BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Application of 

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 between Oklahoma City (OKC) and ) 

Ronald Reagan Washington National Airport (DCA) ) 

Docket DOT -OST -2000-7182 

ANSWER OF OKLAHOMA CITY DEPARTMENT OF AIRPORTS 

IN SUPPORT OF THE APPLICATION OF SOUTHWEST AIRLINES 

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 

March 20, 2012 
1

BEFORE THE 

U.S. DEPARTMENT OF TRANSPORTATION

WASHINGTON, D.C.

____________________________________________

Application of )

SOUTHWEST AIRLINES CO. )

For exemptions from 14 C.F.R. Part 93, )

Subparts K and S, pursuant to 49 U.S.C. ) Docket DOT-OST-2000-7182

§41718(b) )

 )

For service between Oklahoma City (OKC) and )

Ronald Reagan Washington National Airport (DCA) )

____________________________________________

INTRODUCTION

On March 5, 2012, Southwest Airlines Co. (Southwest) 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. These slot exemptions authorize service to a small or medium hub airport 

within the 1,250-mile perimeter established for civil operation at DCA, under Title 49 U.S.C.§ 

49109. Details of Southwest’s service proposal are as follows:

ROUTE: DCA-OKC, with continuing single-plane service to Dallas Love Field (DAL)

SCHEDULE: Eastbound: 09:00 DAL – 09:50 OKC

10:15 OKC – 14:05 DCA

Westbound: 14:50 DCA – 16:50 OKC 

17:35 OKC – 18:30 DAL 

START: Within 90 days of the Department’s Final Order

AIRCRAFT: Stage III Boeing 737-700 aircraft (137 seats)
APPLICATION MEETS STATUTORY CRITERIA 

As per its filing, Southwest's proposed service would significantly advance the statutory goals of 

AIR-21 and Vision 100 by fulfilling four of the five statutory criteria, the maximum number 

possible. Specifically, Southwest's proposal would: 

• Provide service by a limited incumbent air carrier at Washington National Airport: 

Southwest is a limited incumbent at DCA following its acquisition of AirTran Airways; 

• Offer DCA non-stop service to a community without such service: OKC has no non-stop 

service to DCA; 

• Provide DCA service to a small community: OKC is classified as a "small hub" by the 

FAA; and 

• Produce the maximum competitive benefits, including low fares: Southwest's proposed 

DCA-OKC-DAL service will generate over $8 million in consumer fare savings 

annually, and will stimulate approximately 55,000 new passengers. 

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 441

h largest MSA in the United States. Population in the region 

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

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

counties, which include many small 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 

2 
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 

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

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

over $5 billion in private-sector investments. Oklahoma City and MAPS has 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 is 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: 

• Listed among the top 20 strongest metropolitan areas (out of the top 100) for ten 

consecutive quarters 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 each of the last twelve months - and finished in the top three lowest for each 

month over the last three years; 

• Generated an unemployment rate more than three percentage points lower than the 

national average in December, 2011 (5.7% vs. 8.9%); and 

• Ranked first in real GDP growth (14.5%) among large metropolitan areas in 2008-09, 

the most recent year available from the Bureau of Economic Analysis. 

3 
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; 

• 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 located here; 

• 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 recently announced plans to relocate 1,500 high-level jobs 

to Oklahoma City, which will double their existing employee base; and 

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

companies. 

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

headlines and honors, including: 

4 
• "Oklahoma City ranked in the top ten in manufacturing growth"- U.S. Bureau of 

Labor Statistics, February 2012; 

• "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 Southwest's application to serve the DCA-OKC market. These can 

be found in Exhibit A. 

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

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, and generated nearly 1.8 million enplanements in 

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

primary facility for a large portion of the state of Oklahoma. OKC is typically a high load factor 

airport, with nearly 80% of segments operating with load factors of 75% or higher for the year 

ended October 2011 (YE Oct11). As of March 2012, airlines serving OKC operate 68 daily 

departures to a total of 20 non-stop destinations (including Baltimore/Washington [BWI] and 

Washington/Dulles [lAD]). The largest carrier at OKC is Southwest, with approximately 20 

daily departures to eight non-stop destinations (see Exhibit B). 

5 
OKC sits on 8,100 acres with three active runways, and is home to sixty 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 

the passenger and security experience at OKC. The first project is a new $40 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 (OKC)- WASHINGTON (DCA) MARKET 

Oklahoma City currently generates more traffic to DCA than any other market located inside of 

the 1,250-mile DCA perimeter lacking non-stop service there (see Exhibit C). Despite this lack 

of non-stop service, and also despite daily non-stop flights from OKC to both BWI and lAD, the 

OKC-DCA market generated 33,664 fared passengers during the year ended September 30, 2011 

(YE 3011). Given that all of these passengers traveled on connecting itineraries, choosing to 

bypass non-stop service to BWI and lAD, it is obvious that DCA is a key destination for the 

Oklahoma City community. 

In addition, note that the figures above reflect only passengers traveling to/from OKC. As this 

will be the only current non-stop service to DCA from the state of Oklahoma, it will likely 

stimulate and carry traffic from a broader 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). 

6 
Many of Oklahoma City's peer regions (as defined by MSA population) located inside of the 

DCA perimeter currently support service to BWI, lAD and DCA- including Raleigh/Durham 

(RDU), New Orleans (MSY), Nashville (BNA), and Indianapolis (IND) (see Exhibit D). Given 

the OKC-DCA passenger numbers in the absence of non-stop service and the surrounding small 

community traffic stimulation potential (both cited above), we believe that Oklahoma City can 

easily join this distinguished group of cities. 

SOUTHWEST IS THE PERFECT CARRIER TO MAXIMIZE THE POTENTIAL OF 

THIS SERVICE 

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

Southwest is the optimal carrier to maximize the associated economic and community benefits. 

Key reasons include: 

Large existing local traffic base 

Southwest carried the largest number of O&D passengers from OKC in the most recent twelve 

month period for which data is available (YE 3011), with an O&D market share of over 38% 

(see Exhibit E). This extensive local traffic base should allow Southwest to ramp up new DCA 

service quickly, as local passengers are familiar with the airline and are comfortable flying with 

them. 

Low fare carrier in a high fare O&D market 

Current fares in the DCA-OKC marketplace are very high, making existing traffic counts in the 

market all that more impressive. For the YE 3011, the average DCA-OKC O&D fare was $271, 

the highest among the top ten inside-the-perimeter markets from DCA without non-stop service 

(see Exhibit C). Based on Southwest's existing passenger yield profile, the airline estimates that 

7 
the introduction of their service in the market will drop the O&D fare to $163, a reduction of 

40%. This substantial projected drop in the local fare level will stimulate an additional subset of 

passengers, on top of those already stimulated by the introduction of non-stop service. 

Mainline aircraft 

Southwest will operate its proposed OKC-DCA nonstop service with 137 -seat B737 -700 aircraft, 

providing for sufficient capacity to maximize the traffic stimulation and economic benefit to the 

regwn. 

Analysis of projected benefits 

Southwest included in their application the projected economic benefits to the Oklahoma City 

region from this proposed new non-stop service. Their findings included: 

• 46,220 annual incremental passengers will be generated in the local DCA-OKC O&D 

market (first run-rate year, includes all carriers), and an additional 8,614 beyond 

passengers will also be generated; 

• $6.1 million in fare savings will accrue to passengers in the local DCA-OKC O&D 

market (including existing and new passengers), while an additional $2.1 million in 

savings will accrue to beyond passengers; and 

• The average DCA-OKC O&D fare will drop from $271 to $163, a decline of 40%. 

CONCLUSION 

Southwest Airlines' proposed non-stop DCA-OKC service fulfills four of the five possible 

statutory criteria for DCA slot exemptions set out in AIR-21 and Vision 100, but we think that 

8 
the story is much more powerful than that. Key factors in support of this application -which are 

not present in the competing applications - include: 

• The service will be operated by the largest carrier in the local marketplace (Southwest at 

OKC); 

• Other than Richmond, VA, situated only 94 miles (and less than two hours driving time) 

from DCA, Oklahoma City is the largest MSA within the DCA perimeter currently 

without non-stop DCA service; and 

• The service will be operated by the nation's largest low fare carrier, further enhancing 

benefits to the traveling public. 

In addition, the potential for significant traffic stimulation in this market is evident, given the 

heavy existing traffic counts despite very high current fares. Southwest's use of 137-seat 

mainline aircraft will help maximize this impact. On behalf of the Oklahoma City community, 

we urge the Department to grant Southwest's request to provide non-stop service in the DCAOKC market. 

Respectfully Submitted, 

urg 

Director of Airports 

Oklahoma City Department of Airports 

March 20, 2012 

Attachments 

9 
EXHIBIT A 

The following parties submitted letters of support for this application: 

1. Governor Mary Fallin, Governor of the State of Oklahoma 

2. Dave Lopez, Oklahoma Secretary of Commerce & Tourism 

3. Mick Cornett, Mayor of the City of Oklahoma City 

4. Peter Delaney, Chairman, President & CEO, OGE 

5. President David Boren, University of Oklahoma & former US Senator 

6. Larry Nichols, Executive Chairman, Devon Energy Corporation 

7. Kirk Humphreys, Chairman, The Humphreys Company; Vice Chairman, Oklahoma City 

Airport Trust; Former Mayor of Oklahoma City (1998-2003) 

8. Oklahoma US Congressional Delegation: Senator James Inhofe, Senator Tom Coburn, 

Congressman Dan Boren, Congressman Frank Lucas, Congressman James Lankford, 

Congressman Tom Cole, Congressman John Sullivan 

9. LeAnn Jenkins, Executive Director, Oklahoma Federal Executive Board 

10. David Rainbolt, Chief Executive Officer, BancFirst Corporation 

11. C. Bruce Lawrence, President & CEO, Integris Health 

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

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

Oklahoma 

14. Rhonda Hooper, President & CEO, Jordan Advertising 

15. Roy H. Williams, President, Greater Oklahoma City Chamber of Commerce 

16. Fred S. Morgan, President & CEO, The State Chamber of Oklahoma 

17. Victor Bird, Director, Oklahoma Aeronautics Commission 

18. Mark Kranenburg, Director of Airports, City of Oklahoma City Department of Airports 

19. Ed Sanchez, Chairman/CEO, Lopez Foods, Inc. 

20. Charles Lamb, Mayor, City of Edmond 

21. Cindy Rosenthal, Mayor, City of Norman 

22. Roscoe Hill, Mayor, City of Woodward 

23. Dan Galloway, City Manager, City of Stillwater 

10 
EXHIBITB 

Departures by Airline at Will Rogers World Airport (OKC)- March 2012 

Marketin2 Carrier Dailv Deuartures Destinations 

Baltimore/Washington, Dallas Love, 

Denver, Houston Hobby, Las Vegas, 

Southwest Airlines 19.8 Kansas Ci!Y, Phoenix, St. Louis 

Denver, Newark, Washington Dulles, 

Houston Intercontinental, Los Angeles, 

United Airlines* 19.1 Chica_g_o O'Hare, San Francisco 

Atlanta, Detroit, Memphis, 

Delta Airlines 15.2 Minneapolis/St. Paul, Salt Lake City 

Dallas/Fort Worth, Los Angeles, 

American Airlines 12.9 Chic'!£_o O'Hare 

Frontier Airlines 1.4 Denver 

TOTAL 68.4 

Source: OAG schedules, March 2012 

* includes service by Continental Airlines 

11 
12

EXHIBIT C

Top 10 markets inside the DCA perimeter without non-stop service to DCA – YE 3Q11

Annual Fared Passengers and O&D Fare

Market DCA Fared Passengers Average O&D Fare

Oklahoma City (OKC) 33,664 $271

Tulsa (TUL) 30,257 $212

Wichita (ICT) 25,665 $187

Moline (MLI) 20,695 $187

Key West (EYW) 18,716 $200

Cedar Rapids (CID) 18,340 $257

Gulfport (GPT) 18,161 $208

Baton Rouge (BTR) 18,060 $222

Northwest Arkansas (XNA) 18,028 $234

Montgomery (MGM) 16,458 $245

Source: Southwest Airlines filing/US DOT O&D Survey, YE 3Q11/US DOT Form 41

Note: O&D fare data includes fared passengers only, excludes all taxes and government 

charges, and includes estimated checked baggage and rebooking fees (per Southwest filing)
EXHIBITD 

Oklahoma City "Peer MSAs"- service to Washington area airports 

Only markets inside the DCA perimeter are listed 

MSA MSA* MSA Primary 

rank nonulation airnort 

[000~ 

22 Pittsburgh, P A 2,357.9 PIT 

25 Orlando-Kissimmee-Sanford, FL 2,188.6 MCO 

27 Cincinnati-Middletown, OH-KY-IN 2,147.6 CVG 

28 Cleveland-Elyria-Mentor, OH 2,077.9 CLE 

29 Kansas City, MO-KS 2,063.0 MCI 

31 Columbus, OH 1,864.6 CMH 

33 Charlotte-Gastonia-Rock Hill, SC 1,804.6 CLT 

34 Indianapolis-Carmel, IN 1,780.0 IND 

36 Virginia Beach-Norfolk-Newport News, 1,691.6 ORF 

VA-NC 

37 Nashville-Davidson-Murfreesboro- 1,633.1 BNA 

Franklin, TN 

38 Providence-New Bedford-Fall River, RI- 1,608.2 PVD 

MA 

39 Milwaukee-Waukesha-West Allis, WI 1,563.7 MKE 

40 Jacksonville, FL 1,370.6 JAX 

41 Memphis, TN 1,329.9 MEM 

42 Louisville-Jefferson County, KY -IN 1,292.8 SDF 

43 Richmond, VA* 1,283.5 RIC 

lAD 

non-ston 

service 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

Yes 

No 

Yes 

Yes 

44 Oklahoma City, OK l,Z74•I::ii~'/> ;:?;\ :oKG'L,,'• ··;f;;~ 3.tves· ,> 

45 Hartford-West Hartford-East Hartford, CT 1,219.8 BDL Yes 

46 New Orleans-Metairie-Kenner, LA 1,179.3 MSY Yes 

47 Raleigh-Cary, NC 1,171.1 RDU Yes 

48 Birmingham-Hoover, AL 1,141.2 BHM No 

50 Buffalo-Niagara Falls, NY 1,135.4 BUF Yes 

51 Rochester, NY 1,055.6 ROC Yes 

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

Source: U.S. Census and OAG Schedules data 

13 

DCA BWI 

non-ston non-ston 

service service 

Yes Yes 

Yes Yes 

Yes Yes 

Yes Yes 

Yes Yes 

Yes Yes 

Yes Yes 

Yes Yes 

Yes Yes 

Yes Yes 

Yes Yes 

Yes Yes 

Yes Yes 

Yes No 

Yes Yes 

No No 

No, Yes 

Yes Yes 

Yes Yes 

Yes Yes 

Yes Yes 

Yes Yes 

Yes Yes 
EXHIBIT E 

O&D passengers by airline at Will Rogers World Airport (OKC)- YE 3Qll 

Carrier Annual uassen2ers (000s) Passen2er share 

Southwest _{_WN} 1,180.4 38% 

American (AA) 610.4 20% 

Delta (DL) 528.2 17% 

United (UA) 367.7 12% 

Continental (CO) 215.4 7% 

Frontier (F9) 144.7 5% 

Source: US DOT O&D Survey, YE 3Qll 

14 
CERTIFICATE OF SERVICE 

I hereby certify that on March 20, 2012, a copy of the foregoing was served via e-mail on the 

following persons: 

leslie.abbott@wnco.com (Southwest Airlines) 

bob.kneisley@wnco.com (Southwest Airlines) 

robert.cohn@hoganlovells.com (Frontier Airlines) 

patrick.rizzi@hoganlovells.com (Frontier Airlines) 

howard kass@usairways.com (US Airways) 

ben jamin.slocum@usairways.com (US Airways) 

amoore@bakerdonelson.com (JAN Airport) 

dvanderleest@jmaa.com (JAN Airport) 

tom.tyra@flylouisville .com (SDF Airport) 

phil.sunderland@mwaa.com (DCA Airport) 

susan.kurland@dot .gov 

todd.homan@dot.gov 

15