OST-99-5712 / Oshkosh, Wisconsin / Application of Air Wisconsin Airlines for EAS / December 28, 1999

Essential Air Service at

Under 49 U.S. C. 41731 et seq.

APPLICATION OF AIR WISCONSIN AIRLINES CORP.

By Order 94-11-12, the Department granted Great Lakes Aviation exemptions from Subparts K and S of Part 93 of the Federal Aviation Regulations (the "HDR") to operate four daily services at Chicago's O'Hare International Airport for the purpose of providing essential air service ("EAS") at Oshkosh, Wisconsin. On May 20, 1999, Great Lakes filed in this docket a 90day Notice of its intent to suspend its subsidy-free service at Oshkosh. As a result of that Notice, Air Wisconsin Airlines Corp. ("Air Wisconsin" or "AWA") hereby requests an exemption from the HDR pursuant to section 41714 of the statute to the extent necessary to use the four exemption slots allocated to Great Lakes Aviation for EAS service at Oshkosh as follows: Two of the exemption slots would be used to provide a daily roundtrip flight between Appleton and O'Hare, serving Oshkosh as a hyphenated point with Appleton; the other two slots would be used to provide an additional daily nonstop roundtrip flight between Central Wisconsin Airport ("CWA") and O'Hare, thus simultaneously satisfying CWA's request for an additional daily service to O'Hare in docket OST-99-6636.

In support of this request, AWA submits the following:

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1. The grant of this exemption request will secure significant benefits for the State of Wisconsin. Among other things, the grant will ensure the residents of all four of the Wisconsin communities affected -- Oshkosh, Appleton, Wausau and Stevens Point -- convenient and reliable quality air service to O'Hare. As noted below, this air service would be provided with newer, more modern equipment than Great Lakes today operates at Oshkosh. More reliable service to O'Hare Airport would, in turn, provide these communities improved access to the network of national and international air transportation services available there. Such improved access for Oshkosh and CWA to the national air transportation system meets one of the fundamental goals of the EAS program. /1

Air Wisconsin will use 32-passenger Dornier 328 turboprop aircraft for these new nonstop flights to O'Hare. These high-speed, turboprop aircraft will provide the reliable, convenient service to O'Hare that all of these Wisconsin communities need. The Dornier 328 will have cabin-crew service available, and the aircraft feature restroom facilities, comfortable seating and more adequate headroom than the aircraft Great Lakes currently uses to serve Oshkosh. In the case of Oshkosh, AWA's introduction of nonstop service with Dornier aircraft will offer the community a much needed service improvement from the tag-end service it currently receives

1/ The EAS program aims at ensuring "service [that] is convenient and affords reasonable, timely access to the national air transportation system." Order 84-7-76 at 2. Access to O'Hare, and the access O'Hare affords to the national and international air transportation system, is of vital importance for the Appleton/Oshkosh and CWA communities. The CWA Airport Board has emphasized that O'Hare is CWA's largest O&D market and that during the past ten years fully one half of CWA's O&D and connecting passengers have moved through O'Hare. See Application of CWA Board, Docket OST-99-6636 (November 23, 1999). Oshkosh, too, considers access to O'Hare essential. See Objection of Winnebago County at 1-2.

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from Great Lakes with 19-seat aircraft that lack both cabin staff and lavatory facilities. See Objection of Winnebago County at 4-5. In the case of CWA, AWA will be able to offer an extra daily flight between CWA and O'Hare increasing both the number of daily frequencies available and offering the community much needed additional seating capacity. /2 See Application of CWA Board at 1-2.

2. Air Wisconsin intends to serve Oshkosh as a hyphenated point with Appleton, serving the city through the Outagamie County Regional Airport, which is only a 30-minute drive from Oshkosh and serves both communities. With the service to Oshkosh hyphenated with Appleton, all CRS displays for this service and all schedules published in other media, as well as all new marketing and promotional materials, will refer to the community as Appleton/Oshkosh. CRS inquiries for service to Oshkosh will default to the Appleton/Oshkosh display.

Air Wisconsin believes that the grant of this request will resolve the current air service dilemma at Oshkosh, while also improving the service available at CWA. With the grant of this application, Appleton/Oshkosh will have seven daily nonstop flights available to O'Hare as opposed to the two daily flights now available at Oshkosh; CWA will have five daily O'Hare

2/ As part of an ongoing process to improve and rationalize the services provided by commuter carriers under the United Express service mark, effective as of January 5, 2000, the United Express service UFS now operates between CWA and O'Hare will be operated by Air Wisconsin. With the grant of this application, Air Wisconsin will be able to offer the communities of Wausau and Stevens Point, which are served by CWA, a total of five daily roundtrips to O'Hare, rather than the four UFS has been operating. See Request of the People and Businesses of Akron-Canton, Ohio to Withdraw Application, Docket OST-99-5676 at 1 (Oct. 15, 1999), for a full description of the ongoing efforts to enhance the United Express service available at small communities.

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nonstops as opposed to the four currently available. The grant of this application will also allow Air Wisconsin to increase the service it operates in its home state and to enhance the efficiency of that service, better ensuring the service's long-term economic viability.

3. In the seven months since Great Lakes announced its intention to suspend subsidy-free service at Oshkosh, no carrier has offered to provide replacement service. Since August, the Department has, therefore, been required to order Great Lakes to continue serving Oshkosh, imposing on the Department an obligation to subsidize Great Lakes' service. See Order 99-8-11 at 2. The subsidy rate approaches half a million dollars annually. The grant of the instant request for exemption slots will enable Air Wisconsin to preserve and improve service to Oshkosh, while eliminating the need for subsidy, and thereby relieve the Department of the burden such subsidy obligation imposes on the limited resources available for subsidized EAS service. /3

WHEREFORE, for all of the foregoing reasons, Air Wisconsin requests an exemption from the HDR as detailed above.

3/ It is entirely possible that with Air Wisconsin's decision to hyphenate Oshkosh and Appleton, the other carriers serving Appleton - Northwest from its hubs at Detroit and Minneapolis, Comair from Cincinnati and Midwest Express from Milwaukee - will also find it commercially advantageous to do so.

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Respectfully submitted,

GEOFFREY T. CROWLEY

CHAIRMAN, PRESIDENT & CEO

AIR WISCONSIN AIRLINES CORP.

W6390 Challenger Drive, Suite 203

Appleton, WI 54915-9120

(920) 739-5123 (Phone)

(920) 749-4158 (Fax)

DATED: December 28, 1999