# sun country airlines

FILED ELEC TRON IC A LLY Ms. Dorothy Beard, C hi e f Docket Operations U.S. D e partm e nt of Transportation Wes t Building Ground Floor Room W12
- 140 1200 New J ersey Ave., SE Washington, D C 20590 Re: Docket OST-2000-7182 ERRATA NOTICE D ear Ms. Beard, October 12 , 2010

MN Ai rl ines, LLC d/b / a Su n Coun tr y Airlines respectfu ll y su bmit s the enclosed co rre cte d s h ee ts to it s application and underlying exhibits filed in th e above-captioned docket on Sep t ember 3 0 , 2010. Copie s of thi s letter and the enclosures have been s ubmitt ed elect r o ni ca ll y to th e D epartmen t 's Docket Operat i o n s and served upon all parties li s t ed on the serv i ce li s t by e l ectron i c ma i l. Respectfully submilted , / s / John S. Fredericksen Vice Pres i dent
- General Counsel MN Airlines, LL C

1300 Mendota He i ghts R o ad , Mendota Heights , MN 55120 Corporat e Headquarters 651
. 681.3900 Re s er v ations 800
. 359
. 6786 Fax 651
. 681
. 3901CERTIFICATE 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 prep aid, on the following: Edward P. Faberman Counsel for AirTran Airways efaberman@wileyrein.com Joanne W. Young Counsel for Spirit Airlines j young@yklaw.com Marshall S. Sinick Counsel for Alaska Airlines msinick@ssd.com Howard Kass US Airways h oward_ kass@usairways.com Carl B. Nelson American Airlines c arl.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. b ob.kneisley@wnco.com Alexander Van Der Bellen Jeff Morgan Sametta C. Barnett Delta Air Lines s ascha.vanderbellen@delta.com sametta.c.barnett@delta.com j eff.morgan@delta.com J effrey Manley United Air Lines jeffrey.manley@united.com Phil ip Sunderland Metropolitan Washington Airports Authority philip.s underland@mwaa.com Capital Region Airport Authority 4100 Capital City Boulevard Lansing, MI 48906 Brian Meehan Federal Aviation Administration b rian.ctr.meehan@faa.gov Scott Donley Federal Aviation Administration s cott.donley@faa.gov Robert E. Cohn Counsel for Republic Airline Counsel for Frontier Airlines r obert.cohn@hoganlovells.com ______/s/

______ Kathy L. LuhrmanAPPLICATION OF MN AIRLINES, INC. D/B/A SUN COUNTRY AIRLINES Page 4 ( Corrections appear i n 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 Was hington 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 equip ment 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 curren tly 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 Lan sing
- DCA service estimated to be 3 1,390 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 sav ings over existing service options and at lower fares . Its proposal therefore satisfies all of the Vision 100 statutory criteria applicable to this proceeding . N onstop service to DCA would be introduced at a small hub airport with no such service today a nd the traveling public would gain substantial competitive benefits.APPLICATION OF MN AIRLINES, INC. D/B/A SUN COUNTRY AIRLINES Page 7 ( Corrections appear i n 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 m arket. 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 5 1,100 passengers for its MSP
- DCA service, Sun Country’s proposal would trans late into total fa re savings of approximately $ 3.93 million per year. E xhibit 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 ave rage $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 exemp tion 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 ( 1 3,140 ) , the effect of Sun Country’s service would be to lower overall fares, stimulat ing 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 9 5, 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 Lansing
Washington 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 LAN MSP 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