BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, DC 20590

 )

Establishment of Slot Exemption Proceeding )

At Ronald Reagan Washington National Airport ) Docket 

Pursuant to 49 USC §41718 ) DOT-OST-2000-7182

)

Consolidated Answer of JetBlue Airways Corporation

Communications with respect to this document should be addressed to:

James Hnat Jonathan B. Hill

Executive Vice President Corporate Affairs, J. Parker Erkmann

 General Counsel & Secretary Benjamin M. Berlin

JetBlue Airways Corporation Cooley LLP

27-01 Queens Plaza North 1299 Pennsylvania Ave., NW

Long Island City, NY 11101 Suite 700

Washington, D.C. 20004-2400

(202) 962-8356

jhill@cooley.com

perkmann@cooley.com

Robert C. Land bberlin@cooley.com

Senior Vice President for Government

 Affairs & Associate General Counsel Counsel for 

JetBlue Airways Corporation JetBlue Airways Corporation

1212 New York Avenue, N.W.

Suite 1212

Washington, DC 20005

April 1, 2014
1

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, DC 20590

________________________________________________

)

Establishment of Slot Exemption Proceeding )

At Ronald Reagan Washington National Airport ) Docket 

Pursuant to 49 USC §41718(b) ) DOT-OST-2000-7182

________________________________________________)

Consolidated Answer of JetBlue Airways Corporation

JetBlue Airways Corporation (“JetBlue”) hereby submits the following Consolidated 

Answer to the competing applications for the pair of slot exemptions to be reallocated for service 

at Ronald Reagan Washington National Airport (“DCA”) pursuant to the provisions of the 

Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (“AIR-21”).1

 In 

light of the Congressionally-established criteria for awarding AIR-21 slot exemptions, JetBlue’s 

application to introduce low fare competitive service in the DCA-Jacksonville, FL (“JAX”) 

market stands far above the competing applications of American Airlines (“American”), 

Southwest Airlines Co. (“Southwest”), and People Express Airlines, Inc. (“People Express”)

because it provides competitive nonstop air transportation on a monopoly nonstop route and 

produces the maximum competitive benefits, including low fares.

2

 

The application of American to serve Long Island MacArthur Airport (“ISP”) satisfies 

only one of the slot exemption criteria—the promotion of air transportation to communities 

without existing nonstop service—but only because American itself has decided to cease DCAISP service. Additionally, an award of slot exemptions to American, DCA’s dominant carrier, 

 1 49 U.S.C. § 41718(b).

2 In addition, JetBlue’s application has the strong support of the Jacksonville community and 

Florida’s legislators, including U.S. Representatives Corrine Brown, Ander Crenshaw, Ron 

DeSantis, and Ted Yoho. The Representatives’ letter of support is attached as Exhibit B6-

2014A-104. Additional letters of support are being sent directly to the Department.
2

undermines the important directive in AIR-21 to foster competition at DCA. The application of 

Southwest to serve Kansas City, Missouri (“MCI”) produces $8.4 million less in consumer 

savings than JetBlue’s application; thus, it fails to maximize competitive benefits and therefore 

does not merit an award of the slot exemptions. Finally, the application of People Express 

should be dismissed because People Express does not have economic authority to engage

directly or indirectly in air transportation, and the Department should not award scarce slot 

exemptions to Vision Airlines, a carrier with questionable operational and financial viability.

The Department has interpreted section 41718’s silence regarding how to weight the five 

within-perimeter slot exemption criteria as providing it with the discretion to weight the criteria 

as it sees fit.3

 This discretion provides the Department with the “essential flexibility it needs” to 

ensure that “its determinations . . . will maximize public benefits.”4

 In this proceeding, JetBlue 

submits that its application maximizes public benefits because it produces the greatest 

competitive benefits, including low fares, introduces competitive nonstop service on a monopoly 

nonstop route to DCA, and promotes greater competition at DCA. Accordingly, JetBlue 

respectfully requests that the Department reallocate the available slot exemptions for its proposed 

DCA-JAX service.

I. The Department Should Not Award Additional Slot Exemptions to American

The Department should not award additional slot exemptions to American, DCA’s 

dominant carrier. Doing so would harm competition at DCA, reward American’s squandering of

 3 See DOT Order 2012-7-26 at 16 (July 24, 2012) (“[T]he Department has the discretion to 

premise an award based upon satisfaction of less than the greatest number of criteria, or even one 

criteria, listed in Section 41718(b), based upon the Department’s analysis of the relative merits of 

each carrier’s proposal when evaluated under the Section 41718(b) criteria.”).

4 Id. (citing DOT Order 2000-7-2).
3

scarce slots by artificially restricting capacity, and reward its voluntary decision to cease

operations to small-hub airports. 

American’s application incessantly asserts that ISP is a small community and that 

awarding it the slot exemptions would allow the Department to reconfirm its commitment to 

ensuring small community access to DCA.

5

 Despite American’s protestations, its application 

does not promote air transportation to a small community. While ISP is a small-hub airport, it 

unquestionably serves a large community. In its own application, American emphasizes the fact 

that ISP serves approximately 1.9 million people. In its zeal to advocate, American conveniently 

has forgotten that the Department expressly rejected the idea that a community of more than one 

million people could qualify as a small community under section 41718(b)(3).6 American’s 

oversight is hard to excuse when one considers the fact that American participated in the 

proceeding in which DOT re-stated the limitation on small communities and was served with the 

order awarding the slot exemptions to Southwest, DOT Order 2013-5-6, less than one year ago. 

The Department should ignore American’s inaccurate statements that its DCA-ISP proposal 

promotes air transportation to a small community. 

A. Awarding The Slot Exemptions To American, DCA’s Dominant Slot Holder, 

Would Harm Competition

A fundamental Congressional goal in AIR-21 is the promotion of competition at DCA. 

Indeed, the statute directs the Department to favor: (1) new entrants and limited incumbent air 

carriers, (2) the introduction of competitive service on monopoly routes, and (3) the service that 

provides the maximum competitive benefits, including low fares. The Department has repeatedly 

stated that promotion of competition is a critical goal in the allocation of slot exemptions. See

 5 Application of American Airlines at 3, 6-12.

6 Order 2013-5-6 at 10 (“As we have noted previously, service to a community with a population of 

well over one million people would not meet the small community criterion.”).
4

Order DOT-OST-2000-7-2 at 20 (July 5, 2000) (allocating slot exemptions because the 

“proposals would meet the statutory criteria of providing competitive nonstop air transportation 

on DCA monopoly nonstop routes by offering low-fare service to compete with US Airways’ 

monopoly”); Order DOT-OST-2004-8-3 at 6 (Aug. 9, 2004) (allocating slot exemptions because 

proposal “provide[d] competitive nonstop air transportation on a monopoly nonstop route to 

DCA” and “produce[d] the maximum competitive benefits, including low fares.”). Given the 

Congressional directive, the award of additional slot exemptions to an air carrier with unequalled 

market dominance at DCA is unwarranted and contrary to Congressional intent.

American’s dominant position at DCA harms consumers because American leverages its 

dominance to regularly charge higher fares on its monopoly routes. The result of American’s 

dominance is evident particularly in markets that have suffered from a chronic lack of 

competition. In the 44 markets that have been served solely by American from the fourth quarter 

of 2010 through the third quarter of 2013, fares have risen on average by 11.9%.

7

 

Not only does American charge higher fares on its monopoly routes, of which DCA-JAX

is one, it artificially restricts capacity at DCA. By operating limited and valuable DCA slots 

(including many of its large-jet air carrier slots) with small regional aircraft, American has 

effectively further restricted capacity at already under-utilized DCA by limiting the number of 

seats in a given market. Of the 67 destinations that American will continue to serve after the 

required slot divestitures, 80% of them will be served with regional jets more than half of the 

time and another 7.5% will be served with regional jets at least part of the time.

8

 Because of the 

slot constraints and the artificial and anticompetitive limitation of the number of seats through 

 7 See Exhibit B6-2014A-101

8 Regional jet in this instance refers to the CR7, CRJ, DH8, E175, and ERD.
5

the use of smaller aircraft, fares at DCA are very high.9

 Through its operating history at DCA, 

American has proven that it would rather squander the scarce public resources, many of which it 

obtained at no cost, rather than serve additional communities, where competition may already 

exist, and provide meaningful levels of service using higher capacity aircraft. American has 

provided no reason to believe that it would abandon its history of anticompetitive behavior and 

do otherwise in the future. 

American’s attempt to equate its slot portfolio with that of JetBlue is laughable. As the 

Department is aware, American recently completed its merger with US Airways, the dominant 

carrier at DCA before the merger. If the Department of Justice had not intervened with a lawsuit 

challenging the merger, American would have controlled 67% of DCA’s departures. As the 

United States aptly noted, except for the divestiture, American “would have had two-thirds of the 

flights at Reagan National but only half the airport’s passengers.”10 Despite being required to 

divest 104 air carrier slots, American still owns 58% of DCA slots. American’s contention that 

“American Airlines, JetBlue and Southwest must be treated equally”11 does not withstand 

scrutiny. As the chart below shows, JetBlue owns only 7% of DCA slots, even after the 

divestiture. American’s DCA slot portfolio dwarfs that of JetBlue.

 9 The Department has repeatedly found that fares at DCA are higher than at other airports. See, 

e.g., Notice on Petition for Waiver of the Terms of the Order Limiting Scheduled Operations at 

LaGuardia Airport, 75 Fed. Reg. 26,322, 26,323 n.12 (May 11, 2010) (“DOT calculated that, at 

DCA, US Airways charged on average 124% of the Standard Industry Fare Level (SIFL), a costbased index that the Department has used historically to assist in its evaluation of pricing. 

However, in markets where it held a 95 to 100% share of nonstop departures, US Airways 

charged substantially more.”).

10 Resp. of Pl. United States to Pub. Comments on the Proposed Final Judgment at 11 n.7, United 

States v. US Airways Grp., Inc., No. 1:13-cv-01236 (D.D.C. Mar. 10, 2014) (“U.S. Comments”). 11 Application of American Airlines at 9.
6

American’s Slot Portfolio Is 8 Times Larger Than JetBlue’s12

The Department should not treat JetBlue and American equally. The Department should 

treat them for what they are: JetBlue, a pro-competitive force that offers significant consumer 

savings to travelers with award-winning customer service on all large jets, and American, a 

legacy carrier that takes advantage of its dominant position to squander valuable slots, artificially 

restrict capacity and maintain higher fares.

Additionally, under the terms of the Proposed Final Judgment, American “shall not 

acquire any interest in any slot at DCA that was in use at the completion of the Transaction 

without providing notice to the United States at least thirty (30) calendar days prior to the 

acquisition.”13 The slot exemptions at issue in this proceeding were in use at the time the 

American-US Airways merger was completed; therefore, American cannot acquire an interest in 

the slot exemptions without first notifying the Department of Justice. American’s application is 

silent as to whether American has complied with this obligation. Unless American informs the 

Department otherwise, the Department should not even consider American for the slot 

 12 Refers to number of operated slots based on October 2013 and October 2014 schedule 

(provided by Diio), includes unannounced frequencies from JetBlue and Southwest

13 Proposed Final Judgment § XIII.A, United States v. US Airways Grp., No. 13-01236 (D.D.C. 

Nov. 12, 2013).

AA/US

58%

DL

12%

UA

9%

B6

7%

WN/FL

Other 10%

4%

Post-Divestiture DCA Slots

US

56%

AA

11%

DL

12%

UA

8%

B6

4% WN/FL

4%

Other

5%

Pre-Divestiture DCA Slots
7

exemptions because American would be barred from obtaining them by the judgment of a federal 

court.14

B. American Does Not Need The Slot Exemptions To Continue Service To ISP

American makes much of the fact that it had to divest 104 slots at DCA,15 but this is 

nothing more than an attempt to draw the Department’s attention away from the fact that 

American, as discussed above, is still by far the dominant carrier at DCA and has the flexibility 

in its slot portfolio to continue to serve DCA-ISP without the slot exemptions at issue in this 

proceeding. On January 15, 2014, American announced that it would no longer provide yearround, daily service from DCA to the following communities: Augusta, Georgia (AGS); Detroit, 

Michigan (DTW); Fayetteville, North Carolina (FAY); Fort Walton Beach, Florida (VPS); Islip, 

New York (ISP); Jacksonville, North Carolina (OAJ); Little Rock , Arkansas (LIT); 

Minneapolis, Minnesota (MSP); Montreal, Canada (YUL); Myrtle Beach, South Carolina 

(MYR); Nassau, Bahamas (NAS); Omaha, Nebraska (OMA); Pensacola, Florida (PNS); San 

Diego, California (SAN)16; Savannah, Georgia (SAV); Tallahassee, Florida (TLH); and 

Wilmington, North Carolina (ILM).17

 14 Even if the slot exemptions at issue in this proceeding are not considered a “slot at DCA” as 

that term is defined in the Proposed Final Judgment, the point remains. The United States 

required the notification provision so it could determine whether “any future slot acquisition” at 

DCA would adversely impact competition. See Competitive Impact Statement at 14, United 

States v. US Airways Grp., No. 13-01236 (D.D.C. Nov. 12, 2013). 15 Sixteen of these slots were not being used by American anyway, but rather were under lease 

and operated by JetBlue.

16 American was not required to relinquish any slot exemptions; it chose to discontinue service to 

San Diego to increase service to LAX.

17 Press Release, American Airlines, American Airlines to Implement Network Changes As A 

Result of DOJ-Mandated Slot Divestitures (Jan. 15, 2014), available at

http://hub.aa.com/en/nr/pressrelease/american-airlines-to-implement-network-changes-as-aresult-of-doj-mandated-slot-divestitures (last accessed on Apr. 1, 2014).
8

American undeniably has the slot portfolio to continue serving most of these 

communities despite the required divestiture. As the Department of Justice noted, American 

“has sufficient capacity to complete the divestitures and maintain service to most, if not all, of 

the cities it currently serves simply by using its slots more efficiently, e.g., by using larger 

aircraft and reducing frequency on some of its routes.”18 

American’s attempt to mislead the Department as to the impact of their recent divestiture 

is revealed when one considers that American’s choice to stop serving San Diego, California is 

not connected to the Department of Justice’s required divestitures in any way. American was not 

required to divest any of its slot exemptions, including its beyond-perimeter slot exemptions. In 

fact, San Diego cannot be served from DCA using a slot because of DCA’s 1250-mile perimeter 

restriction. American served San Diego pursuant to a pair of beyond-perimeter slot exemptions. 

American made a business decision to withdraw its San Diego service to add additional 

frequencies to Los Angeles at San Diego’s expense. 

The Department should not reward American’s attempt to game the slot exemption 

criteria. If American did not cancel its own DCA-ISP service, American’s application would not 

satisfy any of section 41718(b)’s decisional criteria. Instead of continuing to serve DCA-ISP

using its large slot portfolio, American has decided to babysit other slots. As American’s recent 

service decisions indicate, and the size of its slot portfolio supports, American could continue 

service to ISP without these additional slot exemptions. The Department should not reward 

American’s anticompetitive behavior.

 18 U.S. Comments at 36 n.64.
9

C. JetBlue’s DCA-JAX Proposal Is Superior To American’s DCA-ISP Proposal.

1. Islip Is Not A Small Community.

Although American touts its commitment to serving small communities as the reason for 

proposing DCA-ISP, Islip does not qualify, in any way, as a small community. While the term 

“small communities” is not defined by statute, the Department has consistently interpreted it to 

mean communities with less than one million people.19 American’s application stated that the 

population of Suffolk County, New York, which represents a fraction of the individuals living 

around ISP, is nearly 1.5 million residents. Clearly, American’s proposed DCA-ISP service does 

not satisfy the small-community decisional criterion. Indeed, American appears to have 

confused the requirement to serve a medium- or small-hub airport found in 49 U.S.C. 

§ 41718(c)(3) with the decisional criteria the Secretary must promote, including air 

transportation to small communities, found in § 41718(b). Service to a small-hub airport does 

not necessarily satisfy the criteria for service to a small community. Many large cities are served 

by multiple airports, and often the large city’s secondary and tertiary airports qualify as small- or 

medium-hub airports. A small- or medium-hub airport in a large community would not satisfy 

section 41718(b)(3)’s requirement. Although the Secretary could still consider it, the proposal 

would have to rely on the other four decisional criteria as the basis for the award.

2. Low Demand For Nonstop DCA-ISP Service Does Not Justify An Award 

Of Slot Exemptions.

There is limited demand for nonstop service to DCA from ISP. As the chart below 

shows, only 2.3% of total passengers from ISP travel to DCA, ranking DCA the seventh mosttraveled upon ISP destination.20 Of the small number of passengers carried on ISP-DCA, only 

 19 DOT Order 2013-5-6 at 10 (May 7, 2013); DOT Order 2004-12-6 at 7 (Dec. 6, 2004).

20 See O&D Survey, as provided by Diio (YE 3Q13).
10

47%—less than half—of those are local (less than 20 PDEW). American could easily meet 

DCA-ISP demand with its existing slot portfolio by routing its connecting passengers through 

other destinations or with its existing slot portfolio. 

Demand For Nonstop DCA-ISP Service Is Not Large Enough To Support An Award21

Rank Destination PDEW Share

1 MCO* 398 22.6%

2 PBI* 271 15.4%

3 FLL* 209 11.8%

4 TPA* 189 10.7%

5 BWI 127 7.2%

6 RSW* 42 2.4%

7 DCA 41 2.3%

* JetBlue provides nonstop service from JFK to these destinations

Additionally, American’s DCA-ISP service is ill-timed for connections at American’s DCA hub 

and is not conducive for business travelers.

As the ISP traffic data demonstrates, American’s proposal to serve DCA-ISP with small 

regional jets is a waste of valuable AIR-21 slot exemptions. The Department should not award 

these scarce resources to American so that it can charge inflated, monopoly prices and artificially 

restrict capacity. 

3. JetBlue’s Proposal Will Provide Competitive Nonstop Air Transportation 

On A Monopoly Nonstop Route And Produce Maximum Competitive 

Benefits While American’s Proposal Will Do Nothing But Provide Service 

To A Small-hub Airport Without Nonstop Service To DCA.

JetBlue’s DCA-JAX proposal offers greater benefits to the traveling public. As was 

discussed in detail in its Application, the proposed DCA-JAX service will provide sorely needed 

competition on a monopoly route and produces competitive benefits by lowering fares. Not once

 21 See O&D Survey, as provided by Diio (YE 3Q13).
11

in its application did American mention providing competitive benefits, including low fares. 

American relies solely on one factor: providing service in a market that does not have nonstop 

service to DCA. Ironically, while American has announced plans to cut its twice daily DCA-ISP 

service, it continues flying the route prior to the DCA slot divestitures taking effect. This 

peculiarity makes the point that it is entirely in American’s discretion to continue service to ISP 

without the slot exemptions. American has made the decision that ISP is not important enough 

to it to use one of its many slots to continue service. Instead American has chosen to ask the 

Department to again provide it further access to DCA by awarding the available pair of slot 

exemptions. Unlike JetBlue, which has had to pay dearly for most of the slots it operates at 

DCA, American has received most, if not all, of its slots at no cost. 

II. JetBlue’s DCA-JAX Application Is Superior To Southwest’s Proposal to Serve Kansas

City

JetBlue’s application to serve DCA-JAX is superior to Southwest’s application because it 

would best promote competition at DCA, maximize competitive benefits, and generate the 

greatest government savings. As discussed in detail in JetBlue’s application, the presence of 

JetBlue at an airport “is one of the most important explanatory factors behind which airports 

have lower fares than others.”22 In addition to lowering fares and growing markets, JetBlue 

offers air travelers unparalleled customer service, winning numerous awards, including the 

prestigious JD Power Award for Customer Satisfaction for nine years in a row.23

 22 Michael D. Wittman & William S. Swelbar, MIT Int’l Ctr. For Air Transp., Evolving Trends of 

U.S. Domestic Airfares: The Impacts of Competition, Consolidation, and Low-Cost Carriers, 

Report No. ICAT-2013-07 at 11 (Aug. 2013).

23 See Exhibit B6-2014-101 of JetBlue’s Application.
12

A. An Award To JetBlue Promotes Competition At DCA

Southwest is no longer the paragon of low-cost carrier (“LCC”) competition. As 

discussed in detail in JetBlue’s Application, the “Southwest Effect” has weakened greatly, and 

Southwest, the nation’s largest domestic airline, has begun to act increasingly like a legacy 

carrier. In May 2013, the MIT International Center for Air Transportation’s issued a report, 

entitled Trends and Market Forces Shaping Small Community Air Service in the United States, 

that concluded that Southwest “has started to behave more like other network legacy carriers in 

the past six years,” noting in particular that Southwest “has started to undertake the capacity 

discipline strategies also practiced by larger network carriers.”24 The study found that “while 

other LCCs/ULCCs were increasing flights and showing some growth in smaller markets, 

Southwest Airlines was cutting scheduled flights at many of the markets it helped 

create.”25 Comparing Southwest to JetBlue, the study found that “Southwest cut 9.8% of its 

scheduled domestic flights from smaller airports26 from 2007-2012, as opposed to a 21.3% 

increase in scheduled flights at these airports by LCC competitor JetBlue Airways.”27 As the 

chart below demonstrates, Southwest clearly is no longer the low-fare force it used to be. In fact, 

fare growth at all of its top ten airports by seats outpaced the average by as much as 16%.

 24 Michael D. Wittman & William S. Swelbar, MIT Int’l Ctr. For Air Transp., Trends and 

Market Forces Shaping Small Community Air Service in the United States, Report No. ICAT2013-02 at 7-8 (May 2013).

25 Id. at 8-9.

26 The MIT study defines “smaller airport” as “airports classified as medium-hubs, small-hubs, 

or non-hubs by the FAA. Id. at 3 n.1.

27 Id. at 9.
13

Growth Of Southwest’s Fares At Its Top 10 Airports Exceeds The Average Fare Growth28

On the other hand, JetBlue’s fare growth in its focus cities in most cases has risen less, or 

modestly more, than the average. In the case of SJU, fares have actually come down by 3%. 

Fare Growth At JetBlue’s Focus Cities Is Generally Less Than The Average29

Southwest’s competitive strategy is especially important given its DCA slot portfolio,

which while not as large as American’s, is considerably larger than that of JetBlue. The 

difference in JetBlue’s and Southwest’s DCA slot portfolio allows Southwest to operate 12 more 

daily roundtrips from DCA than JetBlue. Moreover Southwest has received, not including its 

 28 See O&D Survey, as provided by Diio (YE 4Q08 vs. YE 3Q13).

29 See O&D Survey, as provided by Diio (YE 4Q08 vs YE 3Q13).

24%

27%

19%

31%

19%

24%

19%

29%

23%

29%

15%

11%

8%

24%

13% 14%

16% 17% 18%

15%

BWI DAL/DFW DEN HOU/IAH LAS LAX MDW/ORD OAK PHX SAN

WN Average

14%

9% 9%

12%

15%

-3%

13% 14%

3%

15%

17%

1%

JFK/EWR/LGA LAX/LGB BOS FLL MCO SJU

B6 Average
14

pendente lite authority, 12 slot exemptions in the past to serve Houston Hobby;30 JAX or 

Milwaukee;31 Atlanta;32 Fort Lauderdale, Fort Myers, or West Palm Beach.

33 

In sharp contrast to Southwest, JetBlue chooses to use its limited slot portfolio to 

compete vigorously against American. As the chart below shows, JetBlue uses 96% of its slots to 

compete directly against the dominant American. Awarding the slot exemptions to JetBlue will 

allow JetBlue to introduce true LCC competition to additional DCA routes and increase the 

competitive environment at DCA.

JetBlue Uses 96% Of Its DCA Slots To Compete Against American, 

Southwest Uses Only 33%34

 30 DOT Order 2013-5-6 (May 7, 2013).

31 DOT Order 2008-2-28 (Feb. 27, 2008).

32 DOT Order 2007-5-12 (May 18, 2007); DOT Order 2004-4-2 (Apr. 1, 2004).

33 DOT Order 2003-1-16 (Jan. 22, 2003). Two of the four slot exemptions awarded to AirTran in 

this order were later withdrawn, DOT Order 2004-8-27 (Aug. 25, 2004), and awarded to Atlantic 

Southeast Airlines, Inc., DOT Order 2004-12-6 (Dec. 6, 2004).

34 Published schedule (October 2014) for JetBlue and Southwest provided by Diio. Includes 11 

of Southwest’s announced 33 frequencies in American-competitive markets (STL, MCI, RSW, 

BNA, MSY, TPA) and 23 of JetBlue’s 24 announced frequencies in American-competitive 

markets (BDL, BOS, CHS, FLL, MCO, NAS, TPA)

96%

33%

0%

25%

50%

75%

100%

B6 WN
15

B. JetBlue’s DCA-JAX Service Will Provide Greater Competitive And Consumer 

Benefits

JetBlue’s DCA-JAX application is superior to Southwest’s for the simple reason that it

produces the maximum competitive benefit, including low fares. As JetBlue discussed in detail 

in its Application, the JetBlue Effect reduces fares on routes it enters by an average of $32, 

nearly twice as much as the effect Southwest has on fares.35 Combining the greater number of 

new passengers stimulated with the JetBlue Effect, JetBlue’s DCA-JAX proposal will produce

$8.4 million more in consumer savings than Southwest’s proposal.

36

Southwest’s characterization of Kansas City, without Southwest service, as the most 

underserved medium or large market within the DCA perimeter is a red herring. Congress 

explicitly directed the Secretary to consider five factors when awarding within-perimeter slot 

exemptions—the promotion of air transportation: (1) by new entrant air carriers and limited 

incumbent air carriers; (2) to communities without existing nonstop air transportation to Ronald 

Reagan Washington National Airport; (3) to small communities; (4) that will provide 

competitive nonstop air transportation on a monopoly nonstop route to Ronald Reagan 

Washington National Airport; or (5) that will produce the maximum competitive benefits, 

including low fares.37 Promoting air transportation to “underserved airports” does not appear on 

the list, and the Department should not focus on passengers per departure; it should, as Congress 

explicitly directed, award the slot exemptions to the application that produces the maximum 

competitive benefits.

 35 Michael D. Wittman & William S. Swelbar, MIT Int’l Ctr. For Air Transp., Evolving Trends of 

U.S. Domestic Airfares: The Impacts of Competition, Consolidation, and Low-Cost Carriers, 

Report No. ICAT-2013-07 at 4 (2013).

36 See section II.B.2 of JetBlue’s Consolidated Answer.

37 49 U.S.C. 41718(b).
16

1. JetBlue’s Proposed DCA-JAX Stimulates 134,060 New Enplanements

While Southwest Stimulates Only 100,801

The consumer benefits of JetBlue’s proposal, and their superiority to those of 

Southwest’s proposed service to a supposedly underserved market, are demonstrated by the fact 

that JetBlue’s proposed DCA-JAX service will stimulate 33% greater new traffic than 

Southwest’s DCA-MCI service. JetBlue proposes an average one-way, nonstop fare of $110, 

which is approximately 41% lower than American’s current average one-way fare of $185.38

Consistent with JetBlue’s experience in other markets, JetBlue’s traffic model predicts that its 

lower fares will stimulate a total of 134,060 new passengers (58,400 on JetBlue and 75,600 on 

American) in the first year of service. 

On the other hand, JetBlue’s traffic model predicts that Southwest’s service, if continued,

would result in the carriage of only 88,732 passengers.39 Because Southwest would only be 

backfilling service offered by Frontier and because American has raised its average fare since 

Southwest began DCA-MCI service, it is reasonable to estimate that Southwest’s service 

accounts for the stimulation of an additional 12,070 new passengers flying DCA-MCI on 

American.40 As the chart below shows, both American and Southwest have raised their fares 

since Frontier exited the market.

 38 DOT O&D Survey via Diio, trailing four quarter data (captured March 22, 2014).

39 Southwest’s traffic stimulation can be estimated by multiplying the number of seats Southwest 

would offer in the first year, 104,390, by the load factor, 85%.

40 To the extent there is any confusion regarding the consumer savings offered by Southwest’s 

DCA-MCI service, the Department should credit JetBlue’s estimates because Southwest failed to 

include any analysis in its application.
17

Nonstop DCA-MCI Fares Before41 And After Southwest’s Entry42

As a result of JetBlue’s greater fare savings, its proposal will stimulate 33% more new 

enplanements. 

JetBlue’s Proposed Service Will Stimulate 33,259 More Enplanements43

In addition, JetBlue’s estimated 41% fare reduction is significantly greater than Southwest’s 

estimate that DCA-MCI fares would increase only 21% if Southwest exited the market.44

 41 See O&D Survey, as provided by Diio (YE 3Q13). Includes estimate of baggage and 

cancellation fees consistent with Southwest’s Application (Exhibit WN-2).

42 Application of Southwest Airlines (Exhibit WN-2).

43 See Exhibits B6-2014A-102 and B6-2014A-103 for JetBlue traffic stimulation calculations.

44 Application of Southwest Airlines at 3.

$186

$140 $147

$188

Before WN (YE 3Q13) After WN (current)

 

100,801 

134,060 

DCA-MCI DCA-JAX
18

2. JetBlue’s Proposed DCA-JAX Service Produces $8.4 Million More In 

Consumer Savings 

JetBlue’s greater traffic stimulation and larger effect on competitor’s pricing will lead to 

consumer savings of $8.4 million more than Southwest. JetBlue’s proposal offers significantly 

greater consumer savings and should be awarded the slot exemptions. As the chart below shows, 

JetBlue’s proposal generates more savings for existing passengers, creates greater savings for 

new passengers, and leads to greater competitive benefits.

JetBlue’s Proposed DCA-JAX Service Produces

$8.4 Million More In Consumer Savings45

Southwest did not include its estimated traffic stimulation and consumer savings resulting 

from an award of slot exemptions for DCA-MCI service because surely those benefits would not 

be sufficient to justify an award. Not only does Southwest know how to perform these 

calculations, it is common for Southwest to perform a detailed analysis specifically for the 

purpose of completing an application for slot exemptions. When the results of that analysis suits 

 45 See Exhibit B6-2014A-102 for calculations of Southwest’s consumer savings. Calculations of 

JetBlue’s estimated consumer savings can be found in Exhibit B6-2014A-103.
19

Southwest’s needs, it includes them in its application.46 Moreover, Southwest has based its 

attacks on other airlines’ applications for slot exemptions on the ground that the airlines did not 

offer an estimated traffic stimulation and consumer fare savings in its initial application.47 One 

must wonder why Southwest did not perform these calculations for its current proposal. Held to 

its own standard, Southwest should not be allowed to argue that its proposal stimulates more 

traffic or creates greater consumer savings than JetBlue’s. In Southwest’s own words, its “afterthe-fact traffic forecast and fare proposal are improper, contrived and not credible.”48 

Additionally, any local DCA-MCI benefits must be reduced by the percentage of travelers 

coming from OAK, if the Department is to believe that that DCA-OAK same-plane service will 

produce significant traffic. Every seat sold to a DCA-OAK passenger, most likely at a fare 

considerably higher than Southwest’s average proposed DCA-MCI fare, is a seat that a local 

MCI customer cannot purchase. The lost local capacity that is drained by the through service, so 

highly touted by Southwest, must be taken as a reduction in Southwest’s service proposal to MCI 

and, therefore, be considered a reduction of its claimed benefit in the DCA-MCI market.

3. The Benefits Of Southwest’s Same-Plane Service To OAK Are Greatly 

Overstated

The Department should disregard the alleged benefits of same-plane service to Oakland, 

California (“OAK”) because they are significantly inflated. First, Southwest has promised and 

failed to deliver benefits from similar same-plane service in its application for a beyondperimeter slot exemption to serve Austin, Texas, with same-plane service to San Diego, 

 46 See Application of Southwest Airlines Co., Docket DOT-OST-2000-7182 (Dec. 5, 2012).

47 See Consolidated Reply of Southwest Airlines Co. and Motion for Leave to File at 4, Docket 

DOT-OST-2000-7182 (Dec. 31, 2012).

48 Id. at 4.
20

California (“SAN”).

49 As the chart below shows, Southwest’s same-plane service represents 

only 14% of total DCA-SAN traffic, or 29 passengers daily each way (“PDEW”). An equally 

miniscule benefit can be expected from Southwest’s proposed DCA-OAK same-plane service

given the much smaller market size of 49 PDEW, especially when one considers that Southwest 

already offers one-stop service from DCA to OAK through Houston and St. Louis. 

Southwest Has Captured Only 14% of DCA-SAN Traffic Through One-Stop Service50

Second, DCA-OAK has sufficient one-stop service. Of the 49 PDEWs for DCA-OAK as 

of year-end 3Q13,

51 61% (32 PDEW) were carried by Delta over Salt Lake City, Utah (“SLC”)

and Los Angeles, California (“LAX”) and 26% (13 PDEW) were carried by American over 

Phoenix, Arizona (“PHX”). Southwest carried only 1 PDEW in the DCA-OAK market, 

connecting over Houston or St. Louis. 

Third, same-plane service is only marginally more convenient than one-stop service. As 

the chart below shows, the time savings offered by same-plane service is negligible.

 49 See DOT Order 2012-5-12 (May 14, 2012) (noting that Southwest would continue from 

Austin, Texas on a single-plane basis to San Diego, California).

50 See O&D Survey, as provided by Diio (YE 3Q13).

51 See O&D Survey, as provided by Diio (YE 3Q13).

WN via 

AUS

29 PDEW

Other

201 

PDEW

DCA-SAN

230 PDEW

WN

1 PDEW

Other

48 PDEW

DCA-OAK

49 PDEW
21

Same-Plane Connection Times Offer Almost No Advantage Over A Connection52

Given the minimal time savings, the Department should expect minimal, if any, benefits from 

Southwest’s proposed service. If, however, the Department believes that Southwest’s DCAOAK same-plane service will offer any benefits and lead to increased DCA-MCI-OAK traffic, it 

must reduce the amount of new local DCA-MCI traffic stimulated and the total consumer 

savings offered to DCA-MCI passengers because the number of seats available for purchase will 

be reduced. Southwest cannot have it both ways.

C. JetBlue’s Proposal Will Result In Greater Government Savings

JetBlue’s entry into the DCA-JAX market will result in significant government savings. 

As discussed in JetBlue’s application, JAX is an important destination for numerous government 

travelers with business related to the significant number of government installations and the 

amount of government-funded research performed in the area. For fiscal year 2014, American 

offers a DCA-JAX government YCA fare of $383 and a government –CA fare of $260, pursuant 

to a contract with the GSA.53 Government travelers are allowed to purchase air transportation on 

a non-GSA contract carrier if that carrier’s fare is lower than the GSA contract rate. JetBlue’s 

average proposed fare for nonstop DCA-JAX service is $110, an impressive $150 lower than the 

lowest government contract fare. Not only will JetBlue’s DCA-JAX service save the 

 52 See Southwest published schedule for March 28, 2014 (itineraries with shortest connection 

times shown).

53 U.S. General Services Administration, Airline City Pairs, http://cpsearch.fas.gsa.gov/ (last 

accessed Apr. 1, 2014).

Plane Change No Plane Change

Routing Connection Time Routing Connection Time Time Savings

DCA-MCI-ABQ 45 min DCA-HOU-ABQ 45 min 0 min

DCA-STL-LAS 35 min DCA-HOU-LAS 30 min 5 min

DCA-MCI-DAL 45 min DCA-STL-DAL 25 min 20 min

DCA-LAS-SAN 70 min DCA-AUS-SAN 45 min 25 min

DCA-HOU-OAK 50 min -- -- --
22

government money in the present fiscal year, the mere presence of JetBlue at the airport is likely 

to cause future GSA contract bids for the route to decrease. As a result, an award of slot 

exemptions to JetBlue will save the United States a significant amount of money. Southwest’s 

proposed service, on the other hand, would result in less government savings because 

Southwest’s average DCA-MCI fare is only a negligible $8 less than the lowest GSA contract 

fares for nonstop DCA-MCI service.

III. The Department Should Not Award The Slot Exemptions To People Express Airlines, 

Inc. 

The Department should not award the valuable slot exemptions to a carrier that lacks 

economic authority to engage directly or indirectly in air transportation. And even if the 

Department overlooked the fact that People Express lacked authority, Vision Airlines—whose 

role in the proposed service is unclear—lacks the financial wherewithal to justify the award of 

the slot exemptions. 

A. The Department Should Disregard The Application Of People Express Airlines

Because It Lacks Authority To Hold Itself Out As An Air Carrier, Either 

Directly Or Indirectly

In order to engage directly or indirectly in air transportation, a carrier is required to hold 

economic authority from the Department pursuant to 49 U.S.C. §§ 41101 or 41301, either in the 

form of a “certificate of public convenience and necessity” or in the form of an exemption from 

the certificate requirement. A carrier may not hold itself out as engaging in air transportation 

without such authority.54 This economic authority is in addition to any safety authority 

necessary under applicable Federal Aviation Administration requirements.

 54 The Department has fined People Express for engaging in air transportation without the 

required economic authority. DOT Order 2012-5-7 (May 9, 2012).
23

The Department should refuse to award valuable and scarce slot exemptions to People 

Express Airlines, Inc. (“People Express”) because it lacks certificate or exemption authority from 

the Department. The Department regularly refuses to award valuable and scarce slot exemptions 

to companies that lack certificate or exemption authority from the Department.55 People Express 

Airlines, Inc. (“People Express”) applied for a Certificate of Public Convenience and Necessity 

on March 19, 2012.56 Review of docket OST-2012-0042 on Regulations.gov reveals that 

Peoples Express has not received certificate authority from the DOT to hold itself out as 

providing common carrier services, in its name or any name. Additionally, a search of 

Regulations.gov reveals that People Express has not received an exemption to hold itself out as 

directly or indirectly engaging in air transportation.

It is unclear whether People Express plans to hold out service indirectly or whether 

Vision Airlines is applying for the slot exemptions under the name People Express. Should the 

latter be the case, the Department should not award the slot exemptions to Vision Airlines 

because Vision Airlines, Inc. has, to the extent a search of the DOT docket section revealed, not 

filed to do business under the name People Express Airlines, Inc. or PEOPLExpress pursuant to 

Part 215 of the Department’s regulations.

Based upon the foregoing, People Express is ineligible to receive an award of slot

exemptions at DCA because it is not an air carrier and cannot provide carriage of persons, 

 55 DOT Order 2004-4-2 at 16 (Apr. 1, 2004) (holding that it was “not in the public interest to 

award slot exemptions” to an applicant that “lack[ed] effective certificate authority from the 

Department and the FAA,” noting that its final fitness certification and FAA certification were 

still pending); DOT Order 1998-4-22 at 23 (Apr. 21, 1998) (noting the Department’s reluctance 

“to take the extraordinary step of granting slot exemptions to [a carrier] when its certification by 

the FAA is still pending, as is its final fitness certification.”).

56 See Application for a Certificate of Public Convenience and Necessity, Docket DOT-OST2012-0042 (Mar. 19, 2012).
24

property, and mail within the United States and because Vision Airlines, Inc. has not applied for 

the DCA slots. The Peoples Express application should be dismissed.

B. Neither People Express Nor Vision Airlines Should Be Awarded The Slot 

Exemptions Because Vision Airlines Is Not Financially Stable

Assuming that the Department overlooked the fact that Vision Airlines has not applied 

for the slot exemptions and does not have authority to do business as People Express, the 

Department should not award it the slot exemptions because Vision Airline’s credit report 

indicates that it has failed to pay its current expenses, bringing its economic viability into grave 

doubt. Only two months ago, the State of South Carolina filed liens against Vision Airlines for 

past due state taxes amounting to approximately $3,700. Additionally, in 2013 the States of 

Nevada and South Carolina filed liens against Vision Airlines amounting to approximately 

$39,000 that remain open. Vision Airlines’ difficulty in paying might stem from the fact that it 

has serious legal troubles. In 2011, Vision Airlines was held liable for $5.3 million in hazard pay 

and interest because it failed to properly pay its pilots, flight attendants, and other air crew 

members.57 Vision Airlines also just recently finished paying $44,000 to Okaloosa County, 

Florida after being charged by the State of Florida with grand theft of more than $100,000 in 

unpaid passenger facility charges.58 The fact that Vision Airlines has failed to timely pay its 

taxes raises serious questions about its ability to continue as a going concern and its compliance 

disposition. Moreover, the Dun & Bradstreet Report on Vision Airlines indicates that Vision 

Airlines is more than 90 days delinquent on paying its $300,000 bill for surety insurance and 

 57 See Hester v. Vision Airlines, Inc., No. 11-15646 (9th Cir. July 18, 2012). Even more 

troubling than Vision’s financial instability, is the fact that it, when performing services under 

contract in a war zone, appears to have fired all of its pilots and crew members who knew about 

their right to hazard pay and hired new crew ignorant of their entitlement to hazard pay to keep 

the money for itself. 

58 Kari C. Barlow, NWF Daily News, Vision Airlines Sends Okaloosa Its Final Check, 

http://www.nwfdailynews.com/local/vision-airlines-sends-okaloosa-its-final-check-document1.286993 (last accessed Apr. 1, 2014).
25

only pays 45% of its bills on time. The Department should not award these valuable slot 

exemptions to an air carrier whose continued operations are in question.

C. JetBlue’s Application Provides Greater Public Benefit Than That Of People 

Express’

Even if the Department were to seriously consider the application of People Express, 

JetBlue’s application is far superior because it serves a market that can support year-round 

nonstop service,59 produces maximum competitive benefits, and introduces much needed 

competition on a monopoly route. 

IV. Conclusion

In light of the considerable consumer and the superior competitive benefits of JetBlue’s 

application, the Department should exercise its discretion to select JetBlue’s proposed DCA-JAX 

service.

Dated: April 1, 2014 Respectfully submitted,

Robert C. Land

Senior Vice President for Government Affairs

And Associate General Counsel

 59 The Department has noted the important of operating year-round service when withdrawing 

two slot exemptions from AirTran. DOT Order 2004-8-27 at 2 (Aug. 27, 2004) (“[S]lot 

exemptions are scarce resources that are in very high demand by carriers that are willing and able 

to use them on a year-round basis for their proposed service.”).
Exhibit B6-2014A-101

Average Fares in American Monopoly Markets60

Market Sole Carrier YE 3Q11 Fare YE 3Q13 Fare % Change

DCA-OAJ American $142 $301 111.4%

DCA-CRW " " $149 $264 77.7%

DCA-ILM " " $154 $221 43.4%

DCA-TYS " " $146 $204 39.1%

DCA-CAK " " $112 $156 38.6%

DCA-SDF " " $145 $190 31.1%

DCA-VPS " " $153 $198 29.2%

DCA-ROC " " $131 $165 26.6%

DCA-FAY " " $147 $184 25.7%

DCA-BHM " " $145 $175 21.2%

DCA-CHA " " $150 $181 20.7%

DCA-SYR " " $148 $177 19.5%

DCA-BGR " " $155 $181 16.7%

DCA-ACK " " $190 $219 15.2%

DCA-TLH " " $164 $188 14.9%

DCA-GSP " " $137 $157 14.8%

DCA-PWM " " $144 $165 14.6%

DCA-ALB " " $134 $151 13.3%

DCA-LIT " " $146 $165 13.1%

DCA-BTV " " $151 $171 13.0%

DCA-BUF " " $118 $132 12.4%

DCA-MVY " " $198 $220 11.3%

DCA-PHL " " $79 $87 10.1%

DCA-BDA " " $162 $178 9.3%

DCA-YHZ " " $232 $248 6.9%

DCA-SRQ " " $136 $145 6.5%

DCA-AGS " " $162 $172 6.2%

DCA-GSO " " $157 $164 4.0%

DCA-SAV " " $159 $165 3.3%

DCA-NAS " " $190 $195 2.8%

DCA-MHT " " $118 $121 2.5%

DCA-CLT " " $155 $155 0.1%

DCA-PNS " " $177 $171 (3.3%)

DCA-LAS " " $223 $213 (4.4%)

DCA-PBI " " $150 $143 (4.7%)

DCA-PHX " " $281 $267 (5.0%)

DCA-SAN " " $243 $227 (6.6%)

DCA-HPN " " $200 $183 (8.2%)

DCA-PIT " " $110 $100 (9.5%)

DCA-EYW " " $197 $173 (12.0%)

DCA-HHH " " $198 $172 (13.3%)

DCA-CAE " " $168 $145 (13.7%)

DCA-DAY " " $149 $124 (16.7%)

DCA-ORF " " $119 $52 (56.1%)

Average American $160 $177 11.9%

 60 See O&D Survey, as provided by Diio. Includes monopoly markets that have been flown by 

American on a continuous basis (without competition from 4Q10 – 3Q13).
EXHIBIT B6-2014A-102

Consumer Savings Calculations for Southwest’s Proposed DCA-MCI Service

(A) Nonstop miles 

(B) Total fared passengers excl. F9 as of YE 3Q 2013 (DOT O&D Survey via Diio), excludes 1.6% of passengers on zero fare tickets

(C) Revenue stimulation assumption (high case)

(D) Assumed monopoly base fare excl. ancillary fee estimate (Application of Southwest Airlines, Exhibit WN-2)

(E) 9.1% estimate of ancillary baggage and cancellation fees (DOT Form 41 via Diio) * (D)

(F) (D) + (E)

(G) Current average DCA-MCI fare (Application of Southwest Airlines, Exhibit WN-2)

(H) (G) - (F)

(I) (H) / (F)

(J) (B) * (F) * (1+ (C))

(K) (J) - (B)

(L) (B) * [$207 (“US DCA-MCI Fare at US DCA monopoly pricing”, Application of Southwest Airlines, Exhibit WN-2) - $171 (“Current 

DCA-MCI Average Fare”, Application of Southwest Airlines, Exhibit WN-2)]

(M) (K) * [(F) – (G)] * 0.5, follows method outlined by the FAA in “FAA Airport Benefit-Cost Analysis Guidance”, Office of Aviation 

Policy and Planning, FAA, Dec. 15, 1999

(N) (L) + (M)

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K) (L) (M) (N)

Fare Change

Market Miles Passengers Before 

Stimulation

Predicted Service 

Stimulation (revenue) Base Fare Fees Total Average Fare w/ WN Absolute %

Pax After 

Stimulation

Annual

WN Pax

Existing 

Pax

New

Pax

Total 

Consumer 

Surplus

DCA-MCI 949 144,380 50% $188 $19 $207 $171 ($36) (17%) 228,016 88,732 $4.5M $1.8M $6.4M

Fare Stimulation

Average Fare Before WN Consumer Surplus
Exhibit B6-2014A-103

JetBlue Fare Stimulation Calculations

(A) Nonstop miles 

(B) Total fared passengers as of YE 3Q 2013 (DOT O&D Survey via Diio), excludes 4.3% of passengers on zero fare tickets

(C) Conservative estimate of market revenue stimulation based on JetBlue’s track record

(D) Total DCA-JAX revenue as of YE 3Q 2013 (DOT O&D Survey via Diio) / (B)

(E) 9.1% estimate of ancillary baggage and cancellation fees (DOT Form 41 via Diio) * (D)

(F) (D) + (E)

(G) Projected JetBlue average fare in year 1 based on comparable DCA markets, includes 4.4% ancillary fee estimate (DOT Form 41 via Diio

(H) (G) - (F)

(I) (H) / (F)

(J) (B) * (F) * (1+ (C))

(K) (J) - (B)

(L) (B) * [(F) - Me], where Me is the new equilibrium price of $113, assuming AA matches B6 fare, weighted by expected market share, plus 

ancillary fee estimate (DOT Form 41 via Diio)

(M) (K) * [(F) - Me] * 0.5, follows method outlined by the FAA in “FAA Airport Benefit-Cost Analysis Guidance”, Office of Aviation Policy 

and Planning, FAA, Dec. 15, 1999

(N) (L) + (M)

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K) (L) (M) (N)

Fare Change

Market Miles Passengers Before 

Stimulation

Predicted Service 

Stimulation (revenue) Base Fare Fees Total Projected B6 Fare

Absolute %

Pax After 

Stimulation New Pax Existing Pax

New

Pax

Total 

Consumer 

Surplus

DCA-JAX 634 140,419 20% $169.28 $15.40 $184.68 $110 ($75) (41%) 274,479 134,060 $10.0M $4.8M $14.8M

Fare Stimulation

Average Fare Before B6 Consumer Surplus
Exhibit B6-2014A-104

Letter of Support

Certificate of Service

I hereby certify that a copy of the foregoing Consolidated Answer of JetBlue Airways 

Corporation was served this 1st day of April, 2014 via email transmission on the following 

persons:

robert.wirick@aa.com

francis.heil@aa.com

howard.kass@aa.com

sascha.vanderbellen@delta.com

jeff.morgan@delta.com

bob.kneisley@wnco.com

leslie.abbott@wnco.com

Charles.donley@squiresanders.com

marshall.sinick@squiresanders.com

robert.cohn@hoganlovells.com

patrick.rizzi@hoganlovells.com

john.fredericksen@suncountry.com

thomas.ting@suncountry.com

dan.weiss@united.com

steve.morrissey@united.com

jonathan.linde@united.com

karine.faden@united.com

lhalloway@crowell.com

gmurphy@crowell.com

john.varley@virginamerica.com

jegillick@zsrlaw.com

jhfoglia@zsrlaw.com

anita.mosner@hklaw.com

Jennifer.nowak@hklaw.com

mike.morisi@flypex.com

shawn.voyles@flypex.com

dhernandez@vedderprice.com

nssparks@fedex.com

sllunsford@fedex.com

jyoung@yklaw.com

lgrunewald@yklaw.com

steve.grossman@flyjacksonville.com

quince.brinkley@mwaa.com

Susan.Kurland@dot.gov

Esta.Rosenberg@dot.gov

Todd.Homan@dot.gov

brian.ctr.meehan@faa.gov

fbavent@airlineinfo.com

info@airlineinfo.com

and via First Class Mail on the following:

Mayor Vincent Gray

Executive Office of the Mayor

1350 Pennsylvania Avenue, NW

Suite 316

Washington, DC 20004

Mayor Alvin Brown

Mayor’s Office

City Hall at St. James Building

117 W. Duval St Suite 400

Jacksonville, FL 32202

John Potter

President and CEO

Metropolitan Washington Airports Authority

1 Aviation Circle

Washington, DC 20001

Arnaldo Deleo

General Manager Aviation Bureau

Port Authority

Government of Puerto Rico

PO Box 362829

San Juan, PR 00936-2829

___________/s/______________________ 

 Michael R. Radlick