BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

____________________________________________

Application of )

US AIRWAYS, INC. )

for an exemption pursuant to 49 U.S.C. §41718 (b) )

 )

For service between Oklahoma City (OKC) and ) Docket DOT-OST-2000-7182

Ronald Reagan Washington National Airport (DCA) )

____________________________________________

ANSWER OF OKLAHOMA CITY DEPARTMENT OF AIRPORTS

IN SUPPORT OF THE APPLICATION OF US AIRWAYS

TO SERVE RONALD REAGAN WASHINGTON NATIONAL AIRPORT

_____________FROM WILL ROGERS WORLD AIRPORT_____________

Communications with respect to this document should be sent to:

Mark Kranenburg

Director of Airports

Oklahoma City Department of Airports

7100 Terminal Drive

Oklahoma City, OK 73159

Mark.kranenburg@okc.gov

Direct phone: (405) 316-3200

December 19, 2012
1

BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

____________________________________________

Application of )

US AIRWAYS, INC. )

for an exemption pursuant to 49 U.S.C. §41718 (b) )

 )

For service between Oklahoma City (OKC) and ) Docket DOT-OST-2000-7182

Ronald Reagan Washington National Airport (DCA) )

____________________________________________

INTRODUCTION

On December 5, 2012, US Airways, Inc. (US Airways) applied for two slot exemptions at 

Ronald Reagan Washington National Airport (DCA) to initiate the only non-stop service 

between DCA and Oklahoma City Will Rogers World Airport (OKC), a small hub airport as 

classified by the FAA (1). These slot exemptions authorize service to a medium-hub or smaller 

airport within the 1,250-mile perimeter established for civil operation at DCA, under Title 49 

U.S.C. §49109. 

In addition, upon an award of these slot exemptions, US Airways proposes to initiate two daily 

non-stop departures between OKC and Charlotte-Douglas International Airport (CLT) – which 

would also represent the only two non-stop departures in this market. Details of US Airways’

service proposal are as follows:

ROUTES: DCA-OKC and CLT-OKC

SCHEDULE: Westbound: 13:50 DCA – 16:10 OKC

Eastbound: 16:40 OKC – 20:30 DCA

Westbound: 11:15 CLT – 12:47 OKC

(1) Note that for purposes of AIR 21/Vision 100 slot exemption applications, OKC is considered a medium hub airport under 

the 1997 hub classifications
2

Eastbound: 13:30 OKC – 16:48 CLT

Westbound: 20:30 CLT – 22:02 OKC 

Eastbound: 07:15 OKC – 10:33 CLT

AIRCRAFT: OKC-DCA service to be operated with mainline E-190 aircraft

OKC-CLT service to be operated with CRJ-700 and CRJ-900 aircraft

APPLICATION MEETS STATUTORY CRITERIA

As per its filing, US Airways’ proposed service would significantly advance the statutory goals 

of AIR-21 and Vision 100 by providing the “maximum competitive benefits to a small 

community that lacks nonstop DCA air transportation”. In addition (and again per US Airways’ 

Application), US Airways’ “three-for-one” service proposal “not only provides first-ever 

nonstop service between OKC and DCA, but also links OKC with US Airways’ largest hub in 

CLT and over 125 connecting destinations (21 international)”. This new portfolio of service will 

lead to substantial consumer benefits.

OKLAHOMA CITY – AN ECONOMIC SUCCESS STORY

With a Metropolitan Statistical Area (MSA) population of just under 1.3 million people, the 

Oklahoma City region is the 43rd largest MSA in the United States (2). Population in the region

grew at over 14% from 2000-2010, an above-average figure across the top 50 metropolitan areas. 

The Oklahoma City region extends into Canadian, Cleveland, Oklahoma, and Pottawatomie 

counties, which include many rural and suburban communities.

Oklahoma City is a city that has invested in itself. Much of its “above-average” growth is due to 

a series of voter-approved sales tax initiatives called the Metropolitan Area Projects (MAPS), a 

visionary capital improvement program that revitalized the community along with its national 

image. Over a period of nine years, MAPS has funded new and upgraded sports, recreation, 

entertainment, cultural, and convention facilities, as well as infrastructure improvements for all 

(2) U.S. Census – 2011 estimate
3

Oklahoma City public schools. The citizens of Oklahoma City have voted three times in favor of 

these projects, providing an investment of $1.84 billion in community enhancements and 

spurring over $5 billion in private sector investments. Oklahoma City and MAPS have become a 

national model for other communities looking to grow and revitalize their cities.

Oklahoma City is the primary economic engine for this region, as well as the entire state of 

Oklahoma, producing over 50% of the state’s job growth since 2009. Oklahoma City’s 

economic profile remains disproportionately strong when compared to the rest of the United 

States, in terms of total performance as well as recent growth. A partial list of the region’s 

accomplishments includes:

 Ranked 6

th best among metropolitan areas for performance during the economic 

recovery of 2009-2010 by The Brookings Institute – based on unemployment rate, job 

creation, housing prices, and the value of goods and services provided;

 Produced the lowest unemployment rate of any U.S. region of over 1 million people 

for 18 of the last 22 months, and finished among the three lowest for each month over 

the last three years; and

 Generated an unemployment rate approximately three percentage points lower than 

the national average in October 2012 (4.9% vs. 7.9%)

Many of the region’s largest employers have significant ties to the Washington, DC area, driving 

enhanced economic benefit to the region from the proposed new service (an estimated 5% of 

total employment in the Oklahoma City region is driven by the federal government):

 As the state’s capital, Oklahoma City has the greatest concentration of 

government agencies and offices located within the state;
4

 Tinker Air Force Base is Oklahoma’s largest single site employer (27,000), with 

the largest group of civilian Air Force personnel in the United States; and

 The FAA’s Mike Monroney Aeronautical Center is one of the Department of 

Transportation’s largest facilities located outside of the Washington, DC area.

In addition, energy, aviation/aerospace, and bioscience each have a strong presence in the region 

- and are all growing at a rapid rate. Highlights include:

 Oklahoma is now one of the top ten states in traditional aerospace occupation 

employment, with more than 300 public and private-sector aviation and aerospace 

firms;

 Oklahoma ranks twelfth nationally in the number of aerospace engineers, fifth in 

aircraft mechanics and service technicians, and eighth in avionics technicians;

 The Boeing Company has recently relocated 1,200 high-level jobs to Oklahoma 

City from California, and has started relocating another 300 employees from 

Wichita; these moves will double its employee base in the community; 

 Oklahoma City is home to the headquarters of two Fortune 500 energy 

companies; and

 Bioscience remains one of the fastest growing sectors, employing over 26,000 in 

health care, research, education, and technology.

Oklahoma City has recently been lauded with several economic growth and quality of life-type 

headlines and honors, including:

 “Oklahoma City ranked in the top ten in manufacturing growth” - U.S. Bureau of 

Labor Statistics, February 2012;
5

 “Only 13 of top 100 metro areas have bounced back from the recession” - U.S. 

Bureau of Labor Statistics, February 2012;

 “10 Great Cities for Starting a Business” - Kiplinger, December 2011;

 “Fourth Best City for a Job Search” - BenefitsPro, October 2011; and

 “Top 10 Best Places To Live” - RelocateAmerica, August 2011.

Numerous community leaders and representatives from the region’s major employers have 

written letters of support for US Airways’ application to serve the OKC-DCA market. These can 

be found in Exhibit A.

In summary, the economic profile and growth trajectory of the Oklahoma City market remains 

perfectly positioned to take maximum advantage of the benefits from non-stop service to DCA.

WILL ROGERS WORLD AIRPORT

OKC is Oklahoma City’s commercial airport, generating nearly 1.8 million enplanements in 

2011 (a 3% increase from 2010). OKC is the largest FAA-designated small-hub airport, and

represents the primary commercial facility for a large portion of the state of Oklahoma. OKC is 

typically a medium-to-high load factor airport, with an aggregate twelve-month figure of 77% 

and several routes operating at 80% or higher (3). As of December 2012, airlines serving OKC 

operate over 67 daily departures to a total of 21 non-stop destinations - increasing to 75 daily 

departures by Summer 2013 (4).

OKC sits on 8,100 acres with three active runways, and is home to 67 tenants and more than 

10,000 employees. In 2006, the airport completed a $110 million terminal expansion/renovation 

project, transforming the 1967 terminal building into a modern, passenger-friendly facility. Two 

significant projects are currently in the design and engineering phase which will further enhance 

(3) U.S. DOT T100 data; YE August 2012

(4) Innovata schedule data via Diio online portal; includes seasonal adds
6

the passenger and security experience at OKC. The first project is a new $35 million 

consolidated rental car facility, which will provide much needed capacity and smoother 

operations for inbound travelers. The second is a new $25 million baggage inspection system,

which will more efficiently and effectively screen passenger bags. 

THE OKLAHOMA CITY – DCA MARKET

Oklahoma City currently generates approximately 25% more traffic to DCA than any other 

city/metropolitan area located inside of the 1,250-mile DCA perimeter lacking non-stop service. 

Top 10 markets inside the DCA perimeter without non-stop service to DCA

Annual Passengers per Day Each Way (PDEWs) for YE 2Q2012

Schedule data as of December 2012

Market PDEWs to DCA

Oklahoma City (OKC) 53.9

Grand Rapids (GRR)* 42.9

Wichita (ICT) 35.7

Tulsa (TUL) 35.3

Baton Rouge (BTR) 30.7

Gulfport (GPT) 28.5

Moline (MLI) 24.8

Montgomery, AL (MGM) 23.4

Cedar Rapids (CID) 22.3

Bloomington-Normal, IL (BWI) 21.0

Source: US DOT O&D survey and Innovata schedule data via Diio online portal

* Market offered non-stop service at some point during twelve-month reporting period (min. 10 departures)

Despite this lack of non-stop service (and also despite daily non-stop flights from OKC to both 

BWI and IAD), the OKC-DCA market generated 54 passengers per day each way (PDEWs)

during the year ended June 30, 2012 (YE 2Q12). Given that all of these passengers traveled on 

connecting itineraries - choosing to bypass non-stop options to BWI and IAD - it is clear that 

DCA is a critical destination for the Oklahoma City community. Also of note is that Oklahoma 

City remains the largest inside-the-perimeter state capital market lacking non-stop service to 

DCA (5), a key destination for many government stakeholders. While residents of smaller 

(5) Innovata schedule data via Diio online portal
7

inside-the-perimeter capitals such as Columbia (SC), Tallahassee (FL), and Lansing (MI) enjoy 

non-stop DCA service, Oklahoma City residents do not currently have non-stop access to this 

important destination.

Many of Oklahoma City’s peer regions (as defined by MSA population) located inside of the 

DCA perimeter currently support service to BWI, IAD and DCA – including Raleigh/Durham 

(RDU), New Orleans (MSY), Nashville (BNA), and Jacksonville (JAX). Given the existing 

OKC-DCA passenger numbers in the absence of non-stop service, Oklahoma City can also easily 

support service from all three Washington airports.

Oklahoma City “Peer MSAs” – service to Washington area airports

Only markets inside the DCA perimeter are listed – schedule data as of December 2012

MSA 

rank

MSA MSA 

population 

(000s)

Primary 

airport

IAD 

non-stop 

service

DCA 

non-stop 

service

BWI 

non-stop 

service

36 Virginia Beach-Norfolk-Newport News, 

VA-NC

1,679.9 ORF Yes Yes Yes

37 Nashville-Davidson-MurfreesboroFranklin, TN1,617.1 BNA Yes Yes Yes

38 Providence-New Bedford-Fall River, RIMA1,600.2 PVD Yes Yes Yes

39 Milwaukee-Waukesha-West Allis, WI 1,562.2 MKE No Yes Yes

40 Jacksonville, FL 1,360.3 JAX Yes Yes Yes

41 Memphis, TN 1,325.6 MEM No Yes No

42 Louisville-Jefferson County, KY-IN 1,294.8 SDF Yes Yes Yes

43 Oklahoma City, OK 1,278.1 OKC Yes No Yes

44 Richmond, VA* 1,269.4 RIC Yes No* No

45 Hartford-West Hartford-East Hartford, CT 1,213.3 BDL Yes Yes Yes

46 New Orleans-Metairie-Kenner, LA 1,191.1 MSY Yes Yes Yes

47 Raleigh-Cary, NC 1,163.5 RDU Yes Yes Yes

49 Buffalo-Niagara Falls, NY 1,134.0 BUF Yes Yes Yes

50 Birmingham-Hoover, AL 1,132.3 BHM No Yes Yes

51 Rochester, NY 1,055.3 ROC Yes Yes Yes

* Note that the stage length from RIC to DCA is 94 miles

Source: U.S. Census (2011 estimate) and Innovata schedule data via Diio online portal
8

THE STATE OF OKLAHOMA LACKS NON-STOP SERVICE TO DCA

As detailed in Exhibit B, Oklahoma remains the most populated inside-the-perimeter state 

without non-stop service to DCA. As such, US Airways’ proposed service will stimulate and 

carry traffic from a broad catchment area spanning other parts of the state. This will include

smaller outlying communities with significant connections to Washington, DC, such as Norman 

(home to the University of Oklahoma), Stillwater (home of Oklahoma State University), and 

Enid (home of Vance Air Force Base). In addition, the Tulsa metropolitan area - home to nearly 

950,000 residents - lies less than two hours northeast of OKC on Interstate 44. For the YE 2Q12,

an additional 35 PDEWs traveled from Tulsa International (TUL) to DCA, bringing the PDEW 

total from the two airports to 89 – all on connecting itineraries. In summary, non-stop OKCDCA service will provide significant benefits across much of Oklahoma.

HOUSTON AND JACKSONVILLE PASSENGERS CURRENTLY BENEFIT FROM

NON-STOP DCA SERVICE

Unlike the Oklahoma City market, Houston and Jacksonville already enjoy non-stop service to 

DCA, as well as a broad array of flights to all three Washington airports. US Airways’ proposed 

service to OKC represents the only current opportunity for the U.S. Department of 

Transportation to bring DCA service to an unserved metropolitan area.

NEW SERVICE FROM OKLAHOMA CITY TO US AIRWAYS’ CHARLOTTE HUB

As part of this service offering, US Airways also proposes twice daily service from OKC to its

hub at CLT, which currently serves over 125 destinations – including 21 international markets

across Europe, Central and South America, and the Caribbean. For the period YE 2Q12, 

approximately 19 PDEWs traveled between OKC and CLT – all on connecting itineraries. 

However, over that same period, a subset of Oklahoma City’s peer MSAs (based on population)
9

which offered non-stop US Airways service to CLT generated on average just under 100 

PDEWs, demonstrating the likely traffic growth this new service will drive. 

Oklahoma City “Peer MSAs” - Traffic Flows to CLT (YE 2Q12)

MSA 

rank

MSA/Airport Primary 

airport

PDEWs to 

CLT

Non-stop to 

CLT**

38 Providence-New Bedford-Fall River, RIMAPVD 152.2 Yes

39 Milwaukee-Waukesha-West Allis, WI MKE 113.4 Yes

40 Jacksonville, FL JAX 83.3 Yes

41 Memphis, TN MEM 91.9 Yes

42 Louisville-Jefferson County, KY-IN SDF 62.9 Yes

43 Oklahoma City, OK OKC 18.9 No

44 Richmond, VA RIC 54.9 Yes

45 Hartford-West Hartford-East Hartford, CT BDL 149.6 Yes

46 New Orleans-Metairie-Kenner, LA MSY 123.3 Yes

47 Raleigh-Cary, NC RDU * Yes

48 Salt Lake City, UT SLC 64.6 Yes

Average (non-OKC): 99.6

 * RDU is only 130 miles from CLT; O&D totals not included in average

 ** Schedule references are for July, 2012 (historical)

Source: US DOT O&D survey and Innovata schedule data via Diio online portal 

In addition, OKC generated over 1,000 PDEWs to domestic markets US serves from CLT which 

would provide geographically reasonable connections to OKC passengers – a figure which does 

not even take into account the previously mentioned 21 international destinations.

US AIRWAYS WOULD REPRESENT A NEW CARRIER FOR OKC

In addition to the fact that Oklahoma City is an ideal market for new DCA non-stop service, the 

proposed service profile from US Airways would in many ways optimize potential benefits to the 

Oklahoma City region. Key reasons include:
10

New carrier for OKC

The commencement of service detailed in this proposal would introduce service to OKC from 

the only major network carrier not currently serving the airport, providing the region’s travelers 

with new access to US Airways’ extensive domestic and international network.

Additional non-stop market

This proposal offers a “three-for-one” service introduction – including service to the third largest 

hub in the United States (US at CLT), which operates non-stop to over 125 destinations across 

three continents. This proposal is the only one in this current process which offers service to a 

market in addition to DCA.

Two-class aircraft

US Airways proposes to serve the OKC-DCA market with 99-seat mainline E-190 aircraft, and 

the OKC-CLT market with CRJ-900 (79 seats) and CRJ-700 (67 seats) aircraft. All of the 

proposed flights will offer two-class service, which is of particular importance to key frequent 

flier and business traveler segments. All proposed aircraft are also Stage 3 compliant.

Analysis of projected incremental traffic

US Airways included in their application the projected incremental traffic volume to the 

Oklahoma City region from the two proposed new routes. Their findings included:

 Over 56,000 annual passengers generated on the new OKC-DCA service, driven by a 

segment load factor of 78%; and

 Over 84,000 annual passengers generated on the new OKC-CLT service, driven by a 

segment load factor of 79%.

12

EXHIBIT A

The following parties submitted letters of support for this application:

 Mark Kranenburg, Director of Airports, City of Oklahoma City Department of Airports

 Oklahoma U.S. Congressional Delegation

 Mary Fallin, Governor, State of Oklahoma

 Senator Brian Bingman, President Pro Tempore, Oklahoma State Senate

 Representative T.W. Shannon, Speaker-elect, Oklahoma House of Representatives

 Mick Cornett, Mayor of the City of Oklahoma City

 Larry McAtee, Councilman, Ward 3, City of Oklahoma City; Trustee, Oklahoma City 

Airport Trust

 Gary Marrs, Councilman, Ward 1, City of Oklahoma City; Surrogate Trustee, Oklahoma 

City Airport Trust

 Brad Henry, Former Governor of the State of Oklahoma

 David L. Boren, President, University of Oklahoma; Former Governor of the State of 

Oklahoma; Former Oklahoma U.S. Senator

 David Walters, President, Walters Power International; Former Governor of the State of 

Oklahoma

 James D. Couch, City Manager, City of Oklahoma City; Trustee, Oklahoma City Airport 

Trust

 Kirk Humphreys, Chairman, The Humphreys Company; Vice Chairman, Oklahoma City

Airport Trust; Former Mayor of Oklahoma City

 Terry Salmon, President, Computer System Designers; Trustee, Oklahoma City Airport 

Trust

 Roy Williams, President, Greater Oklahoma City Chamber of Commerce

 J. Larry Nichols, Executive Chairman, Devon Energy Corporation

 William E. Durrett, Senior Chairman of the Board, American Fidelity Corporation

 Rick Bott, President and Chief Operating Officer, Continental Resources

 Peter Delaney, Chairman, President and CEO, OGE Energy Corporation

 C. Bruce Lawrence, President and CEO, Integris Health

 Sheri Stickley, President and CEO, Oklahoma Bioscience Association

 Rhonda Hooper, President & CEO, Jordan Advertising

 Ronald Perry, President, Prime Time Travel

 Michael C. Turpen, Attorney, Riggs, Abney, Neal, Turpen, Orbison & Lewis

 LeAnn Jenkins, Executive Director, Oklahoma Federal Executive Board

 Kelly Brander, President and CEO, Arvest

 Robert C. Zahl, Zahl-Ford, Inc.

 Berry Johnson, Citizen, City of Oklahoma City
13

EXHIBIT B

Air service to DCA – “inside-the-perimeter” states with population over three million

Schedule data as of December 2012

State Population 

(000s)

Non-stop 

markets 

to DCA

Texas 25,146 3

New York 19,378 8

Florida 18.801 12

Illinois 12,831 1

Pennsylvania 12,702 2

Ohio 11,537 4

Michigan 9.884 2

Georgia 9,688 3

North Carolina 9.535 6

New Jersey 8.792 1

Massachusetts 6,548 1

Indiana 6,484 1

Tennessee 6,346 4

Missouri 5,989 2

Wisconsin 5,687 2

Minnesota 5,304 1

Alabama 4,780 2

South Carolina 4,625 4

Louisiana 4,533 1

Kentucky 4,339 3

Oklahoma 3,751 0

Connecticut 3,574 1

Iowa 3,046 1

Note: Virginia and Maryland not included due to proximity to DCA

Source: U.S. Census (2010) and Innovata schedule data via Diio online portal