SOUTHWEST AIRLINES CO.

Robert W. Kneisley

Associate General Counsel

919 18th Street, NW, Suite 600

Washington, DC 20006

(202) 263-6284

(202) 263-6291 - Fax

bob.kneisley@wnco.com

____________________________________________________________________________________

August 26, 2014

The Honorable Susan Kurland

Assistant Secretary for Aviation and International Affairs

U.S. Department of Transportation

1200 New Jersey Avenue, SE

Washington, D.C. 20590

Re: Slot Exemption Proceeding at Ronald Reagan Washington National Airport 

Pursuant to 49 U.S.C. Section 41718(b), DOT-OST-2000-7182

Dear Secretary Kurland:

Southwest Airlines Co. (“Southwest”) makes this brief submission in response to 

JetBlue Airways’ announcement on August 22 that it would initiate two daily nonstop

flights between Ronald Reagan National Airport (“DCA”) and Jacksonville, Florida 

(“JAX”), regardless of the outcome of this proceeding.

JetBlue’s announcement has undermined the very basis of its application in this 

proceeding, making it moot for all practical purposes. JetBlue’s request for slot 

exemptions in this case was predicated almost entirely on the alleged benefits of 

providing competition to an American Airlines monopoly in the DCA-JAX market.1 But 

JetBlue’s decision to launch two flights in the DCA-JAX market with its own slots 

eliminates American’s monopoly and provides the competition it previously sought to 

add only with slot exemptions. Given this development, there is simply no reasonable 

basis to consider awarding valuable slot exemptions for an eighth flight in what has now 

become an extremely well served, competitive (i.e., non-monopoly) market. 

Even before this development, Southwest’s proposed service in the DCAKansas City (“MCI”) – Oakland (“OAK”) market was a far superior choice to JetBlue’s 

application: The DCA-MCI market is 27% larger than DCA-JAX; Southwest provides 

the only large-jet service in the market; and the loss of Southwest’s pendente lite

service would create yet another DCA monopoly for American.2 Moreover, Southwest’s 

 

1

“JetBlue proposes to introduce sorely needed competitive service using Stage 3 Embraer E190 jets on a 

monopoly market presently operated by the dominant carrier at DCA, American Airlines (formerly US 

Airways).” Application of JetBlue Airways Corporation, March 25, 2014, Docket DOT-OST-2000-7182, at 

p.1.

2

Answer of Southwest Airlines Co., April 1, 2014, Docket DOT-OST-2000-7182, at p.3.
service has been enthusiastically embraced by the community, with load factors 

averaging close to 90%.

3

It is now even more clear that Southwest’s proposal for DCA-MCI-OAK service 

will have by far the greatest impact on competition, generate the highest level of public 

benefits, and produce the most efficient use of scarce DCA slot exemptions of all 

applications in this proceeding. Accordingly, Southwest respectfully requests that the 

Department award the available slot exemptions for its proposed DCA-MCI-OAK 

service.

 

Sincerely,

____________________

Robert W. Kneisley

cc: All parties on the Service List

 

3

For the period July 28 – August 24, 2014, based on Southwest internal data.