BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

_____________________________________ 

 ) 

Application of ) 

 ) 

SOUTHWEST AIRLINES CO. ) 

 ) 

For Inside Perimeter Slot Exemptions ) Docket DOT-OST-2000-7182 

pursuant to 49 U.S.C. § 41718(b) ) 

 ) 

For service between William P. Hobby Airport ) 

(“HOU”) and Ronald Reagan Washington ) 

National Airport (“DCA”) ) 

_____________________________________ ) 

APPLICATION OF 

SOUTHWEST AIRLINES CO. 

 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 

 

December 5, 2012
1 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

OFFICE OF THE SECRETARY 

WASHINGTON, D.C. 

_____________________________________ 

 ) 

Application of ) 

 ) 

SOUTHWEST AIRLINES CO. ) 

 ) 

For Inside Perimeter Slot Exemptions ) Docket DOT-OST-2000-7182 

pursuant to 49 U.S.C. § 41718(b) ) 

 ) 

For service between William P. Hobby Airport ) 

(“HOU”) and Ronald Reagan Washington ) 

National Airport (“DCA”) ) 

_____________________________________ ) 

APPLICATION OF 

SOUTHWEST AIRLINES CO. 

On November 13, 2012, the Department of Transportation (“DOT” or 

“Department”) established a slot exemption proceeding pursuant to 49 U.S.C. 

§ 41718(b) to request applications from carriers using Stage 3 aircraft for two AIR-21 

slot exemptions previously held by Spirit Airlines. These slot exemptions authorize 

service to a medium hub or smaller airport within the 1,250-mile perimeter established 

for civil operations at Ronald Reagan Washington National Airport (“DCA”) under Title 

49 U.S.C. § 49109. 

 Southwest Airlines Co. (“Southwest”), a limited incumbent carrier at DCA, hereby 

applies for the two slot exemptions available in this proceeding in order to provide largejet, low-fare service between DCA and Houston, one of the largest and most over-priced 

monopoly routes at DCA. As shown below, Southwest’s application is not only 

consistent with the AIR-21 decisional criteria but will generate enormous public and 
2 

competitive benefits for DCA and Houston travelers. A letter from the Honorable Annise 

D. Parker, Mayor of Houston in support of Southwest’s Application is attached hereto. 

Houston has long been served by two airports, George Bush Intercontinental 

Airport (“IAH”) and William P. Hobby Airport (“HOU”).1

 United Air Lines, Inc. (“United”) 

currently has a monopoly on nonstop service in the DCA-Houston market by virtue of its 

service between DCA and its hub at IAH. Consumers will benefit enormously if 

Southwest is granted authority to provide low-fare competition in the DCA-Houston 

market with nonstop service between DCA and HOU. 

DETAILS OF SOUTHWEST’S SERVICE PROPOSAL

ROUTE: HOU-DCA-HOU 

SCHEDULE: HOU – DCA (1025 – 1420) 

(All times are local) DCA – HOU (1500 – 1720) 

FREQUENCY: Daily service 

START DATE: Within 90 days of the 

Department’s Final Order 

AIRCRAFT TYPE: Stage 3 Boeing 737-700 aircraft 

SEATING CAPACITY: 143 seats, all coach configuration 

PROJECTED AVERAGE FARE: $207 each-way2

PROJECTED TRAFFIC STIMULATION: 105,382 annual new passengers 

PROJECTED CONSUMER FARE SAVINGS: $19.1 million annually 

                                                           

1

 IAH and HOU are both owned by the City of Houston and operated by the Houston Airport System 

(“HAS”). The U.S. government has long recognized that the two airports jointly serve the greater Houston 

area. For example, the U.S.-Mexico Bilateral Aviation Agreement, as amended, designates Houston as a 

single point, which can be served by either airport.

2

 Fares referred to in this Application and exhibits exclude all taxes and other government charges but 

include average per-person checked baggage and rebooking/change fees based on DOT Form-41 data. 
3 

I. Southwest’s Service Proposal is Consistent with the AIR-21 

Decisional Criteria, and Will Maximize Consumer Benefits from 

Expanded Low-Fare Competition at DCA.

Southwest’s proposed DCA-HOU-DCA service would significantly advance the 

statutory goals of AIR-21 by fulfilling three out of the four possible carrier selection 

criteria. Applicants in this proceeding are only able to satisfy a maximum of four of the 

AIR-21 decisional criteria because providing “competitive nonstop air transportation on 

a monopoly nonstop route to DCA,” is mutually exclusive with providing nonstop DCA 

service to a community “without existing nonstop air transportation to DCA.” In addition, 

Houston Hobby is eligible for service in this proceeding because it was classified as a 

medium hub airport by the FAA in 1997 and thus meets the requirement of 49 U.S.C. § 

41714(h), as referenced in the Department’s November 13 Notice. In contrast, Houston 

Intercontinental Airport is a large hub and therefore ineligible for service in this 

proceeding. 

Specifically, Southwest’s proposal would meet the following three AIR-21 criteria: 

• provide service by a limited incumbent air carrier at Washington National Airport; 

Southwest is a limited incumbent at DCA; 

• offer competitive nonstop air transportation on a monopoly nonstop route to DCA; 

DCA-Houston is currently a high-fare, monopoly route; and 

• produce the maximum competitive benefits, including low fares; Southwest’s 

proposed HOU-DCA-HOU service will stimulate more than 105,000 new passengers 

in the market and generate over $19 million in consumer fare savings annually. 

Southwest is a recent new entrant at DCA and after many attempts was only able 

to initiate service through its 2011 acquisition of AirTran Airways. Southwest/AirTran is 

a limited incumbent carrier, fulfilling the first AIR-21 criterion with a total of 30 slots and 

slot exemptions (15 daily flights) used for service on six nonstop DCA routes. In total, 
4 

Southwest operates only 3.5% of DCA slots, in stark contrast to the dominant 

incumbent carrier US Airways that controls 472 DCA slots, over 54% of the airport’s 

total. See Exhibit WN-100. 

The Department has recognized in past proceedings that effective competition at 

DCA requires a critical mass of slots.3 An award of the slot exemptions at issue here 

would help Southwest provide more effective and expansive competition with incumbent 

DCA carriers, and generate enormous benefits for the traveling public in doing so. In 

this way, selecting Southwest’s proposal in this proceeding would not only meet the 

AIR-21 criteria but would best advance the broader public interest by expanding lowfare service and competition at DCA. 

II. Houston is One of the Largest DCA Monopoly Routes and Suffers 

from Some of the Highest Fares, Making it an Especially Deserving

Market for Selection in this Case.

 

Southwest’s proposed service would provide sorely needed low-fare competition 

on one of the highest fare monopoly routes at DCA. Currently United offers the only 

nonstop service between DCA and Houston. Due to its monopoly position, United’s 

average one-way nonstop fare in the DCA-IAH market is a stunning $334, 43% above 

average DCA fare levels for that distance (Exhibit WN-101). In fact, Houston is the 

fourth most overpriced of all DCA nonstop markets (Exhibit WN-102). 

By way of comparison, Southwest’s average BWI-HOU nonstop fare is only 

$207, a full $127 – or 38% – less than United’s DCA-IAH nonstop fare (Exhibit WN103). Putting it another way, United’s DCA-IAH nonstop fare is 61% higher than 

Southwest’s BWI-HOU fare. At BWI, where United’s nonstop IAH service competes with 

                                                           

3

 See, e.g., DL/US Slot Swap Proceeding (Docket No. FAA-2010-0109); Final Order, 76 Fed. Reg. 63702, 

63708 (Oct 13, 2011). 
5 

Southwest’s nonstop HOU service, United’s average one-way nonstop fare is $240, 

almost 30% less than its DCA fare to IAH. See Exhibit WN-104. Clearly, Southwest 

places significant downward pressure on United’s pricing when Southwest is able to 

compete head-to-head with United in a nonstop market. 

III. Southwest’s Proposed Service Will Save Consumers Millions of 

Dollars Annually and Enable Tens of Thousands of New Passengers 

to Travel on This Important Route.

Southwest’s proposed low-fare competition against United’s high-fare monopoly 

in the DCA-Houston market will stimulate a huge amount of new traffic to and from DCA 

and generate enormous consumer fare savings. An analysis by the Campbell-Hill 

Aviation Group of Southwest’s service proposal assumes that Southwest will charge an 

average one-way fare of $207 for its nonstop DCA-HOU service, equal to Southwest’s 

average BWI-HOU nonstop fare.4

 See Exhibit WN-103. This projected $207 fare is 

$127, or 38%, below United’s current monopoly fare in the DCA-Houston market. 

Using standard traffic forecasting techniques, Campbell-Hill projects that 

Southwest’s service proposal will stimulate over 105,000 new annual passengers in the 

DCA-Houston market. See Exhibit WN-105. Southwest will carry many of the new 

passengers itself of course, but others will be carried by United, which historically 

lowers its fares in response to direct Southwest competition. As a result, the DCAHouston market as a whole will grow significantly, and passengers will benefit both 

directly by flying on Southwest’s new service and indirectly by patronizing the competing 

carrier that is forced to reduce its high monopoly fares in response to Southwest’s 

competition. 

                                                           

4 This assumption is in fact conservative. Southwest’s recent experience in the DCA-AUS market shows 

that Southwest’s average DCA-AUS fare is almost 5% lower than its average BWI-AUS fare (for the 

August-October 2012 time period; based on internal Southwest analysis).    
6 

Based on Southwest’s new low-fare competition and the resulting traffic 

stimulation, Campbell-Hill projects that Southwest’s proposed HOU-DCA service will 

generate over $19 million annually in consumer fare savings (Exhibit WN-106). While 

this is a very large amount, Campbell-Hill’s projection is conservative in several 

respects. Among other things, (1) it assumes that United will only partially match 

Southwest’s fares, consistent with United’s practice in competing against Southwest in 

the BWI-Houston market, and (2) no consumer fare savings in connecting markets 

beyond Houston are included, although those markets will also experience fare 

reductions and savings in DCA service due to Southwest’s new low-fare competition. 

Details of the above-described traffic forecast and fare benefits calculations, 

including a full explanation of the methodology and assumptions used by Campbell-Hill, 

are set forth in Appendix 1 attached hereto. 

IV. Houston Hobby, the Close-in Houston Airport, Has No Nonstop DCA 

Service Today; Southwest’s Service Would Provide Inter-Airline and 

Inter-Airport Options and Competition for Consumers.

Southwest Airlines has served Houston for more than 41 years, and by next 

summer will operate 1,055 weekly departures to/from 42 nonstop cities. Southwest is 

continuing to grow at Houston and recently received approval to construct an 

international facility that will allow it to operate 20-25 daily Latin America/Caribbean 

flights starting in 2015. 5 The DCA-HOU route will integrate well with Southwest’s 

network, not only providing enormous benefits to consumers traveling nonstop between 

DCA and Houston, but also convenient one-stop or connecting opportunities between 

                                                           

5

 For information on the Houston Hobby international expansion see www.freehobbyairport.com.
7 

DCA and several other cities that lack nonstop DCA service today.6 The benefits of 

Southwest’s new service and competition will therefore be felt far beyond Houston, to 

other points in Texas as well as nearby states. 

 Houston has a vibrant and growing economy. It is the fifth largest metro area in 

the U.S. with 6.1 million residents. Of Houston’s two major airports, Hobby is more 

convenient to the city center than Houston Intercontinental, as HOU is only 12 miles 

from downtown compared to 22 miles for IAH. See Exhibit WN-107. Additionally, there 

are more people living within 30 minutes and 60 minutes of HOU than IAH (Exhibit WN108). Not surprisingly, most large Houston markets have nonstop service from both 

airports, and in those markets HOU passengers total 96% of IAH passengers (Exhibit 

WN-109). Clearly, the demand for service to HOU is as strong as it is to IAH. Yet DCA 

is one of only three top 20 Houston markets that does not have nonstop service from 

HOU.7 Southwest’s proposal would rectify this conspicuous absence of needed air 

service. In fact, Southwest’s Houston Hobby to DCA service will provide a critical link 

between the most convenient airport in Houston with the preferred Washington, DC 

airport, and it will offer consumers fares that are 38% below the prevailing average 

nonstop fare in the market today. 

                                                           

6

 Southwest’s DCA-HOU service will offer on-line connections to SAT, ABQ, ELP and OKC, among other 

points. None of these cities have nonstop access to DCA today. 7

 U.S. DOT O&D Survey and Schedule data, YE Q2 2012.
8 

CONCLUSION

 For the reasons stated above, Southwest urges the Department to award it the 

two slot exemptions at issue in this proceeding to enable it to initiate competitive lowfare service between Houston Hobby and DCA. 

 Respectfully submitted, 

 __________________________ 

 Robert W. Kneisley 

December 5, 2012
CERTIFICATE OF SERVICE

I hereby certify that on December 5, 2012, a copy of the foregoing was served 

via e-mail on the following persons: 

msinick@ssd.com (Alaska Airlines) 

francis.heil@aa.com (American Airlines) 

sascha.vanderbellen@delta.com (Delta Air Lines) 

robert.cohn@hoganlovells.com (Frontier Airlines & Republic Airline) 

patrick.rizzi@hoganlovells.com (Frontier Airlines & Republic Airline 

robert.land@jetblue.com (JetBlue Airways) 

jhill@dowlohnes.com (JetBlue Airways) 

dkirstein@yklaw.com (Spirit Airlines) 

jyoung@yklaw.com (Spirit Airlines) 

John.Fredericksen@suncountry.com (Sun Country Airlines) 

dan.weiss@united.com (United Air Lines) 

howard_kass@usairways.com (US Airways) 

Benjamin.slocum@usairways.com (US Airways) 

pmurphy@lopmurphy.com (USA3000) 

barbara.russell@virginamerica.com (Virgin America) 

jegillick@zsrlaw.com (Virgin America) 

susan.kurland@dot.gov

todd.homan@dot.gov

Mario C. Diaz 

Director of Aviation 

Houston Airport System 

16930 JFK Boulevard 

Houston, Texas 77032 

John Potter 

President and CEO 

Metropolitan Washington Airports Authority 

1 Aviation Circle 

Washington, DC 20001 

info@airlineinfo.com

 

 __________________________ 

 Leslie C. Abbott
Southwest Has Only 3.5% of DCA Slots

While US Airways Controls Over 54% of All DCA Slo

DCA Slots

472

400450500

Total Slots = 870

300350400200250

104 102

76

36 50 30

100150

20

8

36 30 18

0

50

US DL AA UA AC AS B6 WN F9 

Percent of Airport Total 54.3% 12.0% 11.7% 8.7% 2.3% 0.9% 4.1% 3.5% 2.1% 

Source: FAA Slot Reports, Current and Future, dated 10-25-2012 and Innovata Schedule data.

Legacy/Foreign Flag Carriers Low Cost 

Total Domestic O&D Passengers (Millions) 42.0 79.1 46.1 62.7 N/A 15.7 21.8 100.2 10.1 
United’s Monopoly DCA-Houston Fare 

Is 43% Above Normal DCA Fare Levels

YE Q2 2012 Fares for Nonstop Passengers/1 United DCA-IAH

$300$350 Average Fare

($334)

+43%

$150$200$250

$50

$100

$0

500 750 1000 1250 1500 1750 2000 2250 

Nonstop Miles

1/ Curve derived from all nonstop passengers in DCA nonstop markets with 50 or more fared passengers per day each way. 

Fares are derived from a yield curve with the following equation: Yield (cents) = 5,760.9 (miles) -.803, R2=0.81.

Note: Fared passengers only. Excludes all taxes and government charges. Includes estimated checked baggage and rebooking/change fees.

Source: U.S. DOT, O&D Survey and Schedule data, YE Q2 2012, via Diio, LLC.
DCA-Houston is One of the Most Overpriced DCA Nonsto

Top 10 DCA Nonstop Markets Ranked By 

Percentage Average Fare Above DCA Market Fare Curve

55%

60%

50%

45%

43%

39%

35%

40%50%

33%

31% 30%

30%10%20%

0%

CLE CVG PHX IAH LGA MEM HPN HSV SL

Current NSPax DCA Fare $277 $284 $374 $334 $230 $288 $225

$268 $32

1/ Fare derived from the yield curve function shown in footnote 1 of Exhibit WN-101.Source: US DOT O&D Survey YE Q2 2012, via Diio, LLC.

Pax DCA Fare $277 $284 $374 $334 $230 $288 $225

$268 $32

Nonstop FareCurve Fare1 $178 $189 $257 $233 $166 $213 $169 $204 $25
Southwest’s Projected DCA-HOU Fare Would

B $127 (38%) l Th U i d’ C DCA IAH F

$400

Average Fare 1

Be $127 (38%) less Than 

U

nited’s 

Current DCA

-IAH

Fa

$334

$300$350

$400

38%

$207

$200$250

-

- $127

$100$150

$0

$50

UA DCA-Houston Fare WN BWI-HOU Fare and 

Assumed WN DCA-HOU Fa

1/ Fared passengers only. Excludes all taxes and government charges. Includes estimated checked baggage and rebooking/change fees. 

2/ DCA-HOU fare projection based on WN BWI-HOU average nonstop fare. 

Source: US DOT O&D Survey YE Q2 2012; US DOT Form 41, via Diio, LLC.
United Charges Nearly $100 More Per One-Way Passen

When Sheltered From Southwest Com

petition at DC

$350

Average Fare 1

p

$334 

$250 $240$300$350

+$94

$207

$240

$200$250

+$33

$100$150

$0

$50

UA DCA-Houston UA BWI-Houston WN BWI-Houston UA 

N C titi C titi No 

1/ Fared passengers only. Excludes all taxes and government charges. Includes estimated checked baggage and rebooking/change fees.

Source: US DOT O&D Survey YE Q2 2012; US DOT Form 41, via Diio, LLC.

No 

Competition

from Southwest

Competition 

from Southwest

No 

fro
Southwest’s Proposal Will Generate Over 105,000 Additional D

Passengers; Southwest Will Carry Over 80,000 Passen

Fared Onboard 

Carried by So

Passengers; Southwest Will Carry Over 80,000 Passen

DCA-Houston Fared Passengers

Stimulated With Southwest Service1

90,000

100,000110,000

81,31

105,382

90 000

100,000110,000

24,45

60,00070,00080,000

,

60,00070,00080,00090,000

30,000 40,00050,000

30,00040,00050,000

,

0

10,00020,000

DCA HOU Local

0

10,00020,000

Note: Represents first normalized year.1/ Includes stimulation created by WN low cost service. Includes passengers that will be carried on WN and other airlines that lower their far

2/ Includes fared onboard passengers only. Including estimated zero-fared passengers would total 88,392 onboard passengers (86% load f

3/ Beyond Houston passengers estimated based on Southwest’s EWR-HOU experience.

DCA-HOU Local

DCA-Connecting 
Southwest’s DCA-HOU Service Will Generate More Than $1

Annually in Consumer Fare Savings to Local PassengAnnually in Consumer Fare Savings to Local Passeng

(First Normalized Year)

DCA-HOU

Consumer Fare 

S i (Milli )

$16$18$20

$16.1

Million

Savings (Millions) $19.1

Million

$10$12$14

$4$6$8

$3.0

Million

$0$2

Savings to Existing

Passengers

Savings to New

Passengers

Total Passenger

Savings

Source: Appendix 1. Excludes savings to passengers connecting at HOU.
HOU is Ten Miles Closer 

To/From Downtown Houston Than IAH

Distance

(miles)

HOU – Downtown 12

Source: Google Maps.

HOU Downtown 12IAH – Downtown 22
Houston Hobby is the Most Convenient Airport for Houston R

30 Min. Drive 

f IAH

1 Hour Drive

rom 

1 Hour Drive

30 Min. Drive 

from HOU

IAH

1 Hour Drive

from IAH

1 Hour Drive

from HOU

HOU

30 1

Mins. Hour

Houston Hobb

y (HOU) 1.84 5.24

Population (Millions) Within

Note: 1 dot = 100 residents.Source: Census 2010 estimates and TargetPro for drive times.

y ( )

Houston Intercon. (IAH) 1.37 5.18
In Domestic Houston Markets With Nonstop Service Fr

Both HOU and IAH HOU Has 96% as Many Local PassengerBoth HOU and IAH, HOU Has 96% as Many Local Passenger

Annual Fared O&D

Passengers in Markets

with Nonsto

p Service

from Both IAH and HOU

(Millions)

5.1 5.3

5.05.5 96%3.54.04.52.02.53.00.51.01.50.0

HOU IAH

Source: US DOT O&D Survey YE Q2 2012.
Summary of Consumer Surplus Benefits From

Southwest’s Proposed DCA – HOU Nonstop Service

(A) (B) (C) (D) (E) (F) (G) (H) (I) (J) (K) (L) (M) 

Passengers Predicted Projected WN Fare Passengers After New 

O&D Market Miles Before Stimulation Service Stimulation Base Fare Fees Total Fare Absolute % Stimulation Stimulation Passengers Existing Pass

Fare Stimulation

Average Fare Before WN Fare Change 

MarketDCA-HOU/IAH 1218 5.7% $276.29 $15.56 $291.84 $235.00 -$56.84 -19% 29.7% 389,486 284,104 105,382 $16

(A) Nonstop Miles(B) DCA fared passengers for YE Q2 2012 DCA fared passengers for YE Q2 2012(C) Predicted Service stimulation from Campbell-Hill Aviation Group, QSI model.(D) Average Fare for Fared Passengers (excludes passengers using frequent flier miles). Includes nonstop and connecting passen

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

(E) Average checked baggage and rebooking/cancellation fees per passenger derived by Campbell-Hill Aviation Group using DOT 

Q1 2012). YE Q1 2012 Fee data was used because WN discontinued reporting FL separately in Q2 2012 Form 41 data. 

(F) Column D + Column E(G) DCA-HOU fare calculated at the weighted average of Southwest’s BWI-HOU fare and United’s BWI-HOU fare

(14.6% WN share at $207 and 85.4% share other airlines at $240). Both fares include checked baggage and reboo

(H) Column G – Column F(I) Column H / Column F

(J) Calculated using a price elasticity coefficient of -1.2. -1.2 is a standard price elasticity coefficient. See FAA Airport Benefit-Cos

Office of Aviation Policy and Planning, Federal Aviation Administration, December 15, 1999.The arc elasticity formula is: Arc Ep = [(Q2-Q1)/((Q1+Q2)/2)] / [(P2-P1)/((P1+P2)/2)] , where Q1 = passengers before WN s

Q2 = Passengers after WN service, P1=Fare Before WN service, P2 = Fare After WN service.

(K) Column B x (1+ Column C) x (1+ Column J)(L) Column K – Column B

(M) Column H x -1 x Column B(N) Column H x Column L x 0.5 x -1. This follows the consumer surplus method outlined by the FAA in “FAA Airport Benefit-Cost A

of Aviation Policy and Planning, Federal Aviation Administration, December 15, 1999.

(O) Column M + Column N
 CITY OF HOUSTON 

 Office of the Mayor

Annise D. Parker 

Mayor 

P.O. Box 1562 

Houston, Texas 77251-1562 

Telephone – Dial 311 

www.houstontx.gov 

December 4, 2012 

The Honorable Raymond H. LaHood 

Secretary of Transportation 

U.S. Department of Transportation 

1200 New Jersey Avenue, S.E. 

Washington, DC 20590 

Re: Docket DOT-OST-2000-7182 

Dear Secretary LaHood: 

I understand that the U.S. Department of Transportation (DOT) will be awarding slots at Washington Reagan 

(DCA) for new air service as a result of Spirit Airlines cancelling all its operations at DCA. On behalf of the 

City of Houston, I write to express my strong support that DOT award slots for any new nonstop service that is 

proposed to the William P. Hobby Airport (HOU) in Houston. 

HOU is one of the largest airports located within DCA’s 1,250-mile perimeter that does not have existing 

nonstop flights to/from DCA. HOU offers Houstonians the convenience of being located only eight miles 

from downtown Houston, as well as having a strong airline tenant (Southwest) that provides 143 daily 

departures to 38 cities. This makes HOU a major part of Houston’s air transportation network and a critical 

economic engine, providing thousands of jobs and billions of dollars in economic benefits for Greater 

Houston. Southwest Airlines has advised me that it will apply for daily, nonstop service on this route. 

As Mayor of the fourth largest city in the United States, I have made it a priority to increase airline competition 

for the benefit of Houston-based consumers. Today, only one airline serves the DCA-Houston market and that 

airline operates from George Bush Intercontinental Airport. History has shown that competition in air service 

brings down fares and provides consumers with additional travel options. 

As one of the most vibrant and fastest growing cities in the United States, and as the energy capital of the 

world, Houston is deserving of competitive air transportation to the Nation’s Capital. Southwest’s business 

model is well-matched to Houston’s needs and its proposed additional access to DCA would well serve the 

public interest. 

For these reasons, I respectfully request DOT to approve Southwest’s application for daily nonstop service 

between DCA and HOU. Thank you for your attention to this important matter. 

Regards, 

Annise D. Parker 

Mayor

Council Members: Helena Brown Jerry Davis Ellen R. Cohen Wanda Adams Mike Sullivan Al Hoang Oliver Pennington Edward Gonzalez 

James G. Rodriguez Mike Laster Larry V. Green Stephen C. Costello Andrew C. Burks, Jr. Melissa Noriega C.O. “Brad” Bradford 

Jack Christie Controller: Ronald C. Green