CORRECTED COPY.

BEFORE THE

OFFICE OF THE SECRETARY

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON D.C.

_____________________________________

)

2012 CHICAGO - CANCUN ) Docket DOT-OST-2012-0001

COMBINATION SERVICE PROCEEDING )

_____________________________________ )

_____________________________________

)

Applications of )

) 

 AIRTRAN AIRWAYS, INC. ) Docket DOT-OST-2011-0225

 )

 FRONTIER AIRLINES, INC. ) Docket DOT-OST-2011-0214

)

For an exemption pursuant to )

49 U.S.C. § 40109 ) 

_____________________________________ )

REPLY OF AIRTRAN AIRWAYS, INC.

Communications with respect to this document should be sent to:

Bob Jordan Robert W. Kneisley

 President Associate General Counsel

AIRTRAN AIRWAYS, INC. Leslie C. Abbott

9955 AirTran Boulevard Senior Attorney

Orlando, FL 32827 SOUTHWEST AIRLINES CO.

 1901 L Street, N.W., Suite 640

Washington, D.C. 20036

 bob.kneisley@wnco.com

(202) 263-6284

January 31, 2012
CORRECTED COPY.

1

BEFORE THE 

OFFICE OF THE SECRETARY

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON D.C.

_____________________________________

)

2012 CHICAGO - CANCUN ) Docket DOT-OST-2012-0001

COMBINATION SERVICE PROCEEDING )

_____________________________________ )

_____________________________________

)

Applications of )

)

 AIRTRAN AIRWAYS, INC. ) Docket DOT-OST-2011-0225

 )

 FRONTIER AIRLINES, INC. ) Docket DOT-OST-2011-0214

)

For an exemption pursuant to )

49 U.S.C. § 40109 ) 

_____________________________________ )

REPLY OF AIRTRAN AIRWAYS, INC.

AirTran and Frontier1have already submitted five rounds of pleadings in this 

carrier selection matter since last November. All relevant evidence is in the record and 

the case is ripe for decision. Confirmation of this fact is that Frontier’s January 26 

Answer contains almost nothing new, but instead just re-hashes the same specious 

arguments that Frontier advanced in its previous pleadings. At this point the record is 

clear: AirTran/Southwest should be selected as the carrier that will best meet the 

Department’s goal of “maximize[ing] public benefits” in the Chicago – Cancun market.2 

The advantages of AirTran/Southwest’s service proposal in this market are many and 

manifest: 

 

1

Common names of carriers are used.

2

Order 2012-1-4, January 9, 2012, at p. 2.
CORRECTED COPY.

2

AirTran’s proposal for serving MDW-CUN, as demonstrated by Southwest’s long 

history of service and consistent low fares at MDW, will provide far greater public 

benefits than Frontier. AirTran/Southwest will pressure the ORD carriers and 

discipline their pricing in a way that Frontier cannot. At the same time 

Southwest/AirTran will balance the air service to Chicago residents by offering 

service at MDW, having the most beneficial impact on the structure of competition in 

the Chicago-Cancun market. Frontier, by contrast, wishes to be one of four carriers 

serving Cancun from ORD, ensuring no service at MDW. Under the circumstances, 

it is not surprising that Mayor Emanuel and many other Chicago leaders have 

expressed their strong support for AirTran/Southwest’s proposal. 

Moreover, Frontier has a charter contract with Apple Vacations that will cover 88% of 

the seats it proposes to operate (Exhibit FL-R-1). Frontier nevertheless wants 

scheduled authority in this market, an outcome that would needlessly bar 

AirTran/Southwest – and Midway Airport – from competing. Other than a fanciful 

hope for interline connecting passengers from its two direct competitors at ORD, 

there is nothing in Frontier’s five pleadings that suggest it could successfully market 

the 12% of seats that may or may not be committed to Apple.3 

AirTran/Southwest’s proposal, on the other hand, would not bar its competitor from 

participating in the CHI-CUN market, as Frontier can fully carry out the Apple 

contract via the almost unlimited charter provisions of the U.S.-Mexico bilateral 

agreement. AirTran’s proposal is thus a “win-win” for the Department and the public, 

yet another way in which AirTran/Southwest will maximize public benefits in the CHICUN market.

AirTran/Southwest is between 40 and 110 times larger than Frontier in Chicago, 

depending upon the measure of size used (see Exhibit FL-SR-1). With just a single 

MDW route, Frontier has only a miniscule presence in the Chicago market and no 

 

3

See AirTran’s January 26 Answer at pp. 2-6 and Exhibit FL-R-1. 
CORRECTED COPY.

3

traffic support at ORD.4 By contrast, AirTran/Southwest has a 57-route network at 

MDW. With no online or interline feed, a Frontier ORD-CUN award would very likely 

end up just like the 23 of its 26 U.S.-Mexico routes that Frontier has either 

suspended for long periods of time or totally abandoned. 

Frontier promotes itself as a low-fare alternative. However, it has made no mention 

of what its fares will be. This is because Apple will set the total package price for 

88% of the seats that Frontier is proposing. Frontier will have no control over what 

the consumer pays for the air transportation portion of the tour package. We do 

know that in head-to-head competitive markets at DEN, Southwest is lower-priced in 

18 of the 27 markets; and overall, its average price is 2.7% lower than Frontier 

(Exhibit FL-R-12). 

AirTran/Southwest is clearly the applicant that will maintain the best service to the 

public over time. Since 2003 Frontier has attempted service in 26 U.S.-Mexico 

routes, but has provided uninterrupted service in only three of those. It has 

abandoned 13 of its attempted Mexico routes, and been in and out of another 10 

with inconsistent patterns of service. The three successful routes all have their own

feed support at DEN, which Frontier obviously lacks in Chicago. 

AirTran/Southwest expects to receive its Single Operating Certificate (SOC) by the 

end of the first quarter, and achieve full schedule integration later this year. Despite 

Frontier’s exaggerated rhetoric, there is no real issue about connectivity. In terms of 

distribution, Southwest has had unparalleled success in reaching consumers with its 

own industry leading website, www.southwest.com. This has reduced its distribution 

costs and its dependency on expensive outside vendors. Nevertheless, it does 

distribute through GDS’s, but to a lesser degree than Frontier. And in this case, 

Frontier will not be distributing and booking reservations for at least 88% of its seat 

capacity, as Apple will handle sales and reservations. 

 

4

Frontier makes the irrelevant point that its single route to/from MDW produces more local passengers per 

departure than Southwest at MDW (Exhibit A-3). But this is the result of a carrier having no connecting passengers 

because it operates only one route. AirTran/Southwest, on the other hand, will be able to carry both local and 

connecting passengers due to their large number of online connections at MDW.
CORRECTED COPY.

4

In terms of consumer ratings of airline services, AirTran and Southwest were ranked 

first and fifth respectively for overall quality, while Frontier placed ninth. See 

AirTran’s January 26 Answer at pp. 13-15. The same AQR study revealed that 

Frontier’s consumer complaints per 100,000 passengers are five times the number 

for Southwest. The consumer appeal of scheduled service by AirTran/Southwest is 

orders of magnitude greater than Frontier’s. Moreover, few if any of Frontier’s forsale passenger amenities may be available to Apple’s charter passengers. Apple 

Vacations will decide what is included, and what is not, in its bundled package price. 

Beyond these over-arching points, AirTran will address the few new arguments 

raised by Frontier in its January 26 Answer. 

I. AIRTRAN/SOUTHWEST’S POTENTIAL CONNECTING TRAFFIC AT

MDW IS UNDERSTATED.

In its January 19 Supplement, AirTran/Southwest showed that it would connect 

21 on-line markets at MDW with less than 40% circuity in support of Cancun service 

(Exhibit FL-107), even though the carrier serves a total of 57 nonstop routes at MDW 

(Exhibit FL-104). Limiting projected connections in this fashion was simply an effort to 

be conservative in measuring AirTran/Southwest’s connecting potential. In fact, 

Southwest today carries a large number of passengers in markets with greater than 

40% circuity. Nevertheless, Frontier attacks AirTran/Southwest’s projected connections 

as “grossly overstated,” claiming that cities with current nonstop service to Cancun 

should be excluded, leaving only seven behind gateway cities supporting MDW-CUN 

service (Frontier Answer at pp. 3-4). 

In fact, the opposite of Frontier’s charge is true: AirTran/Southwest have

understated their connecting potential at MDW. Southwest carried over 1.4 million 
CORRECTED COPY.

5

connecting passengers via MDW in markets that had nonstop service during the 12 

months ended September 30, 2011 (Exhibit FL-SR-2). These passengers traveled in 

467 unique O&D markets via MDW despite having a nonstop alternative. For example, 

15,000 passengers travelling between IAD and SAN connected at MDW despite the 

existence of nonstop service between IAD and SAN. Therefore, Frontier’s argument 

that markets with current nonstop service to CUN should be excluded from 

AirTran/Southwest’s connecting markets is belied by Southwest’s experience at MDW 

today. 

Moreover, 220 of the 467 markets noted above have circuity exceeding 40%

when connecting at MDW compared to travelling nonstop. For example, 2,582 

passengers in the BUF-MCO market connected at MDW despite circuity of 44%

compared to nonstop BUF-MCO service. Collectively these 220 markets generated 

over 216,000 passengers.5 All of this demonstrates that AirTran’s projection of 

connecting traffic at MDW was in fact very conservative since it did not include any 

markets with greater than 40% circuity. 

Frontier’s attack on AirTran/Southwest’s connecting potential is especially ironic 

coming from a carrier that has virtually zero connecting support. Frontier would carry no

online connecting passengers at ORD since it has no service at ORD, and instead 

bases its entire claim of behind-gateway support on interline connections from direct 

competitors at ORD. But as AirTran has already shown, Frontier has no realistic hope 

of attracting such passengers except for the few that fall into Frontier’s lap as a result of 

 

5

U.S. DOT Origin-Destination Passenger Survey, YE Q3 2011. In fact, counting all Southwest MDW markets (not 

just those having nonstop alternatives), Southwest carried a total of 367,411 passengers who connected at MDW 

in markets with greater than 40% circuity (Id.).
CORRECTED COPY.

6

flight cancellations or oversales by United or American. See AirTran Answer at pp. 4-5 

and Exhibit FL-R-2.

II. MDW IS PREFERRED BY HALF THE CHICAGO MARKET, MAINLY AS

A CONSEQUENCE OF SOUTHWEST’S LOW FARES.

As shown in AirTran Exhibits FL-117, FL-118 and FL-119, in markets where 

services are similar between the two Chicago airports, AirTran/Southwest originates as 

much traffic at MDW as the ORD carriers. This is in part because the geographical 

location of MDW is preferred by a large segment of the Chicago population, and in part

due to Southwest’s lower fares. As a further public benefit, Southwest has caused air 

fares to decline significantly in head-to-head markets competitive with ORD. This 

“Southwest Effect” has been demonstrated in numerous exhibits that AirTran previously 

submitted to the Department. 

Nevertheless, Frontier persists in an ostrich-like denial of reality in claiming that 

the “Southwest Effect” at MDW is a “myth,” and MDW fares do not discipline ORD fares

(Frontier Answer at pp. 9-12). Beyond the voluminous material that AirTran has already 

submitted to establish MDW’s strong disciplining effect on ORD,6the attached Exhibit 

FL-SR-3 presents additional compelling evidence7. That exhibit presents 12 pairs of 

markets, each consisting of (1) a market served both by Southwest at MDW and 

carriers at ORD, and (2) a market of very similar nonstop distance that is served only at 

ORD and not by Southwest. In each of the 12 comparisons the average ORD fare is 

significantly lower in markets where Southwest competes at MDW vis-à-vis the markets 

that are not served by Southwest at MDW. In fact, the “fare premium” achieved in the 

 

6

See, e.g., AirTran’s January 19 Supplement at p. 7 and Exhibits FL-120, -121 and -122; and AirTran’s January 26 

Answer at p. 7 and Exhibits FL-R-3 through FL-R-10.

7

Based on current DOT O&D data (12 months ended September 30, 2011).
CORRECTED COPY.

7

12 ORD markets that do not face Southwest’s competition at MDW ranges as high as 

106% for the SDF/DSM comparison (Exhibit FL-SR-3). There can be no residual doubt 

that Southwest disciplines the fare structure at ORD, and that award of the ChicagoCancun route to AirTran/Southwest will pressure UA and AA pricing far more than the 

minimal service that Frontier might offer to the public outside of the Apple charter 

program. 

In Exhibit A-4 Frontier attempts to show obliquely that MDW fares do not 

discipline ORD fares because the average fare differential is +15% in favor of ORD. 

Frontier supports this assertion by reference to a DOT observation that EWR does not 

discipline LGA fares. However, there are key structural differences between the New 

York/Newark airports and Chicago. As shown in Exhibit FL-SR-4, a diffuse group of 

LCC’s provide only 12% of the seat capacity at EWR, and only 16% at LGA. However, 

in Chicago, LCC competition (provided almost entirely by Southwest and AirTran) is 

much stronger and more broadly available. LCC services are concentrated at MDW 

and LCC’s account for 29% of all domestic seat capacity in Chicago. Again, there is no 

doubt that low-fare services have permeated the entire Chicago landscape and caused 

fares to decline significantly at both ORD and MDW. 

Frontier wants the Department to believe that fare discipline means fare equality. 

It doesn’t; AirTran has already explained why average fares are naturally higher at ORD 

for reasons having nothing to do with competition from MDW (AirTran Answer at pp. 7-

9). But the disciplining effect of MDW is clear from the fact that ORD fares are 

materially lower in markets that are served by AirTran/Southwest from MDW. This fact 

is incontrovertible – both in Chicago and across the AirTran/Southwest system. 
CORRECTED COPY.

8

Frontier resorts to a 1998 case involving TWA, America West (HP) and several 

other now-defunct carriers to support of its claim that MDW does not discipline ORD. 

The facts in that 14-year old case are very different from the competitive dynamics 

between MDW and ORD today, however. The primary issue facing DOT in that case 

was United’s argument that HP’s service at MDW adequately competed with UA at 

ORD so that it would be unnecessary to award HP slots at ORD. But as AirTran’s 

exhibits have shown, AirTran/Southwest have a far greater competitive impact in the 

Chicago market at MDW today than HP did with a minimal presence at MDW 14 years 

ago. In addition, in rejecting United’s argument, the Department stated that “there is no 

comparison in available connecting opportunities” between ORD and MDW. Today, 

with Southwest/AirTran’s 220 daily departures to 57 nonstop destinations from MDW, 

this is no longer the case. Midway is one of Southwest’s largest airports, and is known 

for its many convenient connections to dozens of destinations across the country. 

Finally, the Department’s 1998 decision was made in the very different context of a slot 

proceeding where a dominant legacy carrier was attempting to bar slots from being 

awarded to a new entrant carrier. Here, of course, no slots are involved, and under 

AirTran’s proposal neither applicant will be barred from competing in the CHI-CUN 

market. 

III. AIRTRAN/SOUTHWEST IS THE LOW-FARE APPLICANT IN THIS

PROCEEDING, NOT FRONTIER.

Throughout all the pleadings during five rounds of exchange in this case, Frontier 

repeatedly describes itself as the low-fare carrier and United and American as the highfare incumbents. Yet, nowhere in this case has Frontier disclosed what its fare or price 
CORRECTED COPY.

9

to the public will be. Nowhere has it compared its proposed fare to that of UA and AA in 

the Chicago-Cancun market. Nowhere has Frontier told the Department what Apple’s 

bundled tour package prices will be and what portion of the bundled price is represented 

by Frontier’s air transportation service. Its claim to be the low-fare alternative is 

therefore nothing but a hollow allegation with no evidentiary support. 

AirTran has compared the prices actually charged to consumers8by

AirTran/Southwest versus Frontier at ITS Denver hub, as shown in Exhibit FL-R-12. In 

the 27 nonstop DEN markets where both carriers compete head-to-head, 

AirTran/Southwest’s average price is lower in 18 markets, and its weighted average 

price over all 27 markets is 2.7% lower than Frontier. 

Frontier’s January 26 Answer (at p. 12) makes erroneous fare comparisons for 

Southwest. It improperly relates Southwest fares from Exhibits FL-120 and FL-121, 

(based on a data source that excludes all ticket taxes, segment fees and PFC’s), to 

Southwest fares in the same markets using a different data source which includes all 

taxes and fees.9This comparison greatly overstates the true amount of Southwest’s 

fare increase, which was in line with an industry-wide response to rapidly rising fuel 

costs in any event.

Finally, for at least 88% of its seat capacity proposed in this case Frontier will 

have no say whatsoever as to what price the passenger will pay. That will be 

determined unilaterally by Apple Vacations (Exhibit FL-R-1). For the remaining 14,784 

seats that Frontier might market directly to the public in competition with its alleged 

 

8

Price to the customer includes base airfare plus average checked baggage and reservation change fees.

9

AirTran’s exhibits are sourced from the DOT Origin-Destination Survey accessed by a provider that excludes 

government taxes and fees from the fare data. Frontier’s comparison is based on the DOT Domestic Airline Fares 

Consumer Report, which includes government taxes and fees.
CORRECTED COPY.

10

interline partners (United and American), there is no indication in the record what its 

fares might be if it operates those off-season filler flights at all. 

IV. AN AWARD TO FRONTIER WOULD BE ESPECIALLY RISKY GIVEN ITS

ABYSMAL TRACK RECORD IN SERVING MEXICO, ESPECIALLY FROM 

MARKETS OTHER THAN DEN.

Frontier’s Answer makes several references to the DOT’s stated carrier selection 

criteria, but ignores any mention of one of the most important factors in this case, 

namely “which applicant will be most likely to offer and maintain the best service for the 

traveling and shipping public.”10 AirTran/Southwest addressed this issue in its January 

19 Supplement. In Exhibit FL-115 AirTran/Southwest presented Frontier’s extremely 

checkered history in serving 26 different U.S.-Mexico routes since 2003. Exhibit FL-115 

shows that of the 26 markets attempted by Frontier, it has completely abandoned 13 of 

them and has interrupted service in another 10 markets. Frontier has maintained 

continuous service in only three of these 26 Mexico routes, and all three are hubsupported routes from Denver to Mexico.

Frontier’s Answer takes no issue with the accuracy of the data portrayed in 

Exhibit FL-115. It simply states that the 10 routes designated in Exhibit FL-115 as 

interrupted service are in fact “scheduled seasonal routes.” But this attempted 

justification does not wash. A closer examination of these 10 routes (depicted by 

dashed blue lines in Exhibit FL-115) tells a different story. As shown in Exhibit FL-SR-5, 

five of the 10 routes in question had service interruptions for 12 or more consecutive 

months. In the cases of MCI-SJD, MKE-CUN and DEN-ZIH, Frontier abandoned those 

markets for almost three years. In the case of the five other routes, the periods of 

 

10 Order 2012-1-4, at p. 2 (emphasis added).
CORRECTED COPY.

11

service suspension differed from year to year in spite of the fact that sunspot leisure 

vacation markets typically have stable seasonality patterns. This is especially true for 

fixed points of origin, like Denver or Chicago. 

Just as Frontier took no issue with the accuracy of the data presented in Exhibit 

FL-115, AirTran/Southwest has no quarrel with the accuracy of the data shown in 

Frontier’s Exhibit A-6, which presents AirTran’s unblemished and uninterrupted record 

of service to Mexico. It is useful for the Department to compare the two U.S.-Mexico 

service histories side-by-side, and AirTran has done this in Exhibit FL-SR-6. Even a 

cursory examination of this exhibit demonstrates that the applicant “most likely to offer 

and maintain the best service for the travelling public” is AirTran/Southwest. 

CONCLUSION

For the reasons stated above and in its prior submissions, AirTran requests that 

the Department act as soon as possible to grant its Application for Exemption and 

designate AirTran to provide scheduled foreign air transportation of persons, property 

and mail between Chicago Midway Airport and Cancun. 

Respectfully submitted,

______________________

Robert W. Kneisley

January 31, 2012
CERTIFICATE OF SERVICE

I hereby certify that on January 31, 2012, a copy of the foregoing was served via 

e-mail on the following persons:

robert.cohn@hoganlovells.com (Frontier Airlines)

patrick.rizzi@hoganlovells.com (Frontier Airlines

susan.kurland@dot.gov

paul.gretch@dot.gov

brian.hedberg@dot.gov

brett.kruger@dot.gov

todd.homan@dot.gov

esta.rosenberg@dot.gov

john.allen@faa.gov 

ursk@dos.gov

Rosemarie S. Andolino

Commissioner

City of Chicago Department of Aviation

rosemarie.sandolino@cityofchicago.org

Erin O’Donnell

Managing Deputy Commissioner 

City of Chicago Department of Aviation, Midway Airport

Erin@cityofchicago.org

__________________________

Leslie C. Abbott
Southwest/AirTran’s Far Larger Presence 

In Chicago Than Frontier Will Strongly Support Cancun Service 

Source: U.S. DOT Origin & Destination Survey & U.S. DOT T-100 Onboard data, YE Q3 2011. OAG Schedules for March 2012.

Docket DOT-OST-2012-0001

Exhibit FL-SR-1

1,689

17

0

200

400

600

800

1,000

1,200

1,400

1,600

1,800

Southwest/AirTran Frontier

228,588

2,058

0

50,000

100,000

150,000

200,000

250,000

Southwest/AirTran

57

1

0

10

20

30

40

50

60

Southwest/AirTran Frontier

Annual Passenger O&D (000) Annual Onboard Passengers (000)

Weekly Aircraft Departures Weekly Seat-Departures

Destinations

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000

20,000

Southwest/AirTran Frontier

17,682

301

0

2,000

4,000

6,000

8,000

10,000

Southwest/AirTran Frontier

301

9,858
MDW

IAD

BDL

ISP

EWR

OAK

SFO

LAX

JAN

SAT

ABQ

ALB

AUS

BHM

BNA

BOI

BOS

BUF

BWI

CHS

CLE

CMH

DAL

DEN

DTW

ECP

FLL

GEG

GSP

HOU

IND

JAX

LAS

LGA

LIT

MCI

MCO

MKE MHT

MSP

MSY

OKC

OMA

ORF

PBI

PDX

PHL

PHX

PIT

PVD

RDU

RSW

SAN

SDF

SEA

SJC

SLC

SMF

SNA

STL

TPA

TUL

TUS

Southwest Carried Over 1.4 Million Connecting Passengers 

Via MDW In 467 O&D Markets With A Nonstop Alternative

WN Connections via MDW in Markets 

with Nonstop Service

Markets 467

WN Passengers 1,421,549

Note: Nonstop service defined as 5 or more weekly roundtrip departures.

Source: U.S. DOT, Origin-Destination Passenger Survey, and Official Airline Guide, YE Q3 2011.

Docket DOT-OST-2012-0001

Exhibit FL-SR-2
The Southwest Effect Is Alive and Well: 

ORD Fares Are Significantly Lower In Markets 

Where Southwest Competes at MDW

Current (YE Q3 2011)

Average ORD Fare

$124

$131

$122

$131

$179

$161

$188

$198

$152

$124

$200

$232

$256

$248

$222

$235

$243

$256 $263 $263

$255

$157

$284

$117

$0

$50

$100

$150

$200

$250

$300

ORD Market STL CVG SDF DSM CLE LEX MSP CAK BNA SGF LIT ROA RDU ABE ORF HPN BDL BTV BOS PWM RSW SRQ TUS BOI

Distance (miles) 258 265 286 299 316 323 334 344 409 438 552 531 647 654 717 738 783 763 867 900 1120 1035 1437 1437

% No WN MDW

Higher 98% 106% 89% 82% 79% 36% 59% 40% 33% 68% 26% 42%

Note: Includes Fared passengers only.

Source: DOT, Origin-Destination Passenger Survey YE Q3 2011.

ORD Fare When WN Offers MDW Nonstop Service

ORD Fare When No WN MDW Nonstop Service

Docket DOT-OST-2012-0001

Exhibit FL-SR-3
Newark and LaGuardia Have Far Less 

LCC Competition Than Chicago

Weekly

Seat Departures

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

800,000

900,000

1,000,000

EWR LGA Chicago

Note: Includes only domestic routes

Source: Official Airline Guide Schedules for the week of March 12 - 18, 2012.

Legacy Seats

LCC Seats

287,075

320,097

906,119

12%

88%

16%

84%

29%

71%

Docket DOT-OST-2012-0001

Exhibit FL-SR-4

EWR

253

34

269

51

LGA Chicago

644

262

Seats (000)

Total Seats 287 320 906
Source: US DOT T-100 Data, OAG Schedules.

Frontier Has Been Absent For More Than 12 Consecutive Months in 

Five of Its 10 So-Called “Seasonal” Mexico Routes

“Seasonal” Service with Suspensions Longer than 12 Consecutive Months

Period of Service Suspension

Service Period

Service Suspended Longer than

12 Consecutive Months

DEN-ZIH

STL-CUN

IND-CUN

MCI-SJD

MKE-CUN

Docket DOT-OST-2012-0001

Exhibit FL-SR-5

34 Months

20 Months

19 Months

34 Months

34 Months
Source: Exhibit FL-115 and Frontier Airlines’ Exhibit A-6.

AirTran is the Applicant “Most Likely

To Offer and Maintain the Best Service”

AirTran’s Unblemished Record of Serving Mexico 

DEN-MZT

DEN-CUN

DEN-SJD

DEN-PVR

DEN-ZIH

SLC-CUN

MCI-CUN

AUS-CUN

BNA-CUN

STL-CUN

MCI-PVR

DEN-CZM

DEN-ACA

IND-CUN

SAN-CUN

MCI-SJD

LAX-SJD

DEN-GDL

SMF-SJD

SJC-SJD

DFW-MZT

SMF-PVR

SJC-PVR

MKE-CUN

ABQ-PVR

STL-PVR

Frontier’s “Proven Track Record” of Serving Mexico 

Jan 2003

Jan 2004

Jan 2005

Jan 2006

Jan 2007

Jan 2008

Jan 2009

Jan 2010Jan 2011

Jan 2012

Jan 2003

Sep 2004May 2006

Jan 2008

Sep 2009

May 2011

Dec 2012

Docket DOT-OST-2012-0001

Exhibit FL-SR-6

ATLCUN

BWICUN

MKECUN

SNASJD

SNAMEX

SATMEX

SATCUN