1

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, DC 20590

 )

Establishment of Slot Exemption Proceeding )

At Ronald Reagan Washington National Airport ) Docket 

Pursuant to 49 USC §41718 ) DOT-OST-2000-7182

)

Application of JetBlue Airways Corporation

Communications with respect to this document should be addressed to:

James Hnat Jonathan B. Hill

General Counsel J. Parker Erkmann

JetBlue Airways Corporation Dow Lohnes PLLC

27-01 Queens Plaza North 1200 New Hampshire Ave., NW

Long Island City, NY 11101 Suite 800

Washington, D.C. 20036

(202) 776-2000

jhill@dowlohnes.com

perkmann@dowlohnes.com

Robert C. Land

Senior Vice President for Government Counsel for 

Affairs & Associate General Counsel JetBlue Airways Corporation

JetBlue Airways Corporation

P.O. Box 1927

Rockville, Maryland 20849-1927

(301) 279-9727

December 5, 2012
2

BEFORE THE

DEPARTMENT OF TRANSPORTATION

WASHINGTON, DC 20590

________________________________________________

)

Establishment of Slot Exemption Proceeding )

At Ronald Reagan Washington National Airport ) Docket 

Pursuant to 49 USC §41718(b) ) DOT-OST-2000-7182

________________________________________________)

Application of JetBlue Airways Corporation

In response to the Department’s Notice,1 JetBlue Airways Corporation (“JetBlue”) 

hereby applies for the pair of slot exemptions to be reallocated for service at Ronald Reagan 

Washington National Airport (“DCA”) pursuant to the provisions of the Wendell H. Ford 

Aviation Investment and Reform Act for the 21st Century (“AIR-21”).2

 JetBlue proposes to 

introduce much needed, low fare competitive service in the DCA-Jacksonville, FL (“JAX”) 

market, a monopoly market presently operated by the dominant carrier at DCA, US Airways. 

JetBlue will provide continuing service to San Juan, Puerto Rico (“SJU”). JetBlue, which is a 

limited incumbent carrier at DCA, 3 will use Stage 3 Airbus A320 single aisle jets for this 

service. In addition, JAX is a medium hub airport within DCA’s 1250-mile perimeter currently 

served by a single carrier from DCA. Accordingly, JetBlue’s application satisfies the criteria 

Congress has directed the Secretary of Transportation to consider in awarding slot exemptions at 

DCA.

I. JetBlue’s Proposal

JetBlue proposes to utilize the two available AIR-21 slot exemptions at DCA to compete 

on the US Airways monopoly route DCA-JAX. JetBlue, within ninety days of a final order 

awarding such slot exemptions, will begin daily roundtrip nonstop service utilizing its largest 

aircraft, the Airbus A320, with 150 seats, as highlighted below.

 1

 See Notice, Establishment of Slot Exemption Proceeding Pursuant to 49 U.S.C. § 41718(b), 

Docket DOT-OST-2000-7182 (Nov. 13, 2012) (the “Notice”).

2 See 49 U.S.C. § 41718(b).

3

 A limited incumbent is an air carrier that holds or operates fewer than 40 slots at DCA, see 49 

U.S.C. § 41714(h)(5), as amended by the FAA Modernization and Reform Act of 2012, Pub. L. 

No. 112-95, 126 Stat. 11 (Feb. 14, 2012). JetBlue holds or operates 36 slots at DCA.
3

JetBlue’s Proposed Schedule

Origin Destination Depart Arrive Frequency Aircraft Seats Distance

DCA JAX 08:00 10:10 Daily A320 150 634

JAX DCA 17:45 19:55 Daily A320 150 634

These departure and arrival times fit within the demand periods experienced at DCA and, 

coupled with JetBlue’s own slot holdings, should allow the FAA to award these slots without 

imposing delays at the airport.

JetBlue proposes to provide daily nonstop service between DCA and JAX utilizing its

Stage 3 Airbus A320 single aisle jet, with continuing service to JetBlue’s focus city of San Juan, 

Puerto Rico. The JetBlue A320 has 150 seats in a three by three seating configuration, providing 

the most legroom in coach of any domestic airline as well as offering JetBlue’s popular ‘Even 

More Space’ product. This application has the strong support of the local communities.4

II. JetBlue Will Initiate Competitive Service in the DCA-JAX Market Where US 

Airways Currently Operates a Monopoly.

Since JetBlue’s first flight in 2000, JetBlue has always maintained a very simple formula 

for deciding which markets to serve - the market needs to be either 1) under-served; 2) overpriced; or 3) have both characteristics. Once JetBlue decides to enter a market, it introduces a

meaningful level of service at lower fares than the market has previously experienced. In turn, 

market size increases and fares decrease. The DCA-JAX market perfectly fits this model.

JetBlue’s model has a demonstrably successful history of stimulating demand rather than 

merely shifting existing traffic. When JetBlue enters a new market, the introduction of new 

service generally lowers fares and causes enplanements to rise. As traffic increases, JetBlue 

grows capacity, satisfying demand. This historical pattern has been replicated time and time 

 4 Attached as Exhibit B6-2012A-101 are letters of support from: (1) Hon. Ander Crenshaw and 

Hon. Corrine Brown, Members of Congress representing the Jacksonville area; (2) Mayor Alvin 

Brown, the Mayor of the City of Jacksonville; and (3) Steven Grossman, the Executive Director 

& CEO of the Jacksonville Aviation Authority. JetBlue will supplement the record as additional 

letters of support become available.
4

again. Below are two recent market illustrations where JetBlue’s entry has increased traffic and 

disciplined fares in both mature and new markets.

JetBlue’s Entry Stimulates Traffic5

 

Based on more than a decade of experience, JetBlue expects a similar result in DCAJAX. The DCA-JAX market is a single carrier market with, not surprisingly, high monopoly 

fares. As a result, JetBlue’s low fare stimulation model will serve as a powerful catalyst for 

lower fares and increased enplanements. Accordingly, with the introduction of new low fare 

competitive service, JetBlue expects that traffic in the DCA-JAX market will grow by 50%, with 

average fares falling by at least 30% in the first year of service. 

 5 See O & D Survey, as provided by Diio (captured Nov. 26, 2012)

211

489

0

200

400

600

YE 1Q11 YE 1Q12

BOS-EWR Industry Passengers Per Day

132%

B6 enters

21

81

0

25

50

75

100

YE 1Q11 YE 1Q12

JAX-SJU Industry Passengers Per Day

279%

B6 enters
5

A. The DCA-JAX Market Is Currently Underserved and Underperforming Due 

to US Airways’ Monopoly.

Today, the DCA-JAX market has four daily nonstop flights in each direction. On its 

face, this may appear to be an ample level of service. But an analysis of US Airways’ JAX-DCA 

commercial strategy demonstrates that the market needs competition. Upon Delta’s exit from the 

market in January 2012, US Airways has flown smaller aircraft and increased fares, leading to 

declines in the number of passengers carried on the route. Considering that Washington is the 

seat of the federal government and Jacksonville has a high concentration of government/military 

installations, the level of service and enplanements in this market should be much higher.

US Airways has served the DCA-JAX market for decades. Historically, this service 

included three daily nonstops operated with Airbus 319 (124 seats) and Boeing 737 (144 seats), 

along with occasional regional aircraft; all are smaller than the Airbus A320 in JetBlue’s 

proposal. Since 2008, US Airways had operated four daily nonstops, but with Embraer 170 (76-

86 seats) and Airbus 319 (124 seats) equipment. Today, US Airways has downsized and only 

operates regional aircraft on this route, flying Embraer 175 aircraft (80 seats). Over the past 

decade, US Airways experienced brief interludes of competition when Delta flew the route, first 

during 2003-2004 and then again in 2010-2012, all with small 50-seat regional jets. 6

 When 

Delta withdrew from the DCA-JAX market in January 2012, nonstop capacity decreased by 

nearly 40%.

B. The Lack of Competition Has Resulted in Higher Fares and Fewer 

Passengers.

When competition existed in the DCA-JAX market, the average fare decreased and 

enplanements increased. As depicted in the charts below, this effect was evident even when US 

Airways faced competition from a high-fare legacy carrier utilizing small regional jets. Upon 

Delta’s withdrawal, these positive trends reversed, and US Airways was left to operate the 

market as a monopoly.

 6 For US Airways and Delta aircraft configurations flown on the route, see historical OAG 

schedules, as provided by Diio (Nov. 26, 2012)
6

Loss of Competition in DCA-JAX Caused Fares to Rise and Service to Fall7

Note: current scheduled capacity through May 2013; fare data through YE 2Q12

 Note: data through YE 2Q2012

A comparison of fares in the DCA-JAX market to competitive DCA routes of a similar 

distance demonstrates the monopoly premium that US Airways charges on the route. In addition 

 7 See OAG schedules in Diio (captured Nov. 26, 2012) and O & D Survey, as provided by Diio.

$50

$100

$150

$200

200

350

500

650

2004 2005 2006 2007 2008 2009 2010 2011 2012

Average fare

Nonstop seats per day

Historical Capacity vs. Fare in DCA-JAX

Daily NS Seats Avg fare

DL 

exits

DL 

enters

$80

$120

$160

$200

100

150

200

250

2004 2006 2008 2010 2012

Average fare

Passengers per day

DCA-JAX Historical Market Size

PDEWs Fare

$100

$125

$150

$175

$200

150

175

200

225

2010 2011 2012

Average fare

Passengers per day

DCA-JAX Market Size Changes

PDEWs Fare

DL 

enters

DL 

exits
7

to JetBlue’s BOS-DCA service, JetBlue also operates nonstop service from DCA to Fort 

Lauderdale-Hollywood (“FLL”), Orlando (“MCO”) and Tampa (“TPA”).8 In each of these 

markets, which are also in Florida and of a similar stage length, JetBlue’s coach fare structures 

are significantly lower, in all categories, than incumbent carrier US Airways on the JAX-DCA 

route, as demonstrated in the chart below. 

*Only sold as roundtrip

III. Granting JetBlue’s Application to Serve DCA-JAX Will Provide Needed 

Competition and Consumer Benefits.

JetBlue’s core philosophy of growing capacity to satisfy demand, regrettably, has been 

difficult to implement at airports where free-market entry has been thwarted due to artificial 

constraints. In particular, of the airports once or currently governed by the High Density Rule,

9

DCA has been especially difficult to enter.

10 Despite a decade’s worth of repeated failed 

attempts to reach commercial terms with incumbent carriers or to gain access through legislative 

means, JetBlue did not begin its very limited DCA operations until November 2010, when it 

obtained a limited number of slots through a commercial transaction with another carrier and 

later through a government approved auction growing out of the US Airways-Delta Air Lines 

“slot swap.” JetBlue has expanded modestly ever since, as shown below.

 8 JetBlue also operates new nonstop service beyond the DCA perimeter to SJU, but as this is new 

service at DCA, never before flown, comparisons are limited to within-perimeter markets served 

by JetBlue.

9 See 33 FR 17896 (Dec. 3, 1968) (codified as 14 CFR part 93, subpart K).

10 JetBlue began commercial operations in 2000, in part, utilizing 75 slot exemptions at JFK 

awarded by the Department. At the time, JFK was a woefully underutilized airport with nearly 

half as many total operations as it has today. JetBlue has also relied in part upon slot exemptions 

and commercial transactions in order to initiate operations at LGA, EWR and ORD. See DOT 

Order 99-9-11 (Sep. 16, 1999).

Advance Purchase

(days) DCA-JAX % higher than in B6 competitive DCA-TPA DCA-FLL DCA-MCO

14 $120* 31% $98 $87 $90

7 $335 194% $118 $118 $106

0 $479 131% $213 $199 $210
8

JetBlue’s Service at DCA

This carefully planned and hard-won entry into the DCA market has resulted in new competitive 

forces being introduced into the market. The proposed service to JAX is a continuation of that 

carefully planned growth strategy that will specifically address a market where competition does 

not exist.

A. JetBlue’s Entry and Expanding Service Has Benefited DCA Travelers.

Introducing and growing our low fare, award-winning customer service at DCA has been 

an important JetBlue goal. While subject to the same constraints as other carriers under the High 

Density Rule, JetBlue has taken aggressive action to grow its presence at the airport. For 

example, as part of the US Airways – Delta slot swap where US Airways acquired 42 additional 

slot pairs from Delta, JetBlue urged the Department to condition the transfer on meaningful 

measures to lessen the anticompetitive impact on customers following the transaction. The 

Department sought to ameliorate the anticompetitive impacts of US Airways’ strengthening its 

already dominant position at DCA and mandated, among other remedies, the divestiture of 16 

slots at the airport. See Petition for Waiver of the Terms of the Order Limiting Scheduled 

Operations at LaGuardia Airport, 76 Fed. Reg. 63,702 (Oct. 13, 2011). In an unprecedented 

process, JetBlue successfully bid at auction for eight slot pairs at DCA, as testament to its depth 

JAX

DCA

BOS (10)

TPA (1)

FLL (3)

MCO (3)

SJU (1)
9

of commitment to expand its low fare service to the nation’s capital.11 JetBlue’s winning bid, 

more than $40 million, was nearly 24% more than the next highest bidder and underpins the 

unique strength of JetBlue’s desire to grow its service at DCA.12 JetBlue has successfully and 

steadily grown its DCA operations into a small but meaningful level of service in several key 

markets. 

In November 2010, JetBlue inaugurated operations at DCA with seven daily roundtrips to 

Boston and one each to its focus cities of Fort Lauderdale/Hollywood and Orlando. This new 

service, even in markets already amongst the most heavily traveled in the nation, has benefited 

the public significantly. As depicted in the chart below, JetBlue’s entry was followed by a 31%

reduction in the average fare level on the DCA-BOS route from $173 to $118. There has been a 

corresponding increase in the amount of traffic on the route; the number of passengers per day 

has nearly doubled from 761 to 1471.

JetBlue’s DCA Entry Increased Traffic and Reduced Fares13

 11 JetBlue had operated, previous to the winning bid, nine roundtrip flights pursuant to a lease 

agreement with American Airlines (8 roundtrips) and one permanently assigned new entrant pair 

of slots from the FAA.

12 Federal Aviation Administration, Slot Reallocation Final Bid Information with Bidder ID 

Assignments for DCA Bundle (Nov. 22, 2011), 

http://www.faa.gov/about/office_org/headquarters_offices/agc/ReAllocation/DCABids/

13 See O & D Survey, as provided by Diio.

761

1,471

0

400

800

1,200

1,600

YE 2Q10 YE 2Q12

BOS-DCA Industry Passengers Per Day

93%

B6 enters
10

JetBlue’s entry into DCA-MCO and DCA-FLL also has led to increases in traffic on the 

routes. As depicted below, traffic has increased by a third (33%) on the DCA-FLL route and by 

nearly half (42%) on DCA-MCO.

JetBlue’s Entry Has Stimulated Traffic Between DCA and Florida14

 14 See O & D Survey, as provided by Diio.

$173

$118

$0

$50

$100

$150

$200

YE 2Q10 YE 2Q12

BOS-DCA Industry Average Fare

(31%)

B6 enters

598

798

0

250

500

750

1,000

YE 2Q10 YE 2Q12

DCA-FLL Passenger Growth with JetBlue Entry

33%

B6 enters

584

828

0

250

500

750

1,000

YE 2Q10 YE 2Q12

DCA-MCO Passenger Growth with JetBlue Entry

42%

B6 enters
11

Low fare new entry, especially on monopoly routes held by legacy carriers, is 

unquestionably beneficial to the travelling public and precisely what JetBlue seeks to expand at 

DCA with its new Jacksonville service.15

The markets where JetBlue has been able to expand and grow its services stand in stark 

contrast to the markets where US Airways has acquired a monopoly in the aftermath of the slot 

swap transaction. Since Delta transferred its DCA slots to US Airways, US Airways has 

acquired a monopoly in seven markets and there is sufficient data to analyze the impact on 

pricing for three of them: DCA-Columbus (“CMH”), DCA- JAX, and DCA-Providence 

(“PVD”). As one would expect, prices have increased in these markets by an average of 19% as 

depicted in the chart below:

Fares Have Increased in US Airways Monopoly Markets

16

Market Remaining carrier YOY fare ∆

DCA-CMH US Airways 4%

DCA-JAX US Airways 16%

DCA-PVD US Airways 40%

US Airways average 19%

If JetBlue’s application to serve DCA-JAX is granted, it forecasts that the introduction of 

its service would have a significant impact on the market that would benefit consumers. JetBlue 

anticipates traffic will grow by 50% while fares will fall by 30%. This small step will bring 

needed relief to travelers on the DCA-JAX route.

 15 See Notice on Petition for Waiver of the Terms of the Order Limiting Scheduled Operations at 

LaGuardia Airport, 75 Fed. Reg. 26322, 26,330 (May 11, 2010) (“DOT believes that, as a 

general rule, in the aviation industry more competitive pressure and pricing discipline can be 

exerted by low-cost carriers than by incumbent legacy carriers. This view is supported by the 

Department of Justice, as well as in the academic literature cited in the Notice and by DOJ in its 

Appendix A. . . . As stated in the Notice, studies indicate that entry by low-cost carriers 

dramatically lowers fares and increases the volume of passengers in a market . . . . ”) (citing 

Comments of the United States Department of Justice, FAA Docket No. 2010-0109 (Mar. 24, 

2010), at 4 & the studies cited therein).

16 See O & D Survey, as provided by Diio.
12

B. JetBlue Has Introduced Award-Winning Customer Service to DCA.

In addition to lowering fares and growing markets, JetBlue also has introduced its awardwinning customer service to DCA. Created after deregulation, JetBlue has achieved profitability 

and customer loyalty through its commitment to customer service. Since our first flight nearly 

thirteen years ago, our commitment to bring humanity back to air travel has proven far more than 

a marketing slogan. JetBlue’s relentless focus on award-winning customer service has been 

widely acclaimed. The loyalty of our customers, more than 26 million last year, has enabled 

JetBlue to receive the prestigious JD Power Award for Customer Satisfaction for an 

unprecedented eighth year in a row.17 JetBlue’s customer-centric approach has enabled its 

profitable growth and allowed JetBlue to become the fastest airline in United States aviation 

history to achieve the ranks of “major” airline as classified by the Department.

JetBlue prides itself on delivering everyday fares coupled with a litany of standard

features that far exceed the extra services provided by other carriers for additional fees. These 

include: 1) no overbooking; 2) first checked bag free; 3) all one-way fares; 4) pre-assigned seats;

5) the most legroom in coach of any domestic carrier; 6) the youngest all-jet mainline fleet of 

any major carrier;

18 7) unlimited snacks and drinks; 8) 136 channels of free entertainment19 and 

9) the award winning customer service delivered by our 14,500 Crewmembers.

Today, JetBlue operates a fleet of 179 new large jet aircraft, comprising 126 Airbus A320 

jets, each with 150 seats, and 53 Embraer E190 jets, each with 100 seats. JetBlue currently 

serves 75 markets, including 21 international destinations.20 JetBlue’s consistent and controlled 

growth since 2000 will continue as the fleet grows to 180 aircraft by the end of 2012, 190 aircraft 

by year end 2013, and 275 aircraft on firm order for delivery by 2021.21 This growing firm order 

 17 See Exhibit B6-2012A-102 for a list of customer service awards won by JetBlue.

18 JetBlue has opted to configure its Airbus A320 fleet with only 150 seats, each with the most 

average legroom in coach of any domestic coach product. By contrast, for example, a Spirit 

Airlines’ Airbus A320 is configured with 178 coach seats, 19% more seats in the same aircraft 

operated by JetBlue, demonstrating one of the standard customer-friendly attributes (legroom) 

offered by JetBlue to all of its customers.

19 Using its LiveTV service, JetBlue provides 136 channels of free entertainment, including 36

channels of premium television, 100 channels of XM radio and 4 on-demand movie channels.

20 JetBlue’s current route map is attached as Exhibit B6-2012A-103 (depicting all the markets

served by JetBlue including seasonal markets Martha’s Vineyard, Nantucket and Anchorage).

21 This fleet growth includes the introduction of the Airbus A321 in 2013 and the Airbus A320-

neo in 2018.
13

book allows JetBlue to grow capacity in the markets where competition has stimulated additional 

demand, further increasing the consumer benefit of its market entry.

IV. Jacksonville Is a Growing, Diversified Metropolitan Area Requiring More 

Frequent and Affordable Service to DCA.

Jacksonville is a growing and thriving market with a diversified economy. With a 

steadily increasing population, Jacksonville is a major intermodal transportation hub. 

Jacksonville has a thriving port for both domestic and international shipping and the cruise ship 

industry. Many major colleges and universities, including the University of Florida, Florida 

State University, Florida A & M and Bethune-Cookman University, which serve more than 

230,000 students, fall within Jacksonville’s catchment area. These institutions include research 

universities with government grants requiring interface with federal agencies. Jacksonville is 

also a major East Coast center of military operations, including the Jacksonville Naval Air 

Station, Mayport Naval Base, Kings Bay Submarine Base and the Florida National Guard 

Headquarters, as well as other military installations. These multifaceted connections between the 

Jacksonville area and the federal government require travel between the region and the preferred 

airport in the nation’s capital, DCA.

Jacksonville is also a regional medical hub, a center for financial and professional 

services, and a tourist destination. Golf is major attraction in the Jacksonville area, and the city 

is home to the Professional Golfers Association (“PGA”) Tour Headquarters. Based on this 

diversified economy, Jacksonville enjoys a higher median household income and a lower 

unemployment rate than the rest of the state of Florida. Traffic at the Jacksonville International 

Airport is very stable with minimal seasonality. All of these attributes suggest a strong need for 

additional service to DCA, yet US Airways has consistently decreased capacity and increased 

fares since Delta’s exit from the market.

V. JetBlue’s Application Satisfies the Statutory Criteria of 49 U.S.C. § 41718(b) 

That the Department Must Consider in Exemption Proceedings.

In 49 U.S.C. § 41718(b), Congress established statutory criteria to direct the 

Department’s decision in slot exemption proceedings. The Notice provided the following 

statement of those five criteria: 
14

the Secretary [shall] distribute within-perimeter slot exemptions in a manner that 

promotes air transportation: (1) by new entrant air carriers and limited incumbent 

air carriers; (2) to communities without existing nonstop air transportation to 

DCA; (3) to small communities; (4) that will provide competitive nonstop air 

transportation on a monopoly nonstop route to DCA; or (5) that will produce the 

maximum competitive benefits, including low fares.

Notice at 1-2. JetBlue’s proposed DCA-JAX service satisfies three of these criteria in a manner 

that provides maximum public benefits. 

1. JetBlue Is a Limited Incumbent Carrier at DCA.

In the FAA Modernization Act of 2012, Congress defined a “limited incumbent air 

carrier” as an air carrier that holds or operates fewer than 40 slots at DCA. See 49 U.S.C. § 

41714(h)(5), as amended by the FAA Modernization and Reform Act of 2012, Pub. L. No. 112-

95, 126 Stat. 11 (Feb. 14, 2012). JetBlue satisfies this definition because it holds or operates 36 

slots at DCA. 

2. JetBlue Will Provide Competitive Nonstop Air Transportation on a 

Monopoly Nonstop Route.

As discussed at length in Section II, the grant of JetBlue’s application will introduce 

competition on a significant route where US Airways has a monopoly. In Department 

proceedings, the introduction of competition in a stifled market has been a primary justification 

for the award of slot exemptions.22

3. JetBlue Will Provide Significant Competitive Benefits and Low Fares.

As discussed in Section II, JetBlue’s proposed DCA-JAX service will have significant 

competitive benefits. JetBlue forecasts that fares will be reduced by 30% and traffic will be 

stimulated by 50%. As the Department has stated in its most recent slot case, Order 2012-7-26, 

the decision as to which criteria to apply and how to weigh them is and can be made on a case by 

case basis, depending on the facts of each case before the Department. JetBlue’s application 

addresses the most important criteria for allocation of DCA slots, the introduction of new low 

 22 See, e.g., Order 2000-7-2 (Jul. 5, 2000) (awarding slot exemptions to Spirit to facilitate its 

proposal to provide “competitive nonstop air transportation on DCA monopoly nonstop routes by 

offering low-fare service to compete with US Airways’ monopoly”).
15

fare service into a market that is presently monopolized by one carrier. The US Airways 

monopoly service inflicts a significant cost on the traveling public in the form of higher fares and 

reduced service. This harm can only be remedied by facilitating more competition when the 

Department has the opportunity in proceedings such as this one.

The two criteria that JetBlue does not satisfy are of secondary importance given the 

potential benefits of JetBlue’s Jacksonville service. First, criterion 2 (service to communities 

without DCA service) is mutually exclusive with criterion 4 (introducing competition on a 

monopoly route). Given the potential size of the JAX-DCA market, where JetBlue proposes to 

introduce service with a 150-seat aircraft, the public benefit will be maximized by introducing 

more capacity, more choice and more service at a lower cost. Second, although JetBlue does not 

propose to serve a small community, that factor is outweighed by the fact that JetBlue will 

introduce competition on a route where a significant number of travelers will benefit.

VI. Conclusion

For all the foregoing reasons, JetBlue respectfully requests that the Department grant its 

application for two slot exemptions to facilitate its new competitive service between DCA and 

JAX.

Dated: December 5, 2012 Respectfully submitted,

Robert C. Land

Senior Vice President for Government Affairs

and Associate General Counsel
16

Certificate of Service

I, J. Parker Erkmann, hereby certify that a copy of the foregoing Application of JetBlue Airways 

Corporation was served this 5th day of December, 2012 via email transmission on the following 

persons:

dhainbach@ggh-airlaw.com

john.varley@virginamerica.com

jyoung@yklaw.com

bob.kneisley@wnco.com

leslie.abbott@wnco.com

howard.kass@usairways.com

robert.wirick@aa.com

francis.heil@aa.com

james.kaleigh@aa.com

Karine.faden@united.com

dan.weiss@united.com

Sascha.vanderbellen@delta.com

john.fredericksen@suncoutry.com

robert.cohn@hoganlovells.com

marshall.sinick@squiresanders.com

charles.donley@squiresanders.com

quince.brinkley@mwaa.com

Susan.Kurland@dot.gov

Esta.Rosenberg@dot.gov

Todd.Homan@dot.gov

brian.ctr.meehan@faa.gov

fbavent@airlineinfo.com

steve.grossman@flyjacksonville.com

jegillick@zsrlaw.com

jhfoglia@zsrlaw.com

and via First Class Mail:

Arnaldo Deleo

General Manager Aviation Bureau

Port Authority

Government of Puerto Rico

PO Box 362829

San Juan, PR 00936-2829

/s/ Parker Erkmann

J. Parker Erkmann
Exhibit B6-2012A-101

Docket DOT-OST-2000-7182

Letters of Support 



Exhibit B6-2012A-102

Docket DOT-OST-2000-7182

Page 1 of 8

JetBlue Customer Service Awards

Year Award Source

2011 Best Airline Logo TV’s NewNowNext Travel Awards

2011 Best Airline Website Booking 

Experience 

U.S. Air Travelers’ Choice Award

2011 Best U.S. Budget Airline About.com

2011 Excellent Web Service 2010 Compuware Gomez Web & Mobile 

Performance Awards

2011 Best Value Airline (Domestic), Most 

Customer Friendly Airline, and Best 

Coach Class Experience

Travel 2011 Editor's Choice Awards

2011 Top Low Cost Airline for Customer 

Satisfaction

JD Power and Associates

2010 Top Low Cost Airline for Customer 

Satisfaction

JD Power and Associates

2010 Spot on list of Top Technology 

Innovators Across America

Information Week 500

2010 Top Rated Large Domestic Airline' for 

Economy and 'Best In-flight 

Entertainment' for Domestic Flights 

Zagat Airline Survey

2010 Best Cabin Ambiance Passenger Choice Awards, Airline 

Passenger Experience Association (APEX)

2010 #1 Airline Brand 2010 Brand Keys Customer Loyalty 

Engagement Index

2010 CIO 100 Award Honoree CIO Magazine

2010 Best Concessions Program Design 

(T5/JFK)

ARN's Best Airport and Concessionaires 

Awards

2010 Most Unique Services (T5/JFK) ARN's Best Airport and Concessionaires 

Awards

2010 Best Overall Concessions Program 

(T5/JFK)

ARN's Best Airport and Concessionaires 

Awards

2010 Best Concessions Management Team 

(T5/JFK)

ARN's Best Airport and Concessionaires 

Awards

2010 Best Coach-Class Experience SmarterTravel Editors' Choice Awards

2010 Most Customer-Friendly Airline SmarterTravel Editors' Choice Awards

2010 Most Pet-Friendly Airline for Carry-on 

Pets

SmarterTravel Editors' Choice Awards

2009 Best Airline Brand 2009 Brand Keys Customer Loyalty 

Engagement Index
Exhibit B6-2012A-102

Docket DOT-OST-2000-7182

Page 2 of 8

JetBlue Customer Service Awards

Year Award Source

2009 Best Environmental Campaign - Jetting 

to Green

Cause Marketing Forum

2009 Best Rated Large Domestic Airline in 

the Economy Category

Zagat Airline Survey

2009 #1 Airline Brand 2009 Brand Keys Customer Loyalty 

Engagement Index

2009 Richard A. Griesbach Award of 

Excellence Winner

ACI-NA 2009 Airport Concessions

2009 #1 U.S. Routes/Single-Class Service 

Airline

Condé Nast Traveler 

2009 Top-Rated Large Domestic Airline -

Economy Seating

Zagat Airline Survey

2009 Best In-Flight Entertainment - Domestic Zagat Airline Survey

2009 5th Annual Extra Miles Awards Budget Travel Magazine

2009 CIO 100 Award Honoree CIO Magazine

2009 Top Low Cost Airline for Customer 

Satisfaction

J.D. Power and Associates

2009 AIGA Corporate Leadership Award AIGA - The Professional Association for 

Design

2008 Best Large U.S. Economy Class Zagat Airline Survey

2008 Best Inflight Entertainment Zagat Airline Survey

2008 Most Eco-Friendly Zagat Airline Survey

2008 Silver Halo- Best Environmental 

Campaign - Jetting to Green

Cause Marketing Forum

2008 Best In-Seat Comfort SmarterTravel Readers' Choice Awards

2008 Best Onboard Entertainment, Domestic 

Airline

SmarterTravel 2008 Readers' Choice 

Awards

2008 Top Low Cost Airline for Customer 

Satisfaction

J.D. Power and Associates

2007 Best Domestic Airline Condé Nast Traveler Readers' Choice 

Awards 

2007 Top Low Cost Airline for Customer 

Satisfaction

J.D. Power and Associates

2007 Best North American Low Cost Airline Skytrax World Airline Awards

2007 World's Most Reliable A320 Fleet Airbus Operational Excellence Awards
Exhibit B6-2012A-102

Docket DOT-OST-2000-7182

Page 3 of 8

JetBlue Customer Service Awards

Year Award Source

2007 #1 Airline Brand 2007 Brand Keys Customer Loyalty 

Engagement Index

2007 Best Low Cost/No Frills Airline OAG, 2007 Airline of the Year Awards

2007 Leading Provider of Domestic Airfare 

Deals 

Travelzoo Awards

2007 Best U.S. Airline Airline Quality Ranking Survey

2007 #2 rated airline University of Nebraska at Omaha Aviation 

Institute and W. Frank Barton School of 

Business at Wichita State University

2007 Best Domestic Airline for Value Travel + Leisure, World's Best Values 

Awards

2007 Most Admired Companies Fortune magazine, #3 rated airline

2007 Best Airline for Customer Satisfaction Market Metrix

2006 Best Domestic Airline Condé Nast Traveler, Readers' Choice 

Awards

2006 Extra Mile Award (shut-eye/snack bar 

services)

Frommer's Budget Travel

2006 Top U.S. Airline for Consumer Demand Kanbay Research Institute 2006 Travel 

Demand Today Report

2006 Best Domestic Airline Travel + Leisure World's Best Values 

Awards

2006 Best Domestic Airline for Value Travel + Leisure, 2006 World's Best 

Values Awards

2006 #1 Airline Brand 2006 Brand Keys Customer Loyalty 

Engagement Index

2006 Highest Low-Cost Carrier Customer 

Satisfaction

J.D. Power and Associates

2006 Best U.S. Airline Airline Quality Ranking Survey, University 

of Nebraska at Omaha Aviation Institute 

and W. Frank Barton School of Business at 

Wichita State University

2006 Best Low Cost/No Frills Airline OAG Airline of the Year Awards

2006 Best Airline Value Entrepreneur Magazine

2006 Passenger Service Award Air Transport World Magazine

2005 Best Value for Cost Condé Nast Traveler Business Travel 

Awards
Exhibit B6-2012A-102

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Page 4 of 8

JetBlue Customer Service Awards

Year Award Source

2005 Best Low-Cost Carrier Condé Nast Traveler Business Travel 

Awards

2005 Best Domestic Airline Condé Nast Traveler Readers' Choice 

Awards

2005 Best Airline for Economy Class Global Traveler magazine

2005 Best Low-Cost Carrier Global Traveler magazine

2005 #1 Airline Brand 2005 Brand Keys Customer Loyalty 

Engagement Index

2005 #2 Domestic Airline Zagat Airline Survey

2005 Great Gay Marketing Award Out & About Travel Magazine Travel 

Awards

2005 #10 Top Performing Medium Airline Aviation Week & Space Technology 

Magazine Top-Performing Companies

2005 #17 Most Improved Medium Airline Aviation Week & Space Technology 

Magazine, 2005 Top-Performing 

Companies

2005 #47 & 48 Reasons to Love Your Country GQ Magazine, "62 Reasons to Love Your 

Country"

2005 Silver Award (JetBlue's Self-Service 

Check-In Kiosk)

Business Week Magazine, 2005 Annual 

Design Awards

2005 #25 JetBlue/Sky's The Limit Wired Magazine, The Wired 40 "masters of 

technology and innovation"

2005 Best Branding The Association of Travel Marketing 

Executives (ATME), 2005 Atlas Awards

2005 World's Best Low-Cost Airline Skytrax Airline of the Year Survey

2005 #2 Airline in North America Skytrax Airline of the Year Survey

2005 Top-Hospitality Airline Market Metrix Hospitality Index

2005 Best Airline Quality The Wall Street Journal Airline Quality 

Survey

2005 Best Airline Service The Associated Press, 2005 Annual Survey

2005 Corporate Community Partnership 

Award

American Red Cross

2005 Best U.S. Airline Customer Satisfaction J.D. Power and Associates

2005 Best Domestic Airline North American Travel Journalists 

Association

2005 Best Value for Cost Condé Nast Traveler Business Travel 
Exhibit B6-2012A-102

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Page 5 of 8

JetBlue Customer Service Awards

Year Award Source

Awards

2005 Great Gay Marketing Award Out & About Travel Magazine Travel 

Awards

2005 #10 Top Performing Medium Airline Aviation Week & Space Technology

Magazine Top-Performing Companies

2005 #17 Most Improved Medium Airline Aviation Week & Space Technology 

Magazine Top-Performing Companies

2005 Silver Award (JetBlue's Self-Service 

Check-In Kiosk) 

Business Week Magazine Annual Design 

Awards

2005 JetBlue/Sky's The Limit Wired Magazine, The 40 "masters of 

technology and innovation"

2005 Best Branding The Association of Travel Marketing 

Executives (ATME) Atlas Awards

2005 World's Best Low-Cost Airline Skytrax Airline of the Year Survey

2005 #2 Airline in North America Skytrax Airline of the Year Survey

2005 Top-Hospitality Airline Market Metrix Hospitality Index

2005 Best Airline Quality The Wall Street Journal Airline Quality 

Survey

2005 Best Airline Service The Associated Press Annual Survey

2005 Corporate Community Partnership 

Award

American Red Cross

2005 Best U.S. Airline Airline Quality Ranking Survey, University 

of Nebraska at Omaha Aviation Institute 

and W. Frank Barton School of Business at 

Wichita State University

2005 Best U.S. Airline Customer Satisfaction J.D. Power and Associates Reports, 2005 

Airline Satisfaction Index Study

2005 Best Domestic Airline North American Travel Journalists 

Association

2004 #1 Airline Brand 2004 Brand Keys Customer Loyalty 

Engagement Index

2004 Best U.S. Service Business 2.0, 2004 Omaha Aviation 

Institute's Quality Ranking Survey

2004 Best Corporate Service USTA/Eastern Corporate Service

2004 Best U.S. Airline Airline Quality Ranking Survey, University 

of Nebraska at Omaha Aviation Institute 

and W. Frank Barton School of Business at 
Exhibit B6-2012A-102

Docket DOT-OST-2000-7182

Page 6 of 8

JetBlue Customer Service Awards

Year Award Source

Wichita State University

2004 Best Domestic Airline Condé Nast Traveler, 2004 Readers' 

Choice Awards

2004 Best Domestic Airline Condé Nast Traveler Business Travel 

Awards

2004 Best Value for Cost Condé Nast Traveler Business Travel 

Awards

2004 #2 Domestic Airline Travel & Leisure World's Best Awards

2004 #2 Domestic Airline Service Travel & Leisure World's Best Service 

Readers' Poll Awards

2004 Best Domestic Airline North American Travel Journalists 

Association, 5-Star Award

2004 North America's Leading Budget Airline 11th Annual World Travel Awards

2004 Top 5 Domestic Airline Departures Readers' Favorite Survey

2004 Best Low Cost Carrier in the World Global Traveler Magazine

2004 Best Low Cost Carrier (Second Place) Executive Travel Magazine

2004 Best in Executive Travel Executive Travel Magazine

2004 Airline Excellence Award, North 

America

Skytrax, 2004 Airline of the Year Survey

2004 Best Low Cost Airline Skytrax Airline of the Year Survey

2004 Best Cabin Staff, North America Skytrax Airline of the Year Survey

2004 Best Airline New York Press, Best of Manhattan 

Readers' Poll

2004 Favorite U.S. Airline Salon.com, Readers' Choice

2004 Most Wanted List Gotham

2004 Best Company in North America Global Finance Magazine

2004 Best CFO (John Owen) Institutional Investor Magazine

2004 Airline Customer Loyalty Award Brandweek

2004 Corporate Service Award United States Tennis Association, Eastern 

Corporate Service Award

2003 Best Domestic Airline Condé Nast Traveler, 2003 Readers' 

Choice Awards

2003 Best Value for Cost Condé Nast Traveler, 2003 Readers' 

Choice Awards

2003 Best Domestic Airline North American Travel Journalists 

Association, Five-Star Award
Exhibit B6-2012A-102

Docket DOT-OST-2000-7182

Page 7 of 8

JetBlue Customer Service Awards

Year Award Source

2003 #1 Airline Brand Brand Keys Customer Loyalty Engagement 

Index

2003 #2 Domestic Airline Travel & Leisure World's Best Awards

2003 Top 5 Domestic Airline Departures, Readers' Favorite Survey

2003 #3 World's Best Low Cost Airline (Best 

U.S. Low Cost Airline)

Business Traveler World's Best Airlines 

Awards

2003 Best Budget Airline 10th Annual World Travel Awards

2003 Best US Airline (Non-Major) Business Travel News Airline Survey

2003 Best Low Cost Airline Entrepreneur Magazine

2003 Best Low Cost Airline Skytrax Airline of the Year Survey

2003 Best Cabin Staff, North America Skytrax Airline of the Year Survey

2003 Airline of the Year Airfinance Journal Deal of the Year

2003 North American Corporate Finance 

Deal of the Year

Airfinance Journal Deal of the Year

2003 Airline Customer Loyalty Award Brandweek

2003 IPO of the Year Corporate Finance Magazine

2003 Marketing Award Airline Business Strategy Award

2003 Editors' Choice Travel-Holiday

2003 Outstanding Inflight Entertainment Onboard Services Onboard Services 

Awards

2003 Outstanding Safety Video Onboard Services Onboard Services 

Awards

2002 Best Domestic Airline Condé Nast Traveler, 2002 Readers' 

Choice Awards

2002 Best Domestic Airline, coach Condé Nast Traveler, 2002 Readers' 

Choice Awards

2002 Best Domestic Airline, Value For Cost Condé Nast Traveler, 2002 Readers' 

Choice Awards

2002 Best Domestic Airline North American Travel Journalists 

Association, Five-Star Award

2002 #2 Domestic Airline Travel and Leisure, 2002 World's Best 

Awards

2002 Best Low-Cost Carrier (Runner-Up) Business Traveler Best in Business Travel 

Awards

2002 "It" Airline Entertainment Weekly It List

2002 Editor's Choice Worth
Exhibit B6-2012A-102

Docket DOT-OST-2000-7182

Page 8 of 8

JetBlue Customer Service Awards

Year Award Source

2002 Marketer of the Year Advertising Age

2002 #4 Brand of the Year brandchannel.com, 2002 Readers' Choice

2002 Finance Award Airline Business Airline Strategy Awards

2002 Market Development Award Air Transport World Industry Achievement 

Awards

2002 Best Overall Airline Onboard Services Onboard Service 

Awards

2002 Best Inflight or Onboard Service Onboard Services Onboard Service 

Awards

2002 Best Onboard Entertainment Onboard Services Onboard Service 

Awards

2002 Best Uniforms (2nd Place) Onboard Services, 2002 Onboard Service 

Awards

2001 Best Domestic Airline, Coach Condé Nast Traveler Business Travel 

Awards

2001 Best Domestic Airline North American Travel Journalists 

Association, Five-Star Award

2001 #2 Domestic Airline Condé Nast Traveler Reader's Choice 

Awards

2001 #2 Domestic Airline Zagat Airline Survey

2001 Best New Airline Money

2001 Favorite U.S. Airline Orange County Register/Knight Ridder

2001 Seal of Approval Diversion

2001 "A" Rating Planetfeedback

2001 #2 Airline Epinions.com

2000 "It" Airline Vanity Fair It List
Exhibit B6-2012A-103

Docket DOT-OST-2000-7182

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