BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Applications of 

FRONTIER AIRLINES, INC. 

AIR CANADA 

ALASKA AIRLINES, INC. 

JETBLUE AIRWAYS CORPORATION 

SUN COUNTRY AIRLINES 

SOUTHWEST AIRLINES CO. 

VIRGIN AMERICA INC. 

For "beyond-perimeter" slot exemptions at 

Ronald Reagan Washington National Airport 

) 

) 

) 

) 

) Docket DOT-OST-2012-0029 

) 

) 

) 

) 

) 

) 

) ___________________________ ) 

CONSOLIDATED ANSWER OF FRONTIER AIRLINES, INC. 

Communications with respect to this document should be addressed to: 

Daniel Shurz 

Senior Vice President, Commercial 

FRONTIER AIRLINES, INC. 

Frontier Center One 

7001 Tower Road 

Denver, CO 80249 

March 27, 2012 

\\DC· 036787/000001 • 3381787 v3 

Robert E. Cohn 

Patrick R. Rizzi 

HOGAN LOVELLS US LLP 

Columbia Square 

555 Thirteenth Street, NW 

Washington, DC 20004 

+1 202 637 4999/5659 

robert.cohn@hoganlovells.com 

patrick.rizzi@hoganlovells.com 

Counsel for 

FRONTIER AIRLINES, INC. 
Frontier's Consolidated Answer 

TABLE OF CONTENTS 

I. NO CARRIER SHOULD RECEIVE MORE THAN 

TWO BEYOND PERIMETER SLOT EXEMPTIONS. 4 

II. ONLY DESTINATIONS WITHOUT EXISTING NONSTOP 

DCA SERVICE SHOULD RECEIVE AN AWARD OF SLOT EXEMPTIONS. 7 

Ill. FRONTIER'S DCA-COLORADO SPRINGS-SAN DIEGO SERVICE 

PROPOSAL SURPASSES ALL OF THE OTHERS IN TERMS OF 

THE PUBLIC INTEREST, THE STATUTORY CRITERIA, AND 

ENHANCED COMPETITION. 7 

A. SOUTHWEST AIRLINES. 9 

B. JETBLUE AIRWAYS. 19 

C. ALASKA AIRLINES. 26 

D. VIRGIN AMERICA. 30 

E. AIR CANADA. 34 

F. SUN COUNTRY. 37 

IV. FRONTIER'S PROPOSAL HAS RECEIVED SIGNIFICANT 

PUBLIC SUPPORT. 39 

v. CONCLUSION. 39 

\\DC. 036787/000001-3385670 vi 
BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

Applications of 

FRONTIER AIRLINES, INC. 

AIR CANADA 

ALASKA AIRLINES, INC. 

JETBLUE AIRWAYS CORPORATION 

SUN COUNTRY AIRLINES 

SOUTHWEST AIRLINES CO. 

VIRGIN AMERICA INC. 

For "beyond-perimeter" slot exemptions at 

Ronald Reagan Washington National Airport 

) 

) 

) 

) 

) Docket DOT-OST-2012-0029 

) 

) 

) 

) March 27, 2012 

) 

) 

) ____________________________ ) 

CONSOLIDATED ANSWER OF FRONTIER AIRLINES, INC. 

There are only eight beyond-perimeter slot exemptions available for allocation by 

the Department in this proceeding. However, seven carriers have applied for a total of 

twenty slot exemptions to fly nonstop to eight destinations, including Frontier Airlines, 

Inc. ("Frontier"). Frontier applied for one pair of slot exemptions to provide first-time 

nonstop service between Ronald Reagan Washington National Airport ("Washington 

National" or "DCA") and Colorado Springs ("COS"), Colorado, with continuing singleplane service to and from San Diego ("SAN"), California. 1 Frontier files this answer in 

opposition to the applications of the other applicants. 

First, Frontier urges the Department not to grant any carrier more than two slot 

exemptions (one pair). 

Frontier Airlines for Colorado Springs (2); Air Canada for Vancouver (2); Alaska Airlines for Portland (2) and 

San Diego (2); JetBiue Airways for San Juan (2) and Austin (2); Sun Country for Las Vegas (2); Southwest 

Airlines for Austin (2); and Virgin America for San Francisco (4). 

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Consolidated Answer of Frontier Airlines, Inc. 

Page 2 

Second, the Department should limit the awards of these scarce slot exemptions 

for service to cities that will receive first-time nonstop DCA service. 

Third, Frontier's first-time nonstop service between DCA and Colorado Springscoupled with single-plane through-service to San Diego - and first-time low-fare 

nonstop competition to United Express' monopoly Dulles-Colorado Springs service is 

superior to the applications of the other carriers. It is Frontier's highest priority and 

should be given the highest priority for an award by the Department. Frontier's DCACOS service would provide unparalleled public interest benefits and maximum 

competitive impact, including low fares, in the local and beyond markets. 

Fourth, Frontier's Colorado Springs proposal should be at the top of the list for 

an award of two beyond-perimeter slot exemptions for the following reasons: 

2 

• Colorado Springs is the State of Colorado's second largest city. 

• Colorado Springs is home to many vitally important military, national 

security, and commercial facilities with critical links to the Nation's Capital. 

• The State of Colorado, the Colorado Congressional delegation, the City of 

Colorado Springs, the Colorado Springs Airport, and military and business 

leaders at Colorado Springs have filed submissions in the Docket strongly 

supporting Frontier's application. 

• Frontier's service would provide first-time low-fare nonstop service 

between Colorado Springs and DCA and first-time low-fare competition to 

the single daily regional jet monopoly high-fare service by United at Dulles 

I nt'l. 

• Colorado Springs is the only beyond-perimeter U.S. destination without 

any mainline aircraft nonstop service to the Washington, D.C. 

metropolitan region ("WAS"2). 

WAS= DCA, lAD, and BWI. 

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Consolidated Answer of Frontier Airlines, Inc. 

Page 3 

• Frontier's service would provide the only low-cost, low-fare service to 

Colorado Springs from the entire Washington, D.C. metropolitan area, 

where currently 92% of connecting passengers use high-cost, high-fare 

legacy carriers. Frontier's service would offer savings of 27% on the 

current average DCA-COS fares. 

• Frontier's low fares would provide substantial savings to military, 

government, business and leisure travelers between DCA and Colorado 

Springs. 

• Frontier is a renowned low-cost, low-fare competitor with a demonstrated 

track record of reducing fares and stimulating traffic when it operates 

nonstop service from DCA to points beyond the perimeter. 

• Frontier's 168-seat A-320 aircraft would provide more annual seats, 

between 7% and 68% more, than the other applicants. 3 

• Frontier's service would produce substantial domestic network benefits in 

multiple markets representing 1.14 million annual DCA passengers, 

including: 

o DCA-San Diego, which would receive 

• one-stop, single-plane service in competition with (i) US 

Airway's high-fare nonstop DCA service (ii) United's highfare nonstop Dulles service, and (iii) Southwest's higher-fare 

nonstop BWI service, and 

• substantial time savings of about 45 minutes roundtrip over 

current connections, with de minimis circuity; 

o DCA-Phoenix, Los Angeles, Seattle, and Portland, which would 

receive an additional low-fare service option by a competitively 

aggressive limited-incumbent low~cost carrier4

; and 

o Denver, where Frontier has an extensive hub with additional on-line 

connections. 

3 Southwest proposes to begin service with smaller 137-seat 8737-700 aircraft which may be converted to 

175-seat 8737-800 aircraft at the end of the year. Frontier's 168-seat A320 would offer 23% more capacity than 

Southwest's 137-seat aircraft. 

4 As the Department said in DOT Order 2004-4-1, at 17 "[w]hile there is overlap between the connecting 

markets that Alaska could serve over Seattle and Los Angeles, passengers would benefit from an alternative 

competitive nonstop choice to DCA on Alaska." So too here, Frontier's beyond-COS connections would receive an 

important, alternative, low-fare one-stop service option from DCA. 

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Consolidated Answer of Frontier Airlines, Inc. 

Page4 

• Frontier's service would expand its growing, competitive presence at its 

newly established Colorado Springs focus city, where it is the only lowcost, low-fare carrier with daily service. Every other U.S. destination 

proposed in this proceeding has daily service from two or more nonlegacy or low-fare carriers. 

• Frontier is a small limited incumbent LCC but has an outsized beneficial 

impact on consumers by virtue of its commitment to low fares. Frontier is 

a substantially smaller carrier at Washington National and in the 

Washington, D.C. metropolitan area than JetBiue or Southwest. 

• Frontier is the only carrier-applicant, other than Alaska Airlines and Virgin 

America, without a within-perimeter hub with which to flow traffic to the 

West. The Department has determined that the competitive benefit of 

granting beyond-perimeter slot exemptions to carriers, like Frontier, that 

do not have within-perimeter hubs to offer connecting opportunities to 

beyond-perimeter points would "still be higher than it would be if we 

granted frequencies to carriers that in many cases already offer DCA 

travelers numerous connecting opportunities to the destinations beyond 

their proposed points via their within-perimeter hubs." DOT Order 2004-7-

1, at 18-19. 

• Frontier's service proposal has garnered overwhelming public support 

from governmental leaders, military leaders, Congress, travelers, and 

businesses. 

And, as discussed in detail below, the other carriers' service proposals would 

provide fewer public interest, competition, and domestic network benefits than Frontier's 

DCA-Colorado Springs-San Diego service. 

I. NO CARRIER SHOULD RECEIVE MORE THAN TWO BEYOND PERIMETER 

SLOT EXEMPTIONS. 

Recognizing that there are only a limited number of slot exemptions available in 

this proceeding, enough to fund only four roundtrip flights, Frontier has submitted a 

narrowly-tailored proposal for only a single pair of slot exemptions to enable it to 

provide one daily nonstop roundtrip to a destination in the West that receives no direct 

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Consolidated Answer of Frontier Airlines, Inc. 

Page 5 

service to DCA. Other carriers (Alaska, JetBiue, Virgin America) were not so tempered 

in their requests, and submitted exorbitant requests for four slot exemptions, or fully 

50% of the available slot pool. While Frontier too would like to significantly increase the 

number of its beyond-perimeter flights, Frontier carefully moderated its proposal to seek 

only two slot exemptions because service to Colorado Springs-Frontier's newly 

established Western focus city-is its highest route case priority. 

The public interest would be best served if the Department maximized the 

number of carriers receiving slot exemptions. The Department has the unique 

opportunity to grant slot exemptions to four airlines. Frontier should be one of the four 

receiving an award. Given the limited number of slots available and number of carriers 

requesting these scarce and valuable opportunities, and consistent with Department 

precedent (DOT Order 2000-7-1), no single carrier should be awarded more than one 

pair of beyond-perimeter slot exemptions (i.e., one roundtrip). 

It would be particularly inappropriate to award half of the available slot 

exemptions to JetBiue, Alaska or Virgin America. JetBiue has now become the largest 

limited incumbent operator and holder of slots at Washington National. Alaska is not a 

low-cost, low-fare competitor; its low-fare claim is nothing more than a route case ploy. 

It would not be in the public interest and would not maximize the competitive benefits to 

award 50% of the slot exemptions to any of them to the exclusion of Frontier. 

Although Virgin America would be a new entrant at DCA, that fact does not 

justify giving it half the available slot exemptions. Indeed, when Frontier sought to gain 

its first entry into DCA in 2000 and requested four of the 12 available slot exemptions 

\\DC- 036787/000001 - 3381787 vJ 
Consolidated Answer of Frontier Airlines, Inc. 

Page 6 

for service to its hub at Denver (which then had no nonstop DCA service), the 

Department awarded Frontier only two slot exemptions. See DOT Order 2000-7-1, at 

22 ("Given the limited number of slot exemptions available and the strengths of some 

other applicants, we have limited the award to two slots rather than the four the carrier 

requested."). And, when National Airlines sought to gain its first service to Washington 

National and requested six slot exemptions (or 50% of the 12 available) for service to its 

hub at Las Vegas, the Department likewise rejected that full request and awarded 

National only two slot exemptions. See DOT Order 2000-7-1, at 22 ("as with Frontier, 

given the strength of other applications, we have also limited the award to two slots, 

rather than the six it requested."). It was not until four years later in 2004 that Frontier 

was able to obtain another beyond-perimeter roundtrip. Especially since there are only 

eight slot exemptions available in this proceeding, there is simply no basis for treating 

Virgin America any differently here, particularly when it seeks to serve a destination 

(San Francisco) that is slated to receive nonstop service to Washington National and 

has numerous nonstop flights to the Washington, D.C. region, particulalry when there 

are other more meritorious service proposals like Frontier's proposing service to a city 

that has no nonstop DCA service. 

As discussed below, among the contenders for first nonstop DCA service, 

Frontier's Colorado Springs proposal should be at the top of the list for an award of two 

slot exemptions. 

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Consolidated Answer of Frontier Airlines, Inc. 

Page 7 

II. ONLY DESTINATIONS WITHOUT EXISTING NONSTOP DCA SERVICE 

SHOULD RECEIVE AN AWARD OF SLOT EXEMPTIONS. 

The Department should use these rare beyond-perimeter exemptions so that 

U.S. communities without nonstop DCA access- like Colorado Springs- gain first-time 

nonstop access to DCA. To be sure, competitive service on a DCA route that receives 

nonstop service in certain circumstances can sometimes provide significant public 

interest and competition benefits, particularly routes that have few or no viable 

alternative routings. But here - with so many communities vying for first-time ever 

nonstop access to slot- and perimeter-constrained Washington National - providing 

first-time nonstop service to DCA should be the Department's highest priority, not 

overlapping nonstop service on routes already fortunate enough to already receive 

nonstop DCA service. Las Vegas, San Francisco, and San Diego already receive or 

will soon receive nonstop DCA service. Las Vegas already receives ample nonstop 

service. United and US Airways recently announced their plans to use two beyondperimeter slot exemptions each for DCA nonstop service to San Francisco and San 

Diego, respectively, under 49 U.S.C. § 41718(g)(3). 

Ill. FRONTIER'S DCA-COLORADO SPRINGS-SAN DIEGO SERVICE PROPOSAL 

SURPASSES ALL OF THE OTHERS IN TERMS OF THE PUBLIC INTEREST, 

THE STATUTORY CRITERIA, AND ENHANCED COMPETITION. 

As noted above, seven carriers (including Frontier) have applied for "beyondperimeter" slot exemptions to fly nonstop to eight destinations in the western United 

States. When the Department scrutinizes those applications against Frontier's in light 

of the statutory criteria, public interest, and competitive benefits, it becomes crystal 

\\DC· 036787{000001 - 3381787 v3 
Consolidated Answer of Frontier Airlines, Inc. 

Page 8 

clear that Frontier's DCA-Colorado Springs-San Diego service should be the first priority 

for an award of two of the available slot exemptions. 

Frontier is a small, limited incumbent which produces an outsized impact on 

consumer benefits by virtue of its commitment to low fares. Frontier's DCA-COS 

service would provide the only low-cost, low-fare service to Colorado Springs from the 

entire Washington, D.C. metropolitan area, where currently 92% of connecting 

passengers use high-cost, high-fare legacy carriers. Frontier is the only low-cost, lowfare airline serving Colorado Springs with daily service, and this first-ever nonstop 

service from Washington National would help strengthen Frontier's presence at DCA. 

Frontier's DCA-COS-SAN service would generate over $12 million in direct annual 

consumer savings. Moreover, Frontier has proven its commitment to low fares at DCA. 

After Frontier's entry in the DCA-DEN market with only a single daily roundtrip flight, 

average fares between DCA and Denver decreased by 13% and traffic on the route 

increased by 37%. F9 Appl., Exhibit F9-11. And, average fares between Denver and 

Dulles lnt'l and between Denver and the entire Washington, D.C. area decreased by 

31% and 35%, respectively. F9 Appl., Exhibits F9-12. 13, and 14. 

Others might argue that because Frontier has six beyond-perimeter slot 

exemptions, it should get no more. Any such argument would be completely without 

merit and inconsistent with Department policy and precedent. The Department 

awarded America West two slot exemptions in 2004 after it had previously received six 

slot exemptions in 2000. The Department explained: 

\\DC· 036787/000001-3381787 vl 
Consolidated Answer of Frontier Airlines, Inc. 

"The Department recognizes the fact that America West holds and 

operates six slot exemptions from the 2000 proceeding, but we 

believe that the statutory criteria require us to consider incumbency 

in a broader context. Even with its new allocations, America West 

remains a limited incumbent, but it is one that can serve multiple 

markets competitively. Although it has six beyond-perimeter slot 

exemptions, the Department believes that the competitive benefit of 

granting an additional frequency to America West is still higher than 

it would be if we granted frequencies to carriers that in many cases 

already offer DCA travelers numerous connecting opportunities to 

the destinations beyond their proposed points via their withinperimeter hubs." DOT Order 2004-7-1, at 18-19. 

Page 9 

So too with Frontier here. Even with an award of just two slot exemptions in this 

proceeding, Frontier would still be a small limited incumbent carrier; much smaller than 

other carriers like JetBiue and Southwest. And, Frontier has no within-perimeter hubs 

over which to connect beyond-perimeter service as other carrier-applicants like JetBiue 

and Southwest do. Moreover, Frontier's DCA-COS service would provide unparalleled 

public interest, competition, and domestic network benefits, as the Department has 

previously recognized: "Frontier is a new entrant/limited incumbent with a record as a 

low-fare competitor . . . . Frontier has a proven track record of providing domestic 

network benefits in DCA origin and destination markets .... " DOT Order 2004-4-1, at 

19. 

Frontier discusses how its proposal surpasses each of the other carrier's service 

proposals below. 

A. SOUTHWEST AIRLINES. 

Southwest has applied for two beyond-perimeter slot exemptions for nonstop 

service to Austin, Texas ("AUS"), a destination that by this summer it will serve with 

\\DC. 036787/000001 • 3381787 vl 
Consolidated Answer of Frontier Airlines, Inc. 

Page 10 

three daily nonstop flights from its hub at BWI. Its Austin service from DCA would not 

offer nearly as many public interest, competition, and network benefits as Frontier's 

Colorado Springs service would. 

1. Southwest emphasizes that it is the "nation's largest domestic airline in 

terms of passenger traffic carried," surpassing even mega-legacy carriers United Air 

Lines and Delta Air Lines. WN Appl. at 8. But that fact - coupled with its large 

presence in the Washington, D.C. metropolitan area and its other within-perimeter hubs 

- is one of the principal reasons why Southwest should not receive an award of two slot 

exemptions in this proceeding before Frontier does. 

Southwest conveniently ignores the tremendous disparity between Southwest's 

presence in the Washington, D.C. metropolitan area and Frontier's. Even using 

Southwest's own data, Southwest has 25 slots/slot exemptions at DCA - 25% more 

than Frontier uses and 316% more than Frontier holds in its own name. Exhibit WN115.5 By its own data, Southwest is the second largest, limited incumbent holder and 

operator of slots at DCA (behind JetBiue). Exhibii WN-115. Nor should the 

Department give credence to Southwest's efforts to obfuscate these clear data by 

ginning up an exhibit purporting to show "DCA slots per 100,000 domestic O&D 

passengers" systemwide. Exhibit WN-118. That exhibit is a non-sequitor and the 

benchmark is meaningless, particularly given the much larger number of passengers in 

Southwest's entire domestic system. 

5 Frontier holds outright only six beyond-perimeter exemptions for service to its hub at Denver, and its only 

other access to Washington National is with a handful of slots and slot exemptions held and operated by Republic 

Airlines to provide within-perimeter service under the Frontier brand. 

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Consolidated Answer of Frontier Airlines, Inc. 

Page 11 

More broadly, Frontier has only nine daily departures from the Washington, D.C. 

area. By contrast, Southwest!AirTran has 266 daily departures from the Washington, 

D.C. area: 12 daily nonstop departures from Washington National, 8 from Dulles lnt'l, 

and 246 daily nonstop departures to 63 destinations including Austin, Texas, from its 

substantial hub at BWI.6 Simply put, Southwest is at least 33% larger than Frontier at 

Washington National and a whopping 2,856% larger in the Washington, D.C. 

metropolitan area. Exhibit F9-A-1. Against this background, it is ludicrous for 

Southwest to claim (as it does) that it is woefully under-represented at DCA and in the 

Washington, D.C. metropolitan area, particularly when compared to Frontier's 

presence. WN Appl. at 8-9 & Exhibits WN-115 - 118. 

Furthermore, while Frontier has been painstakingly and patiently developing its 

much smaller presence for more than 12 years, until recently, Southwest had shown no 

real interest in DCA. In the twelve years since AIR-21 originally created the slot 

exemptions in 2000, there have been ten within-perimeter slot exemption allocation 

proceedings (plus the one currently pending), and Southwest did not even bother to 

apply in the first nine. Likewise, there have been five beyond-perimeter slot exemption 

proceedings, and Southwest did not participate in any of them. 

Southwest's claims of under-representation simply ring hollow when viewed 

through the prism of reality. Compared to Frontier, Southwest is over-represented at 

DCA and in the Washington, D.C. region. It should not be awarded more slot 

exemptions at the expense of Frontier, a much smaller low-fare competitor, which 

6 lAD information is from www.southwest.com, "City Fact Sheets," dated February 12, 2012; BWI information 

from published data, peak-day Friday schedule for June 2012. 

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Consolidated Answer of Frontier Airlines, Inc. 

Page 12 

barely has but a toehold at DCA and in the Washington, D.C. metropolitan area. Given 

Frontier's longstanding efforts to develop a larger competitive presence at Washington 

National and the relatively few remaining smaller LCCs, as a matter of competitive 

policy the Department should favor an award of slot exemptions to Frontier to bolster its 

ability to compete more effectively against the legacy carriers, including Southwest, as 

a means to maximize low-fare consumer benefits. 

2. Austin has significantly better service to Washington, D.C. than Colorado 

Springs. The summer 2012 schedules show that Austin will receive five daily nonstop 

flights on two competing carriers from the Washington, D.C. metropolitan area: 

Southwest schedules three daily mainline aircraft flights from BWI and United Air Lines 

schedules two daily flights from Dulles lnt'l (one mainline and one United Express). 

Exhibit F9-A-2. That amounts to 365,632 annual nonstop seats from WAS to Austin. 

Exhibit F9-A-3. By contrast, Colorado Springs has no nonstop mainline flights from the 

Washington, D.C. metropolitan area, just a single daily monopoly small regional jet 

service on United Express from Dulles lnt'l. A market of Colorado Springs' size with its 

extensive communities of interest with the Nation's Capital certainly should receive its 

first mainline nonstop service from Washington, D.C. before Austin gets its sixth. 

3. An award of two slot exemptions to Southwest would not inject a new 

competitor in the WAS-Austin market because Southwest already provides twice daily 

nonstop service to Austin from WAS and will start a third daily this summer. As a result, 

Southwest would effectively be competing against itself, and it would experience selfdiversion if it introduced nonstop DCA-AUS service (a fact that Southwest's traffic 

"forecast" conveniently overlooks). Frontier, on the other hand, would be a new and 

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Consolidated Answer of Frontier Airlines, Inc. 

Page 13 

low-fare competitor in the WAS-Colorado Springs market, competing directly with the 

single daily regional jet legacy carrier flight from Dulles lnt'l and enabling a carrier with a 

small presence in the D.C. area to expand incrementally. 

4. Colorado Springs also places a higher relative priority on service to the 

Nation's Capital than Austin does. The Washington, D.C. metropolitan area is by far 

Colorado Springs' largest destination but only Austin's sixth largest destination? 

5. Air fares between Washington, D.C. and Austin are not as expensive as 

air fares between Washington, D.C. and Colorado Springs. For example, the average 

net fare for WAS-COS was $241, more than 15.3% higher than the average net fare 

for WAS-AUS of $209.8 Frontier will provide the air fare relief that Colorado Springs 

needs more than Austin, just as Frontier did when it entered the nonstop DCA-Denver 

market. 

6. The Department should also give no decisional weight to Southwest's 

fictitious claimed average fare of $169 for its DCA-AUS service because it lacks any 

reasonable or experiential basis. Exhibit WN-200 at 3-4. This claimed average fare is 

belied by Southwest's own fares in the WAS-Austin market. Southwest's current 

average fare between BWI and Austin is $214 (net) and $251 (total), 26.7% higher on a 

net basis and 49% higher on a total basis than the illusory average fare that Southwest 

claims in its application. Exhibit F9-A-4. Even Southwest concedes this large 

difference between its current BWI-AUS fare and its "proposed" fare for DCA-AUS. 

Exhibit WN-200 at 3 & n.4. As proof that Frontier delivers on its low-fare promise 

7 

8 

Diio US DOT O&D Data for YE 3011. 

Diio US DOT O&D Data for YE 3011. 

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Consolidated Answer of Frontier Airlines, Inc. 

Page 14 

whereas Southwest does not, the current Frontier total average fare in the DEN-DCA 

market is $233, 7% lower than Southwest's AUS-BWI total average fare of $251. 

Further, the DEN-DCA route is 132 miles longer than AUS-BWI, so Frontier's milesadjusted DEN-DCA fare is 18% lower than Southwest's miles-adjusted AUS-BWI fare. 

In addition, as US Airways demonstrated in the pending within-perimeter 

proceeding (US Answer, at 14-15 (dated March 20, 2012, Docket DOT-OST-2000-

7182)), on the four new nonstop routes Southwest launched between January 2009 

and April 2010 where Southwest was the only carrier providing nonstop service with a 

single daily roundtrip, fares actually increased by between 0.2% and 1 0.0%. (HartfordDenver: 4.2%; Chicago-Ontario, CA: 10.0%; Little Rock-Phoenix: 1.2%; BirminghamPhoenix: 0.2%).9 That is a far different story than Southwest's projected reduction in 

fares by more than 21%. 

Southwest's claims about stimulating the market by more than 109% are 

similarly unrealistic. For example, on the four routes identified above, the route 

stimulation ranged from - 6% to 49.1 %, with an average of only 15.9%. That average 

is only one-seventh of Southwest's projected stimulation in this case and is over two 

times greater than the most stimulated of these markets. 

Indeed, if the Department gives any consideration to Southwest's estimated 

average fare, and its claimed "consumer savings", then it must likewise consider 

Frontier's. Frontier's nonstop DCA-Colorado Springs-San Diego service will produce 

direct annual consumer savings of $12.4 million. Frontier prepared its own forecast of 

9 Diio weekly schedule data and U.S. DOT O&D SuNey. 

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Consolidated Answer of Frontier Airlines, Inc. 

Page 15 

traffic and annual consumer savings resulting from its low-fare DCA-COS-SAN service. 

Frontier estimates its average blended net fare on the routes at $133, a savings of 

nearly 32% on the current blended O&D average net fare of $196. F9 Appl., Exhibit F9-

4. Frontier further estimates that its entry as a low-fare competitor on this route will also 

stimulate demand substantially, as was the case when it began nonstop DCA-Denver 

service. Given those realistic and conservative inputs, Frontier forecasts direct annual 

consumer savings as a result of its nonstop DCA-Colorado Springs service of $12.4 

million. F9 Appl., Exhibit F9-4. Although Southwest claims benefits of $23.1 million 

annually, Exhibit WN-200, that claim is highly exaggerated. Much of Southwest's 

estimated savings are based on an unrealistic average net fare of $169, a 109% 

stimulation factor that is not justified, and alleged consumer savings in beyond-AUS 

services which - as Frontier demonstrated above- will, in reality, have only de minimis 

impacts given the level of current nonstop service in each of those markets from both 

DCA and the broader WAS area. With proper adjustments, Southwest's annual direct 

savings would be no more than Frontier's. 

7. Frontier would also provide more capacity than Southwest. Frontier would 

commence service using its largest aircraft, the 168-seat A-320. Southwest states that 

it will begin service with 137-seat 8737-700 aircraft (although it claims that it will switch 

to a 8737-800 aircraft at the end of the year). Frontier's A-320 aircraft will offer 23% 

more annual nonstop capacity than Southwest's 8737-700 aircraft. Exhibit F9-A-5. 

And, Frontier's A-320 mainline aircraft has more passenger amenities than 

Southwest's, with personal TVs at each seat and substantial STRETCH seating. 

Southwest offers none of these amenities on its 8-737-700 and 8-737-800 aircraft. 

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Consolidated Answer of Frontier Airlines, Inc. 

Page 16 

This is yet another distinct consumer benefit of Frontier's proposed service over 

Southwest's, particularly given the stage length of these beyond-perimeter flights and 

the ongoing single-plane service to San Diego. 

8. Frontier's single-plane, one-stop service to San Diego also offers more 

benefits to travelers than Southwest's single-plane through-service to San Diego. First, 

although Southwest claims that its one-stop San Diego service would be "the quickest 

[one-stop] flight option available between SAN and DCA," WN Appl. at 9, Frontier's 

would in fact be even faster, saving travelers over 30 minutes roundtrip. Compare WN 

Appl. at 3 with F9 Appl., Exhibit F9-2. Second, Frontier's DCA-COS-SAN route is 

notably less circuitous than Southwest's proposed DCA-AUS-SAN route, 1.2% versus 

8.9%. Exhibit F9-A-6. 

9. Frontier's beyond-COS connections to Phoenix, Los Angeles, Portland, 

Seattle, and Denver would also provide greater benefits than Southwest's beyond-AUS 

connections to Dallas and Houston. WN Appl. at 4. As an initial matter, Southwest's 

two connections should not even be considered insofar as they are both withinperimeter destinations. These back-hauls to points within the perimeter are not 

consistent with the statutory criteria, which evaluates whether the proposed air 

transportation provides "domestic network benefits beyond the 1,250 mile perimeter." 

2012 FAA Act, Section 414(a)(2)(emphasis added). In any event, Frontier's beyondCOS connecting destinations (excluding San Diego) have about 1.02 million annual 

DCA O&D passengers, as compared to the much smaller traffic pool for Dallas and 

Houston of 783,268 annual DCA passengers. Exhibit F9-A-7. Moreover, while 

Portland has no nonstop service to Washington National and the other beyond-COS 

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Consolidated Answer of Frontier Airlines, Inc. 

Page 17 

cities have between two and four daily nonstop each, Dallas and Houston have far 

more nonstop flights to Washington National, with 11 average daily nonstops to Dallas 

and eight average daily nonstops to Houston. Exhibit F9-A-8. Clearly, the larger and 

less well-served beyond-perimeter cities benefiting from Frontier's one-stop service via 

Colorado Springs warrant another competitive connecting option more than withinperimeter cities of Dallas and Houston. As the Department recognized when it awarded 

Alaska four slot exemptions for service to Seattle and Los Angeles, "[w]hile there is 

overlap between the connecting markets that Alaska could serve over Seattle and Los 

Angeles, passengers would benefit from an alternative competitive nonstop choice to 

DCA on Alaska." DOT Order 2004-4-1, at 17; see also DOT Order 2000-7-1, at 21 

("Granting two slots at Las Vegas will enable America West to offer additional 

connecting options to passenger who will have the option of connecting either through 

Phoenix or Las Vegas.") 

10. Indeed, the Department should not overlook the fact that, unlike the State 

of Colorado, much of the State of Texas- including its two largest cities- are within the 

DCA perimeter and enjoy substantial nonstop service to Washington National. All told, 

Dallas/Ft. Worth and Houston enjoy a total of 19 daily departures to/from DCA. The 

State of Colorado warrants its fifth nonstop service to Washington National before 

Texas gets its 201

h. 

11. Austin also has daily service from a variety of non-legacy carriers -

AirTran, Southwest, JetBiue, and Frontier. Colorado Springs, by contrast, receives 

daily service from only one such carrier, Frontier. Exhibit F9-A-9. An award to Frontier 

would strengthen its ability to compete vigorously at COS against the legacy carriers 

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and expand its growing network there, whereas Austin already enjoys more non-legacy 

alternatives. 

12. Frontier's DCA-Colorado Springs service would also serve a wide variety 

of travelers, from time-sensitive government officials, military personnel, and 

businessmen and businesswoman, to more flexible leisure passengers. The GSA and 

its city-pair program would benefit greatly from the introduction of low-fare nonstop DCA 

-COS service by Frontier. Southwest, by contrast, claims that the majority of its 

passengers to Austin from Washington National would be leisure travelers - even more 

than currently use its supposedly less convenient BWI-AUS service. WN Exhibit 200 at 

3 & n.4. 

13. Southwest also has several within-perimeter hubs over which it could 

readily operate service to Austin and beyond from the Washington, D.C. area. It serves 

Chicago (Midway) from BWI and Dulles lnt'l, Houston from BWI, as well as Atlanta 

which AirTran/Southwest serves with multiple daily flights from Washington National. 

By contrast, Frontier has no within-perimeter hub. Exhibit F9-A-10; see DOT Order 

2001-6-20, at 9 (awarding two slot exemptions to Alaska Airlines in substantial part 

because it lacked an "inside-perimeter" hub which other applicant-carriers were able to 

use to serve beyond-perimeter cities). 

14. An award to Frontier would enable it to provide another nonstop route. 

Frontier does not currently serve COS-SAN and the DCA-COS service will provide the 

firm foundation upon which Frontier can commence a new route, namely COS-SAN. 

Exhibit F9-A-11. Southwest's proposal would not add a second new nonstop route 

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because Southwest already serves its single-plane beyond-AUS point of San Diego 

from Austin. 

For all of these reasons and the substantial additional benefits of Frontier's 

service proposal (as detailed in its Application), Frontier's DCA-Colorado Springs-San 

Diego service merits an award of two beyond-perimeter slot exemptions before megacarrier Southwest and its Austin service. 

B. JETBLUE AIRWAYS. 

JetBiue has applied for four (or fully 50%) of the available beyond-perimeter slot 

exemptions for service to San Juan, Puerto Rico, and Austin, Texas. JetBiue makes it 

clear that the Austin proposal is its second priority. 86 Appl., at 1. Neither of JetBiue's 

proposals merits an award of beyond-perimeter slot exemptions before Frontier's 

Colorado Springs proposal. 

As a threshold matter, Frontier should be first in line before JetBiue for the award 

of slot exemptions. JetBiue has now become, by far, the largest limited incumbent 

operator at Washington National, with 34 slots 10 and 17 daily departures, nearly twice 

the size of Frontier at DCA. Frontier has access to only 18 slots and slot exemptions at 

Washington National for nine daily departures. Exhibit F9-A-12. And, most of these 

are held and operated by Republic Airlines to provide within-perimeter service under the 

Frontier brand. When the broader Washington, D.C. metropolitan area is considered, 

the disparity in the level of Washington operations between Frontier and JetBiue is 

even greater. JetBiue operates seven daily nonstop departures from Dulles (including 

10 See Exhibit WN-115. 

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nonstops to the West Coast) and five daily nonstop departures from BWI. JetBiue is 

88% larger than Frontier at Washington National and 222% larger in the Washington, 

D.C. metropolitan area. Exhibit F9-A-13. Given Frontier's much smaller presence at 

DCA and Washington, D.C. and JetBiue's much larger and more flexible slot portfolio at 

Washington National, an award to fund Frontier's proposal to provide first nonstop 

service to Colorado Springs should come before any award to JetBiue. 

Frontier discusses the relative deficiencies of JetBiue's San Juan and Austin 

proposals below: 

-+ San Juan, Puerto Rico. 

1. Frontier would make better use of two valuable beyond-perimeter slot 

exemptions by offering 13,140 (or 12%) more annual nonstop seats to Colorado 

Springs than JetBiue would to San Juan ("SJU"). Exhibit F9-A-14. The provision of 

greater capacity is a standard favorable carrier selection factor in restricted-entry 

proceedings. See, e.g., DOT Order 2005-3-25, at 4 (Ryan Airlines (with 183 seats) 

selected over USA 3000 (with 168 seats) "based on Ryan's proposal to serve ... using 

larger aircraft .... "). 

2. Colorado Springs -with its mix of time-sensitive government, military, and 

commercial travelers, as well as leisure travelers - should receive its first mainline 

nonstop service from WAS before the primarily leisure destination of San Juan receives 

its fourth. San Juan currently has three nonstop mainline flights on two competing 

carriers from the Washington, D.C. metropolitan area: United Air Lines operates a daily 

nonstop flight from Dulles lnt'l and AirTran/Southwest offer twice daily service from 

BWI. Exhibit F9-A-15. Colorado Springs has no nonstop mainline flights from the 

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Washington, D.C. metropolitan area; its only WAS service is a single daily regional jet 

flight on United Express from Dulles lnt'l. 

3. Colorado Springs is a much higher fare market for passengers than San 

Juan, which is primarily a leisure market that benefits from multiple daily mainline 

nonstop flights from the Washington, D.C. metropolitan area on two competing carriers. 

For example, the average net fare for DCA-COS was $225, 17% higher than the 

average fare for DCA-SJU of $192; and the average net fare for WAS-COS was $241, 

36% higher than the average fare for WAS-SJU $177. Exhibit F9-A-16. Because of 

the dearth of service options between Colorado Springs and DCA, producing high 

average fares, Colorado Springs has a greater need for first-time low-fare competition 

than San Juan, which already has low-fare competition. Exhibit F9-A-9. 

4. JetBiue's beyond-SJU connections do not offer nearly the same level of 

public interest, competition, and network benefits as Frontier's beyond-COS 

connections. 

First, Frontier's single-plane service (to San Diego) serves an O&D DCA market 

that is over three times larger than JetBiue's single-plane service (to St. Thomas) -

126,129 annual DCA passengers for SAN compared to only 38,544 passengers for 

STT. Exhibit F9-A-17. Moreover, Frontier's single-plane, one-stop service to San 

Diego makes a relatively short stop outbound at COS, while JetBiue's single-plane 

service remains in San Juan for over 1% hours before continuing on to St. Thomas. 86 

Appl. Exhibit G. With a turn time that long, it is the equivalent of a connection. 

Therefore, Frontier's quicker single-plane service to San Diego with little wait time will 

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provide a greater level of competitive impact and attractiveness than Jet81ue's delayed 

single-plane service to STT. 

Second, Frontier's beyond-COS connections are to large U.S. destinations -

Seattle, Los Angeles, San Diego, Portland, Phoenix, and Denver - which represent 

about 1.14 million annual DCA passengers. Jet81ue's domestic beyond-SJU 

connections to Mayaguez, St. Thomas, St. Croix, and Vieques have only a fraction of 

the DCA traffic - about 44,718 annual DCA passengers. Exhibit F9-A-18. The 

remaining four Jet81ue connections (Santo Domingo, Anguilla, Tortola, Nevis) are 

admittedly to foreign points and do not provide "domestic" network benefits. However, 

even if considered, they pale in comparison to Frontier's beyond-COS points in terms of 

DCA passenger traffic. 86 Appl. at 12, 18-20. 

Third, five of the eight claimed Jet81ue connections are interline, not online, 

connections, operated by Cape Air with tiny 9-seat turboprop aircraft. 86 Appl., at 12. 

All of Frontier's connections are seamless online connections on large jet mainline 

aircraft with substantial on-board amenities. 

5. The Washington, D.C. metropolitan area is also Colorado Springs' top 

destination. It is San Juan's fourth largest U.S. destination. 11 This disparity shows that 

Washington, D.C. is Colorado Springs' top destination (even without having nonstop 

mainline service), but not San Juan's. 

6. San Juan also has daily service from a variety of non-legacy LCCs -

AirTran, Spirit, and Frontier. Exhibit F9-A-9. Frontier is the only LCC serving Colorado 

11 Diio US DOT O&D Data for YE 3Q11. 

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Springs. An award to Frontier would strengthen its ability to compete vigorously at COS 

against the legacy carriers and expand its growing network at the city. San Juan 

already enjoys more non-legacy alternatives. 

7. Unlike Frontier, whose only hub is beyond the perimeter, JetBiue has 

within-perimeter anchor/hub cities through which it carries traffic from Washington 

National and the broader Washington, D.C. area to San Juan. For example, JetBiue 

currently offers connections from Washington National to San Juan via Boston, Ft. 

Lauderdale, and Orlando. Exhibit F9-A-19. By contrast, Frontier has no withinperimeter anchor city/hub through which to serve Colorado Springs. See DOT Order 

2001-6-20, at 9. 

In sum, Frontier's DCA-Colorado Springs-San Diego service proposal is far 

superior in terms of capacity, enhanced market structure, domestic network benefits 

beyond the DCA perimeter, and the need for air fare relief than JetBiue's DCA-San 

Juan-St. Thomas proposal. 

~ Austin, Texas. 

1. JetBiue has made clear that Austin ("AUS") is its distant second choice, 

and that alone is telling. But, even if the Department gets beyond JetBiue's own 

devaluation of its Austin service proposal, the facts and data reveal that Frontier's 

Colorado Springs service is a much stronger service proposal than JetBiue's Austin 

proposal. 

2. Frontier would serve Colorado Springs with the largest aircraft in its fleetthe 168-seat A-320. By contrast, JetBiue would serve Austin with a smaller 1 00-seat 

E190. This translates into real public benefits because Frontier would provide 68% (or 

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49,640) more annual nonstop seats than JetBiue. Exhibit F9-A-14. This huge 

advantage ensures that the maximum number of potential passengers has access to 

the service funded by two of the scarce beyond-perimeter slot exemptions. To this 

point, the Department has never awarded beyond-perimeter slots for any proposal with 

such a small aircraft (as JetBiue has proposed for its Austin service). 

3. As discussed above in connection with Southwest's Austin proposal, 

Austin has substantial service to Washington, D.C., whereas Colorado Springs does 

not. The summer 2012 schedule shows that Austin will receive five daily nonstop flights 

on two competing carriers from the Washington, D.C. metropolitan area: United Air 

Lines schedules two daily flights from Dulles lnt'l (one mainline and one United 

Express) and Southwest schedules three daily mainline aircraft flights from BWI. 

Exhibit F9-A-2. Colorado Springs has no nonstop mainline flights from the Washington, 

D.C. metropolitan area, just a single daily monopoly regional jet flight on United Express 

from Dulles lnt'l. 

4. Nonstop service to the Washington, D.C. metropolitan area is by far 

Colorado Springs' top priority: WAS is Colorado Springs' largest destination. But, WAS 

is only Austin's sixth largest destination. 

5. Frontier's proposal not only provides first nonstop service to a large 

western city, it also combines that service with the benefit of single-plane, one-stop 

service to another large market in the West, San Diego. JetBiue's Austin proposal has 

no single-plane service benefit. Exhibit F9-A-20. And, indeed, the ability of Frontier to 

operate nonstop DCA-Colorado Springs service is the key to enabling Frontier to 

commence nonstop Colorado Springs-San Diego service, thereby offering the 

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additional substantial benefit of a new route for Colorado Springs' air service network. 

By contrast, JetBiue already serves Austin-Long Beach nonstop, and thus its DCAAUS service would not result in a second new route. 

6. Unlike Frontier with its connections at Colorado Springs to large beyondperimeter destinations like Los Angeles, Seattle, Portland, Phoenix, and Denver, 

JetBiue concedes that its only viable connection would be to Long Beach, California, a 

city it already serves with one daily nonstop flight from Dulles lnt'l. Frontier's one-stop, 

beyond-COS points with 1.14 million DCA O&D passengers are 274 times larger than 

the Long Beach-DCA O&D market. Exhibit F9-A-21. 

7. JetBiue's claims about its projected fares for DCA-AUS service are 

overblown, as its own application shows, and thus should be disregarded or at least 

substantially discounted. On this point, JetBiue suggests a fare range of $125- $665, 

representing alleged reductions of 44% and 54%, respectively, over United's current 

fare structure between $222 and $1,473. B6 Appl. at 24. But, that is an unrealistic 

reduction, and is belied by JetBiue's experience in other markets. For example, 

accepting at face value the accuracy of JetBiue's data, its entry into Austin resulted in 

much smaller fare reductions: 

AUS-FLL, a -17% fare change; 

AUS-LGB, -12%; 

AUS-MCO, -15%; 

AUS- SFO, -7%, 

AUS-NYC, -24%; 

AUS- BOS, -28% 

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See 86 Appl. at 14-15. 

None of these is even close to the -44% to -54% fare reduction that JetBiue claims it 

would generate in the DCA-AUS market. 

In terms of any relevant benchmark for public interest, competition, and network 

benefits, JetBiue's DCA-Austin service simply does not compare to Frontier's DCAColorado Springs-San Diego service. 

C. ALASKA AIRLINES. 

Alaska Airlines seeks four slot exemptions to fund daily nonstop service between 

Washington National and Portland ("POX"), Oregon, and between Washington National 

and San Diego ("SAN"), California. Before addressing the specific weaknesses of each 

particular proposal, there are three overarching and dispositive deficiencies with both of 

Alaska's proposals when compared to Frontier's Colorado Springs-San Diego service. 

First, despite its "route case" claims, Alaska Airlines is not a low-fare competitor. 

It is a high-fare legacy airline that, unlike Frontier, does not have low-fares in its DNA. 

When the U.S. Department of Justice commented on the Delta-US Airways slot 

exchange, it defined Alaska ("AS") as a "legacy carrier" and excluded it from the 

category of "low-cost carriers."12 The DOJ, however, categorized Frontier ("F9") as a 

low-cost carrier, and indeed the Department of Transportation has long recognized 

Frontier as a low-cost, low-fare competitor: 

12 See Comments of U.S. Dep't of Justice, Appendix A, at A-1 & n.1, dated March 24, 2010 (Docket FAA2010-0109). 

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"The Department noted that Frontier has a unique business plan and 

relationship in the Republic structure, and confirmed that its yields have 

remained consistent with those of LCCs."13 

"Frontier is a new entranUiimited incumbent with a record as a low-fare 

competitor . ... " DOT Order 2004-4-1, at 19 (emphasis added). 

This is a critical distinction between the two applications. 

In an attempt to ovecome this glaring weakness, Alaska has contrived a 

commitment to low fares. AS Appl. at 2. The so-called commitment should be seen for 

what it really is; a route case gambit that has no relation to reality, and therefore must 

be ignored. Alaska's track record, particularly at DCA, does not demonstrate any such 

commitment. For example, Alaska's average fare was $340 for DCA-SEA and $256 

for DCA-LAX. 14 Alaska's own data show that its average net fare was $276 for DCASEA and $209 for DCA-LAX. Exhibit AS-D-8. Those real world fares are significantly 

higher than, and are wholly inconsistent with, Alaska's unreal and illusory route case 

fares of between $149 and $179 for its proposed Portland and San Diego service. And, 

in any event, as Alaska concedes, that "commitment" - for what little it may be worth -

is only for one year and subject to fuel price increases during that year. AS Appl. at 2 & 

n.2. 

What is important is not the route case "promise", but the reality in the 

marketplace. Frontier is a low-cost carrier with a track record of competing based on 

low costs and ultra-low fares. Not so with Alaska. It is a high-cost, high-fare legacy 

airline. Merely promising to offer low fares will not make it so. Also, when Alaska 

13 Notice of Grant of DL-US Petition for a Waiver, 76 Fed. Reg. 63702, 63707 (October 13, 2011) (emphasis 

added). 

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began serving its two current DCA markets, fares in the first year after entry did not 

change in DCA-SEA and dropped by only 8% in DCA-LAX. 

Second, Frontier would offer over 8,000 more annual nonstop seats for its 

proposed beyond-perimeter services than Alaska would operate to Portland or San 

Diego. Exhibit F9-A-22. 

Third, as discussed at the outset, no carrier- including Alaska -should receive 

50% of the slot exemptions in this grossly oversubscribed slot proceeding. Indeed, 

given that Alaska is not a low-fare competitor, an award to Frontier of two slot 

exemptions should be given higher priority than an award to Alaska. 

In terms of destination-specific deficiencies of Alaska's proposals, Frontier 

addresses those, in turn, below: 

~ Portland, Oregon. 

1. Portland ("POX") has a nonstop mainline flight from the Washington, D.C. 

metropolitan area. Colorado Springs has none. 

2. On a mile-adjusted basis, Colorado Springs is more expensive, and in 

need of more air fare relief, than Portland. Specifically, in terms of total average fares, 

DCA-POX costs 13.1 cents per mile, whereas DCA-COS costs 20.3 cents per mile. 

Exhibit F9-A-23. Frontier's low-fare service to Colorado Springs would provide the fare 

and service competition that Colorado Springs so badly requires. 

3. Alaska's proposal would not offer the additional benefits of single-plane, 

one-stop service to any destination beyond Portland. Exhibit AS-D-1. Frontier would 

provide single-plane through service to San Diego via Colorado Springs, thereby 

14 Table 1A of the DOT Air Fare Report, March 2012 (average fare for largest carrier on route, Alaska). 

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extracting even greater consumer and competition benefits from the scarce beyondperimeter exemptions to be awarded. 

4. Alaska's claimed connections beyond Portland to ten cities (Anchorage, 

Bellingham, Seattle, Vancouver, Spokane, Redmond, Medford, San Jose, San 

Francisco, Eugene, Exhibit AS-D-5) offer potential benefits for far fewer passengers 

than Frontier's beyond-COS connections (San Diego, Portland, Los Angeles, Seattle, 

Phoenix, Denver). Alaska's ten beyond-POX cities represent collectively 579,424 

annual DCA passengers, whereas Frontier's beyond-COS cities represent 1,149,451 

annual DCA passengers. Exhibit F9-A-24. 

For all of the reasons set forth above, Frontier should receive an award of two 

beyond-perimeter slot exemptions for DCA service to Colorado Springs before Alaska 

receives any slot exemptions for service to Portland. 

~ San Diego, California. 

1. Alaska has made clear that San Diego is its second priority in this 

proceeding, behind Portland. AS Appl. at 5. And, with US Airways' recent 

announcement that it will commence nonstop Washington National-San Diego service, 

the need for another overlapping nonstop service by another high-fare legacy carrier 

(i.e., Alaska) is now less important. 

San Diego should be a lower priority for a nonstop frequency than Colorado 

Springs given that even before US Airways' nonstop service announcement, San Diego 

already receives five daily nonstop flights to the Washington region: United operates 

three daily nonstop flights to San Diego from Dulles lnt'l and Southwest operates two 

daily nonstop flights from BWI. Colorado Springs, by contrast, receives no nonstop 

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mainline aircraft service from the entire Washington, D.C. metropolitan region; it is 

relegated to a single daily small regional jet flight by United Express from Dulles lnt'l. 

2. Frontier would offer long-term low-fare competition in the DCA-San Diego 

market with its proposed single-plane, one-stop service via Colorado Springs. Alaska's 

proposed nonstop DCA-San Diego flight would not offer long-term low-fare 

competition. In fact, as demonstrated above, Alaska's claims to offer short-term low 

fares are belied by market realities. 

3. An award to Frontier would also enable San Diego to receive the benefits 

of another nonstop route which it currently does not have, namely to Colorado Springs. 

Frontier's nonstop DCA-Colorado Springs service would make that additional route a 

reality. Not so with Alaska's single-plane service to Honolulu ("HNL"), because Alaska 

already operates service between San Diego and Honolulu. Exhibit F9-A-11. 

4. Alaska's single-plane beyond-SAN service to Honolulu also does not 

benefit nearly as many potential passengers as Frontier's single-plane beyond-COS 

service to San Diego. DCA-SAN is about 2% times larger than DCA-HNL, 126,129 vs. 

50,093 annual passengers. Exhibit F9-A-25. 

Like its Portland service, Alaska's proposed service to San Diego falls short in 

terms of public interest, completion, and network benefits when compared to Frontier's 

Colorado Springs-San Diego service. 

D. VIRGIN AMERICA. 

Virgin America has applied for four (or 50%) of the available beyond-perimeter 

slot exemptions to operate twice daily nonstop service to San Francisco, a destination 

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which will soon receive nonstop service from Washington National and which has 

substantial nonstop flights from Dulles and BWI. Frontier's first-time ever nonstop 

mainline service to Colorado Springs from the entire Washington, D.C. metropolitan 

area would generate greater public interest, competition, and network benefits than 

Virgin America's duplicative San Francisco service. 

1. Virgin America should not be awarded 50% of the available slot 

exemptions. Other new entrant carriers - like Frontier and National - have had to make 

do with an initial allocation of two beyond-perimeter slot exemptions as new entrants to 

their respective hubs, and Virgin America's case is even less compelling than Frontier's 

was then and is now. When Frontier sought to gain its first service to Washington 

National in 2000 and sought four slot exemptions (or 33% of the 12 available) for 

service to its hub at Denver, the Department rejected that request and awarded Frontier 

only two slot exemptions. See DOT Order 2000-7-1, at 22 ("Given the limited number 

of slot exemptions available and the strengths of some other applicants, we have 

limited the award to two slots rather than the four the carrier requested."). 15 It was not 

until four years later in 2004 that Frontier was able to obtain another beyond-perimeter 

roundtrip. There is simply no basis for treating Virgin America any differently here, 

particularly when Virgin America wants to serve a destination (San Francisco) that is 

receiving nonstop service to Washington National (there was no nonstop service to 

Denver when Frontier first applied) and when there are other more meritorious service 

proposals like Frontier's. 

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2. United Air Lines recently announced it would operate nonstop service 

from Washington National to its hub in San Francisco with service starting in mid-May 

with B-737 aircraft. 16 While we appreciate Virgin America's desire to serve DCA, with 

United's plan to operate nonstop service between DCA and San Francisco, there is a 

less urgent need for San Francisco to gain yet another duplicating nonstop service, 

particularly if such an award is at the expense of Frontier's proposed service to provide 

first-ever nonstop DCA service to Colorado Springs. 

An award to Virgin America in favor of Frontier would be particularly unwarranted 

given that, including nonstop Washington National service, San Francisco receives a 

whopping 19 daily nonstop mainline flights with 2,548 daily seats from the Washington, 

D.C. area: 15 from Dulles lnt'l and 3 daily mainline nonstop flights from BWI. Exhibit 

F9-A-26. Indeed, Virgin America itself operates four daily nonstop between Dulles lnt'l 

and San Francisco. Exhibit VX-5. By contrast, Colorado Springs has no mainline 

nonstop service to any of the three major airports in the Washington, D.C. metropolitan 

area, just a single daily 66-seat regional jet flight from Dulles lnt'l. 

3. Indeed, although WAS-San Francisco is a larger market than WASColorado Springs, it is also a better served market. For example, there is one mainline 

daily nonstop flight for every 64,620 annual WAS-SFO passengers, but there is only 

one regional jet daily nonstop flight for 92,330 annual WAS-COS passengers. Exhibit 

F9-A-27. And, there are 1.40 nonstop seats per WAS-SFO passenger, as compared 

to .52 nonstop seats per WAS-COS passenger. Exhibit F9-A-28. 

15 And, when National Airlines sought to gain its first service to Washington National and requested six slot 

exemptions (or 50% of the 12 available) for service to its hub at Las Vegas, the Department likewise rejected that 

request and awarded National only two slot exemptions. See DOT Order 2000-7-1, at 22 (to same effect). 

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4. Frontier would also offer over 41% (or 35, 770) more annual nonstop seats 

with its 168-seat A-320 aircraft than Virgin America would offer on its 119-seat A-319. 

Compare Exhibit F9-5 with VX Appl. at 5. Indeed, given this disparity and the size of 

the markets at issue, it is simply ludicrous for Virgin America to claim, as it does, that its 

small A-319 aircraft is "right-sized" for San Francisco. VX Appl. at 5. 

5. Air fares between Washington, D.C. and San Francisco are not nearly as 

high as air fares between Washington, D.C. and Colorado Springs. For example, the 

average net fare for DCA-COS was $225, more than 14% higher than the DCA-SFO's 

average net fare of $197; and the average total fare for DCA-COS was $302, nearly 

11% higher than DCA-SFO's corresponding fare of $273. Exhibit F9-A-29. The 

disparity among fares is even more pronounced if considered on a miles-adjusted 

basis. In terms of net fares, DCA-San Francisco costs 8.1 cents per mile, whereas 

DCA-Colorado Springs costs nearly twice as much - 15.1 cents per mile. In terms of 

average total fares, DCA-San Francisco costs 11.2 cents per mile, whereas DCAColorado Springs costs 20.3 cents per mile. Exhibit F9-A-30. This is yet another factor 

strongly favoring an award to Frontier of two beyond-perimeter slot exemptions before 

any allocation is made to Virgin America for overlapping nonstop seNice to San 

Francisco. 

6. The Washington, D.C. metropolitan area is also Colorado Springs' largest 

destination but only San Francisco's fourth largest destination. 17 Thus, Colorado 

16 

17 

Notice of United Air Lines, filed February 27, 2012 (Docket DOT-OST-2012-0029). 

Diio US DOT O&D Data for YE 3011. 

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Springs has demonstrated its higher relative prioritization for nonstop DCA service than 

San Francisco. 

7. Virgin America also claims beyond-SFO connections to four large cities in 

the West (Seattle, Los Angeles, Las Vegas, San Diego), VX Appl. at 15, but the 

combined demand for DCA service pales in comparison to the six cities which will have 

one-stop service from Frontier via Colorado Springs (Seattle, Los Angeles, San Diego, 

Denver, Phoenix, Portland). Frontier's beyond-COS markets serve 52% more annual 

DCA passengers than Virgin America's beyond-SFO markets. Exhibit F9-A-31. 

Moreover, its connections via San Francisco are more circuitous than Frontier's 

connections over Colorado Springs: VX - 29.5% average circuity; F9 - 4.5% average 

circuity. 

8. Virgin America's proposal would not offer the additional benefits of singleplane, one-stop service to any destination beyond San Francisco. Exhibit AS-D-1. 

Frontier would provide single-plane through service to San Diego via Colorado Springs, 

thereby generating even greater consumer and competition benefits from the scarce 

beyond-perimeter exemptions to be awarded. 

E. AIR CANADA. 

Air Canada's proposal for nonstop service to Vancouver ("YVR") simply does not 

compare to Frontier's Colorado Springs DCA proposal. 

1. Frontier would offer 40% (or 35,040) more seats annually than Air 

Canada. Frontier would operate 168-seat A-320 mainline aircraft to Colorado Springs 

as compared to Air Canada's much smaller 120-seat A-319 aircraft. Exhibit F9-A-32. 

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2. The Colorado Springs-DCA market is over 82% larger than VancouverDCA. DCA-Colorado Springs has more than 31,000 annual passengers, but DCAVancouver had less than 17,000 annual passengers. Exhibit F9-A-33. 

3. The overall Colorado Springs-Washington, D.C. market is nearly twice as 

large as Vancouver- Washington DC. The WAS-Colorado Springs market had over 

92,000 annual passengers, compared to the 48,494 passengers in the WASVancouver market. Exhibit F9-A-33. 

4. In addition to substantially greater traffic demand, Colorado Springs has a 

higher relative priority for nonstop DCA service than Vancouver. The Washington, D.C. 

metropolitan area is by far Colorado Springs' largest destination with 127 passengers 

per day each way ("PDEW"), but only Vancouver's ninth largest U.S. destination with 

just 66 PDEW. 18 

5. Air Canada's proposal would benefit only foreign communities. And, in 

any event, the benefits of Air Canada's claimed beyond-YVR connections to 17 

Canadian points and six transpacific destinations are de minimis, particularly when 

compared to the benefits of Frontier's beyond-COS connections. Compare Exhibit AC2 with F9 Appl., Exhibit F9-21. With only a handful of slot exemptions available, they 

should be awarded for the benefit of U.S. carriers and "domestic" U.S. communities. 

First, the statute directs the Department to consider whether the proposed air 

transportation provides "domestic network benefits beyond the 1,250 mile perimeter." 

2012 FAA Act, Section 414(a)(2); see also DOT Order 2012-2-21, at 3. Neither 

18 Diio US DOT O&D Data for YE 3011. 

\\DC- 036787/000001-3381787 v3 
Consolidated Answer of Frontier Airlines, Inc. 

Page 36 

Vancouver nor any of the proposed beyond-YVR connecting destinations is a domestic 

point, and thus Air Canada offers no "domestic network benefits". By contrast, 

Frontier's beyond-COS services would be to large U.S. cities- San Diego, Seattle, Los 

Angeles, Portland, Phoenix, and Denver. 

Second, collectively the 17 beyond-YVR Canadian points amount to a mere 

fraction (or 1.4%) of the traffic in Frontier's beyond-COS markets: 16,120 annual 

passengers from DCA to Air Canada's beyond-YVR Canadian points, compared to 

about 1,140,000 annual DCA passengers for Frontier's beyond-COS U.S. points. 19 

Exhibit F9-A-34. And, if the three largest beyond-YVR Canadian points which already 

have one-stop Air Canada service from Washington National via Toronto and/or 

Montreal are excluded, Air Canada's beyond-YVR Canadian connections account for 

only about 681 annual DCA passengers?0 

6. Another important distinction is that Air Canada is not a low-fare 

competitor. Frontier, on the other hand, is a recognized low-cost, low-fare competitor. 

See, ~. DOT Order 2004-4-1, at 19 ("Frontier is a new entranUiimited incumbent with 

a record as a low-fare competitor"). 

7. Air Canada also has within-perimeter hubs -Toronto and Montreal- over 

which it can, and indeed does, carry traffic from Washington National and the broader 

Washington, D.C. area to Vancouver and its claimed beyond-YVR points. Exhibit F9-A35. By contrast, Frontier has no within-perimeter hub offering such flexibility and 

accommodation. This is yet another critical distinction between the two proposals 

19 

20 

Diio US DOT O&D Data for YE 3011. 

Diio US DOT O&D Data for YE 3011. 

\\DC- 036787/000001 • 3381787 v3 
Consolidated Answer of Frontier Airlines, Inc. 

Page 37 

militating strongly in favor of an award of two slot exemptions to Frontier for service to 

Colorado Springs, as the Department has previously acknowledged. See DOT Order 

2001-6-20, at 9 (awarding two slot exemptions to Alaska Airlines in substantial part 

because "unlike Northwest, Alaska has no inside-perimeter hubs that connecting 

passengers to DCA could utilize with less circuity as an alternative to DCA - Seattle 

service. Thus, the potential network benefits of Alaska's proposal are not diminished by 

the potential self-diversion of passengers to [its] other inside-perimeter hubs that was 

evident in Northwest's proposal."). 

8. Colorado Springs also has substantially greater communities of interest 

with the Nation's Capital than Vancouver. Colorado Springs is home to the United 

States Air Force Academy, as well as Ft. Carson (one of the largest U.S. Army 

installations in the world, with more than 30,000 assigned personnel), Cheyenne 

Mountain, Schriever Air Force Base, and Peterson Air Force Base (the host installation 

to four major military commands), and many defense contractors have a significant 

presence there. All of these facilities and organizations generate extensive travel to 

and from the Washington, D.C. area. Vancouver has no such military, national 

defense, and related commercial links with Washington, D.C. metropolitan area. 

For all of these reasons and those set out in its Application, Frontier's Colorado 

Springs service proposal is superior to Air Canada's Vancouver proposal. 

F. SUN COUNTRY. 

Sun Country has applied for two beyond-perimeter slot exemptions to serve Las 

Vegas ("LAS"). Its service proposal is not nearly as compelling as Frontier's. 

\\DC· 036787/000001 - 3381787 v) 
Consolidated Answer of Frontier Airlines, Inc. 

Page 38 

1. Frontier would offer over 30% (or 28,470) more annual nonstop seats with 

its 168-seat A-320 aircraft than Sun Country would offer on its 129-seat B-737. Exhibit 

F9-A-36; compare Exhibit F9-5 with Sun Country Appl. at 2. 

2. Las Vegas already receives nonstop service to Washington National on 

US Airways. Colorado Springs does not. Moreover, Las Vegas receives seven daily 

mainline nonstop flights from the Washington, D.C. metropolitan area offering 708,370 

annual mainline seats, whereas Colorado Springs has no mainline nonstop service from 

WAS. Exhibits F9-A-37 and -38. 

3. Sun Country offers no single-plane beyond-LAS service if it receives 

. beyond-perimeter slot exemptions. Frontier would offer timely single-plane through 

service via Colorado Springs to San Diego, a city that accounts for over 126,000 annual 

DCA passengers. 

4. Sun Country would offer no "domestic network benefits" beyond the 

perimeter because there would be no on-line connections at Las Vegas for its proposed 

DCA flight. Frontier, by contrast, would offer one-stop connecting service beyond 

Colorado Springs to six cities representing 1.14 million annual DCA passengers. 

Exhibit F9-A-39. 

5. Las Vegas already has the benefit of daily service from various U.S. cities 

by non-legacy carriers. Colorado Springs does not. Exhibit F9-A-9. Frontier is the only 

low-fare, non-legacy carrier operating daily service at Colorado Springs and nonstop 

DCA service would enhance its ability to compete with the stronger legacy carriers there 

and would enable it to inaugurate nonstop Colorado Springs-San Diego service. 

\\DC -036787/000001- 3381787 vl 
Consolidated Answer of Frontier Airlines, Inc. 

Page 39 

6. Colorado Springs' DCA fares are 11.4% higher than Las Vegas' DCA 

fares and 56% higher on a miles-adjusted basis. Exhibits F9-A-40 and -41. 

Sun Country's service proposal simply does not warrant an award of beyondperimeter slot exemptions at the expense of any such award to Frontier. 

IV. FRONTIER'S PROPOSAL HAS RECEIVED SIGNIFICANT PUBLIC SUPPORT. 

Frontier's proposed DCA-COS-SAN service has received thousands of letters of 

support from politicians, local leaders, former military leaders, business, NGOs, 

educational institutions, and residents. U.S. Senators Udall and Bennet of Colorado, as 

well as U.S. Representatives DeGette, Lamborn, Coffman, Polis, Gardner, and Tipton, 

have voiced their unequivocal support for Frontier's application. Exhibit F9-A-42. The 

Governor of Colorado, the Attorney General for the State of Colorado, the Mayor of 

Colorado Springs, its City Council, and others have demonstrated their support as well. 

Exhibit F9-A-42. And, confirming the critical need for this service for the brave men and 

women in the military stationed in the area, eight retired four-star generals, the Military 

Council of the Greater Colorado Springs Chamber and EDC, The Colorado Thirty 

Group, and the National Homeland Defense Foundation have all written the Secretary 

in support of Frontier's Colorado Springs service. Exhibit F9-A-43. 

* * * 

V. CONCLUSION. 

Frontier's application meets all of the requisite statutory objectives for an award 

of beyond-perimeter slots and its service proposal is far superior to the applications of 

the other six carriers. For the reasons stated above, the Department should award two 

\\DC- 036787/000001 -3381787 vJ 
Consolidated Answer of Frontier Airlines, Inc. 

Page 40 

of the beyond-perimeter slot exemptions to Frontier for daily nonstop roundtrip service 

between DCA and Colorado Springs. 

\\DC· 036787/00000\ - 338\787 v3 

Respectfully submitted, 

Robert E. Cohn 

Patrick R. Rizzi 

HOGAN LOVELLS US LLP 

555 Thirteenth Street, NW 

Washington, DC 20004 

+1 202 637 4999/5659 

Counsel for 

FRONTIER AIRLINES, INC. 
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Exhibit F9-A-1: Frontier is Smaller than Southwest at DCA and Much Smaller 

than Southwest in WAS 

- Southwest is 33% larger at DCA 

- Southwest is 2,856% larger in WAS (DCA/IAD/BWI) 

Source: published, peak day (Friday) schedule data for July 2012 

Daily DCA Departures Daily WAS Departures 

300 

12 

I I 2so 

9 

200 

1 50 

100 

50 

I I 

0 

Frontier So lith west Frontier So lith west 
Exhibit F9-A-2: Austin Has Five Daily WAS Nonstops; Colorado 

Springs Has Only One Daily Regional Jet Nonstop Service 

Source: Diio schedules data for peak day (Friday) in JUL12 

- BWI-AUS = 3x daily 

- lAD-AU$= 2x daily 

Dailly Mainl'ine WAS Nonstops 

6 

5 

5 

4 

3 

2 

I 

I 1 

1 

0 

COS.-'vVAS A US.-\IVA S. 
Exhibit F9-A-3: Austin has 365,632 Annual Nonstop Seats from WAS; 

Colorado Springs has Only 48,246 Annual Nonstop Seats from WAS 

Source: Diio schedules date for YE DEC12 

WAS = DCA/IAD/BWI 

Annual Nonstop WAS Seats 

4 00.000 ' 365,53 2 I 

35 0,.000 

300,.000 

250,000 

200.000 

150,000 

100,000 

4 8,246 

50,000 

0 

A US-WAS COS-\IVAS 
Exhibit F9-A-4: Southwest's Current Net and Total Average Fares for BWI-AUS 

are 26% and 49% Higher than Southwest's Fictitious Proposed Fare for DCA-AUS 

Source: 

- BWI-AUS net fare for Southwest, Exhibit WN-200 at 3 & N.4 

- BWI-AUS total fare for Southwest, DOT Air Fare Report (March 2012), Table lA 

Southwest's AUS Average Fares 

$260 ~2 1 

$240 

$220 I $214 

$200 

$180 

$160 

$140 

$120 

$100 

INN - B\1\o' IA US. Net W N- B\IVIA US Tot al W N - DCAAUS 

Proposed 
Exhibit F9-A-5: Frontier's Proposed DCA-COS Service Would Provide 23% 

More Annual Nonstop Seats Than Southwest's Proposed DCA-AUS Service 

• Source: F9, WN Applications 

Proposed Arnnual Nornstop Seats 

100,1010 

'!JV N DCA-A US 
Exhibit F9-A-6: Frontier's DCA-COS-SAN Service Would Be Nearly 8% 

Less Circuitous than Southwest's DCA-AUS-SAN Service 

Source: F9, WN applications 

- F9 DCA-COS-SAN is 1.2% circuitous 

- WN DCA-AUS-SAN is 8.9% circuitous 

J 

~ 

"· 

t 

~ ) "' 

~ A-,~-\ . . 't ·~·.' 

~;X.,·.~ ~· ·~., 

~~ 
Exhibit F9-A-7: Frontier's Beyond-COS Destinations have Over 30% More 

Annual DCA Passengers than Southwest's Beyond-AUS Points 

Source: DOT YE3Q11 data 

- F9: DCA to SEA/LAX/PDX/DEN/PHX (F9 Appl. at 11-15 & Exhibit F9-3) 

- WN: DCA to HOU/DAL (WN Appl.) 

An1nua l DCA O&D Passengers 

1,200,000 -.--------------------------

1.,;0 21,13 1 

1.000,000 -+----i 

7831268 

800,000 -+----i 

600,000 -+----i 

400,000 -t------1 

200,000 -t-------1 

0 

F9 Bey ond COS WN Bey ond A US 
Exhibit F9-A-8: Frontier's Beyond-COS Destinations have Far Fewer 

DCA Nonstops Each than Southwest's Beyond-AUS Points 

Source: Diio schedules data for YE DEC12 

DaHy DCA Nonstops 

12 

11 

10 

8 

6 

4 

4 

3 

2 II 

2 

None 

0 

~ & <..;~ ff ~ ~~ 0..:::, Q((; ~ 'j ~ "' ~ ;§ '<.o/ '<.o,' '<.0)' '<.o,' "<.0, ' 

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Exhibit F9-A-9: Colorado Springs is the Only Proposed U.S. 

Destination with Just One Non-Legacy Carrier 

Destination 

Colorado Springs 

Austin 

San Juan 

Portland 

San Diego 

San Francisco 

Non-Legacy Carriers with Daily 

Service 

Frontier 

Southwest, JetBiue, Frontier 

Air Tran, JetBiue, Spirit 

Southwest, Spirit, Virgin 

America, Frontier, JetBiue 

JetBiue, Southwest, Spirit, 

Virgin America, Frontier 

AirTran, Southwest, JetBiue, 

Virgin America, Frontier 
Exhibit F9-A-10: Southwest Has Within-Perimeter Hubs; 

Frontier Does Not 

Source: www.southwest.com 

~ 
Exhibit F9-A-11: Frontier's DCA-COS Service Would Enable a New 

Beyond Route, COS-SAN; No Other Same-Plane Proposal Would 

Source: F9, WN, AS and B6 applications 

- AS already serves SAN-HNL 

- WN already serves AUS-SAN 

- B6 already serves SJU-STI 
Exhibit F9-A-12: JetBiue is Almost Twice as Large as Frontier at DCA 

Source: Diio schedules data for peak day (Friday) duringJUL12 

Da'ily DCA Nonstops 

17 

18 

16 

14 

12 

10 

I 9 

8 

6 

4 

2 

0 

JetBiue Fr ontie r 
Exhibit F9-A-13: JetBiue is Already 222% Larger than Frontier in WAS 

Source: Diio schedules data for peak day (Friday) during JUL12 

- WAS = DCA/IAD/BWI 

Daily WAS Nonstops 

35 

29 

30 

25 

20 

15 

10 

5 

0 

JetBiue Frontier 
Exhibit F9-A-14: Frontier's DCA-COS Service Would Provide 12% and 68% 

More Annual Nonstop Seats than JetBiue's DCA-SJU and DCA-AUS Services 

Source: F9, B6 applications 

P1roposed An1nual Nonstop Seats 

140.000 I 

:1!22, 6410 

1 20,000 

1 00 .000 

80,.000 

60.000 

40.000 

20.0.00 

0 

F9 DCA-COS 8.6 DCA-SJU B6 DCA-A US 
Exhibit F9-A-15: San Juan has Three Daily Mainline Nonstops from 

WAS on Two Competing Carriers, while Colorado Springs has None 

Source: Diio schedules data for peak day (Friday) during JUL12 

- WAS = DCA/IAD/BWI 

Da'ily Mainl.ine WAS Nonst ops 

3.5 

3 

3 

2.5 

2 

1.5 

1 

0.5 

No·ne 

0 

SJU cos 
Exhibit F9-A-16: Colorado Springs Faces Much Higher Fares 

than San Juan from DCA and WAS 

Source: DOT Data YE3Q11 data 

- Fares are one-way, net of taxes and fees 

Average DCA One Way Fare Average WAS One Way Fare 

$230 $250 

s 240 -t-----J 

$220 s 230 -t-----1 

$210 s 220 -t-----1 

$210 -t----1 

$200 

$192 

$200 -t----1 

$190 -t----1 

$190 s 180 -t----1 

$180 $170 -t-----1 

s 160 -t----1 

$170 $150 -t-----' 

cos SJU cos 5JU 
Exhibit F9-A-17: Frontier's Single-Plane, One-Stop Destination is 

Over Three Times Larger than JetBiue's 

Source: DOT Data YE3Qll data 

Annual DCA O&D Passengers 

140,000 

' 1 26,129 

I 

120,000 

100,000 

80,000 

60 ,000 

40,.000 

38,544 

20,000 

0 

F9 _ s.an Diego 8·6 - S.t. Tho rn as. 
Exhibit F9-A-18: Frontier's Beyond-COS Connections Serve Over 25 

Times More DCA Passengers than JetBiue's Beyond-SJU Connections 

Source: DOT Data YE3Qll data 

- F9: DCA to SEA/LAX/PDX/DEN/PHX/SAN (F9 Appl. at 11-15 & Exhibit F9-3) 

- BG: DCA to MAZ/STI/STX/VQS (BG Appl.) 

Annual DCA O&D Passengers 

1,400,000 

I 

1,149A 51 

1,200,000 

1,000,000 

800,000 

600,000 

400,000 

200,000 

I 

44,718 

I 

0 

F9 - Be•,rond C05 B6 - Bey ond 5JU 
Exhibit F9-A-19: JetBiue has Within-Perimeter Hubs/Anchor Cities 

over which It Already Offers One-Stop DCA-SJU Service 

Source: www.jetblue.com 

~ 

If':• 

~ 

\ 1:1 0

f--• ----------~----~_j 
Exhibit F9-A-20: Frontier's DCA-COS Service Would Provide Single-Plane, 

One-Stop Service to SAN; JetBiue's DCA-AUS Would Offer No Similar Benefit 

Source: F9, BG applications 

Frontier 

~ ")\ ~ 

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Exhibit F9-A-21: Frontier's Beyond-COS Destinations Have 274 Times 

More Annual DCA Passengers than JetBiue's Beyond-AUS Point 

Source: DOT Data YE3Q11 

- F9: DCA to SEA/LAX/PDX/DEN/PHX/SAN (F9 Appl. at 11-15 & Exhibit F9-3) 

- B6: DCA to LGB (B6 Appl.) 

Annual DCA O&D Passengers 

1,400,000 

I 1,149,451 

1,200,000 

1,000,000 

800,000 

600,000 

400,000 

200,000 

I 4,1 98 

0 

F9 - Beyond COS B6 - Beyond SJU 
Exhibit F9-A-22: Frontier's DCA-COS Service Would Provide Over 8,000 

More Annual Nonstop Seats than Alaska's DCA-POX or DCA-SAN Service 

Source: F9, AS applications 

Proposed An1n1ual Nonstop Seats 

1 24 .!000 

1221 640 

I 

1 22 ,000 

1 20,000 

118,000 

116.000 

114.000 

112.000 

110.000 

F9 DCA-COS AS.DCA-PDX AS DCA-SA N 
Exhibit F9-A-23: On a Miles-Adjusted Basis, DCA-COS is More 

Expensive and in Greater Need of Low-Fare Service than DCA-POX 

Source: DOT Air Fare Report (March 2012), Table 1A 

- DCA-COS= 1487 miles, $302 average total fare 

- DCA-PDX = 2350 miles, $309 average total fare 

Total Avera.ge Fare Per MHe fin cents) 

25.0 

I 

20.3 

I 

20 .0 

1 5.0 13.1 

1 0.0 

5 .. 0 

0.0 

DCA-COS DC.A -P DX 
Exhibit F9-A-24: Frontier's Beyond-COS Destinations have 98% More 

Annual DCA Passengers than Alaska's Beyond-POX Points 

Source: DOT Data YE3Q11 

- F9: DCA to SEA/LAX/PDX/DEN/PHX/SAN (F9 Appl. at 11-15 & Exhibit F9-3} 

- AS: DCA to SFO/SEA/SJC/ANC/GEG/YVR/EUG/MFR/RDM/BLI (AS Appl.) 

An11nual DCA O&D Passenge1rs 

1.4 00,000 -,---------------------------

1.2100,000 1,149,451 

1,0 0 0 .o 0 0 -+-------1 

800.000 

579,424 

600.000 

400.000 

20 0 .o 0 0 --1--------4 

0 

F9- Bey ond COS AS - Bey ond PDX 
Exhibit F9-A-25: Frontier's Same-Plane, One-Stop DCA-SAN Market is 2.5 

Times Larger than Alaska's Same-Plane, One-Stop DCA-HNL Market 

Source: DOT Data YE3Qll; F9, AS applications 

Annual DCA O&D Passen.gers 
Exhibit F9-A-26: San Francisco has 19 Daily Mainline WAS 

Nonstops; Colorado Springs has None 

Source: Diio schedules data for peak day {Friday) in JUL12 

WAS = DCA/IAD/BWI 

Daily M a'inl'ine WAS Nonstops 

20 19 

18 +-----------------------~ 

16 

14 

1 2 

1 0 

8 

6 

4 +-----------------------~ 

2 None 

0 

COS-'vVAS S.FO -'v'u'A 5 
Exhibit F9-A-27: San Francisco is Better Served from WAS than 

Colorado Springs 

Source: DOT Data YE3Qll and Diio schedules data for peak day (Friday) in JUN12 

WAS = DCA/IAD/BWI ~----------------------------------------------------------~ 

Annual WAS Passengers per Nonstop Flight 

100,000 

92,330 

90,000 

80,000 

70.000 I 64,620 

60,000 

50,000 

40,000 

30.000 

20,000 

10,000 

0 

5FO cos 
Exhibit F9-A-28: San Francisco Has 169% More Annual Nonstop 

Seats per Passenger from WAS than Colorado Springs 

Source: DOT Data YE3Q11 and Diio schedules data for YE DEC12 

WAS = DCA/IAD/BWI 

Annual WAS Nonstops Seats per Passenger 

1.60 

I 1.40 

1.40 

1.20 

1.00 

0.80 

0.60 

0.40 

0 .20 

0 .00 

SFO cos 
Exhibit F9-A-29: Colorado Springs' Fares from DCA are 11%-

14% Higher than San Francisco's DCA Fares 

Average One Way Net Fare* 

?230 S225 

$22 5 

?220 

?21 5 

?210 

$20 5 

?200 

$195 

$190 

$185 

$180 

cos 

* Source: DOT Data YE3Qll 

SFO 

Average One Way Total Fare** 

JV4 ?3o5 I s 

?300 $295 --

$290 

$285 ~-­

$280 

$275 

$270 

$265 

$260 

$255 l_ 

~ 

cos SFO 

**Source: DOT Air Fare Report (March 2012), Table lA 
Exhibit F9-A-30: Colorado Springs' Fares from DCA are 81%-86% 

Higher than San Francisco's DCA Fares on a Miles-Adjusted Basis 

Average One Way Net Yield* 

1 6.0 •J•• 

14.0 

12.0 r--------: 10 ~ 

8.0 r--------: 

~ 

4.0 E 

2.0 

0.0 

cos 

* Source: DOT Data YE3Q11 

SFO 

Average One Way Total Yield** 

25 .0 

20.3 

20.0 

15.0 

11.2 

10.0 

5 .0 

0 .0 

cos SFO 

** Source: DOT Air Fare Report (March 2012), Table lA 
Exhibit F9-A-31: Frontier's Beyond-COS Markets Serve 52% More 

Annual DCA Passengers than Virgin America's Beyond-SFO Markets 

Source: DOT Data YE3Q11 data 

- F9: DCA to SEA/LAX/PDX/DEN/PHX/SAN (F9 Appl. at 11-15 & Exhibit F9-3) 

- VX: DCA to SAN/LAS/LAX/SEA (VX Appl. at 15) 

Annual DCA O&D Passengers 

1.400,000 

I 1,149.451 

1,200,000 

1,000,000 

757,039 

800,000 

600,000 

400,000 

200,000 

0 

F9 - Beyond cos VX - Beyond SFO 
Exhibit F9-A-32: Frontier's DCA-COS Service Would Provide 40% 

More Annual Nonstop Seats than Air Canada's DCA-YVR Service 

Source: F9, AC applications 

Proposed Ann1ual Nonstop Seats 
Exhibit F9-A-33: DCA-COS and WAS-COS are More than Twice 

as Large, Respectively, as DCA-YVR and WAS-YVR 

Source: DOT Data YE3Qll 

100000 -, Annual O&D Passengers 92,384 

I 

90000 

80000 

70000 

60000 

I 

50000 I 

48,494 

40000 31,442 

' 30000 

20000 j • 16,570 

10000 

0 

DCA COS DCAYVR WASCOS WASYVR 

34 
Exhibit F9-A-34: Frontier's Beyond-COS Destinations have Over 70 Times 

More DCA O&D Passengers than Air Canada's Beyond-VVR Canadian Points 

Source: DOT Data YE3Qll 

Annual O&D Passengers 

1200000 

1000000 

800000 

600000 

400000 

200000 

16,120 

0 

cos YVR 

35 
Exhibit F9-A-35: Air Canada has Service to Vancouver via its Three 

Within-Perimeter Hubs; Frontier has No Within-Perimeter Hubs 

Source: www.aircanada.com 

~..,.. 

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( 

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~ 

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- - ~. r=-';' ~ : - ~ ' 'lr 'C;l:> • 

': 

. . 
Exhibit F9-A-36: Frontier's DCA-COS Service Would Provide 30% 

More Annual Nonstop Seats than Sun Country's DCA-LAS Service 

Source: F9, SY applications 

Prorposed Annual Nonstop Sea1ts 

94, 1. 70 

SY DCA-LA S. 
Exhibit F9-A-37: Las Vegas has Nonstop Mainline Service from All 

Three WAS Airports, including DCA; Colorado Springs Has None 

Source: Diio schedules data for peak day (Friday) in JUL12 

- DCA-LAS has one daily mainline nonstops 

- lAD-LAS has two daily mainline nonstops 

- BWI-LAS has four daily mainline nonstops 

Daily ine WAS Nonstops 

8 

7 

7 

6 

5 

4 

3 

2 

1 

I N o·n e 

0 

cos. LAS. 
Exhibit F9-A-38: Las Vegas has 14.7 Times More Annual Nonstop 

WAS Seats than Colorado Springs 

Source: Diio schedules data for YE DEC12 

Arnrnual Nonstop WAS Seats 

800.000 7081370 

700.000 -+-------------------1 

600 ,000 ,------------_j 

500.000 l ____________ _j 

4 00 ,000 l ____________ _j 

300.000 l ____________ _j 

200.000 ,-----=-=~--------J 100.000 4 81246 

0 

DCA -·COS. DCA-LAS 
Exhibit F9-A-39: Sun Country Would Offer No Beyond-LAS Connections, 

Whereas Frontier Would Offer Beyond-COS Connections to Destinations 

Accountine for 1.14 Million Annual DCA Passeneers 

Source: DOT Data YE3Q11 

- F9: DCA to SEA/LAX/PDX/DEN/PHX/SAN (F9 Appl. at 11-15 & Exhibit F9-3) 

- SY: none (SY Appl.) 

Annual DCA O&D Passengers 

1.400,000 I 

1,149A51 

1.2 00,000 

1,000,000 

800,000 

600,000 

4 00,000 

200,000 

I None 

0 

F9 - Beyond COS SY - Beyond LAS 
Exhibit F9-A-40: Colorado Springs' Fares from DCA are Higher 

than Las Vegas' DCA Fares by 11.4% 

Source: DOT Air Fare Report (March 2012L Table lA 

Avera,ge DCA Total Fare 

$320 

$302 

$300 

$2 80 I 5271 

$2 60 

$2410 

$220 

$200 

DCA-LAS DCA -COS 
Exhibit F9-A-41: On a Miles-Adjusted Basis, DCA-COS Fares are 

Higher than DCA-LAS Fares by 56% 

Source: DOT Air Fare Report (March 2012}, Table 1A 

- DCA-COS= 1487 miles, $302 average total fare 

- DCA-LAS= 2089 miles, $271 average total fare 

Total Average Fare Per M 'ile (1in cents) 

25.0 

20.3 

20.0 

15.0 13.0 

1 0.0 

5.0 

0.0 

DCA-LAS DCA-COS 
EXHIBIT F9-A-42 
<!rnngr.e.s.s nf tq.e l!tnif.ell ~tat.e.s 

ma.sflittghm, :S<!r 2D515 

The Honorable Ray LaHood 

Secretary of Transportation 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

March 27, 2012 

Re: Application of Frontier Airlines for Two Beyond-Perimeter Slot Exemptions for Washington 

National-Colorado Springs Nonstop Service (Docket DOT-OST-2012-0029) 

Dear Secretary LaHood: 

We urge the Department of Transportation to award two beyond-perimeter slot exemptions at 

Ronald Reagan Washington National Airport (DCA) to Frontier Airlines for new, nonstop 

service to Colorado Springs (COS). This new route would be the first non-stop flight to connect 

these two cities, and the resulting benefits to consumers in the form of decreased flight time and 

increased fare competition- as well as economic benefits to both the Washington and Colorado 

Springs markets - make it a compelling applicant for new flights authorized by the FAA 

Modernization and Reform Act of2012 (P.L.112-95). 

Frontier's proposed DCA-COS service is particularly important given the unparalleled 

commercial, aerospace and high-tech industry, governmental, and military links between 

Colorado Springs and the National Capital Region. "The Springs" is Colorado's second largest 

city and a primary access point for the Rocky Mountains and three of Colorado's top tourist 

destinations: the U.S. Air Force Academy, Pikes Peak, and the Garden of the Gods. Colorado 

Springs is also home to over 36,000 Department of Defense personnel and five major military 

installations (Fort Carson, Schriever Air Force Base, Peterson Air Force Base, Cheyenne 

Mountain Air Force Station, and the U.S. Air Force Academy)- all of which are located within 

25 miles of the Colorado Springs Airport. These installations house numerous major military 

commands like U.S. Northern Command, North American Aerospace Defense Command, U.S. 

Air Force Space Command, the 4th Infantry Division, and the U.S. Army Space and Missile 

Defense Command. In addition, the U.S. Olympic Committee and the U.S. Olympic Training 

Center also call Colorado Springs home, and nearly every high-tech and defense contractor in the 

country has a significant presence in the region. 

These military installations, organizations, and businesses generate extensive travel to and from 

the Washington, D.C., area, making our nation's capital the number one destination for Colorado 

Springs air passengers. Proposed service by Frontier Airlines would fill a glaring service void by 

providing for the first time much-needed, nonstop DCA service and low-fare competition to a 

market for which currently over 90 percent of passengers are forced to purchase high-fare 

connecting tickets. Of additional benefit to consumers, this new non-stop route could reduce 

travel time by up to three hours over existing options. 

PRINTED ON RECYCLED PAPER 
Frontier recently established Colorado Springs as a focus city, and it is the only low-fare carrier 

offering daily service to a growing Colorado Springs route network. Enabling Frontier to provide 

DCA-COS service would help strengthen Frontier's low-fare competitive presence in the state 

and allow it to offer improved service via Colorado Springs to several other western cities, 

including San Diego, which would receive one-stop single-plane service from DCA. DCA-COS 

would also provide the cities of Los Angeles, Seattle, Portland, Phoenix, and Denver with an 

additional one-stop connecting option to Washington, DC. 

For these reasons, we strongly support Frontier's bid to acquire two beyond-perimeter slot 

exemptions for Colorado Springs - DCA service and ask for your full and fair review of its 

application. We look forward to hearing back from you on this matter, which is of the utmost 

importance to the people of Colorado. 

Warm Regards, 

Senator Michael F. Bennet 

Representative Diana DeGette 

~oe~ ... fb..--c· . Representative Doug Lamborn 

- Representative Mike Coffman 

6Wter: 

Representative Scott Tipton 
OFFICE OF THE GOVERNOR 

136 State Capitol 

Denver, Colorado 80203 

Phone (303) 866-2471 

Fax (303) 866-2003 

March 27, 2012 

The Honorable Ray LaHood 

Secretary of Transportation 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

STATE OF COLORA.DO 

John W. Hickenlooper 

Governor 

Re: Application of Frontier Airlines for Two Beyond-Perimeter Slot Exemptions for Washington 

National-Colorado Springs Nonstop Service (Docket DOT-OST-2012-0029) 

Dear Secretary LaHood: 

We would like to express our strong support of the application of Frontier Airlines for two 

beyond-perimeter slot exemptions at Ronald Reagan Washington National Airport (DCA) to 

enable it to provide low-fare, nonstop service between DCA and Colorado Springs. 

Washington, D.C. and the surrounding metropolitan area is, by far, Colorado Springs' largest 

destination. These commercial, goverrunental, and military links between Colorado Springs and 

the Nation's Capital generate extensive travel, yet there is no nonstop service between Colorado 

Springs and DCA. It is a large, underserved, market that needs and can support nonstop service. 

Frontier's proposal would fill this critical air service void. It would also compete vigorously with 

the current nonstop service from Dulles International and one-stop connecting flights which 

Colorado Springs-DCA passengers are required to use because of the current lack of nonstop 

service. 

Colorado Springs is Colorado's second largest city and the home to some of the U.S. military's 

largest and most important installations like Fort Carson (one of the largest U.S. Army 

installations in the world with more than 30,000 assigned personnel), Peterson Air Force Base 

(which is the host installation for U.S. Northern Command, North American Aerospace Defense 

Command (NORAD), U.S. Air Force Space Command, and U.S. Army Space Command), and 

the U.S. Air Force Academy. 

Colorado Springs is home to many organizations that have national significance. Because of the 

proximity to the numerous military installations in the area many defense contractors have 

operations in the area. Colorado Springs is home to the U.S. Olympic Complex, which is the 

flagship training center for U.S. Olympic Committee and the Olympic Training Center programs. 
Both USOC member organizations known as national goveming bodies have their national 

headquarters on the complex. Colorado Springs is also the main gateway to many Colorado 

tourist and recreational attractions; Pike's Peak is located 10 miles west of the city, and Colorado 

Springs offers routes to major Colorado Ski Resorts that avoids the congested I-70 corridor. 

Enabling Frontier to provide nonstop Colorado Springs-DCA service would offer the public 

expanded service and more travel options that would extend beyond the Washington D.C. 

Metropolitan Area and Colorado Springs, by offering same-plane service to San Diego (a new 

route for Colorado Springs) and, connections via Colorado Springs to Portland, Seattle, Los 

Angeles, Phoenix, and Denver. 

The residents and businesses of Colorado Springs, as well as the tens of thousands of men and 

women in the military stationed in the area, deserve this new service. Frontier's service would 

provide the nonstop service we need. We hope that your Department will seize this opportunity 

and reduce this service deficiency by awarding two slot exemptions to Frontier for Washington 

National- Colorado Springs- San Diego service. 

For these reasons, our administration urges the Department to award Frontier two beyondperimeter slot exemptions for Colorado Springs-DCA service. 

Sincerely, 

Clf::omo~• d.:tt:::c.<~~r' 

CC: Bill Hybl 
ATTORNrnYGENERALOFCOLORADO 

John W. Suthers 

The Honorable Ray LaHood 

Secretary of Transportation 

U. S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

March 21, 2012 

Re: Application ofFrontier Airlines for Two Beyond-Perimeter Slot 

Exemptions for Washington National-Colorado Springs Nonstop Service 

(Docket DOT-OST-2012-0029) 

Dear Secretary LaHood: 

I'm writing to encourage the approval of a direct flight for Frontier Airlines 

from Colorado Springs to Reagan National Airport. 

I'm the Attorney General of Colorado and reside in Colorado Springs. I travel to 

Washington, D.C. approximately once a month as part of my job responsibilities. I 

frequently leave on a Sunday or Monday morning and would welcome the opportunity 

to fly from Colorado Springs rather than travelling to Denver. As it is, I often see many 

people from Colorado Springs on the always-full Denver flights and I know they also 

would love the chance to fly from the Springs. 

Your consideration and approval of this new route would be greatly appreciated. 

Sincerely, 

:t:w~ Colorado Attorney General 

State Services Building • 1525 Shennan Slreet-7'h Floor • Denver, Colorado 80203 

Phone (303) 866-3557 • FAX (303) 866-4745 
CITY OF COLORADO SPRINGS 

March 19, 2012 

The Honorable Ray LaHood 

U.S. Secretary ofTransportation 

1200 New Jersey Avenue, SE 

Washington, D.C. 20590 

RE: Washington National-Colorado Springs Non-Stop Service (Docket DOT-OST-2012-0029) 

Dear Secretary LaHood: 

STEVE BACH 

1'v\AYOR 

This letter serves to convey the strong support that the City of Colorado Springs has for Docket DOTOST-2012-0029; Frontier Airlines request to add non-stop service from Colorado Sp.rlhgs Airport (COS) to 

Ronald Reagan-Washington National Airport (DCA). 

As you may know, Colorado Springs is home to an extensive network of Department of Defense and 

defense-related organizations that conduct business in the Washington, D.C. and Northern Virginia 

areas. The establishment of non-stop service between COS and DCA would greatly enhance connectivity 

for these businesses and for the industry in our region. 

Frontier Airlines, if successful in this bid, would help grow Colorado Springs' business community, 

develop healthy competition within the airline markets of the region, retain employers in the region, 

and provide a valued service to local citizens. 

Thank you for your consideration of the Frontier Airlines' application. 

Steve Bach 

Mayor 

30 South Nevada Avenue, Suite 601 • TEL 7"19-385-5900 FAX 719-385-5488 

Mailing Address: Post Office Box 1575, Mail Code 6'10 • Colorado Springs, Colorado 80901-1575 
March 20, 2012 

The Honorable Ray LaHood 

Secretary of Transportation 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

SCOTT HENTE 

PRESIDENT 

RE: Application of Frontier Airlines for Two Beyond-Perimeter Slot Exemptions for washington 

National-Colorado Springs Nonstop Service (Docket DOT-OST-2012-0029) 

Dear Secretary LaHood: 

The Colorado Springs City Council wholeheartedly supports the establishment of non-stop 

service between COS and DCA. This service would greatly enhance connectivity for the business 

and travel communities, and promote a level of competition that is not currently in the market. 

This proposed bid will serve as a valued benefit for air passengers within the Colorado Springs 

area, the Pikes Peak Region, and beyond. 

This service would enable our citizens to travel from the Colorado Springs Airport directly to 

Ronald Reagan Washington National Airport; a service that we all believe is greatly needed for 

this area. 

Thank you for your consideration of this application of Frontier Airlines. We would greatly 

appreciate your support. 

Respectfully, 

Bv--

Scott Hente, President 

Colorado Springs City Council 

c: City Council 

Mark Earle, Director of the Colorado Springs Airport 

107 North Nevada Avenue, Suite 300 • TEL n9-335-5487 FAX 719-385-5495 

iv\ailing Address: Post Office Box 1575, Mail Code 1549 • Colorado Springs, Colorado 80901-1575 
State Representative 

JANAK JOSHI 

Colorado Stnte Capitol 

200 East Colfax Avenue, Room 271 

Denver, Colorado 80203 

Capitol: 303-866~2937 

E~mail: janak..joshi.house@state.co.us 

COLORADO 

HOUSE OF REPRESENTATIVES 

March 21,2012 

The Honorable Ray LaHood 

Secretary of Transportation 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

STATE CAPITOL 

DENVER 

C0203 

Member; 

Education Committee 

Finance Committee 

Health and Envmmment 

Cmnminee 

Re: Application of Frontier Airlines for Two Beyond-Perimeter Slot Exemptions for 

Washington National-Colorado Springs Nonstop Service (Docket DOT-OST-2012-0029) 

Dear Secretary LaHood: 

My name is Janak Joshi and I have the honor of representing House District 14, Colorado 

Springs, in the Colorado House of Representatives. It has come to our attention that Frontier 

Airlines has applied for two slot exemptions at the Ronald Reagan Washington National Airport 

(DCA) to provide non-stop service to the Colorado Springs Airport (COS). This bid will serve as 

a valued benefit for air passengers within the Colorado Springs area and beyond. 

Such a service would provide jobs and growth within my district as well as offer our many 

military servicemen and women an opportunity to have a direct flight to DCA. Succinctly, the 

establishment of non-stop service between COS and DCA would greatly enhance coi1Ilectivity 

for the business and travel communities, and promote a level of competition that is not currently 

in the market. Please consider these many opportunities that would greatly benefit my district, 

Colorado, and our nation. 

Sincerely, 

_-'/,_ ....

-- /·G· ()~~/Di/0L- r / Qv JanakJos -

State Representative 

House District 14 
BILL L. CADMA..'l" 

State Senator 

Colorado State Capitol 

Denver, CO 80203 

Office (719) 57D-9300 

Capitol: (sos) 866-2737 

billcadman.senate@state.co.us 

SENATE 

STATE OF COLORADO 

DENVER 

SENATE MINORITY LEADER 

The Honorable Ray LaHood 

Secretary of Transportation 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

March 26, 2012 

COMMITIEES 

i'Vlember of: 

Legislative Council 

Executive Committee of Legislative 

Council 

Re: Application of Frontier Airlines for Two Beyond-Perimeter Slot Exemptions for 

Washington National-Colorado Springs Nonstop Service (Docket DOT-OST-2012-0029) 

Dear Secretary LaHood: 

It is an honor to endorse the efforts of Frontier Airlines to provide non-stop service from the 

Colorado Springs Airport (COS) to the Ronald Reagan Washington National Airport (DCA). 

Frontier's bid will serve as a valued benefit for air passengers within the Colorado Springs area 

and beyond. 

The establishment of non-stop service between COS and DCA vvill greatly enhance connectivity 

for the business and travel communities. This opportunity will promote a level of competition 

that is not currently in the market. 

It is my pleasure to wholeheartedly support Frontier's efforts in creating this nonstop service. 

Bill L. Cadman 

Senate Minority Leader 
ELPASO COUNTY 

COMMISSIONERS 

AMY LA THEN, CHAIR 

S,\I,Ll& CL.ARJ{, Vtct CUAUl 

COLORADO 

EL PASO BOARD OF COUNTY COMl\USSIONERS 

March 20, 2012 

The Honorable Ray LaHood 

Secretary of Transpiration 

US Department ofTransportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

DENNIS HISEY 

DARRYL GLEt"''N 

PEGGY LITI'L&TON 

Re: Application of Frontier Airlines for Two Beyond-Perimeter Slot Exemptions for 

Washington National-Colorado Springs nonstop Service (Docket DOT-OST-2012-0029) 

Dear Secretary LaHood; 

The Board of County Commissioners of El Paso County, Colorado strongly supports the application of 

Frontier Airlines to provide non-stop service from Colorado Springs to Ronald Reagan National Airport. 

El Paso County is Colorado's most populous county with more than 630,000 residents. But the Colorado 

Springs Municipal Airport is the closest and most convenient airport for many residents from all of 

southern Colorado. 

As proud home of the United States Air Force Academy, Fort Carson, NorthCom, Schriever AFB, Peterson 

AFB, and Cheyenne Mountain Air Station, our area generates a huge demand for air service in and out of 

the D.C. area. Additional trips are generated by the headquarters of the U.S. Space Foundation, the 

United States Olympic Committee, the Olympic Training Center, the world famous Broadmoor Hotel, the 

nearby Pueblo Depot Activity and the high speed rail test facilities in Pueblo County. Service personnel 

and their families, retirees with ties to the Pentagon and friends and family in the D.C. area and other 

members of our community who provide support for these installations all travel regularly to the DC 

area. 

200 S. CASCADE AVENUE, SUITE 100 

OFFICE: (719) 520-7276 

WWW.ELPASOCO.COM 

COlORADO SPRINGS, CO 80903 

FAX: (719) 520-6397 
Non-stop service between Colorado Springs (COS) and Ronald Reagan Washington National Airport 

(DCA) would be a very valuable asset to all of southern Colorado, reduce costs and improve efficiencies 

for government agencies and businesses serving those agencies and make it easier and more convenient 

for residents in the D.C. area to take advantage of the unmatched scenic beauty and recreational 

opportunities that would be available just a few hours away in Colorado. Currently, when flying to the 

DC area, is wasted in changing planes, layovers, and cancelled flights connecting through crowded 

airports in Denver, Chicago, Dallas or Houston. The addition of Frontier's non-stop service will promote 

higher a level of competition and greater convenience for travelers throughout southern Colorado. 

The Colorado Springs Municipal Airport is a modern, highly efficient, facility with convenient access, 

from Interstate 25 on the recently completed Milton Proby parkway. It has runways capable of servicing 

all types of aircraft and plenty of room to grow. 

Our unique location at the gateway to the Colorado mountains and our unique position as home to so 

many agencies, businesses and non-profits which require frequent travel to D.C. would be compelling 

reasons to consider the Frontier request. But when you also understand the impact of so many active 

duty military personnel, retirees and DOD civilian contractors and their families who need convenient 

access to the D.C. area, we believe the Frontier Airlines request for two beyond-perimeter exemption 

slots is the clearly the best choice and should be approved. 

Sincerely, on behalf of all of the Board. 

Amy Lathen 

El Paso County Commissioner 

Chair 

El Paso County Commissioner 

Liaison to the Colorado Springs Airport Commission 
SOARD OF DIRECTORS 

OFFiCERS 

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City of~ Cr<d< 

Mayor 1'\"o T"" Goldie 0,... 

Town of Calhln 

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Town of Fllrplay 

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MayorTmls&non 

Town of Monument 

Mayer ProTem KelehMcCatferty 

Town of~ 

Coul:d:ueuMMI 8tVJdy W-.m: 

City of Colondo ~ 

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City of O>londo~ 

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March 23, 2012 

Pikes Peak Area 

council of Governments 

communities working Together 

Re: Application of Frontier Airlines for Two Beyond-Perimeter Slot Exemptions 

for Washington National-Colorado Springs Nonstop Service (Docket 

DOT -OST-20 12-0029) 

The Honorable Ray LaHood 

Secretary of Transportation 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Dear Secretary LaHood: 

The Pikes Peak Area Council of Governments (PPACG) is a voluntary 

association of 16 municipal and county governments that serves as a forum of 

local governments to work on regional issues. Among our many 

responsibilities, PPACG is responsible for the production of the regional 

transportation plan and the certain regional planning efforts in support of the 

Pikes Peak area's military installations. 

We recently learned that Frontier Airlines has applied for two slot exemptions 

at the Ronald Reagan Washington National Airport (DCA) to provide non-stop 

service to the Colorado Springs Airport (COS). This bid will serve as a valued 

benefit for air passengers within the Pikes Peak region and beyond. 

Providing non·stop DCA service would be particularly beneficial to the five 

major military installations that lie at the heart of our economy. 

As a regional planning agency that values the region's military members and 

installations and their efforts to collaborate with local, state, and federal 

agencies, non·profits, and other stakeholders, we fully support Frontier 

Airlines' bid and urge you to award the exemption. 

Sincerely, 

daaee~ Sallie Clark, Chair 

Board of Directors 

Pikes Peak Area Council of Governments 

15 S. 7th Street 

Colorado Springs, CO 80905 

I 5 South 7th Street. Colon.do Springs. CO 80905 • 719-471·7080 • www.ppaq.org • ppact@ppaq.org 
CITY OF COLORADO SPRINGS 

March 20, 2012 

The Honorable Ray LaHood 

Secretary, US Department Of Transportation 

1200 New Jersey Ave SE 

Washington, DC 20590-0001 

BERNIE HERPIN 

COUNCILMEMBER 

Re: Application of frontier Airlines for Two Beyond-Perimeter Slot Exemptions for Washington 

National-Colorado Springs Nonstop Service (Docket DOT-OST-2012-0029) 

Dear Mr. Secretary: 

lt has come to my attention that Frontier Airlines has applied for two slot exemptions at the Ronald 

Reagan Washington National Airport (DCA) to provide non-stop service to the Colorado Springs 

Airport (COS). This bid will serve as a valued benefit for air passengers within Colorado Springs, the 

Pikes Peak Region, and Southern Colorado. 

As the second largest city, and largest county, in Colorado, this non-stop service between Colorado 

Springs and Washington, DC will greatly enhance air travel to our region resulting in increased business 

and leisure travel. 

We are the proud home offive military bases. This non-stop service will also benefit Department of 

Defense travelers. 

I respectfully request your support for this request. This service will provide an economic benefit to our 

area and increase air travel competition. Thank you for considering my request. 

;;:,L. 

BemieHerp~ Council Member District 4 

BH:ms 

107 North Nevada Avenue. Suite 300 • TEL 719·385-5492 FAX 719·385-5495 

Mailing Address: Post0fr1ce Box 1575, Mail Code 1549 • Colorado Springs, Colorado 80901-1575 
The Honorable Ray LaHood 

Secretary of Transportation 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

March 23, 2012 

Re: Application of Frontier Airlines for Two Beyond-Perimeter Slot Exemptions for Washington 

National-colorado Springs Nonstop Service (Docket DOT-OST-2012-0029) 

Dear Secretary LaHood: 

on behalf of the Colorado Springs Airport Advisory Commission, 1 am writing in strong support 

of Frontier Airlines' application for two beyond-perimeter slot exemptions to provide non-stop 

service between the Colorado Springs Airport (COS) and Ronald Reagan Washington National 

Airport (DCA). This letter has the strong and unanimous support of all Commission members. 

Frontier's proposal would establish first time ever, non-stop service between Colorado's second 

largest city and DCA. While the Washington D.C. metropolitan area is the top ranked 

destination out of COS, our passengers have never had direct access to the city's primary, close· 

in airport. The approval of Frontier's application would address this lon~standlng service 

deficiency and remove a constraint that has affected our business and tourism economies for 

years. 

The lack of non-stop DCA service has been particularly hard on the five major military 

installations that lie at the very heart of our economy. Colorado Springs is home to Ft. Carson, 

Cheyenne Mountain Air Force Station, Schriever Air Force Base, Peterson Air Force Base and the 

United States Air Force Academy. These facilities host a broad range of critical operational 

missions, and serve as the headquarters for major national commands such as U.S. Northern 

Command, North American Aerospace Defense Command, u.s. Air Force Space Command and 

the U.S. Army Space and Missile Defense Command. The addition of non-stop COS..DCA service 

would provide much more efficient connectivity between these essential fac;)lities and our 

nation's capital. Military staffs now are able to access the<:apitol area only1:hrough Denver and 

other hubs, with the increased time and effort that is required to do that. We vigorously 

support Federal money-saving efficiencies such as that requested by this application. 

For the reasons outlined above, we respectfully request that the Department ofTransportation 

give full and favorable consideration to Frontier Airlines' application. 

Sincerely, 

Walter D. Miller, Chairman 

Colorado Springs Airport Advisory Commission 

Colorado Springs, Colorado 
The Honorable Ray LaHood 

Secretary of Transportation 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

March 23, 2012 

Re: Application of Frontier Airlines for Two Beyond-Perimeter Slot Exemptions fllf' Washington 

National-Colorado Springs Nonstop Service (Docket DOT-osr-:to12-oo29) 

Dear Secretary LaHood: 

On behalf of the ColoradoSpringsAirport Advisory Commission, lam writing in strong support of 

Frontier Airlines' application for two beyond-perimeter slot eXemptions to provide non'StOp serv.ice 

between the Colorado Springs Airport (COS) and Ronald Reagan Washington National Airport (DCA). 

Frontier's proposal would estabfish firsttime ever, non-stop servJce between Colorado's second largest 

city and DCA. Whilethe Washington D.C. metropolitan area is tile top ranked destination out of COS, 

our passengers have never ha<;l direct access to the city's primary, clqse-in airport. The approval of 

Frontier's application would address this long-standing service deficient\' and remove a constraint that 

has.affected our bu~iness and tourism e~onomies for years. 

The lack of non-stop. DCA service has been particularly hard on the five major military installations that 

lie at the heart of our economy. Colorado Spring£ is home to Ft. Carson, Cheyenne Mountain Air Force 

Station,. Schriever Air force Base, Peterson Airforce Base. and the. United States Air Force Academy; 

These facilities host a broad range Clfoperational missions, and serve asthe headquarters for major 

natlonal.c.ommands such as U.S. Northern Command, North American Aerospace. Detlmse Command, 

U.S. Air Force Space Command and!he U.S. Afmy Space and Missile Defense Command .. 

Presently, the necessary 65+ mile drive to DIA. to accomplish national defense related travel to the 

capital, oft.en compounded by the threat offrequent we.ather problems along the route, jeopardizes the 

timely'conduct of that business and places'the traveler at unnecessary risk, The addition of non·stop 

COS.,DtA service wquld provide greater connectivity between these essential facilities and our nation's 

capital, and would greatly enhance the overall efficiency and effectiveness of our national defense 

effort. 

For the reaso!)s o!Jtllned. a~ove, we respectfully request thatthe .Department ofTransportation give. full 

and favorable consideration to Frontier Airlines' application. 

Respectfully, 

~·'*IJ~~ Andrew W. Biancur, Col. USAF (Ret.) 

AirportAavisory Commission 

Colorado:Sprlngs, co. 
EXHIBIT F9-A-43 
March 27, 2012 

The Honorable Ray LaHood 

Secretary ot Transportation 

U.S. Department ofTransportation 

1200 New Jersey Avenue SE 

Washington D.C. 20590 

Re: Docket DOT·05T·2012·0029 

Dear Secretary LaHood: 

**** 

We are writing to express our full and unqualified support for Frontier Airlines' application for two slot 

exemptions to provide first time ever, non-stop service between the Colorado Springs Airport (COS) and 

Ronald Reagan Washington National Airport (DCA). 

As senior officers who have had responsibility for the major military commands, we can attest to the critical 

need for a direct air transportation link to the Pentagon and other governmental centers in our nation's 

capital. The five military installations 1n Colorado Springs-Ft. Carson, Cheyenne Mountain Air Force Station, 

Schriever Air Force Base, Peterson Air Force Base, and the United States Air Force Academy-host a broad 

array of operational missions, as well as four major military commands-U.S. Northern Command, North 

American Aerospace Defense Command. U.S. Air Force Space Command. and U.S. Army Space & Missile 

OefensP Command/Army Forces Strategic Command. These military organization<, thE? htmdreds of defense 

contractors that support them and the civilian population of greater Colorado Springs generate tremendous 

demand for travel to and from Washington D.C. Due to its close proximity to the Pentagon, the Capitol and 

other nearby destinations, the vast majority of that travel is routed through DCA. 

The establishment of non-stop service between COS and DCA would address a long-standing deficiency in 

the transportation system that ties our nation's capital with the tremendous concentration of military assets 

that our nation has placed in Colorado Sprinss. In the interest of increasing the efficiency and effectiveness 

of these assets, we strongly urge that you approve Frontier Airlines' application. 

Respectfully submitted, 

Kevin P. Chilton 

General, USAF Retired 

General. USAF Retired 

\b,JJ~\b.s-- Ho\v.l:J!. MjSiiJ 

General. USAF Retired 

~21)'---- lante \l.jLord --

General, USAF Retired 

!Ur?dd..J 

Charles R. Holl:nd 

General, USAF Retired 

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·, 

.::-~~ ·& ::"!~ 

Victor E. Renuart. <--.- ··-Ronald W. Yates Jr. If· 

General. USAF Retired General, USAF RE>tired 
Board of Dlrectas 

Doug Quimby 

Choir 

La Plato Commvnmes. 

Ire. 

Mike Jorgensen 

Vice-Chair 

Red NciJncl Cadillac. 

rc. 

Chris 81ees 

1recsurer 

BiggsKofford. P.C.. 

Dan Ma!Inarlc 

Secrefal'y 

Alme!CC!fX(afon 

Frank Caris 

dpiX.lLC 

Debbie Chandler 

Cokxado Springs 

Heo!lh Partners 

Toby Gannett 

TI1e Palisode5 at 

BroadmoorPak 

Steve Helbing 

Wefts Forgo Bank 

Chris Jenkins 

Nor 'wood 

Development 

TomNeppl 

Splngs Fobncalion.lnc 

Sherr! Newell 

Colcrado Splngs 

Utilities 

Kevin O'Neil 

lheO'Neil Group 

Dove Polenchar 

EIPDnXYFOundcmon 

Venkat Reddy, Ph.D. 

University of Colcrado 

Colorado Splngs 

General "Gene" 

Renuart, USAF (Ret.) 

THE CHAMBER 

Colorado Splings 

Regional Economic 

Development Corporation 

The Greater Colorado Springs Chamber & EDC 

March21.2012 

The Honorable Ray LaHood 

Secretary of Transportation 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Re: Application of Frontier Airlines for Two Beyond-Perimeter Slot 

Exemptions for Washington National-Colorado Springs Nonstop 

Service (Docket DOT -OST -2012-0029) 

Dear Secretary LaHood, 

The Military Affairs Council of The Greater Colorado Springs Chamber and 

EDC has been an integral part of our community since 1941, when it 

worked with the Army, and with strong community support, to bring Fort 

Carson to Colorado Springs. Since that time, it has been instrumental in 

community support for the continued growth of our military in the region. 

Our five military installations are unique in not only the concentration of 

military, but also in the diversity of critical national missions- from the North 

American Aerospace Defense Command and US Northern Command, 

the Air Force Academy, Fort Carson, and the bases engaged in space 

and cyberspace operations. 

It has come to our attention that Frontier Airlines has applied for two slot 

exemptions at the Ronald Reagan Washington National Airport (DCA) to 

provide non-stop service to the Colorado Springs Airport (COS). This bid 

will serve o valued benefit for air passengers within the Colorado Springs 

area- especially our military community. 

We have over 61 ,000 military, government civilians, and contractors 

working on our five military installations, and the great number of 

aerospace/defense contractors in our region supporting our military. 

There are significant travel requirements to our nation's capital, not only 

for Pentagon travelers, but also in support of other national agencies and 

contractor required visits to offices in Washington, DC. The establishment 

of non-stop service between COS and DCA provides not only a highly 

efficient option for military and business travelers, but for the general 

public as well, and promotes a level of competition that is not currently in 

the market. 

Chamber 719-635-1551: 6 S. iejan Street Suite 700 EDC 719·471-8183: 102 S. iejon Street Suite 430 

Colorado Springs, Colorado 80903 
[I]CoiOr,ldoSptir:gs: 

~:onal &:onomic -------------------------THE "''' CHAMBER ,jp ", .••• """""""'"'"''"""''" -

Thank you for your strong consideration of Frontier Airlines application. We 

enthusiastically support their request. It will bring a much needed flight 

service to our community and truly support the many travelers between 

Colorado Springs and Washington National. 

Respectfully, 

/·a~ 

Col Brian Binn, USAF (Ret) President 

Military Affair Division 

"'· 

/J;;~f. '1-r/U£/trv~ Mr DeForest A. Hamilton, Ill. Chair 

Military Affairs Council Advisory Board 

Maj Gen ~ortner. USAF (Ret), Chair 

Defense Mission Task Force 

The Greater Colorado Spri11gs Cl1amber & £DC 

Chamber 719-635-1551: 6 s. Tejon Slreef Suite 700 EDC 719-471-8183: 102 s. Tejon Street Suite 430 

Colorado Springs, Colorado 80903 
William Thayer TuttFounding Chairman 

1912-1989 

Gen. James E. HillFounding Chairman 

1921-1999 

William B. TuttHonorary Ufetime Chairman 

Donald E. AddyChairman 

Christian Anschutz -

Vice Chairman 

John A. Love -

Vice Chairman 

C. David McDermottVice Chairman 

MalVin Stein - Vice Chairman 

Trustees 

LTG Ed Anderson, 

US Army (ret) 

George M. Douglas 

Gen Howell Estes, 

USAF (ret) 

Will F. Nicholson. Jr. 

Dennis A. Weber 

Trustee Emeritus 

Hal Littrell 

THE COLORADO THIRTY GROUP 

March 26, 2012 

The Honorable Ray LaHood 

Secretary of Transportation 

U.S. Department of Transportation 

1200 New Jersey Avenue SE 

Washington, DC 20590 

Dear Secretary LaHood, 

I am writing on behalf of The Colorado Thirty Group (CTG), an organization 

founded in 1978 consisting of over 160 business and civic leaders in 

Colorado. Our mission is "To educate, inform, and foster understanding and 

cooperation between the civilian community, the government of the United 

States, and the armed forces." 

We are aware that FrontierAirlines has applied for two slot exemptions at the 

Ronald Reagan Washington National Airport (DCA) to provide non-stop 

service to Colorado Springs, CO (COS). If awarded this service it will result in 

a valuable benefit to air passengers in the Colorado Springs area and 

beyond. 

Colorado Thirty Group participants are frequent travelers to Washington, DC 

and having Frontier's competively priced service directly from COS would be 

very valuable to all of us and the community at-large. 

We urge you to approve their application. 

Respectfully, 

Donald E.Addy, Chairman 

1259 Lake Plaza Drive, Suite 250 

Colorado Springs, Colorado 80906 

719-576-1328 

www.cothirty.org 

VERUS GRATIA 
March 16, 2012 

The Honorable Ray LaHood 

Secretary of Transportation 

NATIONAL HOMELAND DEFENSE FOUNDATION"' 

Securing the Future of Liberty "' 

General Gene Renuart (USAF, ret) 

Chairman of the Board 

U.S. Department of Transportation 

1200 New Jersey Avenue SE 

Washington, DC 20590 

Dear Secretary LaHood, 

I am writing on behalf of the Board of Directors of The National Homeland Defense 

Foundation (NHDF). The National Homeland Defense Foundation (NHDF) exists for the 

purpose of Securing the Future of LibertyTM through sharing of innovation, research, 

education, and information in the fields of homeland defense and security. 

NHDF conducts two major events in Colorado Springs each year; the NATIONAL 

SYMPOSIUM on Homeland Security & Defense, and the National Security Innovation 

Competition. Each event draws several hundred people to the city from around the U.S. 

We are aware that Frontier Airlines has applied for two slot exemptions at the Ronald 

Reagan Washington National Airport (DCA) to provide non-stop service to Colorado 

Springs, CO (COS). If awarded this service it will result in a valuable benefit to air 

passengers in the Colorado Springs area and beyond. 

Having low-cost round trip air service from DCA to COS will be extremely valuable to our 

constituents who travel to COS for our annual events. It will enhance connectivity and 

ease of travel for all citizens of the Colorado Springs greater area. 

I urge you to approve the Frontier application on Docket DOT-OST-2012-0029. 

Sincerely, 

Gene Renuart, Chairman of the Board 

1259 Lake Plaza Drive Suite 250 

Colorado Springs, CO 80906 

www .nhdf .org 
CERTIFICATE OF SERVICE 

I hereby certify that a copy of the foregoing Consolidated Answer of 

Frontier Airlines, Inc. has been served this 2?'h day of March 2012, upon each of the 

following addressees: 

bob.kneisley@wnco.com; megan.lawrence@alaskaair.com; marshall.sinick@squiresanders.com; 

anita.mosner@hklaw.com; jhill@dowlohnes.com; john.fredericksen@suncountry.com; 

john.varley@virginamerica.com; jegillick@zsrlaw.com; info@airlineinfo.com; 

brian.ctr.meehan@faa.gov; Phii.Sunderland@mwaa.com; 

Mayor Stephen Bach 

Colorado Springs 

sbach@springsgov.com 

\\DC - 036787/000001-3381787 v3