BEFORE THE

OFFICE OF THE SECRETARY

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON D.C.

_____________________________________

)

2012 CHICAGO - CANCUN ) Docket DOT-OST-2012-0001

COMBINATION SERVICE PROCEEDING )

_____________________________________ )

_____________________________________

)

Applications of )

) 

 AIRTRAN AIRWAYS, INC ) Docket DOT-OST-2011-0225

 )

 FRONTIER AIRLINES, INC. ) Docket DOT-OST-2011-0214

)

For an exemption pursuant to )

49 U.S.C. § 40109 ) 

_____________________________________ )

SUPPLEMENT TO APPLICATION 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

January 19, 2012
1

BEFORE THE 

OFFICE OF THE SECRETARY

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON D.C.

_____________________________________

)

2012 CHICAGO - CANCUN ) Docket DOT-OST-2012-0001

COMBINATION SERVICE PROCEEDING )

_____________________________________ )

_____________________________________

)

Applications of )

) 

AIRTRAN AIRWAYS, INC ) Docket DOT-OST-2011-0225

 )

 FRONTIER AIRLINES, INC. ) Docket DOT-OST-2011-0214

)

For an exemption pursuant to )

49 U.S.C. § 40109 ) 

_____________________________________ )

SUPPLEMENT TO APPLICATION OF AIRTRAN AIRWAYS, INC.

On January 9, 2012, the Department of Transportation (“Department” or “DOT”) 

issued Order 2012-1-4 establishing this proceeding to select one carrier to provide 

direct carrier (own-aircraft), scheduled combination air services between Chicago, 

Illinois, and Cancun, Mexico. The third and last designation under the U.S.-Mexico 

bilateral agreement for scheduled services in the Chicago – Cancun market will become

available when USA3000 ends its current service (reportedly on January 30, 2012). 

AirTran Airways, Inc. (“AirTran”) and Frontier Airlines, Inc. (“Frontier”) have filed 

competing applications seeking exemption authority for the one available designation in 

this market.

1

 

 

1

AirTran submitted an Application for Chicago-Cancun service on December 6, 2011 (Docket OST-2011-0225), an 

Answer to Frontier’s Application on December 6, 2011 (Docket OST-2011-0214), and a Reply to Frontier’s Answer on 

December 22, 2011 (Docket OST-2011-0225). 
2

Pursuant to Order 2012-1-4, AirTran is hereby providing additional information 

requested by the Department to supplement its previously filed Application and related 

pleadings, including a more complete analysis that builds on the materials already 

submitted to the docket. This supplemental filing addresses all of the pertinent carrier 

selection criteria referenced in Order 2012-1-4 and further demonstrates the clear 

superiority of AirTran’s application over Frontier’s.

I. AIRTRAN’S SERVICE PROPOSAL WILL PUT THE CHICAGOCANCUN DESIGNATION TO THE HIGHEST AND BEST USE.

AirTran, a wholly-owned subsidiary of Southwest Airlines (“Southwest”),

proposes to provide year-round daily service between Chicago Midway Airport (MDW) 

and Cancun, Mexico (CUN) beginning no later than March 11, 2012. Specific proposed 

schedules are shown on Exhibit FL-101. Service will be provided with Boeing 737-700 

aircraft configured for 137 seats, consisting of 12 Business Class and 125 Coach seats. 

The aircraft needed for this service are on-hand in AirTran’s fleet; no cancellation of 

existing service will be required to serve MDW-CUN. There will be no reduction in 

service in off-peak periods under AirTran’s proposal. In fact, in the future 

AirTran/Southwest will have the ability to up-gauge to 175-seat B737-800 aircraft on this 

route during the peak season, as Southwest will take delivery of over 30 B737-800’s in 

2012 and additional such aircraft in succeeding years.

2

 

Other elements of AirTran’s service proposal, as required by the Department’s 

evidence request on page 4 of Order 2012-1-4, are shown in Exhibits FL-102 (fuel 

consumption/availability and other summary statistics of AirTran’s proposal), and 

 

2

In addition, Southwest recently announced that it will be re-configuring all of its B737-700s to introduce new interiors

and an expanded seating capacity of 143 seats, an increase from the current 137-seat configuration. 
3

Exhibits FL-107, -108, and -109 (nonstop connecting schedules both southbound and 

northbound). Details on current AirTran scheduled and charter services to Mexico are 

shown in Exhibit FL-103. 

Finally, in response to paragraph 5 of the Department’s evidence request, 

AirTran states that its case for being selected as the primary carrier in the CHI-CUN 

market is overwhelming, but in the event the Department does not select AirTran, it is 

willing to accept back-up authority under the standard conditions specified in Order 

2012-1-4. 

II. AIRTRAN/SOUTHWEST’S HUGE PRESENCE IN CHICAGO WILL 

STRONGLY SUPPORT ITS CANCUN SERVICE, WHILE FRONTIER 

HAS VIRTUALLY NO CHICAGO SERVICE TO SUPPORT ITS 

PROPOSAL.

As a combined carrier, AirTran/Southwest have a massive presence at Chicago 

that will strongly support new service to Cancun.3 AirTran/Southwest together currently 

serve 57 destinations from MDW with nonstop service, and generate a 28% share of the 

domestic Chicago O&D market. See Exhibits FL-104 and FL-110. This ranks second 

behind United by just one percentage point, while Frontier has only a 1% share of the 

Chicago market (Exhibit FL-110). This is because Frontier serves just one Chicago 

route: MDW-DEN (Exhibit FL-114). As a consequence, AirTran/Southwest carry over 

41 times more Chicago-originating domestic O&D traffic then Frontier (Exhibit FL-111) 

and provide the Chicago market nearly 70 times more seat capacity than Frontier 

(Exhibit FL-112). 

 

3

For purposes of the present proceeding, AirTran and Southwest should be considered essentially as one since they 

will be operating as a single combined carrier during most of the period in question. See Answer of AirTran Airways, 

filed December 6, 2011 in Docket OST-2011-0225, at p. 3 for additional details on the Southwest/AirTran integration. 
4

With their huge presence at MDW, AirTran/Southwest serve 27 cities with less 

than 40% circuity that would provide additional passenger support for service to 

Cancun. As shown on Exhibit FL-107, based on current schedules 21 of these 27 

markets offer convenient connections with AirTran’s proposed Cancun service. The 

connecting flights are shown in Exhibits FL-108 (southbound) and FL-109 (northbound). 

By comparison, Frontier serves only a single destination from Chicago (DEN) and the 

service is to MDW, not ORD. Therefore, Frontier would obtain no connecting traffic in 

support of its proposed Cancun service at ORD (Exhibit FL-114). 

With its extensive network of connections at MDW, AirTran/Southwest are

heavily committed to Chicago and have the large market presence to ensure that 

AirTran’s MDW-CUN service is successful and sustained. Between the two applicants, 

AirTran will unquestionably deliver far greater public benefits to Chicago O&D 

passengers as well as travelers in numerous connecting markets behind the Chicago 

gateway. 

III. AIRTRAN/SOUTHWEST’S CANCUN SERVICE AT MIDWAY WILL

GENERATE FAR GREATER PUBLIC BENEFITS THAN REDUNDANT 

SERVICE BY FRONTIER AT O’HARE. 

As AirTran stated in its previous filings, the best use of the one available 

Chicago-Cancun scheduled designation is for the Department to authorize new 

AirTran/Southwest competition and service from Chicago Midway Airport. Today MDW 

has no nonstop service to Cancun, while both United and American provide daily, yearround nonstop service to Cancun from ORD. United and American’s service to Cancun 

is an integral part of their ORD hub networks, and combined the two carriers offer 892 
5

round-trips per year in this market.4In addition, the Department recently granted 

Mexican carrier Aeromexico’s application to provide nonstop ORD-CUN service with 

multiple weekly frequencies.5 Accordingly, Aeromexico could add hundreds of 

additional round-trips annually in the same airport-pair. 

In contrast to the existing concentration of service at O’Hare, AirTran proposes to 

operate daily year-round service to/from Cancun at Chicago’s Midway International 

Airport. Therefore, awarding one of the three U.S. designations to AirTran at MDW 

would create a geographical diversity of service that does not now exist and would 

clearly benefit the region. Not surprisingly, Chicago leaders at the federal, state and 

local level strongly support AirTran’s new nonstop service proposal from MDW. For 

example, Mayor Rahm Emanuel wrote in “strong support” of AirTran’s application: 

I believe that the daily, year-round nonstop scheduled service proposed by 

AirTran offers the most sustainable option for enhanced scheduled air 

service in the Chicago-Cancun market. AirTran’s new low-fare service 

from Midway, supported, in part, by strong connecting feed traffic from 

Southwest Airlines’ expansive network, will complement the current 

scheduled services provided by United Airlines and American Airlines from 

Chicago’s O’Hare International Airport in this market. This will encourage 

competition and provide the traveling public with a variety of service 

options.6

By comparison, Frontier’s proposal would waste a scheduled service designation 

and deny major portions of the Chicago market a more convenient low-fare service at 

Midway. This outcome would be particularly perverse since Frontier’s contract with 

 

4

Based on Official Airline Guide, YE 2Q 2012.

5

See Notice of Action Taken dated December 20, 2011 in Docket DOT-OST-2011-0231, approving Aeromexico’s 

application for exemption to serve Chicago – Cancun; counsel for Aeromexico has verified that the carrier intends to 

serve ORD.

6

Letter of Mayor Rahm Emanuel to Secretary Ray LaHood, December 22, 2011, filed in Dockets DOT-OST-2011-

0225 and -0214.
6

Apple Vacations could be satisfied using its charter authority in the ORD-CUN market 

(Exhibit FL-106).7 

Frontier previously advanced a theory that the Chicago-Cancun market is 

primarily located at ORD and not MDW.8 However, this simply reflects the reality that all 

of the current nonstop service to Cancun is at ORD (Exhibit FL-116). As the examples 

below from Southwest’s history at MDW illustrate, it has been demonstrated time and 

again that where nonstop services are comparable between MDW and ORD, the traffic 

divides almost equally (Exhibit FL-117). In large part this is because the close-in 

resident population is about equal in size for both Chicago airports – 8.3 million within 

60 minutes of MDW and 8.8 million for ORD (Exhibit FL-105). 

For example, before Southwest served the MDW-IAD market, ORD had 41 times 

more originating traffic than MDW. Today, MDW is 22% larger than ORD in terms of 

Chicago originating IAD passengers (Exhibit FL-118) despite the large United Airlines 

hub operations at both ORD and IAD. The same equalization of traffic occurred after 

Southwest began MDW-BUF service. Before entry, the ORD-BUF traffic was 34 times 

the MDW-BUF originating traffic. After entry by Southwest the MDW-BUF originating 

passengers were 73% as great as the ORD-BUF traffic volume (Exhibit FL-119). With 

Southwest’s extensive network at MDW and strong presence in Chicago, its proposed 

Midway - Cancun service will no doubt follow the same pattern, generating new 

passengers and creating additional intra-Chicago competition at MDW. 

 

7

See section VI, infra. 

8

Frontier Reply and Answer, December 15, 2011 at p. 5.
7

IV. HISTORY SHOWS THAT ALL CHICAGO PASSENGERS WILL 

BENEFIT FROM ADDITIONAL COMPETITION AT MIDWAY.

History has shown repeatedly and conclusively that air service at Midway 

competes vigorously with air service at O’Hare. This is not surprising, since the resident 

population within a 60-minute drive from MDW is 94% as large as the 60-minute drive 

contour around ORD (Exhibit FL-105). In fact, most of the Chicago population overlaps, 

i.e., it resides within the 60 minute contour of both ORD and MDW. 

Several examples prove this point. Southwest’s entry into the MDW-LGA market 

in June 2009 caused average fares to decline from $142 to $110 and annual traffic at 

MDW to increase from 172,230 to 435,120, or by 153%. At the same time, the ORDLGA average fare declined from $154 to $129 and O’Hare’s LGA traffic increased by 

more than 200,000 annual O&D passengers (Exhibit FL-120). The same phenomenon 

occurred after Southwest’s March 2009 entry in the MDW-MSP market: average fares 

dropped at both MDW and ORD, by 42% and 45% respectively, while total ChicagoMSP traffic increased by 173,000 annual O&D passengers (Exhibit FL-123). 

The point is that, contrary to Frontier’s unsupported claims, the Chicago market 

has benefitted enormously from competition between MDW and ORD in a host of 

domestic markets, and the same will be true internationally if AirTran/Southwest is 

authorized to serve MDW – CUN. This will not only provide a new and needed travel 

option for Chicago residents, but will ensure that the carriers serving ORD – CUN must 

compete vigorously for business with the nation’s largest low-fare carrier at nearby

MDW.
8

V. IN CONTRAST TO FRONTIER’S DUBIOUS SERVICE RECORD TO 

MEXICO, AIRTRAN/SOUTHWEST WILL UNQUESTIONABLY

PROVIDE STRONG AND SUSTAINED COMPETITION IN THE 

CHICAGO-CANCUN MARKET.

One of the Department’s important carrier selection criteria is the likelihood of 

maintaining the proposed service over the long term. Once again the 

AirTran/Southwest proposal is far superior. There is no doubt, based on a host of 

objective factors, that AirTran/Southwest is far more likely than Frontier to maintain its 

proposed service and competition for the indefinite future. 

To begin with, Southwest has an unmatched history of service stability in 

Chicago and across its system. In the case of Chicago Midway in particular, Southwest

began service in 1985 with a single route to/from STL. Over the past 27 years it has 

expanded its MDW service to 57 routes, and has never discontinued service on a route 

in which it offered daily service (Exhibit FL-113).9 This is a remarkable record 

considering all of the adverse economic cycles, significant exogenous events (including 

the 9/11 attacks), and the enormous increase in fuel costs since 1985. Nevertheless, 

Southwest has not only maintained its Midway service, but has expanded it greatly. 

Currently AirTran/Southwest serve 57 nonstop destinations to and from Midway, with 

1,689 weekly departures and 228,588 seat-departures (Exhibit FL-104). 

Frontier’s service history to Mexico, on the other hand, reveals what can fairly be 

characterized as a pattern of trial and error. As shown in Exhibit FL-115, Frontier has 

entered 26 U.S.-Mexico routes beginning in 2003. Of the 26 routes attempted, Frontier 

abandoned 13 and provided interrupted service in another 10. Frontier has provided 

continuous service on only three of its 26 routes since it began. Significantly, all of 

 

9

The only MDW markets in which Southwest dropped service are BUR and PBI, both of which Southwest served for 

brief periods on Saturdays only. See Exhibit FL-113.
9

those three markets are from its Denver hub where Frontier can support the Mexico 

flights with flow traffic over multiple connecting segments. The value of a connecting 

network to support service to Mexico is therefore abundantly clear from Frontier’s own 

checkered experience. In Chicago, where Frontier lacks any behind-gateway support, 

Frontier’s history raises serious doubts about both its ability and commitment to sustain 

the service that its current application promises. 

Beyond this, at ORD Frontier would be competing against established network 

service from United and American with no passenger feed and little name recognition, 

raising further doubts whether it would have the necessary staying power in this market. 

AirTran/Southwest, on the other hand, will unquestionably be able to provide strong, 

sustained, and likely growing competition in the Chicago-Cancun market, supported by 

its enormous base of operations at MDW. 

VI. THE PUBLIC INTEREST WILL BE BEST SERVED IF AIRTRAN IS 

AWARDED THE SCHEDULED DESIGNATION, WHILE FRONTIER 

CAN SERVE THE MARKET VIA CHARTERS.

As AirTran has stated before, the Department has available to it an unusual “winwin” resolution to the carrier selection dispute in this proceeding. AirTran/Southwest 

have demonstrated beyond doubt their superiority over Frontier with respect to all the 

Department’s important carrier selection criteria, and thus should be awarded the single 

scheduled service designation that is available in the Chicago-Cancun market. But at 

the same time, an award to AirTran need not exclude Frontier from this market. Frontier 

has repeatedly made clear that its motivation for seeking Chicago-Cancun authority is to 

step into the shoes of USA3000, by providing lift to Apple Vacations in its bulk tour 

operator business. See, e.g., Frontier Application at pp. 2-4. Frontier can easily meet 
10

this objective under the liberal provisions of the US – Mexico bilateral for charter 

services. Indeed, AirTran’s own experience with charters to Mexico (on behalf of Apple 

Vacations as well as other tour operators) demonstrates that bulk contract tour services

can easily be, and often are, operated as charter flights. AirTran has provided lift for 

many such charter operations to Cancun and other Mexico destinations, and continues 

to do so from various U.S. cities. See Exhibit FL-103. These services are in fact classic 

charter operations, where the tour operator handles all sales and advertising, while the 

carrier simply provides lift. This is the kind of business that Apple Vacations is in, and 

Frontier has given no valid reason why it cannot adequately service Apple’s business in 

Chicago as charters. An award of scheduled authority to Frontier, on the other hand, 

would squander the one available U.S. designation and needlessly block AirTran - and 

Midway - from the market. 

VII. AIRTRAN’S APPLICATION HAS RECEIVED

ENORMOUS POLITICAL AND COMMUNITY SUPPORT

AirTran’s application to provide MDW-CUN service has received extraordinary 

support from Chicago elected officials and community leaders. As noted above, Mayor 

Emanuel has written in strong support of AirTran’s application, and Congressman Dan 

Lipinski (D-IL) has as well, stating that:

MDW offers my constituents, and the millions living and working in 

northeast Illinois, hundreds of daily domestic flight options. While 

domestic service at MDW has grown over the years and is very strong 

today, international service has not kept pace....Given the potential public 

benefits to my constituents and all air travelers across the country, I 

support AirTran’s efforts to provide service between MDW and CUN.10

 

10Letter of Representative Dan Lipinski to Secretary Ray LaHood, December 19, 2011, filed in Docket DOT-OST2011-0225. 
11

Similarly, Rosemarie Andolino, Commissioner of the Chicago Department of Aviation, 

wrote specifically in support of the “win-win” resolution that AirTran has advocated, 

stating that:

[I]n the narrow Chicago-Cancun scheduled market at issue in this 

proceeding, Frontier’s lack of existing scheduled service at O’Hare, and 

limited presence in the Chicago market in general, makes Frontier a more 

appropriate candidate for providing new service in this market under the 

unlimited-entry charter provisions of the U.S.-Mexico bilateral 

agreement.11

AirTran’s proposal has also received support from numerous other Chicago leaders 

and organizations, including the following:12

Michael Madigan, Speaker of the Illinois House 

Jerry Roper, President and CEO of the Chicagoland Chamber of Commerce

Patrice Brooks, EVP of the Chicago Southland Chamber of Commerce

Carlos Tortolero, President and Founder, National Museum of Mexican Art

Dr. Vincent Allocco, CEO of El Valor

John Bournan, Sargent Shriver National Center on Poverty Law 

Beyond this, AirTran’s proposal is supported by the pilot unions of both companies, the 

Southwest Airlines Pilots’ Association (SWAPA) and the AirTran Master Executive 

Council (MEC) of the Air Line Pilots Association, International.

13

This outpouring of support for AirTran’s application reflects the enormous public 

benefits that the AirTran/Southwest MDW-CUN service will generate for the Chicago

economy and its citizens, and AirTran urges the Department to fully credit this 

impressive display of community support.

 

11 Letter of Commissioner Rosemarie S. Andolino to Secretary Ray LaHood, December 23. 2011, filed in Dockets 

OST-2011-0225 and -0214.

12 All the support letters referenced herein have been filed in Docket OST-2011-0225.

13 See the SWAPA brief and AirTran MEC letter filed in Docket OST-2011-0225.
12

WHEREFORE, for the reasons stated above and in its prior submissions, AirTran 

requests that the Department grant its application for exemption authority and designate 

AirTran to provide scheduled foreign air transportation of persons, property and mail 

between MDW and CUN. 

Respectfully submitted,

______________________

Robert W. Kneisley

January 19, 2012
13

CERTIFICATE OF SERVICE

I hereby certify that on January 19, 2012, 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
AirTran’s MDW-CUN B737-700 Nonstop Service Proposal 1

Summer

3:40

0915

1255

Chicago

(MDW)

Cancun

(CUN)

Summer

3:45

1735

1350

Winter

3:40

Winter

3:45

1735

1350

FL 97

Daily

FL 98

Daily

0915

1255

.

Season

Elapsed Time

Flight

Freq/Wk

1 AirTran/Southwest will have the ability in the future to up-gauge to the 175-seat B737-800 during the peak season. Southwest will take 

delivery of over 30 B737-800’s in 2012. All times shown are local. Proposed flight times are subject to availability of compatible time slots in 

CUN and may require slight modification on certain days. 

Docket DOT-OST-2012-0001

Exhibit FL-101
Summary Statistics for AirTran’s MDW-CUN Proposal 

Based on Forecast Year

Statement on Fuel Availability: AirTran anticipates no difficulty 

in obtaining fuel from suppliers at MDW or CUN.

Aircraft B737-700 /1

Departures 730

Segment Miles (statute miles) 1,431

Total Annual Aircraft Miles (statute miles) 1,044,630

Annual ASMs 143,114,310

Fuel Consumption (gallons) 1.1 million

1 AirTran/Southwest will have the ability in the future to up-gauge to the 175-seat B737-800 during the peak season. Southwest will take delivery of over 

30 B737-800’s in 2012.

Docket DOT-OST-2012-0001

Exhibit FL-102
AirTran’s Current Services to Mexico

Docket DOT-OST-2012-0001

Exhibit FL-103

Roundtrip

Flights per 

Market Week

ATL-CUN

BWI-CUN

MKE-CUN

15

8

1

Scheduled Service

Roundtrip

Flights per 

Market Week

DTW-CUN

PIT-CUN

MKE-CUN

MKE-CZM

MKE-PVR

MKE-ZIH

2

2

5

1

1

1

Charter Service

All services shown are current as of January 2012. The scheduled services are offered 

year-round, the charter services are offered only during peak season. Charters are 

operated for bulk tour operators Apple Vacations and Funjet, which handle advertising 

and sales; AirTran provides lift only.
MDW

IAD

LGA

EWR

ISP

PHL

PVD

MHT

SRQ

TPA

SAT

ONT

SNA

LAX

SAN

SFO

OAK

SJC

SMF

RNO

PDX

SEA

MSP

CUN

ATL

MCO

RSW

ABQ

ALB

AUS

BDL

BHM

BNA

BOS

BUF

BWI

CHS

CLE

DEN CMH

DTW

FLL

GSP

HOU

IND

JAN

LAS

LIT

MCI

MSY

OMA

ORF

PHX

PIT

RDU

SDF

SLC

STL

TUS

AirTran/Southwest’s Huge Presence in Chicago 

Will Support Its Proposed MDW-CUN Service

Current FL/WN MDW Service

Destinations 57

Weekly Departures 1,689

Weekly Seat Departures 228,588

Current FL/WN Markets

 Proposed FL/WN Market

Source: OAG schedule for the week of March 12, 2012.

Docket DOT-OST-2012-0001

Exhibit FL-104
The MDW Population within a 60 minute Drive is 94% 

of the ORD Population within a 60 minute Drive

Source: Targetpro, via MapInfo, 2009 population estimates. 

MDW

MDW

60 Minute Drive

ORD

60 Minute Drive

MDW ( )

ORD ( )

MDW % of ORD

= 100 residents

ORD

8.3 million

8.8 million

94%

Population

Within 60 Minutes

Docket DOT-OST-2012-0001

Exhibit FL-105
The AirTran/Southwest Proposal Would Bring First Competitive Service to MDW 

While Frontier Could Serve Apple Vacations with Charter Authority

462

430

365

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

Docket DOT-OST-2012-0001

Exhibit FL-106

AA

Annual 

Roundtrips

UA F9 FL/WN

ORD Service

MDW 

Service

462

430

365

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

1/ AM has indicated that it plans multiple weekly nonstop flights (See APPLICATION OF AEROVIAS DE MEXICO, S.A. DE C.V.

FOR EXEMPTION AUTHORITY, December 15 ,2011. AirTran assumes daily service for this case. 

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

None

AM /1 AM /1
CUN

MDW

MHT

LGA

EWR

BDL

ALB

MSP

OMA

DEN

SJC

OAK SFO

SMF

SLC

RNO

SEA

PDX

BOS

BUF

CLE

CMH

DTW

IND

ISP

MCI

PIT

PVD

STL

AirTran/Southwest Would Connect 21 Markets 

At MDW With Less Than 40% Circuity

Proposed FL/WN Market

Actual FL/WN Connections Based on March 2012 Schedule (21 Markets) 

 Potential FL/WN Connections (6 Markets)

Current FL/WN Service (<40% Circuity)

Destinations 27

Weekly Departures 786

Weekly Seat Departures 106,947

Source: OAG schedule for the week of March 12, 2012.

Docket DOT-OST-2012-0001

Exhibit FL-107
AirTran Nonstop-to-Nonstop Connections - Southbound

Note: All times local. 

Source: FL/WN proposed schedules.

0915

Origin Flight

MDW

Arrival

MDW

Depart Destination Flight

1255 FL-97

CMH

IND

BUF

STL

EWR

DTW

EWR

CLE

LGA

MCI

MSP

OMA

CLE

BUF

STL

ALB

BOS

ISP

MHT

PIT

DTW

OMA

ALB

BDL

BOS

MHT

PIT

PVD

CMH

CMH

LGA

IND

STL

STL

PVD

0605

0625

0600

0600

0600

0710

0605

0655

0600

0600

0600

0605

0705

0650

0640

0635

0600

0625

0615

0725

0745

0630

0640

0630

0610

0630

0730

0625

0750

0750

0640

0820

0715

0720

0655

WN-1904

WN-2567

WN-465

WN-275

WN-1694

WN-1200

WN-950

WN-2564

WN-3566

WN-454

WN-2088

WN-1480

WN-747

WN-949

WN-2168

WN-2848

WN-290

WN-703

WN-731

WN-652

WN-25

WN-583

WN-2581

WN-2146

WN-2479

WN-1957

WN-1323

WN-3438

WN-2432

WN-2438

WN-1944

WN-168

WN-976

WN-716

WN-197

73G

73G

73G

73G

73G

73G

73G

73G

73G

73G

73G

73G

73G

73G

73G

73G

73G

73G

73G

73G

733

73G

73G

73G

73G

73G

73G

73G

733

73G

73G

73G

733

73G

73G

73G

Elapsed

Time

7:50

7:30

7:55

6:55

7:55

6:45

7:50

7:00

7:55

6:55

6:55

6:50

6:50

7:05

6:15

7:20

7:55

7:30

7:40

6:30

6:10

6:25

7:15

7:25

7:45

7:25

6:25

7:30

6:05

6:05

7:15

5:35

5:40

5:35

7:00

3:40

Destination

Arrive

0615

0620

0650

0700

0715

0720

0720

0725

0725

0725

0725

0730

0735

0740

0740

0750

0750

0750

0750

0750

0755

0755

0800

0800

0800

0800

0800

0800

0805

0805

0805

0815

0820

0820

0830

Departure

Time

CUN

Eqpt

Days of 

Operation

12345..

12345..

12345..

12345..

.....6.

.....6.

12345..

.....6.

12345..

12345..

12345..

12345..

12345..

......7

12345..

12345.7

12345..

12345.7

12345..

12345.7

12345..

.....6.

.....6.

12345..

.....6.

.....6.

.....6.

.....6.

.....6.

12345.7

.....6.

......7

.....6.

......7

12345..

1234567

Seats

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

Docket DOT-OST-2012-0001

Exhibit FL-108
AirTran Nonstop-Nonstop Connections - Northbound

1905

1905

1905

1905

1910

1910

1925

1930

1935

1935

1940

1940

1945

1950

2000

2000

2000

2015

2015

2025

2025

2025

2025

2025

2025

2030

2035

2045

2045

2045

2045

2045

2050

2050

2110

2115

2115

2120

2145

2155

2155

Origin Flight

MDW

Arrival

MDW

Depart Destination Flight

2050

2050

2030

2010

2210

2020

2050

2135

2110

2230

2250

2230

2245

2140

2225

2205

2250

2320

2315

2310

2335

2325

2150

2240

2335

2220

2240

2335

2355

2345

2300

2355

2215

2215

2315

2340

2250

2245

2245

0005

2330

WN-744

WN-240

WN-2200

WN-3353

WN-2243

WN-679

WN-850

WN-1622

WN-2364

WN-816

WN-1807

WN-683

WN-1281

WN-253

WN-485

WN-3023

WN-2222

WN-37

WN-393

WN-2004

WN-1978

WN-1070

WN-2424

WN-3887

WN-1274

WN-1334

WN-1827

WN-662

WN-606

WN-1499

WN-192

WN-627

WN-1713

WN-1713

WN-250

WN-1338

WN-189

WN-355

WN-3882

WN-1278

WN-637

CUN FL-98 1350 73G

73G

73G

733

73G

73G

733

73G

733

73G

73G

73G

73G

73G

733

733

733

73G

73G

73G

73G

73G

73G

73G

73G

73G

733

73G

73G

73G

73G

73G

73G

733

73G

73G

733

73G

733

733

73G

735

Elapsed

Time

3:45

8:00

8:00

6:40

6:20

7:20

6:30

7:00

6:45

8:20

7:40

8:00

10:40

10:55

6:50

7:35

7:15

11:00

8:30

8:25

8:20

8:45

8:35

8:00

7:50

8:45

7:30

7:50

8:45

9:05

8:55

8:10

9:05

8:25

8:25

8:25

8:50

10:00

8:55

8:55

9:15

10:40

Destination

Arrive

1735

Departure

Time

DEN

DEN

MCI

STL

BDL

STL

MSP

DTW

DEN

EWR

ISP

SFO

SFO

IND

BUF

DTW

OAK

BDL

LGA

ALB

BOS

MHT

OMA

PIT

PVD

IND

CMH

ALB

BOS

MHT

PIT

PVD

MCI

MCI

CMH

BUF

DEN

OMA

STL

CLE

DEN

Eqpt

Days of 

Operation

1234567

......7

12345..

.....6.

.....6.

.....6.

12345.7

.....6.

12345.7

.....6.

12345.7

12345.7

12345.7

.....6.

12345.7

.....6.

.....6.

.....6.

12345.7

12345.7

.....6.

.....6.

.....6.

.....6.

.....6.

.....6.

.....6.

.....6.

12345.7

12345.7

12345.7

12345.7

12345.7

......7

12345..

12345.7

12345.7

12345.7

12345.7

12345.7

12345.7

12345.7

Seats

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

137

122

Note: All times local.

Source: FL/WN proposed schedules.

Docket DOT-OST-2012-0001

Exhibit FL-109
AirTran/Southwest Carries The Second Largest 

Number of O&D Passengers In Chicago

Note: Frontier includes Midwest and Frontier data, United includes United and Continental data.

Source: U.S. DOT O&D Survey data, YE Q2 2011.

Domestic O&D Passenger Share

29%

28%

26%

16%

1%

0%

5%

10%

15%

20%

25%

30%

UA FL/WN AA Other F9

Docket DOT-OST-2012-0001

Exhibit FL-110
AirTran/Southwest Carries Over 41 Times More 

Originating Passengers Than Frontier From Chicago

5,448,234

131,821

0

1,000,000

2,000,000

3,000,000

4,000,000

5,000,000

6,000,000

41.3 Times

Chicago Domestic Originating O&D Passengers

Note: Frontier includes Midwest and Frontier data.

Source: DOT, Origin-Destination Passenger Survey, YE Q2 2011.

AirTran/Southwest Frontier

Docket DOT-OST-2012-0001

Exhibit FL-111
208,160

2,994

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

130,000

140,000

150,000

160,000

170,000

180,000

190,000

200,000

210,000

69.5 Times

Note: Frontier includes Midwest and Frontier data.

Source: OAG, November 2011.

AirTran/Southwest Frontier

AirTran/Southwest Operates Nearly 70 Times As Much 

Capacity As Frontier In Chicago

Weekly Seat Departures

Docket DOT-OST-2012-0001

Exhibit FL-112
Jan 1985

Jan 1987Jan 1989

Jan 1991

Period of Service Suspension

Service Period for Current Route

Service Period for Discontinued

Route

Jan 1993

Jan 1995Jan 1997

Jan 1999

Jan 2001

Jan 2003Jan 2005

Jan 2007

Jan 2009

Jan 2011

Jan 2012 STL

MCI

BNA

DTW/DET

IND

CLE

CMH

SDF

BWI

OMA

LIT

BHM

PVD

JAN

MHT

ISP

PHX

HOU

RDU

LAS

MCO

BDL

TPA

ABQ

FLL

SEA

OAK

LAX

SAN

PBI

SLC

PHL

ORF

PDX

SJC

PIT

MSY

AUS

BUF

TUS

ALB

SMF

BUR

SAT

RSW

DEN

SNA

RNO

IAD

SFO

MSP

LGA

BOS

ONT

GSP

EWR

CHS

Docket DOT-OST-2012-0001

Exhibit FL-113

1 Both MDW-PBI and MDW-BUR were short-term experimental markets with Saturday only service.

Source: Southwest Internal data.

In 27 Years Southwest Has Abandoned Only Two1 of Its 57 MDW Routes
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.

CUN

ORD

MDW

DEN

Docket DOT-OST-2012-0001

Exhibit FL-114
Source: US DOT T-100 Data, OAG Schedules.

Frontier’s Mexico Service Has Been Spotty

DEN-MZT

DEN-CUN

DEN-SJD

DEN-PVR

DEN-ZIH

SLC-CUN

MCI-CUN

AUS-CUN

BNA-CUN

STL-CUN

MCI-PVR

DEN-CZM

DEN-ACA

IND-CUN

SAN-CUN

MCI-SJD

LAX-SJD

DEN-GDL

SMF-SJD

SJC-SJD

DFW-MZT

SMF-PVR

SJC-PVR

MKE-CUN

ABQ-PVR

STL-PVR

Docket DOT-OST-2012-0001

Exhibit FL-115

Period of Service Suspension

Service Period for Current Route

Service Period for Discontinued

Route

Period of Service Suspension

Service Period for Current Route

Service Period for Discontinued

Route
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

35

7

0

5

10

15

20

25

30

35

40

Nonstop Flights Connecting Options

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; Appendices A-D.

ORD MDW ORD MDW

Best Roundtrip Elasped Time at ORD = 7:25

Best Roundtrip Elasped Time at MDW =12:07

Daily Roundtrip

Nonstops

Average Online 

Roundtrip Flights per Day

Docket DOT-OST-2012-0001

Exhibit FL-116
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

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.

Docket DOT-OST-2012-0001

Exhibit FL-117
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

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.

Docket DOT-OST-2012-0001

Exhibit FL-118
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

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.

Docket DOT-OST-2012-0001

Exhibit FL-119
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

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

Docket DOT-OST-2012-0001

Exhibit FL-120
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

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

Docket DOT-OST-2012-0001

Exhibit FL-121
Southwest’s Entry in MDW-BWI Stimulated Total Chicago

Traffic And Lowered Fares at Both ORD and MDW

$114

$50

$66

$165

$0

$10

$20

$30

$40

$50

$60

$70

$80

$90

$100

$110

$120

$130

$140

$150

$160

$170

$180

Before 

WN

Nonstop

ORD

Note: Before Period = YE Q2 1993. After Period = YE Q3 1994.

Source: DOT, Origin-Destination Passenger Survey.

MDW

Average Fare

After 

WN

Nonstop

Before 

WN

Nonstop

After 

WN

Nonstop

17,310

321,440

621,400

261,700

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

Before 

WN

Nonstop

MDW ORD

O&D Passengers

After 

WN

Nonstop

Before 

WN

Nonstop

After 

WN

Nonstop

Docket DOT-OST-2012-0001

Exhibit FL-122