BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. Applications of FRONTIER AIRLINES, INC. AIR CANADA ALASKA AIRLINES, INC. JETBLUE AIRWAYS CORPORATION SUN COUNTRY AIRLINES SOUTHWESTAIRLINES 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. ALASKAAIRLINES. 

### 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 viBEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C. Applications of FRONTIER AIRLINES, INC. AIR CANADA ALASKA AIRLINES, INC. JETBLUE AIRWAYS CORPORATION SUN COUNTRY AIRLINES SOUTHWESTAIRLINES 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 ofthe 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).

\\DC- 036787/00000\ • 3381787 v3Consolidated Answer of Frontier Airlines, Inc. Page 2 Second, the Department should limit the awards ofthese 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 oftwo 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 Int'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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• 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.

\\DC· 036787/00000\

- 3381787 v3Consolidated 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

\\DC- 036787/000001-3381787 v3Consolidated Answer of FrontierAirlines, 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% ofthe 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% ofthe slot exemptions to any ofthem 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 vJConsolidated 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% ofthe 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.

\\DC- 036787/000001 -3381787 vJConsolidated Answer of FrontierAirlines, 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 - 3381787v3Consolidated 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 oftwo ofthe 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 vlConsolidated 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 ofjust 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 ofthe 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 vlConsolidated 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 oftwo 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.

\\DC· 036787/000001-3381787 v3Consolidated 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 ofthem. 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.

\\DC- 036787/000001 -3381787 v3Consolidated 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 ofslot 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

\\DC- 036787/000001 - 3381787 v3Consolidated 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.

\\DC- 036787/000001 -3381787 vJConsolidated 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 10.0%. (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.

\\DC • 036787/000001 - 338\787v3Consolidated 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.

\\DC- 036787/000001 • 3381787 vlConsolidated 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

\\DC. 036787/000001.3381787 v3Consolidated 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

\\DC· 036787/000001 • 3381787 v3Consolidated Answer of FrontierAirlines, Inc. Page 18 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

\\DC. 036787/000001 - 3381787 vlConsolidated Answer of Frontier Airlines, Inc. Page 19 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%) ofthe 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 slots10 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 underthe 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.

\\DC· 036787/00000\ • 338\787 vlConsolidated Answer of Frontier Airlines, Inc. Page 20 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

\\DC· 036787/000001 -3381787 v3Consolidated Answer of FrontierAirlines, Inc. Page 21 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

\\DC. 036787/000001-3381787 vlConsolidated Answer of Frontier Airlines, Inc. Page 22 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.

\\DC- 036787/000001

- 3381787 v3Consolidated Answer of Frontier Airlines, Inc. Page 23 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 100-seat E190. This translates into real public benefits because Frontier would provide 68% (or

\\DC- 036787/000001-3381787 v3Consolidated Answer of Frontier Airlines, Inc. Page 24 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 jetflight 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

\\DC- 036787/000001 -3381787 vJConsolidated Answer of Frontier Airlines, Inc. Page 25 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%

\\DC- 036787/000001 • 3381787 vJConsolidated Answer of Frontier Airlines, Inc. Page 26 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).

\\DC· 036787/000001 • 3381787 vJConsolidated Answer of Frontier Airlines, Inc. Page 27 "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 ofLCCs." 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).

\\DC· 036787/00000\ • 3381787 v3Consolidated Answer of Frontier Airlines, Inc. Page 28 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 oftotal 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 ofthe DOTAir Fare Report, March 2012 (average fare for largest carrier on route, Alaska).

\\DC- 036787/000001-3381787 vJConsolidated Answer of FrontierAirlines, Inc. Page 29 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

\\DC- 036787/000001

- 3381787 v3Consolidated Answer of Frontier Airlines, Inc. Page 30 mainline aircraft service from the entire Washington, D.C. metropolitan region; it is relegated to a single daily small regional jetflight 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

\\DC- 036787/000001-3381787 v3Consolidated Answer of Frontier Airlines, Inc. Page 31 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.

\\DC- 036787/000001 • 3381787 vJConsolidated Answer of Frontier Airlines, Inc. Page 32 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).

\\DC- 036787/000001-3381787 v3Consolidated Answer of FrontierAirlines, Inc. Page 33 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.

\\DC- 036787f000001 -3381787 v3Consolidated Answer of Frontier Airlines, Inc. Page 34 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-seatA-319 aircraft. Exhibit F9-A-32.

\\DC • 036787/000001 • 3381787 vJConsolidated Answer of Frontier Airlines, Inc. Page 35 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 v3Consolidated 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 v3Consolidated 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 superiorto 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 vlConsolidated Answer of FrontierAirlines, 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 vJConsolidated Answer of FrontierAirlines, 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 DailyWAS Departures 300 12 I I 2so 9 200 1 50 100

50 

### I I 0 Frontier Solithwest Frontier Solithwest

# Exhibit F9-A-2: Austin Has Five Daily WAS Nonstops; Colorado Springs Has Only One Daily Regional Jet Nonstop Service

Source: Diio s chedules data for peak day (Friday) in JUL1 2

- BWI-AUS = 3x daily

- lAD-AU$= 2x daily 

# Dai ll y Mainl'ine WAS Nonstops 6 5 

### 5 4 

### 3 2 I

I 1 1 

### 0 COS.

-'vVAS AUS.

-\IVAS.

## Exhibit F9-A-3: Austin has 365,632 Annual Nonstop Seats from WAS; Colorado Springs has Only 48,246Annual Nonstop Seats from WAS

Source: Diio schedules date for YE DEC12 WAS = DCA/IAD/BWI 

# Annual Nonstop WAS S eats 4 00
.000 ' 

### 365,53 2 I 

### 350,.000 300 ,.000 250,000 200
.000 1 50,000 1 00 ,000 

### 4 8,246

50,000 0 

### AU S-WAS COS -\IVAS

## Exhibit F9-A-4: Southwest's Current Net and Total Average Fares for BWI-AUS are 26% and 49% Higherthan Southwest's Fictitious Proposed Fare for DCA-AUS

Source:

- BWI-AUS netfare 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 AUSAverage Fares $260**~2 1**  $240 $220 

# I $214 $200 $180 $160 $140 $120 $100 IN N - B\1\o' IA US. Net W N- B\IVIA USTot 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 

# ProposedArnnual Nornstop Seats

100,10 10

'!JVNDCA

-AUS

# 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 

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## "·**~** t ) "'**~ A-,~-\**  .**. 't** **·~· .'** 

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## 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 & E xhibit F9-3)

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

# An1 nualDCA O&D Passengers 1 ,200,000 -.-------------------------- 1.,;021,13 1 1.000,000 -+----i 7831268

800,000 -+----i 600,000 -+----i 400,000 -t------1 200,000 -t-------1 0 F 9 Beyond COS WN Beyond 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 forYE DEC12 

## DaHy DCA 

## Nonstops 1 2 11 1 0

8

6 4 4 3 2 

# II 2 None 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
AirTran, 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 alreadyserves 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 1 8 1 6 14 1 2 10 

# I 9

8 6 4 2 0 JetBiue Fronti e r

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

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

- WAS = DCA/IAD/BWI 

## Daily WAS 

## Nonstops 35 29 30
25
20 15
1 0

5
0 Jet Biue Frontier

## Exhibit F9-A-14: Frontier's DCA-COS Service Would Provide 12% and 68% MoreAnnual Nonstop Seats than JetBiue's DCA-SJU and DCA-AUS Services

Source: F9, B6 applications

# P1 roposedAn1 nual Nonstop Seats 140
.000 I :1!22, 64 1 0 

### 1 20,000 1 00
.000

80, . 000 60
.000 40
.000 20
.0.00 0 F9 DCA-COS 8.6 DCA-S JU B6 DCA-A U S

# 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) duringJUL12

- WAS 

## =DCA/IAD/BWI 

## Da'ily Mainl.ineWAS Nonstops 3
.5 3

3
2.5

2
1.5

1
0
.5 No· ne 0 S JU 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 oftaxes 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 $1 70 -t-----1 

### s

160 -t----1 $170 $ 150 -t-----' cos S JU cos 5 JU

# 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. Thor n 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 - Beyond 5JU

# Exhibit F9-A-19: JetBiue has Within-Perimeter Hubs/Anchor Cities over which ItAlready Offers One-Stop DCA-SJU Service

Source: www.jetblue.com

# ~

If':•**~** \ 1:1 0 f

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## 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

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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 S JU

## 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

# An1 n1 ual Nonstop Seats 1 24 .!000 1221

### 640 I 

### 1 22,000 1 20,000 11 8,000 11 6
.000 114
.000 11 2
.000 11 0
.000 

### F 9 DCA

-COS AS.DCA

- PDX AS 

### DCA

-SAN

# 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 

# TotalAvera. 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 DC A

-COS 

### D C

.A-PDX

# 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 & E xhibit F9-3}

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

# An1 1 nual DCA O&D 

# Passenge1 rs 1 .400,000 -,--------------------------- 1
.2 1

### 00,000 1,149,451 

### 1 ,

0 00

# .o 00 -+-------1 

### 800
.000 579,424 

### 600
.000 400
.000 200

# .o 00 --1--------4



### 0 F9- Beyond COS AS - Beyond 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 datafor peak day {Friday) in JUL12 WAS = DCA/IAD/BWI 

# Daily 

# M a' inl' ine WAS 

# Nonstops 20 19 1 8**+-----------------------~** 

### 16 14 

### 1 2 1 0



### 8 6 

### 4**+-----------------------~** 

### 2 None 0 

### COS-'vVAS S.FO

-'v 'u

'A5

# Exhibit F9-A-27: San Francisco is Better Served from WAS than Colorado Springs

Source: DOT Data YE3Qll and Diio schedules datafor 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% MoreAnnual Nonstop Seats per Passenger from WAS than Colorado Springs

S

ource: DOT Data YE3Q11 and Diio schedules datafor YE DEC12 WAS = DCA/IAD/BWI 

## AnnualWAS 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 $225 ?220 ?21 5 ?2 10 $205 ?200 $195 $190 $185 $180 cos
* Source: DOT Data YE3Qll SFO 

### Average One WayTotal 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% Higherthan 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 WayTotal 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 - Beyondcos 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

# ProposedAnn1 ual NonstopSeats

# 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 DCACOS 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**~..,. .** **Oo ~~~** **·** 

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# 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

# Pror posedAnnual Nonstop Sea1 ts

94, 1.70

S

Y 

### DCA

-LAS
.

# 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 nons tops

- 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. L AS.

## Exhibit F9-A-38: Las Vegas has 14.7Times More Annual Nonstop WAS Seats than Colorado Springs

Source: Diio schedules data for YE DEC12 

# Ar nr nual Nonstop WASS eats 800
.000 7081 370 700
.000 -+-------------------1 

### 600,000 

# ,------------_j 500
.000 

# l
____________ _j 400, 000 

# l
____________ _j 300
.000 

# l
____________ _j 200
.000

# ,----**-=-=~ --------** **J** 1 00
.000 

### 4 81246 0 

### DCA

- · C

OS. 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 & E xhibit F9-3)

- SY: none (SY Appl.)


# Ann ual DCA O&D Passengers 1.400,000 I 1, 149A5 1 1
.

2 00 ,000 1 ,000 ,000

800 ,000 600 ,000 4 00 ,000 200 ,000 

# I None 0 F9 - Beyond COS S Y - 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 DCATotal Fare $320 $302 

### $300 $280 

# I 5271 

### $260 $241 0 $220 $200 DCA

-L AS 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 

# T otal Average Fare Per M 'ile 

# (1 in cents ) 25
.0 20
.3 20
.0 1 5
.0 13.0 1 0
.0

5
.0 0
.0 DCA

-L AS DCA

-COS

# EXHIBIT F9-A-42

## <!rnngr.e.s.s nftq.e l!tnif.ell**~tat.e.s** ma.sflittghm, :S<!r 

### 2D515

The Honorable Ray LaHood Secretary ofTransportation U.S. Department ofTransportation 1200 NewJersey Avenue, SE Washington, DC 20590 March 27, 2012

Re: Application ofFrontierAirlines for Two Beyond-Perimeter SlotExemptions for Washington National-Colorado SpringsNonstop Service (DocketDOT-OST-2012-0029) Dear Secretary LaHood: We urge the Department ofTransportation 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 inthe form ofdecreased 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 andthree ofColorado's top tourist destinations: the U.S. Air Force Academy, Pikes Peak, andthe Garden ofthe Gods. Colorado Springs is also home to over 36,000 Department ofDefensepersonnel and five major military installations (Fort Carson, Schriever AirForce Base, Peterson AirForce Base, Cheyenne Mountain Air Force Station, andthe U.S. Air Force Academy)- all ofwhich are located within 25 miles ofthe 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 4thInfantry 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 inthe country has a significantpresence 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 airpassengers. 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 competitionto a market for which currently over 90 percent ofpassengers are forced to purchase high-fare connecting tickets. Ofadditional benefit to consumers, this newnon-stop route couldreduce travel time by up to three hours over existing options.

PRINTED ON RECYCLED PAPERFrontierrecently 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 ofLos Angeles, Seattle, Portland, Phoenix, and Denver with an additional one-stop connecting option to Washington, DC. For these reasons, we strongly supportFrontier's bid to acquire two beyond-perimeter slot exemptions for Colorado Springs

- DCA service and ask for your full and fair review ofits application. We look forward to hearing back from you onthis matter, which is ofthe utmost importance to the people ofColorado.
Warm Regards,

SenatorMichael F. Bennet

Representative DianaDeGette

# ~oe~

# ... fb..--c·
. Representative Doug Lamborn



# - Representative Mike Coffman 

# 6Wter: Representative ScottTiptonOFFICE OF THE GOVERNOR 136 State Capitol Denver, Colorado 80203 Phone (303) 866-2471 Fax (303) 866-2003

March 27, 2012 TheHonorable Ray LaHood Secretary ofTransportation U.S. Department ofTransportation 1200 New JerseyAvenue, SE Washington, DC 20590 

# STATE OF COLORA.DO

John W. Hickenlooper Governor

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: We would like to express our strong supportofthe application ofFrontier Airlines for two beyond-perimeter slot exemptions at Ronald Reagan WashingtonNational Airport (DCA) to enable it to provide low-fare, nonstop servicebetween 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 theNation's Capital generate extensive travel, yet there is no nonstop servicebetween Colorado Springs and DCA. It is a large, underserved, market that needs and can support nonstop service. Frontier'sproposal would fill this critical air service void. Itwould also compete vigorouslywith the current nonstop service from Dulles International and one-stop connecting flights which Colorado Springs-DCA passengers are required to use because ofthe current lack ofnonstop service. Colorado Springs is Colorado's second largest city and the home to some ofthe U.S. military's largest and most important installations like Fort Carson (one ofthe largest U.S. Army installations in the world with more than 30,000 assigned personnel), Peterson AirForce 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 theU.S. AirForceAcademy. Colorado Springs is home to many organizations that have national significance. Because ofthe proximityto the numerous military installations in the areamany 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 OlympicTraining Centerprograms.Both USOC member organizations known as national govemingbodies 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 ofthe 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 offerthe public expanded service and more travel options that would extend beyond the Washington D.C. Metropolitan Area and Colorado Springs, byoffering 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 ofColorado Springs, as well as the tens ofthousands ofmen and women inthe military stationed in the area, deserve this new service. Frontier's servicewould provide the nonstop service we need. Wehopethat your Department will seizethis opportunity and reduce this service deficiency by awarding two slot exemptions to Frontier for Washington National- Colorado Springs- SanDiego service. Forthese reasons, our administration urges the Department to award Frontiertwo beyondperimeter slot exemptions for Colorado Springs-DCA service. Sincerely,

# Clf::omo~•**d.:tt:::c.<~~r'**
CC: Bill Hybl

## ATTORNrnYGENERALOFCOLORADO John W. Suthers

The HonorableRayLaHood Secretary ofTransportation U. S. DepartmentofTransportation 1200 NewJerseyAvenue, SE Washington, DC 20590 March 21, 2012

Re: ApplicationofFrontierAirlines for Two Beyond-PerimeterSlot Exemptions for Washington National-Colorado SpringsNonstop Service (DocketDOT-OST-2012-0029) DearSecretary LaHood: I'mwritingtoencourage the approval ofa direct flight for FrontierAirlines from Colorado Springs to ReaganNational Airport. I'mtheAttorney General ofColorado andreside in Colorado Springs. I travel to Washington, D.C. approximately once a month as part ofmyjobresponsibilities. I frequently leave ona Sunday orMondaymorning andwould welcome theopportunity to fly from Colorado Springsratherthan travelling to Denver.As it is, I often see many people from Colorado Springs on the always-full Denverflights and I knowthey also would lovethe chanceto fly from the Springs. Your consideration and approval ofthis newroute wouldbe greatly appreciated. Sincerely,

# :t:w~ Colorado Attorney General

State Services Building • 1525ShennanSlreet-7'hFloor • 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 NewJersey 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 letterserves to convey the strong support thatthe City ofColorado 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 forthe industry in our region. Frontier Airlines, ifsuccessful in this bid, would help grow Colorado Springs' business community, develop healthy competition within the airline markets ofthe region, retain employers in the region, and provide avalued service to local citizens. Thank you for your consideration ofthe Frontier Airlines' application.

Steve Bach Mayor

30 South Nevada Avenue, Suite 601 • TEL 7"19-385-5900 FAX 719-385-5488 MailingAddress: Post Office Box 1575, Mail Code 6'10 • Colorado Springs, Colorado 80901-1575March 20, 2012 The Honorable Ray LaHood Secretary ofTransportation U.S. Department ofTransportation 1200 NewJersey Avenue, SE Washington, DC 20590 

### SCOTT HENTE PRESIDENT

RE: Application ofFrontierAirlinesfor Two Beyond-PerimeterSlotExemptionsfor washington National-Colorado Springs Nonstop Service (Docket DOT-OST-2012-0029) Dear Secretary LaHood: The Colorado Springs City Council wholeheartedly supports the establishment ofnon-stop service between COS and DCA. This service would greatly enhance connectivity forthe business and travel communities, and promote a level ofcompetition that is not currently in the market. This proposed bid will serve as avalued benefitfor air passengers withinthe Colorado Springs area, the Pikes Peak Region, and beyond. This service would enable our citizensto 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 ofthis application of FrontierAirlines. We would greatly appreciate your support. Respectfully,



# Bv--

Scott Hente, President Colorado Springs City Council

c: City Council Mark Earle, Director ofthe 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 80901-1575State Representative JANAKJOSHI ColoradoStnte Capitol 200 East ColfaxAvenue, 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 HonorableRay LaHood Secretary ofTransportation U.S. Department ofTransportation 1200NewJersey Avenue, SE Washington, DC 20590 STATE CAPITOL DENVER

C0203 Member; Education Committee Finance Committee Health and Envmmment

Cmnminee

Re: Application ofFrontierAirlines forTwo Beyond-PerimeterSlotExemptions for WashingtonNational-Colorado Springs Nonstop Service (Docket DOT-OST-2012-0029) Dear SecretaryLaHood: My name is Janak Joshi and I have the honor ofrepresenting HouseDistrict 14, Colorado Springs, inthe Colorado House ofRepresentatives. Ithas cometo our attention thatFrontier Airlines has applied for two slot exemptions atthe Ronald Reagan Washington National Airport (DCA) to provide non-stop service to the Colorado Springs Airport (COS). Thisbid will serve as a valued benefit for airpassengers within the Colorado Springs area and beyond. Such a servicewould providejobs 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 ofnon-stop service between COS and DCAwould greatly enhance coi1Ilectivity for the business andtravel communities, and promote a level ofcompetition that is not currently in the market. 

### Please considerthese many opportunities thatwould greatly benefit my district, Colorado, and ournation. Sincerely, 

# _-'/,_
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# Qv JanakJos

- State Representative House District 14BILLL. CADMA..'l" State Senator Colorado StateCapitol

Denver, CO 80203 Office (719) 57D-9300 Capitol: (sos) 866-2737 billcadman.senate@state.co.us 

### SENATE STATE OF COLORADO DENVER SENATE MINORITYLEADER

The Honorable RayLaHood Secretary ofTransportation U.S. Department ofTransportation 1200NewJersey Avenue, SE Washington, DC20590 March26, 2012 COMMITIEES i'Vlemberof: Legislative Council Executive Committee ofLegislative Council

Re: Application ofFrontierAirlines forTwo Beyond-PerimeterSlotExemptions for Washington National-Colorado Springs Nonstop Service (Docket DOT-OST-2012-0029) DearSecretary LaHood: It is an honor to endorse the efforts ofFrontier 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 andbeyond. The establishment ofnon-stop service between COS andDCAvvill greatly enhance connectivity for the business and travel communities. This opportunity will promote a level of competition that isnotcurrentlyin the market. Itis mypleasureto wholeheartedly supportFrontier's efforts in creating this nonstop service.

Bill L. Cadman SenateMinorityLeader

# ELPASO COUNTY

COMMISSIONERS AMY LA THEN, CHAIR S,\I,Ll& CL.ARJ{, Vtct CUAUl 

## COLORADO
EL PASO BOARD OF COUNTYCOMl\USSIONERS

March 20, 2012

The Honorable Ray LaHood Secretary ofTranspiration US Department ofTransportation 1200 NewJersey Avenue, SE Washington, DC 20590 DENNIS HISEY DARRYL GLEt"''N PEGGY LITI'L&TON

Re: Application of FrontierAirlinesforTwo Beyond-PerimeterSlot 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 countywith 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 ofthe United States Air Force Academy, Fort Carson, NorthCom, Schriever AFB, Peterson AFB, and Cheyenne Mountain AirStation, ourarea generates a huge demand for airservice in andout 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 COlORADOSPRINGS,CO 80903 FAX: (719) 520-6397Non-stop service between Colorado Springs (COS) and Ronald Reagan Washington National Airport (DCA) would be a veryvaluable 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 thatwould 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 ofcompetition and greater convenience fortravelers throughout southern Colorado. The Colorado Springs Municipal Airport is a modern, highly efficient, facility with convenient access, from Interstate25 on the recently completed Milton Proby parkway. It has runways capable ofservicing all types ofaircraft 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 bestchoice and should be approved. Sincerely, on behalf ofall ofthe Board.

Amy Lathen El Paso County Commissioner Chair El Paso County Commissioner Liaison to the Colorado Springs Airport CommissionSOARD OF DIRECTORS OFFiCERS Comll'\b.tiolwSallie Qrk a ....eo""'l' eta.. ConwnbMou• OtMic Hite)t**-""~"·** EIP:oso<:o""'l' t•Vite O.Jr

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### March 23, 2012 

# Pikes Peak Area council of Governments communities working Together



### Re: Application ofFrontierAirlines for Two Beyond-PerimeterSlotExemptions for Washington National-Colorado Springs Nonstop Service (Docket DOT-OST-2012-0029) The Honorable RayLaHood Secretary ofTransportation U.S. DepartmentofTransportation 1200New JerseyAvenue, SE Washington, DC 20590 Dear Secretary LaHood: The PikesPeakArea CouncilofGovernments (PPACG) is a voluntary association of 16 municipal and county governments that serves as a forum of local governments to work on regionalissues.Among our many responsibilities, PPACG isresponsible for the production ofthe regional transportation planandthe certainregional planning efforts insupportofthe Pikes Peakarea's militaryinstallations. We recently learned thatFrontierAirlines has applied for two slot exemptions atthe RonaldReaganWashington NationalAirport (DCA) to provide non-stop service to the Colorado SpringsAirport (COS). Thisbid will serve as a valued benefitfor airpassengers within the PikesPeakregion and beyond. Providing non·stop DCA service wouldbe particularly beneficial to the five major militaryinstallationsthatlie atthe heartofoureconomy. As a regionalplanning agency that values the region's military members and installations and theirefforts to collaborate withlocal, state, andfederal agencies, non·profits, andother stakeholders, we fully supportFrontier Airlines' bid andurge you to awardthe exemption. Sincerely,

# daaee~ Sallie Clark, Chair Board ofDirectors Pikes PeakArea Council ofGovernments 15 S. 7th 

### Street Colorado Springs, CO 80905

I5 South 7th Street. Colon.doSprings. 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 OfTransportation 1200 NewJersey Ave SE Washington, DC 20590-0001 

### BERNIE HERPIN COUNCILMEMBER

Re: Applicationoffrontier Airlines for Two Beyond-Perimeter Slot Exemptions for Washington National-Colorado Springs Nonstop Service (Docket DOT-OST-2012-0029) Dear

### Mr. Secretary: lthas come to my attention thatFrontier Airlineshas applied for two slot exemptions atthe Ronald Reagan Washington NationalAirport (DCA) to provide non-stop service to the Colorado Springs Airport (COS). Thisbid 

### will serve 

### as avalued benefit for airpassengers within Colorado Springs, the Pikes

### Peak Region, and SouthernColorado. As the second largest city, and largest county, in Colorado, this non-stop service between Colorado Springs and Washington, DC will greatly enhance airtravel to our region resulting in increased business and leisure travel. We are the proud home offivemilitary bases. This non-stop service will also benefit Department of Defense travelers. Irespectfully request your support for this request. This servicewill provide an economic benefitto our area and increase airtravel competition. Thankyou for considering myrequest. 

# ;;:,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 80901-1575The Honorable Ray LaHood SecretaryofTransportation U.S. DepartmentofTransportation 1200 New JerseyAvenue, SE Washington, DC 20590 March 23, 2012

Re: Application ofFrontierAirlinesforTwo Beyond-PerimeterSlot Exemptionsfor Washington National-coloradoSprings NonstopService (Docket DOT-OST-2012-0029) Dear Secretary LaHood:
on behalfofthe Colorado SpringsAirport Advisory Commission, 1am writing in strong support ofFrontierAirlines' applicationfortwo beyond-perimeterslot exemptionsto provide non-stop service betweenthe ColoradoSpringsAirport (COS) and Ronald Reagan Washington National Airport (DCA). This letter has the strongand unanimous support ofall Commission members. Frontier's proposalwould establishfirst time ever, non-stop service betweenColorado'ssecond largestcity and DCA. While theWashington D.C. metropolitan area is the top ranked destinationoutofCOS, ourpassengers have neverhad direct access to thecity's primary, close· in airport. The approval ofFrontier'sapplication would address this**lon~standlng** service deficiency and remove a constraintthathas affected ourbusiness and tourism economiesfor years. The lack ofnon-stop DCA service has been particularlyhard on thefive majormilitary installationsthatlie atthe very heartofoureconomy. ColoradoSpringsis home to Ft. Carson, Cheyenne Mountain Air ForceStation, SchrieverAir Force Base, Peterson Air Force Base and the United StatesAir Force Academy. Thesefacilities host a broad range ofcritical operational missions, and serveasthe headquartersfor majornational commandssuch as U.S. Northern Command, North American Aerospace DefenseCommand,

### u.s. Air Force Space Command and the U.S. Army Space and Missile Defense Command. The addition ofnon-stop COS..DCA service would provide much more efficientconnectivitybetweenthese essentialfac;)lities and our nation's capital. Military staffs now are ableto accessthe<:apitol area only1:hrough Denver and otherhubs, with the increased time and effort thatis required to dothat. We vigorously support Federal money-saving efficiencies such asthatrequested by this application. Forthe reasons outlined above, werespectfully requestthatthe DepartmentofTransportation give full and favorable consideration to FrontierAirlines' application. Sincerely,

Walter D. Miller, Chairman Colorado Springs AirportAdvisory Commission Colorado Springs, ColoradoThe Honorable RayLaHood SecretaryofTransportation U.S. DepartmentofTransportation 1200 NewJerseyAvenue, SE Washington, DC 20590 March 23, 2012

Re: Application ofFrontierAirlinesforTwo Beyond-PerimeterSlotExemptionsfllf'Washington National-ColoradoSprings Nonstop Service (Docket DOT-osr-:to12-oo29) DearSecretary LaHood: On behalfoftheColoradoSpringsAirportAdvisoryCommission,lamwriting in strong supportof FrontierAirlines' applicationfortwo beyond-perimetersloteXemptionstoprovide non'StOp serv.ice betweentheColoradoSprings Airport (COS) and Ronald ReaganWashington National Airport (DCA). Frontier's proposal would estabfishfirsttime ever, non-stop servJce between Colorado's second largest cityand DCA. WhiletheWashington D.C. metropolitan area istiletop ranked destination outofCOS, ourpassengers have neverha<;ldirect access tothecity'sprimary, clqse-in airport. The approvalof Frontier'sapplication would addressthis long-standing service deficient\' and remove 

### aconstraintthat has.affected our**bu~iness**andtourism**e~onomies**foryears. The lackofnon-stop.DCA service has beenparticularlyhardon thefive majormilitary installationsthat lie attheheartofoureconomy. ColoradoSpring£is home to Ft. Carson, Cheyenne MountainAirForce Station,.SchrieverAirforce Base, Peterson Airforce Base. andthe. UnitedStatesAir Force Academy; Thesefacilities hosta broad range Clfoperational missions, and serveasthe headquarters for major natlonal.c.ommandssuch as U.S. Northern Command, North American Aerospace.Detlmse Command, U.S. AirForceSpace Command and!heU.S. AfmySpace and MissileDefenseCommand
.. Presently, thenecessary 65+miledriveto DIA.to accomplish national defense related travel tothe capital, oft.en compoundedby thethreatoffrequentwe.atherproblemsalongtheroute,jeopardizesthe timely'conductof thatbusiness and places'thetraveler atunnecessary risk, The additionofnon·stop COS.,DtA service wquld provide greaterconnectivitybetweentheseessential facilities and ournation's capital, and wouldgreatlyenhance the overall efficiencyandeffectiveness ofournational defense effort. Forthereaso!)s o!Jtllned.**a~ove,**we respectfullyrequestthatthe.DepartmentofTransportation give.full and favorable considerationtoFrontierAirlines' application. Respectfully,

# ~·'*IJ~~ AndrewW. Biancur, Col. USAF(Ret.) AirportAavisory Commission Colorado:Sprlngs,

## co.

# EXHIBIT F9-A-43March 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 ourfull 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 militarycommands, 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 ofthattravel 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 thatyou 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



# __**j/8~~0** ,.--·

....**-·---~)** ·,**.::-~~** ·&**::"!~** <--.- ··-Ronald W. Yates Victor E. Renuart. Jr. If· General. USAF Retired General, USAF RE>tiredBoard of Dlrectas Doug Quimby Choir La Plato Commvnmes. Ire. Mike Jorgensen Vice-Chair Red NciJnclCadillac. 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 Palisode5at BroadmoorPak Steve Helbing Wefts Forgo Bank Chris Jenkins Nor 'wood Development TomNeppl Splngs Fobncalion.lnc Sherr! Newell ColcradoSplngs Utilities Kevin O'Neil lheO'Neil Group Dove Polenchar EIPDnXYFOundcmon Venkat Reddy, Ph.D. UniversityofColcrado Colorado Splngs General "Gene" Renuart, USAF (Ret.) 

## THE CHAMBER ColoradoSplings Regional Economic DevelopmentCorporation 

## The Greater Colorado Springs Chamber & 

## EDC

March21.2012 The Honorable Ray LaHood Secretary ofTransportation U.S. Department ofTransportation 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) DearSecretary LaHood, The Military Affairs Council ofThe 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. Ourfive 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 ourattention that Frontier Airlines has applied for twoslot exemptions at the Ronald Reagan Washington National Airport (DCA) to provide non-stop service to the ColoradoSprings 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 ourfive military installations, and the great numberof aerospace/defense contractors in our region supporting our military. There are significant travel requirements to our nation's capital, notonly 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 efficientoption 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.

Chamber719-635-1551: 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 

# -------------------------THECHAMBER """""""'"'"''"""''" - "''' ,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: 6s. Tejon Slreef Suite 700 EDC 719-471-8183: 102 s. Tejon Street Suite 430 Colorado Springs, Colorado 80903William 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, USArmy (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 ofTransportation U.S. Department of Transportation 1200 New Jersey Avenue SE Washington, DC 20590 Dear Secretary LaHood, I am writing on behalf ofThe 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 ofthe 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 itwill 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 GRATIAMarch 16, 2012
The Honorable Ray LaHood Secretary ofTransportation NATIONAL HOMELAND DEFENSE FOUNDATION"' Securing the Future of Liberty"' General Gene Renuart (USAF, ret) Chairman of the Board

U.S. Department ofTransportation 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 oftravel for all citizens ofthe Colorado Springs greater area. I urge you to approve the Frontier application on Docket DOT-OST-2012-0029. Sincerely,

Gene Renuart, Chairman ofthe Board

1259 Lake Plaza Drive Suite 250

Colorado Springs, CO 80906 www.nhdf.orgCERTIFICATE 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 ofthe 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