EATON COUNTY BOARD OF COMMISSIONERS 

MEMHRkS 

• Michael lloscy 

Blake Mulder 

Sue HolTinati 

Larry Brunette "' ' '. 

Jitii Osicczonck' 

John Boles • 

Glenn Frectnan Ml 

MRMUEItS 

Joseph Brchlcr 

Royer Eakin 

Wiiyrie Kidge 

' ; Dalc'Barr, •• 

•Jereniy'Wliitiuni 

Ben Colcslock 

1045 Independence Blvd,CharloUe, Ml 48SI3 • 

John Forell, Chairperson 

' •- - ^Daryl Baker, Vice Chairperson. •• 

. . f , j„ . . . 

Docket Management Facility 

U.S. Depailmcnt ofTransportation ' ' • ' 

1200 New Jersey Avenue SE., 

West Building Ground Floor, Room WI2-'I40, 

Washington, DC 20590 

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Ref: Sun Country Slot Exemption - Docket Number FAA-2012-0089 

Ladies and Gentlemen: 

Sun Country Airlines has requested an exemption Ironi the slot limit tor Ronald Reagan 

Washington National Airport (DCA) set forth in § 93.123(a). to permit the FAA to create air 

carrier slots during certain limited hours for Sun Country's use. The proposed air carrier slots 

would replace two slot exemptions under DOT Order 2010-12-16 awarded to Sun Country. On 

January'6, 2012, the United States Court of Appeals for the District of Columbia Circuit vacated 

the DOT Order, and Sun Country will lose its existing service between DCA and Lansing's 

Capital Region-Airport. Specifically, Sun Country desires one daily slot during each of the 1000 

and I 100 hours. The proposed exemption would permit Sun Country to continue operating its 

existing services and avoid an inequitable result ofthe Court's order. 

The introduction of Sun Country Airlines service on the LAN-DCA route has been extremely 

bcnetlcial to the consumers in that market. According to DOT data for the third quarter of 201 I, 

the average fare on that route has, decreased by 26% year over year, and the number daily 

passengers on (he route has risen by 156%. Sun Country has proven that a new entrant carrier at 

DCA can successfully compete, even with this very limited slot availability, and even in a new 

entrant market, in addition to the competitive benefits enjoyed by consumers in the Lansing 

metropolitan area,' the service has provided additional benefit to consumers in Minneapolis-Sl. 

Paul. The LAN-DCA service connects with daily service in the LAN-MSP market,-pi^oviding 

citizens of Minneapolis-St. Paul with a low fare alternative to the non-stop service provided to 

pCA by Delta Air Lines. ..'.". " ' . : 
Without the exemption, Sun Country will be forced to terminate service between LAN and DCA. 

Lansing will no longer have direct air access to DCA, and those passengers who use Sun 

Country currently offers scheduled service for sale on the LAN-DCA-LAN route only through 

the end of April, due to the Republic Airlines. Inc. decision, and pending a decision by the FAA 

on this Application for Exemption. Summer season sales in the market are largely dependent on 

available for sale as soon as possible. Further delay, in the ability to offer the market for sale 

will result in significant negative financial impart, on both Sun Country and on its customers. 

The Sun Country DCA service is essential to the economic growth of the Greater Lansing 

Region. The daily service is the only large aircraft (737-800) service to Washington Reagan 

Airport, in the state of Michigan outside of Detroit. Prior to Sun Country, the regional 

community had requested the introduction of this service from numerous other airline operators 

without success. Accordingly, it is critical that the FAA take the necessary steps to ensure the 

continuation of the Sun Country slots at the established flight times in support of Greater 

Lansing's business and economic growth. 

Your immediate approval of this exemption, so that Sun Country can begin to enter (lights 

schedules for sale for the balance of 2012, will be greatly appreciated. 

Sincerely, 

Qa/ii/)(i OcJf^^-' 

Daryl Bakerl Chairman 

Public Works and Planning Committee