1. IBT: the entities are operating as a single transportation system as evidenced by substantial operational integration, common control and ownership, and overlapping senior management and labor relations at each subsidiary. When it comes to flight operations DAL/CMR/ASA did not have substantial integration nor labor integration. You may have shared above and below wing. Also CMR/ASA operated under a CPA, you don't see RAH's various carriers operating under a CPA with Frontier- if I'm not mistaken.

2. IBT: Pilot recruiting for each of its subsidiaries is handled by RAH. In addition, DAL/CMR/ASA all separate. I remember when CHQ bought Shuttle and then the whole Republic thing then the APA caught em' and here came the E170s and multi-certificates and so forth because my roommate at the time was an RAH pilot. To me, the big difference is RAH acquired and integrated all of these airlines immediately (also per the CHQ/IBT section 1 required it) whereas Delta bought ASA and Comair but never integrated them into ma Delta. They were just owned.

3. IBT: contends that further evidence of single carrier status is the fact that all the Pilots of the various subsidiaries have been integrated into a single seniority list. DAL/CMR/ASA never had SSL.

4. IBT: “[RAH] holds out to the public that its operating carriers are part of a consolidated entity.” DAL/CMR/ASA did not operate as Delta Air Lines, they operated as Delta Air Lines or Delta Connection (which began in 1984)

5. IBT: While each of RAH’s subsidiaries is a separate corporate entity with its own FAA operating certificate, their operations are all consolidated and commonly-scheduled under the Frontier brand, and they are held out as single company of affiliates on RAH’s website. Further, the subsidiaries are presented on a consolidated basis for both financial reporting and operating performance. DAL did not hold CMR/ASA out as being the same operation although we do determine scheduling per the CPA but I don't know if I would say even now with CMR that we have consolidated financial and operational performance reporting. I'll check, but imho I've never seen the 10-K's alluding to us as one but rather as "our numbers and then here are the final numbers of our wholly owned CMR".

6. IBT: both ALPA and UTU agree that Frontier is appropriately included in the single transportation system.

7. IBT: rejects FAPA’s main contention that the diverse operations of Chautauqua/RA/Shuttle (fixed-fee) and Frontier (branded) make a single system finding inappropriate.