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 19 th 

### 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. I NTRODUCTION 

### 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:- 2 -

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; 5 

### and

 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

. A LASKA 

### ’ S 

### P ORTLAND 

### & S AN 

### D IEGO 

### S ERVICE 

### P ROPOSALS 

### M ORE 

### T HAN 

### M EET THE 

### FAA R EAUTHORIZATION 

### A CT 

### ’ S 

### S ELECTION 

### C RITERIA 

### . 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. P ORTLAND 

### -DCA N ONSTOP 

### S ERVICE 

### —A LASKA 

### ’ S 

### N UMBER 

### O NE PRIORITY AND 

### U RGENTLY NEEDED 

### S ERVICE 

### Alaska’s dual-class-configured B-737-800 service 28 

### would represent the first-ever
nonstop service in the market. Alaska estimates that it would carry approximately 103,000 29


### 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 3 rd Quarter 2011 vs. YE 4th Quarter 2000. 40 USDOT DB1B Date YE 3 rd Quarter 2011.- 8 -

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



### T his 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. S AN 

### D IEGO 

### -DCA N ONSTOP 

### S ERVICE 

### —T HE LARGEST 

### DCA M ARKET 

### W ITHOUT 

### N ONSTOP 

### S ERVICE 

### 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 3 rd 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. A LASKA 

### ’ S 

### R EMARKABLY 

### E FFICIENT 

### U SE 

### O F 

### I TS 

### DCA S LOTS AND 

### S YSTEMWIDE 

### A CHIEVEMENTS 

### L END 

### S UBSTANTIAL 

### S UPPORT 

### F OR 

### A LASKA 

### ’ S 

### P ORTLAND AND 

### S AN 

### D IEGO 

### P ROPOSALS 

### . 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 3 rd 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 Slots 52 

### 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. A LASKA 

### ’ S 

### A WARD 

### -W INNING 

### S ERVICE 

### A ND 

### F REQUENT 

### F LIER 

### P ROGRAM 

### P ROVIDE A 

### S TRONG 

### F OUNDATION FOR 

### T HE 

### S UCCESS OF 

### A LASKA 

### ’ S 

### P ROPOSED 

### S ERVICE 

### . 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 B ROAD 

### A RRAY OF 

### P OLITICAL 

### , C IVIC AND 

### E MPLOYEE 

### I NTERESTS 

### V OICE 

### S UPPORT 

### F OR 

### A LASKA 

### ’ S 

### P ORTLAND AND 

### S AN 

### D IEGO 

### P ROPOSALS 

### . 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 19 th 

### 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 LettersDeparture Airport Departure Time A rrival Airport A rrival Time DCA 17:35 PDX 20:25
PDX 10:10 DCA 18:10

Departure Airport Departure Time A rrival Airport A rrival 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

Washington DC* 

# PDX

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

Washington DC* 

# PDXAS‐D‐5:Alaska'sProposedPortland‐DCANonstopServiceWillConnectPassengersto10CitiesBeyondPDXBellinghamSpokaneMedfordEugeneSanFranciscoSanJoseAnchorageVancouverSeattleRedmondDCA*PDXNotes:Source:OAGScheduleforSummer2012AdjustedforNon‐StopDCA‐PDXServiceRoundtripConnectionsBasedonCircuityof1.3orlessandroundtripconnections,maxconnecttimeof4hours*ApplicationforSlotsBellinghamSpokaneMedfordEugeneSanFranciscoSanJoseAnchorageVancouverSeattleRedmondDCA*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 Detai l

A laska Average FaresPeak 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

‐ SAN DCA

‐ PDX 

## 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

A nnual Pa x 103k A nnual Pa x 101k A nnual Pa x 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:PacificNorthwestHastheHighestLoadFactortoWashingtonD.C.inUnitedStates91%87%73%68%71%87%Notes:Source:DepartmentofTransportation‐T‐100Data‐Year‐EndNov'11IndustryLoadFactorsbyRegionforbothIAD/DCA91%87%79%76%73%68%71%87%

## 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 SOUTHEAS T 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 SOUTHEAS T 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 StatesAS‐D‐17:Alaska'sCommitmenttoLowFaresisDemonstratedbyGrowthintheWestCoast‐HawaiiMarketIndustryAverageFare‐WestCoast‐HawaiibyQuarter2010Q2 2010Q3 2010Q4 2011Q1 2011Q2 2011Q3Alaska $228 $220 $239 $232 $252 $260Hawaiian $262 $258 $271 $261 $301 $296Delta $232 $238 $266 $266 $284 $277American $265 $276 $269 $274 $307 $296United $263 $270 $290 $303 $320 $317Total $255 $257 $269 $265 $293 $292ASv.Avg.($27) ($36) ($30) ($34) ($41) ($32)LowestFareAlaskaHasAveragedtheLowestFaresfromtheWestCoasttoHawaiiInEachoftheLast6Quarters$269$293$292ASvs.IndustryWestCoastHawaiiFaresAlaskaTotalNotesSource:DepartmentofTransportation‐DB1BData‐ThroughSep'11IncludesWA,OR,CA‐Excludesfreepassengersinadditiontotaxesandfees$228$220$239$232$252$260$255$257$269$265$293$2922010Q2 2010Q3 2010Q4 2011Q1 2011Q2 2011Q3ASvs.IndustryWestCoastHawaiiFaresAlaskaTotal

# AS-D-18: Support LettersOFFICE 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.comJOHN 

### 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 Aur ora, 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 , 201 2
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 Portl and International Airport (PDX) and one daily roundtrip flight between DCA and San Diego International Airport (SA N). 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 it s 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 co nsumer 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 Washin gton 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 mor e 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 6 4 0 flights per week to 33 destinations. As a result, Alaska’ s nonstop flight would also improve serv ice 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 nons top route to DCA

. A direct route from SAN to DCA will provide residents of Southern California, particularlySAFETY 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 u rge 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 congressEmerald Plaza 402 W est 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