BEFORE THE OFFICE OF THE SECRETARY DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

_____________________________________ ) Applications of ) ) US AIRWAYS, INC. ) REPUBLIC AIRLINE INC. ) MN AIRLINES, LLC )

d/b/a SUN COUNTRY AIRLINES ) Docket DOT - OST - 2000 - 7182 AIRTRAN AIRWAYS INC. ) SOUTHWEST AIRLINES CO. ) ) For exemptions from 14 C.F.R. Part 93, ) Subparts K and S, pursuant to 49 U.S.C. ) § 41718(b) ) ) For service from Ronald Reagan ) Washington National Airport (within

- ) perimeter slot exemptions) )

_____________________________________ )

REPLY OF SOUTHWEST AIRLINES CO. Communication with respect to this document should be addressed to: Bob Jordan Robert W. Kneisley

Executive Vice President

-- Associate General Counsel Strategy and Planning Leslie C. Abbott SOUTHWEST AIRLINES CO. Attorney 2702 Love Field Drive SOUTHWEST AIRLINES CO. Dallas, TX 75235

- 1611 1901 L Street, NW Suite 640 Ron Ricks Washington, DC 20036

Executive Vice President

-- bob.kneisley@wnco.com Corporate Services (202) 263

- 6284 SOUTHWEST AIRLINES CO. 2702 Love Field Drive Dallas, TX 75235

- 1611 October 26, 20101 BEFORE THE OFFICE OF THE SECRETARY DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

_____________________________________ ) Applications of ) ) US AIRWAYS, INC. ) REPUBLIC AIRLINE INC. ) MN AIRLINES, LLC )

d/b/a SUN COUNTRY AIRLINES ) Docket DOT - OST - 2000 - 7182 AIRTRAN AIRWAYS INC. ) SOUTHWEST AIRLINES CO. ) ) For exemptions from 14 C.F.R. Part 93, ) Subparts K and S, pursuant to 49 U.S.C. ) § 41718(b) ) ) For service from Ro nald Reagan ) Washington National Airport (within

- ) perimeter slot exemptions) )

_____________________________________ ) RE PLY OF SOUTHWEST AIRLINES CO. Southwest Airlines Co. (“Southwest”) files this Reply to the answers filed by other applicants in this proceeding in order to correct factual errors (specifically by Republic) 1 as well as to respond to inaccurate and/or inappropriate statements by other parties. Southwest requests leave from the Department to the extent necessary to file this Reply. G ood cause exists for granting this request, as th e Reply is narrowly tailored to factual inaccuracies and improper statements raised in the other parties ’ answers, and will thereby provide the Department with a more complete and accurate record upon which to base its decision. 2

1 Common names of the applicant carriers are used in this document. 2 DOT Rule 6 (14 CFR § 302.6).2 I. REPUBLIC IS NOT “ A LOW - FARE CARRIER ,” ESPECIALLY IN THE DCA MCI MARKET In unusually strident language even for a slot exemption proceeding, Republic ’s Answer hurls s everal inflammatory charges at Southwest, while at the same time repeatedly threatening to sue the Department if it “confiscates” 3 the slot exemptions and thereby interfere s with “ Republic’s rightful entitle ment under the law. ” 4 Incredibly, Republic ’s counsel ev en goes so far as to call Southwest (which holds no DCA slots) “gluttonous” 5 for electing to compete against Republic (the holder of 14 1 DCA slots) for two slot exemptions. Beyond that, Republic labels Southwest’s proposal to serve DCA “irresponsible” and “a grave disservice to the travelling public.” 6

Republic r epeated ly asserts that it is a “ low

- fare carrier ” an d that it will “maintain [its]... low

- fare service between DCA and Kansas City” if awarded the two slot exemptions at issue in this proceeding. These and other epithets are baseless , but they do underscore the fact that Republic is desperate to avoid head

- to
- head competition against Southwest in the DCA

- MCI market, and will go to extreme lengths to protect its privileged position there. In fact, aside from its overheated rhetoric, Republic ’s Answer makes s everal mis

- statements in describing its

own DCA

- MCI service as well as Southwest’s propos al for competing service in the same market

.

7

3 Republic Answer at 21

. However, the most recent DOT data available (y ear e nding March 31, 2010) show conclusively that Republic charges high fares, an

4 Id . at 12, n. 13

. 5 Id at 15

. 6 Id . at 16. 7 Id . at 1.3 average of $ 213 each way in the DCA

- MCI market including taxes

. 8 Republic claims that this information is “out

- of

- date ,” 9
In stead , Republic urges the Department to believe that it has now “adopted Frontier’s pricing model” and will charge low fares on the DCA

- MCI route going forward. However, this “ deathbed conversion ” is merely an assertion of counsel with no supporting evidence. It is instructive that Republic failed to mention this “low fare pricing model” in its original application, which it filed before Republic learned that Southwest was also applying for the sa me slot exemptions in the same market

. yet does not refute th e accuracy of this fare data.

10 Moreover, Frontier’s low

- cost structure is based largely on utilization of mainline Airbus equipment in long

- haul , leisure

- oriented Denver markets. Republic’s claim that Frontier’s average fare on the DCA

- DEN route
- flown with a 150

- seat A320 aircraft

- somehow substantiates Republic’s “low

- fare” claims for the business

- oriented DCA

- MCI
route

– flown with RJ aircraft at least one

- third smaller and over a stage length that is 526 miles shorter

– is absurd

. 11 Republic also suggests that Southwest distorts Republic’s reported fares in its analysis because “they are tainted by the fares of US Airways.” 12

8 Included in this Reply is a Surrebuttal Statement of Dr. Brian M. Campbell and corresponding exhibits prepared by the Campbell

- Hill Aviation Group o n behalf of Southwest Airlines

. This is incorrect. Exhibit WN

- 3 shows Republic’s average fare and US Airways’ average fare in the DCA

MCI mar ket separately. As it happens, both fares are high and very close to one another. Including average baggage and cancellation fees paid per passenger ( but

9 Republic Answer at 20. 10 In its Application, Republic only stated in passing that “as of September 2010 and Republic’s brand transformation from Midwest to Frontier, Republic introduced one

- way pricing i n the DCA

- MCI market.” Republic Application at 9

. 11 Republic proposes to use aircraft almost 40% smaller than Southwest’s full sized jets. See Exhibit WN

- SR

- 1. If Republic really believe s that additional seat capacit y is warranted on this route, it is certainly free to up

- gauge the aircraft it uses for its two other daily flights. 12 Republic Answer at 20.4 excluding all taxes ) , Republic’s average fare for the 12 months ended March, 2010 (the most recent D OT data available) was $174. 13 US Airway’s average fare for the same period was slightly higher at $181 , so the weighted average for the two carriers in the market was $177. Thus, Republic’s much touted claim that it is “the Lowest Fare Carrier in the Kansas City

- Washington, D.C. market” 14

In addition, Republic suggests that Southwest has made “unsupportable claims about Republic’s fares by adding ancillary revenues that are not broken down by any data released by DOT.” actually means nothing more than charging a few dollars less than US Airways. This high

- fare duopoly will continue unless Southwest is given the opportunity by the Department to provide low

- fare competition in this ma rket

.

15

Finally, Republic’s privately negotiated contract fare for federal government employee travel is not r elevant to the question of whether or not Republic provides consumers with low fares in the DCA

- MCI market

. To state the obvious, t his fare is not available to the general public and has no bearing on the fares that would be availa ble in the open marketplace. In fact, this fare is likely below Republic’s fully allocated costs, However, data on Republic’s baggage and cancellation fees

–
an a verage of $ 13.34 per passenger for YE March 31, 2010 and $14.71 for 1 st Quarter 2010

– come directly from data that Republic itself reported to DOT in its quarterly Form 41 filings. In order to make apples

- to
- apples fare comparisons , it is entirely approp riate
t o include empirical , carrier

- specific data on passenger - paid ancillary fees since this provides a more accurate picture of the total cost of the ticket to passengers.

13 See Fare Comparison Table in Section II. See also , Rebuttal Statement of Campbell

- Hill at 5 and Exhibit WN

- R

- 2

. This fare is consistent with Republic’s own statement that its fare for this period was $159, a figure that excludes average per - passenger baggage and cancellation fees of approximately $ 14.71 . Republic Answer at 20. 14 Republic Answer at 2 and 4. 15 Id

. at 20.5 placing pressure on Republic to cross

- subsidize its government fare by charging well above average fares to the public. 16
Based on all available published d ata, as well as the evidence in the record, it is clear that Republic has not provided consumers with low fares in the MCI

- DCA market over the past six years when it had an opportunity to do so , and there is no reason to believe that it will materially red uce fares going forward

– unless , or course, it is faced with low

- fare competition from Southwest Airlines.

II. DESPITE REPUBLIC’S CLAIMS TO THE CONTRARY, SOUTHWEST CONSISTENTLY OFFERS WELL DOCUMENTED LOW FARES TO CONSUMERS Republic goes to great lengths to try to discredit the fare comparisons Southwest presented in its initial A pplication which demonstrated that Southwest would charge significantly lower fares than Republic ’s existing fares in the DCA

- MCI market. However, Republic completely fails in its effort because it has employ ed data in a misleading fashion that precludes apples

- to
- apples comparisons. For example, Republic argues that Southwest’s projected $132 fare for DCA

- MCI is belied by Southwest ’s average fare in the BWI

- MCI market of $161 for 1 st Quarter 2010

. 17 As Southwest discussed in detail in its Answer, BWI is a separate competitive market from DCA and thus is entirely irrelevant to this proceeding. 18

16 Surrebuttal Statement of Dr. Brian M. Campbell at 2. However, even if that were not the case, Republic’s claim is erroneous. Based on DOT’s most recent Form 41 data, Southwest’s fare for the BWI

- MCI market for 1 st Quarter 2010 was

17 Republic Answer at 20. 18 Southwest Answer at 6

- 7; Rebuttal Statement of Dr. Brian M. Campbell at 5

- 6; Exhibits WN

- R

- 22 and 23. Both DOT and DOJ concur with this conclusion, see , e.g. , Notic e on Petition for Waiver of the Terms of the Order Limiting Scheduled Operations at LaGuardia Airport: Grant of Petition with Conditions , FAA

- 2010

- 0109.6 $138. 19

In fact, when taxes are included , Republic's actual average fare in the DCA

- MCI market is significantly higher than presented by Southwest ’s Application and Answer. Specifically, for year ending March 31, 2010 Republic’s one

- way fare in the DCA

- MCI market was $197 , rather than $174 This reported fare exclude s all government imposed taxes ( i.e. , the 7.5% Excise Tax, Passenger Segment Fee, 9/11 Security Fee and PFCs )

. On the other hand the $161 Southwest fare that Republic trumpets includes those government taxes. So, Republic is comparing a Southw est fare in a different market that includ es taxes ($161)
to one that excludes taxes (the projected $132). Such a comparison is misleading and proves nothing.

20 and for 1 st Quarter 2010 it was $ 21 3

. 21 Of course the margin of difference between Southwest’s projected fare for the DCA

- MCI market and Republic’s actual fare remain the same since taxes are largely a constant. Moreover , if Republic insists on comparing its actual 1 st Quarter 2010 fares in the DCA

MCI market to Southwest’s actual fares in the BWI

- MCI market for the same period, Republic’s fares are m ore than 30% higher

. The table below summarizes Southwest and Republic fares with and without government taxes and carrier

- imposed ancillary fees ( i

. e
. , average per - passenger baggage/cancellation fees) :

19 Includes $0.3 7 average per - passenger bag/cancellation fees

. See Exhibit WN

- SR

- 2. 20 In clud es $13.34 average per - passenger bag/cancellation fees

. See Exhibit WN

- SR

- 2. 21 Includes $14.71 average per - passenger bag/cancellation fees

. See Exhibit WN

- SR

- 2.7 Southwest ( Projected ) Republic ( Actual ) % Republic Higher Than Southwest Southwest ( Actual ) % Republic Higher Than Southwest DCA
- MCI DCA
- MCI BWI - MCI
YE March 31, 2010 Base Fare only $132 $159 20% $133 20 % Base Fare plus Ancillary Fees $132 $174 31% $133 30% Base Fare plus Ancillary Fees & Taxes $155 $197 27% $154 28%

1 st Q 2010 Base Fare only $138 $174 26% $138 26% Base Fare plus Ancillary Fees $138 $189 37% $138 37% Base Fare plus Ancillary Fees & Taxes $161 $213 32% $161 32% As shown, Republic’s fares in e very category are much higher, by 20 % to 37% , than Southwest ’s when viewed on a true, apples

- to
- apples basis. This analysis simply reaffirms what Southwest has said from the beginning of this proceeding: that if given the opportunity to compete i n the DCA

- MCI market, it will offer fares that are significantly lower than Republic’s. This conclusion should not be surprising, for it is simply a corollary of the fact that Sou thwest is and always has been a low

- fare carrier , and does not have
to promis e to change its business model in order to justify low fares in a DOT selection proceeding

.

III. SPECULATION BY COMPETING APPLICANTS ON THE VIABILITY OF SOUTHWEST’S SERVICE PROPOSAL IS IRRELEVANT Republic and the other applicants argue that Southwest’s proposed service for DCA

- MCI should be rejected because it may not be “viable.” Of course it is hardly surprising that Southwest’s competitors would be critical of its proposed entry into DCA. Even beyond their immediate objective of seeking the two sl ot exemptions at issue8 here, it is in their interest to keep Southwest out of this protected, high

- fare market for as long as possible

. Such self

- serving arguments should be given zero credence. In fact, taken to their logical conclusion, these claims would effectively disqualify

n ew entrant carriers from ever receiving slot ex emptions at DCA since competitors could always argue that the new services might not be “viable.” Thus , if left up to Republic and US Airways, slot exemptions should always be al located to incumbent carriers to avoid that risk

. However , as the Department well knows, allocating slot exemptions to new entrant carriers is encouraged by DOT policy as well as AIR

- 21 and Vision

- 100. Indeed, 49 USC § 41718(b) specifically directs t he S ecretary to develop criteria for distributing slot exemptions in a manner that promotes air transportation , including “(1) by new entrant air carriers ....” Thus, while Southwest would certainly like to establish service with more than

one DCA flight per day, it recognizes that DCA is unique and it does not currently have an opportunity to acquire more than these two slot exemptions. A s stated in both its Application and Answer, Southwest will look to grow its presence at DCA through every reasonable mean s from this modest beginning. However, in the interim, Southwest has the financial resources and corporate fortitude to sustain a one flight per day schedule

. The Department should emphatically reject the self

- serving and anti

- competitive arguments of DCA incumbents to the contrary.9 C onclusion The complete record of this proceeding demonstrates conclusively that Southwest Airlines will provide far greater benefits to the public than Republic or any other competing applica nt for the slot exemptions at issue here. We therefore urge the Department to grant the slot exemptions to Southwest to enable it to initiate its first

- ever service to Ronald Reagan Washington National Airport and provide much needed low

fare competition on the DCA

- MCI route. Sincerely,

__________________ Robert W. Kneisley
October 26, 20101 

### Surre buttal S tatement of D r . B rian M. C ampbell
I have reviewed the Answers of Republic, US Airways, Sun Country and AirTran. For the most part they s imply contain argument with few empirical facts. However, it is necessary to correct the record in three s ignificant areas: (1) the notion propounded by Republic that it has somehow become a “low

- fare carrier” just in time for this proceeding, (2) Republic’s claim that its average fare in the DCA

- MCI market would be lower than Southwest’s , and (2) the a rgument of several carriers that Southwest should be denied the opportunity to operat e a single daily round trip at DCA because , in the opinion of these competitors, Southwest’s service would “ not be viable. ”

1.0 Republic Is Not A Low
- Fare Carrier in the DCA
- MCI Market I n both its Application and Answer, Republic urges the Department to believe that it is

now a “ low

- fare carrier. ” Yet, despite all of its statements , in none of its documents has Republic stated explicitly what its DCA

- MCI fares wi ll be if awarded this slot pair. Instead, Republic talks about “rebranding” its DCA

- MCI flights as a low

- fare Frontier service, which it has not been heretofore. Republic does not describe the features or fare structure of this “model , ” but it is noteworthy that Frontier’s low

- cost structure was a consequence of its Airbus fleet, not the higher unit cost RJ’s flown by Republic on the DCA

- MCI route

. 1

Southwest, o n the other hand, stated in its Application that it will price the DCA

- MCI market in accordance with its system

- wide fare structure, and that it expects its weighted average fare (excluding taxes and fees) to be approximately $132 (Exhibit WN

- 3). Republic goes so far as to suggest that its average fare in the long haul, leisure

- oriented DCA

- DEN market, operated by Frontier with 150 seat A320 aircraft substantiates its “low

- fare” claims for the DCA

- MCI RJ Republic discloses nothing about its s o - called Frontier rebranding initiative, nor does it disclose what its DCA

- MCI fare will be for non - government travel. Its reference to a fare “starting at $99” says nothing about the fares that will actually be charged to the public

.

1 Republic’s current average seats per departure is 76. By contrast, Southwest would operate the B73 7

- 70 0

- NG with 137 seats, or 61 seats per flight more than Republic, and 44,530 seats per year more than Republic (Exhibit WN

- SR

1)

. Republic did state that its average DCA

- MCI fare, excluding checked bag gage and reservation cancellations/rebooking fees, was $159, presumably for the 12 months ended March, 2010. This is consistent with Southwest’s derivation of $174 for Republic including those fees.2 service with some sort of halo credibility. This is fallacious. Republic proposes to operate a plane with 34% fewer seats than the A320 over a stage length that is 526 miles shorter. Throughout its presentation Republic touts its $ 9 5 contract fare limited to federal government employee travel

. I expect this fare is below Rep ublic’s fully allocated costs , so in order for the service to be financially viable , Republic must cross

- subsidize its government fares by charging well above average cost to the public passenger

– precisely the passengers that DOT must be concerned with i n this proceeding

. As shown in Exhibit WN

- 3 , both the Republic an d US Airways average fares in the DCA

- MCI market are quite high . Including baggage and cancellation fees, the Republic average fare for the 12 months ended March, 2010 was $174. 2 US Airways ’ fare was slightly higher so the weighted average of the two carriers was $177. The $174 Republic fare includes average per - passenger baggage/cancellation fees of $14.71 3 . Th is is fully consistent with Republic’s own statement that its avera ge fare for this period was $159, 4 which exclude s the baggage and reservations cancellation/rebooking fees.

2.0 Republic Has Made An Invalid Comparison of Southwest’s Fares And Ignored Its Own High Fare
P age 20 of Republic’s R eply s t ates that a DOT consumer report 5

To make an apples

- to

- apples comparison to Republic’s time period, Campbell

- Hill has derived the expected fare for S outhwest in the DCA

- MCI market using only the Q1 2010 data , shows Southwest’s average fare in the BWI

- MCI market was $161 for Q1, 2010. Republic alleges this is inconsistent with Southwest’s expected average fare in the DCA

- M C I market of $132 (Exhibit WN

- 3). As stated plainly in the source note to Exhibit WN

- 3 , Southwest’s fare analysis and yield curve were developed using the DOT Origin

- Destination Passenger Survey, as presented in electronic format by Data Base Products. Thi s is a standard industry source of DOT databases and is used by DOT and other government agencies in addition to airline parties. These data exclude all government taxes and fees (including federal excise tax, segment fees, September 11 security fees, and PFC’s ) , a fact well known to all users.

2 From DOT O&D and Form 41 reports. 3 Exhibit WN

- SR

- 2

. 4 Answer of Republic Airlines Inc. at page 20. 5 Republic cites DOT, Domestic Airline Fares Consumer Report for First Quarter 2010 , Table 1, page 12 of 23, dated July 2010.3 and t he result is a fare of $138. So , comparing identical time periods Southwest’s estimated D CA

- MCI fare of $138 is $23 lower than the DOT reported BWI

- MCI average Southwest fare of $161 for Q1 2010 . The data source for the DOT fare analysis is DBIB which include s excise taxes, segment taxes, 9/11 charges, and PFC’s, 6

In terestingly, Republic did not compare the DOT’s reported “fully loaded” Southwest BWI

– MCI fare to Republic’s average DCA

- MCI fare in the same report. For Q 1 , 2010 Republic charged an average of $198 per DCA

- MCI passenger, or 23.0% more than Southwest’s $161 BWI

- MCI fully loaded fare

. Adding Republic’s average $15 in average per passenger checked baggage and cancellation fees brings its total cost to passenger s of $213, while Southwest’s charge remains at $161. This is a difference of 32%, or $52 per passenger in favor of Southwest. This demonstrates again that Republic is a high

- fare carrier in the DCA

MCI route, while Southwest would provide low

- fare competition , if given the opportunity

. and it also includes all O&D traffic ( both nonstop and connecting passengers. Those passengers in the data who connected between BWI and MCI, e.g. via MDW, paid double for excise taxes, PFC’s segment fees, etc. I t is clea r that the $2 3 difference is due to the taxes and fees included in the DOT reported fares but not in the data used by Southwest in its “pure” fare analysis. Republic’s fare comparison is simply wrong and proves nothing . It compares apples to oranges.

Finally, at page 20 of its Reply, Republic alleges that its DCA

- MCI fare is only $159. This could only be true by excluding ticket taxes and PFC’s. However, the DOT consumer report that Republic used to try to paint inconsist ency in Southwest fare comparisons shows Republic’s fare in the DCA

- MCI market is $198 including ticket taxes and PFC’s. Thus, for its own benefit it used the DOT report to inflate the appearance of Southwest’s fare, but it used the a different data source , the O&D survey data excluding taxes and PFC’ s, to minimize the appearance of its own fare.

3.0 The Fact That Southwest Would Begin Its DCA Service With One Slot Pair Is Irrelevant to the Department’s Selection Criteria
The final issue I wish to address has been raised by all the competing applicants. This is the question of whether Southwest’s single round trip will be “ viable. ” Southwest has opened stations with a single route, as exemplified by its recent successful entry at M SP. Southwest will

6 A fact well known by the DOT.4 require additional slots to mount a significant level of competitive low

- fare service across the spectrum of DCA markets. It is my understanding that Southwest will make every reasonable effort to acquire additional DCA slots and expan d the scale and scope of its services, quite apart from its proposed acquisition of AirTran. The Department should not concern itself with Southwest’s long

- run “viability” at DCA. Southwest Airlines will do fine, and so will the Washington, DC consumer. However, I wish to address this issue of viability by returning specifically to the Answer of Republic and Exhibit R

- 1 appended thereto. Southwest has a long history of low

- fare service development at Kansas City and it will serve the DCA market with mo re seats and lower fares than Republic. Gone are the days of the 1990’s when Kansas City had spotty nonstop and frequently multi

- stop service to the west coast. Southwest now provides service between MCI and Las Vegas (4), Los Angeles (2), Oakland (1), Portland (1), Phoenix (3), San Diego (2), and Seattle (1). This makes a total of 14 daily round trips to seven west coast markets. 7 At page 1 of Republic’s Exhibit R

- 1 the Airport Director states. . .”I must voice my concern to the long term viability of a carrier offering less than three daily flights on this route.” S ix of Republic’s ten MCI routes have service of only one frequency per day, and five of the six are clearly business markets (Exhibit WN

- SR

- 4)

. I assume these markets are “viable” for R epublic

. Southwest serves 19 nonstop routes at MCI and it operates less than three daily frequencies in 10 of them (Exhibit WN

- SR

- 3)

. I firmly believe that these 10 routes are viable for Southwest Airlines

. It is simply irrational and without evidentiar y support to assume that one daily roundtrip by Southwest in the DCA

- MCI market would not be “viable.”

7 Exhibit WN

- SR

- 3.

## Southwest’s Service Proposal Would Provide DCA
– MCI Passengers At Least 28,000 More Annual Seats Than Republic’s Proposal Exhibit WN

- SR

- 1

Aircraft type Seats per departure Annual one - way seats \ 1

Greater no. of seats proposed by Southwest B737 - 700NG 137 100,010

-- EMB - 190 99 72,270

27,740 EMB - 170 76 55,480

45,530 Southwest Current Schedule Proposed Republic Service Proposals

1/ Seats per departure x 2 slots x 365 days.

## Fee - Related Revenues for Selected Carriers’ Domestic Operations (YE March 31, 2010 and First Quarter 2010) Exhibit WN

- SR

- 2

Source: DOT, Form 41 Financial Data, Schedule P12 and Origin

- Destination Passenger Survey, via Data Base Products Southwest US Air Frontier Midwest Total A. YE March 31, 2010 Fee - Related Revenue (million $) Passenger Baggage $27.9 $350.3 $52.9 $22.7 $75.7 Cancellation $0.0 $186.7 $18.2 $7.8 $26.0 $27.9 $537.0 $71.2 $30.5 $101.7 Q1 2010 O&D Statistics Fared Passengers (million) 80.3 40.1 7.3 2.3 9.6 Average Fees per Fared Passenger Passenger Baggage $0.35 $8.74 $7.20 $9.93 $7.85 Cancellation $0.00 $4.66 $2.48 $3.41 $2.70 $0.35 $13.40 $9.69 $13.34 $10.55
B. First Quarter 2010 Fee - Related Revenue (million $) Passenger Baggage $6.9 $93.4 $12.2 $6.4 $18.6 Cancellation $0.0 $48.5 $3.2 $1.7 $5.0 $6.9 $141.9 $15.5 $8.1 $23.6 Q1 2010 O&D Statistics Fared Passengers (million) 18.6 9.0 1.5 0.6 2.1 Average Fees per Fared Passenger Passenger Baggage $0.37 $10.38 $7.88 $11.60 $8.86 Cancellation $0.00 $5.39 $2.10 $3.11 $2.36 $0.37 $15.76 $9.98 $14.71 $11.23

## Southwest Successfully Operates Less Than Three Daily Round Trips in 10 of its 19 MCI Nonstop Markets

Destination October 18, 2010 Departures October 18, 2010 Seat Departures ABQ 2 274 BNA 4 548 BWI 3 411 DAL 9 1,218 DEN 5 685 IND 2 274 LAS 4 548 LAX 2 274 MCO 2 244 MDW 10 1,340 MKE 3 411 OAK 1 137 OKC 2 274 PDX 1 137 PHX 3 411 SAN 2 259 SEA 1 137 STL 5 670 TPA 1 137

Total 62 8,389

Source: OAG, Schedules for October 18, 2010. Exhibit WN

- SR

- 3

## Republic Operates Only One Flight Per Day in 6 of its 10 MCI Nonstop Markets Exhibit WN

- SR

- 4

Destination October 18, 2010 Departures October 18, 2010 Seat Departures BOS 1 76 CMH 1 98 DCA 3 228
DEN 5 540
LAX 1 98
LGA 3 250
MKE 4 326 MSY 1 76 SEA 1 98 SFO 1 98

Total 21 1,888

Source: OAG, Schedules for October 18, 2010.