O � N�� � �A a , _-,,,.�z��iY
�,'o �y � A :,O ,O ,O �O ,O t� 1� I�f� 1� �., a+ ,.".-.� ., �
c � � p �`v � y' PUPUUPUUP � U � z ! ;•¢„�::.+::��
' `t. � >. O ..: - "' p � �e- r- �- r- � r- s- r a- � � � � �'.i > :
.� + � ro � O � � ~ �• � • Q ' - c� }�--}~ ��
k � - ` � Z . 5�.:
� _ w C CL co � ' : •
� � `° _° ,�e
r --
:�
; � . �.. � $� ,
i �� , APPENDIX C ;� `� �
� ; y
�.� ' --- ---- -��_�- --
_.. _..... _..�_ —___-- _ � �'j '.y��l�p ,,•_ � ;
i%�^-!
� 1
__ �f' S�`'i;+�. �<'1ry.?t � -a. .
�� i - _—. _ —- - '----' — _.. -"--= �_ ':�:s�}a- ?!�,�'°;y�x,,'.
��_
� - _.
. -�--
� - �_��_ . . . . ... � . . . . r..�..
�kk• . '__._'._. - . _ ' _'" . . __.. _.. - . . - . . . � 5i" ..
. . . ` . , � � �' . . . . . . . • - . '
. . .
.
� . . . � . . . . .
. . . ♦ . _. �. • . .. . . .
" '-�, . ,
AFFIDAVIT OF NOTIFICATION '
I certify that I have forwarded notice and copies of this
document to the following parties :
Charles H. Miller, Councel for the Applicants
Covington and Burling ,
888 16th street N.W.
Washington, D.C. 20006
Wm. G. Mahoney
HighsaW, Mahoney & Friedman
Suite 210
1050 17th street N.W.
Washington, D.C. 20036 �
Martin C. Sehan, Counsel for IAM and Allied Pilots Assoc.
Surrey, Karasik, Morse end 3ehan
500 f if th avenue � .
New York, N.Y. 10036
Robert S. Sa;elson
Cohen, Weiss, & Simon
605 3rd, avenue .
� New York, N.Y. 10016
Gary A Green
Daniel Katz
legal Department
Airline Pilots Association, International
1625 Massachusetts avenue, N.W. �
Washington, D.C. 20036
STATEMENT
IF NECESSARY, WE ARE PREPARED TO PARTICIPATE IN A HEARING
TO FIIRTHER SIIBSTANTIATE AND EXPLICATE THESE VIEWS.
.�- .
11 .
� • , .: . . . .