BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

______________________________________
In the Matter of

Docket DOT

- OST

- 2012

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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 AuthorityBEFORE 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 Author ity (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 Wash ington
Dulles International A irports. Reagan National has had federal limitations on its numbers of flights for over four decades, well before the Authority was crea ted in 198 7

. Those 1960’s era
DOT flight limitations were adopted by Con gress at the time it consented to the Authorit y’s
creation . The limitations were designed to resolve issues over congestion and noise at and around Reagan National, and the different role s 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 ofMetropolitan Washington Airports Authority Application for Beyond

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2 today’s mode rn 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 signific antly 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.

The se 60 slot ex emptions will strain the facilities at Reagan National. Th e se 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 jeopa rdy.

Today t here are 44 gates at Reagan National and all are heavily utilized. Airlines hoping to enter the airport following this proceeding may have difficulty securing gate s and other essential operating space. If Congress were to authorize additi onal flights at Reagan National in
the future , it is highly likely that airport’s present 44 gates will not be sufficient to mee t 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 par king. 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
air lines 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 m ore extended periods of time. Thirty times l ast 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 Reag an 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 Nati onal 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

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3 Under this direction, the Authority has acted over the past 25 years to avoid undertaking activities at one airport that could adver sely 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 autho rizations of additional flights at Reagan National . The A uthority 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 carri er 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. M oreover, 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 submitte d,

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 AuthorityMetropolitan Washington Airports Authority Application for Beyond

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4 CERTIFICATE OF SERVICE

I hereby certify that a copy of the foregoing Comments of the Metropolitan Washington Airports Authority has been served this 27 th 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@usair ways.com

pmurphy@lopmurphy.com

barbara.russell@virginamerica.com

brian.ctr.meehan@faa.gov

Marshall.Sinick@squiresanders.com

jegillick@zsrlaw.comMetropolitan Washington Airports Authority Application for Beyond

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5 robert.cohn@hoganlovells.com

patrick.rizzi@hoganlovells.com

anita.mosner@hklaw.com

info@airlineinfo.com

___________________________________ Philip G. Sunderland March 27, 2012