BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

________________________________________

In the Matter of

Docket DOT-OST-2012-0029

Establishment of Slot Exemption Proceedings

At Ronald Reagan Washington National Airport

Pursuant to 49 U.S.C. section 41718

_________________________________________

COMMENTS OF THE CITY AND COUNTY OF SAN FRANCISCO AND 

SAN FRANCISCO INTERNATIONAL AIRPORT 

IN SUPPORT OF APPLICATION OF VIRGIN AMERICA INC. 

Communications with respect to this document should be sent to:

 

 JOHN L. MARTIN

 Airport Director

 San Francisco International Airport

DENNIS J. HERRERA

City Attorney

SHERYL L. BREGMAN

Airport General Counsel

San Francisco International Airport

International Terminal, 5th Floor

San Francisco, California 94128

Telephone: (650) 821-5088

Facsimile: (650) 821-5086

sheryl.bregman@sfgov.org

Dated: March 27, 2012
1

BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

________________________________________

In the Matter of

Docket DOT-OST-2012-0029

Establishment of Slot Exemption Proceedings

At Ronald Reagan Washington National Airport

Pursuant to 49 U.S.C. section 41718

_________________________________________

COMMENTS OF THE CITY AND COUNTY OF SAN FRANCISCO AND 

SAN FRANCISCO INTERNATIONAL AIRPORT (SFO)

IN SUPPORT OF THE APPLICATION OF VIRGIN AMERICA INC. 

The new allocation criteria for beyond-perimeter exemptions enunciated by Congress in 

FAA 2012 more than amply support allocation of the four slots requested by Virgin America in 

this proceeding; respectfully, they virtually compel it. The thrust of the new statutory directive 

was to place much greater emphasis on serving the greatest origin-destination market needs and 

bolster new entrant competition. The facts in this proceeding – without embellishment —support 

the allocation to Virgin America of the slot exemptions for two roundtrip daily flights to serve 

San Francisco, as follows:

1. The San Francisco Bay Area is by far the largest market in the U.S. without nonstop 

service to Ronald Reagan Washington National Airport (DCA). The roughly one million SFOWashington, D.C. origin-destination passengers is nearly three times the size of the next largest 
2

unserved market in this proceeding, San Diego. Even though no limited incumbent applicant in 

this proceeding has selected San Diego as its first choice for nonstop service, US Airways has 

announced daily nonstop service there starting June 8, 2012. The San Francisco market is more 

than five times the size of all the other applicants. (Exhibit SF-1.) In fact, it is as large as all the 

unserved markets proposed for nonstop DCA service in this proceeding – combined. (Exhibits

SF-1 and SF-2.)

2. The Bay Area has suffered a gross and inequitable lack of service to DCA for more 

than a decade, since DCA beyond-perimeter exemptions began. Meanwhile, far smaller markets 

like Phoenix, Denver, and Seattle have been awarded multiple nonstop flights to DCA. (Exhibit

SF-3.) Estimated conservatively, SFO’s comparative market size would dictate nearly six

nonstop daily SFO-DCA flights. (Exhibit SF-4.) SFO is pleased that United Airlines has 

announced its intention to begin one such daily service later this year, but that is not nearly 

enough to meet the Bay Area’s needs. There remains a huge deficit in service to the Bay Area –

even well beyond the two additional flights Virgin America proposes. After a decade of 

disadvantage, the Bay Area and its travelers must play catch-up.

3. The San Francisco region is precisely the type of world-class, long-haul businessfocused market that requires and deserves time-saving, nonstop service to the Capital’s most

convenient airport. A nonstop flight to DCA will save each passenger on average 2 hours and 20 

minutes over existing connecting service from SFO to DCA (Exhibit SF-5), alone generating 

more than $6.3 million in the value of travel time saved. (Exhibit SF-6.) The convenience and 

time savings are essential to travelers to and from the Bay Area, a true global business hub. The 
3

region’s GDP ranks within the world’s top 20 national economies; it hosts more Fortune 500 

companies than any U.S. region expect New York; and it has the sixth highest concentration of 

Fortune Global 500 companies in the world – after only New York, London, Tokyo, Seoul, and 

Beijing. (Bay Area Economic Profile, Bay Area Council Economic Institute, March 2012.) The 

current lack of a robust, direct link between this global center of business, finance, and 

technology and the seat of the federal government through close-in DCA must be remedied. 

With all due respect, tourists and visitors to leisure destinations like Puerto Rico and Colorado 

Springs and other more leisure-heavy markets proposed in this case have effective and readily 

available substitutes via extensive air service offered at Dulles International.

4. The Bay Area air travel market is growing strongly while the other markets proposed 

in this case have been flat or declining. Air travel demand to and from Washington at SFO has 

dramatically out-performed almost every other market in this case since 2005. Over that period, 

SFO origin-destination traffic to/from Washington, D.C.’s key airports has grown 61 percent. 

Of all the other cities in this case, the only other significant growth market was Portland, which 

grew at far less than half the rate of SFO. (Exhibit SF-7). Nonstop service to DCA should be 

allocated first to fast-growing markets like the Bay Area, rather than to markets, like those in this 

proceeding, that have either not grown or contracted as much as 20 percent over the period. 

These key facts alone demonstrate the need for at least two additional SFO-DCA services 

beyond United’s planned service. (Significantly, large incumbent carriers are not bound to any 

particular choice of beyond-perimeter point by FAA 2012.) The deep support for the service 
4

among the Bay Area civic and business communities and its federal, state, and regional political 

leadership is well-documented in the letters attached as an appendix hereto. 

Equally important, the applicant proposing service to San Francisco in this case – Virgin 

America – provides even further reason for the award of the additional services to the Bay Area. 

Virgin America – the only total new entrant at DCA in this case – clearly fulfills all of the 

statutory criteria, as follows: 

Virgin America has proven to be a tough competitor since 2007 against much larger, 

well-established incumbents in the SFO-Washington market. Today it successfully operates up 

to four daily flights at Dulles International in direct competition with major hub airlines – on 

both fares and service. Over the last four financial quarters, Virgin’s fares have averaged 25 

percent lower than the network carriers on the route. (Exhibit SF-8.) The result: Annual savings 

to SFO-Washington passengers of $27 million on Virgin’s four daily flights. (Exhibit SF-9.) 

Virgin America’s competitive fare-lowering record has been demonstrated in numerous 

major markets and is consistent with the Justice Department’s empirical determination in 2010 

that nonstop market entry by low-cost carriers reduces fares by roughly 25 percent. (Comments 

of the U.S. Department of Justice in Docket FAA-2010-0109; see also Application of Virgin 

America, at 13.) Other applicants in this proceeding promise that their lower fares would 

“stimulate” new traffic to DCA. There will be no need to stimulate the SFO-DCA market as the 

service demand is certain to be far greater than the available capacity of even three daily flights. 
5

Virgin America has been a powerful competitor in service quality as well as fares. 

Service quality is of real value to Bay Area travelers, particularly on a long business route like 

SFO-DCA. The airline’s range of in-flight amenities – WiFi, numerous USB jacks, and satellite 

TV – are important to the in-flight productivity of the Bay Area’s business travelers on long-haul 

routes. A March 14, 2012 JD Powers and Associates report found Virgin America, JetBlue, and 

Southwest all among the fifty “2012 Customer Service Champions” – out of over 800 U.S. 

companies in over 20 industries. 

The remaining relevant statutory criterion – albeit de-emphasized in the FAA 2012

statute – is the degree to which the applicant offers “domestic network benefits” beyond the 

perimeter. The applicants in this case have chosen to serve communities or hubs that are far 

smaller than SFO and, in most cases, where they themselves are small participants in the market. 

In contrast, Virgin America proposes to serve DCA from its headquarters and hub city where it 

has already grown dramatically in just five years and where it already serves and connects 17 

destinations, including nearly a half-dozen major West Coast markets. (Exhibit SF-10.) As it 

plans to grow its fleet by another 50 percent over the next three years – far more rapidly than 

other applicants – the domestic network benefits Virgin America offers at SFO will continue to 

expand commensurately.

Finally, the limited incumbents that are the subject of this proceeding by definition have 

relatively little representation at DCA, but Virgin America has NO access to DCA, either within 

or beyond the perimeter. Granting new entrant Virgin America the four slots it seeks would still 
leave it the smallest slot-holder at DCA, except for the anomalous situation of Republic and Sun 

Country. (See Exhibit VX-7, Application of Virgin America, March 12, 2012.) 

CONCLUSION: 

Judged by every one of the beyond-perimeter exemption allocation criteria enunciated by 

Congress in FAA 2012, Virgin America merits the award of four slots needed to operate a 

competitive schedule of two daily nonstop flights between San Francisco and DCA. Long 

denied essential nonstop access to DCA, San Francisco respectfully submits that the Bay Area 

merits no less a level of service. 

Respectfully submitted, 

.A/l / /I . J! ' i/ :/ ( l/l JOH~ L. MARTIN 

Airport Director 

San Francisco International Airport 

DENNIS J. HERRERA 

City Attorney 

! L. 

SHERYL L. BREGMAN 

Airport General Counsel 

San Francisco International Airport 

International Terminal, Floor 

San Francisco, California 94128 

Telephone: (650) 821-5088 

(650) 1-5086 

Counsel for City and County San Francisco and 

San Francisco Airport Commission 

6 
CERTIFICATE OF SERVICE

I hereby certify that on this 27th day of March, 2012, a copy of the foregoing Comments 

of the City and County of San Francisco and San Francisco International Airport was served via 

electronic mail on the parties named below:

carl.nelson@aa.com

jhill@dowlohnes.com

perkmann@dowlohes.com

robert.land@jetblue.com

sascha.vanderbellen@delta.com

scott.mcclain@delta.com

sametta.c.barnett@delta.com

rbkeiner@crowell.com 

lhalloway@crowell.com

gmurphy@crowell.com 

dan.weiss@united.com

steve.morrissey@united.com

jonathan.linde@united.com

bob.kneisley@wnco.com

leslie.abbott@wnco.com

dkirstein@yklaw.com 

jyoung@yklaw.com 

marshall.sinick@squiresanders.com

edward.sauer@squiresanders.com

cdonley@squiresanders.com

robert.cohn@hoganlovells.com

patrick.rizzi@hoganlovells.com

john.varley@virginamerica.com

jegillick@zsrlaw.com

jhfoglia@zsrlaw.com

anita.mosner@hklaw.com

jennifer.nowak@hklaw.com 

howard.kass@usairways.com

benjamin.slocum@usairways.com

john.fredericksen@suncountry.com

susan.kurland@dot.gov

todd.homan@dot.gov

james.dann@dot.gov

peter.irvine@dot.gov

dennis.devany@dot.gov

esta.rosenberg@dot.gov

brian.ctr.meehan@faa.gov

john.allen@faa.gov

john.potter@mwaa.com

william.stallings@usdoj.gov

 Bryant Templeton
O&D Passengers to Washington Area Markets, YE3Q 2011

* Currently served nonstop to DCA

** Subsequent to the initial applications in this docket, US Airways announced it will start nonstop daily service to DCA.

Source: DOT O&D Survey, YE3Q2011

The San Francisco Market to Washington Is Much Larger than the Other 

Markets for Which Exemptions Are Sought in This Proceeding

1

978,300

419,430 365,120

192,230 168,070 145,910

68,140 48,775

-

200,000 

400,000 

600,000 

800,000 

1,000,000 

1,200,000 

San Francisco Las Vegas San Diego Portland Austin San Juan Colorado 

Springs

Vancouver

Reagan National Dulles

1

*

Docket DOT-OST2012-0029

Exhibit SF-1 

**
O&D Passengers to Top Washington Area Long-Haul Markets, YE3Q 2011

* Markets granted beyond-perimeter exemptions

Source: DOT O&D Survey, YE3Q2011

SFO-DCA Is the Largest Market without Nonstop Service to DCA, and Is 

Much Larger than Other Long Haul Markets that Have Been Granted 

Beyond-Perimeter Exemptions

2

1,099,330

978,300

655,150

425,560 419,430 365,120

264,200

216,770 192,230 168,070 145,910

-

200,000 

400,000 

600,000 

800,000 

1,000,000 

1,200,000 

Los 

Angeles*

San 

Francisco

Denver* Seattle* Las Vegas* San Diego Phoenix* Salt Lake 

City*

Portland Austin San Juan

Reagan National Dulles

2

Docket DOT-OST2012-0029

Exhibit SF-2 
-

200,000 

400,000 

600,000 

800,000 

1,000,000 

1,200,000 

1,400,000 

1,600,000 

Reagan National Dulles

O&D Passengers to Top 20 Washington Area Markets, YE3Q 2011

Even without Any Nonstop Service from DCA, San Francisco Is 

One of the Washington Area’s Largest Markets of Any Distance

Source: DOT O&D Survey, YE3Q2011 3

Docket DOT-OST2012-0029

Exhibit SF-3 
4

SFO Is Much Larger than Other Markets that Have Been 

Awarded Multiple Beyond-Perimeter Exemptions

Based on the number of exemptions granted to Denver, SFO should gain six additional 

non-stop DCA daily flights – more than any other market

Rank Airport

O&D Passengers

YE3Q2011

Beyond-Perimeter 

Exemptions

Exemptions Based on 

DEN as Base Level

Shortfall Based on 

DEN as Base Level

1 LAX Los Angeles 1,099,330 1 6.6 5.6

2 SFO San Francisco 978,300 0 5.9 5.9

3 DEN Denver 665,150 4 4.0 0.0

5 SEA Seattle 425,560 2 2.6 0.6

4 LAS Las Vegas 419,430 1 2.5 1.5

6 SAN San Diego 365,120 0 2.2 2.2

7 PHX Phoenix 264,200 3 1.6 -1.4

8 SLC Salt Lake City 216,770 1 1.3 0.3

9 PDX Portland 192,230 0 1.2 1.2

10 AUS Austin 168,070 0 1.0 1.0

11 SJU San Juan 145,910 0 0.9 0.9

12 COS Colorado Springs 68,140 0 0.4 0.4

12 YVR Vancouver* 48,775 0 0.3 0.3

12

Source: DOT O&D Survey, YE3Q2011, except Vancouver – MIDT 2011. 4

Docket DOT-OST2012-0029

Exhibit SF-4 
Carrier Connection TtlPax Share Tot E Time

AA DFW 14,120 9.3% 540

UA ORD 11,290 7.4% 483

US CLT 10,670 7.0% 536

FL ATL 10,350 6.8% 502

US PHL 10,070 6.6% 520

FL MKE 9,760 6.4% 485

DL MSP 9,650 6.4% 481

AA ORD 9,080 6.0% 495

DL ATL 7,720 5.1% 484

92,710 61.1% 505

Passengers currently connect at a variety of hubs to travel from DCA to SFO, with an average one-way 

travel time of 505 minutes, (8 hours and 25 minutes)

Top Carrier-Gateway Shares DCA-SFO, YE3Q 2011

Travel time for passengers taking the non-stop DCA-SFO flight would be 365 minutes (6 hours and 5 

minutes). 

Each passenger taking the non-stop flight would save an average of 140 minutes (2 hours and 20 minutes) 

for a total passenger time savings of over 168,000 hours annually for each daily DCA-SFO nonstop 

roundtrip flight, at a conservative load factor assumption.

Seat Config.

Assumed Load Factor

(VX IAD-SFO YE 

Nov'11)

Annual Nonstop Passengers 

By VX (based on 1x Daily)

Total Travel Time Saved 

in Annual Hours

119 83.1% 72,189 168,441

5

Each Passenger Traveling on the DCA-SFO Flight Would Save 

Two Hours and 20 Minutes

Based on analysis of published flight schedules in OAG, and DOT O&D Survey, YE3Q2011 5

Docket DOT-OST2012-0029

Exhibit SF-5 
6

*U. S. Department of Transportation, “Revised Departmental Guidance –Valuation of Travel Time in Economic Analysis,” Memorandum, Feb. 11, 2003. For air 

travel, the guidance recommends the following hourly values of travel time by trip purpose in 2000 U.S. dollars per person-hour: personal, $23.30; business, 

$40.10; and all purposes, $28.60. Using $28.60 in 2000 dollars and applying the CPI inflator value yields $37.65 in 2012 dollars

Each Daily DCA-SFO Nonstop Roundtrip Flight Would Save Over 

$6 Million in Passenger Travel Time Annually

Annual Nonstop 

Passengers By VX 

(based on 1x 

Daily)

Total Travel 

Time Saved in 

Annual Hours

Value of 

Passenger 

Travel Time per 

Hour*

Annual Value 

of Passenger 

Travel Time 

Saved

72,189 168,441 $37.65 $6,341,801

Docket DOT-OST2012-0029

Exhibit SF-6 
7

Washington-SFO Has Experienced Higher Growth than Any of the 

Other Markets that Have Received or Applied for Exemptions

60.7%

25.7%

19.6%

7.3%

1.4%

-5.5%

-9.7% -12.7%-15.4%-18.2%-18.3%-19.9%

-30%

-20%

-10%

0%

10%

20%

30%

40%

50%

60%

70%

Washington O&D Passengers to Markets Listed, 2005 – YE3Q2011

Source: DOT O&D Survey, DCA/IAD to airports listed, 2005-YE3Q2011

YVR 2005 MIDT data not available

O&D Passengers Growth 2005-YE3q'11

2005 YE3q'11 % Passengers

SFO 608,820 978,300 60.7% 369,480

PDX 152,950 192,230 25.7% 39,280

LAX 918,960 1,099,330 19.6% 180,370

SLC 202,040 216,770 7.3% 14,730

AUS 165,730 168,070 1.4% 2,340

DEN 703,530 665,150 -5.5% -38,380

SEA 471,260 425,560 -9.7% -45,700

PHX 302,650 264,200 -12.7% -38,450

COS 80,580 68,140 -15.4% -12,440

LAS 512,750 419,430 -18.2% -93,320

SAN 446,940 365,120 -18.3% -81,820

SJU 182,100 145,910 -19.9% -36,190

Passenger Growth to/from Washington in Markets 

that Have Applied For or Received BeyondPerimeter Exemptions

Docket DOT-OST2012-0029

Exhibit SF-7 
8

Virgin America’s Nonstop SFO Service to Washington Dulles, Introduced in 

September 2007, Brought Lower Nonstop Fares to that Market

8

Over the past four quarters, Virgin’s SFO-Dulles fare has averaged $221 – 25% lower than United’s 

average of $296

Source: DOT O&D Survey; fares are one-way

$273

$308

$300

$301

$194

$209

$242

$239

$100 

$150 

$200 

$250 

$300 

$350 

$400 

4q-071q-082q-083q-084q-081q-092q-093q-094q-091q-102q-103q-104q-101q-112q-113q-11

United IAD Average Virgin America

Average One-Way Fares, IAD-SFO

Docket DOT-OST2012-0029

Exhibit SF-8 
9

Virgin America Currently Saves Passengers Nearly $27 Million/Year on Its 

Four Daily Washington Dulles-SFO Round-Trips

Virgin can be expected to bring this same level of savings – approximately $6.7 million annually 

per daily roundtrip flight – to the DCA-SFO market

Seat 

Config.

Load Factor

(IAD-SFO YE 

Nov'11)

Nonstop 

Passengers By VX 

(based on 1x Daily)

Average Fare 

Differential 

with United 

IAD-SFO

Annual Fare 

Savings per 

Daily Round 

Trip

149 83.1% 90,388 $74.5 $6,730,290

Annual savings for passengers on Virgin America’s four daily Washington Dulles-SFO round-trips: 

4 x $6,730,290 = $26,921,162

Source: DOT O&D Survey; T-100

Docket DOT-OST2012-0029

Exhibit SF-9 
Virgin America Has an Expanding Network Beyond SFO

10

Additional destinations that Washington passengers can 

reach via Virgin America flights at SFO

• Las Vegas

• Los Angeles

• Palm Springs

• San Diego

• Seattle

Just announced

• Portland

Washington-DCA

San Diego

Palm Springs

Las Vegas

Los Angeles

Seattle

Portland

San Francisco

Docket DOT-OST2012-0029

Exhibit SF-10
Docket DOT-OST-2012-0029

Appendix to Comments of the City and County of San Francisco and San 

Francisco International Airport in Support of Application of Virgin America Inc.

Gov. Jerry Brown

Lt. Gov. Gavin Newsom

US Senator Dianne Feinstein

Mayor Ed Lee

Congressperson Jackie Speier

Congressperson Anna Eshoo

Congressperson Barbara Lee

Congressperson Jeff Denham

Congressperson Mike Honda

Congressperson Zoe Lofgren

CA State Senator Leland Yee

CA Assemblymember Fiona Ma

San Francisco Chronicle Editorial, 3/18/2012

Silicon Valley Leadership Group

San Francisco Chamber of Commerce

Bay Area Council

San Francisco Travel

San Mateo County Economic Development Association

San Mateo County/Silicon Valley Convention and Visitors Bureau

Burlingame Chamber of Commerce

Levi Strauss & Co.

Union Bank

Oracle

EA (Electronic Arts)
OFFICE OF THE GOVERNOR 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey A venue, S.E. 

Washington, D.C. 20590 

Re: 

March 20, 2012 

Iication for "Be and-Perimeter" Slots 

I am writing to ex ress my strong support for Virgin America's application for two non-stop 

daily flights between San Francisco International Airport ("SFO") and Reagan International 

Airport ("DCA"). With no current service at DCA and as the only airline headquartered in 

California, Virgin America is uniquely suited to bring meaningful low-fare competition to the 

largest market in the nation previously without nonstop flight service to DCA: the San Francisco 

Bay Area. Allocation of additional beyond perimeter slots to SFO will provide assurances that 

the Bay Area will finally have efficient, modem and low-fare nonstop service to DCA. 

The State of California is grateful for the work of the Department of Transportation, Congress 

and the President on the recently signed FAA Modernization and Reform Act of 2012 which 

allows for the opportunity to award these new routes between DCA and domestic airports located 

beyond the current 1,250 mile perimeter limit SFO currently has no non-stop service to DCA 

and while I understand United Airlines intends to begin one daily flight to DCA in mid-May, 

SFO is the second largest market for the Washington D.C. area after Los Angeles. The demand 

between SFO and DCA clearly warrants more than a single flight per day. 

Since 2007, Virgin America has expanded to 17 new markets and created 2480 jobs- with plans 

to add 500 additional jobs annually over the next three to five years. For every one airline job 

there is a job multiplier of 5: I. Virgin America continues to spur major growth, with plans to 

grow from its current 50 aircraft fleet to over I 00 aircraft by 20 I 9. The opportunity for this 

airline to grow into this new market is vital to the region and to the State. 

GOVERNOR EDMUND G. BROWN JR. • SACRAMENTO, CALIFORNIA 95814 • (916) 445-2841 
Secretary LaHood 

March 20, 2012 

Page 2 

As I understand it, Virgin America is currently the only low cost carrier applying for slots 

between SFO and DCA. More than a single flight on more than one carrier would provide a real 

competitive advantage for the conswner and will also guarantee that local conswners and 

businesses reap the benefit that competition provides. 

When making this critical decision, I urge you to consider the positive impact of improving the 

connection between Washington D.C. and the San Francisco Bay Area and Silicon Valley, home 

to countless innovation-based companies. Thank you for your consideration. 

---.-.Jr. f11tJ ~ 

\ 
February 29, 2012 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

GAVIN NEWSOM 

LIEUTENANT GOVERNOR 

Re: Docket No. OST-2012-0029, Application of Virgin America Inc. for "Beyond-Perimeter" Slots 

Dear Secretary LaHood: 

I am writing to express my strong support for Virgin America's proposal to provide two nonstop 

flights between San Francisco International Airport (SFO) and Reagan National Airport (DCA). With no 

current service at DCA and as the only airline headquartered In California, Virgin America is uniquely 

suited to bring meaningful low-fare competition to the largest market in the nation previously 

without nonstop flight service to DCA: the San Francisco Bay Area. 

The State of California is grateful for the work of the DOT, Congress and the President on the recently 

signed the FAA Modernization and Reform Act of 2012, which included a provision authorizing the 

award of new routes between DCA and domestic airports located beyond the current 1,250 mile 

perimeter limit. Historically, the Bay Area has been shut out from DCA nonstop service, with all 

"beyond-perimeter'' flight awards being made to non-California airports- with the exception of a 

daily flight at los Angeles. Previous DCA awards have been made to smaller markets, including: 

Denver (four roundtrip frequencies) and Phoenix (three roundtrip frequencies). In terms of 

passenger traffic, San Francisco dwarfs these and all other beyond-perimeter markets. Because SFO 

has been the largest beyond-perimeter market without nonstop flights to DCA, local consumers have 

suffered with higher fares and limited options- either travel to Washington Dulles or a one-stop 

connecting flight when traveling to downtown Washington, D.C. 

When making this critical decision, I urge you to consider the positive impact of improving the 

connection between Washington D.C. and the San Francisco Bay Area and Silicon Valley's critical 

innovation-based economy. Allocation of two round-trip flights to Virgin America will provide 

assurance that the Bay Area will finally have efficient, modern and low-fare nonstop flight service to 

DCA. It will also guarantee that local consumers and businesses reap the benefit that only real 

competition can provide. 

. '~'I i j ; (; f ,\' I \' ~ I. i ) 1 -l • ' j ; ; ; 
Since its launch in 2007, Virgin America has lowered fares and provided a unique new service option. 

According to the airline, when it enters long-haul markets from SFO it typically sees fares drop by 

one-third. The Wall Street Journal went so far as to describe the low-fare airline's impact on fares as 

"the Virgin effect."1 In addition, the carrier's decision to headquarter in the Bay Area has created 

thousands of local jobs. The airline has grown to over 2,500 employees, with plans to add 500 new 

jobs on an annual basis over the next three to five years. 

As the former Mayor of San Francisco, I worked hard to get Virgin America to headquarter In the Bay 

Area and have been thrilled to see the effect of their presence at SFO. When more airlines compete, 

consumers and local economies win- with lower fares, improved service and local job growth. 

Thank you for your consideration. 

Gavin Newsom 

lieutenant Governor, State of California 

1 The Virgin Effect: Lower Cross-Country Fares, H Wall Street Journal, October 30, 2007. 
DIANNE FEINSTEIN 

CAUFORNIA 

~nittb ~tatts ~tnatt WASHINGTON, DC 20510-0504 

httpJ/felnsteln.senate.gov 

March 6, 2012 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

SELECT COMMITTEE ON INTElliGENCE • CHAIRMAN 

COMMITTEE ON APPROPRIATIONS 

COMMITTEE ON THE JUDICIARY 

COMMITTEE ON RULES AND ADMINISTRATION 

Re: Docket No. OST -2012-0029 for "Beyond-Perimeter" Slots 

Dear Secretary LaHood: 

I am writing to express my strong support for proposals to provide 

nonstop flights between the San Francisco Bay Area and Reagan National 

Airport (DCA). 

The recently enacted FAA Modernization and Reform Act of 2012 

authorizes you to award new flights between DCA and domestic airports 

located beyond the current 1 ,250 mile perimeter limit. 

Multiple direct flights from DCA to San Francisco - the largest 

metropolitan area and largest air travel market in the country without 

nonstop service to DCA today- would provide a tremendous expansion of 

direct service, increase competition between carriers, and potentially reduce 

prices. Previous DCA awards have been made to smaller markets, including 

Denver (four roundtrip frequencies) and Phoenix (three roundtrip 

frequencies). In terms of passenger traffic, the Bay area's three major 

airports represent a market that dwarfs most other beyond-perimeter 

markets. 

When making this decision, I urge you to consider the positive impact 

of improving the connection between Washington D.C. and the San 

Francisco Bay Area, which is home to critical innovation-based companies. 

Allocation of multiple round-trip flights to San Francisco will provide 
efficient, modem and low-fare nonstop flight service to DCA. It will also 

guarantee that local consumers and businesses reap the benefit that real 

competition provides. 

I also encourage you to consider the impact of your selection on 

consumer ticket prices. It is my understanding that some new entrants in the 

San Francisco market have a demonstrated downward impact on ticket 

prices within the markets they serve. If this is true, I hope you will consider 

this benefit when making your selections. 

Thank you in advance for considering this request. Nonstop service 

between San Francisco and DCA is long overdue, and I hope you can 

appreciate the substantial benefits it will provide. If you have any questions 

or concerns, please do not hesitate to contact me. Thank you for your 

consideration. 

Sincerely, 

/,/··· ' 

/ 

/ 

Jt. ~ hvL-----_ 

Dia Feinstein 

""~ U · ed States Senator 

DF/mbn 
Office of the Mayor 

City & County of San Fr~tncisco 

March 7, 2012 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Edwin M. Lee 

Re: Docket No. OST-2012-0029, Application of Virgin America Inc. for "Beyond-Perimeter'' 

Slots 

Dear Secretary LaHood: 

I am writing to express my strong support for Virgin America's proposal to provide two nonstop 

flights between San Francisco International Airport (SFO} and Reagan National Airport (DCA}. 

With no current service at DCA, and as the only airline headquartered in California, Virgin 

America is uniquely suited to bring meaningful low-fare competition to the largest market in the 

nation previously without nonstop flight service to DCA: the San Francisco Bay Area. 

As a result of the work by you, your department and Congress, the President recently signed 

the FAA Modernization and Reform Act of 2012, which included a provision authorizing you to 

award new flights between DCA and domestic airports located beyond the current 1 ,250 mile 

perimeter limit. Historically, the Bay Area has been shut out from DCA nonstop service, with all 

"beyond-perimeter" flight awards being made to non-California airports - with the exception of a 

daily flight at Los Angeles. Previous DCA awards have been made to smaller markets, 

including: Denver (four roundtrip frequencies} and Phoenix (three roundtrip frequencies}. In 

terms of passenger traffic, San Francisco dwarfs these and all other beyond-perimeter markets. 

Because SFO has been the largest beyond-perimeter market without nonstop flights to DCA, 

local consumers have suffered with higher fares and limited options - either travel to 

Washington Dulles or a one-stop connecting flight when traveling to downtown Washington, 

D.C. 

When making this critical decision, I urge you to consider the positive impact of improving the 

connection between Washington D.C. and Silicon Valley's powerful innovation-based economy. 

Allocation of two round-trip flights to Virgin America - our hometown carrier- will provide 

assurance that the Bay Area will finally have efficient, modern and low-fare nonstop flight 

service to DCA. It will also guarantee that local consumers and businesses reap the benefit 

that only real competition can provide. 

Since its launch in 2007, Virgin America has lowered fares and provided a unique new service 

option. According to the airline, when it enters long-haul markets from SFO, it typically sees 

fares drop by one-third. The Wall Street Journal went so far as to describe the low-fare airline's 

impact on fares as "the Virgin effect."1 In addition, the carrier's decision to headquarter in the 

Bay Area has created thousands of local jobs. The airline has grown to over 2,500 employees, 

with plans to add 500 new jobs on an annual basis over the next three to five years. 

1 The Virgin Effect: Lower Cross-Country Fares," Wall Street Journal, October 30, 2007. 

I Dr. Carlton II. (;oodktt Pbce, [{oom 200. San Fr:mcisco. Calil(•rnia <) 1102-t<H I 

( II 'iJ 'i'i 1-() I II 
The Honorable Raymond H. LaHood 

March 7, 2012 

Page Two 

When more airlines compete, consumers and local economies win -with lower fares, improved 

service and local job growth. Virgin America has been a case study for the positive impacts of 

competition in the Bay Area. The award of two roundtrip flights to the carrier will both spur 

continued local economic growth and ensure that SFO-DCA travelers will finally benefit from 

real competition. Thank you for your consideration. 

Sincerely, 

~ Edwin M. Lee 

Mayor 

so Van Ness Avenue I San Francisco, CA 94102 workforce.development@sfgov.org I www.oewd.org 

p: 415-581.2))5 f: 415-581.2)17 
JACKIE SPEIER l2fJI O!SlRICT, CALifOHN!A 

2, 1 c~~,NoN Hous.f OFFCr Buit[IING 

\N~.S.HINfJH~l'l. DC 20515 0512 

t2021 225-3531 

FAX: f2021 226 4183 

·~00 S. Et C,u+IINU Rt:Al. SUI rt 4 1 0 

SAN MA 'EO, CA 94402 

!~501 342-0300 

FAX: ;6501 375 8270 

March 19, 2012 

(ongre9'5 of tbe ~lttiteb !$tate5' 

j'!)ouse of Jl\epresentatiben 

mtasbinutont ill<!C 20515-0512 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

COMMITTEE ON HOMELAND SECURITY 

SUBCOMMITTEES 

RANKIIIG MfMBEA vr CcurPnHrr.;:;ofW>M 

MtD ft1 ffllrGlM:E 

COMMITTEE ON OVERSIGHT AND 

GOVERNMENT REFORM 

SUBCOMMITTEES 

REGUtAIORf AHAIRS, 5nt1UtUS 0VI.:A.S!GHr ANO 

GovERM.1fl"lT Sr-t:NOINB 

r AAP. FINA""ctAt SERVICEs ANo 

BAitO!JiS OF PuBLIC MID PA:lVATr Pf.IC)(1RAMS 

TfCH~OlOGY. I~Jf!)RttfA'fiQN POtl(t' ANO 

P><O(UREMENT Aff.ORM 

cket No. OST -2012-0029 A lication of Vir in America Inc. for "Be ondPe i eter" Slots 

Dear~ary~ocr: 

I am writing to express my strong support for Virgin America's proposal to provide two nonstop 

flights between San Francisco International Airport (SFO) and Reagan National Airport (DCA). 

With no current service at DCA and as the only airline headquartered in California, Virgin 

America is uniquely suited to bring meaningful low-fare competition to the largest market in the 

nation previously without nonstop flight service to DCA: the San Francisco Bay Area. In 

addition, Virgin America is the only carrier to apply to provide service between DCA and SFO. 

As you are well aware, the recently signed FAA Modernization and Reform Act of2012 

authorizes you to award new flights between DCA and domestic airports located beyond the 

current 1,250 mile perimeter limit. Historically, the Bay Area has been shut out from DCA 

nonstop service, with all "beyond-perimeter" flight awards being made to non-California airports 

-with the exception of a daily flight at Los Angeles. Previous DCA awards have been made to 

smaller markets, including: Denver (four roundtrip frequencies) and Phoenix (three roundtrip 

frequencies). In terms of passenger traffic, San Francisco dwarfs these and all other beyondperimeter markets. Because SFO has been the largest beyond-perimeter market without nonstop 

flights to DCA, local travelers have had limited options - either travel to Washington Dulles or a 

one-stop connecting flight when traveling to downtown Washington, D.C. 

When making this critical decision, I urge you to consider the positive impact of improving the 

connection between Washington D.C. and the dynamic innovation-based economy in San 

Francisco and the Silicon Valley. Allocation of two round-trip flights to Virgin America will 

provide assurance that the Bay Area will finally have efficient, modern and low-fare nonstop 

tlight service to DCA. 

Since its launch in 2007, Virgin America has lowered fares and provided a unique new service 

option. In addition, the carrier's decision to headquarter in my district (in Burlingame, 

PR!NTEO ON RECYClfO PAf->fA 

tt·::'~l1 
California) has created thousands of local jobs. Virgin America has established a maintenance 

hub at SFO, and is providing pilot simulator training locally. The airline has grown to over 2,500 

employees, with plans to add 500 new jobs on an annual basis over the next three to five years. 

When more airlines compete, consumers and local economies win - with lower fares, improved 

service and local job growth. The award of two roundtrip flights to the carrier will both spur 

continued local economic growth and ensure that SFO-DCA travelers will tinally benefit from 

real competition. Thank you for your consideration of my request. 

All the best, 

Jac ie Speier 

mber of Congress 
~§. ~d,.,. 

y~g;~ 

tff'~ 

March 211 2.012 

The Honorable Raymond H. LaHood1 Secretary 

U.S. Department of Transportation 

uoo New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Dear Secretary LaHood, 

I'm writing to express my support for Virgin America's proposal to provide non-stop service 

between San Francisco International Airport (SFO) and Reagan National Airport I DCA). 

As you know, the Federal Aviation Administration Modernization and Reform Act of 2.011 

authorized you to award four new "slots" between DCA and domestic airports located 

beyond the current 11250 mile perimeter limit. l urge you to consider the positive impact of 

allocation of a_dditional beyond perimeter slots to SFO to improve the connection between 

Washington D.C. and Silicon VaHey's powerful innovation-based economy. 

lt is my understanding that Virgin America is the only low cost carrier applying for slots 

between SFO and DCA, and has bid for two daily round trip flights. This proposal would 

provide a competitive advantage for the consumer and will also guarantee that local 

consumers and businesses reap the benefit that competition provides. 

l respectfully request that you give this project your highest consideration, and 1 thank you in 

advance for your cooperation. 

Most gratefuHy1 

Anlla-C. Eshoo 

.Member of Congress 
BARBARA LEE 

COMMITTEE ON 

APPRO PRIATIO NS 

L-Ibor, c~h h lnd ffurnan S< \' H. . 

EJuc l!IOfl, <lnd Rcl altd A CCI'K1Cl 

f in.md:al Strvi«:r;; artd Gc: n.e n[ Govcrnmcnt Q!nngr£55 nf tqe Jlnitril ~tatrs 

71fnu.ae nf llttpre.aentatiue.a 

i!Jan11ingtnn, it«. 20515-0509 

March 23, 2012 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

REPLY TO OFFICE CHECKED 

. ; WAS HI NGTON Of'FICE 

2267 RAYBURN HO.O. 

WASI!INGTON. D.C. 20515 

Phon<: (202 ) 225 -2661 

Fax: (202 ) 225-9817 

. DISTRICTOFFICE 

IJOI CLAY STREET. SUITE IOOON 

OAKLAI'ID. CA 94612 

Ph n~: (5 I 0) 763-0370 

F3x: (S 10) 763-6538 

we ~ite : 1ce.hou:-;c.gov 

Re: Docket No. OST-2012-0029. ApPDcatlon of Vlr&ln America fnc. for "Beyond-Perimeter" Slots 

Dear Secretary LaHood: 

I am writing to express my strong support for Virgin America's proposal to provide two nonstop flights 

between San Francisco International Airport (SFO) and Reagan National Airport (DCA). With no current service at 

DCA and as the only airline headquartered In California, Virgin America is uniquely suited to bring meaningful lowfare competition to the largest market in the nation previously without nonstop flight service to DCA: the San 

Francisco Bay Area. 

As a result of the work by you, your department and Congress, the President recently signed the FAA 

Modernization and Reform Act of 2012, which included a provision authorizing you to award new flights between 

DCA and domestic airports located beyond the current 1,250 mile perimeter limit. Historically, the Bay Area has 

been shut out from DCA nonstop service, with all "beyond-perimeter" flight awards being made to non-California 

airports - with the exception of a daily flight at los Angeles. Previous DCA awards have been made to smaller 

markets, including: Denver (four roundtrip frequendes) and Phoenix (three roundtrip frequencies). In terms of 

passenger traffic, San Francisco dwarfs these and all other beyond-perimeter markets. Because SFO has been the 

largest beyond-perimeter market without nonstop flights to DCA, local consumers have suffered with higher fares 

and limited options- either travel to Washington Dulles or a one-stop connecting flight when traveling to 

downtown Washington, D.C. 

When making this critical decision, I urge you to consider the positive impact of Improving the connection 

between Washington D.C. and Silicon Valley's powerful innovation-based economy. Allocation of two round-trip 

flights to Virgin America- our hometown carrier- will provide assurance that the Bay Area will finally have efficient, 

modern and low-fare nonstop flight service to DCA. It will also guarantee that local consumers and businesses reap 

the benefit that only real competition can provide. 

Since Its launch in 2007, Virgin America has lowered fares and provided a unique new service option. 

According to the airline, when it enters long-haul markets with less competition from SFO It typically sees fares drop 

by one-third. The Wall Street Journal went so far as to describe the low-fare airline's impact on fares as "the Virgin 

effect."1 In addition, the carrier's decision to headquarter In my district (in Burlingame, California) has created 

thousands of local jobs. The airline has grown to over 2,500 employees, with plans to add 500 new jobs on an 

annual basis over the next three to five years. 

When more airlines compete, consumers and local economies win- with lower fares, improved service and 

local job growth. Virgin America has been a case study for the positive impacts of competition in the Bay Area. The 

award of two roundtrip flights to the carrier will both spur continued l9cal economic growth and ensure that SFODCA travelers will finally benefit from real competition. Thank you for your consideration. 

1 The Virgin Effect: Lower Cross-Country Fares, • Wall Sf~fl.ialilfn~~c!M'f-!YfJ, 2007. ': .. -:: :__.;.. 1 
Sincerely, 

Barbara Lee 

Member of Congress 
.JEFF DENHAM 

f.: MAll \r!A '/.,-'(8Sl1T 

dt:PhJ;Ti,hnu-~e- ·]·)v \!Congress of tbe 'ijlntteb ~tates 

jt)ouse of l\cprescntatibts 

i!J!fagf)ington, ilht 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department ofTransportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

March 22,2012 

HOUSE NATURAL RESOURCES COMMITIEE 

HOUSE TRANSPORTATION AND 

INFRASTRUCTURE COMMITIEE 

Ctv'\I~:'IIAN, SutKGMMIHH GN 

Eco~JOMlC Ot• .. ELOPMENT, 

Pvauc 8u,LOlNG5 AN'J EMERGENCY MANAGEMF.NT 

HOUSE COMMITIEE ON 

VETERANS' AFFAIRS 

Re: Docket No. OSI-2012-0029. Application of Vlrxin Ametlca Inc:. for "Beyond-Perimeter" Slots 

Dear Secretary LaHood: 

I am writing to express my support for Virgin America's proposal to provide two nonstop flights between 

San Francisco International Airport (SFO) and Reagan National Airport (DCA). With no current service at DCA and as 

the only airline headquartered in California, Virgin America is uniquely suited to bring meaningful competition to 

the largest market in the nation previously without nonstop flight service to DCA. 

As a result of the work by you, your department and Congress, the President recently signed the FAA 

Modernization and Reform Act of 20U, which included a provision authorizing you to award new flights between 

DCA and domestic airports located beyond the current 1,250 mile perimeter limit. Historically, parts of California 

have been shut out from DCA nonstop service, with all "beyond-perimeter" flight awards being made to nonCalifornia airports - with the exception of a daily flight at Los Angeles. Previous DCA awards have been made to 

smaller markets, including: Denver (four roundtrip frequencies) and Phoenix (three roundtrip frequencies). In 

terms of passenger traffic, San Francisco outpaces these and all other beyond-perimeter markets. Because SFO has 

been the largest beyond-perimeter market without nonstop flights to DCA, local consumers have suffered with 

higher fares and limited options- either travel to Washington Dulles or a one-stop connecting flight when traveling 

to downtown Washington, D.C. 

When making this critical decision, I urge you to consider the positive impact of improving the connection 

between Washington D.C. and California's powerful innovation-based economy. Allocation of two round-trip flights 

to Virgin America will provide greater assurance that California will finally have efficient, modern and low-fare 

nonstop flight service to DCA. It will also guarantee that local consumers and businesses reap the benefit that only 

real competition can provide. 

When more airlines compete, consumers and local economies win- with lower fares, improved service and 

local job growth. Virgin America has been a study for the positive impacts of competition In the airline industry. 

The award of two roundtrip flights to the carrier will both spur continued local economic growth and ensure that 

SFO-DCA travelers will finally benefit from real competition. Thank you for your consideration. 

;llt:.. "'t() 

1';.'!() r>">'if HEPNC'>)N .:\·.~Ntl;, 1201 

Fr)IO'..or .. ~). CA 93720 

Pr•CNf. (r;.8~) ,~<~f}-2,~'10 

Frd .. :ssg; 't<1Q~nq9 

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',1o --:.tsro. CA 953~)5 

h-'C!'.f i209) '1)~:;~!}8 

c.c~t-., l/G9t :1!1~~028 
MICHAEL M. HONDA 

15TH DISTRICT, CALJFORMA 

WASHINGTON OFFICE: 

1713 LONGWORTH House 0FI'1CE BUilOING 

WASHINQ70N, DC 20516 

PHONE: (202) 225-2631 

FAX: (202) 225-2699 

http://www.honda.hn<l .... gov 

DISTRICT OFFICE: 

1999 Solll'H BASCOM AVENUR 

SunE #815 

CAMPS Ell, CA 96008 

PHONE: (408) 568-a0!15 

FAX: (408) 651H1085 

([ongress of tbt Wniteb ~tates 

j!)ouse of l\epresentatibes 

GllAOV RESIOSNTl!! (888) 643-4715 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

March 22, 2012 

COMMITTEE ON APPROPRIATIONS 

SUBCOMMirt'EE8! 

CO~MEACE, Jusru;w, AND SoENCE 

LE<JISLATTVE BRANCH, RANKING MEIIABIYf 

COMMITIEE ON THE BUDGET 

SENIOR MAJORITY WliiP 

CONORE6510NA1. AsJw PACifiC 

AME~ICAN CAucus, CHAIA EM"'ITVS 

CONGRESSIONA1.-Ex£CUTM! 

COMMISSION ON CHINA 

Re: Docket No. OST-2012-0029, Application of Virgin America Inc. for "BeyondPerimeter" Slots 

Dear Secretary LaHood: 

I am writing to express my strong support for Virgin America's proposal to provide two 

nonstop flights between San Francisco International Airport (SFO) and Reagan National Airport 

(DCA). 

As you are aware, the recently signed the FAA Modernization and Reform Act of2012 

included a provision authorizing you to award new flights between DCA and domestic airports located 

beyond the current 1,250 mile perimeter limit. Historically, the Bay Area has been shut out from DCA 

nonstop service, with. all "beyond-perimeter" flight awards being made to non-California airportswith the exception of a daily flight at Los Angeles. Previous DCA awards have been made to smaller 

markets, including: Denver (four roundtrip frequencies) and Phoenix (three roundtrip frequencies). In 

terms of passenger traffic, San Francisco dwarfs these and all other beyond-perimeter markets. 

When making this critical decision, I urge you to consider the positive impact of improving the 

connection between Washington D.C. and Silicon Valley's powerful innovation-based economy. 

Allocation of two round-trip flights to the San Francisco Bay Area will provide efficient, modem and 

low-fare nonstop flight service to DCA. 

Thank you in advance for considering this request. Nonstop service between the San Francisco 

Bay Area and DCA is long overdue. If you have any questions or concerns, please do not hesitate to 

contact me. Thank you for your consideration. 

Sincerely, 

Michael M. Honda 

Member of Congress 

PRI~O ON RECYC!.EO PAPER 
COMMITTEE ON THI! JUDICIARY 

• f1ANf,"•U ,\1f ,• .. ;Hf-r-f ~ Sud(Ut.-1;\HI ~r-c :·l:-1 

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COMMITTEE ON HOUSI! ADMINISTRATION 

• f?sV\'i'OI';(j .'\/E\-{(lt;P- SU,K\lt.•.\t~f HE !lN 

t/•:Ht:~I,_H-!T 

COMMITTEE ON SCIENCE, SPACE, AND 

TECHNOlOGY 

• Surv 1-:;M ... HTTCf U~-< E·.Ult:IY ,·,~Jf} E"..:'~I·~O'-.M£-Nf 

• S0ecu-~A\HflU: 01', ·~.vu;.Tit...Afi-1\:';~ VH) 

0\f"r<~";h-:,.rlT 

(ongress of tfJe itniteb $tate% 

J[)ouse of l'\eprcsentatibcs 

Q'i!lasbington, wi{ 20515 

ZOE LOFGREN 

16TH DISTRICT, CALIFORNIA 

March 22, 20 12 

The Honorable Ray LaHood, Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue SE 

Washington, DC 20590 

035 Nr;q-:-H f-''J{C•I S!Hl:.cf 

SJ !I> f~ 

SAN JosE, Ci\ •JS112 

I \08) )71-U700 

C•-I}I,R, c.-~uf(.:;nNIA o~Mn· n:.-nc 

Cf;rJ~,t~tssi<Y'" ... L OtttO-\ I10l"-< 

CtJ-CI-/_~/R, \~ONGRf.S~~tGNAl CMJ(C'~ dN 

V;CTN.AM 

Re: Docket No. OST-2012-0029, Application of Virgin America Inc. for "BeyondPerimeter" Slots 

Dear Secretary LaHood, 

I write in support of Virgin America Inc.'s application for two nonstop slots between Ronald 

Reagan Washington National Airport (DCA) and San Francisco International Airport (SFO). 

As you know, the FAA Modernization and Refonn Act of2012 authorized new "beyondperimeter" flights from DCA. California, the most populous state in the country, currently has 

only one flight from DCA, to Los Angeles, and "the Bay Area remains the largest metropolitan 

area without service to DCA. It is my understanding that Virgin America's proposal would 

provide Bay Area businesses and consumers more transportation options and lower fares through 

increased competition. The proposal would also provide the Washington, D.C. area with 

increased access to the economic centers of San Francisco and Silicon Valley. 

This proposal provides a great opportunity for both Northern California and the Washington, 

D.C. area. Thank you for the Department's full and fair consideration of this application. 
STt\TE Ct-\PliTA_ 

::JAC.R·'\MENTO Ct\ 9S8l,J. 

l[L •9161 6:':>1 4(:.()8 

~-\ ,oJ:bl 327·2 18.6 

400 S CL C:l.M!t'JO f?EAL 

SUITF: 630 

SAN ;'>;fA'EO CA 94402 

lll 16501 340 88:!0 I,, ·6C'0• )40 1661 

HIRAM JOHNSON 

'::::1 T ·\ r ~ Of' PICE 8t11LQING 

4::.'15 GOt DEI'J GATE AVE 

SUi-rE 1<1:-?00 

SAN f.-RANC1S(;0 C-"\ 94102 

I(L •415• 557 7857 

f.\;>; i4J5' S57 7864 

February 28, 20 12 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Depar1ment of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

<!InHfornia ~tate ~ennte 

SENATOR LELAND Y. YEE, PH.D. 

EIGHTH SENATE DISTRICT 

STANDING COMMITTEES 

GOVERNI\·1ENT'AL 

URGANIZATiOOJ 

~HH-iAN SERVICES 

LABOR & rNOUSTRIAL 

r;!:£LATIQNS 

SELECT COMMITTEES 

ASIAN PACIFIC rSLJ>.NOER 

AFFAIRS 

81>.V ~REA SUST"-INABLF 

OEVELOPMENr AND 

ECdN011.1JC PROGRESS 

CALIFORNI"-S PUBLIC 

RECORDS & OPEN 

MEETING LAWS 

Re: Docket No. OST -2012-0029, Application of Virgin America Inc. for "Beyond-Perimeter" Slots 

Dear Secretary LaHood: 

I am writing to express my strong support for Virgin America's proposal to provide two nonstop flights between San 

francisco International Airport (SFO) and Reagan National Airport (DCA). With no current service at DCA and as the only 

airline headquartered in California, Virgin America is uniquely suited to bring meaningful low-fare competition to the largest 

market in the nation previously without nonstop flight service to DCA: the San Francisco Bay Area. 

As a result of the work by you, your department and Congress, the President recently signed the FAA Modernization 

and Reform Act of 2012, which included a provision authorizing you to award new flights between DCA and domestic airports 

located beyond the current I ,250 mile perimeter limit. Historically, the Bay Area has been shut out from DCA nonstop service, 

with all ''beyond-perimeter" flight awards being made to non-California airports- with the exception of a daily tlight at Los 

Angeles. Previous DCA awards have been made to smaller markets, including: Denver (four roundtrip frequencies) and 

Phoenix (three roundtrip frequencies). In terms of passenger traffic, San Francisco dwarfs these and all other beyond-perimeter 

markets. Because SFO has been the largest beyond-perimeter market without nonstop flights to DCA, local consumers have 

suffered with higher fares and limited options- either travel to Washington Dulles or a one-stop connecting flight when 

traveling to downtown Washington, D.C. 

When making this critical decision, I urge you to consider the positive impact of improving the connection between 

Washington D.C. and Silicon Valley's powerful innovation-based economy. Allocation of two round-trip flights to Virgin 

America -our hometown <:arrier- will provide assurance that the Bay Area will finally have efficient, modern and low-fare 

nonstop flight service to DCA. It will also guarantee that local consumers and businesses reap the benefit that only real 

competition can provide. 

Since its launch in 2007, Virgin America has lowered fares and provided a unique new service option. According to 

the airline, when it enters long-haul markets from SFO it typically sees fares drop by one-third. The Wall Street Journal went 

~o t:cu as to describe the low-fare airline's impact on fares as "the Virgin etTect." In addition, the carrier's decision to 

headquarter in the Bay Area has created thousands of local jobs. The airline has grown to over 2,500 employees, with plans to 

add 500 new jobs on an annual basis over the next three to five years. 

When more airlines compete, consumers and local economies win- with lower fares, improved service and local job 

growth. Virgin America has been a case study for the positive impacts of competition in the Bay Area. The award of two 

roundtrip flights to the carrier will both spur continued local economic growth and ensure that SFO-DCA travelers will finally 

benefit from real competition. Thank you for your consideration. 

Senator 

~f(f(~ Leland Y. Yee, Ph.D. 

California State Senate 
02/29/2012 15:06 FAX 916 319 2112 

STAT! CAPITOL 

P.O. BOX 942849 

SACRAMENTO, CA 94249-0012 

(916) 319-2012 

FAX (916) 319-2112 

DISTRICT OFACE 

455 GOlDEN GATE AVENUE,I14600 

SAN FRANCISCO, CA 94102 

(415) 557-2312 

FAX (415) 557-1176 

WEBSITE http:/twww.~ca.gov/ma 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Re: Docket No. OST -2012-0029 

ASSEMBLYWOMAN FIONA MA 

February 29, 2012 

Application of VIrgin America Inc. for "Beyond-Pedmeter" Slots 

Dear Secretary LaHood: 

couumees 

AGRICULTURE 

@0011001 

BUSINESS AND PROFESSIONS 

GOVERNMENTAL ORGANIZATION 

PUBLIC EMPLOYEES. RETIREUENT 

AND SOCIAL SECURITY 

UTIUTIESANDCOMMERCE 

CHAIR, SELECT COMUITTEE ON 

DOMESTIC VIOlENCE 

I am writing to express my strong support for Virgin America's proposal to provide two nonstop 

flights between San Francisco International Airport (SFO) and Reagan National Airport (DCA). With 

no current service at DCA and as the only airline headquartered In California, Virgin America is 

uniqueiy suited io bring mai:irtingful competition to the Ia. ~est matr;:et in the natlon ;:m~viously wlthcut 

nonstop flight service to DCA: the San Francisco Bay Area. 

As a result of the work by you, your department and Congress, the President recently signed 

the FAA Modernization and Reform Act of 2012, which included a provision authorizing you to award 

new flights between DCA and domestic airports located beyond the current 1,250 mile perimeter limit. 

Historically, the Bay Area has been shut out from DCA nonstop service, with all "beyond-perimeter" 

flight awards being made to non-california airports - with the exception of a daily flight at Los 

Angeles. Previous DCA awards have been made to smaller markets, including: Denver (four 

roundtrip frequencies) and Phoenix (three roundtrip frequencies). In terms of passenger traffic, San 

Francisco dwarfs these and all other beyond-perimeter markets. Because SFO has been the largest 

beyond-perimeter market without nonstop flights to DCA, local consumers have suffered with limited · 

options - either travel to Washington Dulles or a one-stop connecting flight when traveling to 

downtown Washington, D.C. 

Additionally, the carrier's decision to headquarter in the Bay Area has created thousands of 

local jobs, and the airline has grown to over 2,500 employees, with plans to add 500 new jobs on an 

annual basis over the next three to five years. The award of two roundtrip flights to the carrier will both 

spur continued local economic growth and ensure that SFO-DCA travelers will benefit from real 

competition. Whe making this critical decision, I urge you to consider the positive impact of improving 

the connection n Washington D.C. and Silicon Valley's powerful innovation-based economy. 

have any questions, please do not hesitate to contact me or my staff. 

Speaker pro Tempore 

Assembly District 12 

......... -

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SF Gate. com 

Arti cle 

SFGate.com 

Print This Article I Back to 

ON THE OPENING OF NONSTOP 

FLIGHTS TO REAGAN NATIONAL 

AIRPORT 

An S.F.-D.C. connection 

Sunday, March 18, 2012 

At long last, a loosening of an archaic federal rule 

advertisement I your ad here 

will allow nonstop flights between San Francisco International Airport and Reagan National Airport. 

United Airlines plans to initiate its nonstop service to the airport just across the Potomac River from 

the nation's capital in May. 

Now for the bad news: 

"If there is only one carrier- United - there's going to be a significant premium" on the price of that 

convenient trip, predicted John Martin, SFO director. 

Virgin America has applied for two of the remaining round-trip slots the federal government has 

made available for long-distance flights to Reagan National. 

The granting of those slots to Virgin America makes sense by every critical measure. It would be 

justified by the high volume of air traffic between San Francisco and Washington, it would make 

sense from the standpoint of the importance of the connection between federal policymakers and this 

region's innovation economy, and it would be a huge plus for Bay Area travelers - especially those 

who are not flying to Washington on an expense account. 

"If you think about it, the least price-sensitive (travelers) are the most time sensitive," said David 

Cush, CEO ofVirgin America, which has argued that its two nonstop options (one leaving SFO at 

9:05 a.m., the other at 1:30 p.m.) would give the airline the economic efficiencies to hold dm-vn fares. 

The original justifications for that 1966 rule have long been exhausted. One reason was to allow the 

new Dulles Airport to thrive. It does - now serving about 20 million passengers a year. Another was 

to steer noisy aircraft away from the more populated neighborhoods in the capital and near-in 

suburbs. Today's jets are quieter and cleaner. 

Also, a flight to National gives a traveler the option to board a Metro train to his or her Washington 

hotel- instead of a long (an hour or more in traffic), expensive (up to $6o) and carbon-intensive ride 

in a taxi or shuttle bus. A trip to National is good for the pocketbook, good for the environment, and 

good for the dialogue between business leaders and policymakers. 

3/26/2012 I 0:51 AM 
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"Getting (business) delegations to go back to D.C. is tough as it is ... and each additional hour is 

valuable time," said Jim Wunderman, CEO of the Bay Area Council. 

Cush praised California Sens. Barbara Boxer and Dianne Feinstein for their efforts in pushing for the 

additional "perimeter slots" as part of the Federal Aviation Administration reauthorization bill. 

''These opportunities don't come along very often," Cush said. 

This is a chance for the feds to strengthen the link between Washington and a region that is driving 

the 21st century economy. The Obama administration should approve Virgin America's application. 

About the 'perimeter rule' 

In 1966, the federal government severely limited flights of more than 650 miles into Washington's 

National Airport. The main reason was to steer long-distance flights into the newly opened Dulles 

Airport in the Virginia suburbs. 

The perimeter was extended to 1,250 miles in the late 1980s, allowing nonstop flights from as far as 

Houston. 

A Federal Aviation Administration reauthorization bill signed by President Obama in February will 

allow eight additional round trips to Reagan National Airport beyond the 1,250 mile perimeter. The 

first four were awarded to "legacy carriers," including United Airlines, which will initiate nonstop 

service from San Francisco to Reagan National in May. Four round-trip slots will be awarded to 

smaller carriers. Virgin America has applied for two of those slots, and would use each for nonstop 

service to SFO. 

http:/ /sfgate.com/cgi-bin/article.cgi?f=/c/a/20 12/03/18/EDJTlN M4I H. DTL 

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,-------> 

SiliCON VALLEY, LEADE~UP 

2001 Gateway Place, Sutle 101E 

(408)501-1864 Fax (408)501-7861 

<MNW.svJg.org 

CARL GUARDINO 

President & CEO 

Boald Officers: 

MIKE KLA YKO, Chair 

Brocade 

TIM GUERTIN, VICe Chair 

Van811 Medical Systems 

TOM WERNER. Past Chair 

SunPower 

AART DE GEUS, Past Ch8Jf 

Synopsys 

MICHAEL SPLINTER, Past Chair 

Applied Materials, Inc. 

ROBERT SHOFFNER 

SecretaryfTI'98Sur91' 

C/Ubank 

Boald Members: 

JOHN ADAMS 

Wells Fargo Bank 

SHELL YE ARCHAMBEAU 

MetricStream, Inc. 

ANDY BALL 

Webcor Builders 

GREG BECKER 

Silicon VaHey Bank 

DAVE BELL 

Inters!/ 

STEVE BERGLUND 

Trimble Navigation 

GEORGE BLUMENTHAL 

University of Caiifomla, Santa Cruz 

TOM BOTTORFF 

Pacific Gas & Electric 

TORY BRUNO 

Lockheed Martin Space Systems 

DAVID GUSH 

VTTgin America 

STEVE DEWITT 

Hewlett-Pilckard Company 

MICHAEL ENGH, S.J. 

Santa Clara University 

TOM GEORG ENS 

NetApp, Inc. 

RAQUEL GONZALEZ 

Bank of America 

JAMES GUTIERREZ 

Progreso Fmanclero 

BARBARA HOLZAPFEL 

SAP 

KEN KANNAPPAN 

Plantronics 

GARY LAUER 

eHealth 

TARKAN MANER 

March 2, 2012 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

RE: Docket No. OST-2012-0029, Application of Virgin America Inc. for "BeyondPerimeter" Slots 

Dear Secretary LaHood, 

On behalf of the Silicon Valley Leadership Group, I am writing to strongly support Virgin 

America's bid for a two nonstop flights between Ronald Reagan Washington National 

Airport (DCA) to San Francisco International Airport (SFO) pursuant to the Federal Aviation 

Administration Modernization and Reform Act of 2012. 

As background, the Silicon Valley Leadership Group, founded in 1978 by David Packard of 

Hewlett-Packard, represents more than 365 of Silicon Valleys most respected employers on 

issues, programs and campaigns that affect the economic health and quality of life in Silicon 

Valley, including energy, transportation, education, housing, health care, tax policies, 

economic vitality, and the environment. Leadership Group members collectively provide 

nearly one out of every three private sector jobs in Silicon Valley. 

The newly opened slots represent an opportunity to improve the connection between Silicon 

Valley's powerful innovation-based economy and Washington DC. The Bay Area represents 

the largest market without nonstop flights to DCA- and corporate customers suffer through 

higher fares and limited travel options when flying to the capital. 

In a March 2011 survey of more than 100 Leadership Group member companies, 67% 

indicated that they travel from the Bay Area to Washington DC on business. Two additional 

nonstop flights to the DC area would provide these companies direct, low fare flights to 

downtown Washington. When more airlines compete, consumers and regional economies 

win, allowing local consumers and businesses to reap the benefits. 

Wyse Technology For these reasons we support Virgin America's bid for two nonstop flights from DCA to SFO. 

~~.A~MC.~~~ c·~,/5);/, ~ u---< 

LENPERHAM •. 

Monoiithic Systems · / 

KIM POLES£ ;'; cA..--tt1 r/M 

ClearS/reel 1- t 

ALAN SALZMAN -Ca I G d. 

Ventage Point Capital PBitners r uar mo 

MAC TULLY President & CEO 

San Jose Mercury News 

RICK WALLACE 

KLA-Tencor 

BILL WATKINS 

BndgeLux 

JED YORK 

San Francisco 49ers 

Working Council Chair. 

STEVE BEITlER, Agdent Technolgies 

Established In 1978 by 

DAVID PACKARD 
SAN FRANCISCO 

CHAMBER OF COMMERCE VI!Mre smart buslne"' starts. 

Steven B. Falk 

President & CEO 

March 2, 2012 

The Honorable Raymond H.laHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Re: Docket No. OST-2012-0029, Application of Virgin America Inc. for "Beyond-Perimeter'' 

Slots 

Dear Secretary LaHood: 

The San Francisco Chamber of Commerce representing over 1,500 local businesses, strongly supports 

Virgin America's proposal to provide two nonstop flights between San Francisco International Airport 

(SFO) and Reagan National Airport (DCA). As the only airline headquartered here in San Francisco, 

Virgin America is uniquely suited to bring meaningful low-fare airline competition to the DCA-Bay 

Area routes. 

Historically, the Bay Area has been shut out of nonstop DCA service, with all previous flight awards 

being made to non-California airports- with the exception of a single daily los Angeles flight. Prior 

DCA awards have been made to a number of smaller cities and markets, including Denver and 

Phoenix. Because SFO has been the largest market without nonstop flights to DCA, local consumers 

and businesses have been the ones to suffer with limited options- essentially travel to Washington 

Dulles, or the option of taking a one-stop connecting flight when traveling to downtown Washington 

D.C. 

When making this critical decision, I urge you to consider the positive impact of improving the 

connection between Washington D.C. and the Bay Area's powerful innovation-based economy. 

Allocation of two round-trip flights to Virgin America- our hometown carrier- will provide 

assurance that the Bay Area will finally have efficient, modern and low-fare nonstop flight service to 

DCA. It will also guarantee that local consumers and businesses reap the benefit that only real 

competition can provide. 

Since its August 20071aunch, Virgin America has lowered fares. and provided a unique new service 

option for local travelers. The Wall Street Journal went so far as to describe the low-fare airline's 

impact on fares as "the Virgin effect." 1 In addition, with fleetwide WiFi, power outlets, touch-screen 

entertainment and new aircraft, Virgin America's investment in its business-friendly product has 

offered an inventive new service option for tech-forward corporate travelers in the Bay Area. 

1 The Virgin Effect: Lower Cross-Country Fares," Wall Street Journal, October 30, 2007. 

235 Montgomery St., 12111 Fir., San Francisco, CA 94104 • tel 415 392 4520 I fax 415 392 0485 
When more airlines compete, consumers and regional economies win- with lower fares and 

improved service. The award of two roundtrip flights to Virgin America will ensure that local 

business travelers will benefit from real competition in the DCA market. On behalf of our region, Bay 

Area travelers and the business community, the San Francisco Chamber of Commerce urges you to 

approve Virgin America's proposal. 

Sincerely, 

Steve Falk 

President and CEO 

San Francisco Chamber of Commerce 

235 Montgomery St., 12"' Fir., San Francisco, CA 94104 • tel 415 392 4520 I fax 415 392 0485 
March 8, 2012 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Re: Docket No. OST-2012-0029, Application of Virgin America Inc. for "Beyond-Perimeter'' Slots 

Dear Secretary LaHood: 

On behalf of the Bay Area Council, I would like to express my strong support for Virgin America's proposal to 

provide two nonstop flights between San Francisco International Airport (SFO) and Reagan National Airport 

(DCA). As the only airline headquartered here in the Bay Area, Virgin America is uniquely suited to bring 

meaningful low-fare airline competition to the DCA-San Francisco routes. 

Historically, the Bay Area has been shut out of nonstop DCA service, with all previous flight awards being 

made to non-California airports (with the exception of a single daily Los Angeles flight). Prior DCA awards 

have been made to a number of smaller cities and markets, including Denver and Phoenix. Because SFO has 

been the largest market without nonstop flights to DCA, local consumers and businesses have been the ones 

to suffer from higher fares and limited options-essentially travel to Washington Dulles, or the option of 

taking a one-stop connecting flight when traveling to downtown Washington D.C. 

When making this critical decision, I urge you to consider the positive impact of improving the connection 

between Washington D.C. and the Bay Area's powerful innovation-based economy. Allocation of two roundtrip flights to Virgin America-our hometown carrier-will provide the Bay Area with efficient, modern and 

low-fare nonstop flight service to DCA. It will also guarantee that local consumers and businesses reap the 

benefit that only real competition can provide. 

Since its August 2007 launch, Virgin America's competitive leadership has lowered fares and provided a 

unique new service option for local travelers. The Wall Street Journal went so far as to describe the low-fare 

airline's impact on fares as "the Virgin effeCt." In addition, with fleetwide WiFi, power outlets, touch-screen 

entertainment and new aircraft, Virgin America's investment in its business-friendly product has offered an 

inventive new service option for tech-forward corporate travelers in the Bay Area. 

When more airlines compete, consumers and regional economies win, with lower fares and improved 

service. The award of two roundtrip flights to Virgin America will ensure that local business travelers will 

benefit from real competition in the DCA market. On behalf of our region, Bay Area travelers and the 

business community, I urge you to consider Virgin America's proposal. 

Sincerely, 

n~w~ 

JiUderman 

President and CEO 

P' ; l : 'i H. I r,(,~ O 

r : , ) :i 1 I) tn·J 
San ' rrancisco 

Travel· 

February 28, 2012 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Re: Docket No. OST-2012-0029, Application of Virgin America I,vc. for 

"Beyond-Perimeter" Slots 

Dear Secretary LaHood: 

On behalf of the San Francisco Travel A.'!Sociation (San Francisco Travel), I would like to express my 

strong support for Virgin America's proposal to provide two nonstop flights between San Francisco 

International Airpmi (SFO) and Reagan National Airport (DCA). As the San Francisco Bay Area's 

hometown carrier, Virgin America is uniquely suited to bring meaningful low-fare airline competition to 

the DCA-San Francisco Bay Area routes. 

Historically, the Bay Area has been excluded from enjoying nonstop DCA service, with all previous flight 

awards being made to non-California airports - with the exception of a single daily Los Angeles flight. 

Prior DCA awards have been made to a number of smaller travel markets, including Denver and 

Phoenix. Because the Bay Area is the largest market without nonstop flights between SFO and DCA, 

local travelers and Washington DC-based t1·avelers alike have suffered higher fares and limited options. 

Since its Augm;t 2007 launch, Virgin America has lowered fares and provided a unique new option for 

travelers in all the markets it serves. We have seen the impact on fares and stimulated travel demand 

firsthand here in the Bay Area. The Wall Street .Journal went so far as to describe the low-fare airline's 

impact on fares as "the Virgin effect." In addition, ·with fleetwide WiFi, power outlets, touch-screen 

entertainment and new aircraft, Virgin America's investment in its business-friendly product has 

offered an inventive new service option for travelers. As the only airline headquartered in California, 

Virgin America has also been a powerful economic driver for the region. The airline has grown to over 

2,.500 employees, with plans to add .500 new jobs on an annual basis over the next three to five years. 

When making this decision, San Francisco Travel urges you to consider the positive impact of 

improving travel options between Washington D.C. and our region. Allocation of two round-trip flights 

to Virgin America will provide assurance that we will finally have efficient, modern and low-fare 

nonstop flight service between the San Francisco Ray Area and the Washington DC metropolitan region. 

It will also help ensure San Francisco and Washington DC-bascd consumers and businesses reap the 

benefits that only real competition can provide. 

When more airlines compete, consumers and local economies win -~ with lower fares, more tourism. 

improved service and local job growth. The award of two roundtrip t1ights to Virgin America will ensure 

that consumers and tourism businesses can benefit from real competition in the SFO-DCA market. On 

behalf of our region, I urge you to eonsider Virgin America's proposal. 

Sincerely, 

t.!~ President & CEO 

1 fhe Virgin Effect: Lower Cross-Country Fares,'' Wall Street Journal, October 30, 2007. 

San Francisco Travclt\.sso.ciatton 

::01 'Third Sl, Str-~ 000 • ~·;nn frl-inu,;r_:(:, C/\ 04~01 • 
~r-~ SAMCEDA *•· ~ : -< .., San Mateo County Economic Development Association 

EXECUTIVE 

COMMITIEE 

Steve Mincey 

Chairman of the BOllrd 

DE'S Architects + Engineers. Inc. 

Elaine Breeze 

Pa!l Chailllllln of the Board 

Urban Housing Group 

Paul Casias 

Vice Chair ol Finance 

My·BuslnOSS·Adrisor UP 

JoAnn Kemisl 

VIce Cbalr 

Sequoia HospitalfCHW 

John Adams 

Vice Chair 

Wells Farco 

Todd Adair 

secretary 

BKF Engineers 

Rosanne Foust 

President & CEO 

SAMCEDA 

DIRECTORS 

Norman Book, Jr. 

carr. McClellan. Ingersoll, 

Thompson & Hom 

An<ly Coo 

Stanfold Hospltol & CUnics 

Jim Comstock, M.Ed. 

Seton Medk:al Cenler/Coe•tside 

Papia Gambelin 

Pacific Gas ond Electrlc Company 

John Hamlllton 

Embarcadero Cspllal Partners, UC 

Max Keech 

Keech Properties, LLC 

Rich lamb 

Wabcor Butlden 

Janine McCaffery 

Heffernan Insurance Brokers 

Sterhen J. Pilch 

Stockbridge Real Estate Funds 

E. Julian Potter 

San Francisco International Airport 

'llano Puccinelli 

Recology San Mateo County 

Randy Smith 

Oracle USA, Inc 

Robert Webster 

Bohannon Dl!'lelcpment Company 

Kenneth Young 

Equity Office Properties 

r. Jack Foster, Jr. 

Foster Enterprt.es 

Emeritus Advisor to the Chairman 

Paul Shepherd 

Cargill Salt 

En:erttus Advisor to the Chalrm811 

March 7, 2012 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Re: Docket No. OST-2012-0029, Application of Virgin America Inc. for "Beyond-Perimeter'' Slots 

Dear Secretary LaHood: 

On behalf of the San Mateo County Economic Development Association (SAMCEDA) I would 

like to express my strong support for Virgin America's proposal to provide two nonstop flights between 

San Francisco International Airport (SFO) and Reagan National Airport (DCA). As the only airline 

headquartered here in the Bay Area, Virgin America Is uniquely suited to bring meaningful low-fare 

airline competition to the DCA-San Francisco Bay Area routes. 

Historically, the Bay Area has been shut out of nonstop DCA service, with all previous flight 

awards being made to non-california airports - with the exception of a single daily Los Angeles flight 

Prior DCA awards have been made to a number of smaller cities and markets, including Denver and 

Phoenix. Because SFO has been by far the largest market without nonstop flights to DCA, local 

consumers and businesses have been the ones to suffer: with higher fares and limited options -

essentially travel to Washington Dulles, or the option of taking a one-stop connecting flight when 

traveling to downtown Washington D.C. 

When making this critical decision, I urge you to consider the positive impact of improving the 

connection between Washington D:C. and the Bay Area's Innovation-based economy. Allocation of two 

round-trip flights to Virgin America - our hometown carrier- will provide assurance that the Bay Area 

will finally have efficient, modern and low-fare nonstop flight service to DCA. It will also guarantee that 

local consumers and businesses reap the benefit that only real competition can provide. 

Since its August 2007 launch, VIrgin America has lowered fares and provided a unique new 

service option for local travelers. The Wall Street Journal went so far as to describe the low-fare 

airline's impact on fares as "the Virgin effect." 1 In addition, with fleetwide WIFi, power outlets, touchscreen entertainment and new aircraft, Virgin America's investment in its business-friendly product has 

offered an inventive new service option for tech-forward corporate travelers In the Bay Area. 

When more airlines compete, consumers and regional economies win- with lower fares and 

improved service. The award of two roundtrip flights to Virgin America will ensure that local business 

travelers will benefit from real competition in the DCA market. On behalf of our region, Bay Area 

travelers and the business community, I urge you to consider Virgin America's proposal. 

s;rw 

Rosanne Foust 

President & CEO 

1 The VIrgin Effect: Lower Cross-Country Fares," Wall Street Journal, October 30, 2007. 

1301 Shoreway Road, Suite 150 I Belmont, California 94002 I P 650.413.5600 I F 650.413.5909 I www.samceda.org 
March 14, 2012 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department ofTransportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

SAN MAT{O COUNTY "''"li_, ·rl"' 1'"' "'""-'-"Y r1-~ h--, ....... 

SILICON VALLEY 

The besr of J·he 

San Francisco Bay Area 

Re: Docket No. OST-2012-0029, Application of Virgin America Inc. 

for "Beyond-Perimeter" Slots 

Dear Secretary LaHood: 

On behalf of the San Mateo County/Silicon Valley Convention and 

Visitors Bureau, I would like to express my strong support for Virgin 

America's proposal to provide two nonstop flights between San 

Francisco International Airport (SFO) and Reagan National Airport 

(DCA). As the only airline headquartered here in the Silicon Valley, 

Virgin America is uniquely suited to bring meaningful low-fare airline 

competition to the DCA-San Francisco Bay Area routes. 

Historically, the Bay Area has been shut out of nonstop DCA service, 

with all previous flight awards being made to non-California airports -

with the exception of a single, daily Los Angeles flight. Prior DCA 

awards have been made to a nuinber of smaller cities and marketS, 

including Denver and Phoenix. Because SFO has been the largest 

market without nonstop flights to DCA, local consumers and 

businesses have been the ones to suffer - with higher fares and limited 

options. They must essentially travel to Washington Dulles, or take a 

one-stop connecting flight when traveling to downtown Washington 

D.C. 

When making this critical decision, I urge you to consider the positive 

impact of improving the connection between Washington D.C. and 

Silicon Valley's powerful innovation-based economy. Allocation of 

two round-trip flights to Virgin America- our hometown carrier- will 

provide assurance that the Bay Area will finally have efficient, modem 

and low-fare nonstop flight service to DCA. It will also guarantee that 

local consumers and businesses reap the benefit that only real 

competition can provide. 
-2-

Since its August 2007 launch, Virgin America has lowered fares and provided a unique new 

service option for local travelers. The Wall Street Journal went so far as to describe the low-fare 

airline's impact on fares as "the Virgin effect." In addition, with fleet wide WiFi, power outlets, 

touch-screen entertainment and new aircraft, Virgin America's investment in its businessfriendly product has offered an inventive new service option for tech-forward corporate travelers 

in the Bay Area 

When more airlines compete, consumers and regional economies win - with lower fares and 

improved service. The award of two roundtrip flights to Virgin America will ensure that local 

business travelers will benefit from real competition in the DCA market. On behalf of our 

region, Bay Area travelers and the business community, I urge you to consider Virgin America's 

proposal. 

Sincerely, 

{}i~~ 

Anne LeClair 

President & CEO 
The Honorable Raymond H. LaHood 

Secretary -

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

BURLINGAME 

CIJAJ\IBER 

Oft' 

COM~tERCE 

~ 

March 20, 2012 

Re: Docket No. OST -2012-0029, Application of Virgin America Inc. for "BeyondPerimeter" Slots 

Dear Secretary LaHood: 

On behalf of the Burlingame Chamber of Commerce, I would like to express my strong 

support for Virgin America's proposal to provide two nonstop flights between San Francisco 

International Airport (SFO) and Reagan National Airport (DCA). As the only airline headquartered 

here in the Bay Area, Virgin America is uniquely suited to bring meaningful low-fare airline 

competition to the DCA-San Francisco routes. 

Historically, the Bay Area has been shut out of nonstop DCA service, with all previous flight 

awards being made to non-California airports- with the exception of a single daily los Angeles flight. 

Prior DCA awards have been made to a number of smaller cities and markets, including Denver and 

Phoenix. Because SFO has been the largest market without nonstop flights to DCA, local consumers 

and businesses have been the ones to suffer: with higher fares and limited options- essentially 

travel to Washington Dulles, or the option of taking a one-stop connecting flight when traveling to 

downtown Washington D.C. 

· When making this critical decision, I urge you to consider the positive impact of improving 

the connection between Washington D.C. and the Bay Area's powerful innovation-based economy. 

Allocation of two round-trip flights to Virgin America- our hometown carrier- will provide 

assurance that the Bay Area will finally have efficient, modern and low-fare nonstop flight service to 

DCA. It will also guarantee that local consumers and businesses reap the benefit that only real 

competition can provide. 

Since its August 2007 launch, Virgin America has lowered fares and provided a unique new 

service option for local travelers. The Wall Street Journal went so far as to describe the low-fare 

airline's impact on fares as "the Virgin effect." 1 In addition, with fleetwide WiFi, power outlets, 

touch-screen entertainment and new aircraft, Virgin America's investment in its business-friendly 

product has offered an inventive new service option for tech-forward corporate travelers in the Bay 

Area. 
When more airlines compete, consumers and regional economies win- with lower fares and 

improved service. The award of two roundtrip flights to Virgin America will ensure that local 

business travelers will benefit from real competition in the DCA market. On behalf of our region, Bay 

Area travelers and the business community, I urge you to consider Virgin America's proposal. 

Sincerely, 

~-Wdty John Delaney 

President, Burlingame Chamber Board of Directors 

BURLINGAME IS OUR BUSINESS! 

417 California Drive * Burlingame, CA. * 94010 

650-344-1735 * info@burlingamechamber.org Email: 

www.burlingamecbamber.org 
March 13, 2012 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, DC 20590 

Levi Strauss & Co. 

1155 Battery Street 

San Franc isco, CA 94111 

levistrauss.com 

Re: Docket No. OST -2012-0029, Application of Virgin America Inc. for "BeyondPerimeter'' Slots 

Dear Secretary LaHood: 

I am writing on behalf of Levi Strauss & Co. to express our support for Virgin America's proposal 

to provide nonstop service between San Francisco International Airport (SFO) and Reagan 

National Airport (DCA). We believe that Virgin America is well-positioned to offer competitive 

service on the DCA-San Francisco routes. 

Flight service to DCA has to date not been offered in the Bay Area. Prior DCA flights have been 

awarded to a number of smaller cities and markets, including Denver and Phoenix. Because 

SFO is the largest market without nonstop flights to DCA, local consumers and businesses have 

incurred higher fares and more limited options for travel to our nation's capitol. Bay Area 

residents and businesses have been required to travel to Washington Dulles, or take a one-stop 

connecting flight to downtown Washington DC. This has cost our company executives time and 

resulted in higher costs. 

As you decide on whether to approve this route, please consider the positive impact on the 

dynamic businesses in the Bay Area that would benefit from your decision. Allocation of Virgin 

America flights between SFA and DCA will provide assurance that the Bay Area will have 

efficient, modern and low-fare nonstop flight service to our nation's capital. 

Levi Strauss & Co. is hopeful that you will give full consideration to Virgin America's proposal 

and grant approval for this new route. You may contact me at 415-501-3974 if you have any 

questions about our company's interest in this matter. 

Sincerely, 

fW i'f- 'if ;yHelga Ying · 

Senior Director, Worldwide Government Affairs and Public Policy 

L<Ovrs• 

;:- · :-:. ---:-:-: ,-;---.--:--:.:--..-------------- --: ~-~ ~-- --~- 7- -----r------:--:-.-:-----;--:7 ;-- --~ ---i -:----:--.• --~-:- ------------------.--- ~~-· ,'.. ':'• J·> :·.; :, ".'~:.~~··. ; . . .· . . . ': : ; it~·. : ..... ~~ ... ;(,. : :' (. · ... ~. It-:' . LE1fiSTRAUSS'tl: CO!;, 
lJ UnionBank 

March 9, 2012 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Julius E. Robinson 

Executive Vice President/Group Head 

RE: Docket No. OST-2012-0029, Application of VIrgin America Inc. for "Beyond-Perimeter" Slots 

Dear Secretary LaHood, 

On behalf of Union Bank, I am writing to strongly support Virgin America's bid for a two nonstop flights 

between Ronald Reagan Washington National Airport (DCA) to San Francisco International Airport (SFO) 

pursuant to the Federal Aviation Administration Modernization and Reform Act of 2012. 

Headquartered in San Francisco, Union Bank, N.A. is a subsidiary of UnionBankCal Corporation and is a 

full-service commercial bank providing an array of financial services to individuals, small businesses, 

middle-market companies, and major corporations. The bank operates 414 branches in California, 

Washington, Oregon, Texas and New York, as well as two international offices, on December 31, 2011. 

As a member of Silicon Valley's business community, I urge you to consider the positive impact of 

improving our connections to the capital. Historically, the Bay Area has been the largest "beyond 

perimeter" market without nonstop flights to DCA. As a result, businesses like ours have suffered with 

higher fares and limited travel options such as flying into Washington Dulles, 26 miles from the city 

center or utilizing one stop connecting flights. 

We conduct extensive business in the Washington area, representing 20 trips per month. The presence 

of two additional nonstop flights would provide us with a far better range of choices when traveling to 

downtown Washington, and can help reduce ticket prices. Allowing more airlines to compete can 

ensure a net win for our travel departments, the business community, and Bay Area travelers. 

For these reasons we support Virgin America's bid for two nonstop flights from DCA to SFO. 

Sincerely, 

Corporate Social Responsibility 

400 California Street, 9'" Floor 

San Francisco, CA 94104 

A member of MUFG, a global financial group 

Tel. 415 765 3883 

Fax. 415 765 4256 

email: julius.robinson@.lm!..Onbank_±om 
ORACLE' 

March 8, 2012 

The Honorable Raymond H. LaHood 

Secretary 

U .5. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

Re: Docket No. OST-2012-0029, Application of Virgin America Inc. for "Beyond-Perimeter" Slots 

Dear Secretary LaHood: 

On behalf of Oracle I would like to express my strong support for Virgin America's proposal to provide two 

nonstop flights between San Francisco International Airport (SFO) and Reagan National Airport (DCA). As the only 

airline headquartered here in the Bay Area, Virgin America is uniquely suited to bring meaningful low-fare airline 

competition to the DCA-San Francisco routes. 

Historically, the Bay Area has been shut out of nonstop DCA service, with all previous flight awards being made to 

non-California airports (with the exception of a single daily Los Angeles flight). Prior DCA awards have been made 

to a number of smaller cities and markets, including Denver and Phoenix. Because SFO has been the largest 

market without nonstop flights to DCA, local consumers and businesses have been the ones to suffer frbm higher 

fares and limited options-essentially travel to Washington Dulles, or the option of taking a one-stop connecting 

flight when traveling to downtown Washington D.C. 

When making this critical decision, I urge you to consider the positive impact of improving the connection 

between Washington D.C. and the Bay Area's powerful innovation-based economy. Allocation of two round-trip 

flights to Virgin America-our hometown carrier-will provide assurance that the Bay Area will finally have 

efficient, modern and low-fare nonstop flight service to DCA. It will also guarantee that local consumers and 

businesses reap the benefit that only real competition can provide. 

Since its August 2007 launch, Virgin America's competitive leadership has lowered fares and provided a unique 

new service option for local travelers. The Wall Street Journal went so far as to describe the low-fare airline's 

impact on fares as "the Virgin effect." In addition, with fleetwide WiFi, power outlets, touch-screen 

entertainment and new aircraft, Virgin America's investment in its business-friendly product has offered an 

inventive new service option for tech-forward corporate travelers in the Bay Area. 

When more airlines compete, consumers and regional economies win, with lower fares and improved service. 

The award of two roundtrip flights to Virgin America will ensure that local business travelers will benefit from real 

competition in the DCA market. On behalf of our region, Bay Area travelers and the business community, I urge 

you to consider Virgin America's proposal. 

;a::)d~ Daniel Mason 

Oracle Corporate Travel Department 
March 9, 2012 

The Honorable Raymond H. LaHood 

Secretary 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, D.C. 20590 

RE: Docket No. OST-2012-0029, Application of Virgin America Inc. for "BeyondPerimeter" Slots 

Dear Secretary LaHood: 

As Senior Director of Government Affairs for Electronic Arts, I see great value in Virgin 

America's application to provide additional direct flights between San Francisco and 

Washington, DC. I, as well as other members of the Government Affairs team, travel 

often to the DC area to work on public policy for our industry both with the 

administration and members of Congress. We do·so in coordination with the 

Entertainment Software Association, of which our CEO is the Chairman of the Board of 

Directors. The ESA is headquartered in Washington DC. 

Additionally, our EA Mythic Studio is located directly outside Washington DC. A direct 

flight from SFO to DCA would be incredibly helpful for our development, operations, 

facilities, and human resources staff that travel to and from this studio frequently. 

EA strongly supports Virgin America's application to provide additional direct flights 

from San Francisco to Washington, DC. lfi can be of further assistance please do not 

hesitate to contact me. 

Sincer~ly, 

Craig ~~de"~ Hagen' (j 

Senior Director of Government Affairs 

Electronic Arts Inc 

209 Redwood Shores Parkway 

Redwood City, CA 94065