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					                           BEFORE THE
                   DEPARTMENT OF TRANSPORTATION
                         WASHINGTON, D.C.



____________________________________________
                                              )
Answer of                                     )
                                              )
        PORT OF SEATTLE                       ) Docket No. OST-2000-7181
                                              )
in support of Application of Alaska Airlines, )
Inc., for an exemption from Subparts K and    )
S of 14 C.F.R. Part 93 pursuant to 49 U.S.C.  )
§ 41718(a) (Ronald Reagan Washington          )
National Airport-Seattle, Washington)         )
____________________________________________)


                  ANSWER OF THE PORT OF SEATTLE
                           IN SUPPORT OF
              THE APPLICATION OF ALASKA AIRLINES, INC.
                                AND
                      MOTION FOR LATE FILING


Communications with respect to this document should be addressed to:

Kazue Ishiwata                                  Anne Purcell, Port Counsel
Market Development Manager                      Isabel R. Safora. Senior Port Counsel
Aviation Director’s Office                      Port of Seattle
Port of Seattle                                 Legal Department
Main Terminal Building                          P. O. Box 1209
17801 Pacific Highway South                     Seattle, WA 98111
P.O. Box 68727                                  (206) 728-3212 (tel)
Seattle, WA 98168                               (206) 728-3205 (fax)
(206) 433-4698 (tel)                            purcell.a@portseattle.org
(206) 248-6855 (fax)                            safora.i@portseattle.org
ishiwata.k@portseattle.org




January 30, 2004
                              BEFORE THE
                      DEPARTMENT OF TRANSPORTATION
                            WASHINGTON, D.C.



____________________________________________
                                              )
Answer of                                     )
                                              )
        PORT OF SEATTLE                       ) Docket No. OST-2000-7181
                                              )
in support of Application of Alaska Airlines, )
Inc., for an exemption from Subparts K and    )
S of 14 C.F.R. Part 93 pursuant to 49 U.S.C.  )
§ 41718(a) (Ronald Reagan Washington          )
National Airport-Seattle, Washington)         )
____________________________________________)


                    ANSWER OF THE PORT OF SEATTLE
                             IN SUPPORT OF
                THE APPLICATION OF ALASKA AIRLINES, INC.
                      AND MOTION FOR LATE FILING


I.     Motion for Late Filing and Introduction

       The Port of Seattle, as the owner-operator of Seattle-Tacoma International Airport

(“SEA”), respectfully requests permission for the late filing of its Answer to the

Application of Alaska Airlines, Inc. (“Alaska Airlines”) for an exemption from subparts

K and S of 14 C.F.R. Part 93.

       Pursuant to 49 U.S.C. § 41718(a), as enacted by the Wendell H. Ford Aviation

Investment and Reform Act for the 21st Century (the "AIR 21 Act" or “AIR-21”), Vision

100 – Century of Aviation Reauthorization Act, P.L. 108-176 (“Vision 100”) and the

Department of Transportation’s (“Department”) December 17, 2003 Notice, the Port of

Seattle, as the owner-operator of Seattle Tacoma International Airport ("SEA"), submits


                                             2
this Answer to the Application of Alaska Airlines, Inc. ("Alaska Airlines”), for an

exemption from subparts K and S of 14 C.F.R. Part 93, to permit Alaska Airlines to

operate two additional daily roundtrip flights between Ronald Reagan Washington

National Airport (“DCA”) and Seattle-Tacoma International Airport (“SEA”). The Port

of Seattle fully supports the Department’s award of four slots under Vision 100 to Alaska

Airlines. Such an award would allow Seattle’s hometown carrier to increase its State of

Alaska-Seattle-DCA frequencies to three daily roundtrips. See Exhibit 6.

       Alaska Airlines is the best choice and should be granted four of the newly

available slot exemptions for the following reasons:

      Seattle is the largest market in the Pacific Northwest and the gateway to other
       cities in the Northwest, Alaska, Western Canada and Asia. Seattle’s importance
       as a major international city and gateway is reflected by the Northwest’s strong
       economic and population growth and rapid recovery since 2001 in international
       and domestic passenger traffic at SEA.

      Selection of Alaska Airlines for nonstop DCA-SEA service will have a
       larger market impact than selection of any of the other applicants’ proposed
       services.

      Delta, American, Continental and United are major slot holders at DCA and
       already have frequent service to their hubs from DCA.

      Alaska Airlines’ proposed expansion of DCA-Seattle service would have
       substantial network benefits, providing time-of-day choice for passengers flying
       to or through its largest hub (SEA) and the first one-stop, single-plane service to
       Fairbanks and Juneau. With expanded DCA-SEA service many small, isolated
       communities in the Pacific Northwest, Alaska and Canada would enjoy improved
       single-connection DCA service. Of these, 14 currently do not have any other one-
       stop connecting DCA service See Exhibit 3, 5.

      The allocation of four additional slot exemptions to Alaska Airlines would best
       further Vision 100’s purpose of maximizing competition. Alaska’s DCA-SEA
       service would further geographically distribute the limited slots, and thereby
       increase competition in multiple markets.




                                             3
      For all of these reasons, Alaska Airlines’ application provides the Department with a

unique opportunity to significantly improve one-stop connecting service from DCA to

many small communities in the Northwest, Alaska and Canada, and make DCA truly

competitive with other airports in the Washington area for travel to and through its

Seattle hub.

II.      Alaska is the Best Choice for Allocating Four Slot Exemptions

         Seattle is the largest market in the Pacific Northwest and the gateway to other

cities in the Pacific Northwest, Alaska, Western Canada and Asia. Seattle’s growing

importance as a major international city and gateway is reflected by the Northwest’s

strong economic and population growth and an increase in passenger traffic at SEA. See

Exhibits 1 and 4.

         Alaska’s DCA-Seattle-Anchorage flight provided Alaska with a new market

presence in the eastern United States. If there were no perimeter rule and no slot

restrictions, Seattle would surely be a market which would generate additional service to

DCA and Alaska. The Department of Transportation has long recognized that one daily

flight is not an effective schedule for domestic air service. The Department indeed sets

the minimum at two per day for most essential air service markets. Seattle was pleased to

get its first flight to Washington Ronald Reagan National Airport in 1991, but now the

Department has an opportunity to make that service much more than a token. The three

daily flights proposed by Alaska Airlines will provide nine roundtrip schedule choices for

passengers who today have only one choice.

         Industry giants American, Delta, United, Northwest and Continental all have

many-times daily services to their multiple hubs. Even AirTran and ATA have


                                              4
respectable Hub-DCA schedules. Similarly, Alaska Airlines is allowed only one daily

DCA flight and is one of only two airlines to be so severely restricted. The DOT can

make Alaska more competitive if it makes DCA-SEA nonstop air service effectively

competitive; to do otherwise would be unfair.

       Seattle is an important business center, one of the most important high-tech

centers in the world, home to numerous publicly traded and large companies, and an

important center of world trade. Seattle generates over 500,000 annual O&D passengers

to/from the three Washington area airports. See Exhibits 12, 14 through 20.

       Seattle Tacoma International Airport had very high traffic growth during the

decade from 1991 to 2000 and has recovered more quickly than other West Coast

Airports from the traffic drop after September 11, 2001. Domestic passenger traffic grew

by nearly 6.5% per annum through the 1990s. See Exhibits 1 and 2.

       The growth of Seattle-Tacoma International Airport is a reflection of the rapid

growth of Seattle, the Seattle-Tacoma metropolitan area and the regional economy.

Today, Seattle is the largest city in the Pacific Northwest, and the Seattle-Tacoma

metropolitan area is the 12th largest in the United States. See Exhibit 7. The Seattle

Tacoma metropolitan area economy is growing at a rate well above the national average.

From 1990 to 2000, the effective buying income of Seattle metropolitan area residents

grew 7.71%, ranking it 6th in the nation. Moreover, retail sales grew 6.91%, ranking this

metropolitan area 11th nationally and growth is continuing. See Exhibits 8 through 11.

       Given SEA’s very large catchment area, which covers Washington, Alaska and

parts of Oregon, Idaho and Montana, regional growth also bears some consideration.

With GDP growth very strong, the Pacific Northwest is growing rapidly. See Exhibits 8


                                             5
and 9. This tremendous regional growth is partly the result of the fact that Washington

State and the Seattle-Tacoma metropolitan area, in particular, are home to several of

America’s largest companies, including the largest software company in the world. See

Exhibits 18 through 20.

       Granting Alaska Airlines four additional slot exemptions to operate Fairbanks-

SEA-DCA and Juneau-SEA-DCA service would:

              Allow Alaska, with the smallest DCA presence of the limited incumbent
               carriers, to build on its single daily Anchorage-SEA-DCA roundtrip.
              Provide the first one-stop single-plane service from Fairbanks and Juneau
               to DCA, which will mean that the three principal cities within the State of
               Alaska would now enjoy one-stop single-plane service to DCA and all
               three would have multiple time-of-day connecting opportunities.

              Expand from one to two or three the single carrier connecting frequencies
               to DCA from 20 communities in the State of Alaska, allowing passengers
               to travel to and from DCA without an overnight layover at Anchorage or
               Seattle.

              Convenience tens of thousands of additional Washington State-, Oregon-,
               Montana/Idaho-, State of Alaska-DCA and international passengers with
               multiple complementary arrival/departure time channels. See Exhibits 21
               through 24.

              Take full advantage of the network benefits which flow from Alaska’s
               leading presence at both Seattle and Anchorage where Alaska, along with
               Horizon Air and its other codeshare partners, operate more than 650 daily
               flights to and from more than 70 beyond-market cities.


III.   Alaska Airlines’ Proposed Service Would Bring Substantial Network
       Benefits to the Pacific Northwest, Alaska and Canada

       Alaska’s proposed new Alaska-SEA-DCA flights will create significant local

market as well as network benefits, further bolster under-served markets, provide needed

competition and offer the benefits of travel on an airline that is a nationally recognized

leader in customer service to a greater number of Alaska-Seattle-Washington passengers.


                                              6
When combined with Alaska’s existing service, the three largest cities in Alaska –

Anchorage, Fairbanks and Juneau – will each enjoy daily one-stop single-plane flights to

DCA. Alaska’s service will greatly benefit Fairbanks, Alaska’s second largest city and

home to several military bases and the gateway to Alaska’s interior and Arctic regions,

including the Arctic National Wildlife Refuge and the North Slope. By providing Alaska

with the ability to offer two additional daily roundtrip flights, award of four slot

exemptions to Alaska will vastly increase the benefits available to its Alaska-SEA-DCA

passengers by offering a well-balanced pattern of flights throughout the day and much

improved connections to Alaska’s West Coast Network.

       WHEREFORE, the Port of Seattle respectfully requests that the Department

approve Alaska’s Application for four beyond-perimeter DCA slot exemptions pursuant

to 49 U.S.C. § 41718(a) or such other relief as the Department may deem appropriate.


                                       Respectfully submitted,




                                       By:____________________________________


                                               Anne Purcell, Port Counsel
                                               Isabel Safora, Senior Port Counsel

                                       On Behalf of:
                                       Port of Seattle



                                      January 30, 2004




                                              7
                               CERTIFICATE OF SERVICE


       I hereby certify that one copy of the foregoing Answer has this day been served

on all parties identified on the attached service list via e-mail unless otherwise noted.


                                                  _______________________________
                                                  Teresa Bach

DATED: January 30, 2004

Keith Loveless, Esq. (by Mail)                      Doyle C. Ruff (by Mail)
Vice President – Legal and                          Airport Director
    General Counsel                                 Fairbanks International Airport
Peter Kraus, Esq.                                   6450 Airport Way
Senior Attorney                                     Suite 1
ALASKA AIRLINES, INC.                               Fairbanks, Alaska 99709
19300 Pacific Highway South
Seattle, Washington 98188

The Honorable Tony Knowles (by Mail)                Lorelei Peter (by Mail)
Governor                                            Federal Aviation Administration
State of Alaska                                     AGC-230
P.O. Box 11001                                      800 Independence Avenue, SW
Juneau, Alaska 99811-0001                           Washington, DC 20004-1109

Christopher Brown (by Mail)                         Lydia Kennard (by Mail)
Airport Manager                                     Executive Director
Ronald Reagan Washington National Airport           Los Angeles World Airports
Washington, DC 20001                                One World Way
                                                    P.O. Box 92216
                                                    Los Angeles, CA 90009

Allen A. Heese (by Mail)                            Joanne W. Young
Airport Manager                                     David Kirstein
Juneau International Airport                          (for America West)
1873 Shell Simmons Drive                            jyoung@bakerlaw.com
Suite 200                                           dkirstein@bakerlaw.com
Juneau, Alaska 99801




                                              8
Carl B. Nelson, Jr.                                Edward P. Faberman
Associate General Counsel                          Michelle M. Faust
American Airlines, Inc.                            Ungaretti & Harris
Carl_Nelson@amrcorp.com                            (for Frontier, Colgan)
                                                   epfaberman@uhlaw.com
                                                   mmfaust@uhlaw.com

Robert E. Cohn                                     Megan Rae Rosia
Alexander Van der Bellen                           Managing Director, Government
(for Delta, Delta Express and Delta Shuttle)       Affairs and Associate Gen. Counsel
Robert_Cohn@shawpittman.com                        Northwest Airlines, Inc.
Sascha_Vanderbellen@shawpittman.com                Megan.Rosia@nwa.com

R. Bruce Keiner                                    Morton V. Plumb, Jr.
Lorraine B. Halloway                               Airport Director
 (for Continental and Continental Express)         Ted Stevens Anchorage International
rbkeiner@cromor.com                                Airport
lhalloway@cromor.com                               Mort_Plumb@dot.state.ak.us

Jeffrey A. Manley                                  Donald T. Bliss
Cathleen P. Peterson                               O’Melveny & Meyers LLP
(for United and United Express)                    (for US Airways, USAirways Express
jmanley@wilmer.com                                 and USAirways Shuttle)
cpeterson@wilmer.com                               dbliss@omm.com

Hon. Arnold Schwarzenegger                         Hon. Ted Kulongoski
Governor                                           Governor
State of California                                State of Oregon
State Capitol Building                             State Capitol Building
Sacramento, California 95814                       900 Court Street NE
                                                   Salem, Oregon 97301-4047

James E. Bennett                                   Hon. Frank H. Murkowski
President & CEO                                    Governor
Metropolitan Washington Airports                   State of Alaska
Authority                                          P.O. Box 11001
1 Aviation Circle, Suite 300                       Juneau, Alaska 99811-0001
Washington, D.C. 20001

Kim Day                                            Hon. Gary Locke
Interim Executive Director                         Governor
Los Angeles World Airports                         State of Washington
One World Way                                      Office of the Governor
P.O. Box 92216                                     P.O. Box 40002
Los Angeles, California 90009                      Olympia, Washington 98504-0002


                                               9
Gina Marie Lindsay
Managing Director of Aviation
Port of Seattle
P.O. Box 1209
Seattle, Washington 98111




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