SOUTHWEST AIRLINES CO. Robert W. Kneisley

Associate General Counsel

919 18 th Street, NW, Suite 600

Washin gton, DC 2000 6 (202) 263

- 6284 (202) 263

- 6291

- Fax bob.kneisley@wnco.com

____________________________________________________________________________________

August 2 6 , 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
(“J AX ”) , re gardless 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 purpose s

. 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 th e 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 DCA

Kansas City ( “ MC I ” )

– Oakland ( “ O AK ” ) 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 enth usiastically 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. Acco rdingly, 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.