OST-99-5533 / Huntsville-Madison County / High Density Rule - Chicago O'Hare / Reply of Huntsville / May 6, 1999

 

Application of

HUNTSVILLE-MADISON COUNTY AIRPORT AUTHORITY DOCKET / OST-99-5533

For exemption from 14 CFR Part 93, Subparts K and S, under 49 U.S.C. 41714 for nonstop service to Chicago O'Hare

 

REPLY OF HUNTSVILLE-MADISON COUNTY AIRPORT AUTHORITY

 

The Huntsville-Madison County Airport Authority hereby replies to the answers filed on April 27, 1999 by United Air Lines, Inc. and Atlantic Coast Airlines, a United Express affiliate carrier. These were the only answers opposing Huntsville's application, which is seeking the award of four exemption slots to support nonstop service to Chicago O'Hare International Airport.

 

United's answer claims that it opposes the award of O'Hare slots to-communities " as a matter of policy," and asserts that it also opposed the prior grant of slots to Greenville/Spartanburg and Savannah/Hilton Head by Order 99-3-12. We have two replies to United's "policy" argument. One is that the Department has already rejected United's position in its order awarding community slots to Greenville/Spartan-

 

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burg and Savannah/Hilton Head, and United is merely repeating arguments that it has already lost. As our response to United on this point, we refer the Department to its own determination in Order 99-3-12.

 

Second if the Department now decides that community awards are not appropriate, despite Order 99-3-12, the Department can instead grant the parallel application for O'Hare-Huntsville exemption slots filed by American Eagle Airlines on April 27, 1999 in Docket OST-99-5587. The Huntsville-Madison County Airport Authority does not care about the procedures used to make slots available. We do care very strongly about achieving nonstop service to O'Hare. As United itself recognizes, "nonstop service to Chicago is important to communities the size of ... Huntsville both because of the access it makes available to Chicago, the principal business center in the Midwest, and because of the access it affords to other communities throughout the U.S. and the World through the global networks ... operates[d] at O'Hare."

As for the answer by Atlantic Coast Airlines, a United Express affiliate of United Air Lines, its opposition to Huntsville's application appears to be motivated solely by its own interest in obtaining O'Hare exemption slots to serve other communities, such as Mobile (Docket OST-99-5581), Charleston (Docket OST-99-5583), and Savannah/Hilton Head (Docket OST 98-3603). As far as any comparison between the merits of Huntsville and Mobile as candidate communities for nonstop Service to Chicago O'Hare, we submit that Huntsville is far more deserving of favorable consideration.

 

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The maximum transportation benefit would be greater out of Huntsville than Mobile because a greater number of Huntsville passengers can be served traveling to Chicago and beyond than Mobile passengers. If you compare the actual passengers which could connect to and beyond Chicago, the number of Huntsville passengers is 368,888 with revenues of $72,859,692 while Mobile has 246,229 passengers with revenues of $41,762,864. When you add the number of inconvenienced Huntsville market passengers driving long distances to other airports the potential Huntsville/Chicago numbers increase to 447,341 passengers with revenues of $82,683,724. Forecasts show that two daily roundtrips connecting Huntsville with Chicago and points beyond would generate 58,000 passengers and three daily roundtrips, 76,000 passengers.

Mobile states they have attracted more jobs than Huntsville since 1990. However the Alabama Development Office stated in March of 1998 "Madison County (Huntsville) leads all other Alabama counties in announced new and expanding industrial jobs seven out of the past eight years" . These industrial jobs help raise the standard of living for our citizens. In fact, NAVISTAR, which is headquartered in Chicago, recently announced plans to employ up to a 1,000 people in Huntsville to produce a new generation of diesel engines. Huntsville not only boast the highest average annual pay in Alabama, it can also claim the highest median family income in the southeast United States. Higher incomes mean more discretionary dollars for consumers to spend on items such as travel, therefore increasing the need for air service access. Huntsville is also

 

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known as the "Silicon Valley of the South". obviously high-tech markets like Huntsville require more air service to meet the needs of business and commerce.

 

It should be noted that United Airlines provided non-stop service between Huntsville and Chicago in addition to Los Angeles, Washington, DC and Denver. After 35 years of service they made the decision to leave the market - it was not for the lack of community support. Huntsville has a proven track record with the Chicago market. We are trying to gain back what we lost and American Eagle is willing to provide this transportation benefit to the public.

 

For the foregoing reasons, the Department should grant the application of the Huntsville-Madison County Airport Authority for exemption slots to allow nonstop service to Chicago O'Hare.

 

Respectfully submitted,

 

Richard Tucker

Executive Director

Huntsville-Madison County Airport Authority

May 6, 1999