WASHINGTON/317737.4

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, DC

__________________________________________

)

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. § 41718 )

__________________________________________)

__________________________________________

)

Application of )

ALASKA AIRLINES, INC. ) Docket DOT-OST-2012-____

)

For exemptions from Subparts K and S of )

14 C.F.R. 93 pursuant to 49 U.S.C. §41718(a) )

(Ronald Reagan Washington National Airport-- )

Portland, OR and San Diego, CA) )

__________________________________________)

APPLICATION OF ALASKA AIRLINES, INC. FOR EXEMPTIONS

Megan Lawrence, Esq.

Managing Director, Gov't Affairs and

Community Relations

Megan.Lawrence@alaskaair.com

Kyle Levine, Esq.

Deputy General Counsel and

Managing Director, Legal

Kyle.Levine@alaskaair.com

ALASKA AIRLINES, INC.

19300 Pacific Highway South

Seattle, WA 98188

Marshall S. Sinick, Esq.

Marshall.Sinick@squiresanders.com

Edward W. Sauer, Esq.

Edward.Sauer@squiresanders.com

Squire Sanders (US) LLP

1200 19th Street, NW

Washington, DC 20036

(202) 626-6651

Counsel for Alaska Airlines, Inc.

Dated: March 12, 2012
- 1 -

WASHINGTON/317737.3

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, DC

__________________________________________

)

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. § 41718 )

__________________________________________)

__________________________________________

)

Application of )

ALASKA AIRLINES, INC. ) Docket DOT-OST-2012-____

)

For exemptions from Subparts K and S of )

14 C.F.R. 93 pursuant to 49 U.S.C. §41718(a) )

(Ronald Reagan Washington National Airport-- )

Portland, OR and San Diego, CA) )

__________________________________________)

APPLICATION OF ALASKA AIRLINES, INC.

FOR EXEMPTIONS

I. INTRODUCTION

Alaska Airlines, Inc. (“Alaska”) proposes to operate the first nonstop flights between

Reagan Washington National Airport (“DCA”) and Portland (“PDX”), Alaska’s number one

priority, and between DCA and San Diego (“SAN”). Alaska proposes one daily B-737-800

roundtrip flight to each city and therefore requests the allocation of four slots.

Alaska’s request to add these two cities to its West Coast-DCA network naturally follows

from Alaska’s success in serving both the Seattle-DCA and the Los Angeles-DCA markets.

These proposals offer substantial advantages to the public, including:
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WASHINGTON/317737.3

PORTLAND-DCA

 First nonstop service to Portland, the second largest Washington D.C. market

without DCA nonstop service;1

 New low fares of $149/$169, well below existing fares for Portland service at

Dulles;2

 Estimated passenger fare savings of $5.5 million 18% in the first year alone;3

 Immediate network benefits for Pacific Northwest passengers connecting to 10 cities

from Portland and, over time, even greater connecting network benefits because of

Alaska’s premier position as the largest carrier at Portland;4

 Major improvement for Portland and beyond-Portland passengers now using DCA

connecting service over Seattle, where Alaska’s 91% average load factor means that

seats are often unavailable;5and

 Optimal departure and arrival times for Portland and beyond-Portland passengers.6

SAN DIEGO-DCA

 First nonstop service to San Diego, the largest Washington D.C. market without

DCA nonstop service; 7

 First through-plane service between DCA and Honolulu;

 New low fares of $159/$179, well below existing fares for San Diego service at

Dulles;8

 Estimated passenger fare savings of $10.6 million or 31% in the first year alone;9

 Optimal departure and arrival times for Honolulu and San Diego passengers;10 and

 Would benefit a large segment of governmental, including military, traffic.

ALASKA AIRLINES AT DCA AND SYSTEMWIDE

 Highest load factor of any carrier at DCA;11

1 AS-D-2.

2 AS-D-9; Alaska’s fare commitment at Portland and San Diego would be applied for at least the first year of service

and would be subject to adjustment in the event of further escalation in the price of jet fuel.

3 AS-D-10.

4 AS-D-5.

5 USDOT T-100 data year-ending November 2011.

6 AS-D-1, AS D-5.

7 AS-D-2.

8 AS-D-9.

9 AS-D-10.

10 AS-D-1.

11 AS-D-11.
- 3 -

WASHINGTON/317737.3

 A track record of lower DCA fares that have generated an estimated $17 million in

passenger fare savings;12

 The highest completion factor of any carrier at DCA;13

 The highest on-time performance of any airline that operates into DCA;14

 On a systemwide basis, the second loweswt consumer complaint ratio of any U.S.

carrier;15 and

 On a systemwide basis, a growing and financially strong carrier that has excellent

relations with its various working groups and has avoided imposing the trauma of

bankruptcy on its passengers, employees or other stakeholders.

II. ALASKA’S PORTLAND & SAN DIEGO SERVICE PROPOSALS MORE THAN MEET THE

FAA REAUTHORIZATION ACT’S SELECTION CRITERIA.

The FAA Modernization and Reform Act (hereinafter “FAA Reauthorizaiton Act”)16

made significant changes to the criteria for the issuance of slot exemptions. The criteria, as

revised, strongly support the allocation of four of the available slot exemptions to Alaska.

Previously, the Department was directed to consider five criteria: i) new entrant/limited

incumbent carrier status;17 ii) domestic network benefits; iii) increase of competition in multiple

markets; iv) no impact on travel options for within perimeter airports; and v) no meaningful

increase in travel delays. The Department’s prior beyond-perimeter decisions generally focused

on the first three criteria, emphasizing service by new entrants/limited incumbents with strong

connecting hub networks outside the perimeter.18

The FAA Reauthorization Act added three new criteria and also changed the manner in

which the criteria are to be applied. The statute also changed the previous requirement that an

application meet all of the enumerated criteria, instead allowing the Department more flexibility

12 AS-D-8.

13 AS-D-13.

14 AS-D-15.

15 AS-D-16

16 P.L. 112-95.

17 “Limited Incumbent” is now defined as a carrier with fewer than 40 slots at DCA. Several exclusions from the

computation of slots held have also been added to the “Limited Incumbent” definition. As a result, numerous

carriers now meet this definition. 49 USC §41714(h)(5)(A) and (B) as amended by the FAA Reauthorization Act.

18 Order 2004-4-1 at 15-16; Order 2000-7-1 at 20-21. The last two criteria never became decisional differentiators.
- 4 -

WASHINGTON/317737.3

by changing the conjunctive “and” to the disjunctive “or.” Two of the new criteria focus on

competition in the local markets.19 The third directs the Department to assess the public benefits

of the proposed service, including the likelihood of lower fares, higher capacity and a variety of

service options.20

Alaska’s proposal to serve the Portland and San Diego-DCA markets, the two largest

Washington D.C. markets without nonstop service to DCA,21 presents the strongest possible case

for such service under the governing criteria. While previous cases assigned substantial

decisional weight to network benefits in beyond-perimeter markets and, in certain instances,

even indicated that strong local market traffic could be an impediment to those network

benefits,22 the new statute requires that local market benefits now be treated as a co-equal

decisional factor with beyond-market network benefits.

As it relates to the third criterion, Alaska proposes to offer fares in the DCA-Portland and

DCA-San Diego markets that are well below existing fares from other Washington D.C. area

airports.23 Alaska’s proposed fare structure would save its customers a total of approximately

$16 million annually over current fares in the two markets.24 These low fares are a natural

extension of Alaska’s lengthy track record of offering lower fares for its DCA service.25

Alaska’s growing West Coast-Honolulu market is another significant example of Alaska’s low

fare track record. Since January 2012, Alaska’s average West Coast-Hawaii fares have been

lower than those charged by any carrier.26 Alaska’s pro-consumer track record and commitment

to its customers is further supported by its actions in the fall of 2011 when it was one of only a

19 49 USC §41718(g)(2)(E),(F).

20 49 USC §41718(g).

21 AS-D-2.

22 Order 20002-11-20 at 7.

23 AS-D-9; AS-D-10.

24 Id.

25 AS-D-7.

26 AS-D-17.
- 5 -

WASHINGTON/317737.3

few carriers that actually reduced the amounts that passengers were required to pay during last

year’s lapse in various federal air transportation taxes rather than taking advantage of a

windfall.27

In the final analysis, four factors seem to be of paramount importance in the evaluation of

slot exemption requests: network and local market benefits; additional market access for the

most limited of limited incumbents; additional competition, and consumer benefits through lower

prices and better service. Alaska’s proposals are unlikely to be matched by any competing

applicant.

III. PORTLAND-DCA NONSTOP SERVICE—ALASKA’S NUMBER ONE PRIORITY AND

URGENTLY NEEDED SERVICE

Alaska’s dual-class-configured B-737-800 service28 would represent the first-ever

nonstop service in the market. Alaska estimates that it would carry approximately 103,00029

passengers in the first normalized year. Alaska’s passenger volume would include connecting

traffic from Alaska’s almost 640 flights per week to the 33 cities Alaska now serves beyond

Portland.30 With the added stimulus of the reduced fares Alaska would offer, Alaska estimates

that its 103,000 local and beyond Portland passengers would enjoy annual savings of

approximately $5.5 million or 18%.31 Passengers throughout the Pacific Northwest – from cities

including Anchorage, Vancouver, Seattle, Spokane and Eugene – would benefit from the

existence of another gateway and one additional nonstop frequency to DCA. This is particularly

important given the region’s extraordinarily high load factor or 91% to Washington D.C.32

27 AS-D-9.

28 AS-7, AS-8; Alaska’s B-737-800 aircraft are configured with 157 seats (16 first class and 141 economy class).

29 AS-D-10.

30 Source: OAG Schedules YE Aug’12.

31 AS-D-10.

32 AS-D-12.
- 6 -

WASHINGTON/317737.3

Alaska is confident that the success of its pioneering Seattle-DCA nonstop service would be

replicated at Portland.

In addition to dramatically improving service and competition in the local Portland-DCA

market, Alaska’s first nonstop frequency would also provide additional connecting service in no

fewer than 10 of Alaska’s 33 beyond-Portland markets.33 The 10 communities that would

immediately benefit from such additional connecting service to DCA are:

Anchorage, Alaska

Vancouver, British Columbia

San Francisco, California

San Jose, California

Eugene, Oregon

Medford, Oregon

Redmond, Oregon

Bellingham, Washington

Seattle, Washington

Spokane, Washington

Alaska proposes the ideal Portland arrival and departure times to maximize the number of

convenient connections passengers would enjoy.34 Alaska’s eastbound departure from Portland

would be at 10:10 AM with a 6:10 PM DCA arrival. Westbound, Alaska’s flight would depart

DCA at 5:35 PM and arrive in Portland at 8:25 PM.35 While connecting banks and individual

flights can change over time, Alaska’s growing presence at Portland, where Alaska is already the

largest carrier, means that there would be an increasing number of beyond-market passengers

who would find Alaska’s Portland-DCA frequency attractive.

Alaska’s route system, ranging from Barrow, Alaska in the north to Mexico City in the

south provides another dimension of potential connecting service for passengers to DCA. Alaska

33 AS-D-5; Alaska has identified specific flights from 10 of Alaska’s 33 beyond-PDX cities in its late summer-fall

schedule which would immediately benefit from Alaska’s new Portland-DCA frequency.

34 AS-D-1.

35 AS-D-1.
- 7 -

WASHINGTON/317737.3

now serves 56 communities on the West Coast.36 Alaska’s premier West Coast presence and

high-quality service has led many large U.S. and foreign carriers to pursue Alaska as a codeshare partner.37 This same West Coast network presence has contributed substantially to

Alaska’s Seattle and Los Angeles success and would do the same for Alaska’s proposed Portland

and San Diego services.

Alaska’s Portland service would represent a convenient, low-fare alternative to United’s

service, which now provides the only Portland-Washington D.C. flight and consists of a single

daily frequency to Dulles. United also carries a substantial number of Portland-Washington D.C.

passengers on connecting services and is the dominant Portland-Washington D.C. area carrier.

Alaska’s introduction of the first nonstop frequency to DCA would represent a significant

competitive improvement for these passengers.

Alaska’s claims about the competitive spur and stimulative effect of Alaska’s SeattleDCA nonstop service are more than borne out by the facts. Alaska has nearly doubled the annual

Seattle-DCA traffic level, from 123,000 to 240,000 passengers, since entering the market in

2001.38 Alaska’s current Seattle-DCA market share is 61 percent, more than twice the market

share of any individual carrier for the last calendar year prior to Alaska’s late 2001 entry.39

The competitive impact of Alaska’s single daily frequency in the Los Angeles-DCA

market has similarly resulted in Alaska achieving the number one market position with a 33%

market share.40 This is more than 10 points greater than the 22% share of American which

serves DCA on a connecting basis and is the second largest Los Angeles-DCA carrier. Alaska’s

36 These communities are in Alaska, British Columbia, California, Oregon, Washington, and coastal Mexico.

37 Air France, Air Pacific, American Airlines, Cathay Pacific, Delta Airlines, Era Alaska, Icelandair, Kenmore Air,

KLM, Korean Air, Lan, PenAir, and Qantas.

38 AS-D-14.

39 USDOT DB1B Data YE 3rd Quarter 2011 vs. YE 4th Quarter 2000.

40 USDOT DB1B Date YE 3rd Quarter 2011.
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WASHINGTON/317737.3

Seattle-DCA and Los Angeles-DCA market shares highlight the competitive impact of nonstop

service and the total effort Alaska invests in developing a new market.

Alaska’s success at Seattle has demonstrated the growing need for the first Portland-DCA

nonstop service. Alaska presently carries over 8,000 Portland-DCA passengers on Alaska’s

Seattle-DCA flights annually.41 Those passengers, however, have to vie with other connecting

passengers, as well as with local Seattle passengers, for increasingly scarce seats. With Alaska

operating at a 91% Seattle-DCA load factor for the 12 months ending November 2011, Alaska

cannot accommodate all of the passengers desiring to use its DCA service.42 Allowing Alaska to

inaugurate Portland-DCA nonstop service would provide Alaska’s Pacific NorthwestWashington D.C. passengers with an important new gateway and much needed relief.

In addition to highly convenient service, Alaska proposes to offer fares as low as $149 for

at least the first year of service, generating an estimated $5.5 million in passenger fare savings.43

This low fare offer, combined with all of the other benefits of Alaska’s proposals are certain to

make Alaska’s Portland-DCA service as successful as Alaska’s other DCA beyond-perimeter

services.

IV. SAN DIEGO-DCA NONSTOP SERVICE—THE LARGEST DCA MARKET WITHOUT

NONSTOP SERVICE

Alaska also proposes the first-ever nonstop service between San Diego and DCA.

Alaska’s San Diego-DCA frequency would originate and terminate in Honolulu, providing the

first ever single-plane service between Honolulu and DCA. Alaska commenced Honolulu-San

41 USDOT DB1B Data YE 3rd Quarter 2011.

42 Alaska’s Los Angeles-DCA nonstop service cannot practically function as an alternative for Portland-DCA

passengers. With that service operating at an average load factor of more than 88 percent, Portland passengers face

almost the same difficulties at Los Angeles that they now encounter at Seattle. It is also instructive to note that in the

context of a contested within-perimeter slot proceeding, the Department concluded that a carrier with a 77 percent

load factor was “more susceptible to passenger spill, particularly during peak periods.” Order 2007-5-12 at 14. At a

91 percent load factor, Alaska’s Seattle “spillage” more closely resembles a cascade.

43 AS-D-10.
- 9 -

WASHINGTON/317737.3

Diego service in November 2011. Linking Alaska’s existing Honolulu service with Alaska’s

proposed San Diego-DCA nonstop service would produce dramatic consumer benefits in two

major cities. In particular, it would offer service to close-in DCA for the large volume of

government traffic, including military, in this market. Alaska’s Honolulu-San Diego-DCA

service would be operated with dual-class 157 seat B-737-800 aircraft.44

Alaska’s Honolulu and San Diego eastbound schedule proposal is tailored to offer

Honolulu-originating passengers a late evening (9:35 PM) departure, allowing passengers to

spend a full final day in Honolulu. San Diego-originating passengers would receive a prime time

7:10 AM departure. In the westbound direction, Alaska’s flight would depart DCA at 4:10 PM

and arrive in San Diego at 6:55 PM.45 This flight would then depart San Diego for Honolulu at

8:25 PM, arriving at 11:30PM. With such attractive scheduling, Alaska’s DCA frequency would

provide substantial benefits to both the San Diego and Honolulu communities.

The San Diego-Washington D.C. area market, with 352,000 annual passengers, is the

largest West Coast beyond-perimeter O&D market not currently benefiting from nonstop service

to DCA.46 In addition to those San Diego passengers now using United’s nonstop service at

Dulles or Southwest’s to BWI, the latest O&D traffic data for the San Diego-DCA market

(IAD/DCA) indicate there are approximately 187,000 passengers currently forced to use even

less convenient connecting service.47 Combining all the San Diego passengers who would prefer

nonstop service to DCA with the more than 123,000 annual Honolulu-Washington D.C.48

passengers who now have to use single and double connecting service demonstrates the very

44 Alaska presently operates 134 weekly West Coast-Hawaii roundtrip flights with B-737-800 aircraft. Alaska

currently has the necessary B-737-800 aircraft in its fleet to operate the proposed services. Alaska also has 23

additional B-737-800 aircraft on firm order.

45 AS-D-1.

46 AS-D-2.

47 AS-D-3.

48 AS-D-2.
- 10 -

WASHINGTON/317737.3

substantial need of both San Diego and Honolulu for DCA service. Alaska’s Honolulu-San

Diego proposal would uniquely provide important new competition to both Southwest and

United; it would also satisfy the undeniable need of the largest market to Washington D.C.

without nonstop service to DCA.49

Alaska estimates that it would carry slightly in excess of 100,000 passengers during its

first normalized year of service. Alaska would also offer San Diego-DCA fares as low as $159

for at least the first year of service, providing an estimated $10.6 million in passenger fare

savings. Approximately two-thirds of current San Diego-Washington D.C. area travelers now

rely on United or Southwest.50 With Alaska’s proven ability to operate DCA beyond-perimeter

service and to garner a significant share of the overall market, Alaska’s proposed nonstop service

would represent a significant competitive stimulus to counter those two carriers’ current market

dominance.

V. ALASKA’S REMARKABLY EFFICIENT USE OF ITS DCA SLOTS AND SYSTEMWIDE

ACHIEVEMENTS LEND SUBSTANTIAL SUPPORT FOR ALASKA’S PORTLAND AND SAN

DIEGO PROPOSALS.

Having to operate with just three DCA roundtrips for the past 8 years, the lowest level of

any incumbent DCA carrier with only one exception,51 Alaska has nonetheless successfully

managed to make extraordinary use of its six DCA slots. The magnitude of Alaska’s slot

handicap at DCA is readily apparent from the following table:

49 AS-D-2.

50 USDOT DB1B YE 3rd Quarter 2011 Data.

51 Sun Country with one within-perimeter roundtrip is the one DCA carrier with fewer than 6 slots.
- 11 -

WASHINGTON/317737.3

U.S. Carrier

DCA Operated Slots52

US Airways 308*

Frontier/Republic 123*

American 87*

Delta 75*

United 46*

Jet Blue 34

Southwest 24

Shuttle America 14

Spirit 6

Alaska 6*

*Existing or Announced Beyond-Perimeter Carriers

Yet in spite of Alaska’s disadvantages, Alaska:

 Operates its DCA flights at a 90% load factor, higher than any other DCA carrier;53 and

 Has the highest DCA completion factor of any DCA carrier;54

Alaska’s exceptional track record at DCA is an extension of Alaska’s systemwide

accomplishments, most notably -

 Alaska has the highest on-time performance among all of the major network carriers;55

and

 Alaska has grown 71% since September 2000 in contrast to the overall industry’s 13%

reduction in domestic operations.56

These significant accomplishments can in part be traced to the excellent relationship

Alaska enjoys with its various employee groups. Alaska has not only avoided work disruptions,

but more importantly, it holds the distinction of being the only network carrier not to have filed

for bankruptcy. While Alaska’s employees have made many sacrifices, they have been spared

52 FAA Office of Slot Administration.

53 AS-D-11.

54 AS-D-13.

55 AS-D-15.

56 OAG Schedule Information.
- 12 -

WASHINGTON/317737.3

the considerable difficulties associated with major job losses, pension terminations and dramatic

service cutbacks.

By any objective measure, Alaska’s exemplary across-the-board record weighs in favor

of Alaska’s selection to serve Portland and San Diego.

VI. ALASKA’S AWARD-WINNING SERVICE AND FREQUENT FLIER PROGRAM PROVIDE A

STRONG FOUNDATION FOR THE SUCCESS OF ALASKA’S PROPOSED SERVICE.

Alaska is proud that in 2011 it received a number of prestigious industry awards, attesting

to the strength and attractiveness of Alaska’s service. These include:

1. J.D. Power & Associates: Highest in customer satisfaction among traditional

North American network carriers. (four years in a row)

2. Executive Travel: Best Domestic Frequent-Flier Program.

3. Air Transport World: The 2011 Airline Technology Leadership Award

recognized Alaska’s record of innovation in flight safety, airport operations, ticket distribution,

marketing and customer technology.

4. Air Transport World: The 2012 Joseph S. Murphy Industry Service Award.

5. FlightStats: #1 North American Major On-Time Performance. (20120 and 2011)

6. FAA Diamond Award, 2001-2011, recognized Alaska’s commitment to aircraft

maintenance and training excellence. (ten years in a row)

VII. A BROAD ARRAY OF POLITICAL, CIVIC AND EMPLOYEE INTERESTS VOICE SUPPORT

FOR ALASKA’S PORTLAND AND SAN DIEGO PROPOSALS.

Alaska is proud and appreciative that the entire Congressional Delegations of the states of

Oregon, Washington and Alaska agree that Alaska’s Portland-DCA nonstop proposal would

confer significant benefits on the residents of their respective states and that the Department
- 13 -

WASHINGTON/317737.3

should approve Alaska’s Portland-DCA proposal.57 Alaska has also received support for its

Portland proposal from the Honorable John Kitzhaber, Governor of Oregon, The Honorable Sam

Adams, Mayor of Portland, and the Honorable Timothy Leavitt, Mayor of Vancouver, WA.

Alaska’s San Diego proposal has been endorsed by the San Diego County Regional Airport

Authority, the San Diego Regional Chamber of Commerce and the San Diego Regional

Economic Development Corporation. Alaska is also particularly pleased to have support from its

own employees – Alaska’s ALPA MEC and the national AMFA. Alaska is confident that these

endorsements will be followed by similar expressions of support from Southern California,

Hawaii and other state and local governmental offices. Businesses and residents will further

attest to the confidence these interests have in the quality and reliability of Alaska’s services.

The Department can be assured that Alaska would apply the same low-fare, high quality service

formula it has successfully used at Seattle and Los Angeles to its newly proposed services from

Portland and San Diego.

In conclusion, for all the foregoing reasons, Alaska Airlines, Inc. hereby requests that the

Department grant it slot exemptions to permit the services to Portland and San Diego described

in this application, and that the Department grant such other and further relief as it may deem

appropriate.

57 Exhibit AS-D-18 includes all of the referenced letters of support. Alaska will supplement the record when

additional letters are received.
- 14 -

WASHINGTON/317737.3

Respectfully submitted,

________________________________

Marshall S. Sinick, Esq.

Marshall.sinick@squiresanders.com

Edward W. Sauer, Esq.

Edward.sauer@squiresanders.com

Squire Sanders (US) LLP

1200 19th Street, NW

Washington, DC 20036

(202) 626-6651
- 15 -

WASHINGTON/317737.3

CERTIFICATE OF SERVICE

I hereby certify that one copy of the foregoing Application of Alaska Airlines, Inc. for

Exemptions has this day been served on each of the following individuals via telecopier or email.

susan.kurland@dot.gov; todd.homan@dot.gov; james.dann@dot.gov

john.allen@faa.gov

dan.weiss@coair.com; steve.morrissey@united.com; jonathan.linde@united.com

rbkeiner@crowell.com

carl.nelson@aa.com

sascha.vanderbellen@delta.com; jeff.morgan@delta.com

jhill@dlalaw.com; robert.land@jetblue.com

jyoung@yklaw.com; dkirstein@yklaw.com

robert.kneisley@wnco.com; leslie.abbott@wnco.com

john.varley@virginamerica.com

howard.kass@usairways.com; benjamin.slocum@usairways.com

john.fredericksen@suncountry.com

agoerlich@ggh-airlaw.com

patrick.rizzi@hoganlovells.com

rick.finn@portofportland.com

hbrown@san.org

Michael.Daum@cantwell.senate.gov

Alexandra.Hackbarth@wyden.senate.gov

James.Feldman@begich.senate.gov

______________________________

Marshall S. Sinick

DATED: March 12, 2012
APPLICATION OF ALASKA AIRLINES, INC. FOR EXEMPTIONS

Appendix and Supporting Exhibits
Application of Alaska Airlines, Inc. for Exemptions

AS-D-1: Alaska Proposed Portland And San Diego Schedule

AS-D-2: San Diego & Portland Are The Largest Markets Without Nonstop Service To

DCA

AS-D-3: San Diego/Honolulu-& Portland Have Amongst The Highest Number Of

Passengers That Have To Make Connections To Washington, DC

AS-D-4: Alaska Has The Premier Portland Hub Presence – Serving 33 Beyond Cities

AS-D-5: Alaska’s Proposed Portland-DCA Nonstop Service Will Connect Passengers To

10 Cities Beyond PDX

AS-D-6: Alaska Is San Diego’s Fastest Growing Airlines And Is Now Well Positioned To

Serve DCA

AS-D-7: Alaska Brings Lower Fares To Washington, DC

AS-D-8: Alaska’s Low DCA Fares Generate Millions In Passenger Savings

AS-D-9: Alaska Would Continue Trend Of Low Fares In DCA-PDX And DCA-SAN

AS-D-10: Alaska’s Low Fares In DCA-PDA/SAN Will Save Consumers Over $16M

Annually

AS-D-11: Alaska Airlines Has The Highest Load Factor In DCA – 90%

AS-D-12: Pacific Northwest Has The Highest Load Factor To Washington, DC In The

United States

AS-D-13: Alaska Is The Most Reliable Of Any Carriers At DCA

AS-D-14: Not used

AS-D-15: Alaska Has The Second Highest On-Time Performance Of All Reporting Carriers

In The United States

AS-D-16: Alaska Has The Second Lowest Rate Of Consumer Complaints Of Any Reporting

Carriers In The United States

AS-D-17: Alaska’s Commitment To Low Fares Is Demonstrated By Growth In The West

Coast-Hawaii Market Alaska Has Averaged The Lowest Fares From The West

Coast To Hawaii In Each Of The Last 6 Quarters

AS-D-18: Support Letters
Departure Airport Departure Time Arrival Airport Arrival Time

DCA 17:35 PDX 20:25

PDX 10:10 DCA 18:10

Departure Airport Departure Time Arrival Airport Arrival Time

DCA 16:10 SAN 18:55

SAN 20:25 HNL 23:30

HNL 21:35 SAN 6:10

SAN 7:10 DCA 15:10

Notes:

Boeing 737‐800 aircraft (157 Seats)

Flights to begin within 90 days of the Department's final order

Westbound

Eastbound

AS‐D‐1: Alaska Proposed Portland and San Diego Schedule

DCA‐PDX Schedule

DCA ‐ SAN Schedule

With continuing, single‐plane service to Honolulu
AS‐D‐2: San Diego & Portland Are The Largest Markets Without NonStop

Service to DCA

Annual Passengers to Washington D.C. (DCA/IAD)

352k

186k 186k

163k 148k

128k 127k 125k 112k 110k

0k

50k

100k

150k

200k

250k

300k

350k

400k

Notes:

Source: Department of Transportation O&D Data ‐ Year‐End Q3 '11

Local Market Passengers to DCA/IAD

SFO excluded ‐ United Begins Daily Service 5/14/2012

352k

186k 186k

163k 148k

128k 127k 125k 112k 110k

0k

50k

100k

150k

200k

250k

300k

350k

400k
AS‐D‐3:  San Diego/Honolulu & Portland Have Amongst The Highest Number

of Passengers That Have to Make Connections to Washington D.C.

   Annual Passengers  ‐ Connecting Traffic to Largest D.C. Markets Without DCA Service

187k

137k 142k 121k

73k 92k 93k 123k

7k

102k

165k

49k 44k

42k

75k 35k 33k

1k

105k

8k

0k

50k

100k

150k

200k

250k

300k

350k

Connecting PAX

Nonstop / One‐Stop PAX

Notes:

Source: Department of Transportation O&D Data ‐ Year‐End Q3 '11

Local Market Passengers to DCA/IAD

SFO excluded ‐ United Begins Daily Service 5/14/2012

187k

137k 142k 121k

73k 92k 93k 123k

7k

102k

165k

49k 44k

42k

75k 35k 33k

1k

105k

8k

0k

50k

100k

150k

200k

250k

300k

350k

Connecting PAX

Nonstop / One‐Stop PAX
AS‐D‐4: Alaska Has the Premier Portland Hub Presence ‐ Serving 33 Beyond Cities

Anchorage

Billings

Bellingham

Boise

Boston

Bozeman

Eugene

Fresno

Spokane

Honolulu

Kona

Las Vegas

Medford

Missoula

Oakland

Maui

Ontario

Chicago

Phoenix

Palm Springs

Redmond

San Diego

Santa Barbara

Seattle

San Francisco

San Jose

Sacramento

Orange County

Santa Rosa

Vancouver

PDX Washington DC*

Notes:

Source: OAG Schedule for 2012

*Application for Slots

Anchorage

Billings

Bellingham

Boise

Boston

Burbank

Bozeman

Eugene

Fresno

Spokane

Honolulu

Kona

Las Vegas

Los Angeles

Long Beach

Medford

Missoula

Oakland

Maui

Ontario

Chicago

Phoenix

Palm Springs

Redmond

San Diego

Santa Barbara

Seattle

San Francisco

San Jose

Sacramento

Orange County

Santa Rosa

Vancouver

PDX Washington DC*
AS‐D‐5: Alaska's Proposed Portland‐DCA Nonstop Service Will Connect Passengers to 10 C

Bellingham

Spokane

Medford

Eugene

San Francisco

San Jose

Anchorage Vancouver

Seattle

Redmond

D

PDX

Notes:Source: OAG Schedule for Summer 2012 Adjusted for Non‐Stop DCA‐PDX Service

Roundtrip Connections Based on Circuity of 1.3 or less and roundtrip connections, max connect time of 4 hours

*Application for Slots

Bellingham

Spokane

Medford

Eugene

San Francisco

San Jose

Anchorage Vancouver

Seattle

Redmond

D

PDX
AS‐D‐6: Alaska Is San Diego's Fastest Growing Airline and Is Now Well

Positioned to Serve DCA

Fall 2010

F ll 2012

Seattle

Portland

Los Cabos

SAN

Notes:

Source: OAG Schedule September 2012 vs. September 2010

*Application for Slots

Fall 2012

Seattle

Portland

Los Cabos

Seattle

Portland

Los Cabos

Santa Rosa

Honolulu

Maui

Puerto Vallarta

Fresno

Monterey

DCA*

SAN

SAN
AS‐D‐7: Alaska Brings Lower Fares to Washington D.C.

AS Nonstop DCA Fare $201 AS Nonstop DCA Fare $256

UA Nonstop IAD Fare $266 UA Nonstop IAD Fare $318

Savings $ (each way) $65 Savings $ (each way) $62

Savings % (each way) 24% Savings % (each way) 19%

Notes:

Source: Department of Transportation O&D Data ‐ Year‐End Q3 '11 (excludes taxes and fees)

Los Angeles Seattle
AS‐D‐8: Alaska's Low DCA Fares Generate Millions in Passenger Savings

Local PAX EW/Day 186 Local PAX EW/Day 96 Local PAX EW/Day 282

Conx. PAX EW/Day 91 Conx. PAX EW/Day 26 Conx. PAX EW/Day 117

Total PAX EW/Day 277 Total PAX EW/Day 122 Total PAX EW/Day 399

AS Local Fare $256 AS Local Fare $201 AS Local Fare $237

AS Flow Fare $316 AS Flow Fare $238 AS Flow Fare $299

AS Average Fare $276 AS Average Fare $209 AS Average Fare $255

IAD Local Fare $314 IAD Local Fare $235 IAD Local Fare $287

IAD Flow Fare $401 IAD Flow Fare $296 IAD Flow Fare $378

IAD Average Fare $343 IAD Average Fare $248 IAD Average Fare $314

Annual Savings $14m Annual Savings $3m Annual Savings $17m

Savings per Pax $67 Savings per Pax $39 Savings per Pax $58

Percent Savings 20% Percent Savings 16% Percent Savings 19%

Notes:

Source: Department of Transportation O&D Data ‐ Year‐End Q3 '11 (excludes taxes and fees)

IAD Local Fare Based on Industry Average Local Fare to IAD in Non‐Stop/One‐Stop Itineraries

IAD Flow Fare Based on Industry Average Fare Weighted for AS Traffic on DCA‐LAX/SEA

Industry Fares in IAD

Consumer Savings

DCA‐SEA DCA‐LAX DCA Combined

Traffic Detail

Alaska Average Fares
Peak Days $169 Peak Days $179

Off‐Peak Days $149 Off‐Peak Days $159

The Alaska Tradition of Low Fares

Proposed Fares in DCA‐PDX and DCA‐SAN

DCA‐PDX DCA‐SAN

AS‐D‐9: Alaska Would Continue Trend of Low‐Fares in DCA‐PDX and DCA‐SAN

Notes:

Source: Alaskaair.com Advertisements Last 12 Months Ended March 2012
AS‐D‐10: Alaska's Low Fares in DCA‐PDX/SAN Will Save Consumers Over $16m Annually

Annual Pax 103k Annual Pax 101k Annual Pax 204k

Savings per Pax $53 Savings per Pax $105 Savings per Pax $79

Annual Savings $5.5m Annual Savings $10.6m Annual Savings $16.1m

Savings Percent 18% Savings Percent 31% Savings Percent 24%

Notes:

Source: Department of Transportation O&D Data ‐ Year‐End Q3 '11 (excludes taxes and fees)

Alaska Passenger Traffic and Local Fare Are Based on Forecast Performance in PDX/SAN‐DCA and Experience in LAX/SEA‐DCA

Local Consumer Savings are Based on Alaska Fare vs. Industry Non‐Stop/One‐Stop Fare in IAD‐PDX/SAN

Connecting Consumer Savings Based on Average Experience in DCA‐LAX/SEA for Year‐End Q3'11

DCA‐PDX DCA‐SAN Combined
AS‐D‐11: Alaska Airlines Has the Highest Load Factor in DCA ‐ 90%

Average Load Factor by Carrier in DCA ‐ YE Nov '11

90%

84% 83% 81%

78% 77% 75% 74%

69% 69% 68%

57%

75%

30%

40%

50%

60%

70%

80%

90%

Notes:

Source: Department of Transportation ‐ T‐100 Data ‐ Year‐End Nov '11

Includes all DCA Flying by Marketing Carrier (non‐directional)
AS‐D‐12: Pacific Northwest Has the Highest Load Factor to Washington D.C. in United Stat

91%

87%

73%

6

87% 71%

Notes:Source: Department of Transportation ‐ T‐100 Data ‐ Year‐End Nov '11

Industry Load Factors by Region for both IAD/DCA

91%

87%

79% 76%

73%

6

87% 71%
AS‐D‐13: Alaska is the Most Reliable of Any Carrier at DCA

DCA Completion Factor by Airline ‐ YE Dec '11

99.4%

99.0% 98.6% 98.6%

97.8% 97.8%

97.0% 97.0%

96.4% 96.1%

93.4%

92.7% 92.7%

96.7%

88%

90%

92%

94%

96%

98%

100%

Notes:

Source: US DOT On‐Time Performance Data ‐ Year‐End Dec '11 (non‐directional)

Includes Carriers Required to Report Data

99.4%

99.0% 98.6% 98.6%

97.8% 97.8%

97.0% 97.0%

96.4% 96.1%

93.4%

92.7% 92.7%

96.7%

88%

90%

92%

94%

96%

98%

100%
AS-D-14:Not Used
AS‐D‐15: Alaska Has the Second Highest On‐Time Performance of All

Percent of Flights Arriving On‐Time JAN‐DEC'11

Airline Percent Rank

HAWAIIAN 92.8 1

ALASKA 88.2 2

AIRTRAN 84.4 3

MESA 83.7 4

DELTA 82.3 5

SOUTHWEST 81.3 6

UNITED 80.2 7

US AIRWAYS 79.8 8

SKYWEST 79.3 9

FRONTIER 79.2 10

AMERICAN 77.8 11

CONTINENTAL 77.1 12

AMERICAN EAGLE 76.3 13

ATLANTIC SOUTHEAST 75.2 14

EXPRESSJET 74.7 15

JETBLUE 73.3 16

Notes:

Source: DOT Air Travel Consumer Report Issued Feb 2012

Reporting Carriers in the United States
AS‐D‐16: Alaska Has the Second Lowest Rate of Consumer Complaints of Any

Complaints Per 100k Enplanements JAN‐DEC'11

Airline Complaints/ 100k Rank

SOUTHWEST 0.32 1

ALASKA 0.48 2

MESA 0.62 3

HAWAIIAN 0.7 4

AIRTRAN 0.72 5

SKYWEST 0.73 6

FRONTIER 0.76 7

ATLANTIC SOUTHEAST 0.88 8

EXPRESSJET 1.04 9

JETBLUE 1.08 10

DELTA 1.23 11

AMERICAN EAGLE 1.45 12

AMERICAN 1.46 13

CONTINENTAL 1.81 14

US AIRWAYS 1.91 15

UNITED 2.21 16

Notes:

Source: DOT Air Travel Consumer Report Issued Feb 2012

Reporting Carrier in the United States
AS‐D‐17: Alaska's Commitment to Low Fares is Demonstrated by Growth in the West Coas

Industry Average Fare ‐ West Coast  ‐ Hawaii by Quarter

2010 Q2 2010 Q3 2010 Q4 2011 Q1 2011 Q2 

Alaska $228 $220 $239 $232 $252 

Hawaiian $262 $258 $271 $261 $301 

Delta $232 $238 $266 $266 $284 

American $265 $276 $269 $274 $307 

United $263 $270 $290 $303 $320 

Total $255 $257 $269 $265 $293 

AS v. Avg. ($27) ($36) ($30) ($34) ($41) 

Lowest Fare

Alaska Has Averaged the Lowest Fares from the West Coast to Hawaii In Each of the Last 6 

$269

$293 

AS vs. Industry West Coast Hawaii Fares

AlaskaTotal

NotesSource: Department of Transportation ‐ DB1B Data ‐ Through Sep '11

Includes WA, OR, CA‐ Excludes free passengers in addition to taxes and fees

$228

$220

$239

$232

$252

$255 $257

$269

$265

$293 

2010 Q2 2010 Q3 2010 Q4 2011 Q1 2011 Q2 

AS vs. Industry West Coast Hawaii Fares

AlaskaTotal
AS-D-18: Support Letters
OFFICE OF MAYOR SAM ADAMS 


Cm' OF PORllAND 


. March 6, 2012 

The Honorable Ray LaHood 

U.S. Department of Transportation 


1200 New Jersey Ave, SE 


Washington, DC 20590 


Re: Alaska Airlines' application for PDX-DCA; Docket No. DOT-OST-2012-0029. 

Dear Secretary laHood: 

I write in support the application of Alaska Airlines to provide one daily roundtrip flight 

between Portland International Airport (PDX) and Reagan National Airport (DCA). 

The Portland-Vancouver region is the second largest market to Washington DC, in terms of 

passengers per day, without nonstop service to DCA, and is the ideal candidate for such service. 

Currently, nonstop service from Oregon and Southwest Washington is limited to just a single 

daily flight between PDX and Washington Dulles (LAD). With nonstop service from PDX to 

DCA, the residents of Oregon and Southwest Washington will benefit from enhanced 

competition and no longer be forced to use less convenient and more time-consuming service to 

reach our nation's capital. 

Alaska Airlines and its regional sister carrier, Horizon Air, have a large hub presence at PDX, 

operating an annual average of more than 640 flights per week to 33 destinations. As a result, 

Alaska's nonstop flight would also improve service levels to Washington, DC for the Oregon 

cities of Eugene, Medford and Redmond, in addition to the greater Portland region. 

Importantly, Alaska has a strong customer service focus, reliable operational performance and 

financial strength, and the region is fortunate to have an asset in the best performing airline in 

the country. These qualities make Alaska the ideal carrier to provide Oregon and Southwest 

Washington residents with their first nonstop service to DCA .. 

I respectfully urge you to grant Alaska Airlines' application to provide PDX-DCA service. 


Thank you for your consideration. 


Sincerely, 

8-$­

Sam Adams 

Mayor 

1221 SW FOURTH AV8'lUE, SUITE 340 +PORTLAND, OREGON 97204 

(503) 823-4120 +mayorsamadams.com 
JOHN A. KITZHABER, MD

Governor

March 8, 2012

The Honorable Ray LaHood

U.S. Department of Transportation

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Alaska Airlines' Application for PDX-DCA; Docket No. DOT-OST-2012-0029.

Dear Secretary LaHood:

I am writing to express my strong support for Alaska Airlines' application to provide one daily roundtrip

flight between Reagan National Airport (DCA) and Portland International Airport (PDX).

Alaska Airlines' proposed service between Portland and Reagan National Airport fully satisfies the

criteria specified for the new slot exemptions at DCA in the FAA Modernization and Reform Act of2012.

The Portland-Vancouver region is the second largest market to Washington DC, in terms of passengers

per day, without nonstop service to DCA. Currently, nonstop service from Oregon/southwest

Washington is limited to just a single daily flight between PDX and Washington Dulles (lAD). With

nonstop service from PDX to DCA, Oregon/southwest Washington residents will benefit from enhanced

competition, lower fares, and additional choices. Moreover, they would no longer be forced to use less

convenient and more time-consuming service to reach our nation's capital.

Alaska Airlines and its regional sister carrier, Horizon Air, have a large hub presence at PDX, operating

an annual average of more than 640 flights per week to 33 destinations. As a result, Alaska's nonstop

flight would also improve service levels to Washington, DC for the Oregon cities of Eugene, Medford and

Redmond, in addition to the greater Portland-Vancouver region. Enhanced air service for these smaller

cities in Oregon is especially important for their economic development.

Alaska Airlines has a strong customer service focus, reliable operational performance, and financial

strength. The State of Oregon enjoys comprehensive access to the best performing airline in the country.

These qualities make Alaska the ideal carrier to provide Oregon/southwest Washington residents with

their first nonstop service to DCA.

I respectfully urge you to grant Alaska Airlines' application to provide PDX-DCA service. Thank you for

your consideration.

254 STATE CAPITOL, SALEM OR 97301-4047 (503) 373-3111 FAX (503) 378-4863

WWW.OREGON.GOV


___________________________________________________________________________________________________ 

Vancouver City Council 

Mayor Timothy D. Leavitt • Jeanne Harris • Jeanne E. Stewart • Larry J. Smith • Jack Burkman • Bart Hansen • Bill Turlay 

City Manager Eric Holmes

City of Vancouver • P.O. Box 1995 • Vancouver, WA 98668-1995 ______________________________________________________________________________________________________________________________________________ 

www.cityofvancouver.us

March 7, 2012

The Honorable Ray LaHood

U.S. Department of Transportation

1200 New Jersey Ave, SE

Washington, DC 20590

Re:  Alaska Airlines’ application for PDX‐DCA; Docket No. DOT‐OST‐2012‐0029.   

Dear Secretary LaHood:

This letter is in support of the application of Alaska Airlines to provide one daily roundtrip flight between Reagan

National Airport (DCA) and Portland International Airport (PDX).

The Portland‐Vancouver region is the second largest market to Washington DC, in terms of passengers per day,

without nonstop service to DCA.  It is the ideal candidate for such service.  Currently, nonstop service from

Oregon/Southwest Washington is limited to just a single daily flight between PDX and Washington Dulles (IAD).  

With nonstop service from PDX to DCA, Oregon/Southwest Washington residents will benefit from enhanced

competition and more efficient access to our nation’s capital.

Alaska Airlines and its regional sister carrier, Horizon Air, have a large hub presence at PDX, operating an annual

average of more than 640 flights per week to 33 destinations.  As a result, Alaska’s nonstop flight flights bring

the East Coast, especially the thriving technology sector, to within a direct jump and helps with both business

recruitment and retention of existing businesses.  We’re especially looking to recruit from the IT sector, which is

strong in the D.C. area, and a single direct flight makes the East Coast more accessible.

Finally, Alaska Airlines is one of the best performing airlines in the country.  We encourage providing such critical

opportunities to such companies.   I respectfully urge you to grant Alaska Airlines’ application to provide PDX‐

DCA service.  Thank you for your consideration.

Sincerely,

Mayor Timothy D. Leavitt

City of Vancouver


AIRCRAFT MECHANICS FRATERNAL ASSOCIATION

AMFA National Office: 14001 E. Iliff Ave, Suite 217 Aurora, Colorado 80114

Phone: (303) 752-2632 Fax: (303) 362-7736

National Director’s Office: Telephone (720)-744-6628

Email: Louie.Key@amfanatl.org

SAFETY IN THE AIR BEGINS WITH QUALITY MAINTENANCE ON THE GROUND

March 6, 2012

The Honorable Ray LaHood

U.S. Department of Transportation

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Alaska’s application for PDX-DCA and SAN-DCA service, Docket No. DOT-OST-2012-

0029. 

Dear Secretary LaHood:

On behalf of the Aircraft Mechanics Fraternal Association, the union that represents the 

mechanics in the service of Alaska Airlines, I am writing in support of the application of Alaska 

Airlines to provide one daily roundtrip flight between Washington Reagan National Airport 

(DCA) and Portland International Airport (PDX) and one daily roundtrip flight between DCA 

and San Diego International Airport (SAN). The company has indicated that PDX is its priority 

route, and we concur with that approach. 

Alaska Airlines has a proven track record of strong customer service and operational reliability, 

which is a testament to the hard work and dedication of its employees. Importantly, the 

company is also financially strong. It is worth mentioning that Alaska is the only established 

network carrier to not have declared bankruptcy. These factors all speak to the ability of Alaska 

Airlines to provide maximum consumer benefits to PDX-DCA and SAN-DCA nonstop 

travelers.

The Portland-Vancouver region is the second largest market to Washington DC without a 

nonstop route to DCA and is the ideal candidate for such service. Nonstop service from 

Oregon/southwest Washington is limited to just a single daily flight between PDX and 

Washington Dulles (IAD). With a direct route from PDX to DCA, Oregon/southwest 

Washington residents will benefit from enhanced competition and no longer be forced to use 

less convenient and more time-consuming service to reach our nation’s capital.

Alaska Airlines and its regional sister carrier, Horizon Air, have a large hub presence at PDX, 

operating an annual average of more than 640 flights per week to 33 destinations. As a result, 

Alaska’s nonstop flight would also improve service levels to Washington, D.C. for the Oregon 

cities of Eugene, Medford and Redmond, in addition to the greater Portland-Vancouver region.

San Diego is currently the largest market to Washington DC without a nonstop route to DCA. 

A direct route from SAN to DCA will provide residents of Southern California, particularly 
SAFETY IN THE AIR BEGINS WITH QUALITY MAINTENANCE ON THE GROUND

those in the San Diego metropolitan region, with much more convenient access to our nation’s 

capital. Alaska Airlines is growing its presence in San Diego, recently adding four new 

destinations to its SAN network. By this summer, Alaska and its regional carrier, Horizon Air, 

will provide an average of 19 daily flights from SAN to nine destinations in the United States 

and Mexico. 

On behalf of our members, hard working Alaska Airlines employees, I respectfully urge you to 

grant Alaska Airlines’ application to provide PDX-DCA and SAN-DCA service. Thank you for 

your consideration.

Sincerely,

Louie Key

National Director
(tnngrexx uf fhB lilnit¿ù Stst¿s

îflfiurl¡ingtun, Eg, ¿t515

February 28, 20L2

The Honorable Ray LaHood

Secretary

U.S. Department of Transportation

L200 Ner¡¡ Jersey Avenue, SE

vlashington, Dc 2 0590

Dear Secretary LaHood:

vle are writing in support of the application submitted by Alaska

Airl-ines, Înc., to secure two of thê eight "beyond-perimeter slot"

exemptíons at Ronald Reagan National Airport (DCA) . Their application

would provide a daily nonstop roundtrip ftíght between DCA and Portland

International- Airport (PDx), as provided by the FAA Modernization and

Reform Act of 2012.

oregon is notoriously underserved for air service into Washington,

D.C. ft is one of the nost populated states 1ùithout nonstop service to

DcA, yet over 420 passengeïs fly betr¡reen Oregon and the Ûlashington, D.C.'

area in each ditection every daY.

Today, nonstop servíce from oregon is linited to a single united

Airlines frequency into vlashington Dulles (IAD) ' In order to f1y in or

out of DCA,. oregon residents have to rnake time consuming connections

through seattle' san Francisco, or through other circuítous points.

Consequently, we actívely supported efforts to increase the number of

beyond-perineter exemptions permitted at DCA so neÌ't entrants and limited

incumbent air carriers have the opportunity to provide direct flights

from the !\¡es t coast ínto DCA.

Alaska Airlines is Ì^re I I -pos itioned to provide oregonians with their

first nonstop service into DcA. Alaska and its regional carrier, Horizon

Air, have a substanÈial hub presence at PDX and currently operate more

than 90 fl-ights per day to 33 destinations. They are highly regarded for

theír customer service, financial strength, and operational performance.

Vle are pleased their proposed nonstop flight from PDX into DCA is the top

príority ln their applicatíon.

Please give their apptication ful-l and fair.consideration.
Sec. Ray LaHood

February 28, 20L2

Page 2

Sincerely,

Ha/^ united States Senator

lrn"** S-*'*

Suzanne Bonamici

Menber of congress

ted States Senator

rJ- uJ-umenauer

Membe.r of Congress

Kurt Schrader

Member of congress
Emerald Plaza

402 West Broadway, Suite 1000

San Diego, California 92101-3585

(619) 544-1300

www.sdchamber.org

March 8, 2012

The Honorable Ray LaHood

U.S. Department of Transportation

1200 New Jersey Ave, SE

Washington, DC 20590

Re: Alaska Airlines’ application for SAN-DCA, Docket No. DOT-OST-2012-0029. 

Dear Secretary LaHood:

This letter is in support of the application of Alaska Airlines to provide one daily round trip flight 

between Washington Reagan National Airport (DCA) and San Diego International Airport (SAN).

San Diego is the largest market to the Washington D.C. area without a nonstop route to DCA. A

direct route from SAN to DCA will provide residents of Southern California, particularly those 

in the greater San Diego region, with much more convenient access to our nation’s capital.

Alaska is growing its presence in San Diego, recently adding four new destinations to its SAN 

network. By this summer, Alaska and its regional carrier, Horizon Air, will provide an average 

of 19 daily flights from SAN to nine destinations in the United States and Mexico. Alaska’s is 

well suited to serve San Diego with nonstop service to DCA.

Direct service between DCA and SAN is an important link that will help with economic 

development, business investment and job creation in San Diego. Major San Diego industries 

including military/defense, technology and research & development depend on the connection 

between our region and our nation’s capital. Thousands of public and private sector travelers

would benefit from a direct flight.

I respectfully urge you to grant Alaska Airlines’ application to serve SAN-DCA. Thank you for 

your consideration.

Sincerely, 

Ruben Barrales

President & CEO 

San Diego Regional Chamber of Commerce