BEFORE THE

OFFICE OF THE SECRETARY

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_____________________________________

)

Application of )

)

AIRTRAN AIRWAYS, INC. )

) Docket No. DOT-OST-2011-0225

for an exemption under 49 U.S.C § 40109 )

) 

(Chicago (Midway), Illinois - Cancun, Mexico) )

_____________________________________ )

_____________________________________

)

Application of )

)

FRONTIER AIRLINES, INC. ) Docket No. DOT-OST-2011-0214

)

for an exemption under 49 U.S.C. § 40109 )

)

(Chicago (O‟Hare), Illinois - Cancun, Mexico) )

_____________________________________ )

REPLY OF AIRTRAN AIRWAYS, INC. 

Communications with respect to this document should be sent to:

Bob Jordan Robert W. Kneisley

 President Associate General Counsel

AIRTRAN AIRWAYS, INC. Leslie C. Abbott

9955 AirTran Boulevard Senior Attorney

Orlando, FL 32827 SOUTHWEST AIRLINES CO.

 1901 L Street, N.W., Suite 640

Washington, D.C. 20036 

 bob.kneisley@wnco.com

(202) 263-6284

December 22, 2011
2

BEFORE THE

OFFICE OF THE SECRETARY

DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

_____________________________________

)

Application of )

)

AIRTRAN AIRWAYS, INC. )

) Docket No. DOT-OST-2011-0225

for an exemption under 49 U.S.C § 40109 )

) 

(Chicago (Midway), Illinois - Cancun, Mexico) )

_____________________________________ )

_____________________________________

)

Application of )

)

FRONTIER AIRLINES, INC. ) Docket No. DOT-OST-2011-0214

)

for an exemption under 49 U.S.C. § 40109 )

)

(Chicago (O‟Hare), Illinois - Cancun, Mexico) )

_____________________________________ )

REPLY OF AIRTRAN AIRWAYS, INC. 

AirTran Airways, Inc. (AirTran) files this Reply in response to the December 15, 

2011 Answer filed by Frontier Airlines (Frontier) to AirTran‟s Application for exemption 

authority to serve the Chicago (Midway) – Cancun, Mexico market.1

BACKGROUND

Spurred by the recent announcement of USA3000 that it intends to terminate 

service in the Chicago – Cancun market at the end of January 2012, AirTran and 

Frontier have both filed applications to assume the one U.S. carrier designation that will 

become available in that market by virtue of USA3000‟s withdrawal. AirTran‟s 

 

1

Common names of airlines are used herein.
3

application seeks authority to serve Cancun from Chicago Midway Airport (MDW) while 

Frontier proposes to fly from Chicago O‟Hare Airport (ORD). Frontier‟s December 15 

answer to AirTran‟s application contains numerous misleading and inaccurate 

statements, and AirTran files this Reply in order to correct the record and provide a 

more accurate basis for the Department‟s decision on the competing applications. 

Notwithstanding the predictable hyperbole in Frontier‟s answer, the facts show 

overwhelmingly that AirTran would provide far greater public benefits than Frontier in 

the Chicago – Cancun market:

AirTran and Southwest Airlines combined have a huge 220-flight-per-day 

network at Midway to support Cancun service, while Frontier has zero flights at 

O-Hare to support its Cancun proposal.

AirTran would provide the first competitive Cancun service at MDW, which 

serves the entire Chicago region but is particularly convenient to South Side 

residents. Frontier would provide redundant service at ORD on top of the many 

Cancun flights operated at ORD by both U.S. and foreign carriers.

AirTran would provide year-round daily service between Chicago and Cancun. 

Frontier would offer daily service only 19 weeks of the year.

AirTran/Southwest‟s massive presence in the Chicago market ensures that its 

Cancun service will be stable, competitive, and successful. Frontier would be 

dependent on a single customer (Apple Vacations), with significant seasonality 

variations and contractual risks that threaten its viability.

There is no need to waste a valuable U.S. designation on Frontier‟s proposal 

since Frontier can serve Apple via charter authority that is fully available under 

U.S. – Mexico bilateral agreement. Awarding Frontier the single available U.S. 

carrier scheduled designation would block AirTran/Southwest, and Midway

Airport, from the Chicago – Cancun market. 

Frontier‟s answer contains numerous exaggerations, distractions, and distortions,

but does not overcome any of these basic facts. 
4

I. FRONTIER’S DESCRIPTION OF THE CHICAGO – CANCUN 

MARKET IS MISLEADING AND DISPROVEN BY THE FACTS. 

Frontier‟s Answer claims that “O‟Hare-Cancun demand is 30 times larger than 

that in the tiny Midway-Cancun market,”

2

implying that only ORD can support nonstop 

service to Cancun. However, the recorded Chicago –Cancun O&D is much greater at 

ORD simply because ORD has far better service to Cancun today than does MDW. As 

attached Exhibit FL- R-101 demonstrates, ORD has six nonstop flights per day while 

MDW has none, and ORD has 35 daily connecting flights compared to only seven at 

MDW. In fact, the best roundtrip (nonstop) service to Cancun offered at ORD has an 

elapsed time under 7.5 hours, compared to more than 12 hours for the best 

(connecting) service at MDW. Therefore it is not at all surprising that the O&D traffic to 

Cancun at ORD is much greater than that at MDW.

Frontier‟s claim therefore proves nothing about consumer preference for ORD vs. 

MDW. It simply reflects the reality that passengers prefer nonstop service over 

connections, and all nonstop Chicago – Cancun service today is provided at ORD while 

MDW offers only inconvenient connections.3 Moreover, far from demonstrating ORD‟s 

“superiority” in serving Cancun, as Frontier would have the Department believe, the 

current O&D data illustrate an urgent need for establishing competitive Cancun service 

at MDW and restoring a balance of service within the Chicago region. 

In fact, MDW is the airport preferred by a large segment of Chicago passengers. 

As shown in Exhibit FL-R-102, in large domestic markets with comparable nonstop 

 

2

Frontier Answer at 2. 

3

As Frontier itself notes, “all U.S. flag service to the Mexican beach destinations is operated from O‟Hare” (Answer at 

5). In fact, the concentration of Mexico service at ORD will be even greater once Aeromexico launches its recentlyannounced ORD-CUN service. See Notice of Action Taken in Docket DOT-OST-2011-0231, December 20,2011 

(counsel for Aeromexico has confirmed the carrier‟s intent to serve ORD). 
5

service, MDW and ORD originate virtually identical volumes of passengers. In addition, 

as shown in Exhibit FL-R-111, the population within a 60-minute drive of MDW is 94% 

of the population within a 60-minute drive of ORD. Thus, MDW is unquestionably a 

convenient airport for the vast majority of Chicago-area passengers. Yet Frontier would 

have the Department believe that all demand is for ORD service, and that an award to 

AirTran/Southwest for its MDW service proposal would be wasted. 

The history of competition between air services provided at ORD vs. MDW also 

illustrates the fallacy of Frontier‟s argument. For example, before Southwest entered 

the MDW–IAD market, O&D passengers in the ORD-IAD market were 41 times greater 

than MDW-IAD O&D passengers (Exh. FL-R-104). Currently, however, MDW-IAD 

passenger volume is 22% greater than ORD-IAD - notwithstanding the fact that United 

has major hubs at both ORD and IAD. Similarly, prior to Southwest‟s entry into the 

Chicago – Buffalo market, the ORD-BUF O&D volume was 34 times greater than that of 

MDW-BUF (Exh. FL-R-105). Today, the MDW-BUF passenger volume is 73% the size 

of the ORD-BUF (Id.).

In addition, Frontier‟s claim that only its proposed ORD–CUN service will provide 

“head to head competition” (Answer at 2) with the network carriers currently serving 

ORD demonstrates a profound lack of understanding of the Chicago aviation market. 

Southwest‟s entry into numerous Chicago markets over the years has vividly 

demonstrated the strong competitive inter-relationship between ORD and MDW within 

the Chicago region. For example, Southwest‟s low-fare entry into the MDW-MSP 

market in March 2009 reduced fares over 40% at both MDW and ORD, while 

stimulating total CHI-MSP traffic by 18% (Exh. FL-R-106). Similarly, Southwest‟s entry 
6

into the MDW-LGA market in June 2009 reduced fares at both MDW and ORD by 

approximately 20%, and stimulated new traffic at both MDW and ORD (Exh. FL-R-107). 

These are just two examples of a pattern that has been repeated many times, as 

Southwest‟s expansion into numerous MDW markets forced fares to decline, and traffic 

to expand, at both ORD and MDW. This pattern demonstrates convincingly that ORD is 

not a market unto itself, as Frontier argues, but is part of a broader Chicago market in 

which the air services at both MDW and ORD compete strongly and continuously with 

one another for passengers. The fact that the U.S. – Mexico bilateral designates 

Chicago as a single market encompassing both ORD and MDW underscores this point. 

AirTran/Southwest‟s service in MDW-Cancun service will compete vigorously with ORDCancun services, and will force competitive responses from the ORD carriers as a 

result. Daily year-round service by AirTran/Southwest will also redress the current 

imbalance of Cancun traffic between Chicago‟s two airports and will generate a 

distribution similar to that experienced in competitive domestic markets served by both 

MDW and ORD. 

II. AIRTRAN WOULD BE A TRUE NEW ENTRANT IN THE MARKET

AND PROVIDE MUCH MORE EFFECTIVE COMPETITION THAN 

FRONTIER. 

Frontier‟s application is replete with statements that it would be a “new entrant” in 

the CHI-CUN market and as such would provide a low-fare alternative at ORD. Upon 

scrutiny, however, these claims have no merit. To begin with, Frontier does not 

disclose its proposed fares, nor does it compare its fares to those of United and 

American in the ORD-CUN market. In actuality, Frontier„s fares would be a bulk 

contract price negotiated with Apple Vacations; Frontier would not determine the seat 
7

price to the passengers for most if not all of its passengers. There is no evidence 

whatever that Frontier would provide price competition with the ORD-CUN incumbents.

Beyond this, while Frontier attempts to promote itself as a new entrant, it also 

makes clear that it will step into the shoes of the current service provider for Apple 

Vacations, USA3000.4 Thus, by its own admission, Frontier‟s service would be a 

continuation of existing vacation package contract lift at ORD, which has not provided 

vigorous low-fare competition with incumbent ORD-CUN carriers in the past. In 

contrast, AirTran would be a true new entrant in the Chicago–CUN market providing 

service from the Chicago airport currently without any nonstop Cancun flights. In recent 

proceedings, the Department has recognized that low fare carriers need a critical mass 

of service to provide effective competition, particularly when competing against with 

dominant legacy carriers.5 With its extensive network of connections at MDW, 

AirTran/Southwest is heavily committed to Chicago and has the large market presence 

to ensure its MDW-CUN service is a success.6 

In fact, AirTran and Southwest together serve 27 cities with less than 40% 

circuity from MDW that would provide additional passenger support for service to 

Cancun (Exhibit FL-R-109). Frontier, by contrast, has exactly zero connections at ORD 

to support its proposed ORD-Cancun service (Exhibit F-R-110). Lacking such support, 

Frontier has advanced a self-serving description of Chicago-Cancun as “primarily a 

local O&D market” (Answer at 8). But this characterization would apply to Frontier only

 

4

Frontier states that it has entered into an agreement with Apple “to replace Apple Vacations’ current allocation 

of seats on USA3000’s flights” and will “ensure Apple Vacations’ customers a seamless transition from USA3000’s 

service without disruption...” Frontier Application at 2-3.

5

See, e.g, Notice of grant of petition with conditions (US/DL Slot Swap), affirming 8 slot pair bundles based on 

DOT/FAA’s finding that “there is likely to be greater overall public benefit if the larger (i.e., 8 slot pair) bundles are 

retained” whereas “...smaller bundles of slots ...could make certain new entrants highly vulnerable... and frustrate 

the competitive responsiveness we are seeking.” 76 Fed. Reg. 63702, 63708 (Oct. 13, 2011). 
8

because it has no connecting support, and not to other U.S. carriers serving the market 

which rely heavily on connections: 53% of United‟s ORD-CUN passengers are 

connecting, and 25% of American‟s ORD-CUN passengers are connecting, while 

USA3000 (into whose shoes Frontier wishes to step) has zero connecting passengers. 

In addition, 43% of Southwest‟s passengers at MDW are connecting.

Thus, Frontier‟s description of the Chicago-Cancun market as “primarily local 

O&D” simply reflects that carrier‟s own lack of network support and exposes a serious 

weakness in its proposal. Without passenger support from behind-ORD destinations, 

Frontier cannot hope to provide daily service outside of the peak season, and its 

proposal for daily flights in only 41⁄2 months of the year reflects that fact. 

AirTran/Southwest, on the other hand, can support at least daily service all year-round 

in MDW-CUN due to its extensive network at MDW and large numbers of connections 

to behind-gateway cities.7 

III. FAR FROM A “PROVEN TRACK RECORD,” FRONTIER HAS 

TERMINATED OVER HALF ITS MEXICO ROUTES AND DOES NOT 

PROVIDE DAILY SERVICE IN ANY OF THOSE THAT REMAIN.

Frontier first began serving Mexico from its Denver hub in 2003. In 2004 it began 

a long series of experiments with 21 other Mexico routes. Frontier has since 

abandoned 13 of those routes (Exhibit FL-R-108). Moreover, in all eight of its remaining 

Mexico markets, Frontier provides less than daily year-round service (Id.). This is 

Frontier‟s “proven track record” (see Frontier Answer at 2). Frontier‟s history of 

 

7

Frontier notes that AirTran provides less-than-daily service in the BWI-CUN market for two months of the year 

(September and October). That level of service reflects the relatively limited connecting support that AirTran has at 

BWI standing alone, however. As Southwest and AirTran schedules are integrated, service levels will increase to at 

least daily year-round. In September 2012, for example, AirTran will offer daily service plus two flights on Saturdays 

in this market and in October 2012 will offer 12 weekly flights.
9

unreliable service to Mexico should not be rewarded with the grant of yet another 

limited-entry route award. That is especially true in this case, where Frontier has no

existing service at its proposed gateway and no passenger feed at ORD, and stakes the 

entire success of its service on one customer (Apple Vacations), which would be in a 

position to drive any price bargain that could easily cause Frontier to abandon yet 

another Mexico route. 

With no connecting market support at ORD, and very little market identification in 

all of Chicago, it is clear that Frontier would be a very weak competitor in the ORD-CUN 

market. To survive it must have the Apple Vacations contract which could easily be 

served by charter authority. For all these reasons the Department should not squander

limited entry authority on Frontier and block AirTran/Southwest (and Midway Airport) 

from the market by doing so.

IV. DESPITE CLAIMS TO THE CONTRARY, FRONTIER’S BUSINESS 

INTEREST IN THE CHICAGO-CANCUN MARKET CAN BE WELLSERVED WITH CHARTER AUTHORITY.

Despite belated protestations that it requires scheduled authority, Frontier has 

offered no evidence that it would generate a single individually ticketed passenger on its 

ORD-CUN flights. Instead, the only passengers Frontier credibly asserts it will carry are 

those provided via a single contract with Apple Vacations. Because Apple will control 

the marketing and distribution as well as much if not all of the schedule, Frontier can

supply this contractual lift via charter service that is permitted under the U.S.-Mexico 

bilateral agreement. 

Therefore, as we noted previously, the competing applications of 

AirTran/Southwest and Frontier present the Department with a “win-win” opportunity. 
10

Awarding scheduled authority to AirTran/Southwest would provide reliable and 

competitive year-round daily service at Midway Airport, while allowing Apple Vacations‟

customers to continue to avail themselves of travel packages with the air portion 

operated by Frontier at ORD, alongside the services of both United and American. 

AirTran/Southwest would compete at MDW against the scheduled services of United 

and American, as well as the charter services by Frontier at ORD, allowing four U.S. 

carriers to share and compete in this important aviation market. 

CONCLUSION

For the reasons given above and in our prior pleadings, we urge the Department 

to grant AirTran‟s application for MDW-Cancun exemption authority, and to designate 

AirTran for such service under the U.S.-Mexico Agreement. 

Respectfully submitted,

____________________

Robert W. Kneisley

December 22, 2011
CERTIFICATE OF SERVICE

I hereby certify that on December 22, 2011, a copy of the foregoing was served 

via e-mail on the following persons:

msinick@ssd.com (Alaska Airlines)

carl.nelson@aa.com (American Airlines)

sascha.vanderbellen@delta.com (Delta Air Lines)

jeff.morgan@delta.com (Delta Air Lines) 

robert.cohn@hoganlovells.com (Frontier Airlines)

patrick.rizzi@hoganlovells.com (Frontier Airlines

jhill@dowlohnes.com (JetBlue Airways)

dkirstein@yklaw.com (Spirit Airlines)

jyoung@yklaw.com (Spirit Airlines)

John.Fredericksen@suncountry.com (Sun Country Airlines)

dan.weiss@united.com (United Air Lines)

howard_kass@usairways.com (US Airways)

pmurphy@lopmurphy.com (USA3000)

barbara.russell@virginamerica.com (Virgin America)

susan.kurland@dot.gov

paul.gretch@dot.gov

brian.hedberg@dot.gov

brett.kruger@dot.gov

todd.homan@dot.gov

esta.rosenberg@dot.gov

john.allen@faa.gov 

ursk@dos.gov

Rosemarie S. Andolino

Commissioner

City of Chicago Department of Aviation

rosemarie.sandolino@cityofchicago.org

Erin O’Donnell

Managing Deputy Commissioner 

City of Chicago Department of Aviation, Midway Airport

Erin@cityofchicago.org

__________________________

Leslie C. Abbott
Recorded O&D Traffic to Cancun is Much Higher at ORD than MDW 

Because ORD Has Much Better Service to Cancun than MDW

6

0

0

1

2

3

4

5

6

Exhibit FL-R-101

35

7

0

5

10

15

20

25

30

35

40

Nonstop Flights Connecting Flights

Note: Includes only intra-alliance connections and uses a minimum connect time of 1 hour and a maximum connect time of 3 hours.

Source: Official Airline Guide schedules for December 17, 2011.

ORD MDW ORD MDW

Best ORD-CUN Roundtrip Elapsed Time = 7:25 

Best MDW-CUN Roundtrip Elapsed Time =12:07 

Daily Roundtrip

Nonstops

Average Daily Online 

Roundtrip Connections 
In Large Markets With Similar Nonstop Service MDW Originates 

99.4% As Many Chicago Passengers As ORD

1,620,592 1,630,918

0

500,000

1,000,000

1,500,000

2,000,000

Domestic Chicago Originating O&D Passengers

Exhibit FL-R-102

MDW ORD

Average Daily

Departures per Market 5.8 6.5

Note: Includes all markets that had 3 or more roundtrip daily nonstops from both MDW and ORD and had similar total departures (plus or minus 2).

Source: DOT, Origin-Destination Passenger Survey, YE Q2 2011; Official Airline Guide, schedules for YE Q2 2011.
The AirTran/Southwest Proposal Would Bring First Competitive Service to MDW 

While Frontier Could Easily Serve Apple Vacations with Charter Authority

462

430

322

365

0

20

40

60

80

100

120

140

160

180

200

220

240

260

280

300

320

340

360

380

400

420

440

460

480

AirTran/Southwest Proposal

Exhibit FL-R-103

AA

Annual 

Roundtrips

UA F9 FL/WN

ORD Service

MDW 

Service

462

430

322

0

20

40

60

80

100

120

140

160

180

200

220

240

260

280

300

320

340

360

380

400

420

440

460

480

Frontier Proposal

AA UA F9 FL/WN

ORD Service

MDW 

Service

C

H

A

R

T

E

R

Annual 

Roundtrips

Source: F9 frequencies calculated from page 7 of Frontier’s Reply and Answer. AA and UA frequencies from OAG, YE Q2 2012. 

NONE
Before Southwest Served MDW-IAD the ORD Originating Passengers

Were 41 Times the MDW Originating Passengers But 

Today MDW is 22% Larger than ORD Traffic

2,893

117,809

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

90,000

100,000

110,000

120,000

41 Times

IAD Chicago 

Originating O&D Passengers

2003

Exhibit FL-R-104

MDW ORD

109,693

89,555

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

90,000

100,000

110,000

120,000

MDW= 

1.22 Times

ORD

MDW ORD

IAD Chicago 

Originating O&D Passengers

YE Q2 2011

Source: DOT, Origin-Destination Passenger Survey.
Before Southwest Served MDW-BUF the ORD Originating Passengers

Were 34 Times the MDW Originating Passengers But

Today MDW is 73% the Size of ORD Traffic

1,437

48,912

0

10,000

20,000

30,000

40,000

50,000

34 Times

BUF Chicago 

Originating O&D Passengers

2003

Exhibit FL-R-105

MDW ORD 49,044

67,254

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

MDW =

0.73 x

ORD

MDW ORD

BUF Chicago 

Originating O&D Passengers

YE Q2 2011

Source: DOT, Origin-Destination Passenger Survey.
Southwest’s Entry in MDW-MSP Stimulated Total Chicago

Traffic And Lowered Fares at Both ORD and MDW

$136

$79

$87

$159

$0

$10

$20

$30

$40

$50

$60

$70

$80

$90

$100

$110

$120

$130

$140

$150

$160

$170

Exhibit FL-R-106

Before 

WN

Nonstop

ORD

Note: Before Period = CY 2008. After Period = YE Q1 2010.

Source: DOT, Origin-Destination Passenger Survey.

MDW

Average Fare

After 

WN

Nonstop

Before 

WN

Nonstop

After 

WN

Nonstop

268,610

488,340

654,955

701,968

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

400,000

450,000

500,000

550,000

600,000

650,000

700,000

750,000

800,000

Before 

WN

Nonstop

MDW ORD

O&D Passengers

After 

WN

Nonstop

Before 

WN

Nonstop

After 

WN

Nonstop
Southwest’s Entry in MDW-LGA Stimulated Total Chicago Traffic 

And Lowered Fares at Both ORD and MDW

$142

$110

$129

$154

$50

$60

$70

$80

$90

$100

$110

$120

$130

$140

$150

$160

Exhibit FL-R-107

Before 

WN

Nonstop

ORD

Note: Before Period = YE Q2 2009. After Period = YE Q2 2010.

Source: DOT, Origin-Destination Passenger Survey.

MDW

Average Fare

After 

WN

Nonstop

Before 

WN

Nonstop

After 

WN

Nonstop

172,230

435,120

1,535,678

1,326,139

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

800,000

900,000

1,000,000

1,100,000

1,200,000

1,300,000

1,400,000

1,500,000

1,600,000

Before 

WN

Nonstop

MDW ORD

O&D Passengers

After 

WN

Nonstop

Before 

WN

Nonstop

After 

WN

Nonstop

$0
Frontier Has Abandoned 13 of 21 Mexico Routes

It Started Since 2004 and Doesn’t Provide 

Daily Year-Round Service in Any of the Remaining Markets

Source: Official Airline Guide schedules for Frontier from January 2004 to June 2012.

Exhibit FL-R-108

Market Start Date End Date Total Months Category

1 ABQ-PVR December 2007 May 2008 6 Dropped

2 AUS-CUN November 2004 March 2005 5 Dropped

3 BNA-CUN November 2004 June 2008 41 Dropped

4 DEN-ACA December 2005 April 2007 11 Dropped

5 DEN-GDL December 2006 January 2008 14 Dropped

6 DFW-MZT June 2007 April 2008 10 Dropped

7 LAX-SJD December 2006 April 2008 17 Dropped

8 SAN-CUN December 2006 August 2007 9 Dropped

9 SJC-PVR December 2007 January 2008 2 Dropped

10 SJC-SJD March 2007 January 2008 11 Dropped

11 SMF-PVR December 2007 December 2007 1 Dropped

12 SMF-SJD March 2007 January 2008 11 Dropped

13 STL-PVR December 2010 April 2011 5 Dropped

14 DEN-CZM 61 Not Daily Year-Round

15 IND-CUN 44 Not Daily Year-Round

16 MCI-CUN 89 Not Daily Year-Round

17 MCI-PVR 50 Not Daily Year-Round

18 MCI-SJD 21 Not Daily Year-Round

19 MKE-CUN 15 Not Daily Year-Round

20 SLC-CUN 78 Not Daily Year-Round

21 STL-CUN 45 Not Daily Year-Round
SFO OAK

SJC

PVD ISP

LGA EWR

MHT

CUN

MDW

DEN

MCI

SMF STL

SLC

RNO

BDL

BOS

PIT

CMH

ALB

OMA

IND

CLE

PDX

BUF

SEA

DTW

MSP

AirTran/Southwest Would Connect 27 Markets 

At MDW With Less Than 40% Circuity

Current FL/WN Markets

Proposed FL/WN Market

Current FL/WN Service (<40% Circuity)

Destinations 27

Weekly Departures 776

Weekly Seat Departures 105,292

Source: OAG schedule for the week of November 14, 2011.

Exhibit FL-R-109
Frontier Would Not Connect Any Markets at ORD 

to Support Its Proposed Cancun Service

Current Frontier Market

Proposed Frontier Market

Current Frontier MDW Capacity

Destinations 1

Weekly Departures 23

Weekly Seat Departures 2,994

Source: OAG schedule for the week of November 14, 2011.

Exhibit FL-R-110

CUN

ORD

MDW

DEN
The MDW Population within a 60 minute Drive is 94% 

of the ORD Population within a 60 minute Drive

Source: Targetpro. 

Exhibit FL-R-111

MDW

MDW

60 Minute Drive

ORD

60 Minute Drive

ORD

MDW

MDW % of ORD

= 100 residents

ORD

8.8 million

8.3 million

94%

Population

Within 60 Minutes