April 20, 2011 

J. David Grizzle 

Chief Counsel 

Federal Aviation Administration 

800 Independence Ave., S.W. 

Washington, D.C. 20591 

 Re: Request of American Airlines and American Eagle 

Airlines for Limited LGA Operating Authorizations 

 Waiver (January-February 2011) 

Dear Mr. Grizzle: 

 American Airlines, Inc. and American Eagle Airlines, 

Inc., under 75 Fed. Reg. 18616, 18617, April 4, 2011, hereby 

request a limited waiver of the 80% usage requirement for 

certain operating authorizations at New York’s LaGuardia Airport 

(LGA) for the January–February 20ll reporting period. 

 Our request is necessitated by the severe snowfall events 

in the Northeast and mid-Atlantic regions that significantly 

disrupted air carrier operations at LGA and other airports on 

the East Coast in the first two months of the year. 

 During the reporting period, the two AMR Corporation 

operating entities, American Airlines and American Eagle Airlines, together held 10,001 LGA operating authorizations and 

published schedules for 9,814 flights, which is a scheduled 

usage rate of 98.13%. If unprecedented storms had not repeatedly struck the region, we would not require waiver relief since 

ample operations had been scheduled to easily meet the 80% useor-lose requirement. 

 American and American Eagle are network carriers, and 

their operations at LGA are impacted by storms not just in the 

Northeast region, but by events at hub airports in other parts 

of the country, including Chicago, Dallas/Ft. Worth, and Miami. 
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During the January-February reporting period, severe storms 

disrupted operations at Chicago on 6 days (January 11-12 and 17 

and February 1-3); at Dallas/Ft. Worth on 5 days (January 9 and 

February 1-4); and at Miami on 3 days (January 11 and February 

1-2). 

 On March 11, 2011, the Air Transport Association submitted a request on behalf of member carriers for usage relief 

on a blanket basis for the three New York area airports (LGA, 

JFK, and EWR) and DCA (FAA-2011-0248). The FAA denied the ATA’s 

petition (76 Fed. Reg. 19517, April 7, 2011), but invited waiver 

requests from individual carriers: 

 “Although the FAA has determined that a 

 general waiver of the usage requirements is 

 inappropriate, it acknowledges that nationwide 

 weather during this period may have caused a 

 unique hardship for some carriers. To assess 

 that hardship and determine whether relief 

 is warranted, the FAA requests that affected 

 carriers submit an individual request for 

 limited waiver. The FAA will consider the 

 periods of January 7 through February 4, 

 2011, but will make a waiver determination 

 on an individual–day basis.” 

 American Airlines and American Eagle seek relief from the 

80% usage requirement for the following LGA operating authorizations: 

ID # 3712 (0630D) 

 There were 41 operating days in the January–February 

reporting period. To achieve 80% usage, 32 operations were 

required. American Eagle conducted 28 operations, and requests 

a waiver covering 4 days. In the January 7-February 4 period 

cited by the FAA, AMR (American and American Eagle combined) 

canceled 11 flights due to weather that were scheduled in the 

0630D window. 
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ID # 2062 (0900A)

 There were 41 operating days in the January–February 

reporting period. To achieve 80% usage, 32 operations were 

required. American Eagle conducted 26 operations, and requests 

a waiver covering 6 days. In the January 7-February 4 period 

cited by the FAA, AMR (American and American Eagle combined) 

canceled 16 flights due to weather that were scheduled in the 

0900A window. 

ID # 3736 (0900D)

 There were 41 operating days in the January–February 

reporting period. To achieve 80% usage, 32 operations were 

required. American conducted 30 operations, and requests a 

waiver covering 2 days. In the January 7-February 4 period 

cited by the FAA, AMR (American and American Eagle combined) 

canceled 17 flights due to weather that were scheduled in the 

0900D window. 

 

ID #s 2096, 2208, 3625, and 3358 (0930D)

 AMR (American and American Eagle) held 4 0930D operating 

authorizations at LGA in the January–February reporting period, 

and operated 136. There were 41 operating days for each 0930 

authorization, a total of 164. Thus, the overall usage by AMR 

was 83%. American and American Eagle should have engaged in 

intra-corporate transactions to balance their 4 authorizations 

at the 0930 hour so that each would have usage of more than 80%. 

To the extent required, we request permission to engage in 

retroactive intra-corporate transfers to achieve that result. 

In the January 7-February 4 period cited by the FAA, AMR 

(American and American Eagle combined) canceled 15 flights due 

to weather that were scheduled in the 0930D window. 

ID # 2241 (1100D)

 There were 41 operating days in the January–February 

reporting period. To achieve 80% usage, 32 operations were 

required. American Eagle conducted 31 operations, and requests 

a waiver covering 1 day. In the January 7-February 4 period 

cited by the FAA, AMR (American and American Eagle combined) 

canceled 30 flights due to weather that were scheduled in the 

1100D window. 
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ID # 3566 (1130A)

 There were 41 operating days in the January–February 

reporting period. To achieve 80% usage, 32 operations were 

required. American conducted 30 operations, and requests a 

waiver for covering 2 days. In the January 7-February period 

cited by the FAA, AMR (American and American Eagle combined) 

canceled 8 flights due to weather that were scheduled in the 

1130A window. 

ID # 2008 (1230D)

 There were 50 operating days in the January-February 

reporting period. American Eagle held this operating authorization for 33 days. Delta Air Lines was the holder for 12 days 

(January 21–February 3, excluding the two Saturdays), and Comair 

was the holder for 5 days (February 4-9, excluding the one 

Saturday). American Eagle conducted 18 operations, and we 

assume that Delta and Comair conducted 31, for a total of 31. 

To achieve 80% usage, 40 operations were required. American 

Eagle requests a waiver covering 9 days. In the January 7-

February period cited by the FAA, AMR (American and American 

Eagle combined) canceled 11 flights due to weather that were 

scheduled in the 1230D window. 

ID # 35022 (1230D)

 There were 50 operating days in the January–February 

reporting period. To achieve 80% usage, 40 operations were 

required. American conducted 38 operations, and requests a 

waiver covering 2 days. In the January 7-February 4 period 

cited by the FAA, AMR (American and American Eagle combined) 

canceled 11 flights due to weather that were scheduled in the 

1230D window. 

 

ID # 2058 (1530D)

 There were 50 operating days in the January-February 

reporting period. American held this operating authorization 

for 44 days. Delta Air Lines was the holder for 3 days (January 

23, January 30, and February 6), and American Eagle was the 

holder for 3 days (February 13, 20, and 27). American conducted 

35 operations, and American Eagle conducted 2. To achieve 80% 

usage, 40 operations were required. Thus, a waiver is not 
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needed unless Delta operated fewer than 3, in which case Delta 

should seek a waiver for failing to achieve 80% usage of the 3 

operating authorizations it held. In the January 7-February 

period cited by the FAA, AMR (American and American Eagle 

combined) canceled 9 flights due to weather that were scheduled 

in the 1230D window. 

ID # 3552 (1700D)

 There were 50 operating days in the January-February 

reporting period. To achieve 80% usage, 40 operations were 

required. American conducted 38 operations, and requests a 

waiver covering 2 days. In the January 7-February 4 period 

cited by the FAA, AMR (American and American Eagle combined) 

canceled 9 flights due to weather that were scheduled in the 

1700D window. 

 

THE FAA SHOULD GRANT THE REQUESTED RELIEF

 In both severity and duration, the successive snowstorms 

that disrupted the Northeast and mid-Atlantic regions in the 

first two months of this year were highly unusual and unpredictable events beyond the control of American and American 

Eagle, and waiver of the minimum operating authorization usage 

is appropriate. As the LGA interim rule provides, “The Administrator of the FAA may waive the 80% usage requirement in the 

event of a highly unusual and unpredictable condition which is 

beyond the control of the carrier and which affects carrier 

operations for a period of 5 consecutive days or more.” 76 Fed. 

Reg. 18616, 18617, April 4, 2011. 

 There was severe weather throughout the January 18–

February 4 time period cited in the FAA’s decision on the ATA 

petition. Indeed, the weather events this past January and 

February were far more severe than those experienced a year ago 

that prompted the FAA to waive the minimum usage requirements on 

a blanket basis at the three New York-area airports and DCA for 

the February 5-15, 2010 period. See 75 Fed. Reg. 9017, February 

26, 2010. 
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 Based on the FAA’s regulations and precedent, and consistent with the public interest, the limited relief requested 

herein by American Airlines and American Eagle Airlines should 

be granted. 

 Respectfully submitted, 

 

 _____________________________ 

 WALTER J. AUE 

 Vice President – Schedules 

 American Airlines, Inc. 

 P.O. Box 619616, MD 5535 

 DFW Airport, Texas 75162 

 (817) 967-2514 

 walter.aue@aa.com