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 Corporation 

operating 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: 
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“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, 32 

operations 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 actual 

usage 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. 
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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 the 

first 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. 
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 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