OST-00-6838 / Sun Country / High Density Rule - New York Kennedy / January 31, 2000

Application of

SUN COUNTRY AIRLINES, INC. / OST-00-6838

under 49 U.S.C. § 41714 for an exemption from the high density rule governing JFK International slots (14 C.F.R. Part 93) (Minneapolis/St. Paul, Minnesota)

Sun Country Airlines, Inc., pursuant to 49 U.S.C. § 41714, hereby applies for an exemption from the high density rule, 14 C.F.R. Part 93, Subparts K and S, to enable operation of one daily round-trip flight between JFK International Airport and Minneapolis/St. Paul, Minnesota using 170-seat Boeing 727-200 aircraft. Sun Country seeks two exemption slots to operate its proposed nonstop point-to-point service.

Sun Country plans to begin the new service in May 2000. Accordingly, the Department is requested to accelerate the answer date, and issue its decision on an expedited basis, so that Sun Country can make the arrangements necessary for operation of the service.

Minneapolis/St. Paul presently has only the barest minimum nonstop daily service to JFK. Sun Country operates a single round-trip that arrives 10:20 and departs 12:50, well bef6re the 15:00-20:00 period covered by the high density rule. No other point-to-point service is offered between the involved airports. Sun Country's additional nonstop round

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trip daily flight thus will double the amount of convenient direct service offered to the public in the market. All other Minneapolis/St. Paul-JFK service is highly circuitous and passes through connecting hubs at O'Hare or St. Louis.

Sun Country will offer walk-up and advance purchase fares at the same level charged for its existing non-high density rule flight. Sun Country's average nonstop one-way fare between Minneapolis/St. Paul and JFK is $129 (see attached illustrative data). This is significantly lower than the prevailing one-way average fare of $227 in that market for inferior connecting service. The difference in advance purchase fares is even greater. Sun Country's lowest advance -one-way fare in the market is $99; the lowest advance one-way fare via a connecting hub is offered by Trans World Airlines via STL at $629.

Sun Country qualifies as a "new entrant air carrier" for purposes of 49 U.S.C. § 41714 because it does not hold or operate (nor has it held or operated, since December 16, 1985) any slots at JFK. See 49 U.S.C. § 41714(h).

Sun Country's request for two exemption slots also is justified by exceptional circumstances. Sun Country proposes to double the existing nonstop point-to-point service between Minneapolis/St. Paul and JFK, thereby increasing the amount of low-fare direct service in a market otherwise served exclusively through circuitous connecting hubs. The fare differences flowing from Sun Country's proposed service are substantial. For example, the highest walk-up fare offered by Sun Country is S299 one-way. The lowest walk-up fare offered by Northwest is $618 one-way, a difference of $319 or 107 percent.

In this case, Sun Country, the only carrier operating nonstop service, is also a low-. fare carrier, offering fares much lower than charged for inferior, circuitous connecting

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service. Grant of the requested exemption slots thus could provide substantial public benefits by doubling the daily volume of low-fare seats in a neglected market.

The instant application for JFK exemption slots gains further support because, as shown in the attached pro forma, there is a reasonable expectation that the proposed service would be operationally and financially viable. Sun Country forecasts an operating profit of $3 million to be obtained from the daily nonstop flight in its first twelve months; 78,642 passengers are estimated to use the additional service made possible by the sought exemption slots.

For the foregoing reasons, the Department should, pursuant to 49 U.S.C. § 41714, grant two exemption slots to enable Sun Country to operate nonstop service between Minneapolis/St. Paul and JFK International, using Boeing 727-200 aircraft, to begin in May 2000.

Respectfully submitted,

Dennis N. Barnes

Attorney for Sun Country Airlines, Inc.

Dated: January 31, 2000

Boeing 727-200 aircraft MSP-JFK

Scheduled Departures: 736

Departures: 721

Block Hours: 1,658

BL HRS/Departure: 2.3

Average Seats: 170

Aircraft Miles: 733,257

Stage Length: 1,017

Passengers Carried: 78,642

Passengers/Departure: 109

RPMS (000): 57,664,796

ASMS (000): 89,875,310

Load Factor: 64.1%

Passenger Fare - Average: $139.09

Passenger Trip: 1,017

Passenger Yield: 13.67 cts

Breakeven Load Factor: 45.8%

Cost/ASM-Average: 6.2 cts

Total Passenger Revenues: $11,078,032

Operating Expenses: $8,028,872

Operating Profit/(Loss): $3,049,160