BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

In the Matter Of 

Establishment of Slot Exemption Proceedings 

At Ronald Reagan Washington National 

Airport Pursuant to 49 U.S.C. S 41718 

) 

) 

) 

) 

) 

 Docket OST-2012-0029 

COMMENTS OF THE PORT OF PORTLAND 

IN SUPPORT OF APPLICATION OF ALASKA AIRLINES, INC. FOR EXEMPTION 

TO PROVIDE NONSTOP SERVICE BETWEEN PORTLAND, OREGON AND 

WASHINGTON REAGAN NATIONAL AIRPORT 

Communications with respect to this document should be addressed to: 

Bill Wyatt, Executive Director 

Tom Imeson, Public Affairs Director 

Rick Finn, Federal Affairs Manager 

Port of Portland 

7200 N.E. Airport Way 

Portland, OR 97208-3529 

Rick.finn@portofportland.com

 

March 27, 2012
1 

BEFORE THE 

DEPARTMENT OF TRANSPORTATION 

WASHINGTON, D.C. 

March 27, 2012 

In the Matter Of 

Establishment of Slot Exemption Proceedings At Ronald 

Reagan Washington National Airport Pursuant to 49 

U.S.C. S 41718 

) 

) 

) 

) 

) 

) 

 Docket OST-2012-0029 

COMMENTS OF THE PORT OF PORTLAND 

IN SUPPORT OF APPLICATION OF ALASKA AIRLINES, INC. FOR 

EXEMPTION TO PROVIDE NONSTOP SERVICE BETWEEN PORTLAND, 

OREGON AND WASHINGTON REAGAN NATIONAL AIRPORT 

The Port of Portland (“Port”) is pleased to submit these comments in strong support 

of the Application of Alaska Airlines, Inc. (“Alaska”) to provide nonstop service between 

Portland International Airport (“PDX”) and Washington D. C.’s Reagan National Airport 

(“DCA”) with two of the eight (8) beyond-perimeter slot exemptions at issue in this docket. 

The PDX-DCA market is the largest O&D market without current or announced 

nonstop service in this case. It is also the fastest growing DCA market and it is the first 

choice of Alaska Airlines. Alaska proposes to provide nonstop service with a state-of-theart B737-800 aircraft, the largest aircraft proposed by the applicant carriers, and Alaska will 

reduce PDX-DCA average fares by 18%.1

 

Grant of Alaska’s application for PDX-DCA nonstop service would be an important 

step toward redressing the serious and longstanding service deficiencies between Portland 

 

1 Exhibit AS-D-10
2 

and Washington, D. C. PDX currently has only one daily nonstop flight to the Washington 

area to accommodate an O&D market of 268,122 passengers. 

The Department will select carriers to operate four (4) new beyond-perimeter 

services nonstop from a list of eight (8) cities included in the carrier applications. PDX 

should clearly be one of the four selected. As shown below, not only does PDX meet all of 

the criteria set forth in the instituting order, it ranks in the top four (or higher) when 

measured against the other seven (7) proposed cities. 

I. PDX HAS A STRONG RECORD OF SERVING THE PUBLIC THAT WILL 

BENEFIT THE PDX-DCA MARKET 

The Port of Portland owns and operates Portland International Airport as well as two 

general aviation airports. PDX is the 26th largest passenger airport and the 26th largest 

cargo airport in the United States. The Port also owns four marine terminals and five 

industrial parks. The most recent economic impact study shows that the Port generated 

26,370 jobs, $1.7 billion in income, and more than $4 billion in business revenue. 

In 2011, PDX served 13.7 million passengers and has enjoyed 19 consecutive 

months of traffic increase. PDX connects Oregon and southwestern Washington to 58 

airports around the world. The airport will have 246 scheduled passenger departures daily 

this summer. Twelve scheduled domestic and international passenger airlines and eight allair cargo carriers serve PDX.2

 

The PDX service area extends far beyond the 2.2 million people in the Portland 

metropolitan area. PDX draws a large number of passengers from Vancouver and Southwest 

 

2 Exhibit PDX - 1
3 

Washington and serves a capture region of more than 3.5 million people in two states. 

PDX is the primary Oregon airport accounting for 87% of all origin-destination passengers 

of the State of Oregon.3

 

In 2004, PDX became only the 12th U.S. metro area to support nonstop service 

across both the Atlantic and the Pacific oceans. Eight years later, PDX is one of only 13 

cities that will have daily nonstop service across both oceans this summer.4 Among these 13 

cities, however, PDX is the only one without nonstop access to DCA.5

 PDX has better 

access to capitals in Europe and Asia than it does to DCA. 

The PDX routes to Europe and Asia were the result of long-term planning by the 

Port, the State and the community to secure air service vital to the growth and prosperity of 

the PDX region. The Port and community identified the strategic air service interests of the 

region and then committed the time and resources with a “whatever it takes” attitude. The 

Port has followed this approach for the last 10 years with great success. 

Following the successful efforts to attract service to Europe and Asia, DCA nonstop 

service became the top air service priority at PDX. The Port worked closely with Alaska 

Airlines and with the Oregon congressional delegation for years promoting expanded 

beyond-perimeter service between PDX and DCA. 

PDX has received numerous citations and awards for customer service, airport 

operations, and concession programs. Conde Nast Traveler magazine named PDX the best 

U.S. airport in four recent annual polls of business travelers. The Airline Pilots Association 

 

3 Exhibit PDX - 2 

4 Exhibit PDX - 3

5 Exhibit PDX - 4 
4 

(ALPA) named PDX “Airport of the Year” in 2010. Also in 2010, Zagat Survey named 

PDX their favorite U.S. airport based on overall quality. The award-winning PDX 

concessions program features the best of local, regional, and national shops and restaurants. 

The airport offers travelers more than 80 shops and restaurants, which are open 365 days a 

year. A vibrant arts and entertainment program enriches the airport experience.6

 

 The PDX environmental department is a leader in wildlife hazard management, 

noise management, and waste reduction and recycling. Since the food waste composting 

program began in 2003, PDX passengers, tenants, and employees have collected more than 

2,175 tons of food waste. PDX is expanding its state-of-the-art system for collecting and 

managing deicing runoff. Nearly 90 PDX vehicles run on natural gas, or biodiesel B-20. 

The Portland service area and the State of Oregon have a deep and extensive 

community of interest with Washington, D.C. Exhibit PDX - 6 lists a selection of 

companies and organizations that would benefit from PDX-DCA nonstop service. 

II. THE DEPARTMENT SHOULD AWARD TWO EXEMPTION SLOTS TO 

ALASKA AIRLINES TO OPERATE PDX-DCA NONSTOP SERVICE 

The PDX-DCA market meets all the criteria set forth in the instituting order for 

beyond-perimeter slot exemptions. PDX has addressed these criteria in order of proposed 

importance. 

 

6 Exhibit PDX - 5 
5 

II. A. Produce public benefits, including lower fares, higher capacity, and a 

variety of service options 

The clearest measure of public benefits is the number of passengers that will have 

nonstop service for the first time. The larger the market, the greater the potential is for 

public benefits. 

PDX-DCA is the largest O&D market among the five proposed airports that do not 

have current or announced nonstop service: 

Proposed Airport O&D Passengers 

PDX 95,797 

AUS 85,383 

SJU 53,982 

COS 31,443 

YVR * 

Source: Exhibit PDX - 7 

PDX is almost twice the size of San Juan (SJU) and over three times the size of 

Colorado Springs (COS). The restricted DOT international O&D database shows that PDXDCA is many times the size of Vancouver, B. C. (YVR) and while we have no information 

in the record regarding foreign flag travel, the PDX-DCA O&D is certainly far larger than 

YVR-DCA O&D. 

The remaining three proposed airports, Las Vegas (LAS), San Francisco (SFO), and 

San Diego (SAN) have or will have nonstop service. LAS has had nonstop service since 

2007 and its traffic numbers include the effect of nonstop service while those of PDX do 

not. SFO will have nonstop service starting May 14 from United Airlines7

 and SAN will 

 

7 Notice of Intent of United Air Lines, Inc., February 27, 2012 to institute nonstop service from San 

Francisco to Washington Reagan National on May 14, 2012. 
6 

have nonstop service starting June 8 from US Airways.8 LAS, SFO, and SAN are 

proportionately smaller than PDX on an O&D passenger per frequency basis.9

 

Alaska has quantified the public benefits of its PDX proposal to be $5.5 million 

annually. Applicant carriers have quantified the public benefits for three other proposed 

airports – AUS, COS10, and SAN.11 There are no quantitative estimates of public benefits in 

the record for SFO, YVR, SJU, or LAS. It is instructive to note that three of the proposed 

airports for which quantifiable estimates have been provided were also the three largest 

DCA markets without nonstop service at the time of filing. Clearly, market size is the 

primary driver of public benefits and compels the selection of PDX as one of the 

Department’s four selections. 

The latest reported O&D passenger data most likely understate the size of the PDX 

market in 2012 relative to the other proposed cities. Last year the PDX-DCA O&D market 

grew 16%.12 Since 2009, DCA has been PDX’s fastest growing market with a 34% 

increase in O&D passengers.13 The PDX-DCA O&D market has grown faster than any 

 

8 Notice of US Airways, Inc. of Beyond Perimeter Service (SAN-DCA), March 21, 2012 begin 

nonstop service from Washington Reagan National Airport to San Diego on June 8, 2012. 

9 Exhibit PDX- 8 

10 While PDX takes no position on the validity of the carrier estimates, the COS estimate does not 

appear comparable to Alaska’s for PDX. If the entire COS-DCA O&D base flew free, the resulting 

fare savings would be only 56% of the amount claimed. 

11 Alaska’s estimate for SAN was submitted prior to US Airways’announcement of SAN-DCA 

nonstop service. The incremental benefits of a second flight will be smaller than Alaska’s original 

estimate. 

12 Exhibit PDX - 9

13 Exhibit PDX - 10
7 

other DCA market at issue.14 Indeed, PDX-DCA passenger growth has been far higher than 

the average growth rate for all PDX markets and all DCA markets.15 As PDX’s growth 

further separates PDX from the crowd, so will the public benefits of PDX-DCA nonstop 

service further elevate the rationale for selecting PDX. 

Lower Fares - Alaska Airlines has proposed fares for PDX-DCA that will lower the 

cost of travel by an average of $53 per passenger ($106 roundtrip) or 18 percent. PDX 

believes Alaska has demonstrated that it will do what it says. 

The PDX-DCA market offers more opportunity for fare savings than other proposed 

cities. For example, DCA is already Washington’s low-fare airport for SFO.16 Not only is 

the SFO-WAS market the only WAS market in this case where the DCA average fare is 

lower than the BWI fare, it is 14% lower. 17 

Higher Capacity -- Alaska has proposed PDX service with the state-of-the-art 

Boeing 737-800 aircraft. It is the largest aircraft proposed for service in this case. 

 Aircraft City Seats 

B737-800 PDX, AUS, SAN 157-175 seats 

 A320 SJU, COS 150-168 

 B737-700 LAS 129 

 A319 SFO, YVR 119-120 

 

14 Exhibit PDX - 11 

15 Exhibit PDX - 12 

16 Exhibit PDX - 13 

17 Exhibit PDX - 14
8 

 E190 AUS 100 

In terms of seats, the only proposed aircraft with more seats than Alaska’s B 737-800 

are single-class proposals. 

Alaska’s proposed service will increase the seats in the PDX-WAS market by 131%. 

The next highest service increase at a proposed airport is only 36%.18 Alaska’s added 

capacity to the PDX-WAS market will have a far greater market impact than would the 

capacity proposed for the other points. 

II. B. Alaska’s proposal will enhance options for nonstop travel to/from PDX 

While any new or additional nonstop flight enhances nonstop travel options, the 

degree of enhancement will depend on the extent a market is served prior to the new service. 

In this case, three proposed cities, LAS, SFO, and SAN have or will have nonstop service to 

DCA, so the opportunity for enhanced options is de minimis relative to PDX which has no 

nonstop DCA service. 

Similarly, Colorado Springs (COS) has access to nonstop DCA service via Denver 

International Airport (“DEN”) which has four (4) daily DCA roundtrip nonstop flights. 

Colorado Springs is virtually surrounded by the Denver metropolitan area and is located 

only 90 minutes from DEN. 19

Two other airports,20 while not having nonstop access to DCA, have far more 

nonstop access to the Washington area airports compared to PDX which has only one flight 

 

18 Exhibit PDX - 15 

19 Exhibit PDX - 16

20 Austin and San Juan
9 

to one Washington, D.C. airport. Both have nonstop service to both IAD and BWI with 

total roundtrips ranging from three to five per day.21 

Vancouver, B. C. is the only proposed point that does not currently have any nonstop 

service to the Washington D. C. area but there is a reason for this condition: YVR-IAD 

nonstop service failed in the marketplace. The last full 12 months of nonstop service 

averaged only 83 passengers per flight including flow and produced an unsustainable 68% 

load factor.22 Seasonal summer service was attempted in 2008, but has not been tried again. 

As noted above, the reported YVR-DCA O&D is quite small and there has been no other 

evidence of market size submitted. 

Finally, DCA is a more important market for PDX than it is for the other candidate 

airports. DCA is PDX’s second largest O&D destination without nonstop service23 and as 

shown above, its fastest growing. Not only is DCA the largest component of the PDX-WAS 

market24, but it is the fastest growing component.25 DCA accounts for 36% of PDX’s 

Washington area travel – more than any of the other airports.26 PDX is the only airport 

proposed for DCA nonstop service where the DCA O&D passengers are greater than the 

O&D passengers at either Dulles or BWI.27

 

21 Exhibits PDX - 17 and 18 

22 U.S. DOT T-100 for year ended September 30, 2007

23 Exhibit PDX - 19

24 Exhibit PDX - 20

25 Exhibit PDX- 21 

26 Exhibit PDX - 22

27 Exhibit PDX - 23
10 

In short, nonstop service to DCA from PDX has a significantly greater potential for 

enhancement of travel than nonstop service to the other seven airports. 

II. C. PDX-DCA nonstop service will introduce nonstop competition in the 

PDX-WAS market 

PDX-DCA nonstop service would have an enormous competitive impact on the 

PDX-WAS market which has been starved for capacity for years. PDX’s lone nonstop flight 

(at Washington Dulles) has operated with a 12-month moving average load factor that has 

hovered around 90% since 2006.28 Further, over half of the PDX-IAD capacity is being 

occupied by flow passengers.29 There are over five PDX-WAS O&D passengers for every 

seat available to local PDX-WAS passengers.30 Currently only 15% of the O&D passengers 

in the PDX-WAS (IAD, DCA, and BWI) market are able to use nonstop service while 

228,000 PDX-WAS O&D passengers were forced to connect via intermediate hubs.31 In the 

last year, PDX-IAD seat capacity has been reduced almost 10% while the latest average fare 

has risen over 10% (3rd quarter 2011 over 3rd quarter 2010).32

The PDX-WAS market is ripe for competition and the competitive impact of 

Alaska’s proposed DCA nonstop will have a greater competitive effect than would DCA 

nonstop service at the other proposed airports. 

 

28 Exhibit PDX - 24

29 Exhibit PDX - 25

30 Exhibit PDX - 26 

31 Exhibit PDX - 27

32 U.S. DLT O&D Survey 
11 

II. D. Alaska’s PDX-DCA nonstop service will increase competition in multiple 

markets

Alaska’s PDX-DCA will bring much needed competition to the PDX-WAS market 

as shown above. Alaska’s service to ten points behind PDX will increase competition for 

each of the points to DCA with services now provided by Delta via Salt Lake City and 

United via Denver or San Francisco. 

II. E. Provide air transportation with domestic network benefits beyond the 

1,250 mile perimeter

The Alaska Airlines network at PDX is extensive and well-developed. Alaska 

provides service in 33 PDX markets, 10 of which are logical flow points.33 Alaska 

continues to build its PDX network and in the last 12 months has added or increased PDX 

service to Maui, Long Beach, Spokane, Boise, Bozeman, Santa Barbara, Anchorage, 

Ontario, and Bellingham. 

By contrast, four of the eight proposed airports simply do not have domestic network 

benefits. Any network benefit for YVR is international, not domestic. The applicant 

carriers for SFO and LAS have no logical flow point at either airport. The claimed network 

benefits for COS are illusory since all but one of its flow points have nonstop service to 

DCA,34 and the one exception (PDX) is the largest DCA market without nonstop service 

and is a candidate to secure nonstop service in this case. The points beyond COS would 

realize little or no benefit from a COS service. 

 

33 Exhibits AS-D-4 and AS-D-5

34 Exhibit PDX - 28
12 

II. F. Alaska’s PDX-DCA nonstop service will not reduce travel options for 

small and medium communities within the perimeter

PDX is 1,100 miles beyond the perimeter and does not have nonstop access to any 

small or medium community with inside-the-perimeter service. All significant PDX-DCA 

passenger routings are via large hubs or intermediates outside the perimeter and all are over 

highly congested segments.35 PDX-DCA nonstop service will alleviate load factor pressure 

and increase travel options in the intermediate markets. 

II. G. Alaska’s PDX-DCA nonstop service will not result in meaningful 

increased travel delays

Alaska’s PDX proposal will not result in meaningful increased travel delays. 

Alaska’s arrival and departure times at PDX are well-timed and are outside the peak airport 

hours. The arrival and departure times at DCA are slot controlled. 

************************** 

For the first time in eight years the Department has the opportunity to open DCA, the 

close-in Washington D.C. airport, to new cities located more than 1,250 miles from DCA. It 

is unknown when, or if, such an opportunity will occur in the future. Thus it is vitally 

important that the Department select the four new routes with the most public benefits. 

 PDX should be one of the four selected services. It is the second largest O&D 

market without current or announced nonstop service in this case and it is the first choice of 

Alaska Airlines. PDX has a compelling need for more Washington service that DCA 

 

35 Exhibit PDX - 30 
13 

service will address. PDX should have its first nonstop access to DCA before (1) other 

smaller markets and (2) other airports have their second, third or more access to DCA. 

 PDX takes no position with respect to the grant of other slot exemption requests 

provided Alaska’s PDX-DCA application is granted. Alaska and PDX have shown that PDX 

meets and surpasses the criteria for routes selection set forth in the instituting order. Indeed, 

PDX ranks in the top four or better in all of the criteria. 

Respectfully submitted, 

______________________________ 

Bill Wyatt 

Executive Director
14 

CERTIFICATE OF SERVICE 

 I hereby certify that one copy of the foregoing Comments has this day been served 

on all parties identified on the attached service list via e-mail unless otherwise noted. 

anita.mosner@hklaw.com 

marshall.sinick@squiresanders.com 

edward.sauer@squiresanders.com 

john.varley@virginamerica.com 

jegillick@zsrlaw.com 

jhfoglia@zsrlaw.com 

robert.cohn@hoganlovells.com 

patrick.rizza@hoganlovells.com 

robert.land@jetblue.com

jhill@dowlohnes.com

perkmann@dowlohnes.com

john.fredericksen@suncountry.com 

bob.kneisley@wnco.com

leslie.abbott@wn.com

esta.rosenberg@dot.gov

brian.ctr.meehan@faa.gov 

susan.kurland@dot.gov

todd.homan@dot.gov

james.dann@dot.gov 

john.potter@mwaa.com

info@airlineinfo.com

fbavent@airlineinfo.com

/s/ Rick Finn 

Rick Finn 
TABLE OF EXHIBITS 

Exhibit Name Exhibit No. 

i 

PDX Serves 58 Destinations Worldwide ............................................................................... 1 

PDX Accounts for 87% Of All Oregon O&D Traffic ........................................................... 2 

PDX Is One Of Only 13 Metro Areas With Daily Nonstop 

Service Across Both The Atlantic And Pacific Oceans ......................................................... 3 

Portland Is The only Major City On The West Coast 

Without DCA Nonstop Service ............................................................................................. 4 

Portland International Airport (PDX) Awards ...................................................................... 5 

There Is A Strong community Of Interest Between PDX 

And Washington, D.C. ........................................................................................................... 6 

PDX Is The Largest DCA O&D Market In This Docket 

Without Current Or Announced Nonstop Service ................................................................. 7 

PDX-DCA O&D Passengers Are First Among All Proposed 

Airports When Weighted For Current and Announced Service ............................................ 8 

PDX-DCA Passengers Are Up 16% Year Over Year ........................................................... 9 

DCA Has Been PDX’s Fastest Growing Market (Of PDX’s 

Top 50 O&D Markets) ......................................................................................................... 10 

PDX Is The Fasted Growing DCA Market Among The Airports 

Proposed For DCA Service ................................................................................................. 11 

PDX-DCA Growth Has Far Outpaces The DCA And PCS Airport 

Averages .............................................................................................................................. 12 

DCA Is Already The Low-Fare Alternative For The SFOWashington, D.C. Market .................................................................................................... 13

SFO Is The Only Proposed DCA Market With DCA Fares 

Lower Than BWI Fares ....................................................................................................... 14

DCA Nonstop Service Will Have The Greatest Impact On PDX ....................................... 15 

DEN Already Serves Much Of The Same Market As COS ................................................ 16 

PDX Has The 2nd Least Nonstop Flights To The Washington Area .................................. 17 

PDX Has The 2nd Least Nonstop Capacity To The Washington Area ............................... 18 
TABLE OF EXHIBITS 

Exhibit Name Exhibit No. 

ii 

DCA Is PDX’s 2nd Largest O&D Market Without Nonstop 

Service ................................................................................................................................. 19 

DCA Is The Largest Component Of The PDX-WAS Market ............................................. 20 

DCA Is The Fastest Growing Component Of The PDX-WAS 

Market ................................................................................................................................. 21 

DCA Is A More Important Component Of The PDX-WAS O&D 

Market Than It Is Of The Other Proposed Routes ............................................................... 22 

PDX Is The Proposed DCA Airport Where DCA O&D Is Greater 

Than IAD Or BWI ............................................................................................................... 23 

PDX-IAD Load Factors Have Been At Capacity For Years ............................................... 24 

Over Half Of PDX’s Limited Washington Nonstop Seats Are 

Occupied By Flow Passengers ............................................................................................. 25 

There Are Over Five PDX-WAS O&D Passengers For Every 

Seat Available To Local Passengers .................................................................................... 26 

Only 15% Of PDX-WAS Passengers Are Able To Use Nonstop 

Service27 

Network Benefits For COS Are Illusory ............................................................................. 27 

Over 80% Of Current PDX-DCA Passengers Are Forced Over 

High Load Factor Segments ................................................................................................ 28 
PDX Serves 58 Destinations Worldwide

Source: Innovata, week of June 11, 2012.

.

Docket DOT-OST-2012-0029

Exhibit PDX-1

Page 1 of 1

Key PDX Facts

● 13.7 million passengers in 2011

● 246 daily flights for summer 2012 to 58 destinations

● One of 13 U.S. airports with daily nonstop service across

both Atlantic and Pacific oceans

BLI BLI BLI BLI

SEA SEA SEA

YVR

LAS

BUR ONT ONT

LGB

STS

OAK

SFO

MFR

SJC SJC SJC

SBA

SAN

LAX SNA

ORD

IAD

JFK

EW R

PHL PHL PHL PHL

PDX BZN BIL BIL BIL BIL RDM RDM

OTH

To KOA To KOA

To NRT To NRT To NRT

To AMS

To HNL To HNL To HNL

To OGG

ANC

ABQ

ATL ATL ATL

BOI BOI BOI BOI

BOS

CLT CLT CLT CLT

COS

DEN

DFW DFW

DTW

EUG

FAT FAT FAT FAT

GEG GEG GEG

IAH

LMT LMT LMT LMT

MCI MCI MCI MCI

MDW MDW MDW

MSO

MSP

PDT PDT PDT PDT

PHX PSP

RNO

SLC

SMF SMF SMF SMF

YKM

YYC

YYZ YYZ YYZ YYZ
PORTLAND PORTLAND PORTLAND

Klamath Falls Klamath Falls Klamath Falls

Medford Medford Medford

North Bend North Bend North Bend

Redmond Redmond Redmond

Eugene Eugene Eugene

Newport Newport Newport

Salem

Pendleton Pendleton Pendleton

Astoria Astoria Astoria

PDX Accounts for 87% of All Oregon O&D Traffic

Source: O&D Survey, YE 2011 Q3.

.

Docket DOT-OST-2012-0029

Exhibit PDX-2

Page 1 of 1

All Other

13%

PDX

87%
PDX is One of Only 13 Metro Areas With 

Daily Nonstop Service Across Both the Atlantic 

And Pacific Oceans

Source: Innovata, week of June 11, 2012; and American Community Survey, 2010.

Docket DOT-OST-2012-0029

Exhibit PDX-3

Page 1 of 1

22,111,682

17,920,862

9,699,178

8,605,658

7,569,282

7,487,912

6,762,256

6,082,028

5,638,509

5,213,991

4,210,504

3,622,591

2,241,913

New York City

Los Angeles

Chicago

Washington, D.C.

Boston

San Francisco

Dallas/Ft. Worth

Houston

Atlanta

Detroit

Seattle

Minneapolis/St. Paul

Portland

Metro Area Population

YES

YES

YES

YES

YES

May 2012

YES

YES

YES

YES

YES

YES

NO

DCA Nonstop

Service
Portland Is The Only Major City On The West Coast 

Without DCA Nonstop Service

SEA

DCA

PDX

LAX

SAN

SFO

Docket DOT-OST-2012-0029

Exhibit PDX-4

Page 1 of 1

Source: Innovata, week of June 11, 2012.

.
Docket DOT-OST-2012-0029

Exhibit PDX-5

Page 1 of 1

Portland International Airport (PDX) Awards

2012

2012:  Best Concessions Management Team ‐‐ Awarded by Airport Revenue News

2012:  Best New Food Concept (Beaches Restaurant) ‐‐ Awarded by Airport Revenue News

2012 Best Retail Design (Nike) ‐‐ Awarded by Airport Revenue News

2011

2011: Safest US Airport ‐‐ Travel & Leisure magazine named PDX among the safest U.S. airports   

2011: ACI‐NA Environmental Award

2010

2010: Best US Airport ‐‐ Zagat Survey  

2010: Airport of the Year ‐‐ The Air Line Pilots Association, Int’l   

2010: On‐Time Performance Service Award ‐‐ FlightStats Performance Service Awards program.  

2010: Partnership Award ‐‐ PDX , the TSA, ACI‐NA and the AAAE received the Partnership Award for

their work together on an airport innovative security measures initiative.  

2010: ACI Environmental Achievement Award 

Other Awards

2010, 2008, 2007, 2006: Conde Nast Traveler magazine Best US Airport

The magazine named PDX the best U.S. airport four times, a result of their survey based on a poll of

business travelers.

2009:  The Frequent Traveler Award for Favorite Retail Store: (Powell’s Books)

Awarded by Airport Revenue News

2008: Best Customer Service Airport

Airport Revenue News (ARN) noted that Portland International Airport received the Best Customer

Service Award in the Medium Airports Division.

2007:  Best New Food Concept:  (Stanford’s Restaurant)

Awarded by Airports Council International
There Is A Strong Community Of Interest Between PDX 

and Washington, D.C.

Docket DOT-OST-2012-0029

Exhibit PDX-6

Page 1 of 2

PDX Metro 

Employees Type of Business

State of Oregon 18,400 State Government

Intel Corp. 15,636 Technology

Providence Health Systems 14,089 Health care and insurance

U.S. Federal Government 13,900 Federal government

Oregon Health & Science University 12,000 Hospital and university

Fred Meyer Stores 9,858 Retail merchandising

Legacy Health Systems 9,732 Nonprofit health care

Kaiser Foundation Health Plan of the NW 9,039 Health care 

City of Portland 8,876 City

Nike, Inc. 7,000 Athletic footwear and apparel

Portland School District 6,855 Education

Evergreen School District 6,448 Education

Multnomah County 5,797 County government

Wells Fargo 4,748 Financial services provider

Portland Community College 4,390 Community college

Beaverton School District 4,247 Education

Portland State University 4,066 College

U.S. Bank 3,899 Financial institution

Southwest Washington Medical Center 3,345 Full-service medical center

Xerox Corp. 3,300 Technology and services

Vancouver School District 3,224 Education

Portland General Electric 2,708 Power electric

The Standard 2,500 Insurance

Daimler Trucks North America 2,450 Heavy-duty/medium diesel trucks

TriMet 2,431 Transit

Additional Companies with business links in D.C.

Thetus Corp. Software firm

Harris Corp. Software firm

Tripware Software firm

McAfee Software firm

FLIR Infared Imaging cameras

Insitu Unmanned Aerial Vehicles (UAVs)

TravelPortland Tourism

TravelOregon Tourism

Portland Business Alliance Economic Development

Greater Portland Inc. Economic Development

Columbia River Economic Development Economic Development

City of Portland City government

City of Vancouver City government
There Is A Strong Community Of Interest Between PDX 

and Washington, D.C.

Docket DOT-OST-2012-0029

Exhibit PDX-6

Page 2 of 2

Washington DC Associations with Links to Oregon

American Physical Society

Institute of Navigation

American Pharmacists Association

Water Environment Federation

Teachers of English to Speakers of Other Languages

National Congress of American Indians

Ecological Society of America

American Wind Energy Association

American Association of Museums

National Forum for Black Public Administrators

American Geophysical Union

Oregon Consular Corps

Honorary Consul - Republic of Korea

Honorary Consul - Canada

Honorary Consul - Malaysia

Honorary Consul - Norway

Honorary Consul - Cyprus

Honorary Consul - Luxembourg

Honorary Consul - Belgium

Honorary Consul - Austria

Honorary Consul - Barbados

Honorary Consul - United Kingdom

Consul General of Japan Oregon

Deputy Consul General of Japan Oregon

Consul General of Mexico Oregon

Honorary Consul - The Netherlands

Honorary Consul - Thailand

Honorary Consul - Liechtenstein

Honorary Consul - Lithuania

Honorary Consul - Repulic of the Philippines

Honorary Consul - Romania
Docket DOT-OST-2012-0029

Exhibit PDX-7

Page 1 of 1

PDX is the Largest DCA O&D Market In This Docket 

Without Current or Announced Nonstop Service

City1 O&D Pax PDEW

Portland 95,796 131

Austin 85,382 117

San Juan, Puerto Rico 53,982 74

Colorado Springs 31,443 43

Vancouver 2 2

1Excludes announced service to SFO which starts May 14, 2012.

2Note: Air Canada did not supply traffic or fare data for YVR

in its application. The restricted U.S DOT data show

small traffic volumes.

Source: U.S. DOT, Origin-Destination Passenger Survey, year ended Q3 2011.
PDX-DCA O&D Passengers Are First Among All Proposed 

Airports When Weighted For Current and Announced Service

1

2

1

2

2

1

1

1

Total

1U.S. Origin-Destination Passenger Survey, YE 2011 Q3.

2Innovata-Diio, week of June 11, 2012. 

PDX

LAS

AUS

SFO

SAN

SJU

COS

YVR

Daily Nonstops2

Annual O&D Per

Daily Nonstop

Docket DOT-OST-2012-0029

Exhibit PDX-8

Page 1 of 1

95,797

176,9913

85,383

148,775

126,122

53,982

31,443

**

Current &

Announced Proposed

0

1

0

1

1

0

0

0

1

1

1

1

1

1

1

1

95,797

88,496

85,383

74,388

63,061

53,982

31,443

**

3Passengers reflect impact of LAS nonstop service (stimulation).

All other airport counts are before stimulation.

**Note: Air Canada did not supply traffic or fare data for YVR

in its application. The restricted U.S DOT data show

small traffic volumes.

DCA O&D

Passengers1
PDX-DCA Passengers Are Up 16% Year Over Year

0

10,000

20,000

30,000

40,000

50,000

60,000

70,000

80,000

90,000

100,000

Q4

02

Q1

03

Q2

03

Q3

03

Q4

03

Q1

04

Q2

04

Q3

04

Q4

04

Q1

05

Q2

05

Q3

05

Q4

05

Q1

06

Q2

06

Q3

06

Q4

06

Q1

07

Q2

07

Q3

07

Q4

07

Q1

08

Q2

08

Q3

08

Q4

08

Q1

09

Q2

09

Q3

09

Q4

09

Q1

10

Q2

10

Q3

10

Q4

10

Q1

11

Q2

11

Q3

11

12-Month Moving Total

Source: U.S. DOT, Origin-Destination Passenger Survey, YE 2011 Q3.

O&D Passengers

Docket DOT-OST-2012-0029

Exhibit PDX-9

Page 1 of 1
+23% +23%

+26% +27%

+34%

0%

5%

10%

15%

20%

25%

30%

35%

40%

DCA OGG JFK AUS KOA

DCA Has Been PDX’s Fastest Growing Market (Of PDX’s 

Top 50 O&D Markets)

(PDX O&D % Change from CY 2009 to YE 2011 Q3)

Source: U.S. DOT, Origin-Destination Passenger Survey, CY 2009 to YE 2011 Q3.

Docket DOT-OST-2012-0029

Exhibit PDX-10

Page 1 of 1

Rank in

Growth %1 2 3 4 5
-32%

-6%

+0.2%

+11% +6% +12%

+34%

-40

-35

-30

-25

-20

-15

-10

-5

0

5

10

15

20

25

30

35

40

PDX SFO AUS LAS SAN SJU COS YVR*

PDX Is The Fastest Growing DCA Market Among The 

Airports Proposed For DCA Service

(DCA O&D % Change from CY 2009 to YE 2011 Q3)

*Note: Air Canada did not supply traffic or fare data for YVR

in its application. The restricted U.S DOT international data show

small traffic volumes.

Source: U.S. DOT, Origin-Destination Passenger Survey, CY 2009 to YE 2011 Q3.

Docket DOT-OST-2012-0029

Exhibit PDX-11

Page 1 of 1
0%

10%

20%

30%

40%

PDX-DCA DCA - All Domestic PDX - All Domestic

PDX-DCA Growth Has Far Outpaced the DCA and PDX 

Airport Averages

Source: U.S. DOT, Origin-Destination Passenger Survey, T-100 Data, YE 2011 Q3.

Docket DOT-OST-2012-0029

Exhibit PDX-12

Page 1 of 1

34%

4%

9%
$0

$50

$100

$150

$200

$250

$300

DCA BWI IAD

DCA Is Already The Low-Fare Alternative For The SFOWashington, D.C. Market

Source: U.S. DOT, Origin-Destination Passenger Survey, YE 2011 Q3.

Docket DOT-OST-2012-0029

Exhibit PDX-13

Page 1 of 1

$197

$261

$228

Nonstop

Competition:          None UA/FL UA/VX
$0

$50

$100

$150

$200

$250

$300

SFO SJU COS/DEN LAS PDX AUS SAN YVR*

Docket DOT-OST-2012-0029

Exhibit PDX-14

Page 1 of 1

SFO Is The Only Proposed DCA Market With DCA Fares 

Lower Than BWI Fares

Average

Fare

DCA

BWI

*Air Canada did not supply traffic or fare data for YVR

in its application. The restricted U.S DOT international data show

small traffic volumes.

Source: U.S. DOT, Origin-Destination Passenger Survey, CY 2009 to YE 2011 Q3.
DCA Nonstop Service Will Have The Greatest Impact on PDX

3,878

7,886

10,534

14,502

17,826

35,980

49,892

Total

Seats

PDX

SJU

AUS

SAN

LAS

SFO

COS/DEN

%

Increase

Docket DOT-OST-2012-0029

Exhibit PDX-15

Page 1 of 1

1,680

5,786

8,084

12,304

16,020

34,300

47,540 

WAS Nonstop

Weekly Seats

Proposed DCA

Nonstop Weekly

Seats

2,198

2,100

2,450

2,198

1,806

1,680

2,352

131%

36%

30%

18%

11%

5%

5%

Source: Innovata, week of June 11, 2012 plus announced. 
DEN Already Serves Much of the Same Market as COS

Source: Nielsen Media Research

DEN

COS

Denver DMA

Colorado 

Springs 

DMA

Docket DOT-OST-2012-0029

Exhibit PDX-16

Page 1 of 1
PDX Has The 2nd Least Nonstop Flights To The Washington 

Area

110

42

52

28

40

28

▬

▬

BWI

Source: Innovata; week of June 11, 2012 plus announced. 

COS/DEN

SFO

LAS

SAN

AUS

SJU

PDX

YVR

Total

Docket DOT-OST-2012-0029

Exhibit PDX-17

Page 1 of 1

56 

14

14

14

▬

▬

▬

▬

DCA IAD

168

190

42

42

28

14

14

▬

334

246

108

84 

68

42 

14

▬

Total one‐way flights for week of June 11, 2012
PDX Has The 2nd Least Nonstop Capacity To The Washington 

Area

14,728

2,765

8,124

3,848

5,480

3,836

▬

▬

BWI

COS/DEN

SFO

LAS

SAN

AUS

SJU

PDX

YVR

Total

Docket DOT-OST-2012-0029

Exhibit PDX-18

Page 1 of 1

9,180

1,736

2,100

2,100

▬

▬

▬

▬

DCA IAD

23,632

27,034

5,796

6,356

2,604

1,932

1,680

▬

47,540 

34,300

16,020

12,304

8,084

5,786

1,680

▬

Total one‐way seats for week of June 11, 2012

Source: Innovata; week of June 11, 2012 plus announced. 
Docket DOT-OST-2012-0029

Exhibit PDX-19

Page 1 of 1

DCA Is PDX’s 2nd Largest O&D Market Without Nonstop 

Service

City O&D Pax PDEW

Orlando 131,364 180

Washington National 95,796 131

Austin 93,042 127

Baltimore 82,036 112

St. Louis 78,022 107

Source: U.S. DOT, Origin-Destination Passenger Survey, year ended Q3 2011.
DCA is the Largest Component of the PDX-WAS Market

PDX-WAS O&D Passenger Shares 

DCA

36%

BWI

30%

IAD

34%

Source: U.S. DOT, Origin-Destination Passenger Survey, year ended Q3 2011.

Docket DOT-OST-2012-0029

Exhibit PDX-20

Page 1 of 1

BWI

30%

IAD

34%

DCA

36%
0

20

40

60

80

100

120

140

160

180

200

Q4

04

Q1

05

Q2

05

Q3

05

Q4

05

Q1

06

Q2

06

Q3

06

Q4

06

Q1

07

Q2

07

Q3

07

Q4

07

Q1

08

Q2

08

Q3

08

Q4

08

Q1

09

Q2

09

Q3

09

Q4

09

Q1

10

Q2

10

Q3

10

Q4

10

Q1

11

Q2

11

Q3

11

12-Month Moving Total

DCA is the Fastest Growing Component of the PDX-WAS 

Market

BWI

IAD

DCA

Source: U.S. DOT, Origin-Destination Passenger Survey, YE 2011 Q3.

O&D Passenger Index

(Index CY 2004 = 100)

Docket DOT-OST-2012-0029

Exhibit PDX-21

Page 1 of 1
13%

17%

 36%

 34%

25%

22%

20%

0%

5%

10%

15%

20%

25%

30%

35%

40%

PDX COS AUS LAS SAN SJU SFO YVR*

DCA Is A More Important Component Of The PDX-WAS 

O&D Market Than It Is Of The Other Proposed Routes

DCA O&D as % of WAS (DCA/IAD/BWI) O&D

Docket DOT-OST-2012-0029

Exhibit PDX-22

Page 1 of 1

*Air Canada did not supply traffic or fare data for YVR

in its application. The restricted U.S DOT international data show

small traffic volumes.

Source: U.S. DOT, Origin-Destination Passenger Survey, YE 2011 Q3.
PDX Is The Proposed DCA Airport Where DCA O&D Is 

Greater Than IAD or BWI

Docket DOT-OST-2012-0029

Exhibit PDX-23

Page 1 of 1

PDX

AUS

COS

SAN

SJU

SFO

LAS

1st

2nd

3rd

3rd

3rd

3rd

3rd

Proposed DCA

Airport

DCA Rank Among

All WAS Airports

Source: U.S. DOT, Origin-Destination Passenger Survey, YE 2011 Q3.
0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

2006 112007 012007 032007 052007 072007 092007 112008 012008 032008 052008 072008 092008 112009 012009 032009 052009 072009 092009 112010 012010 032010 052010 072010 092010 112011 012011 032011 052011 072011 09

PDX – IAD Load Factors Have Been At Capacity For Years

12-Month Moving Average

Source: U.S. DOT, T-100 data, YE 2011 Q3.

PDX – IAD Average Load Factors

90%

Docket DOT-OST-2012-0029

Exhibit PDX-24

Page 1 of 1
Over Half of PDX’s Limited Washington Nonstop Seats 

Are Occupied By Flow Passengers

DCA

36%

BWI

30%

IAD

34%

Source: U.S. DOT, Origin-Destination Passenger Survey and T-100 data, year ended Q3 2011.

Docket DOT-OST-2012-0029

Exhibit PDX-25

Page 1 of 1

54%

46%

113,964 PDX-IAD Nonstop Seats

51,898 seats 

available for 

local 

passengers

62,066 seats 

occupied by 

flow 

passengers
0

50,000

100,000

150,000

200,000

250,000

300,000

O&D Passengers Nonstop Seats Nonstop Seats Less Flow

There Are Over Five PDX-WAS O&D Passengers For 

Every Seat Available To Local Passengers

PDX-BWI/IAD/DCA

Source: U.S. DOT, Origin-Destination Passenger Survey, T-100 Data, YE 2011 Q3.

Docket DOT-OST-2012-0029

Exhibit PDX-26

Page 1 of 1

268,122

113,964

51,898
Only 15% of PDX-WAS O&D Passengers Are Able To Use 

Nonstop Service

DCA

36%

BWI

30%

IAD

34%

Source: U.S. DOT, Origin-Destination Passenger Survey, year ended Q3 2011.

Docket DOT-OST-2012-0029

Exhibit PDX-27

Page 1 of 1

15%

85%

Via 

Intermediate =

227,856

IAD Single 

Coupon =

40,266
Network Benefits For COS Are Illusory

SEA

Source: Innovata, week of June 11, 2012.

COS

PDX

LAX

SAN

DEN

DCA

Docket DOT-OST-2012-0029

Exhibit PDX-28

Page 1 of 1

SEA 2

PDX 1 (Largest DCA O&D without nonstop service)

LAX 2

SAN 1 

DEN 4

Present or Proposed Daily Roundtrip DCA Nonstops
Over 80% of Current PDX-DCA Passengers Are Forced 

Over High Load Factor Segments

Source: U.S. DOT, Origin-Destination Passenger Survey, year ended Q3 2011.

Docket DOT-OST-2012-0029

Exhibit PDX-29

Page 1 of 1

ORD

30%

DEN

15%

DFW

5%

IAH

6%

SEA

9%

MSP

7%

PHX

6%

Other

18%

ATL

4%

ORD (UA)

DEN (UA/F9)

SEA (AS)

MSP (DL)

PHX (US)

IAH (CO)

DFW (AA)

ATL (DL)

91%

89%

▬

90%

▬

91%

92%

92%

▬

▬

93%

▬

89%

▬

▬

▬

PDX-DCA

Intermediate PDX Leg DCA Leg

Blocking Segment

PDX-DCA Routing Distribution