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 Corporationoperating entities, American Airlines and American Eagle Airlines, together held 10,001 LGA operating authorizations and published schedules for 9,814 flights, which is a scheduledusage rate of 98.13%. If unprecedented storms had not repeatedly struck the region, we would not require waiver relief sinceample 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.- 2 -

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 the80% 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.- 3 -

**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.- 4 -

**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-Februaryreporting 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- 5 -

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.- 6 -

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