OST-98-4647 / American Eagle / High Density Rule - Chicago O'Hare / Answer of Savannah/Hilton Head / November 17, 1998
Application of
AMERICAN EAGLE AIRLINES, INC. /
Docket OST-98-4647under 49 U.S.C. 41714 for an exemption from the high density rule governing Chicago O'Hare slots (14 CFR Part 93 (Greenville/Spartanburg, South Carolina)
ANSWER OF THE COMMUNITY OF
SAVANNAH, GEORGIA/HILTON HEAD, SOUTH CAROLINA
On
March 11, 1998, the community of Savannah, Georgia/Hilton Head, South Carolina ("Savannah/Hilton Head") along with other municipalities and businesses from the states of Georgia and South Carolina /1 ("Parties") requested that the Department of Transportation ("Department") grant an exemption from the requirements of Subparts K and S of Part 93 of the Federal Aviation Regulations to award the necessary slots so that they may obtain direct nonstop service to Chicago's O'Hare Airport. The parties requested eight slots at O'Hare to allow four Savannah/Hilton Head-O'Hare round-trip flights.1/ The parties include the Governors of Georgia and South Carolina, Chambers of Commerce, the Savannah/Hilton Head Area Convention and Visitors Bureau, and civic officials, hotels, resorts, and businesses from throughout the South Carolina and Georgia areas. (Copies of letters of support were submitted with the petition.)
After the Parties filed the March 11 petition, Atlantic Coast Airlines d/b/a United Express ("ACA") filed an application for slots under the provisions of Subparts K and S of the Part 93 of the Federal Aviation Regulations ("FAR's") (14 C.F.R. Part 93, Subparts K and S) ("Subparts K and S" or the "High Density Rule") to authorize ACA to conduct five operations (three roundtrip flights) at O'Hare utilizing 50-seat regional jet aircraft to and from Savannah/Hilton Head. ACA has constructed a three daily roundtrip flight schedule using the requested exemption authority and combined it with an operation in a non-controlled hour.
American Eagle Airlines, Inc. also filed an application for an exemption from the high density rule to obtain three exemption slots at Chicago O'Hare International Airport under 49 U.S.C. §41714. American says that it will use these three exemption slots plus "three additional slots of its own" to operate three daily roundtrips between O'Hare and Greenville/Spartanburg, South Carolina. American will use 50-seat regional jet equipment to operate these services.
As stated in ACA's application, "the combined Savannah, Georgia/Hilton Head, South Carolina market is now the largest Chicago O'Hare market without nonstop service." In its comments in this docket (OST-98-4647), ACA again shows that the Savannah/Hilton Head market is the largest O'Hare market without non-stop service (
See Exhibit 2 to ACA's November 9, 1998 Answer). The Savannah/Hilton Head market is significantly larger than the Greenville/Spartanburg market (according to ACA, larger than Greenville/Spartanburg). Not only is it the largest market without O'Hare service, but it continues to grow with new business and leisure destinations opening and under planning. Based upon the data depicting available traffic, marketing and potential growth information for the two-state area, there is no doubt that the service in the ACA application, as well as that proposed by the Parties, justifies an exemption to allow O'Hare service. Awarding available slots for Savannah/Hilton Head would result in much greater numbers of passenger enplanements to Chicago and overall economic benefits than if those slots were Awarded to Greenville/Spartanburg.Although smaller than Savannah/Hilton Head, Greenville/Spartanburg has service to more hubs, including hubs that provide its residents with access to areas of the country and the world that Savannah/Hilton Head is seeking through its and ACA's application.
Under a totally deregulated system with no barriers to entry, Savannah/Hilton Head and Greenville/Spartanburg would be able to secure service to O'Hare. Unfortunately, O'Hare is a restricted high-density airport. With capacity restricted by FAA regulations so that only a few additional flights at O'Hare may be authorized, the capacity should be awarded to the community with the largest unserved Chicago market -- Savannah/Hilton Head.
In this case, that same community also has the best potential for additional growth, has been aggressive in utilizing market practices to attract other service, and has generated enormous community support for its effort to secure much desired service to Chicago. As DOT has suggested, Savannah/Hilton Head has taken a number of important steps to attract service. The service that has started in Savannah/Hilton Head has exceeded all expectations. In some cases, carriers started with a few flights and added service to accommodate growing demand. For all of these reasons, it is time for the Department to make an award of all available slots to Savannah/Hilton Head.
Maximum economic development for the Savannah/Hilton Head area cannot exist when its service is limited and those wishing to travel to or do business in the area do not have reasonable access to major parts of this country and to the world.
By adding convenient one-stop service to most major Canadian, Asian and European markets through O'Hare, the resorts and businesses in the area would be able to attract a significant number of new customers. Without that service, the area is disadvantaged as to other areas with significant international service.
As demonstrated by the applications submitted by the Parties and ACA, there is a significant market for Savannah/Hilton Head-O'Hare service. As the largest market without service, the Savannah/Hilton Head market will continue to grow, particularly with ACA's already successful Washington-Dulles service. If service is to be a reality for the spring of 1999, the Parties need an answer as soon as possible.
Therefore, the Parties request that the Department immediately grant the slots requested by the Parties and ACA.
Respectfully submitted,
Edward P. Faberman
UNGARETTI & HARRIS
1747 Pennsylvania Avenue, NW
Suite 900
Washington, DC 200006-4604
Tel: (202)778-4460
Fax: (202)33-1486
SUBMITTED: November 17,1998