sun country 

airlines 

FILED ELECTRON ICALLY 

Ms. Dorothy Beard, Chi ef 

Docket Operations 

U.S. Department of Transportation 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Ave., SE 

Washington, DC 20590 

Re: Docket OST-2000-7182 

ERRATA NOTICE 

Dear Ms. Beard, 

October 12, 2010 

MN Airlines, LLC d/b/a Sun Country Airlines respectfully submits the enclosed 

corrected sheets to its application and underlying exhibits filed in the above-captioned docket on 

September 30, 2010. 

Copies of this letter and the enclosures have been submitted electronically to the 

Department's Docket Operations and served upon all parties listed on the service list by 

electronic mail. 

Respectfully submilted, 

/s/ 

John S. Fredericksen 

Vice President - General Counsel 

MN Airlines, LLC 

1300 Mendota Heights Road, Mendota Heights, MN 55120 

Corporate Headquarters 651 .681.3900 Reservations 800.359.6786 Fax 651 .681 .3901 
CERTIFICATE OF SERVICE

I hereby certify that I have on this12th day of October 2010 served a copy of the foregoing errata 

notice of MN Airlines, LLC d/b/a Sun Country Airlines by electronic mail or first-class mail, 

postage prepaid, on the following:

Edward P. Faberman

Counsel for AirTran Airways 

efaberman@wileyrein.com

Joanne W. Young

Counsel for Spirit Airlines

jyoung@yklaw.com

Marshall S. Sinick

Counsel for Alaska Airlines 

msinick@ssd.com

Howard Kass

US Airways

howard_kass@usairways.com

Carl B. Nelson

American Airlines

carl.nelson@aa.com

R. Bruce Keiner

Counsel for Continental Airlines

rbkeiner@crowell.com

Hershel Kamen

Dan Weiss

Continental Airlines

hkamen@coair.com

dan.weiss@coair.com

Robert W. Kneisley

Southwest Airlines Co.

bob.kneisley@wnco.com

Alexander Van Der Bellen

Jeff Morgan 

Sametta C. Barnett

Delta Air Lines

sascha.vanderbellen@delta.com

sametta.c.barnett@delta.com

jeff.morgan@delta.com

Jeffrey Manley

United Air Lines

jeffrey.manley@united.com

Philip Sunderland

Metropolitan Washington Airports 

 Authority

philip.sunderland@mwaa.com

Capital Region Airport Authority

4100 Capital City Boulevard

Lansing, MI 48906

Brian Meehan

Federal Aviation Administration

brian.ctr.meehan@faa.gov

Scott Donley

Federal Aviation Administration

scott.donley@faa.gov

Robert E. Cohn

Counsel for Republic Airline

Counsel for Frontier Airlines

robert.cohn@hoganlovells.com

______/s/______

Kathy L. Luhrman
APPLICATION OF

MN AIRLINES, INC.

D/B/A SUN COUNTRY AIRLINES

Page 4 (Corrections appear in bold)

Granting Sun Country’s request would confer substantial benefits on passengers traveling 

between DCA and Central Michigan. Lansing currently has no nonstop service to DCA or to 

any other Washington area airport. Existing services between Lansing and DCA are limited to 

change-of-plane services over the hubs of major carriers. Service from Lansing to connecting 

hubs is currently provided with small regional jets, rather than the B737-NG equipment operated 

by Sun Country. Granting Sun Country’s request for the exemption slots at DCA would 

substantially reduce the elapsed travel time between Lansing and Washington, D.C. While the 

shortest elapsed travel time in the Lansing-DCA market is currently 3 hours, 17 minutes, Sun 

Country’s proposed nonstop service would cut the elapsed travel time to 1 hour, 32 minutes, with 

a total savings in elapsed time of 1 hour, 45 minutes.

Sun Country’s proposal would have additional consumer benefits in the form of 

significantly lower fares. The current average fare for air travel between Lansing and DCA is 

$164. Sun Country’s proposed average fare for its Lansing-DCA flights would be $130, over 

20% less. Exhibit SY-2. With the number of passengers for its Lansing-DCA service estimated 

to be 31,390 per year, the average annual fare savings for the passengers on Sun Country’s 

proposed service would be in excess of $1 million. Id. 

In short, Sun Country’s Lansing-DCA service would produce significant time savings 

over existing service options and at lower fares. Its proposal therefore satisfies all of the Vision 

100 statutory criteria applicable to this proceeding. Nonstop service to DCA would be 

introduced at a small hub airport with no such service today and the traveling public would gain 

substantial competitive benefits.

 
APPLICATION OF

MN AIRLINES, INC.

D/B/A SUN COUNTRY AIRLINES

Page 7 (Corrections appear in bold)

options, maximizing the competitive benefits from the award of scarce within-perimeter slots at 

DCA. 

Sun Country’s proposed single-plane service would mean dramatically lower fares for 

passengers traveling in the MSP-DCA market. The current average fare for MSP-DCA service 

is $222. Sun Country’s average fare in the same market would be $145, a reduction of 35%. 

With estimated annual traffic of 51,100 passengers for its MSP-DCA service, Sun Country’s 

proposal would translate into total fare savings of approximately $3.93 million per year. Exhibit 

SY-3. Substantial benefits would also be achieved for passengers in the local MSP-Lansing 

market, where Delta currently provides the only nonstop service. MSP-LAN fares now average 

$198; Sun Country would offer an average fare in the same market of $130, around 34% less. 

Exhibit SY-4.

6

Granting the DCA within-perimeter exemption slots available in this proceeding to Sun 

Country would therefore have the added benefit of promoting a competitive alternative to the 

dominant carrier at MSP. Delta’s share of total enplanements at its MSP fortress hub has 

reached 76 %, an alarming level of concentration that threatens to squelch meaningful 

competition for the foreseeable future unless the Department uses slot exemption proceedings 

such as this one to remedy the situation. Granting DCA slot exemptions for Sun Country’s 

single-plane service from MSP to Washington, D.C. via Lansing would be a start.

Although annual MSP-LAN passenger figures are not large (13,140), the effect 

of Sun Country’s service would be to lower overall fares, stimulating traffic and increasing 

competition with the incumbent carrier on the route.

 6 The combined fare savings achieved from Sun Country’s service proposal would total an 

impressive $5.9 million annually, benefiting 95,630 passengers per year. Exhibit SY-5.
Sun Country's Proposed Single-Plane 

Minneapolis-Lansing-DCA Service

Minneapolis/St. Paul

Lansing

Washington DCA

Segment Dept Arrv

MSP-LAN 7:45 AM 10:05 AM

LAN-DCA 10:40 AM 12:10 PM

DCA-LAN 1:00 PM 2:30 PM

LAN-MSP 3:15 PM 4:00 PM

CORRECTED EXHIBIT SY-1; 

CHANGES UNDERLINED
Sun Country’s Proposed MSP-LAN-DCA Service 

Would Provide Substantial Benefits to Lansing 

and Washington Area Passengers

• In addition to the time savings, Sun Country’s proposed Lansing-DCA 

nonstop service would provide huge consumer benefits for LansingWashington passengers:

Current 

LAN-DCA 

Average Fare

Sun Country Proposed 

LAN-DCA 

Average Fare % Difference

$164 $130 -21%

Estimated # 

of Passengers 

Sun Country 

Would Carry between 

LAN and DCA

Times Current 

LAN-DCA 

Average Fare 

of $164

Times 

Proposed 

LAN-DCA 

Average Fare 

of $130

Average Annual Fare Savings by 

Passengers as a Result of 

Sun Country’s Proposed 

LAN-DCA Service

31,390 $5,147,960 $4,080,700 $1,067,260

Most current industry fare data (1Q2010) APGDat O&D Itinerary Report for LAN-DCA 

• In 2004, when NW and DH flew nonstop services between LAN and 

IAD, there were 127 passengers daily each way between LAN and the 

Washington area. 

CORRECTED 

EXHIBIT SY-2; 

CHANGES 

UNDERLINED
Sun Country’s MSP-LAN-DCA Service Would 

Provide Substantial Benefits to MSP-DCA 

Passengers

• Sun Country’s proposed MSP-DCA single-plane service would provide 

huge consumer benefits for MSP-DCA passengers:

– Currently, only Delta provides nonstop MSP-DCA service. Sun Country’s 

service would provide the first competitive alternative for MSP-DCA and 

DCA-MSP passengers

Current 

MSP-DCA

Average Fare

Sun Country Proposed 

MSP-DCA 

Average Fare % Difference

$222 $145 -35%

Most current industry fare data (1Q2010) APGDat O&D Itinerary Report for MSP-DCA 

Estimated # 

of Passengers 

Sun Country 

Would Carry between 

MSP-DCA

Times Current 

MSP-DCA 

Average Fare 

of $222

Times 

Proposed 

MSP-DCA 

Average Fare 

of $145

Average Annual Fare Savings by 

Passengers as a Result of 

Sun Country’s Proposed 

MSP-DCA Service

51,100 $11,344,200 $7,409,500 $3,934,700

CORRECTED 

EXHIBIT SY-3; 

CHANGES 

UNDERLINED
Sun Country’s MSP-LAN-DCA Service Would 

Also Provide Substantial Benefits to LANMSP Passengers

• Sun Country’s proposed MSP-LAN-DCA service would provide huge 

consumer benefits for LAN-MSP passengers:

– Currently, only Delta provides nonstop LAN-MSP service. Sun Country’s 

service would provide the first competitive alternative for LAN-MSP

passengers

Current 

LAN-MSP 

Average Fare

Sun Country Proposed 

LAN-MSP 

Average Fare % Difference

$198 $130 -34%

Estimated # 

of Passengers 

Sun Country 

Would Carry between 

LAN-MSP

Times Current 

LAN-MSP 

Average Fare 

of $198

Times 

Proposed 

LAN-MSP 

Average Fare 

of $130

Average Annual Fare Savings by 

Passengers as a Result of 

Sun Country’s Proposed 

LAN-MSP Service

13,140 $2,601,720 $1,708,200 $893,520

Most current industry fare data (1Q2010) APGDat O&D Itinerary Report for MSP-LAN 

CORRECTED 

EXHIBIT SY-4; 

CHANGES 

UNDERLINED
Sun Country’s MSP-LAN-DCA Service Would 

Carry Over 95,000 Passengers Annually, at an 

Annual Savings to Those Passengers of 

Nearly $6 million

31,390

51,100

13,140

95,630

0

25,000

50,000

75,000

100,000

LAN-DCA MSP-DCA MSP-LAN TOTAL

Annual Passengers

1.07

3.93

0.89

5.90

$0

$1

$2

$3

$4

$5

$6

LAN-DCA MSP-DCA MSP-LAN TOTAL

$ Millions

Annual Savings

CORRECTED 

EXHIBIT SY-5;

CHANGES 

UNDERLINED