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OST-99-6547

Spirit Airlines, Inc.

Counsel:  GKMG Consulting, Anita Moser, 202.342.5201

Spirit Airlines, Inc.

Spirit's planned services would advance the public's interest and comport with the Department's criteria for granting an exemption in all respects. Spirit is a new entrant, low-fare airline that is poised to bring the benefits of competition -- and low fares -- to a market that is presently non-competitive. If granted the requested exemption from the slot rule at LaGuardia Airport, Spirit proposes to offer low-fare, nonstop schedule service using MD-80 jet aircraft that meets Stage 3 noise requirements. In Order 97-10-17, the Department expanded its definition of exceptional circumstances to recognize the need for competitive service in a market -- especially for low fare competitive service. The Department clarified that exceptional circumstances exist "where consumers would be able to obtain significantly lower fares in noncompetitive or under served markets."

Counsel:  Broward County Aviation Diector, William Sherry

New York continues to rank as the number one market for the region in terms of visitation and passenger traffic. However, the fluctuations in the number of passengers from year to year are a direct reflection of a lack of stable and affordable air service. Our air trade area can support - and desperately needs - more frequent and affordable New York service to meet the growing market demand. It is the only way we will be able to realize the economic benefits of Southwest Florida's popularity in the New York market. We have already experienced the benefits related to Spirit's entry into the market. Detroit has consistently ranked as one of the top visitor markets to Southwest Florida. Its full potential was constrained due to a lack of frequent and affordable air service.

By:  Lee County, Robert Ball

The New York-Orlando market has enough capacity to sustain Spirit's proposed service. Two of the three New York City area airports (Newark and LGA) are the top two domestic O&D markets for Orlando, according to second quarter 1999 data. The third (JFK) was in the top 20. As such, these three airports -- both individually and collectively -- represent a very significant passenger and shipper market for Orlando.

Counsel:  Preston Gates, Jonathan Blank, 202.662.8450

Spirit Airlines, Inc. hereby files the attached letter in support of its Application from Palm Beach International Airport. Spirit Airlines is seeking the award of fourteen exemption slots so that it may provide new nonstop jet service between New York's LaGuardia Airport, on the one hand, and Detroit, MI, Ft. Lauderdale, FL, Ft. Myers, FL, Orlando, FL, Tampa, FL, and West Palm Beach, FL, on the other hand. As demonstrated by the attached letter in support (Exhibit No. 1), there is great need and desire for reliable, convenient, low-fare nonstop jet service to and from LaGuardia.

Counsel:  GKMG, Anita Mosner, 202-342-5201

Spirit Airlines, Inc.

The President of the Borough of Queens is the highest level county-wide executive in Queens County in New York City. If Spirit Airlines' application for 14 slot exemptions at LaGuardia Airport is granted, it would have a significant adverse impact on the residents of Queens County, which is the home of both LaGuardia and John F. Kennedy International Airport and has a population of approximately two million individuals. Because the Borough President is elected by and represents the entire county, and works closely with the aviation industry to balance the economic and transportation benefits of that industry with its negative impacts on residents, the Borough President's Office is in the best position to represent Queens County's interest in this proceeding.

Counsel:  Queens Borough President, Hugh Weinberg

Spirit Airlines, Inc.

If there is any room left for discussion of the benefits to be offered by Spirit’s proposed services, the Department need only look at the use Spirit has made of its LGA-Melbourne and LGA-Myrtle Beach exemption authority. Since Spirit introduced service at Melbourne, average fares in the market have declined 63%, and O&D traffic has increased 964%. At Myrtle Beach, Spirit’s service has brought a 67% fare reduction, and a greater than 500% traffic increase. See Application of Spirit, at 5. The Borough of Queens’ claim that there is a "lack of public benefits that would accrue from any new service" (Answer, at 10) should be put to rest.

Counsel:  GKMG Consulting Services, Anita Mosner, 202.342.5201

Spirit Airlines, Inc.

Counsel:  Office of the Queens Borough President, Hugh B. Weinburg

Spirit Airlines, Inc.

The Office of the President of the Borough of Queens in New York City hereby requests permission to file this unauthorized document in order to supplement its original answer to Spirit Airlines' application for slot exemptions at LaGuardia Airport. We seek to file this document in light of recent factual developments which, we believe, should be considered in connection with Spirit's application. 
While Spirit is factually accurate in its observation that it is within its legal rights to fly the MD-80 aircraft in the routes for which it is seeking exemptions, we believe that it is within the discretion of the decision-makers at the United States Department of Transportation (DOT) to take notice of the particular aircraft model which those seeking exemptions seek to use.  In this case, given the recent problems experienced by Alaska Airlines with its MD-80 aircraft and the federal government's recent decision to inspect all MD-80 and similar aircraft, we respectfully request that the DOT give added weight to Spirit's proposed use of the MD-80 aircraft. The Borough President's Office is of course concerned about the safety of air travel for all those traveling, as well as for all those living near and around airports and under flight paths. For all the reasons stated in the Borough President's December 8, 1999 response and in all subsequent submissions to the DOT, it is respectfully submitted that Spirit's application be denied in its entirety.

Counsel: Queens Borough President, Hugh Weinberg

Establishment of Slot Exemptions Proceedings 

By:  Bradley Mims

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