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OST-2000-7176

Establishment of Slot Exemptions Proceedings 

By:  Bradley Mims

The Wendall H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions)

Notice from April 14th

By:  Bradley Mims

Legend Airlines, Inc.

It is unfortunate that a carrier that once championed the rights of new entry and competition now raises objections to a new entrant carrier's application to obtain slots at high density airports, but, sadly, that is what America West Airlines, Inc. has done by filing an Answer opposing new entrant Legend Airlines, Inc.'s application for slots at Chicago O'Hare and LaGuardia. In the not so distant past, America West was an advocate of new entry and promoted public interest factors set forth by the Airline Deregulation Act.

Counsel:  Ungaretti Harris, Edward Faberman, 202.639.7500

Midwest Express Airlines, Inc.; The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

Midwest Express has been providing service to Kansas City since 1989. Currently, Midwest Express offers Kansas City nonstop and single plane service to six cities, as well as connecting service to 25 other points. The service Midwest Express offers Kansas City is absolutely essential to the economic well being of the community and allows Kansas City to compete with other communities for economic development opportunities. Kansas City is appreciative of the efforts Midwest Express has extended on our behalf as we recognize that Midwest Express has specialized in providing exceptional service from mid-continent cities to major business centers that other carriers do not choose to offer.

With regard to Washington's National Airport, Midwest Express has requested that DOT exercise its existing authority to retime one of the carrier's existing nighttime slots to make it a 7 a.m. slot. The movement of this slot will, along with other self help measures taken by Midwest Express, permit the carrier to not only offer daily nonstop Kansas City-DCA service, but as well, two new daily one stop single plane flights in the market. This flight schedule will increase the amount of single plane service capacity currently in the Kansas City-DCA market by 78 percent.

Counsel:  Kansas City Aviation, Russell Widmar, 816.243.3100

Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

• Legend is a new entrant that has no slots at LaGuardia.
• Legend will operate to Dallas Love Field Airport, providing service to the Dallas Fort Worth Metroplex with connecting service to Los Angeles and Las Vegas.
• All of Legend's aircraft are Stage 3 compliant.
• Legend requests 18 slot exemptions.

Counsel:  Ungaretti Harris, Edward Faberman, 202.639.7500

Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

Following Midway's filing of the exemption application, the FAA was able to ease the immediate crisis by making available to Midway two temporary slots through October 28, 2000. That action will enable Midway to maintain its LaGuardia operations for the immediate months. But it will not accommodate the longer term transportation needs of the LaGuardia-Raleigh/Durham market, both because the two temporarily extended slots remain subject to termination by their lessor as of October 29, 2000, and the lease for five of the other slots for Midway's existing operations at LaGuardia will terminate on March 31, 2001 (leaving Midway with only its own three slots as of April 1, 2001), and because it has been virtually impossible to expand operations to meet growing demand through the marketplace acquisition of slots. Accordingly, the basis for Midway's exemption application continues and the need for the requested slots remains critical.

Counsel:  Midway Airlines, Stephen Lachter, 20.862.4321

America West Airlines, Inc.

America West was compelled to file its initial application for the slot exemptions it seeks well before the April 5, 2000 enactment of Air 21 due to its inability to continue slot exchanges and leases from other major incumbents and their commuter affiliates at JFK and LGA. Loss of America West's JFK and LGA service would cause substantial harm to the travelling public currently relying on these America West flights, through reduced service options and higher fares. America West provides the only competitive service in the substantial LGA - Columbus market, virtually all the non-stop service in the Phoenix - JFK market, and much of the competitive service in the chronically underserved JFK - Las Vegas market. For example, America West's average JFK - Los Angeles fare is 50 percent lower than the two largest carriers in that market.

Counsel:  Baker Hostetler, Joanne Young, 202.861.1532

The Wendall H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions)

Order 2000-4-10-Erratum on page 2, in the first paragraph in the Decision section, in lines 8-9, the text reads as "...fewer than 20 slots and slot exemptions at Chicago O'Hare Airport;..." The text should read as "...fewer than 20 slots exemptions at New York's LaGuardia Airport;..."

By:  Bradley Mims

Pro Air, Inc.

Certification of Pro Air, Inc. certifying that it currently holds two slot exemption, which are operated at 1200 and 1230. In addition, Pro Air is currently using two slots granted to it on a temporary basis by the Federal Aviation Administration (the "FAA"), which are operated at 2100 and 2130. The two permanent slot exemptions that Pro Air holds are clearly less than the maximum of 20 slots and slot exemption allowed under 49 U.S.C. Section 41716(b). In addition, Pro Air has no code-share agreements with any other air carrier at LaGuardia Airport that would increase the number of slots and slot exemptions under 49 U.S.C. Section 41714(K).

Counsel:  Pro Air, Bradley Toney, 206.623.2000

American Trans Air, Inc. 

Counsel:  Squire Sanders, Marshall Sinick, 202.626.6651

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions)

Counsel;  Silverberg Goldman, Robert Silverberg, 202.944.3300, rsilverberg@sgbdc.com

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions)

Counsel:  GKMG Consulting, Mark Kahan, 703.312.1446

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions)

While it is true that both airports in Queens generate thousands of jobs and other economic benefits for residents of the county, it is also true that these residents must also bear the burdens resulting from close proximity to the airports, including aircraft noise, air pollution, safety risks, and increased levels of traffic congestion on the airports' access roads, on the airports' tarmacs and runways, and in the skies above and around Queens. These problems are exacerbated near LaGuardia, which is located in one of the most densely populated residential areas of all the airports in the nation.

For the reasons discussed herein, the Queens Borough President strongly opposes the recent orders of the United States Department of Transportation ("DOT"), enabling the addition of up to 608 additional flights at LaGuardia, and asks that DOT develop a plan to implement Air 21 in a more orderly and environmentally responsible way.

Counsel: Queens Borough President's Office, Hugh Weinberg, 718.286.2880

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions)

Legend requests that the Department deny the Borough's request to reconsider its orders. Considering that new entrants will control less than Five percent of LaGuardia slots, reconsideration would be a blow to competition and would undo the aims of Congress in FAIR-21.

Counsel:  Ungaretti Harris, Edward Faberman, 202.639.7500

Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

If the Department nonetheless considers the Borough President's "objections" as a petition for reconsideration, that petition should be denied. The Borough President's real complaint is that Congress has directed the Department to award slot exemptions for specified service with regional jets between LaGuardia and small-hub and non-hub cities and for service by new entrants using up to 20 slots. DOT and Congress did not "throw open the doors to LaGuardia" or "eviscerate the High Density Rule" (Objections at 6) before 2007.

Counsel:  Crowell Moring, Bruce Keiner, 202-624-2500

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions)

Counsel:  Silverberg Goldman, Robert Silverberg, 202.944.3300, rsilverberg@sgbdc.com

Counsel:  GKMG Consulting, Mark Kahan, 703.312.1446

Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

The Delta Connection carriers, including Comair, Inc., Atlantic Southeast Airlines, Inc. and Atlantic Coast Jet, Inc. ("Delta Connection") hereby answer in opposition to the Objections of the Office of the President of the Borough of Queens (the "Borough President")., The Borough President opposes the blanket authorization of slots at LaGuardia Airport by Orders 2000-4-10 and 2000-4-11 that was mandated by the Wendell H. Ford Investment and Reform Act for the 2 Pt Century ("Air 21 ").

Counsel:  Shaw Pittman, Robert Cohn, 202.663.8060

American Trans Air, Inc. 

• 1. ATA holds or operates fewer than twenty (20) slots at LaGuardia Airport, and has held or operated fewer than twenty (20) slots at LaGuardia Airport since December 6, 1985.
• 2. ATA will utilize its slots to serve Chicago (Midway) from LaGuardia, Airport.
• 3. All aircraft to be utilized in this service are Stage 3 compliant.
• 4. The effective date for slots requested hereunder is September 15, 2000 (four slots).
• 5. ATA requests four (4) slot exemptions for use at LaGuardia Airport.
• 6. ATA requests slots at the following times:

Slot 1: 1600 A Slot 2: 1830 D
Slot 3: 1900 A Slot 4: 1930 D

Counsel:  Squire Sanders, Marshall Sinick, 202.626.6651

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions)

On May 31 and June 13, 2000, Spirit submitted to the Department certifications setting forth its proposed schedules for the LGA - Ft. Lauderdale, LGA - DTW and LGA -TPA markets. Spirit hereby submits the following amendment to its previous certifications, which sets forth Spirit's flight schedules between LGA and Ft. Lauderdale and Detroit's Metro Airport, effective as of mid-July.

Spirit's amended certification of June 13, which refers to LGA-DTW operations, erroneously states that all four of the slots covered by the certification would be used for services to DTW, rather than for a mixed LGA - DTW/FLL schedule as set forth above.

Counsel:  GKMG Consulting, Mark Kahan, 703.312.1446

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

Counsel:  GKMG, Anita Mosner, 703-312-1446

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

Counsel:  Shaw Pittman, Nathaniel Breed, 202.663.8060

Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

Counsel:  Midway Airlines , Jonathan Waller, 919.595.6000

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions

Counsel:  Baker Hostetler, Joanne Young, 202.861.1532

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

Counsel:  AirTran, 

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

By this order the Department grants a July 31, 2000, request by the Office of the President of the Borough of Queens to withdraw a motion that she filed on June 2, 2000, for reconsideration of Orders 2000-4-10 and 2000-4-11. Orders 2000-4-10 and 2000-4-11 granted certain exemptions from slot restrictions at LaGuardia Airport. While we are granting her request to withdraw her petition, her petition raised issues that are of great concern to the people living and working near LaGuardia and to airline passengers. We are therefore discussing those issues in this order, since we wish to clarify the likely effects of our earlier orders implementing Congress' directive authorizing additional flights at LaGuardia and the other slot-restricted airports.

By:  Francisco Sanchez

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

Southeast Airlines, Inc. hereby submits its Certification, pursuant to 49 U.S.C. 41716(b) and the blanket exemption granted by Order 2000-4-10, served 19 April 2000, in connection with the request of Southeast that it be assigned two (2) operating slots at New York's LaGuardia Airport, to enable Southeast to operate one (1) daily non-stop round-trip public charter flight between Norfolk International Airport and LGA, commending 17 November 2000

Counsel:  Aviation Law Center, Terence Haglund, 757.299.0557

Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

Counsel:  Aviation Law Center, Terence Haglund, 757.299.0557

Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

Counsel:  Aviation Law Center, Terence Haglund, 757.299.0557

Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

Counsel:  Sun Country, Dennis Barnes, 202.467.7060

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

AirTran Airways, Inc. in its September 8, 2000 Application set forth its intent to operate service from New York's LaGuardia Airport to Atlanta, Georgia and a "new focus city". AirTran has since announced and commenced service between New York's LaGuardia Airport and Pittsburgh, Pennsylvania using six slots with a planned service increase utilizing eight slots.

Counsel:  AirTran, Richard Magurno

Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

Pursuant to the U.S. Department of Transportation (the "DOI") Order 2 000-4-10 for slot exemptions at New York's LaGuardia Airport, Midway Airlines Corporation ("Midway") in accordance with the requirements outlined therein hereby certifies the following information, and Midway requests fifteen (15) new slot exemptions.

Midway holds three (3) slot exemptions at LaGuardia Airport which are now beingoperated along with fifteen (15) slot exemptions Midway previously obtained pursuant to Order 2000-4-10. On December 4, 2000, Midway participated as an eligible carrier in the Federal Aviation Administration's lottery to reallocate exemption slots at LaGuardia Airport.

In that lottery, Midway was eligible to select and did select for use the fifteen (15) new slot exemptions set forth in Schedule A attached hereto and incorporated herein (the "Air 21 slots"). Pursuant to the Notice of Lottery for Takeoff and Landing Times at LaGuardia Airport issued by the Federal Aviation Administration dated November 29, 2000, Midway is required to re-certify certain matters with respect to the Air 21 slots as follows:

Midway will use all its Air 21 slots to provide non-stop service between LaGuardia Airport and Raleigh-Durham International Airport;

Midway will provide service in this market using Boeing 737-700, Fokker F-100 and/or Canadair Regional Jet aircraft, which are all Stage 3 compliant; and

Midway will use the Air 21 slots for service into and out of LaGuardia Airport at the times and on the frequencies set forth in Schedule A.

Counsel:  Midway Airlines, Jonathan Waller, 919.959.6000

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions)

Vanguard will utilize its newly-awarded slots to operate an additional daily nonstop roundtrip flight between Kansas City International Airport ("MCI") and LaGuardia Airport, commencing on or about January 31, 2001

By:  Vanguard, Brian Gillman, 816.243.2100

AirTran Airways

Pittsburgh, Pennsylvania:

Atlanta, Georgia: 

By:  AirTran, John Kirny, 407.152.5600

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions); American Trans Air, Inc. 

Counsel:  Squire Sanders, Marshall Sinick, 202.626.6651

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

Counsel:  PA Consulting, Anita Mosner, 703.312.1446

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

Legend will operate between Dallas Love Field and LaGuardia.

Counsel:  Legend Airlines, T. Allan McArtor, 214.358.8200

On January 29, Spirit Airlines submitted a Certification concerning its use of slots at New York's LaGuardia Airport ("LGA"). Spirit misidentified certain of the slots it received in the lottery for LGA slots held on December 4, 2001. Accordingly, Spirit has attached a Revised Attachment 1, which sets forth the slots Spirit wishes to certify, and the markets for which those slots will be used.

Counsel:  PA Consulting, Anita Mosner, 703.312.1446

America West Airlines, Inc.

Since deregulation, America West's competitive fares have reduced the cost of air transportation in markets where it has been allowed to compete. However, at LaGuardia, fares in major Western markets remain high as a result of a rule that has long outlived its intended purpose. Such an anticompetitive rule should not remain in effect in perpetuity, particularly where its anticompetitive impact has long been recognized. Today, it is clearly in the public interest, indeed essential, to put America West on a more level playing field with the pre-deregulation incumbents by authorizing service between its hubs and LaGuardia despite the Port Authority's local perimeter rule.

Whatever grounds the Port Authority may have had for establishing the perimeter rule at LaGuardia, there is no justification for continuing to deny America West the ability to operate the pro-competitive services it proposes. America West's proposal to operate competitive service between LaGuardia and its hubs which provide more effective competition to the incumbents at LaGuardia and make more efficient use of airspace and LaGuardia's limited capacity than much of the new regional jet service proposed by affiliates of entrenched incumbent carriers. The grant of this application will automatically exempt the service from the perimeter rule and enable America West to initiate this valuable service.

WHEREFORE, for the reasons stated above, America West respectfully requests that the Department grant it an exemption from Subparts K and S of Part 93 of the Federal Aviation Regulations to operate sixteen exemption slots at LaGuardia for service to Phoenix and Las Vegas, and for such other and further relief as the Department deems in the public interest.

Counsel:  Baker Hostetler, Joanne Young, 202.861.1532

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions) 

The requested slot exemptions will allow America West to continue its highly successful, competitive, full-service operations between LGA and Columbus with connections to the West. If America West was forced to end these operations, the traveling public would lose an important cornpetitive force and access to lower fares from LGA to Columbus, Phoenix, Las Vegas and the West would be diminished. The benefits that deregulation has brought to these markets would be lost, aiid the Departin ei it's goal of promoting competition in the air transportation industry would sLiffer a severe setback. Granting An-ierica West its requested and permitting it to provide this service oii America West Express will enhance consumer welfare and preserve competition, thereby furthering policies recognized as critically important by the Department.

Counsel: Baker Hostetler, Joanne Young, 202.861.1532

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions) 

Despite a Congressional mandate to open LaGuardia to additional small-city and new entrant service, the Department has forced regional carriers to eliminate flights between LaGuardia and small cities and forced new entrants and limited incumbents to eliminate flights at LaGuardia because of extraordinary delays and congestion. America West has requested both a dozen or more additional slots and an exemption from the long-standing, judicially- sanctioned perimeter rule at LaGuardia while the Department is struggling with allocating reductions of existing services at LaGuardia. Although Continental is reluctant to dignify America West's application with a response, the importance of slots at LaGuardia to Continental compels it to oppose America West's application for the following reasons.

Counsel:  Crowell Moring, Bruce Keiner, 202.624.2500, rbkeiner@cromor.com 

Delta, like every other airline serving LaGuardia, must abide by the perimeter rule, and is prevented from operating long-haul services it would otherwise provide. While Delta would certainly welcome the opportunity to fly nonstop from LaGuardia to Delta's primary western hub at Salt Lake City, and to fly nonstop to important west coast cities such as Los Angeles, there are serious legal and policy questions as to whether the Department can or should overrule the Port Authority's long-standing perimeter rule on the basis of America West's application. There are also serious policy questions as to whether the Department should be adding more flights at LaGuardia, after it has just determined to force Delta and other airlines to substantially reduce existing slot exemption service expressly authorized by AIR-21.

Counsel:  Shaw Pittman, Robert Cohn, 202.663.8060 

Counsel:  Port Authority of New York and New Jersey, Milton Pachter

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions)

It is important to preserve the status quo for now., and to ensure that LaGuardia continues to operate smoothly and efficiently, pending the implementation by the FAA of a permanent market-based system to replace the lottery system, scheduled for mid-September 2001. This also means keeping the perimeter rule in place, to preserve LaGuardia's role as a business traveler’s airport and an airport serving all kinds of short and medium-range travellers.

Counsel: Queens Borough President's Office, Hugh Weinberg, 718.286.2880

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions)

America West's application gives the Department the opportunity to step up and take action that will have an immediate and direct pro-competitive impact on the market and benefit consumers traveling between LaGuardia and the West. To permit the fares for thousands of passengers who travel in these markets to be effectively controlled by a perimeter rule that has long outlived any possible benefit is contrary to the dictates of the Airline Deregulation Act and the stated policy of the Department to promote competition. For these reasons the Department should reject the objections and grant the requested slot exemptions.

Counsel:  Baker Hostetler, Joanne Young, 202.861.1532

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century and America West Airlines, Inc.

OST-00-7176	March 1, 2001	Answer of the Port Authority of New York and New Jersey in Opposition to Application for Exemption	New York, LaGuardia (LGA)- Columbus, Ohio (CMH)
		Service List

The considerations that caused the FAA to limit the number of AIR-21 flights at LGA are applicable today, and the granting of exemptions from the high density rule at LGA under 49 U.S.C. §41714(c) would have the same adverse effects as the granting of exemptions under AIR-2 1. The necessity to limit operations at LGA to 75 per hour, at least until a permanent demand management policy is implemented, has not abated. The policy considerations supporting America West's application are not different in kind, and do not appear more weighty, than those supporting the statutory exemptions in AIR-21. The FAA recognized that those considerations were outweighed by the problem of congestion at LGA when it established the 75 operations per hour limit. Similarly, America West's application should be denied to avoid upsetting the status quo established at LGA by the FAA to address congestion pending implementation of a longer term solution.

Counsel:  Port Authorty of NY/NJ, Milton Pachter, 212.435.6830

The Department could not rationally conclude that awarding the slot exemptions for Columbus service requested by America West would serve the public interest when Congressional determinations that the public interest requires unrestricted small-community service at LaGuardia by aircraft with fewer than 71 seats are being ignored. Columbus today receives LaGuardia service from America West and three other carriers: Delta today offers 21 weekly flights, American offers 25 weekly flights and US Airways offers 23 weekly flights. Even without the additional slot exemptions it seeks, America West can continue to operate two daily roundtrips between LaGuardia and Columbus (see America West application at 3) and add Columbus flights at other New York/Newark airports.

Counsel:  Crowell Morning, Bruce Keiner, 202.624.2500, rbkeiner@cromor.com 

America West Airlines, Inc.

The Port Authority and Continental wrongly argue that the grant of America West's request would be inconsistent with the FAA imposed exemption slot cap and lottery to allocate these slots and therefore not in the public interest. America West's application is not inconsistent with the lottery, which was required because of excessive new service. America West is asking the Department to act to preserve service that has been in place for almost a decade and which has important competitive implications. Continental and the other incumbents as a result of Air 21 are all operating more service at LaGuardia than they operated before the law was passed. Unless the Department acts positively on this application, America West will be the only carrier forced to reduce service below its pre-Air 21 level. This certainly is not the result Congress intended when it enacted Air 21 to expand opportunities at LaGuardia for new entrants. Indeed it is exactly the opposite of what Congress intended. Clearly, in determining the public interest as required by 49 U.S.C. § 41714(c), the Department must balance the important competition issues raised by America West in its application with the minimal impact the service would have on congestion. On balance for the reasons discussed in the application and below, the public interests at stake manifestly support approval of the America West request.

Counsel:  Baker Hostetler, Joanne Young, 202.861.1532

America West Airlines, Inc.

We have decided to deny America West's application at this time, without prejudice.

America West has applied for these slot exemptions under the provisions of 49 U.S. C. section 41714(c), which, as amended by AIR-2 1, authorizes the Secretary to grant them to qualifying new entrants at LGA, ORD, and JFK if he finds such grant to be "in the public interest." As to public interest factors, America West argues that service between LGA and its hubs at Phoenix and Las Vegas is "much needed," and that the Department's authorization of such service would be "pro-competitive. " It asserts that these flights would benefit more passengers, make more efficient use of airspace, and make better use of scarce capacity at LGA than other services being initiated with AIR-21 exemption slots allocated by the FAA lottery. It further argues that the original rationale for the perimeter rule has been substantially undermined by various factors.

The Department agrees that, if granted, service between LGA and America West's western hubs would likely be quite successful, and, given America West's new entrant status', the granting of such exemptions would be pro-competitive. However, it is unclear as to how the Department could grant these exemptions at this time without impairing other important interests - notably, the serious congestion that has affected LGA, and the Department's efforts to relieve that congestion with the slot lottery.

In order to grant America West the exemptions it seeks, we would either have to withdraw slots or slot exemptions from carriers permitted to operate them under the terms of the lottery in order to reaward them to America West, or authorize additional flights over and above the ceiling established for maximum operations by the lottery. The former approach would effectively require us to terminate service by carriers, to communities and for passengers that have current expectations of being able to provide and receive such service until at least September 15, 2001. Nor is the latter approach any more viable, for it would be inconsistent with the FAA's determination that, to appropriately restrain congestion problems at LGA, scheduled operations should be limited to 75 per hour.

FAA is now considering various alternative longer-term approaches to supplant the slot lottery at LGA. These alternatives may be more conducive to permitting America West's arguments to be favorably considered. Our action on this application is therefore without prejudice to America West reapplying for these exemptions, to the extent it believes appropriate under any successor congestion management regime at LGA.

By:  Susan McDermott

Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

Midway holds fifteen (15) slot exemptions at LaGuardia Airport obtained pursuant to Order 2000-4-10 and set forth in Schedule A hereto (the "AIR 21 Slots"). Midway wishes to change the frequency of the 0700 departure slot time from "12345" to "Daily", and to change the frequency of the 2100 arrival slot time from "123457" to "Daily", each effective as of July 7, 2001.

Midway has returned to the FAA three AIR 21 slots as set forth in Schedule A but wishes to preserve whatever rights it may have to such slots whether now existing or hereafter established and to preserve whatever rights it might have to recommence use of such slots on September 15, 2001.

Counsel:  Midway Airlines, Jonathan Waller, 919.959.6000

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (Slot Exemptions) 

Counsel:  Baker Hostetler, Joanne Young, 202.861.1532

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century

AirTran Airways will utilize two slot exemptions used for PIT-LGA in ATL-LGA service. The proposed slot exemptions are 35003 and 35004. The additional roundtrip to ATL commenced on July 5, 2001.

Counsel:  AirTran, Richard Magurno

American Trans Air, Inc.

Counsel: American Trans Air

The Wendell H. Ford Aviation Investment and Reform Act for the 21st Century (Notice of Alternative Policy Options for Managing Capacity Airport and Poropsed Extension of the Lottery Allocation)

Vanguard currently holds six slots at LaGuardia, four of which were awarded on October 1, 2000 and two of which were awarded at the August 15, 2001 LaGuardia slot lottery. The two slot exemptions when added to Vanguard's existing slot holdings at LaGuardia will not exceed twenty (20) slots.  Vanguard will utilize its LaGuardia slots to serve Kansas City International Airport.  Vanguard currently operates four slots and will initiate operations of the other two slots effective June 3, 2002.  After taking into account FAA-approved slot trades and slot slides, the time of slot exemption operations to be operated as of June 3, 2002 will be 1300A, 1800A, 2320A, 659D, 1400D and 1840D.

By:  Vanguard, Robert Rowen, 816.243.2100

American Trans Air, Inc.

ATA holds or operates fewer than twenty (20) slots at LaGuardia Airport, and has held or operated fewer than twenty (20) slots at LaGuardia Airport since December 6, 1985.  ATA will utilize the slots to service Indianapolis from LaGuardia Airport.  The effective date for slots re-certification hereunder is September 16, 2002.

Counsel: American Trans Air, Inc., Brian Hunt

Spirit Airlines, Inc.

Certification of Spirit Airlines, Inc. pursuant to Order 2000-4-10 and 14 CFR Section 302.4(b), submitting information concerning its recent allocation by lottery of two (2) operating slots at New York's LaGuardia Airport.  Spirit will use its two additional slot exemptions at LGA so that it may provide an additional daily nonstop roundtrip between LGA and Fort Lauderdale, Florida (FLL).  Spirit intends to operate its proposed LGA services using only Stage 3-compliant MD-80 series aircraft.

Spirit requests two (2) LGA-FLL slots on or before May 1, 2003. The times for the requested slots are as follows:

• Arrive   1930

• Depart  2030

Counsel: Garfinkle Wang, Anita Mosner, 703-294-5890

OST-00-7176

October 15, 2003

Correction Submitted by ATA Airlines Regarding Re-certification of Slots

By: ATA, Brian Hunt

Frontier Airlines, Inc.

OST-00-7176 - Denver-New York LaGuardia

Application for an Exemption | Word

Hereby requests the Department of Transportation (“Department”) to issue an order granting Frontier a total of two (2) additional slots with which to add to its existing service at New York’s LaGuardia Airport (“LGA”) in accordance with 49 U.S.C. Section 41716(b) Frontier serves LGA from Denver International Airport (“DEN”).  Section 41716(b) directs the Secretary to grant by Order exemptions from Subparts K and S (the “High Density Airport Rule”) to any new entrant or limited incumbent if the number of slot exemptions held by the applicant carriers does not exceed twenty (20) in number.  As of October 24, 2003, Frontier was operating four (4) slots at LGA.

This application was also filed in Docket OST-00-7188 along with a “Response of Frontier Airlines, Inc. to American Airlines, Inc. and US Airways, Inc.” on November 13, 2003. 

Counsel: Ungaretti & Harris, Edward Faberman, 202-639-7501, epfaberman@uhlaw.com

OST-00-7176 - Denver-New York LaGuardia

November 4, 2003

Correspondence of the Denver Metro Chamber of Commerce

By: Tom Clark

JetBlue Airways Corporation

OST-00-7176 - Certification for LaGuardia Slots

January 21, 2004

Certification for LaGuardia Slots | Word

Respectfully certifies as follows in order to receive 10 exemption slots at LaGuardia Airport: JetBlue presently holds no slots at LaGuardia Airport. JetBlue will utilize the 10 slots to operate to JetBlue route destinations. All of JetBlue A-320 aircraft are Stage 3 compliant. JetBlue will coordinate its slot request with the FAA Slot Administration Office and will advise DOT in a subsequent filing of the specific destinations to be served, along with flight schedules.

Counsel: JetBlue and Dow Lohnes, Jonathan Hill, 202-776-2725, jhill@dlalaw.com

OST-00-7176 - Interim Slot Rules at LaGuardia Airport

February 2, 2004

Certification of Midwest Airlines

Commencing April 4, 2004, it intends to utilize two slot exemptions at New York LaGuardia Airport to operate a daily roundtrip flight between LaGuardia and Milwaukee, Wisconsin. These two slot exemptions were awarded to Midwest by Federal Aviation Administration lottery on January 8, 2004.

Counsel: Silverberg Goldman, Robert Silverberg, 202-944-3300, rsilverberg@sgbdc.com

OST-00-7176 - Interim slot rules at LaGuardia Airport Exemptions for New Entrant and Limited Incumbent Air Carriers)

February 2, 2004

Re-Certification of ATA Airlines

ATA will utilize the slots to service Chicago Midway from LaGuardia Airport.

Counsel: ATA, Brian Hunt

OST-00-7176 - New York LaGuardia Slot Exemptions

February 24, 2004

Application for LaGuardia Airport Slots

CanJet is requesting 4 slots as a new entrant carrier in connection with the daily service it plans to initiate between Toronto‑New York and Montreal‑New York. CanJet holds all requisite authority from the U.S. and Canadian governments to conduct scheduled foreign air transportation between these points.

Arrive/ Market Depart Equipment 

Toronto-LGA 1350/1440 B737-200 

Montreal-LGA 1125/1215 B737-200

Counsel: Zuckert Scoutt, Nathaniel Breed, 202-298-8660, npbreed@zsrlaw.com

OST-00-7176 - New York LaGuardia Airport Slots

February 26, 2004

Amendment No. 1 to Application for LaGuardia Airport Slots

CanJet' request for LaGuardia airport slots is supported not only by the reasons stated in CanJet's February 24 application but in addition by the provisions of the U.S.‑Canada Air Transport Agreement. Specifically, Section 1 of Annex II to the U.S.‑Canada bilateral provides that "Canadian and United States airlines shall be subject to the same system for slot allocation at United States high density airports as are U.S. airlines for domestic services." CanJet' s February 24 application is consistent with the procedures for the allocation of slot exemptions at LaGuardia for U.S. carriers as set forth in (i) the provisions of 49 U.S.C. § 41716(b) as enacted by the Wendell H. Ford Aviation Investment and Reform Act for the 21^st Century and (ii) Order 2000-4-10.

The effective date for the slots which CanJet proposes to use at LaGuardia is May 31, 2004. Any LaGuardia airport slot exemptions allocated to CanJet should be issued under its corporate name, which is "I.M.P. Group Limited

Counsel: Zuckert Scoutt, Nathaniel Breed, 202-298-8660, npbreed@zsrlaw.com

OST-00-7176

March 12, 2004

Re-Certification of ATA Airlines

Hereby certify the following pursuant to Order 2000-4-10, 14 C.F.R. 3024(b) and 65 F.R. 75765 in connection with AlA's request for two (2) slot exemptions to serve LaGuardia Airport. ATA will utilize the slots to service LaGuardia Airport from St. Petersburg, Florida

ATA requests the two slot exemptions at the following times:

• Slot 1: 1500D  Slot Nbr 35077
• Slot 2: 1900A Slot Nbr 35112

Counsel: ATA, Brian Hunt

WestJet

OST-00-7176 - Certification for LaGuardia Slots

May 18, 2004

Application and Certification for LaGuardia Slots

Counsel: Garofalo Goerlich, Don Hainbach, 202-776-3970

JetBlue Airways Corporation

OST-00-7176 - Certification for LaGuardia Slots

May 21, 2004

Certification for LaGuardia Airport Slots | Word

Pursuant to the provisions of § 41716 (b) of the ?Wendell H. Ford Aviation Investment and Reform Act for the 21st Century", and Order 2000-4-10, JetBlue Airways Corporation respectfully certifies as follows in order to receive three (3) additional exemption slots at LaGuardia Airport:

• 1. JetBlue presently holds no slots at LaGuardia Airport,
• 2. JetBlue will utilize the three (3) slots to operate to JetBlue route destinations,
• 3. All of JetBlue A-320 aircraft are Stage 3 compliant.

Counsel: Dow Lohnes, Jonathan Hill, 202-776-2725, jhill@dlalaw.com

JetBlue Airways Corporation

OST-00-7176 - Certification for LaGuardia Slots

May 24, 2004

Certification for LaGuardia Airport Slots | Word

Pursuant to the provisions of § 41716 (b) of the "Wendell H. Ford Aviation Investment and Reform Act for the 21st Century", and Order 2000-4-10, JetBlue Airways Corporation respectfully amends its certification flied on May 21st as follows in order to clarify that it already holds eleven slots at LaGuardia and is requesting an addition three (3) exemption slots at LaGuardia Airport with this Amended Certification :

• 1. JetBlue presently holds eleven (11) slots at LaGuardia Airport pursuant to its January 24, 2004 certification.
• 2. JetBlue will utilize the additional three (3) slots to operate to JetBlue route destinations,
• 3. All of JetBlue A-320 aircraft are Stage 3 compliant.

Counsel: Dow Lohnes, Jonathan Hill, 202-776-2725, jhill@dlalaw.com

JetBlue Airways Corporation

OST-00-7176 - Certification for LaGuardia Slots

June 24, 2004

Supplemental Certification for LaGuardia Airport Slots | Word

Pursuant to the provisions of § 41716 (b) of the “Wendell H. Ford Aviation Investment and Reform Act for the 21st Century”, and Order 2000-4-10, JetBlue Airways Corporation respectfully supplements its certifications filed on January 21st and May 21st as it impacts JetBlue’s proposed operations out of LaGuardia Airport as follows:

• 1. JetBlue presently holds fourteen (14) slots at LaGuardia Airport pursuant to its January 24, 2004 and May 21, 2004 certifications;
• 2. JetBlue will utilize these slots to operate to seven (7) daily, roundtrip, non- stop flights to Fort Lauderdale/Hollywood Florida, at the time set forth in Exhibit 1 hereto;
• 3. All of JetBlue A-320 aircraft are Stage 3 compliant.

Counsel: Dow Lohnes, Jonathan Hill, 202-776-2725, jhill@dlalaw.com

Jetsgo Corporation

OST-00-7176 - New York LaGuardia Airport Slots

July 14, 2004

Application for LaGuardia Airport Slots

Jetsgo requests 12 slots at LaGuardia (LGA) to enable it to provide scheduled daily service between Toronto (YYZ) and LGA. This service will commence September 20, 2004, and will be operated with 160-seat MD-83 aircraft. Jetsgo does not currently serve LGA, and thus holds no slots at that airport.

Counsel: Sher & Blackwell, 202-463-2513, matwood@sherblackwell.com

August 5, 2004

Re-Certification of ATA Airlines

Holds or operates fewer than twenty (20) slots at LaGuardia Airport, and has held or operated fewer than twenty (20) slots at LaGuardia Airport since December 6, 1985. Will utilize the slots to service LaGuardia Airport from Indianapolis, Indiana.

Counsel: ATA, Brian Hunt

August 20, 2004

Re-Certification of ATA Airlines

ATA holds or operates fewer than twenty (20) slots at LaGuardia Airport, and has held or operated fewer than twenty (20) slots at LaGuardia Airport since December 6,1985. ATA will utilize the slots to service Midway from LaGuardia Airport.

Slot 1: 1700A Slot Nbr 35086 Day 6
Slot 2: 1500D Slot Nbr 35077 Day 6

Counsel: ATA, Brian Hunt

OST-00-7176 - Certification for LaGuardia Slots

September 15, 2004

Re-Certification for LaGuardia Airport Slots

Westjet currently holds no slots at LaGuardia Airport. However, on June 10, 2004, in accordance with the lottery procedures and the adopted procedures for new entrant carriers not operating at LaGuardia Airport, WestJet accepted the Federal Aviation Administration's offer of four slots.

Westjet will utilize the slots to service LaGuardia Airport from Toronto, Canada. Westjet will utilize Stage 3 compliant B-737 aircraft. Westjet will initiate operations of the four slots effective September 20, 2004. Westjet requests the four slot exemptions at the following times:

Slot 1: 1040A Daily
Slot 2: 1110D Daily
Slot 3: 1530A X67
Slot 4: 1620D X67

Counsel: Garofalo Goerlich, Don Hainbach, 202-776-3970

OST-00-7176 - LGA Slots

December 8, 2004

Certification of Jetsgo Corporation

Jetsgo currently holds no slots at LaGuardia Airport. Jetsgo will use the two slots to operate daily air transportation between Toronto and LaGuardia.

Counsel: Sher & Blackwell, Mark Atwood, 202-463-2513

OST-00-7176 - LGA Slots

February 2, 2005

Petition of AirTran Airways for an Exemption

Pursuant to 49 U.S.C. § 41716 (b), AirTran Airways, Inc. files this petition for slot exemptions to obtain four additional slots at LaGuardia Airport for one roundtrip between LGA and Akron-Canton Airport ("CAK"), Ohio and one roundtrip between LGA and Newport News/Williamsburg Airport ("PHF"), Virginia.

On March 4, 2003, AirTran initiated two daily nonstop flights between CAK and LGA. AirTran utilized its existing slot holdings for this service. After one month of service, the LGA-CAK local market grew by 735% to over 300 passengers a day. Within four months of its initiation of the CAK-LGA service, on July 2, 2003, AirTran added a third daily nonstop flight from CAK to LGA. After one full month of the three‑ roundtrip service, the CAK‑LGA passenger numbers increased from 300 to 570 passengers per day and load factors have exceeded 80%. Those numbers continue today. With the three round trips, passengers from both the CAK and New York communities have increased travel plans benefiting all carriers serving both markets.

On March 5, 2002, AirTran initiated two daily nonstop flights between PHF and LGA with its existing LGA slot holdings. With the two flights, the LGA‑PHF market grew over 3,000%. The LGA service was so successful that on July 2, 2003, AirTran added a third daily nonstop PHF‑LGA flight. After one full month of the three roundtrip service, the daily passenger numbers increased from 250 to 410 passengers per day. As a result of the success of the PHF‑LGA service, AirTran also added nonstop PHF service to Boston, Orlando, Atlanta and Tampa.

Counsel: Wiley Rein, Edward Faberman, 202-719-7420

OST-00-7176 - LGA Slots

February 15, 2005

Re: Letter from JetBlue Requesting Additional Slot Exemptions

On behalf of JetBlue Airways Corporation, I am writing to request that the FAA grant to JetBlue nine (9) additional AIR-21 slot exemptions to operate out of LaGuardia Airport. JetBlue, as a limited incumbent, presently holds eleven (11) such exemptions at LaGuardia and one (1) temporary slot for a total of twelve (12) slots for operations between the hours of 0700 and 2159. JetBlue is fully qualified to receive such an additional allocation under the terms 49 USC § 41716. JetBlue is prepared to return the one (1) temporary slot when and if the nine (9) additional AIR-21 slots become available. With the nine (9) additional slots JetBlue would have twenty (20) slots as allowed under AIR-21.

Counsel: JetBlue, Robert Land

OST-00-7176 - LGA Slots

February 16, 2005

Answer of JetBlue Airways

The statutory language imbedded in an Omnibus Appropriations Act that was passed as part of an enormous and rushed appropriations process last year, does not change the law that existed prior to its enactment nor does it change the reasoning of FAA’s prior decision issued by the FAA Chief Counsel in October of 2003. The newly enacted statute does not direct FAA to take any action but only indicates in "may" take certain action, presumptively in compliance with other laws and regulations. The provision does not change the requirements of Air 21 giving new entrants/limited incumbents rights, rights that have not been available and rights that must be addressed before the relief requested by AirTran can or should be granted.

Therefore, JetBlue requests the FAA favorably consider AirTran’s petition only after all carriers, such as JetBlue, seeking to expand service at LaGuardia under Air 21’s existing procedures, are afforded their rights to do so.

Counsel: Dow Lohnes, Jonathan Hill, 202-776-2725, jhill@dowlohnes.com

February 17, 2005

Answer of American Airlines

Any additional slot exemptions issued under the new law should be within the limit on total LGA operations established by the FAA in late 2000. In response to a dependability crisis at LGA caused by excessive AIR-2l operations, the FAA adopted a regulatory cap on LGA services by 65 Fed. Reg. 75765, December 4, 2000. That cap remains in place, and was most recently extended to October 25, 2005 by FAA action in 69 Fed. Reg. 40711, July 6, 2004.

The FAA has administered the LGA cap through a lottery process that reallocates unused AIR‑2l slots when and if they become available. See 65 Fed. Reg. 75765, December 4, 2000. In enacting the new law, Congress must be presumed aware of the longstanding LGA cap, and clearly did not intend to overturn that cap in the absence of specific language doing so. Indeed, by using the term "may" rather than "shall" with respect to grant of additional slot exemptions, Congress has not mandated action by the Secretary, and certainly has not mandated action inconsistent with the LGA regulatory cap.

Counsel: American, Carl Nelson, 202-496-5647, carl.nelson@aa.com

February 17, 2005

Answer of Delta Air Lines

AirTran already operates twice daily service between LaGuardia, on the one hand, and Akron-Canton and Newport News/Williamsburg, on the other hand. AirTran seeks a discretionary exemption to operate a third daily flight to each of these airports. By contrast, many small and medium sized communities lost all service to and from LaGuardia when the Delta Connection carriers were forced to curtail operations authorized by the mandatory regional jet exemption provisions of AIR-21.

It would be inconsistent with the statute to favor additional discretionary exemptions to AirTran over those the Secretary was legally required to grant to the Delta Connection carriers. Under section 41716(a) the Secretary "shall grant" exemptions for regional jet services, such as those operated by the Delta Connection carriers. By contrast, the new omnibus bill provision on which AirTran relies is discretionary, since under section 41716(b) the secretary "may grant" slots to incumbent carriers with 20 to 28 slots.

Counsel: Shaw Pittman, Alexander Van der Bellen, 202-663-8060

OST-00-7176 - Exemption from 14 CFR 93.123 - LGA Slots

February 17, 2005

Request for Clarification by US Airways

it is unclear which administrative procedure AirTran is utilizing to advance its position. Accordingly, it is unclear how the DOT and/or the FAA plan to address AirTran's Petition. To the extent it is viewed as a rulemaking petition, as previous AirTran requests have been viewed (see, e.g., Docket FAA-03-15925), US Airways would await the DOT/FAA's publication of a summary of the Petition and establishment of a public comment period in the Federal Register. To the extent that AirTran' s filing is viewed as an application for slot exemptions under 49 U.S.C. § 41716, as some have been, US Airways would plan to file its comments on or before February 28, 2005.

Counsel: US Airways, Elizabeth Lanier, 703-872-5230

OST-2000-7176 - Petition for LGA Slots

February 28, 2005

Answer of US Airways

Contrary to what AirTran would have the DOT and the FAA believe, this legislative amendment does not mandate that the DOT/FAA award these four LGA slot exemptions to AirTran. The amendment is discretionary or permissive; it does not require that the DOT/FAA award these four slot exemptions to anyone or to any place. This language is particularly noteworthy when juxtaposed to the mandatory language used in the other statutory provisions regarding slot exemptions. That is, although the Secretary "may" now grant no more than 4 additional slot exemptions at LaGuardia Airport to an incumbent air carrier operating at least 20 but not more than 28 slots at such airport as of October 1, 2004, to provide air transportation between LaGuardia Airport and a small hub/nonhub airport, the Secretary "shall" grant exemptions to any air carrier to provide nonstop service using aircraft with less than 71 seats between LaGuardia Airport and a small/non-hub airport if certain requirements are met.

Despite the mandatory language in Section 41716(a), the operational cap imposed by the FAA at LaGuardia has precluded eligible airlines, such as the US Airways Express carriers, from adding and initiating service between LaGuardia and small/non-hub communities with smaller aircraft. If the FAA determined that additional operations could now be accommodated at LaGuardia, it should first provide slot exemptions to such airlines under Section 41716(a), as it was directed to do, before awarding any slot exemptions pursuant to the discretionary language in the amendment upon which AirTran relies

Counsel: US Airways, Elizabeth Lanier, 703-872-5230

OST-00-7176 - New York LaGuardia Airport Slots

March 2, 2005

Certification for LaGuardia Airport Slots

Jetsgo currently holds four slots at LaGuardia Airport; these slots are used for operations between Toronto and LaGuardia five days per week Monday through Friday. Two of them are also used on Sundays. The slots used Monday ‑ Friday are numbers 35118 (arrival) and 35063 (departure), which are used for afternoon flights, and numbers 35016 (arrival) and 35044 (departure), which are used for morning flights. Slots 35118 (arrival) and 35063 (departure) are also used for flights on Sunday.

Jetsgo was also previously awarded two slots for use on Saturday. A Saturday flight was operated briefly, but had to be cancelled and the slot was returned. The carrier now finds, however, that market conditions warrant the resumption of the Saturday flight between Toronto and LaGuardia and therefore submits this certification in support of a request for slots to operate this flight.

Counsel: Sher & Blackwell, 202-463-2513, matwood@sherblackwell.com

OST-00-7176 - Petition for LGA Slots

March 3, 2005

Response of AirTran Airways

Considering the dramatic change taking place in the industry and the success of AirTran's small community service, it is important for these exemption slots to be allocated as soon as possible. AirTran is in the process of modifying schedules for the remainder of the year. It is essential that the CAK-LGA and the PHF-LGA roundtrips be made permanent.

Counsel: Wiley Rein, Edward Faberman, efaberman@wrf.com

OST-00-7176 - Petition for LGA Slots

February 23, 2005

Re: Recertification of ATA Airlines

ATA will utilize the slots to service LaGuardia Airport from Chicago Midway.

Counsel: ATA Brian Hunt

OST-00-7176 - LGA Slots

February 22, 2004

Comments of The James City Council Board of Supervisors

Congress passed the Fiscal Year 2005 Omnibus Appropriations Bill with language that instructed the Department of Transportation to:

"make it their highest priority to allocate permanent slots at LaGuardia Airport to allow the Communities of Akron-Canton, Ohio and Newport News/Williamsburg, Virginia to have permanent third-roundtrips to LaGuardia Airport."

Air Tran Airways has now filed a petition with D.O.T. seeking the slots to operate third roundtrip service. New York is a vital destination for Southern Virginia and our local government needs the third round trip to offer economic development opportunities not available with only two daily roundtrips.

By: Michael Brown

OST-00-7176 - LGA Slots

March 11, 2005

Comments of Akron-Canton Airport

By: Frederick Krum, 330-499-4059

OST-00-7176 - LGA Slots

March 16, 2005

Comments of Newport News-Williamsburg International Airport

PHF is a small hub airport. It is the specific type of airport that Congress wanted to have increased LGA service when it enacted AIR‑21. Congress further expressed a strong preference for PHF‑LGA service in the Omnibus Appropriations Bill of 2005. The public interest for the service is overwhelming and the benefit to the PHF community is immense. On behalf of the residents and businesses of the PHF area, we ask that the Department immediately approve AirTran's request for additional LGA slots to allow the third PHF‑LGA roundtrip to become permanent.

By: James Smith, 757-877-0221

OST-2000-7176

March 29, 2005

• Ex-Parte Letter to Congressman Bobby Scott
• Ex-Parte Letter to Senator George Voinovich
• Ex-Parte Letter to Mayor Jeanne Zeidler
• Ex-Parte Letter to Congressman Sherry Brown