April 20, 2011

J. David Grizzle Chief Counsel Federal Aviation Administration 800 Independence Ave., S.W. Washington, D.C. 20591

Re: Request of American Eagle Airlines for Limited DCA Slot Usage Waiver (January-February 2011)

Dear Mr. Grizzle:

American Eagle Airlines, Inc., under 14 CFR 93.227(j),hereby requests a limited waiver of the 80% slot usage requirement with respect to 2 slots at Ronald Reagan Washington National Airport (DCA), ID # 104 (0700) and ID # 194 (2000), for the January–February 20ll reporting period.

Our request is necessitated by the severe snowfall events in the Northeast and mid-Atlantic regions that significantly disrupted air carrier operations at DCA and other airports on the East Coast.

During the reporting period, the two AMR Corporationoperating entities, American Airlines and American Eagle Airlines, together held 5,984 DCA slots and published schedules for 5,554 flights, which is a scheduled usage rate of 92.81%. If unprecedented storms had not repeatedly struck the region, American Eagle would not require waiver relief since ample operations had been scheduled to easily meet the 80% use-or-lose requirement.

On March 11, 2011, the Air Transport Association submitted a request on behalf of member carriers for slot usage relief for DCA and the three New York area airports (LGA, JFK, and EWR) (FAA-2011-0248). The FAA denied the ATA’s request on March 28, 2011 (76 Fed. Reg. 19517, April 7, 2011), but invited waiver requests from individual carriers:- 2 -

“Although the FAA has determined that a general waiver of the usage requirements is inappropriate, it acknowledges that nationwide weather during this period may have caused a unique hardship for some carriers. To assess that hardship and determine whether relief is warranted, the FAA requests that affected carriers submit an individual request for limited waiver. The FAA will consider the period of January 7 through February 4, 2011, but will make a waiver determination on an individual–day basis.”

American Eagle seeks relief from the 80% usage requirement for two specific DCA slots:

Slot ID # 104 (0700)

This is a Monday–Friday slot with 41 operating days in the January–February reporting period. To achieve 80% use, 32operations were required. American Eagle conducted 31 operations, and seeks a waiver covering 1 day. In the January 7- February 4 period recognized by the FAA as experiencing severe weather impacting the Northeast and mid-Atlantic regions, AMR (American and American Eagle combined) cancelled 13 flights due to weather that were scheduled in the 0700 slot window.

In the alternative, and to the extent required, we request authorization to engage in retroactive intra-corporate transactions involving the 5 DCA slots held by AMR at the 0700 hour. Of the 231 AMR slots at 0700 in the reporting period, American Eagle and American Airlines flew 187, or an actualusage rate of 81% despite numerous weather-related cancellations. Due to clerical oversight, exacerbated by challenging operational conditions, we did not conduct contemporaneous transfers between the two AMR entities to ensure 80% use for each of AMR’s 0700 slots. If the FAA does not grant a waiver for 1 day as requested above, we should be authorized to retroactively redistribute AMR’s slots in the 0700 window.- 3 -

Slot ID # 194 (2000)

This is a daily slot with 59 operating days in the January–February reporting period. To achieve 80% usage, 46 operations were required. American Eagle conducted 42 flights, and requests a waiver covering 4 days. In the January 7- February 4 period recognized by the FAA as experiencing severe weather impacting the Northeast and mid-Atlantic regions, AMR (American and American Eagle combined) canceled 20 flights due to weather that were scheduled in the 2000 slot window.

THE FAA SHOULD GRANT THE REQUESTED RELIEF

In both severity and duration, the successive snowstorms that disrupted the Northeast and mid-Atlantic regions in thefirst two months of this year were highly unusual and unpredictable events beyond the control of American Eagle, and waiver of the minimum slot use requirements is appropriate. As the High Density Rule provides, “examples of conditions which would justify waiver under this paragraph are weather conditions which result in the restricted operation of an airport for an extended period of time.” See 14 CFR 93.227(j). Those conditions were present throughout the January 7–February 4 time period cited in the FAA’s decision on the ATA petition. Indeed, the weather events this past January and February were far more severe than those experienced a year ago that prompted the FAA to waive the minimum usage requirements at DCA (and the three New York-area airports) for the February 5-15, 2010 period. See 75 Fed. Reg. 9017, February 26, 2010.

Based on the FAA’s regulations and precedent, and consistent with the public interest, the limited relief requested herein by American Eagle should be granted.- 4 -

Respectfully submitted,

___________________________ WALTER J. AUE Vice President – Schedules American Airlines, Inc. P.O. Box 619616, MD 5535 DFW Airport, Texas 75162 (817) 967-2514 walter.aue@aa.com