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March 28, 2012
Kathryn B. Thomson Chief Counsel Federal Aviation Administration 800 Independence Avenue, S.W. Washington, D.C. 20591

Re: FAA Exemption No. 7370F (FAA Docket No. FAA - 2002 - 13734) Republic Airline Inc.

Dear Ms. Thomson : Republic Airline Inc. (“Republic”) hereby respectfully requests that the Federal Aviation Administration (“FAA”) extend Exemption No. 7370F, issued on June 14, 2010, for an additional two

- year period. 1 Exemption No. 7370F grants Republic the right to use exemption slot number 1497 at Ronald Reagan Washington National Airport (“DCA”) until September 30, 2012

. All of the public interest justifications that supported the initial grant of Exemption No. 7370 nearly twelve years ago and its six subsequent extensions (A

- F ) remain fully valid today. Therefore, consistent with prior precedent, the FAA should renew Exemption No.
7370F and the corresponding slot number 1497.

1 The FAA’s letter granting Exemption 7370F stated that if Republic wished to seek a further extension of the exemption, it should submit its Petition for extension on or before March 30, 2012 . This request for extension is timely filed in response to the FAA’s directive

.- 2

- Ms. K. Thomson March 28, 2012

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- 3374501 v4 In further support of this request, Republic states as follows:
I. Back ground. 1. The FAA originally awarded DCA slot number 1497 to Braniff Airlines and subsequently to America West Airlines. The FAA, however, eventually withdrew it from America West for non

- use. It remained unused until the FAA granted the Petition of Midwest Express Airlines, Inc. for an exemption to use Slot 1497 for a two

- year period. See Exemption No. 7370, dated October 19, 2000.
2. The FAA has extended the exemption six times

– on December 23, 2002 (No. 7370A) for two years; February 15, 2005 (No. 7 370B) for several months; August 8, 2005 (No. 7370C) for two years; June 25, 2007 (No. 7370D) for two years; July 10, 2009 (No. 7370E) ; and June 14, 2010 (No. 7370F) for two y ears. Midwest was acquired by Republic Air ways Holdings, Inc. and pursuant to Exemption 7370F the FAA transferred the exempt ion to Republic Airline and extended it for another two years.
3. In each extension, in cluding the most recent one , the FAA concluded that “the justification for the issuance . . . remains valid and is in the public interest.” Republic continues to use the exemption to provide needed DCA service to Midwest
communities under the Frontier brand. The same public interest considerations supporting the previous six extensions apply with equal force to Republic’s current
extension r equest

.

II. Extension o f Exemption No. 7370F Is Fully Justified, In The Public Interest, and Consistent With Precedent.- 3

- Ms. K. Thomson March 28, 2012

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- 3374501 v4 1. Republic (and, before it, Midwest and Midwest Express) have consistently operated slot number 1497 under this exemption for service between communities in
the under

- served Midwest and Washington, D.C., except for the period when DCA was closed after the September 11 th terrorist attacks.
2. The exemption slot was initially used by Midwest for a nonstop DCA

– Kansas City flight

. Republic currently uses the exemption slot to provide a nonstop DCA

– Milwaukee flight unde r the Frontier brand, and will use it for nonstop DCA

– Madison service starting around June 7, 2012. The FAA Slot Administrator approved a temporary change in the time of slot exemption 1497 to 1700 for operational and scheduling reasons for the Summer 2012.
3. Republic holds and operates a very limited network of slots and slot exemptions at DCA under the Frontier brand, serving Milwaukee, Kansas City, Omaha, Grand Rapids, and Mad ison. Failure to extend the exemption would have a serious detrimental impact on Republic/Frontier’s very limited DCA service pattern.
4. Although s lot number 1497 is not tied to any particular DCA destination, Republic currently uses the Slot to provide n onstop service under the Frontier brand between DCA and Milwaukee. The exemption allows Republic to offer passengers a second daily roundtrip and thereby enhance competition between Washington, D.C., and Milwaukee, 2 where AirTran operates four daily nonst op flights at DCA and AirTran/Southwest operates three daily nonstop flights at BWI.

2 Effective April 16, 2012, Frontier will operate a single daily DCA

– Milwaukee roundtrip.- 4

- Ms. K. Thomson March 28, 2012

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- 3374501 v4 5. Extension of the exemption slot would permit Republic to operate the DCA
service under the Frontier brand and continue to provid e important pro

- consumer and
pro - competition benefits for local and connecting passengers traveling between the Nation’s Capital and Milwaukee and to points beyond.
6. On the other hand, failure to extend Exemption No. 7370F would force Republic either (i ) to eliminate 50% of its current nonstop DCA

– Milwaukee roundtrips (or 100% of its nonstop DCA

– Milwaukee service after April 16, 2012) , or (ii) in order to
maintain its current Milwaukee service , to use slots from another c ity such as Kansas City, Omaha or Grand Rapids/Madison

. 7. Taking slots currently deployed for service between DCA and another city would potentially eliminate 50% of its nonstop DCA

– Kansas City flights, or 50% of its DCA

– Omaha service , or 100% of its Grand Rapids/Madison service.
8. Either way, if the exemption is not extended and Republic is thereby forced to

cease using the S lot, it will require Republic to cease a DCA flight with the attendant adverse impact on leisure, business, and government passengers, the affected local
and be yond/behind communities, Republic’s limited DCA network, and inter

- carrier and
inter

- hub competition.
9. Exemption No. 7370F was granted and renewed six times because it was in the public interest. Republic continues to use this exemption slot under the F rontier brand to benefit Midwest communities as it was intended, and will continue to use the exemption to provide important consumer, competitive, and other public benefits. It- 5

- Ms. K. Thomson March 28, 2012

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- 3374501 v4 would also continue to support DCA’s operational efficiency without negativel y affecting safety. Accordingly, extension of the exemption continues to be in the public interest.

III. Conclusion. Republic requests that the FAA extend the termina tion date of Exemption No.
7370F for an additional two years or such period as the FAA may deem appropriate. Republic agrees to the conditions and li mitations in Exemption No. 7370F as part of any renewal or extension of this Exemption.
Sincerely yours,

______________ Robert E. Cohn Patrick R. Rizzi Counsel for Republic Airline Inc.