OST-97-2985 / Simmons Airlines, Inc. d/b/a American Eagle / Answer of Springfield-Branson Regional Airport / October 24, 1997

Application of

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

under 49 USC 41714 for an exemption from the high density rule governing Chicago O'Hare slots (14 CFR Part 93)

 

ANSWER OF SPRINGFIELD - BRANSON REGIONAL AIRPORT TO APPLICATION OF SIMMONS AIRLINES, INC. FOR AN EXEMPTION

 

Pursuant to Rule 406 of the Department's Rules of Practice, (14 C.F.R.) S302 406, the Springfield-Branson Regional Airport (Springfield) hereby answers the Application of Simmons Airlines, Inc. (Simmons) seeking an exemption from the high density rule regarding airport slots at Chicago's O'Hare airport. Springfield believes that Simmons has demonstrated sufficient reason to warrant grant of its Application. In support of its Answer, Springfield states the following:

 

1. By Order 96-10-42, the Department sought applications, "...from carriers interested in providing air service between small communities (non hubs) and Chicago O'Hare Airport .." (Page 1). Referring to the President's signing of the Department's F/Y 1997 appropriations level, the Department said that the report language expressed Congress' desire that the Department enable increased access to O'Hare Airport, particularly for small and medium sized communities. The Department noted that, "The Secretary is also directed to use exemption authority to improve service to nonhub airports where significant improvements can be achieved." (Order, Page 2.)

 

2. Following that Order and its language, on October 9, 1997, Simmons, an American Eagle carrier, filed an application for exemption to enable it to provide service between ten small, nonhub communities -- including Springfield, MO, and O'Hare Airport. Simmons proposes to operate, beginning in 1998, three daily nonstop roundtrips in each market using 50 seat Embraer 145 regional jet aircraft. If sufficient aircraft are not immediately available to start service to all communities, Simmons will initiate service to five of them, including Springfield, using Saab 340B or ATR 42 aircraft presently in its fleet.

 

3. Springfield, MO is a nonhub airport with a significant community of interest with Chicago. Chicago is Springfield's third largest true O-D market, generating almost 24,000 passengers in 1996 (Appendix A). At Chicago, AA and its commuter affiliates would be able to provide direct on-line connections in an additional fifteen (15) markets which generate over 67,000 Springfield true O-D passengers. On a combined basis, Simmons' proposal potentially will convenience almost 90,000 total Springfield travelers.

 

The preceding figures are substantially understated. SH&E conducted a survey of Springfield area travel agencies for 1996. Over 75,000 tickets were analyzed. 31% of the total travelers ticketed locally began their trip at St. Louis, Kansas City or Tulsa, instead of at the local Springfield airport. For Chicago and the cities which could flow via ORD to points in the East, the survey identified the "leakage" from the local airport as 34%. That would bring the total traffic which Simmons could convenience to a level in excess of 120,000 passengers.

 

Springfield does not have nonstop service in the 442 mile Chicago market. While connecting service always has been available, TWA's single plane, one-stop is of recent vintage. One stops also are provided twice daily by American Eagle.

 

In the Spring of 1997, Springfield made a detailed presentation seeking nonstop ORD service to a major airline. After review, that airline declined to initiate the requested service, citing the lack of slots as a key factor.

 

For a brief time between October 1, 1988 and May, 1989 United Airlines provided nonstop service to and from Chicago (ORD) with three daily B-737 roundtrips. American Eagle provided three roundtrips in the same market but only for a very short time in 1994 -- approximately four months. During that period it carried almost 7,600 passengers -- 20 per trip. Springfield definitely will generate sufficient traffic to and through O'Hare to produce a profitable operation for Simmons.

 

4. By Order 97-1-7, the Department granted O'Hare slot exemptions to Great Lakes Aviation for service to five small communities: Dubuque and Mason City, Iowa, Huron and Sioux Falls, South Dakota and Fargo, North Dakota. In that Order, the Department noted that, "Great Lakes' proposal is fully consistent with the congressional intent, described above, that the Department make the fullest use of its exemption power to 'improve service to nonhub airports where significant improvements can be achieved'...".

 

The Springfield - O'Hare market is considerably larger than four of the five markets in which Great Lakes was granted an exemption. Only Sioux Falls is larger but that market enjoyed nonstop jet service on United as well as UA Express and received one stops from Northwest and, at times, TWA in 1996. (Now, all nonstop service is by UA*.) (Appendix C) Clearly, if those markets qualify for an exemption, so does Springfield.

 

5. Nonstop service in the 442 mile Springfield - O'Hare market will represent a "significant improvement" compared to what is available today. The market is too long for nonstop turboprop aircraft to serve. It is the ideal length and size for the regional jet which Simmons proposes.

6. As Simmons' filing notes, United and its affiliates hold 1,016 O'Hare slots compared to 898 for American and its affiliates. Grant of added slots to Simmons will enhance the competitive level at O'Hare.

 

7. Attached to this Answer are several letters from Springfield area businesses in support of granting the exemption to Simmons (Appendix D).

 

For the reasons cited above, Simmons application for slot exemption should be granted as expeditiously as possible.

 

Respectfully Submitted,

SH&E, Inc., Robert Dunn

On behalf of:

Robert Hancik, Director
Springfield - Branson Regional Airport