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### CAPITAL REGION AIRPORT AUTHORITY

Chris Holman Chai rman Dick Baker Victor Celentino Samantha Harkins John Shaski Greg Ward Robe rt F Selig, AAE President

- CEO April 22, 2016 VIA EMAIL AND REGULATIONS.GOV Reginald C
. Govan, ChiefCounsel Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20591 Re: JetBlue Petition for Reconsideration and Request for Backup Authority Docket FAA-2015-3491 Dear ChiefCounsel Govan: On March 31 , 2016, the Federal Aviation Administration ("FAA " ) granted an exemption to American 1 to reinstate nonstop service between Lansing, Michigan' s, Capital Region International Airport ("LAN") and Ronald Reagan Washington National Airport ("DCA" ). 2 The FAA granted this exemption based on the overwhelming public interest associated with continuing nonstop DCA service for the Mid-Michigan region, whose residents had come to rely on and expected to continue until at least 2019. 3 The Lansing Exemption ensures that the Greater Lansing Community would have stable, reliable nonstop air service to Washington, DC

- Mid-Michigan ' s top business travel destination

- at least through at least June 2018. This, in tum, will stimulate business , grow tourism, and ease travel for Central Michigan residents and visitors. JetBlue now seeks to further disrupt LAN-DCA service, hanning the Greater Lansing Community in the process , with requests for both reconsideration ofthe Lansing Exemption and an award ofback-up authority which would allow it to serve a different community. 4 The Capital Region Airport Authority ("CRAA " ) opposes both ofthese requests by JetBlue as being detrimental to LAN travelers and the Greater Lansing Community.

1 Common names are used for air carriers. 2 See Exemption Nos. 15867 and 15869 , Dockets FAA-20 15-3491 and -3932, March 31,2016 (" Lansing Exemption"). 3 See Lansing Exemption, p . 7. 4 See Letter ofJetBiue re : Petition for Reconsideration and Request for Backup Authority, April 12 , 2016 ( " JetBlue Letter").

Capital Region International Airport + 4100 Capital City Blvd. + Lan sing, Mic higan 48906 + 517

-321-6121 + Fax 517-321

- 6197 www.fl yla nsing. comReginald C. Govan, Esq. April 22, 2016 Page 2
JetBlue Would Not Fulfill the Public Interest Recognized by FAA in the Lansing Exemption 

### JetBlue has no desire to serve LAN, and admits that it did not petition the FAA for an exemption to operate LAN-DCA after Sun Country ceased service
. 5 

### Indeed, when Sun Country announced the end ofits service, CRAA approached JetBlue about its interest in operating the route, but received no response. With no interest in serving LAN, it is impossible for JetBlue to fulfill the public interest considerations described in the Lansing Exemption. 6 

### JetBlue is only interested in growing its presence at DCA, not in meeting the Greater Lansing Community's needs for Washington, DC, travel. 7 It 

### is clear JetBlue believes the Greater Lansing Community, which supported its nonstop DCA air service for over four years and lost it through no fault ofits own, should suffer without DCA service in order that JetBlue can have another pair ofDCA slots. CRAA submits that JetBlue's attempt to use the preservation ofLAN-DCA air service for Mid-Michigan travelers

- which the FAA has repeatedly determined to be in the public interest- as a forum to complain about their DCA slot holdings is misplaced, and that there are other venues better suited to address such issues. JetBlue 's Series of Statements about LANAir Service are Meritless. 

### In its attempt to convince FAA to reconsider the Lansing Exemption, or give JetBlue backup authority, JetBlue makes a series of assertions which have no basis in fact. First, JetBlue's statements that the Lansing Exemption is "unprecedented" and amounts to carriers creating new slots are disingenuous and misplaces the public interest. 8 

### The FAA did not create new slots out ofwhole cloth- it protected nonstop DCA service for the Greater Lansing Community without creating any additional flights at DCA that did not exist before. The FAA was correct to do this in 2012, over the objections ofJetBlue, when LAN risked losing Sun Country ' s service as a result ofa D.C. Circuit Court ruling ;9 

### and it was equally correct to do so now, when LAN lost Sun Country ' s service after coming to rely on it and expecting to have it until2019
. Moreover, JetBlue's formulation suggests that Lansing ' s air service should not be protected in the same manner as other communities solely due to the form oftheir DCA service rights, and because that form changed due to circumstances beyond the community's control.

5 See JetBlue Letter, p. 3. 6 Lansing Exemption, p. 7. 7 See, e.g., Answer ofJetBlue Airways Corporation, September 17, 2015 , Docket FAA-2015-3491, p. 1, 6, and 7

-8 and JetBlue Letter, p. 4 (requesting back-up authority for two daily DCA operations without discussing LAN service)
. 8 JetB lue Letter, p. 1. 9 See Exemption No. 10466, March 2, 2012 , Docket FAA-2012-0089
. During that process , JetBlue raised objections then that are similar to the objections it raises now, and FAA disagreed with them.Reginald C. Govan, Esq. April 22, 2016 Page 3 Jackson, Mississippi, originally obtained nonstop DCA air service via the grant ofAIR 21 slot exemptions. 10 When Delta announced it was ceasing service in 2012, the Department of Transportation reallocated the AIR 21 slot exemptions to US Airways, preserving the service. 1 1 Lansing ' s DCA air service was similarly obtained through a grant of AIR 21 slot exemptions, and only a subsequent D.C. Circuit Court ruling requiring the return ofthese AIR 21 slot exemptions to Republic caused LAN-DCA service to rely on an FAA Exemption
. JetBlue would see LAN travelers unfairly penalized with a loss of DCA service even though the community had nothing to do with the change from an AIR 21 exemption to an FAA exemption. Second, contrary to JetBlue's suggestion otherwise, 12 American has given CRAA no reason to be concerned about American's ability to follow through on its promises to provide conveniently scheduled LAN-DCA service using regionaljets with WiFi, First Class, and premium economy seating, and also provide three-times-daily service to Chicago, Illinois ("ORD"). CRAA continues to work closely with American to facilitate these flights and ensure their success. Indeed, LAN-DCA flights are open for sale, and as confirmed in American's press release ofApril 18, 2016, LAN-DCA operations will begin on July 5, 2016, using 76-seat regionaljets with two classes of service, with flights timed to allow a full day ofbusiness in Washington and still return to LAN at a decent hour
. 13 LAN-ORD operations will commence August 23, 2016. 14 JetBlue's concerns about American's long term commitment to LAN-DCA service are similarly misguided. 15 As noted in the Lansing Exemption, the Greater Lansing Community overwhelmingly supported American's proposal for LAN-DCA service. 16 The Greater Lansing Community is excited to welcome American to LAN, and this support from Mid-Michigan political leaders, businesses, educational institutions, and citizens will translate into passenger traffic that ensures the long-term sustainability of LAN-DCA service
. 1 7 Lastly, JetBlue's suggestion that LAN travelers do not deserve new American service because they can make a 90-minute drive to Detroit, Michigan, is hypocritical and insulting to the Greater Lansing Community
. JetBlue serves many communities located within a 90-minute

1 0 See Department ofTransportation Order 2004- 12-6. 1 1 See Order 2012-7-26 12 See JetBlue Letter, p. 2. 13 Weekday and Sunday LAN to DCA flights will arrive at DCA at 8:04am and DCA to LAN flights will depart DCA at 5:00pm. Saturday flights will arrive at DCA at 10:39 am, and depart DCA at 5:20pm. 14 See "D.C
. flights from Lansing start July 5" , Detroit Free Press , Alexander Alusheff, April19 , 2016 , available at http ://www.freep.com /story/travel/20 16/04 ! 19/dc-flights-lansing-start-july-5/83223 3 7 4/ 15 See JetBlue Letter, p. 3. 16 See Lansing Exempt ion, p. 5 and 8. CRAA previously provided a full summary of Central Michigan ' s support for American's service proposal. (See Additional Comments ofthe Capital Region Airport Authority, September 24, 2015, Docket FAA-2015-3491, p. 2.) 17 CRAA is aware ofAmerican' s long track record ofusing AIR 21 slot exemptions to successfully connect small communities with the Nation ' s Capital, and has never returned such an exemption because a route was unsustainable. CRAA fully expects LAN-DCA service to be similarly successful.Reginald C. Govan, Esq. April 22, 2016 Page 4 

### drive ofits hubs. 18 

### The Greater Lansing Community is no less entitled to convenient air service by their choice ofcarrier than these communities served by JetBlue.

AnAward o(Backup Authority to JetB!ue Would Not Benefit Lansing Travelers 

### CRAA objects to JetBlue's request for backup authority because it would not benefit Mid-Michigan travelers, and could actually harm them. JetBlue has made clear it will not serve LAN and simply wants another pair of slots at DCA. Furthermore, JetBlue's behavior throughout this proceeding suggests it would continue to harass American in an attempt to pry the exemption away for its own use elsewhere. Such behavior could cast doubt on American's LAN-DCA service, potentially depressing traffic and affecting the sustainability ofthe service. The FAA has recognized the strong public interest ofnonstop LAN-DCA service and should not award JetBlue back-up authority which would undermine it. 19 

### CRAA is not aware of any AIR 21 slot exemption orders at DCA

- for either withinperimeter or beyond-perimeter service- in which back-up authority has ever been granted. 20 

### There is no reason for the FAA to take such an unprecedented step in this case. 21 

## * * * After nearly seven months without nonstop service to DCA, the Greater Lansing Community is excited to welcome American to LAN, where it will benefit the community by both reinstating nonstop DCA service and adding competitive new service to ORD. CRAA is confident demand for LAN-DCA service will demonstrate that FAA was correct to listen to support expressed by the Greater Lansing Community and to recognize the need to preserve LAN-DCA service.

18 LaGuardia (LGA) , Newark (EWR) and Westchester (HPN) are each within 87 minutes ofJFK; Burbank (BUR) and Los Angeles (LAX) are each within 81 minutes ofLong Beach (LGB); Worcester (ORH) is within 73 minutes ofBoston (BOS); and West Palm Beach (PBI) is within 62 minutes ofFt. Lauderdale (FLL). Sources: http: //www.jetblue. com/wherewejet/ and Googl e Maps. 19 CRAA would not object to an award ofbackup a uthority to JetBlue conditioned on JetBlue operating all ofthe same services American will offer, including: one daily nonstop LAN-DCA roundtrip, conveniently timed to allow a full day ofbusiness in Washington, DC, without a late night return; and three daily roundtrips between LAN and ORD, conveniently timed throughout the day. 20 In Order 2008-2-28, DOT made an alternative award of within-perimeter slot exemptions in the event either Spirit or AirTran failed to inaugurate ser vice
. However, this was not a standing back-up authority as it expired as soon as these carriers inaugurated their respective services. 21 JetBlue ' s cites " limited operating authorizations" that are international operating rights. (JetBlue Letter, p. 4-5 and fn 6.) These are entirely different than the rights in question here which have their roots in AIR 21 slot exemptions.Reginald C. Govan, Esq. April 22, 2016 Page 5 

### JetBlue will not serve LAN and seeks to harm the Greater Lansing Community by permanently removing LAN-DCA air service
. Granting JetBlue ' s petition for reconsideration of the Lansing Exemption and request for an award ofback-up authority would only provide JetBlue a platform to continue these efforts. Accordingly, the FAA should deny both of JetBlue's requests. Respectfully submitted,

# ~~ President-CEO Capital Region Airport Authority
cc: Kathryn B. Thompson, Esq
. - U.S. Department ofTransportation Susan McDermott

- U.S. Department ofTransportation Bob Goldner- U.S
. Department ofTransportation