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February 20, 2012 

Via Fax-202-493-2251 

Docket Management Facility 

U.S. Department of Transportation 

1200 New Jersey Avenue, S£ 

West Building Ground Floor, Room W12-140 

Washington. DC 20590 

R£: Sun Country Slot Exemption - Docket Number FAA-2012-0089 

Ladies and Gentlemen: 

I am writing regarding Sun Country Airlines' requested exemption from the slol limit for 

Ronald Reagan Washinijton NaLional 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 .Tanuary 6, 2012, the United Stales Court of Appeals for the District of Columbia 

Circuit vacated the DOT Order, and Sun Couaitry will lose its existing service between DCA and 

Lansing's Capital Region International Airport. As I understand it. Sun Country desires one 

daily slot during each of the 1000 and 1100 hours. The proposed exemption would permit Sun 

Country to continue operating its existing sciviccs lo benefit all in the Mid-Michigan area. 

As you know. Repubhc, through their subsidiaries Midwesi andyor Frontier, offer no 

sei^vice from Lansing. While the FAA must comply with the court order, T hope tiiat an 

acconunodation for an exeinpLion can be extended to Sun Country for the reasons I detail below. 

The Sun Coiuilry DCA service is important to the economic vitality and recovery of the 

Greater Lansing Region. Lansmg is the capital city of Michigan and there are many business, 

le^slative and personal reasons to justify the need for convenient travel lo Washington, DC for this 

area's residents. My personal issue includes the fact that my son and his fiance have now moved to 

Washington, DC, My wife and 1 as well as my son, hope to use the Lansing to DC flight numerous 

times each year. Additionally, from a business standpoint my Law Firm (40 plus attorneys) 

presently has an office in Washington, DC. It is a considerable inconvenience in terms of time and 

(^iiASEn TncDiLCOC K DAVI D & ^UNLA T ip c LANSING DFTFOrr GFVysID RAPIDS WASHINGTON D.C. 
02/20/201 2 MON 15:1 1 F.\X 0002/00 2 

Docket Management Facility 

U.S. Department of Transportation 

February 20, 2012 

Page 2 

expense to our clients for our attorneys to have to travel to Detroit to catch a flight to Washington, 

DC. 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, tiie regional community had 

requested the introduction of this service from numerous other airline operators without success. As 

a matter of history, the capital city of Michigan has been sporadically and inconsistently served by 

the defunct Independence Air which left the Lansing market in January 2005, and the former 

Northwest, which cancelled their route in January 2006. Sim Country ha;; safely and efficiently 

operated this service since its inception. This is a very popular route and the Capitol City Airport 

certainly needs this fliglit lo remain financially sound. Michigan, m general, and Lansing in 

parhcular, has long felt the biunt of our country's recession to a far greater extent than the rest of the 

country. To eUminate tlie Lansing lo Washington. DC flight will be another set back to this 

community's effort to recover lirom the near depression that has gripped this area for the past ten 

years. 

Accordingly, it is critical to Lansing and to the enure Mid-Michigan area that the FAA take 

the necessary steps to ensure the continuation of the Sim Country slots at the established flight times 

in suppon. of Greater Lansing's business and economic growth. 

In summary, your prompt approval of this exemption is requested so that Sun Country can 

begin to enter flight schedules for sale for the balance of 2012. 

Sincerely, 

ERASER TRKBILCOCK DAVIS & DUNLAP, RC . 

/%oi^ a ich 

Gary C. Rogers 

Direct Dial Number- (517)377^)828 

E-mail Addre:>->- GR0GERSigFRASHRLAWFlRM.COM 

GCR/jae 

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