BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

______________________________________

In the Matter of

 Docket DOT-OST-2012-0029

Establishment of Slot Exemption Proceedings

At Ronald Reagan Washington National Airport

Pursuant to 49 U.S.C. section 41718

______________________________________

COMMENTS OF THE METROPOLITAN WASHIINGTON AIRPORTS AUTHORITY

Communication with respect to this document should be sent to:

Philip G. Sunderland

Office of General Counsel

Metropolitan Washington Airports Authority

1 Aviation Circle

Washington, DC 20001-6000

Phone: 703.417.8615

Fax: 703.417.3917

Philip.Sunderland@mwaa.com

Attorney for Metropolitan Washington Airports Authority
BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

______________________________________

In the Matter of

 Docket DOT-OST-2012-0029

Establishment of Slot Exemption Proceedings

At Ronald Reagan Washington National Airport

Pursuant to 49 U.S.C. section 41718

______________________________________

COMMENTS OF THE METROPOLITAN WASHIINGTON AIRPORTS AUTHORITY

The Metropolitan Washington Airports Authority (Authority) files these Comments in 

order to inform the Department of Transportation (DOT) and the applicant carriers in this 

proceeding of circumstances at Ronald Reagan Washington National Airport that will impact 

additional services to the airport. 

The Authority takes no position as to which airlines the Department should select to 

operate the new slot exemptions at Reagan National. The Authority’s concern is with the 

ongoing efficient operation of the airport regardless of which new services are selected.

The Authority is charged by law with the operation of Reagan National and Washington 

Dulles International Airports. Reagan National has had federal limitations on its numbers of 

flights for over four decades, well before the Authority was created in 1987. Those 1960’s era 

DOT flight limitations were adopted by Congress at the time it consented to the Authority’s 

creation. The limitations were designed to resolve issues over congestion and noise at and 

around Reagan National, and the different roles to be played by Reagan National and Dulles 

International. The limitations served to stabilize long-standing concerns about these issues. 

Importantly, the limitations also served as the basis for the capacity design and construction of 
Metropolitan Washington Airports Authority

Application for Beyond-Perimeter Slot Exemptions

Docket OST-2012-0029

2

today’s modern airport facilities at Reagan National. Indeed, the flight limitations are reflected 

in the number of gates and in other facilities now in use at the airport.

Since 2000, Congress has enacted a series of statutes that have increased operations 

significantly at Reagan National. Flights inside and outside the 1,250 mile perimeter were 

increased in 2000 and again in 2003 by a total of 44 slot exemptions. Earlier this year, Congress 

directed that another 16 slot exemptions be approved. 

These 60 slot exemptions will strain the facilities at Reagan National. These facilities 

were simply not designed with these added services in mind. Should Congress continue to add 

exemptions in the future, the efficient operation of the airport will be placed in jeopardy. 

Today there are 44 gates at Reagan National and all are heavily utilized. Airlines hoping 

to enter the airport following this proceeding may have difficulty securing gates and other 

essential operating space. If Congress were to authorize additional flights at Reagan National in 

the future, it is highly likely that airport’s present 44 gates will not be sufficient to meet the 

increased demand. In addition, parking space for aircraft remaining overnight is now virtually 

at capacity. There are 44 aircraft parking spaces at gates and 28 spaces away from gates for 

overnight parking. All 44 gate spaces are now used every night. Of the 28 spaces away from 

the gates, 26 are estimated to be in use every night starting this summer. This means that 

airlines with an unexpected need to overnight an aircraft or wishing to serve a destination 

requiring an overnight parking arrangement will not have the option to keep additional aircraft 

overnight at Reagan National in the future.

As for automobile parking, new flights at Reagan National will cause further strain to 

already busy parking lots. Long-haul flights in particular create the need for greater automobile 

parking capacity since passengers traveling to distant cities park their cars for more extended 

periods of time. Thirty times last year the economy parking lot at Reagan National was 

completely filled to capacity. That situation can now only be expected to worsen.

Finally, the Authority is concerned that the expansion of authorized flights at Reagan 

National has already depressed domestic airline service at Dulles International, and that further 

expansions will only further harm domestic service at Dulles. The Authority has been directed 

by Congress to develop, improve and operate both Reagan National and Dulles International, 

and to manage the two facilities as a “unit” in order to optimize the performance of each. 
Metropolitan Washington Airports Authority

Application for Beyond-Perimeter Slot Exemptions

Docket OST-2012-0029

3

Under this direction, the Authority has acted over the past 25 years to avoid undertaking 

activities at one airport that could adversely affect the other. Unfortunately, the authorization 

of new flights at Reagan National has, in our view, had the effect of adversely affecting 

operations at Dulles International, and we believe that similar adverse effects will follow from 

future authorizations of additional flights at Reagan National. The Authority intends to carefully 

monitor the impacts of the recently-authorized increased operations at Reagan National on

Dulles International. 

In conclusion, the Authority takes no position on carrier selection. However, the parties 

need to be aware that their new services will place a strain on facilities at Reagan National 

which will have negative impacts on their abilities, as well as Authority’s ability, to provide 

quality passenger services. Moreover, the authorization of even more flights at Reagan 

National in future years will further impair operations at the airport, will likely require major 

facility improvements, and could undermine services at Dulles International. 

Respectfully submitted,

Philip G. Sunderland

Office of General Counsel

Metropolitan Washington Airports Authority

1 Aviation Circle

Washington, DC 20001-6000

Phone: 703.417.8615

Fax: 703.417.3917

Philip.Sunderland@mwaa.com

Attorney for Metropolitan Washington Airports Authority
Metropolitan Washington Airports Authority

Application for Beyond-Perimeter Slot Exemptions

Docket OST-2012-0029

4

CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Comments of the Metropolitan Washington 

Airports Authority has been served this 27th day of March 2012 upon each of the following 

addressees:

bob.kneisley@wnco.com

msinick@ssd.com

carl.nelson@aa.com

sascha.vanderbellen@delta.com

jeff.morgan.@delta.com

jhill@dowlohnes.com

jyoung@yklaw.com

dkirstein@yklaw.com

john.fredericksen@suncountry.com

dan.weiss@united.com

steve.morrissey@united.com

jonathan.lind@united.com

howard_kass@usairways.com

benjamin_slocum@usairways.com

pmurphy@lopmurphy.com

barbara.russell@virginamerica.com

brian.ctr.meehan@faa.gov

Marshall.Sinick@squiresanders.com

jegillick@zsrlaw.com
Metropolitan Washington Airports Authority

Application for Beyond-Perimeter Slot Exemptions

Docket OST-2012-0029

5

robert.cohn@hoganlovells.com

patrick.rizzi@hoganlovells.com

anita.mosner@hklaw.com

info@airlineinfo.com

___________________________________

Philip G. Sunderland

March 27, 2012