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, 2010
1

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. 

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. Good cause exists for granting this request, as the 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 DCAMCI MARKET

 In unusually strident language even for a slot exemption proceeding, Republic’s 

Answer hurls several inflammatory charges at Southwest, while at the same time 

repeatedly threatening to sue the Department if it “confiscates”3 the slot exemptions and 

thereby interferes with “Republic’s rightful entitlement under the law.”

4

 Incredibly, 

Republic’s counsel even goes so far as to call Southwest (which holds no DCA slots) 

“gluttonous”5 for electing to compete against Republic (the holder of 141 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 repeatedly asserts that it is a “low-fare carrier” and 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 several mis-statements in describing its 

own DCA - MCI service as well as Southwest’s proposal for competing service in the 

same market. 

7

 3 Republic Answer at 21.

 However, the most recent DOT data available 

(year ending 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

Instead, 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 same slot exemptions in the same market.

yet does not refute the 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 on behalf of Southwest Airlines.

 This is incorrect. 

Exhibit WN-3 shows Republic’s average fare and US Airways’ average fare in the DCAMCI market 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 in 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 believes that additional seat capacity 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 DOT 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 market. 

15

Finally, Republic’s privately negotiated contract fare for federal government 

employee travel is not relevant to the question of whether or not Republic provides 

consumers with low fares in the DCA-MCI market. To state the obvious, this fare is not 

available to the general public and has no bearing on the fares that would be available 

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 average of $13.34 per passenger for YE March 31, 2010 and $14.71 for 1st 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 appropriate 

to 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 data, 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 reduce 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 Application 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 employed 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 1st 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 1st 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., Notice 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 excludes 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 Southwest fare in a different market that includes taxes ($161) 

to one that excludes taxes (the projected $132). Such a comparison is misleading and 

proves nothing.

20 and for 1st Quarter 2010 it was $213.21 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 1st Quarter 2010 fares in the DCAMCI market to Southwest’s actual fares in the BWI-MCI market for the same period, 

Republic’s fares are more 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 $0.37 average per-passenger bag/cancellation fees. See Exhibit WN-SR-2. 

20 Includes $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%

1st 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 every 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 in 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 Southwest is and always has been a low-fare carrier, and does not have 

to promise 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 slot exemptions at issue 
8

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 

new entrant carriers from ever receiving slot exemptions 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 allocated 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 the Secretary 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. As stated in both its 

Application and Answer, Southwest will look to grow its presence at DCA through every 

reasonable means 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

Conclusion

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 applicant 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 lowfare competition on the DCA-MCI route. 

Sincerely,

__________________

Robert W. Kneisley

October 26, 2010
1

Surrebuttal Statement of Dr. Brian M. Campbell

I have reviewed the Answers of Republic, US Airways, Sun Country and AirTran. For 

the most part they simply contain argument with few empirical facts. However, it is necessary to 

correct the record in three significant 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 argument 

of several carriers that Southwest should be denied the opportunity to operate 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

In 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 will 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, on 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 so-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 B737-700-NG with 

137 seats, or 61 seats per flight more than Republic, and 44,530 seats per year more than Republic (Exhibit WN-SR1). Republic did state that its average DCA-MCI fare, excluding checked baggage 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 $95 contract fare limited to federal 

government employee travel. I expect this fare is below Republic’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 in this proceeding. 

As shown in Exhibit WN-3, both the Republic and 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 $14.713

. This is fully consistent with Republic’s own 

statement that its average fare for this period was $159,4 which excludes 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

Page 20 of Republic’s Reply states that a DOT consumer report5

To make an apples-to-apples comparison to Republic’s time period, Campbell-Hill has 

derived the expected fare for Southwest 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-MCI 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. This 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 the result is a fare of $138. So, comparing identical time periods Southwest’s estimated 

DCA-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 includes excise 

taxes, segment taxes, 9/11 charges, and PFC’s,6

Interestingly, 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 Q1, 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 perpassenger checked baggage and cancellation fees brings its total cost to passengers 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 DCAMCI 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. It is clear that 

the $23 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 inconsistency 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 MSP. 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 expand 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 more 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.” 

Six 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 

Republic. 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 evidentiary 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.