BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C.

_____________________________________

)

Applications of )

)

FRONTIER AIRLINES, INC. )

SOUTHWEST AIRLINES CO. )

US AIRWAYS, INC. ) Docket DOT-OST-2000-7182

)

INSIDE PERIMETER SLOT EXEMPTIONS )

under 49 U.S.C. § 41718(b) )

_____________________________________ )

CONSOLIDATED REPLY OF SOUTHWEST AIRLINES CO.

AND MOTION FOR LEAVE TO FILE

Communication with respect to this 

 document should be addressed to:

Ron Ricks Robert W. Kneisley

 Executive Vice President -- Associate General Counsel

 Chief Legal and Regulatory Officer Leslie C. Abbott

Madeleine Johnson Senior Attorney

 Vice President General Counsel SOUTHWEST AIRLINES CO.

SOUTHWEST AIRLINES CO. 1901 L Street, NW

2702 Love Field Drive Suite 640

Dallas, TX 75235-1611 Washington, DC 20036

 bob.kneisley@wnco.com

 (202) 263-6284

March 29, 2012
1

BEFORE THE

DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY

WASHINGTON, D.C.

_____________________________________

)

Applications of )

)

FRONTIER AIRLINES, INC. )

SOUTHWEST AIRLINES CO. )

US AIRWAYS, INC. ) Docket DOT-OST-2000-7182

)

INSIDE PERIMETER SLOT EXEMPTIONS )

under 49 U.S.C. § 41718(b) )

)

_____________________________________ )

CONSOLIDATED REPLY OF SOUTHWEST AIRLINES CO.

AND MOTION FOR LEAVE TO FILE

Southwest Airlines 1files this Consolidated Reply in order to address certain 

inaccurate, misleading, and in some cases completely false statements contained in 

pleadings recently filed by US Airways and Frontier in this proceeding.2 Southwest 

seeks leave to file this document pursuant to Rule 6 of the Department’s Rules of 

Practice (14 CFR §302.6). Good cause exists because this Reply will correct the record 

in several important respects and thereby contribute to a more accurate and informed 

basis for the Department to render its decision. Further, this Reply is narrowly tailored 

to address only certain misleading and incorrect statements that are related to material 

issues in this proceeding. 

 

1 Common names of airlines are used herein.

2

Specifically, this document is being filed in response to certain statements in US Airways’ Consolidated 

Answer and Frontier’s Answer, both filed March 20, 2012; US Airways’ Additional Comments filed March 

22; and Frontier’s Reply filed March 23.
2

REPLY TO US AIRWAYS:

1. US Airways’ Criticisms of Southwest’s Traffic Forecast

Are Misleading and Erroneous

US Airways’ Consolidated Answer (at p. 13) claims that “Southwest overstates its 

effect on both stimulation and fares, resulting in unsustainable service.” These 

criticisms, and the data US Airways uses to support them, are misleading and in some 

respects patently false. Southwest’s industry-changing history of dramatically 

expanding new markets by the introduction of low fares is well-known to the 

Department. Yet, in claiming that Southwest will not be able to achieve its forecast 

traffic stimulation in this case, US Airways relies on a tiny sample of data -- just four 

markets in “Figure 7(a)” -- that is both inaccurate and misleading. In fact, none of the

four markets in Figure 7(a) proves US Airways’ claims. 

The first two markets in Figure 7(a) (BDL-DEN and CHI-ONT) are fundamentally 

different from DCA-OKC because they both were served with low fares by Southwest on 

a connecting and through service basis prior to Southwest’s introduction of nonstop 

service. In CHI-ONT, Southwest’s share of the local O&D traffic was 43% prior to its 

nonstop, and in BDL-DEN Southwest’s share was 20% of the traffic before its nonstops

(Exhibit WN-SR-101). Consequently, these markets had already been stimulated by 

low fares prior to Southwest’s nonstop service. The average market fare after 

Southwest’s nonstops in both markets was essentially the same as the prior average 

fare so further price stimulation understandably did not occur (Exhibit WN-SR102, p. 1). 

Nevertheless, both markets did grow significantly after the introduction of Southwest’s 

nonstop service – i.e., 50% in the case of BDL-DEN and 57% in CHI-ONT. This growth 
3

all was due to “service stimulation” since average fares did not change (Exhibit WN-SR102, p. 2).3

 

The other two markets in Figure 7(a) are even less relevant, since US Airways 

used grossly incorrect time periods for measuring traffic stimulation as a result of 

Southwest’s entry. In the case of LIT-PHX, Southwest began nonstop service in March 

1994, but US Airways measured traffic stimulation in the 12 months ending Q1 2011 – a 

17 year omission. Similarly, Southwest entered BHM-PHX in December 1999, but US 

Airways calculated stimulation during the 12 months ending Q3 2010 – 14 years later.

A more representative sample of markets for purposes of Southwest’s DCA-OKC 

proposal would be markets with high fares prior to Southwest’s nonstop entry, for that is 

precisely the situation with DCA-OKC. The current average DCA-OKC fare (for 

connecting or through-plane service) is $271, while Southwest’s projected average fare 

for nonstop service is $163 (Exhibit WN-119), a 40% reduction. Attached Exhibit WNSR-103 contains an analysis of eight markets that Southwest entered since January 

2009 with fare reductions of 40% or more. As the exhibit shows, dramatic traffic 

stimulation occurred in all eight markets as a result of Southwest’s low fares, ranging 

from 56% to over 4,000%, with an eight-market average of 214%. 

The empirical data in Exhibit WN-SR-103 suggests that Southwest’s forecast 

traffic stimulation of 137% for DCA-OKC is entirely reasonable. US Airways’ Figure 7(a) 

and the corresponding text attacking Southwest’s price stimulation in new nonstop 

markets are entirely unfounded and should be disregarded.

 

3

By contrast, Southwest’s forecast service stimulation for its DCA-OKC proposal is a conservative 28%. 

Exhibit WN-202, Line 3.
4

2. US Airways’ Under-Utilization of DCA Slots

Cannot be Explained by “Commuter Slots”

US Airways’ March 22 Additional Comments assert (at p. 2) that Southwest’s 

allegation that US Airways uses slots inefficiently at DCA “distorts the facts” because 

Southwest fails to distinguish between unrestricted “air carrier slots” and “commuter 

slots” that are restricted to aircraft with 76 seats. This claim is baseless. As Exhibit 

WN-SR-104 shows, 71% of US Airways’ 460 slots at DCA are unrestricted “air carrier 

slots.” Yet US Airways operates only 27% of its DCA flights with mainline jet aircraft

(Exhibit-R-112). This fact alone demonstrates that US Airways grossly under-utilizes its 

DCA slots. 

Beyond this, Southwest has calculated that the aircraft size used on US Airways’

“air carrier slots” averages only 88 seats (Exhibit WN-SR-104). This confirms the

inefficient use of US Airways’ DCA slots, and cannot be explained by irrelevant 

references to the “commuter slot” restriction. The undeniable fact is that US Airways 

routinely schedules small commuter and RJ aircraft for slots where no size restriction 

applies. To cite the most recent egregious example, US Airways obtained 84 

unrestricted DCA slots from Delta in the slot swap approved by the Department in 

October 2011. US Airways has added 13 new DCA routes with 48 of those slots --

every one of which is with RJ aircraft, averaging just 53 seats (Exhibit WN-R-114). 

US Airways touts itself as “the number one small community provider at DCA.”4 

This is a highly misleading statement. US Airways is not expanding its small community 

service for the public good as it implies, but rather because that type of high-fare, lowcompetition service is an integral part of US Airways’ business model for Washington 

 

4 Consolidated Answer of US Airways, Inc., at page 4. 
5

DC. US Airways’ transparent strategy at DCA has been to avoid competition and 

charge high fares to the greatest extent possible; and if it can connect captive 

passengers at DCA from one monopoly segment to another, so much the better. While 

service to small communities is one goal of U.S. public policy, to do so on this scale at 

one of the most desirable and capacity-restricted airports in the country is enormously 

wasteful. 

US Airways’ strategy has even led to the creation of a “hub” at DCA, an airport 

uniquely designed to serve local traffic to and from the nation’s capital. Hubs by their 

very nature process millions of connecting passengers who have no interest or reason 

to be at the hub airport, other than to change planes. In fact, 37% of all passengers 

processed by US Airways at DCA are connecting or through passengers. Therefore, of 

US Airways’ 460 total slots, the equivalent of 170 slots are consumed by traffic that has 

no desire to be in Washington (Exhibit WN-SR-105). 

Baseless accusations against Southwest cannot hide these unfortunate facts, 

which is another reason why US Airways does not deserve yet another pair of slots that 

it will under-utilize with RJ aircraft in furtherance of wasteful DCA operations.

3. US Airways’ Description of the Decisional Criteria

In This Case is Incorrect. 

Not content merely with the opportunity to compete with limited incumbents for 

the slot exemptions that are at issue in this case, US Airways has advanced a novel 

argument that the limited incumbent/new entrant decisional criterion of AIR-21”does not 

apply” to this case at all (Consolidated Answer of US Airways at p. 2). Consequently, 

under US Airways’ theory, only four criteria apply, and US Airways allegedly meets 

three of them (Id. at pp. 2-3). 
6

US Airways has misinterpreted the applicable law. Of the 20 slot exemptions 

that Congress authorized the Department to allocate pursuant to 49 U.S.C. § 41718, six 

were designated for “air transportation to small hub airports and non-hub airports” 

without regards to new entrant or limited incumbent status. See 49 U.S.C. 

§41718(c)(3)(A). However, this provision is not applicable. The slot exemptions at 

issue here are authorized for service to “medium hub and smaller airports,” which are 

governed by § 41718(c)(3)(B), which does not eliminate the limited incumbent/new 

entrant criterion. Consistent with this interpretation, the Department enumerated all five

criteria in its February 17, 2012 Notice, including the limited incumbent/new entrant

qualification.5 So, while US Airways is indeed eligible to compete for the slot exemptions 

in this case notwithstanding its Large Incumbent status, the limited incumbent/new 

entrant criterion of AIR-21 remains one of five possible carrier-selection factors that 

apply in this case. 

Finally, US Airways also is incorrect in its claim that OKC should be considered a 

“medium hub” for purposes of this case (Consolidated Answer at p. 2). OKC is 

classified as a “small hub” in the FAA’s most current Terminal Area Forecasts, and 

therefore must be considered as such for purposes of the case. The fact that OKC was 

classified as a “medium hub” in 1997 is irrelevant since the slot exemptions at issue 

may be used for service to “medium hub or smaller airports” (see above). OKC is 

obviously an eligible airport under this standard (which US Airways acknowledges), and 

thus its 1997 classification is no longer relevant. 

 

5 DOT Notice at p. 2. 
7

REPLY TO FRONTIER:

1. Frontier’s After-the-Fact Traffic Forecast and Fare Savings

Are Contrived and Not Credible 

Frontier’s March 5 Application in this proceeding, which consisted of 13 pages 

touting the alleged benefits of Frontier’s proposed DCA-SDF service, contained no fare 

proposal, no traffic forecast, and no calculation of fare savings – in other words, no 

economic impact or benefits analysis at all. Southwest’s Application, on the other hand, 

included all these essential elements of a serious service proposal for scarce DCA slot

exemptions. Southwest projected an average fare of $163 in the DCA-OKC market (a 

40% reduction from current fares), a detailed and transparent traffic forecast that 

projected stimulation of 55,000 new passengers, and a fully explained estimate of 

consumer fare savings of $8.2 million annually (Exhibits WN-117 through -121). 

It was only in Frontier’s March 20 Answer -- more than two weeks later, and with 

the benefit of having all of Southwest’s economic analysis during that time -- that 

Frontier for the first time presented a proposed fare and assumed traffic for its DCASDF proposal.

6

 Also in Frontier’s March 20 Answer was an estimate of fare savings

that – surprise – exceeded the fare savings calculation that Southwest had submitted 15 

days earlier. 

Frontier’s filing of an application devoid of any economic analysis, followed by a 

submission more than two weeks after having the benefit of Southwest’s fully 

documented proposal, smacks of gamesmanship that should have no place in a 

Department carrier-selection proceeding. Frontier’s actions are a disservice to the 

Department and the parties, who rightly expect all applicants to present the essential 

 

6

Frontier assumed its passenger traffic by simply assigning a 75% load factor to its proposal without analysis 

(Exhibit F9-R-2).
8

elements of their proposals at the beginning of the process in an open and transparent 

way. 

In any event Frontier’s after-the-fact economic projections have no credibility and 

should be disregarded. As shown in Exhibit WN-117, Southwest estimated that fare 

savings of $8.2 million will accrue to passengers annually from its proposed DCA-OKC 

service. Frontier’s belated estimate of $9.9 million in fare savings from DCA-SDF 

service was computed on a different, more inflated basis than Southwest used. Rerunning Southwest’s model using Frontier’s methodology would increase Southwest’s 

DCA-OKC savings to $11.1 million annually (Exhibit WN-SR-106).

Further, Frontier touts the fact that the $103 fare it contrived for rebuttal purposes 

is lower than Southwest’s DAL-OKC fare of $163. This is true in absolute dollars but 

entirely irrelevant, since the DCA-OKC route is 1,158 miles but DCA-SDF is only 474 

miles. When the two applicants’ fares are compared on a per-mile basis, it is revealed 

that Frontier’s yield (fare-per-mile) would be 54% higher than Southwest’s (Exhibit WNSR-107). Thus, Frontier’s claims of having “lower fares” are not only invalid but the 

opposite is true: Southwest will offer by far the better fare value to passengers.7

2. Frontier’s Claim that BWI and DCA Serve the Same Market

is Erroneous & Contrary to the DOT’s Own Findings

Frontier repeatedly attempts to discredit Southwest’s DCA-OKC proposal by 

claiming that Baltimore-Washington International (BWI), like DCA, is just part of the 

“WAS” market that should be used for purposes of comparing the applicants’ proposals 

 

7

Frontier also argues in its Answer that it really has only 12 DCA slots because 8 of its 20 are operated 

(on its behalf) by Republic (Answer of Frontier at pp. 3, 18). Following Frontier’s logic it would then be the 

case that Southwest has zero DCA slots, since all 25 of Southwest’s slots are operated by its whollyowned subsidiary AirTran Airways. Thus, if Frontier’s theory is accepted, it must also be true that 

Southwest is applying in this case not as a limited incumbent, but as a new entrant. 
9

in this case (see, e.g., Frontier Answer at pp. 17-21). This, it hopes, would make 

Southwest an incumbent in its own proposed market. But Frontier’s claim is contrary to 

the Department’s own empirical analysis of airline competition in the 

Washington/Baltimore area, in which the Department has found DCA to be a separate 

market from both BWI and Washington Dulles (IAD). This issue was a central question 

in the recent DL/US “Slot Swap” proceedings, as Delta and US Airways argued strongly 

that competition from carriers at IAD and BWI should assuage concerns over US 

Airways’ increasing dominance and monopolization at DCA. The Department 

(supported by the Antitrust Division of the Department of Justice (DOJ)) rejected that 

argument. Based on an extensive analysis of carrier pricing at all three airports, the 

Department concluded that “for a large portion of passengers, especially time-sensitive 

passengers...Washington area airports are not effective substitutes for each other.”8

Specifically, DOT found that the “average yield in all markets at DCA is 27 cents per 

mile, vs. 17 cents at Dulles and 14 cents at BWI.”9The Department also concluded that 

“if the airports were effective economic substitutes for all passengers, [DOT] would 

expect to see a greater self-equalizing of yields and the yield spreads would not differ 

so significantly.” 10 Similarly, the Department found that disparities in fare levels 

between the three airports were significant and persistent, and found “no evidence of 

any significant substitutability existing among... Washington area airports.” Only eight 

 

8

Grant of Petition with Conditions (DL/US Slot Swap 1), 75 Fed. Reg. 26322, 26333 (May 11, 2010); Department of 

Justice Comments, p. 16 (March 24, 2010) and Department of Justice Reply Comments pp. 9-11 (April 5, 2010), 

filed in Docket FAA-2010-0109.

9

Id. at 26333.

10 Id. 
10

months ago, the Department reaffirmed these findings in its July 28, 2011 Notice in the

revised Slot Swap proceeding.11

The factors examined by the Department demonstrate convincingly that neither 

airlines nor passengers consider the three Washington/Baltimore area airports to be 

economic substitutes for one another. This not only is true due to each airport’s unique 

geographic location, but it also reflects the distinct high-density pockets of population 

within the regions, and the lengthy and often unpredictable travel times between 

downtown DC and outlying areas in the region. Otherwise, why would JetBlue have 

paid $40 million for 8 slot pairs at DCA in the DL/US Slot Swap case auction? If airport 

access in the region is interchangeable and passengers do not have strong airport 

preferences, then the market value of DCA slots would be minimal. Such is clearly not

the case.

Frontier does not even acknowledge the Department’s recent and extensive 

analysis of airline competition in the Washington/Baltimore area, much less address the

Department’s findings in a serious way. Instead, Frontier mindlessly repeats its 

unsupported refrain that BWI, IAD, and DCA are all part of a single, self-serving “WAS” 

market that must be used to compare applications in this case. Frontier’s argument is 

self-serving and erroneous, and should be rejected once again, as both the DOT and 

DOJ have done in the past. 

3. Frontier’s March 23 Reply is Baseless 

Both US Airways and Frontier filed pleadings objecting to the discussion in 

Southwest’s March 20 Response addressing the interlocking commercial relationships 

between US Airways and Frontier’s parent company Republic Airways Holdings. 

 

11 Grant of Petition with Conditions (DL/US Slot Swap No. 2), 76 Fed. Reg. 45313, 45327-28 (July 28, 2011). 
11

Frontier even goes so far as to say that Southwest’s “falsehoods” should be “stricken 

from the record” (Frontier Reply at p.1). These objections12 are completely misguided

and have no merit.

The extensive commercial and contractual relationships among Frontier, 

Republic, and US Airways are both highly unusual in the airline industry and highly 

relevant to this proceeding. As Southwest pointed out in its Response, if Frontier were 

to be awarded the DCA-SDF route it would be competing against affiliated companies 

within its own Republic Holdings family that are already operating the DCA-SDF route 

for US Airways (Exhibit WN-R-207). Southwest raised the logical and legitimate 

question whether this unusual circumstance would affect the vigor of competition on that

route. This is hardly a surprising question. Given that the majority of Republic 

Holdings’ business is contract flying, and that US Airways accounts for 43% of that 

business and is by far the largest customer of Republic Holdings (Exhibit WN-R-210), 

would it be surprising that Republic Holdings would not want one of its subsidiaries to 

cause economic losses to that customer? Particularly when Holdings, according to 

several media reports,13 is in the process of trying to sell that same subsidiary because 

it loses money and does not fit into Republic’s contract flying business model? 

This is an issue of the very real economic incentives that could well affect both 

Frontier and its parent company Republic Holdings in the event Frontier is awarded the 

DCA-SDF route, and therefore is a perfectly legitimate matter for the Department’s 

 

12 Reply of Frontier, March 23, 2012 and Additional Comments of US Airways, March 22, 2012. US 

Airways’ filing is not only confused but irrelevant, since Southwest did not address the question whether 

US Airways is or is not competing vigorously with Frontier. Rather, Southwest’s concern is that Frontier

may have an economic incentive not to compete aggressively against US Airways because of the 

potential conflict of interest within Frontier’s own corporate family, that of Republic Holdings. 

Consequently, US Airways’ Additional Comments should be disregarded. 

13 See, e.g., “Republic Hones Its Pitch to Sell or Spin Off Frontier,” Wall Street Journal (Feb. 7, 2012), at 

p. B4.
12

consideration. Judging from the rhetoric in its March 23 Reply it appears that Frontier 

“doth protest too much” against Southwest’s raising of this issue. If anything deserves 

to be “stricken” from the record in this case it is Frontier’s deliberately delayed and 

contrived economic forecasts, which as noted above are a flagrant abuse of the 

Department’s process. But Southwest is not requesting that the Department strike 

anything, as we are confident it is fully capable of according all evidence its appropriate 

weight and credibility. 

CONCLUSION

The record of this proceeding demonstrates that Southwest’s proposal for DCAOKC-DAL service will not only satisfy the maximum number of decisional criteria but will 

provide far greater benefits to the public than the proposals of either Frontier or US 

Airways. We therefore urge the Department to grant the two slot exemptions at issue to 

Southwest to enable it to initiate the first-ever nonstop service between DCA and OKC, 

with single plane service beyond to Dallas Love Field.

Respectfully submitted,

__________________________

Robert W. Kneisely 

March 29, 2012
CERTIFICATE OF SERVICE

I hereby certify that on March 29, 2012, a copy of the foregoing was served via email on the following persons:

robert.cohn@hoganlovells.com (Frontier Airlines)

patrick.rizzi@hoganlovells.com (Frontier Airlines)

howard_kass@usairways.com (US Airways)

benjamin.slocum@usairways.com (US Airways)

tmerrick@swapa.org (SWAPA)

susan.kurland@dot.gov

todd.homan@dot.gov

brian.ctr.meehan@faa.gov

Mark Kranenburg 

Director of Airports 

Will Rogers World Airport 

mark.kranenburg@okc.gov

John E. Potter

President and Chief Executive Officer 

Metropolitan Washington Airports Authority

john.potter@mwaa.com

info@airlineinfo.com

__________________________

Leslie C. Abbott
Southwest Carried Significant Shares of Traffic in 

US Airways’ Figure 7(a) Markets Before Nonstop Service

Source: U.S. DOT, Origin-Destination Passenger Survey, via Diio, LLC.

Docket OST-2000-7182

Exhibit WN-SR-101

31% 30%

20%

9%

6%

4%

0% 0%

0 %

5 %

10%

15%

20%

25%

30%

35%

DL UA WN US AA CO F 9 AC

43%

20%

14%

12%

6%

4%

0% 0%

0 %

5 %

10%

15%

20%

25%

30%

35%

40%

45%

50%

WN UA US AA DL CO F 9 AS

Percentage Share of CHI-ONT O&D Passengers Before WN Nonstop – CY 2009

Percentage Share of BDL-DEN O&D Passengers Before WN Nonstop- CY 2009
The Southwest Markets in US Airways’ Figure 7(a) 

Already Had Low Fares Before Southwest’s Nonstop, So the Traffic

Increases Were Due to Service Stimulation Alone

Fares In New Southwest Nonstop Markets

Market Fare Market Fare Current WN

 Before Nonstop After Nonstop Yield Curve Fare

BDL-DEN $172 $173 $180

CHI-ONT $183 $181 $181

Docket OST-2000-7182

Exhibit WN-SR-102

Page 1 of 2
The Southwest Markets in US Airways’ Figure 7(a) 

Already Had Low Fares Before Southwest’s Nonstop, So the Traffic

Increases Were Due to Service Stimulation Alone

Fared O&D Passengers Fared O&D Passengers Period Period 

 Before Nonstop After Nonstop % Increase Before After

BDL-DEN 89,527 134,691 50% CY 2009 YE Q1 2011

CHI-ONT 79,228 124,140 57% CY 2009 YE Q1 2011

O&D Passengers In New Southwest Nonstop Markets

Southwest’s Estimated Service Stimulation

in its DCA-OKC Forecast = 28%1

Docket OST-2000-7182

Exhibit WN-SR-102

Page 2 of 2

NOTE: THE OTHER TWO MARKETS CITED IN FIGURE 7(a), BHM-PHX AND LIT-PHX, HAVE BEEN SERVED BY WN SINCE DECEMBER 1999 AND MARCH 1994, RESPECTIVELY. 

BHM-PHX had no service in just February 2009 and LIT-PHX was temporarily suspended from September 2008-July 2009. Therefore, citing these market examples is completely invalid. 

Also note that US calculated the CHI-ONT traffic increase incorrectly. 

1/ See Southwest Application, Appendix 1.

Source: U.S. DOT, Origin-Destination Passenger Survey, via Diio, LLC; Consolidated Answer of US Airways, Figure 7; WN yield curve from WN Application, Appendix 6.
In Eight Nonstop Markets Entered by Southwest Since 2009 Where Average 

Fares Declined by at Least 40%, Traffic Increased by an Average of 214%

Docket OST-2000-7182

Exhibit WN-SR-103

Note: All HOU markets include IAH and HOU, All ECP markets include ECP and PFN.

Source: U.S. DOT, Origin-Destination Passenger Survey, via Diio, LLC.

Period O&D Passengers Average Fare Change

Market Before After Before After Before After Passengers Fare

BNA-ECP YE Q1 2010 YE Q2 2011 1,251 54,609 $331.93 $121.51 4264.7% -63.4%

ECP-MCO YE Q1 2010 YE Q2 2011 2,163 44,844 $251.86 $102.25 1972.8% -59.4%

BWI-ECP YE Q1 2010 YE Q2 2011 6,569 73,116 $230.83 $124.86 1013.0% -45.9%

ECP-HOU YE Q1 2010 YE Q2 2011 3,150 35,010 $247.92 $157.95 1011.5% -36.3%

SFO-SNA YE Q1 2009 YE Q2 2010 187,637 747,658 $149.73 $72.42 298.5% -51.6%

BWI-LGA YE Q1 2009 YE Q2 2010 20,034 77,328 $154.20 $86.80 286.0% -43.7%

MCI-MKE YE Q3 2009 CY 2010 73,076 149,134 $155.91 $91.34 104.1% -41.4%

BOS-PHL YE Q2 2009 YE Q3 2010 162,652 253,045 $222.20 $132.54 55.6% -40.4%

456,532 1,434,743 $179.56 $93.33 214.3% -48.0%
US Airways’ Average Aircraft Size Used for 

Its DCA Air Carrier Slots Is Only 88 Seats

Line 1/ From OAG, week of June 11-17, 2012.

Line 2/ From OAG, week of June 11-17,2012. Includes US aircraft with 76 or fewer seats only.

Line 3/ From FAA Slot Reports, Current and Future, dated 2-13-2012 and OAG schedules June 2012. US Has 327 air carrier slots and 133 commuter slots.

Line 4/ From FAA Slot Reports, Current and Future, dated 2-13-2012 and OAG schedules June 2012. US Has 327 air carrier slots and 133 commuter slots.

Line 5/ (Line 1 – (Line 2 x Line 3) )/ (Line 4). Assumes that commuter slots are operated at the US’s commuter aircraft average aircraft size at DCA. 

Docket OST-2000-7182

Exhibit WN-SR-104

1. US Airways Average DCA Aircraft Size 78.4

2. US Airways Average DCA Commuter Aircraft Size 54.9

3. US Airways Commuter Slots as % of Total Slots 29%

4. US Airways Unrestricted Air Carrier Slots as % of Total Slots 71%

5. Average Aircraft Size for US Airways Air Carrier Slots 88.0
Local

63%

Connecting/

Thru

37%

Mainline/Large Aircraft 

RJ/Commuter Aircraft 

US Airways Wastes 170 DCA Slots to 

Accommodate Connecting Traffic

Docket OST-2000-7182

Exhibit WN-SR-105

Source: OAG Schedules for the week of June 11th through the 17th, 2012; U.S. DOT, O&D Survey and T-100 data, via Diio, LLC.

US Airways’ DCA Network

Weekly Departures

Ave. Seats per Departure

Current DCA Slots

1,414

78

460

YHZ

DCA

Distribution of US Airways’ 

DCA Onboard Passengers

Total US Slots

Percent Connecting/thru Pax

Equivalent Slots Used for 

Non-Washington Pax (460 x 37%)

460

37%

170
1/ Exhibit WN-117

2/ In accordance with economic theory for estimating the savings to new customers, Southwest multiplied the number of newly generated passengers by 50% of the fare difference (savings). 

This is illustrated is Southwest’s Application, Appendix 1, page 4, and it is a method used by FAA. Frontier on the other hand included 100% of the fare difference in its savings calculation. $6.1

$0.5

$1.5

$0

$1

$2

$3

$4

$5

$6

$7

$8

$9

$10

$11

$12

$8.2

million

WN Consumer Fare SavingsSouthwest Method

(Millions)1

Frontier’s Fare Savings Methodology Produces Annual 

Savings Exceeding $11 Million for Southwest’s Route Proposal

Docket OST-2000-7182

Exhibit WN-SR-106

DCA-OKC

DCA-DAL

DCA-Cx Beyond OKC

$8.6

$0.9

$1.5

$0

$1

$2

$3

$4

$5

$6

$7

$8

$9

$10

$11

$12 $11.1

million

WN Consumer Fare SavingsFrontier’s Method

(Millions)2
14.1

21.7

0.0

5.0

10.0

15.0

20.0

25.0

WN DCA-OKC F9 DCA-SDF

Proposed Yield 

(Cents)

Docket OST-2000-7182

Exhibit WN-SR-107

+54%

Frontier's Comparison of Fares is Highly Misleading

Source: U.S. DOT, O&D Survey and Schedule data, YE Q3 2011, via Diio, LLC.

1,158 miles

$163

474 miles

$103

Nonstop

Miles

Fare

Despite lower absolute fares, F9's 

proposed yield exceeds WN's by 

more than 50%