OST-97-2984 / American Trans Air (exemption Sarasota, FL-New York (LGA)) / Answer of Sarasota Manatee Airport Authority / Dated October 14, 1997

Application of

for an exemption pursuant to 49 U.S.C. § 41714 (c) (Sarasota, Florida-New York (La Guardia Airport)

I. THE SARASOTA-BRADENTON MARKET IS LARGE AND GROWING

Sarasota and Manatee have the seventh largest MSA population in Florida. Sarasota Bradenton International Airport is the gateway to several Central Florida tourist attractions, including the Ringling Museum of Art, Mote Marine Aquarium, Selby Gardens and the Asolo Theater. While predominantly a leisure market, Sarasota-Bradenton has become a rapidly growing business community as evidenced by the presence of Tropicana Beverages (4000 employees), Arthur Andersen (500 employees) and recent arrival Ameritech ( 1500 employees in 3 years). The Sarasota-Bradenton area was ranked 1st in the U.S. for annual rate of increase in new jobs in a metropolitan area as published by the Bureau of Economic Analysis, U. S. Department of Commerce.

With its proximity to Tampa, Sarasota-Bradenton has had to compete for service to address the needs of the local community. Tampa is not, however, a substitute for direct services. The drive between our service area and Tampa can be quite lengthy. Moreover, the markets are distinct. Despite the fact that the economy of the Sarasota-Bradenton area is flourishing, with the growth of tourism and with corporations locating in the area to take advantage of a hospitable business climate and educated workforce, Sarasota Bradenton International Airport has faced a decline in air service. The Sarasota Bradenton International Airport once served over 2 Million passengers annually (1990). In 1996, less than 1.6 Million passengers utilized the Sarasota Bradenton International Airport. This is a loss of 400,000 passengers or 20% of our market coming during a period of substantial growth.

Sarasota Bradenton International Airport has lost two major carriers since 1994 (American Airlines and United Airlines). TWA recently announced cessation of service from Sarasota Bradenton International Airport. Intercession by the community and the Airport convinced TWA to reverse that decision, however, the service level was reduced from four flights per day to one flight per day. ATA's proposal to launch nonstop seasonal service to New York's La Guardia Airport will receive the active support of the Sarasota-Bradenton community. The New York area is undeniably Sarasota-Bradenton's largest origin destination market, generating 65,000 passengers per year. When combined with Newark, the New York area generates nearly 165,000 passengers per year. SMAA estimates we have an additional 20% to Tampa International. As a result of the scarcity of nonstop service, the community will be forced to use connecting services or endure long drives to other Florida gateways to meet their air service needs.

Sarasota-Bradenton has lost service over the last five years and has very limited service from low fare carriers, that being ATA. The lack of nonstop service to La Guardia forces our customers to utilize the hub cities on the higher fare major carriers or travel to Tampa for nonstop service.

If Sarasota-Bradenton is to sustain its economic growth and continue to attract high caliber technology and aerospace corporations, it must be in a position to offer competitive air service at competitive fares. While the placement of this seasonal service does not address completely the service needs of our community in that market, we believe it will demonstrate to ATA and other carriers the opportunity that exists at Sarasota Bradenton International Airport and lead to additional service in our market.

With the approval of this exemption, ATA's La Guardia service will offer a low fare competitive alternative. With its support of ATA's application for an exemption, we are asking the Department to let the market forces demonstrate the demand in our area and assist our community in securing better air service through this demonstration.

WHEREFORE, for the reasons stated above, Sarasota Manatee Airport Authority respectfully urges the Department of grant to ATA an exemption from Subparts K and S of Part 93 of the Federal Aviation regulations to the extent necessary to permit ATA to operate the seasonal nonstop, roundtrip flight from Sarasota Bradenton International Airport to New York's LaGuardia Airport.

Respectfully submitted,

FREDRICK J. PICCOLO, A.A.E.
Executive Director
Sarasota Manatee Airport Authority