OST-1997-3153 - Great Lakes Aviation - Proposal to Increase Essential Air Service Flights

OST-1997-3153

Great Lakes Aviation, Ltd.

OST-97-3153 | November 18, 1997

Re: Proposals to Increase Essential Air Service Flights

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Enclosed are proposals to increase essential air service from 12 to 18 flights per week at Ironwood and Manistee, Michigan, at Mattoon, Mount Vernon, and Sterling/Rock Falls, Illinois and at Ottumwa, Iowa. These proposals require 20 additional slot exemptions at Chicago O'Hare International Airport for the enhanced service levels at these communities.

Exhibit A - Schedule Comparison : Current vs. Proposed
EAS for Decatur, Mattoon, and Mount Vernon, IL
EAS for Mount Vernon
EAS for Ironwood, MI
EAS for Manistee, MI
EAS for Ottumwa, IA
EAS for Sterling/Rock Falls, IL

By: Douglas Voss, President and CEO, 712.262.1000

Great Lakes Aviation, Ltd. d/b/a United Express (Chicago O'Hare Slots)

OST-97-3153 | December 9, 1997

Answer of American Airlines and American Eagle

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Attachment A

Counsel: American, Carl Nelson, 202-496-5647

Great Lakes Aviation, Ltd. (Exemption, High Density Rule, Chicago O'Hare)

OST-97-3153 | December 22, 1997

Motion for Leave to File

Answer of The City of Decatur, Illinois

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The Great Lakes proposal would neatly take care of the Department's obligation to see that service is provided in the Decatur - O'Hare market without the need to provide subsidy. In fact, as Decatur understands the Great Lakes' proposal for the other six cities, it would reduce significantly the total subsidy cost of serving them, increase service at least at one other point (Mattoon-Charleston), and permit Great Lakes to withdraw its recent notice of suspension of service at Mount Vernon.

Claims by American Airlines that it is affected negatively by grant of EAS slots to a United Express airline must be considered in relation to (1) American's very large inventory of O'Hare commuter slots, and (2) the fact that American in the past served many of the same Illinois points covered by Great Lakes' application but chose to suspend service at those points and take away the slots for use at larger cities.

Counsel: Zuckert Scoutt, Raymond Rasenberger, 202-298-8660

Simmons Airlines, Inc. d/b/a American Eagle / Trans States Airlines, Inc. / Reno Air, Inc. / Atlantic Coast Airlines / Great Lakes Aviation, Inc. d/b/a United Express (High Density Rule, Chicago O'Hare)

OST-95-368 | OST-97-2368 | OST-97-2771 | OST-97-3259 | OST-97-3153 | December 30, 1997

Motion for Leave to File and Comments of Comair

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At the outset, two aspects of these O'Hare slot requests have become quite clear. First, except for Reno Air (which has had a close relationship with American), all the applicants are controlled by either American or United in terms of O'Hare operation (none is really a new entrant) and the requests simply constitute a battle between the two carriers which dominate the hub and an effort by both carriers to expand that hubs dominance in the nations Second, the enormous requests for slot allocations and the likelihood of an almost endless stream of subsequent requests make it apparent that an ad hoc market by market approach to the problem will not work. Instead, the Department needs to step back, look at the entire picture and make a determination based on solid facts and nationwide impact.

Counsel: Steptoe Johnson, Richard Taylor, 202-429-6459

Simmons Airlines, Inc. d/b/a American Eagle, et al.

OST-95-368 | OST-97-2368 | OST-97-2771 | OST-97-3259 | OST-97-3153 | January 6, 1998

Re: Corrections to Comments filed by Comair

Comair, Inc. respectfully requests that two corrections be made to the Comments filed by it herein on December 30, 1997. The first correction is to change the word "sold" to "solid" on page 2, line 6 from the bottom. The second correction is to change "80" to "25". on page 3, line 9 from the bottom. Corrected pages 2 and 3 are attached hereto and have been served on all parties.

Counsel: Steptoe Johnson, Richard Taylor, 202-429-3000

Simmons Airlines, Inc. d/b/a American Eagle / Trans States Airlines, Inc. d/b/a United Express / Reno Air, Inc. / Atlantic Coast Airlines d/b/a United Express / Great Lakes Aviation Ltd. d/b/a United Express (High Density Rule, Chicago O'Hare)

OST-97-2985 | OST-97-2368 | OST-97-2771 | OST-97-3259 | OST-97-3153 | January 9, 1998

Motion for Leave to File and Response of American Airlines and American Eagle to Comments of Comair

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Comair and Delta, and their hub services at Cincinnati, have no special claim to protection from competition. Indeed, American and American Eagle are at a decided competitive disadvantage at O'Hare in competing with nearby hubs, such as Cincinnati, for national traffic flows because O'Hare is the only slot-controlled hub airport in the United States. The additional slots that the Department has been asked to make available at O'Hare cannot begin to redress the overwhelming advantage enjoyed by Delta and Comair in operating at an unconstrained airport.

Counsel: American, Carl Nelson, 202-496-5647, carl_nelson@amrcorp.com

Motion for Leave to File and Reply of Atlantic Coast Airlines to Comments of Comair

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Comair's arguments for rejecting the current O'Hare slot exemption applications lack both merit and substance. To credit Comair's position would be tantamount to reverting to the policies embodied in the pre-deregulation Federal Aviation Act. Moreover, Comair is asking the Department to ignore the Congressional directive to expand service opportunities between non-hub cities and O'Hare. Finally, Comair has mischaracterized ACA's motives for seeking O'Hare slots. Accordingly, the DOT must reject the selfserving and protectionist arguments of Comair and promptly proceed to decide the issues raised by the competing slot applications of ACA and Simmons.

Counsel: Bagileo Silverberg, Robert Silverberg, 202-944-3300

Great Lakes Aviation, Ltd. d/b/a United Express (Service to Essential Air Service Points for Chicago O'Hare)

Order 98-1-16 | OST-97-3153 | Issued January 21, 1998 | Served January 27, 1998

Order Denying Application for Slot Exemptions at Chicago O'Hare (Editor's Note: This PDF File Courtesy of the Department with Editor's Enhancements - Originally Issued January 21)

By this order the Department is denying the application filed by Great Lakes Aviation, Ltd., d/b/a United Express, for exemptions from 14 CFR Part 93, Subparts K and S. to enable 20 additional flight operations at Chicago's O'Hare Airport to provide essential air service (EAS) at Ironwood and Marustee, Michigan; Mattoon, Mount Vernon, and Sterling/Rock Falls, Illinois; and Ottumwa, Iowa.

We do not contest Great Lakes' expectation that traffic would increase over time in response to the addition of a third round trip. It is far from clear, however, that it would do so in sufficient volume to ultimately reduce the carrier's overall subsidy need. The affected communities' traffic histories do not indicate a need for increased service, and Great Lakes' trafficc projections under the proposed higher service level do not reflect significant traffic stimulation.

Appendix - Historical Enplanements At Great Lakes' O'Hare EAS Communities

By: Charles Hunnicutt