'--' 

CAPITAL REGION AIRPORT AUTHORITY 

Chris Holman 

Chairman 

Dick Baker 

Victor Celentino 

Samantha Harkins 

John Shaski 

Greg Ward 

Robert F Selig, AAE 

President - CEO 

April 22, 2016 

VIA EMAIL AND REGULATIONS.GOV 

Reginald C. Govan, Chief Counsel 

Federal Aviation Administration 

800 Independence A venue, SW 

Washington, DC 20591 

Re: JetBlue Petition for Reconsideration and Request for Backup Authority 

Docket FAA-2015-3491 

Dear Chief Counsel Govan: 

On March 31 , 2016, the Federal Aviation Administration ("FAA") granted an 

exemption to American1 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 of the 

Lansing Exemption and an award of back-up authority which would allow it to serve a 

different community.4 

The Capital Region Airport Authority ("CRAA") opposes both of these 

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-2015-3491 and -3932, March 31,2016 

("Lansing Exemption"). 3 See Lansing Exemption, p. 7. 4 See Letter of JetBiue re: Petition for Reconsideration and Request for Backup Authority, April 12, 

2016 ("JetBlue Letter"). 

Capital Region International Airport + 4100 Capital City Blvd. + Lansing, Michigan 48906 + 517-321-6121 + Fax 517-321-6197 

www.flylansing.com 
Reginald C. Govan, Esq. 

April 22, 2016 

Page 2 

JetBlue Would Not Fulfill the Public Interest Recognized by FAA in the Lansing Exemption 

J etBlue 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 of its 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 of its own, should suffer without DCA service in order that JetBlue can have 

another pair of DCA slots. 

CRAA submits that JetBlue's attempt to use the preservation of LAN-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 LAN Air Service are Meritless. 

In its attempt to convince FAA to reconsider the Lansing Exemption, or give J etBlue 

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 of whole 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 of JetBlue, when LAN risked losing 

Sun Country's service as a result of a 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 of their 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 JetBlue 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 of AIR 

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. 11 

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 of these 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 regional jets 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 of April 18, 2016, LAN-DCA operations will begin on July 5, 2016, using 76-seat 

regional jets with two classes of service, with flights timed to allow a full day of business 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.

17 

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 

10 See Department of Transportation Order 2004-12-6. 11 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 Exemption, p. 5 and 8. CRAA previously provided a full summary of Central Michigan 's support for 

American's service proposal. (See Additional Comments of the Capital Region Airport Authority, September 24, 

2015, Docket FAA-2015-3491, p. 2.) 17 CRAA is aware of American's long track record of using 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 of its hubs. 18 The Greater Lansing Community is no less entitled to convenient air service 

by their choice of carrier than these communities served by JetBlue. 

An Award 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 of the service. 

The FAA has recognized the strong public interest of nonstop 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 of JFK; Burbank (BUR) 

and Los Angeles (LAX) are each within 81 minutes of Long Beach (LGB); Worcester (ORH) is within 73 minutes 

of Boston (BOS); and West Palm Beach (PBI) is within 62 minutes of Ft. Lauderdale (FLL). Sources: 

http://www.jetblue.com/wherewejet/ and Google Maps. 19 CRAA would not object to an award of backup authority to JetBlue conditioned on JetBlue operating all of the 

same services American will offer, including: one daily nonstop LAN-DCA roundtrip, conveniently timed to allow a 

full day of business 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 service. 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 of back-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 of Transportation 

Susan McDermott - U.S. Department of Transportation 

Bob Goldner- U.S. Department of Transportation