Answer of Southwest Airlines Co (Cuba)

BEFORE THE
U.S. DEPARTMENT OF TRANSPORTATION

OFFICE OF THE SECRETARY
WASHINGTON, D.C.
_____________________________________
)
2016 U.S.-CUBA FREQUENCY
)
ALLOCATION PROCEEDING
)
_____________________________________ )
Docket DOT-OST-2016-0021
CONSOLIDATED ANSWER OF SOUTHWEST AIRLINES CO.
Communications with respect to this

document should be sent to:
Mark Shaw
Senior Vice President General
Counsel and Corporate Secretary
SOUTHWEST AIRLINES CO.
2702 Love Field Drive
Dallas, TX 75235-1611
Andrew Watterson
Senior Vice President
Network and Revenue
2702 Love Field Drive
Dallas, TX 75235-1611
March 14, 2016
Robert W. Kneisley
Associate General Counsel
Leslie C. Abbott
Senior Attorney
919 18th Street, N.W., Suite 600
Washington, D.C. 20006
bob.kneisley@wnco.com
leslie.abbott@wnco.com
(202) 263-6284
TABLE OF CONTENTS
I.
Southwests Proposal is Justified by Empirical Analysis as well as its

Successful History of Low Fare Service and New Market Development.
II.
The Majority of Havana Frequencies Should be Allocated to South Florida

Airports, the Most Convenient Gateways for the Cuban American Population
as well as Connecting Points for the Rest of the Country.
III.
As Between Fort Lauderdale and Miami, FLL Will Be the Airport Preferred
by Most Cuban American Travelers from South Florida.
IV.
American Airlines Service Proposal Fails to Maximize Consumer Benefits

and Warrants Only a Fraction of its Excessive MIA Frequency Request.
V.
JetBlue is a Higher Fare, Higher Cost and Smaller Carrier With Less Market
Impact than Southwest Airlines.
VI.
Spirits High Fee Service Proposal and Unreliable Market History Do Not Warrant
an Award in this Case.
VII.
Deltas Proposal Lacks Analytical Support and Would Do Nothing to Enhance the
Competitive Market Structure or Offer Low Fares.
VIII. There is No Justification for Uniteds Saturday-only Requests that Would Disrupt
Critical Daily Service Patterns From Viable Gateways.
IX.
Frontiers Service Proposal Is Unsupported by the Evidence and Undermined by

Its Long History of Market Failures.
X.
Alaskas LAX-HAV Proposal Would Serve a Significantly Smaller Market than FLLHAV and Deserves At Most One Frequency.
XI.
Sun Countrys Less-than-daily Service is Not Viable and Would Divert Valuable
Frequencies from Important Daily Service Proposals.
XII.
Silver Airways Proposes Service With Very Small Aircraft (34 Seats) and its
Application Should Be Denied on that Basis Alone.
XIII. Dynamic International Airways And Eastern Airlines Are Unfit to Hold Scheduled
U.S. Cuba Authority and thus Ineligible in this Proceeding.
BEFORE THE
U.S. DEPARTMENT OF TRANSPORTATION
OFFICE OF THE SECRETARY
WASHINGTON, D.C.
_____________________________________
)
2016 U.S.-CUBA FREQUENCY
)
ALLOCATION PROCEEDING
)
_____________________________________ )
CONSOLIDATED ANSWER OF SOUTHWEST AIRLINES CO.

Pursuant to Order 2016-2-12 (DOT Order) establishing this proceeding,
Southwest files this Consolidated Answer to the Applications submitted by the 12 other
participating carriers for the 20 daily round trips available between U.S. point(s) and
Havana (HAV). 1 As is detailed below, a review of the competing Applications shows
conclusively that Southwests proposal will generate by far the greatest public benefits
in this case. When considered side-by-side for substance, it is clear that Southwest has
provided not only a realistic proposal that will maximize public benefits but the one that
is best justified by empirical analysis and forecasts, as well as by Southwests
successful 45 year history of low fare service and new market development.
I.
Southwests Proposal is Justified by Empirical Analysis as well as its

Successful History of Low Fare Service and New Market Development.
Southwest is requesting nine of the 20 available daily HAV frequencies to provide
six nonstop flights per day between Fort Lauderdale International Airport (FLL) and
None of the nine non-Havana markets are oversubscribed. Southwests rebuttal analysis therefore
focuses entirely on the route proposals for Havana service. For purposes of this discussion Southwest
assumes that the Department will award all non-Havana frequency requests, except to those carriers that
do not hold the required scheduled operating authority.
HAV, two daily flights between Tampa International Airport (TPA) and HAV and one
daily flight between Orlando International Airport (MCO) and HAV. In Order 2016-2-12,
the Department clearly articulates the decisional criteria that will guide its allocation of
the scarce HAV frequencies: (1) maximizing public benefits, (2) offering and
maintaining the best service for the traveling and shipping public, and (3) the effects
of the service on the overall competitive environment, including effects on market
structure and competition in the U.S.-Cuba market, and any other market(s) shown to
be relevant.2 As explained in detail below and in the attached exhibits, Southwests
proposed daily, low fare service from the three Florida airports that serve the vast
majority of the Cuban American population best satisfies these criteria.
Southwest is the only applicant that has supported its proposals with detailed
forecasts of its own traffic. As shown herein, Southwest will almost certainly have the
lowest South Florida Havana fares of any applicant in this case. For its six daily FLL
HAV round trips Southwest will fly its 175-seat B737-800 aircraft, among the largest
planes proposed by any applicant. The Department can be assured that, more than any
other airline in this case, Southwest will successfully develop the new Havana markets,
operate at high load factors, and bring the greatest air travel value to the U.S.
consumer. In addition to its proven commitment to offering low fares and exceptional
consumer value, Southwest has the terminal facilities and the aircraft necessary to
support its service with maximum efficiency and outstanding product features.
DOT Order 2016-2-12 at 2.
II.
The Majority of Havana Frequencies Should be Allocated to South Florida

Airports, the Most Convenient Gateways for the Cuban American
Population as well as Efficient Connecting Points for the Rest of the
Country.
It is clear from Southwests direct exhibits, and those of other applicants, that a
large majority of Cuban Americans in the United States reside in Florida, and
particularly South Florida. Sixty-eight percent (68%) of Cuban Americans live in Florida
(Exhibit WN-200) and 80% of Floridas total live in the Ft. Lauderdale Miami area
(Exhibit WN-201). The Cuban American population in Ft. Lauderdale Miami totals
1,061,180 (Exhibit WN-202) and represents 54% of all Cuban Americans in the U.S.
The rest of the Cuban American population (outside Florida) is widely dispersed. 3
Recognizing the prohibition on U.S. resident tourist travel to Cuba, the vast majority of
the proposed service to Cuba, especially to Havana, will be aligned with the
concentrations of Cuban American residents. The chart below and Exhibit WN-R-101
show that South Florida dwarfs other cities in terms of resident Cuban American
population.
Exhibit WN-202.
Residents of Cuban-American Origin

1,200,000
1,061,180
1,000,000
800,000
+678%
600,000
400,000
200,000
156,514
120,826
63,288
56,821
22,115
15,382
13,413
7,305
4,439
Metro Area
As shown above, the South Florida Cuban American population is nearly seven
times larger than New YorkNewark, which has the second largest Cuban American
population. Accordingly, a majority of the 20 available Havana frequencies should be
dedicated to South Florida service.
Because there are obviously insufficient HAV frequencies available to satisfy all
requests in this proceeding it is important to examine the extent to which each proposed
gateway to Havana serves the most relevant U.S. traveler population, i.e. Cuban
Americans. 4 The chart below shows that 94% of all Cuban American residents in the
United States can travel to Havana via FLL with a trip circuity of less than 35%. 5
To do this, Southwest tracked travel distance for each resident going to Havana via each proposed
gateway, versus a theoretical nonstop routing from their home. Then, all trip routings with origin to
destination circuity in excess of 35% circuity were eliminated from further consideration. Finally, the
percent of Cuban American residents that could be served by each alternative gateway proposed in the
case was determined and compared to all other gateways. See, Exhibit WN-R-106.
5
35% circuity is an accepted analytical limit for forecasting traffic. Circuity in excess of 35%
introduces significant additional travel time that is inconvenient for affected passengers.
% of U.S. Residents of Cuban-American Origin within

35% Circuity of Subject Gateway
100%
97%
94%
90%
80%
70%
60%
50%
43%
41%
40%
29%
30%
26%
20%
13%
12%
11%
10%
9%
8%
7%
BOS
DEN
LAX
0%
MIA
FLL
TPA
MCO
ATL
CLT
EWR
JFK
DFW
Gateway
In addition, 43% and 41% respectively (previous chart and Exhibit WN-R-106) of
Cuban American population served by TPA and MCO can travel to HAV with less than a
35% trip circuity. All other proposed gateways outside Florida are far more circuitous
and therefore less convenient to large numbers of potential travelers. The percentage
of Cuban Americans that could travel from their place of residence to Havana from each
non-Florida gateway with less than 35% circuity is as follows: 6
ATL
CLT
EWR
JFK
DFW
BOS
DEN
LAX
29%
26%
13%
12%
11%
9%
8%
7%
FLL
94%
See Exhibits WN-R-102 through R-106.
It is also significant that 90% of the U.S. charter flights to Havana during the 12
months ended August 31, 2015 were operated to and from FLL/MIA. (Exhibit WN-R107). While some charter passengers travel to South Florida from elsewhere and make
a connection to their charter flight, the Cuban tour operators are heavily concentrated in
the South Florida market because that is where the majority of the travelers originate.
III.
As Between Ft. Lauderdale and Miami, FLL Will Be the Airport Preferred by
Most Cuban American Travelers from South Florida.
The extensive Cuban American population in South Florida has convenient
access to two airports that are only 29 miles apart: Ft. Lauderdale (FLL) and (MIA).
Given the density of the population in the areas surrounding these two nearby airports,
Ft. Lauderdale/Miami has long been considered a single airline market served by two
airports. Accordingly, an important consideration in this proceeding is the appropriate
allocation of frequencies between FLL and MIA. Distance (travel time) is obviously an
important factor, but both airports are convenient to the Cuban American population in
South Florida. FLL is within an hour of 80% of that population and within 45 minutes of
61% of that population (Exhibits WN-R-212 and R-213). MIA is also convenient and is
closer for the largest segment of the Cuban American population.
However, distance is only one consideration in the mind of passengers when
choosing between airports. Fares and other costs incurred by passengers at each
airport are of equal or greater importance. As shown herein, FLL offers consumers
significantly lower fares than MIA, which attracts passengers who will drive further to
save a considerable amount of money. Southwest has proven this to be true in many
cities and regions. For example, Southwests service at Little Rock AR historically drew
many passengers from 140 miles away in Memphis TN, which until recently had no low
cost carrier service itself. Southwests entry at BWI beginning in 1993 penetrated the
Northern Virginia market located much closer to DCA and IAD. Similarly, Southwests
entry into Providence and Manchester instead of Bostons Logan airport succeeded in
attracting large numbers of Boston passengers. In the present situation, the low fares
offered by Southwest and other low cost carriers at FLL attract hundreds of thousands
of local passengers away from the higher fares and greater congestion at MIA.
For that reason, FLL is the center of low fare air service in South Florida while
MIA is not (Exhibits WN-R-201-203). The chart below shows the distribution of low fare
service within each airport.
Sixty-three percent (63%) of FLLs seat-departures are
operated by low cost carriers 7 while only 3% of MIAs seat capacity is provided by such
carriers.
Miami
Fort Lauderdale
Low Cost
Carriers
= 3%
Other Airlines
= 37%
Low Cost
Carriers
= 63%
Other Airlines
= 97%
Low Fare Carrier Seat Capacity Share for FLL and MIA
In absolute terms, FLL has 23 times as many domestic low fare carrier seatdepartures as MIA (Exhibit WN-R-202); and when service to the Caribbean markets is
7
The low cost carriers include Southwest, JetBlue, Spirit, Allegiant, and Frontier.
examined, one finds that FLL enjoys over 24,000 low fare carrier weekly seatdepartures while MIA has zero (Exhibit WN-R-203).
One of the reasons why FLL has attracted the low fare carriers, especially
Southwest, Spirit and JetBlue, is because the airlines cost of operation at the two
airports differs dramatically $5.84 per enplaned passenger at FLL versus $20.54 at
MIA (Exhibit WN-R-204). 8 This differential by itself allows airlines at FLL to charge $15
less per one-way passenger than their counterparts at MIA. Congestion costs at MIA
also impact airline economics more than at FLL and this adds more dollars to the fare
differential. Therefore, as shown in the chart below and Exhibit WN-R-205, it should not
be surprising that FLL has 50% more domestic O&D passengers in markets served
nonstop at both airports 13.5 million at FLL and 9.0 million at MIA. 9
Annual
O&D Passengers
FLL Has 50% More Domestic O&D in Markets With

Both FLL and MIA Nonstop Service
16,000,000
14,000,000
13,465,475
12,000,000
50%
4,494,038
10,000,000
8,971,437
8,000,000
6,000,000
4,000,000
2,000,000
0
Fort Lauderdale
8
9
Miami
Terminal plus airfield charges.

For the 12 months ended September 30, 2015. See Exhibit WN-R-205.
Southwest has analyzed what the fare differential is likely to be between

Southwests proposed FLLHAV service and Americans proposed MIAHAV service.
This analysis is presented in Exhibits WN-R-206 through WN-R-211.
In domestic
nonstop markets, Southwests average fares at FLL are significantly lower than
Americans fares at MIA. As the chart below shows, at the FLL HAV distance of 255
miles, Southwests average fare is $49.44 lower than Americans (Exhibit WN-R-206). 10
Americans Average MIA Fares are Significantly Higher than Southwests

Average FLL Fares In Domestic Nonstop Markets
Avg. One-Way Fare Including Avg.
Baggage/Cancellation Fees Paid,
YE Q3, 2015
$300
At FLL-HAV Distance of 255 Miles the One-Way

MIA AA Fare is $49 Higher on Average
AA MIA Fare Curve
$250
$200
WN FLL Fare Curve

= $49
$150
$100
$50
$0
0
250
500
750
1000
1250
1500
1750
2000
2250
Distance (Miles)
When all carriers are included in this analysis, and not just Southwest and
American, the average one-way fare differential in favor of FLL is $48.03 (Exhibit WN-R207).
10
All fares include baggage, cancellation and usage fees in the case of ULCCs.
10
Southwest also analyzed fares in the FLL/MIASJU 11 markets to determine likely

fare differentials in Havana service. Both airports enjoy nonstop service to San Juan, a
predominantly Visiting Friends and Relatives (VFR) and leisure market. For the most
recent 12 months the average FLL one-way fare was 25%, or $50, lower than the MIA
fare (Exhibit WN-R-208), and the FLLSJU O&D passenger volume was 103% larger
than the MIASJU market (Exhibit WN-R-209).
Baggage/Cancellation and Passenger
Usage Fees Paid, YE Q3, 2015
Average FLL-SJU Fares Are 25%

Lower than MIA-SJU Fares
$250
$198
$200
-25%
-$50
$148
$150
$100
$50
$0
Fort Lauderdale
Miami
(All U.S. Airlines)
(All U.S. Airlines)
Finally, Southwest analyzed the average one-way SJU fares paid by passengers
of Southwest, Spirit and JetBlue at FLL, and American at MIA.
Average
baggage/cancellation and passenger usage fees (Spirit) actually incurred by

passengers, as reported to DOT by each carrier, must be combined with the base fare
in order to arrive at the price actually paid by the consumer for air travel. The chart
below and Exhibit WN-R-210 show clearly that Southwest provides the lowest price in
the market by a large margin.
11
San Juan, Puerto Rico.
11
Average
One-Way
Price Paid
FLL - SJU
Southwest
Spirit
JetBlue
$124
137
156
MIA - SJU
American
$198
Source: Exhibit WN-R-210.

Based on this analysis it is reasonable to conclude that Southwest will have the
lowest South FloridaHavana average fare paid: approximately $45 lower than
American, $21 lower than JetBlue and $9 lower than Spirit (Exhibit WN-R-211).
$140
Southwest Savings vs.

American = $45
$120
$126.43
$102.24
$100
$90.01
$81.19
$80
$60
$40
$20
$0
SOUTHWEST
% Higher than Southwest:
--
SPIRIT
JETBLUE
11.0%
25.9%
AMERICAN
55.7%
Estimated MIA-HAV
Estimated FLL-HAV
It is important to note that this fare difference does not reflect fully the differential
in checked baggage and other costs actually incurred by many U.S. passengers
traveling from South Florida to Havana. Baggage costs are particularly relevant in this
proceeding due to the high percentage VFR passengers. These individuals will be
12
more likely than average U.S. travelers to check multiple bags to carry items from the
U.S. to Cuba for family members and friends. Therefore Southwests Bags Fly Free
policy for the first two checked bags for all passengers is a particularly important
consumer benefit in this proceeding. Likewise, Southwests No Change Fee policy will
provide important benefits compared to the other applicants, who charge as much as
$200 for a ticket change and rebooking, apart from any fare difference. The table below
summarizes the wide differential in these fees:
As the Department knows, airport choice is much more complicated than a

simple drive-time comparison. Comparisons of schedules (frequency and time of day),
airport facilitation time, parking cost, expected delay and risk allowance factors, and
comparative fares all play a part in passenger choice behavior. As shown on Exhibit
WN-R-214, Southwest has combined drive time and fare differential into a single
13
composite metric. 12 Southwests analysis shows that most Cuban Americans and other
residents in South Florida will prefer FLL over MIA for their travel to HAV when
comparative drive times, fares, and other passenger costs such as parking are all taken
together. The rationale is that, for most South Florida passengers, the savings in lower
fares and other passenger costs at FLL greatly exceed the time value of driving to FLL
instead of MIA. This conclusion in turn supports allocating most of the frequencies
awarded for South Florida service to FLL rather than MIA.
IV.
American Airlines Service Proposal Fails to Maximize Consumer Benefits

and Warrants Only a Fraction of its Excessive MIA Frequency Request.
American has requested 10 MIAHAV, one CLTHAV and one DFWHAV for
daily service, plus once-a-week from each of LAX and ORD to/from HAV. Southwest
focuses first on Americans MIA request and then the CLT and DFW proposals. 13
Americans purported justification for 10 daily MIA HAV frequencies is woefully
lacking in both evidentiary support and credibility. First of all, American, like the other
legacy carriers, has remained completely silent on the issue of fares.
This is not
surprising given that Americans MIA-HAV fares will undoubtedly be significantly higher
than Southwests FLL-HAV fares. Indeed, the analysis in Exhibits WN-R-206 and R211 demonstrates that Americans average one-way MIA HAV fare will be $45 to $50
higher than Southwests average one-way FLL HAV fare (Exhibit WN-R-301).
12
A detailed explanation of the methodology for this analysis is given in Exhibit R-200.
Americans request for a Saturday only service between ORD and HAV, and for Sunday only between
LAX and HAV could be funded with the unused portion of the FedEx request, which Southwest does not
oppose.
13
14

Baggage/Cancellation Fees Paid, YE Q3, 2015
$180
$166.85
$160
+$49
$140
126.43
$117.42
$120
+$45
$100
$81.19
$80
$60
Southwest
At FLL
American
at MIA
Southwest
At FLL
American
at MIA
$40
$20
$0
Average Domestic FLL/MIA Fare at HAV Distance
Estimated FLL/MIA-HAV Average Fare
As the chart below shows, this differential is consistent with the finding that
Americans average domestic fare is 42% higher than Southwests average fare (Exhibit
WN-R-302).
Avg. One-Way Domestic Fare Including Avg.
Baggage/Cancellation Fees Paid at WN Length of Haul
$250
$230.82
$225
+42%
$200
$175
$162.01
$150
$125
$100
$75
$50
$25
$0
Southwest
American
15
This fare differential is not surprising given that Americans average domestic
unit cost is 24% higher than Southwests unit cost (Exhibit WN-R-303). To demonstrate
the enormous impact Southwest has in disciplining Americans pricing, Exhibit WN-R304 and the chart below shows that Americans fares are 19% lower in markets with
Southwest competition compared to markets where American has no LCC competition.
e-Way Domestic Fare Including Avg.
/Cancellation Fees Paid, YE Q3, 2015
$340
American Fares Without

Southwest or Other LCC
Competition
$320
$300
$280
$260
$240
American Fares with

Competition from Southwest
and no other LCC
$220
$200
$180
$160
$140
$120
$100
$80
200
500
1000
1500
2000
$60
$40
$20
AA without WN
Competition
$185
$229
$269
$295
$316
th WN
Competition
$151
$186
$218
$239
$255
Fare Change with

WN Competition
-18.7%
-18.9%
-19.0%
-19.1%
-19.1%
$0
0
100
200
300
400
500
600
700
800
900 1000 1100 1200 1300 1400 1500 1600 1700 1800 1900 2000
Trip Length (One-Way Nonstop Miles)
This percentage fare differential is virtually constant across all trip distances.
The Department can be assured that Southwest will employ its time-tested low fare
pricing strategies to will provide by far the most effective low fare competition against
Americans MIA-HAV service.
Furthermore, American has not provided a passenger traffic forecast to support
its requested 10 daily MIAHAV round trips. Rather, Americans case rests on two
evidentiary premises: (1) the fact that more Cuban Americans live closer to MIA than
FLL, and that the South Florida Cuban American population is very large compared to
16
other U.S. metro areas; and (2) Americans projection of potential 2017 MIAHAV
charter flights (absent scheduled service), for the entire industry. 14
Americans justification for 10 MIAHAV frequencies based its charter service is
fundamentally flawed. According to DOTs T-100 data, American has averaged just 1.1
MIA-HAV charters per day for the 12 months ended August 31, 2015. The carrier
provides no insight into how and why it will increase from 1.1 charters to 10 daily
scheduled flights when its only apparent evidence is its projection that the whole
industry would operate 9.5 or 10 charters per day absent scheduled services.
A review of Americans Application leaves the reader with the distinct impression
that regardless of how many HAV frequencies it may be awarded by the Department,
American will simply assign scheduled flight numbers to what would otherwise be
charters. See for example, Americans Application at page 20 where the carrier refers
to . . . the smooth transition from charter flights to scheduled flights. This plan is
supported further by the testimony of Arthur Torno where he states at page 2 of AA
Testimony T-4 American will rely on its relationships with these CSPs to quickly make
the transition to providing extensive scheduled service between the U.S. and Cuba
(emphasis added).
Simply converting charter flights to schedule flights will not add seat capacity to
the U.S. Havana market but it will consume highly valuable scheduled frequencies
available in this proceeding. Consumers in this market will benefit to the greatest extent
possible only if scheduled services are additional to charter capacity. All of Southwests
14
Exhibit AA-710. Americans projection of 9.5-10 daily MIA-HAV charters is overstated due to an
inaccurate calculation and rounding error. When these are corrected, Americans projection would be 8.9
daily flights.
17
proposed service, by contrast, will be a net gain to the market as Southwest has not
been a charter participant in Cuba.
American can continue to operate as many charter flights to Havana as it wishes,
of course, and since American is in the process of reducing its U.S.-Caribbean service
significantly, 15 charter service may be the best course for American to follow in the
future.
In any event, Americans historical (and current) level of MIAHAV charter
activity does not support anything like 10 scheduled frequencies per day. Nor should
American be awarded any scarce frequencies to accommodate Sixth Freedom traffic
through its Miami hub. Americans proposal includes eight international connections at
MIA that would block seats to HAV and provide no benefit for American consumers
(Exhibit WN-R-305). An reasonable estimate of this traffic suggests that approximately
10% of Americans proposed MIAHAV capacity would be consumed by Sixth Freedom
passengers.
For all the reasons stated above, and in Section III, there is no evidentiary
justification for allocating anywhere near 10 MIAHAV frequencies to America. Given
its modest participation currently in the South FloridaHavana charter market, American
should not be awarded more than a fraction of the MIAHAV frequencies it requests.
In addition, Americans request for once daily service in the DFWHAV and CLT
HAV markets should be denied for several reasons. First, American has provided no
empirical justification to demonstrate public need or likely success in these markets.
Second, as shown below, Cuban American populations in both these cities is miniscule
compared to Ft. Lauderdale/Miami. The Dallas Cuban American population of 13,413 is
15
See Exhibit WN-R-409. From March 2010 to March 2016 Americans U.S.-Caribbean departures, seatdepartures, and number of routes served declined by 28%, 19% and 25% respectively.
18
only 1.2% of that in Ft. Lauderdale/Miami, and Charlottes Cuban American population
of 7,305 is a mere 0.7% of Ft Lauderdale/Miamis (Exhibit WN-R-306).
Dallas and Charlotte Have Very Small Cuban American
Populations Compared to Ft. Lauderdale-Miami
U.S. Residents of Cuban-American Origin
1,200,000
1,061,180
1,000,000
800,000
600,000
400,000
200,000
13,413
7,305
Dallas
Charlotte
0
Ft Lauderdale-Miami
Metro Area
Third, as potential connecting hubs, both DFW and CLT are inconvenient for all but a
small fraction of Cuban Americans residing throughout the U.S., while FLL is
convenient 16 to 94% of that population (Exhibit WN-R-307). Fourth, Americans own
theory of traffic support undermines completely any justification for allocating scarce
HAV frequencies to DFW and/or CLT. Americans MIA justification is based on two
simplistic factors where do Cuban Americans live and what is the distribution of
Havana charters by U.S. gateway. In its Application at page 17 American summarizes
industry charters to Cuba by U.S. gateway. Both DFW and CLT are subsumed within
the all other gateway category showing less than 1% of all charters in 2015. So there
16
Within 35% mileage circuity.
19
is nothing in the charter O&D record that supports Americans requests for DFW or CLT,
and the geographical distribution of the Cuban American population 17 does not lend any
support either.
V.
JetBlue is a Higher Fare, Higher Cost and Smaller Carrier With Less Market
Impact than Southwest Airlines.
JetBlue requests 10 Havana frequencies but offers little positive evidence to
support its Application. In fact, JetBlue has provided no traffic forecasts of any sort,
which would be necessary to lay a foundation for maximizing public benefits with even a
single HAV frequency. The essence of JetBlues case is its claim that it is a low fare
carrier and will offer low fares to/from Havana. In support it provides data for a few
carefully selected short-haul Boston markets 18 where pre-existing fares were high and
no other LCC or ULCC carriers were competing. The truth is that when JetBlues impact
on market fares is compared to the Southwest Effect on market fares, the difference
overwhelmingly favors Southwest Southwest reduces fares an average of $41.46 per
one-way flight versus $28.91 for the JetBlue Effect. This is a 43% difference in favor
of Southwest (exhibit WN-R-401). 19
17
See Exhibit WN-R-306 and R-307.

BOS DCA, BOS EWR and BOS DTW.
19
These results and more detail on the derivation of these numbers are shown in Appendix 12 of
Southwests direct exhibits.
18
20
Southwest Competition Reduces Fares an Average

of 43% More than Competition from JetBlue
Fare Impact of Low Cost
Carrier Competition
Southwest
JetBlue
$0.00
-$5.00
-$10.00
-$15.00
-$20.00
-$25.00
-$30.00
-$28.91
43%
-$35.00
-$40.00
-$41.46
-$45.00
-$50.00
Focusing on the FLL markets in particular, Exhibit WN-R-402 and the chart below
show that for the most recent year of DOT data (YE Q3 2015), Southwests average
fare in domestic markets where both airlines compete nonstop is lower than JetBlues in
six of the seven markets.
21
Avg. One-Way Fare Including Avg. Baggage and

Cancellation/Rebooking Fees Paid Fared Passengers Only
Southwest
JetBlue
$250
$197
$186
$200
$167
$160
$150
$156
$154
$147
$140
$139
$131
$127
$132
$124
$108
$100
$50
$0
AUS
BDL
PIT
LAS
PVD
RDU
SJU
In the FLL SJU market, a predominantly leisure market with considerable

Hispanic travel, JetBlues average fare ($156) is 25.8% higher than Southwests
($124). 20
Average Southwest and JetBlue Fares in SJU Markets

Southwest
JetBlue
$200
$180
$172
$156
$160
$155
$143
$134
$140
$124
$120
$100
$80
$60
$40
$20
$0
FLL
20
MCO
Exhibit WN-R-403.
22
TPA
As shown above, in the two other relevant Florida San Juan markets where the
two carriers compete, JetBlues average fare is higher than Southwests: $172 versus
$143, or 20.3% higher in the case of MCO SJU, and $155 versus $134 or 15.7%
higher in the case of TPA SJU (Exhibit WN-R-403).
It is not surprising that Southwests fares are lower than JetBlues fares because
Southwests unit costs are significantly lower as well. For the year ended September
30, 2015 Southwests cost per ASM was 20% lower than JetBlues costs (Exhibit WN-R404). This cost differential has existed for many years (12% to 20% between 2010 and
2015) and it has been increasing since 2012 (Exhibit WN-R-405).
JetBlue has requested a total of eight Florida-Havana frequencies (4 FLL + 2
TPA + 2 MCO) while Southwest has asked for nine (6 FLL + 2 TPA + 1 MCO).
However, as the chart below highlights, Southwest is significantly larger with broader
U.S. network services than JetBlue at the competing Florida gateways (Exhibit WN-R406 and R-407). As a result, Southwest will be able to serve numerous cities in the
Midwest and Heartland that are not served by JetBlue. Under JetBlues proposal, these
communities will have far fewer convenient one-stop low-fare service options than the
Northeast cities where JetBlues service is concentrated.
23
Southwests Has More Convenient Connections at FLL than JetBlue
SYR
SYR
SYR
SYR
SYR
SYR ORH
ORH
ORH
ORH
ORH
DTW
DTW
DTW
DTW
DTW
DTW
BDL
BDL
BDL
BDL BOS
SWF
SWF
CLE
CLE
SWF
BOS
CLE
SWF
SWF BDL
BOS
CLE
CLE
BOS
HPN
HPN
LGA
LGA
HPN
HPNBOS
LGA
LGA
LGAHPN
PIT
PIT
PIT
PIT
PIT EWR
EWR
EWR
EWR
EWR
EWR
PHL
PHL
PHL
PHL
PHL
JFK
JFK
JFK
DCA
DCA
DCA
DCA
DCA BWI
BWI
BWI
RIC
RIC
BWI
BWI
RIC
RIC
RIC BWI
RDU
RDU
RDU
RDU
RDU
MKE
MKE
MKE
MKE
MKE
MDW
MDW
MDW
MDW
MDW
MCI
MCI
MCI
MCI
MCI
MCI
DEN
DEN
DEN
DEN
DEN
DEN
BUF
BUF
BUF
ALB
ALB
BUF
BUF
ALB
ALB
ALB
BDL
BDL
BDL
BDL
BDL
BDL
PVD
PVD
PVD
PVD
PVD
PIT
PIT
PIT
PIT
PIT
PHL
PHL
PHL
CMH
CMH
CMH
PHL
PHL
PHL ISP
ISP
CMH
CMH PIT
IND
IND
IND
ISP
ISP
ISP
IND
IND
IND CMH
BWI
BWI
BWI
BWI
BWI
BWI
DCA
DCA
DCA
DCA
DCA
DCA
STL
STL
STL
STL
STL
STL
BNA
BNA
BNA
BNA
BNA
BNA
LAS
LAS
LAS
LAS
LAS
LAS
PHX
PHX
PHX
PHX
PHX
PHX
SFO
SFO
SFO
SFO
SFO
SFO
RDU
RDU
RDU
RDU
RDU
RDU
LAS
LAS
LAS
LAS
LAS
LAS
ATL
ATL
ATL
ATL
ATL
ATL
DAL
DAL
DAL
DAL
DAL
DAL
LAX
LAX
LAX
LAX
LAX
LAX
CHS
CHS
CHS
CHS
CHS
CHS
MSY
MSY
MSY
MSY
MSY
MSY
AUS
AUS
AUS
AUS
AUS
AUS
HOU
HOU
HOU
HOU
HOU
HOU
JAX
JAX
JAX
JAX
JAX
JAX
AUS
AUS
AUS
AUS
AUS
AUS
TPA
TPA
TPA
TPA
TPA
TPA
FLL
FLL
FLL
FLL
HAV
HAV
HAV
HAV
SJU
SJU
SJU
SJU
SJU
SJU
SJU
SJU
SJU
SJU
SJU
SJU
In addition, as shown below, Southwest is five times larger than JetBlue at TPA
(Exhibit WN-R-408 and R-409).
Southwest Has Five Times More Service at TPA to U.S. Points than JetBlue
Average Daily Departures
Average Daily Seat-Departures

14,000
100
13,195
90
Nonstop Destinations
40
89.1
37
35
12,000
80
30
10,000
70
574%
514%
20
50
6,000
429%
25
60
8,000
40
15
30
4,000
10
1,958
20
2,000
10
WN
B6
14.5
WN
B6
WN
B6
Due to its significantly larger operation, Southwests TPA-HAV service would

connect with 33 domestic U.S. markets whereas JetBlues proposed service at TPA
would only connect with seven.
24
Southwests TPA Convenient Connections Compared to JetBlues
DEN
DEN
DEN
DEN
DEN
DEN
MCI
MCI
MCI
MCI
MCI
MCI
LAS
LAS
LAS
LAS
LAS
LAS
FNT
MKE
MKE
BUF
MHT
GRR
FNT
MKE
BUF
MHT
GRR
ALB
ALB
FNT BUF
MKEGRR
MKE
BUF
BUF
MHT
MHT
GRR
GRR FNT
ALB
ALB
ALBMHT
BDL
BDL
BDL
MDW
BDL
BDL
MDW
MDW
MDW
CAK
CAK
CAK
CAK
CAK
ISP
ISP
PVD
ISP
PVD
ISP
ISP PVD
PVD
PVD
PIT
PIT
PIT
PIT
PIT
CMH
PHL
PHL
CMH
PHL
CMH
CMH PIT
PHL
PHL
IND
IND
IND CMH
BWI
BWI
BWI
BWI
BWI
STL
STL
STL
STL
STL
STL
SDF
SDF
SDF
SDF
SDF
DCA
DCA
DCA
DCA
DCA
MEM
MEM
MEM
MEM
MEM
MEM
RDU
RDU
RDU
RDU
RDU
RDU
ATL
ATL
BHM
BHM
BHM
ATL
ATL
ATL
BHM
BHM
BHMATL
DAL
DAL
DAL
DAL
DAL
DAL
PHX
PHX
PHX
PHX
PHX
PHX
BNA
BNA
BNA
BNA
BNA
BNA
BOS
BOS
BOS
BOS
BDL
BDL
BDL
BDL
BDLBOS
HPN
HPN
LGA
LGA
HPN
HPN
LGA
LGA
LGAHPN
EWR
EWR
JFK
JFK
EWR
EWR
EWR JFK
JFK
JFK
JFK
DCA
DCA
DCA
DCA
DCA
AUS
AUS
AUS
AUS
AUS
HOU
HOU
SAT
SAT
HOU
HOU
HOU
SAT
SAT
SAT HOU
MSY
MSY
MSY
MSY
MSY
MSY
TPA
TPA
TPA
TPA
FLL
FLL
FLL
FLL
FLL
FLL
HAV
HAV
HAV
HAV
SJU
SJU
SJU
SJU
SJU
SJU
Finally, Southwest is more than twice the size of JetBlue at MCO (Exhibit WN-R410 and R-411). 21
Southwest is More than Twice as Large as JetBlue at MCO to U.S. Points

20,000
140
18,662
50
124.6
18,000
45
44
120
40
16,000
178%
100
14,000
12,000
159%
35
159%
30
80
25
10,000
60
8,000
48.1
6,708
6,000
20
17
15
40
10
4,000
20
2,000
WN
B6
WN
B6
WN
B6
Even though Southwest is only requesting one MCO-HAV frequency and JetBlue
is requesting two, Southwests daily service would still provide convenient connections
to 18 more U.S. cities than JetBlues two proposed flights (32 connections for
Southwest vs. 14 for JetBlue).
21
In all airport size comparisons (such as Exhibit WN-R-406), Southwest has used the 50 U.S. states.
This eliminates international routes that are not relevant to this proceeding.
25
Southwest Has Significantly More Convenient Connections at MCO than JetBlue
OMA
OMA
OMA
OMA
OMA
OMA
DEN
DEN
DEN
DEN
DEN
DEN
MCI
MCI
MCI
MCI
MCI
MCI
SYR
SYR
SYR
BUF
SYR
BUF
BUFSYR
BUF
FNT
ROC
ROC
MKE
MKE
MHT
MHT
BUF
GRR
GRR
FNT
ROC
MKE
BUF
FNT
FNT BUF
ALB
ALB
MKE
MKEGRR
MHT
MHT
MHT
BUF
BUF ROC
GRR
GRR
GRRFNT
ALB
ALB
ALB MHT
BDL
BDL
BDLPVD
MDW
MDW
PVD
MDW
PVD
BDL
BDL
BDL
MDW
MDW
PVD
CAK
CAK
CAK
CAK
CAK
ISP
ISP
ISP
ISP
ISP
PIT
PIT
PIT
PIT
CMH
CMH
CMH
PHL
PHL
PHL
IND
IND
PHL
PHL
PHL
IND
IND
IND
BWI
BWI
BWI
BWI
BWI
STL
STL
STL
STL
STL
SDF
SDF
SDF
SDF
SDF
DCA
DCA
DCA
DCA
DCA
MEM
MEM
MEM
MEM
MEM
MEM
ORH
ORH
ORH
ORH
ORH
BDL
BDL
BDL BOS
BDL
BOS
BOS
BOS
BOS
BOS
HPN
HPN
HPN
HPN
HPN PVD
PVD
PVD
LGA
LGA
LGA
LGA PVD
EWR
EWR
EWR
EWR
EWR
EWR
JFK
JFK
JFK
JFK
BWI
BWI
BWI
BWI JFK
DCA
DCA
DCA BWI
SLC
SLC
SLC
SLC
SLC
BNA
BNA
BNA
BNA
BNA
BNA
ATL
BHM
ATL
BHM
BHMATL
ATL
BHM
DAL
DAL
DAL
DAL
DAL
DAL
AUS
AUS
AUS
AUS
AUS
HOU
HOU
SAT
SAT
HOU
HOU
SAT
SAT
SAT HOU
MSY
MSY
MSY
MSY
MSY
AUS
AUS
AUS
AUS
AUS
MCO
MCO
MCO
MCO
HAV
HAV
HAV
HAV
SJU
SJU
BQN
SJU
BQN
BQN
SJU
SJU
BQN
PSE
PSE
PSE
PSE
PSE
SJU
SJU
SJU
SJU
SJU
SJU
When comparing the two applications side-by-side, a totality of factors including

Southwests greater market fare impact and broader connecting service options make
all of its Florida HAV service proposals a superior choice over JetBlues.
JetBlue also proposes two daily JFK HAV flights. New York/Newark is the
second largest Cuban American residential community; however, it is only 15% the size
of the Ft. Lauderdale Miami population (Exhibit WN-R-101). Accordingly, it would
justify at most a single JFK HAV frequency to JetBlue as the only LCC proposing New
York/Newark service. 22
Finally, JetBlue has made no effort to justify an award for BOSHAV services
and there is little to support it in any event. The airport is geographically off-side to most
of JetBlues domestic service at Boston (Exhibits WN-R-412 and WN-R-413) and the
Cuban American population is only 15,382 residents (Exhibit WN-R-101).
22
See also Exhibit WN-R-413 showing that FLL is a much more convenient gateway for Cuban
Americans than JFK, EWR or BOS and Exhibit WN-R-414 showing that JetBlues proposed JFK-HAV
route would only connect to 7 U.S. points without excessive circuity.
26
In conclusion, Southwests FloridaHavana proposals will provide greater public

benefits than JetBlues, and Southwest has justified all of its requests with empirical
forecasts, while JetBlue has not. Considering the two carrier applications side-by-side,
it is clear that Southwest will be a stronger low-fare competitor in the U.S. Cuba
market, and will offer consumers significantly larger and broader U.S. network services
than JetBlue at the competing Florida gateways.
VI.
Spirits High Fee Service Proposal and Unreliable Market History Do Not
Warrant an Award in this Case.
Spirit proposes two daily flights between FLL and HAV utilizing its A319 aircraft
with 145 seats. As shown below and in Exhibit WN-R-505, this means that Southwest
would carry at least 21% more HAV passengers per nonstop flight than Spirit. This is a
significant difference with so few HAV frequencies available to allocate to U.S. carriers.
Annual One-Way Seats/Passengers
140,000
127,750
+21,900
+21%
120,000
108,587
105,850
+18,614
+21%
100,000
89,973
80,000
60,000
40,000
20,000
0
Annual Seats Per Daily
Southwest 737-800
Frequency

Spirit A319 Frequency
Annual Southwest
Passengers Per Daily
Southwest 737-800
Frequency
Annual Spirit Passengers

Per Daily A319 Frequency
In its application, Spirit states that it will offer low fares, and it may indeed offer
low base fares, but when all the added fees and charges are included, the actual
27
average price paid by Spirits FLLSJU passengers today is 11% higher than the
comparable Southwest FLL--SJU price paid (Exhibit WN-R-502). 23
As shown below, consistent with this finding, Spirits FLL-HAV fare is projected
by Southwest to also be 11% higher than Southwests. 24
$140
$126.43
$120
$102.24
$100
$90.01
$81.19
$80
$60
$40
$20
$0
SOUTHWEST
--
SPIRIT
JETBLUE
11.0%
25.9%
Estimated FLL-HAV
AMERICAN
55.7%
Estimated MIA-HAV
While Spirit makes a lot of noise about offering cheap fares, its impact on the
competitive market structure pales in comparison to Southwest.
As shown below,
Southwests effect on reducing domestic fares is 58% greater than Spirits impact on
fares (Exhibit WN-R-501).
23
Additional fees paid by passengers on Spirit come directly from Spirits own Form 41 filing with DOT.
See also, Exhibit WN-R-210.
24
Southwest distinguishes itself from other carriers by offering consumers inclusive fares without hidden
fees as highlighted in the Companys Transfarency Campaign. Details of the camplain are available at:
http://www.transfarency.com/?src=SRCH_16_AD_c_138_22105988_p_transfarency&ct=UN
28

Carrier Competition
Southwest
Spirit
$0.00
-$5.00
-$10.00
-$15.00
-$20.00
-$25.00
-$26.13
-$30.00
58%
-$35.00
-$40.00
-$41.46
-$45.00
-$50.00
Similarly, it is reasonable to assume that Spirit will have a minimal impact on U.S.
Cuba fares compared to Southwest and will therefore have little effect on the overall
competitive environment, including effects on market structure and competition in the
U.S.-Cuba market as called for in the Departments Instituting Order. 25
Spirit is also much smaller than Southwest at FLL and would offer consumers far
less connectivity. According to the published March, 2016 schedules and shown in the
chart below depending upon the metric used, Southwest is 33% to 76% larger to U.S.
points than Spirit at FLL (Exhibit WN-R-503).
25
DOT Order at 2.
29
Southwests U.S. Service Compared to Spirit (NK) at FLL


10,000
70
9,318
30
28
62.3
9,000
60
25
45%
8,000
7,000
50
6,427
33%
21
76%
20
6,000
40
35.3
15
5,000
30
4,000
10
3,000
20
2,000
10
1,000
WN
WN
NK
NK
WN
NK
Spirits FLL HAV service would connect to only 20 U.S. domestic points compared to
27 points for Southwests service (Exhibit WN-R-504).
Southwests FLL Convenient Connections Compared to Spirits
MSP
MSP
MSP
MSP
MSP
MKE
MKE
MKE
MKE
MDW
MDW
MDW
MDW
MDW
MDW
MCI
MCI
MCI
MCI
MCI
MCI
DEN
DEN
DEN
DEN
DEN
STL
STL
STL
STL
BUF
BUF
BUF
BUF
PIT
PIT
PIT
PHL
PHL
PHL
CMH
CMH PIT
PHL
PHL
CMH
CMH
IND
IND
IND
IND
IND CMH
IND
BWI
BWI
BWI
BWI
BWI
BWI
DCA
DCA
DCA
DCA
DCA
DCA
BNA
BNA
BNA
BNA
BNA
LAS
LAS
LAS
LAS
LAS
PHX
PHX
PHX
PHX
PHX
PHX
ALB
ALB
ALB
ALB
ALB
ALB
BDL
BDL
BDL
BDL
BDL
PVD
PVD
PVD
PVD
PVD
PVD
ISP
ISP
ISP
ISP
ISP
ISP
IAG
IAG
IAG
IAG
DTW
DTW
DTW
DTW
DTW
CLE
CLE
CLE
BOS
BOS
BOS
BOS
BOS
LGA
LGA
LGA
LGA
LGA
LGA
ACY
ACY
ACY
ACY
BWI
BWIACY
BWI
BWI
BWI
DEN
DEN
DEN
DEN
LAS
LAS
LAS
LAS
LAS
LAS
RDU
RDU
RDU
RDU
RDU
LAX
LAX
LAX
LAX
LAX
LAX
ATL
ATL
ATL
ATL
ATL
DAL
DAL
DAL
DAL
DAL
DAL
PBG
PBG
PBG
PBG
PBG
PBG
ORD
ORD
ORD
ORD
PHX
PHX
PHX
PHX
PHX
DFW
DFW
DFW
DFW
DFW
ATL
ATL
ATL
ATL
MYR
MYR
MYR
MYR
MYR
MSY
MSY
MSY
MSY
MSY
MSY
AUS
AUS
AUS
AUS
AUS
HOU
HOU
HOU
HOU
HOU
HOU
TPA
TPA
TPA
TPA
TPA
TPA
TPA
TPA
TPA
TPA
TPA
TPA MCO
MCO
MCO
MCO
MCO
FLL
FLL
FLL
FLL
HAV
HAV
HAV
HAV
SJU
SJU
SJU
SJU
SJU
BQN
BQN
BQN
BQN
BQN
Spirit did attempt an industry traffic forecast using some of the same market
comparables as Southwest (Exhibit CU-6). But Southwests forecast (Exhibit WN-100)
is conservative by comparison.
In Order 2016-2-12, the Department states that it will consider which applicants
will be most likely to offer and maintain the best service for the traveling and shipping
30
public (emphasis added). 26 It is therefore of decisional significance that Spirit has a

history of abandoning international routes an astonishing 16 such abandonments in
the past 10 years, nine of which were Ft. Lauderdale routes (Exhibit WN-R-506).
27
With this record, there is ample reason to question Spirits commitment to the Cuba
market, which will likely take time to develop due to current U.S. Government limitations
on travel.
Finally, Spirit has among the worst passenger complaint levels of all scheduled
carriers tracked by the DOT.
26
27
In contrast, as the chart below shows, Southwests
Id.
Spirit also abandoned DCA in 2012 when it sold its slots to Southwest (Exhibit WN-R-507).
31
complaint level is among the lowest, and is about 5% of the level recorded against Spirit
(Exhibit WN-R-508).
Complaints per 100,000
Enplanements,
January - December 2015
25.0
Southwest
Spirit
20.0
19.2
15.4
15.0
12.7
12.6
11.6
11.7
10.8
10.3
11.0
10.0
8.0
8.5
7.3
5.0
0.6
0.5
0.5
0.4
0.4
0.7
0.7
0.6
0.5
0.5
0.3
0.5
0.0
January
February
March
April
May
June
July
August
September
October
November December
2015
Spirit clearly will not offer the best service for the traveling and shipping public
and its track record also suggests that it may not maintain its service either. 28
Therefore, in light of the significant demand for HAV frequencies, Spirit simply does not
merit an award in this case.
VII.
Deltas Proposal Lacks Analytical Support and Would Do Nothing to

Enhance the Competitive Market Structure or Offer Low Fares.
Delta requests an allocation of five daily frequencies to serve Havana (2 MIA, 1
JFK, 1 ATL and 1 MCO). It proposes to serve no other markets in Cuba. Deltas
proposal is extremely weak and unsupported in several major respects. Delta provides
no analytical support for its assumed load factors and local vs. connecting ratios (Exhibit
28
DOT Order at 2.
32
DL-601). Delta also makes no suggestion that it will offer low fares. Ironically, Deltas
proposal depends on Sixth Freedom traffic to support its JFK and ATL flights, despite its
boisterous campaign against the three major Middle East carriers for their participation
in U.S. O&D Sixth Freedom traffic. 29
It is not surprising that Delta has made no low fare proposal. As shown below, in
the domestic marketplace Deltas average fare level is 46% higher than Southwests
(Exhibit WN-R-601)
$250
$236.77
$225
+46%
$200
$175
$162.01
$150
$125
$100
$75
$50
$25
$0
Southwest
Delta
This substantial fare differential results, at least in part, from Deltas high unit
costs which are 48% more than Southwests (Exhibit WN-R-602). Deltas entry into the
MIA HAV market would provide no consumer fare benefit (Exhibit WN-R-603). In
addition to providing no fare benefits, Deltas MIA service would do nothing to discipline
Americans legacy carrier pricing as shown in the chart below. In contrast, American
29
See Deltas Application at page 3, and Exhibits DL-202 and DL-703 through DL-710.
33
reduces its fares significantly in response to competition from Southwest (see Section
IV above and Exhibit WN-R-304).
Deltas Entry in the MIA-HAV Market Would Do Nothing to Discipline Americans
Pricing and Would Have Little if Any Effect on Fares
Legacy Fares in Markets With

One Legacy Carrier Only
$380
$360
$340
$320
Legacy Fares With

Legacy Only Competition
$300
$280
$260
$240
Legacy Fares With

Southwest and No Other
LCC Competition
$220
$200
$180
$160
$140
Legacy Only,
Distance
1 Carrier
200
$188
500
$240
1000
$289
1500
$322
$347
2000
$120
$100
$80
$60
$40
$20
Legacy Only,
2 or 3 Carriers
$200
$245
$284
$311
$331
Legacy
with WN
Competition
$152
$192
$229
$249
$273
$0
0
100
200
300
400
500
600
700
800
900
1000 1100 1200 1300 1400 1500 1600 1700 1800 1900 2000
Finally, Delta has insignificant proposed connecting options at MIA, with just
seven connecting U.S. cities other than New York and Atlanta (Exhibit WN-R-605). As
shown below, Southwest is twice as large at FLL as Delta is at MIA (Exhibit WN-R-604)
and Southwests FLL proposal would connect to 27 U.S. points (Exhibit WN-R-606),
dwarfing Deltas seven (excluding New York and Atlanta). Based on a totality of factors,
Delta should not be awarded any frequencies to serve MIAHAV.
34
Southwest Provides Almost Three Times as Many

Convenient Connections at FLL Compared to Delta at MIA
Delta proposes equally insignificant connections in Orlando, with just eight U.S.
connecting cities other than New York and Atlanta while Southwests proposal would
connect to 32 U.S. points behind MCO (Exhibit WN-R-609).
Southwests low fare
proposal to serve MCO HAV is vastly superior both in terms of expected fare
difference and interior markets served. As shown below, Southwest is twice the size of
Delta at MCO (Exhibit WN-R-607) and Southwest will offer its traditional low fares while
Delta can be expected to operate with much higher fares.
Southwest Provides Almost Three Times As Many

Convenient Connections at MCO Compared to Delta
SEA
SEA
SEA
MSP
MSP
MSP
OMA
OMA
OMA
OMA
OMA
OMA
DEN
DEN
DEN
DEN
DEN
DEN
MCI
MCI
MCI
MCI
MCI
ROC
FNT
ROC
MKE
MKE
MHT
MHT
MHT
BUF
FNT
GRR
ROC
ROC
MKE
BUF
FNT
FNT BUF
GRR
ALB
ALB
MKE
MKEGRR
MHT
MHT
BUF
BUF ROC
GRR
GRRFNT
ALB
ALB
ALB MHT
BDL
BDL
MDW
PVD
PVD
BDL
MDW
MDW
BDL
BDLPVD
MDW
PVD
PVD
PVD
CAK
CAK
CAK
CAK
CAK
ISP
ISP
ISP
ISP
ISP
ISP
PIT
PIT
PIT
CMH
CMH
CMH
PHL
PHL
PHL
IND
IND
IND
PHL
PHL
IND
IND
IND
BWI
BWI
BWI
BWI
BWI
BWI
STL
STL
STL
STL
STL
SDF
SDF
SDF
SDF
SDF
DCA
DCA
DCA
DCA
DCA
DCA
MEM
MEM
MEM
DTW
DTW
DTW
SLC
SLC
SLC
LGA
LGA
LGA
IND
IND
IND
IND
IND
CVG
CVG
CVG
CVG
JFK
JFK
JFK
JFK
JFK
JFK
BNA
BNA
BNA
BNA
BNA
RDU
RDU
RDU
RDU
RDU
RDU
ATL
ATL
BHM
BHM
BHM
ATL
ATL
BHM
BHM
BHMATL
LAX
LAX
LAX
LAX
LAX
LAX
ATL
ATL
ATL
DAL
DAL
DAL
DAL
DAL
AUS
AUS
AUS
AUS
AUS
HOU
HOU
SAT
SAT
HOU
HOU
SAT
SAT
SAT HOU
MSY
MSY
MSY
MSY
MSY
MSY
MCO
MCO
MCO
MCO
HAV
HAV
HAV
HAV
CUN
CUN
CUN
CUN
GRU
GRU
GRU
SJU
SJU
SJU
SJU
SJU
SJU
35
Finally, Delta proposes once daily ATL-HAV and JFK-ATL. As the chart below
and Exhibit WN-R-610 show, the Ft. Lauderdale/Miami Cuban American population is
nearly 7 times as large as New York/Newark and 48 times as large as that of Atlanta.
The Cuban American Population in New York and Atlanta are Very Small
Compared to Ft. Lauderdale-Miami
1,200,000
1,061,180
1,000,000
800,000
600,000
400,000
200,000
156,514
22,115
Ft Lauderdale-Miami
New York-Newark
Atlanta
Metro Area
In addition, FLL nonstop service is convenient to many more Cuban Americans

than either JFK or ATL (Exhibit WN-R-611). Finally, Exhibit WN-R-612 shows that once
excessively circuitous and international routes are removed, Deltas JFK-HAV proposal
connects to just 8 U.S. points. Considering all the facts, the best use of scarce HAV
frequencies is to allocate them to South Florida rather than ATL or JFK.
36
VIII.
There is No Justification for Uniteds Saturday-only Requests That Would

Disrupt Critical Daily Service Patterns From Viable Gateways.
United requests one daily EWRHAV frequency plus 4 once-a-week frequencies
at Chicago, Houston, Washington and a second Saturday-only at Newark. Uniteds

once-a-week proposals are not supported by a meaningful market analysis or forecast,
and United should not be permitted to disrupt the 7-day patterns that other applicants
would operate from more viable U.S. gateways in this case. With its four once-a-week
proposals United appears to be simply throwing its hat in the ring, as none of them have
any semblance of seriousness.
In order to maximize public benefits of the HAV
frequencies, the Department should accept no once-a-week remnants from Uniteds

service proposal.
In addition, United provides no analytic support for its daily EWRHAV proposal.
It has offered no traffic forecast to justify its application. This is not surprising since the
Cuban American population living in the New York-Newark metro area is 156,514,
which is only 15% of the Ft. Lauderdale Miami population (Exhibit WN-R-703).
Finally, United has not submitted a low fare proposal or shown any amount of fare
savings - because it cant. Uniteds domestic average fare levels are 48% higher than
Southwests (Exhibit WN-R-701), which is not surprising given the fact that its unit costs
are 44% higher than Southwests costs (Exhibit WN-R-702).
37

$250
$239.96
$225
+48%
$200
$175
$162.01
$150
$125
$100
$75
$50
$25
$0
Southwest
United
United has also applied for one daily frequency for EWR-HAV.
As noted
previously, in Exhibit WN-R-703 and in the chart below, the FLL/MIA Cuban-American
population dwarfs that of New York-Newark.
Accordingly, EWR frequencies would
serve only a small share of U.S. - Havana travelers and should not be awarded at the
expense of the great majority of the Cuban American population for whom FLL is a far
more convenient gateway (Exhibit WN-R-704).
1,200,000
1,061,180
1,000,000
800,000
600,000
400,000
200,000
156,514
Ft. Lauderdale-Miami
New York-Newark
Metro Area
38
IX.
Frontiers Service Proposal Is Unsupported by the Evidence and

Undermined by Its Long History of Market Failures.
Frontiers service proposal is centered on Miami (3 daily frequencies) with a
conditional offer to serve DENHAV so long as it also receives a MIAHAV frequency.

Frontier has a very small presence in Miami, and it cannot provide U.S. network benefits
or blanket coverage of the U.S. as Southwest can do from FLL.
Today Frontier
operates only six week day departures at MIA to six cities, none of which are points in
the Caribbean or Latin America. As the chart below shows, Southwest is ten times
larger at FLL as Frontier is at MIA to U.S. points (Exhibit WN-R-802).
Southwests U.S. FLL Service Dwarfs Frontier at MIA
10,000
70
9,318
30
28
62.3
9,000
60
25
8,000
848%
7,000
6,000
50
949%
367%
20
40
15
5,000
30
4,000
10
3,000
20
6
2,000
983
10
5.9
1,000
WN-FLL
F9-MIA
WN-FLL
F9-MIA
WN-FLL
F9-MIA
Frontier has only four connecting routes to U.S. cities at MIA (Exhibit WN-R-803).
As shown below, Southwest, on the other hand, will provide connections to 27 U.S.
points from FLL (Exhibit WN-R-804).
39
Southwests Offers Almost Seven Times As Many Convenient

Connections at FLL than Frontier at MIA
MKE
MKE
MKE
MKE
MKE
MDW
MDW
MDW
MDW
MCI
MCI
MCI
MCI
MCI
MCI
DEN
DEN
DEN
DEN
DEN
DEN
STL
STL
STL
STL
STL
STL
BUF
BUF
BUF
ALB
ALB
ALB
BUF
BUF
ALB
ALB
ALB
BDL
BDL
BDL
BDL
BDL
BDL
PVD
PVD
PVD
PVD
PVD
PIT
PIT
PIT
PIT
PIT
PHL
PHL
PHL
CMH
PHL ISP
PHL
CMH
ISP
CMH
CMH PIT
IND
IND
ISP
IND CMH
ISP
ISP
IND
IND
BWI
BWI
BWI
BWI
BWI
BWI
DCA
DCA
DCA
DCA
BNA
BNA
BNA
BNA
BNA
BNA
LAS
LAS
LAS
LAS
LAS
LAS
PHX
PHX
PHX
PHX
PHX
PHX
ORD
ORD
ORD
ORD
ORD
ORD
LGA
LGA
LGA
LGA
LGA
PHL
PHL
PHL
PHL
PHL
RDU
RDU
RDU
RDU
RDU
RDU
ATL
ATL
ATL
ATL
ATL
ATL
ATL
ATL
ATL
ATL
ATL
ATL
DAL
DAL
DAL
DAL
MSY
MSY
MSY
MSY
MSY
AUS
AUS
AUS
AUS
AUS
AUS
TPA
TPA
TPA
TPA
TPA
HOU
HOU
HOU
HOU
HOU
HOU
FLL
FLL
MIA
MIA
HAV
HAV
HAV
HAV
SJU
SJU
SJU
SJU
SJU
SJU
Frontier styles itself as an ultra-low cost carrier (ULCC).
But as the
Department is aware, there are gimmicks and hidden charges in the pricing structure of
some ULCC carriers. The empirical evidence shows that Southwest, which eschews
hidden fees, 30 has twice as much impact on lowering market fares than Frontier (Exhibit
WN-R-801).
Southwests Low Fare Service Has a Substantially Greater Impact on
Market Structure and Competition than Spirits
Carrier Competition
Southwest
Frontier
$0.00
-$5.00
-$10.00
-$15.00
-$20.00
-$21.99
-$25.00
88%
-$30.00
-$35.00
-$40.00
-$41.46
-$45.00
-$50.00
30
See details of Southwests No Hidden Fees Transfarency Campaign at

http://www.transfarency.com/?src=SRCH_16_AD_c_138_22105988_p_transfarency&ct=UN
40
Frontiers proposal is not supported by market analysis or a traffic forecast of any

kind. We are simply asked to believe it can fill its airplanes, earn a profit, and stay and
develop its markets. This is an extremely tall order when Frontier has abandoned 73
domestic and 13 international stations since 2005 (Exhibits WN-R-809 and R-810).
Frontier has Abandoned 13 International Airports Since 2005
Period Served
Q1 05
Q1 06
Q1 07
Q1 08
Q1 09
Q1 10
Q1 11
Q1 12
Q1 13
Q1 14
Q1 15
Q1 16
Q1 17
MZT
PVR
SJD
ZIH
ACA
CZM
YYC
GDL
YVR
SJO
LIR
MBJ
HUX
These domestic and international abandoned airports represent 60% of the 134
airports Frontier has served since 2005 (Exhibit WN-R-811).
41
Frontier Has Abandoned More than Half the Airports it Has Served Since 2005
Airports Currently
Served
= 42% (56)
Airports
Abandoned
= 58% (78)
In total, Frontier has abandoned a staggering 283 routes since 2005 (Exhibit WNR-812). Frontier only commenced service to Miami in December 2014 (15 months ago)
and it is already beginning to reduce its service and seat capacity (Exhibit WN-R-805).
Spirit Has Only Served MIA for 15 Months and is
Already Starting to Pull Down Service
Weekly Departures
Weekly Seat-Departures
45
8,000
42
7,056
40
7,000
-17%
-14%
35
6,080
35
6,000
30
5,000
25
4,000
20
3,000
15
2,000
10
1,000
July 2015
July 2016
July 2015
42
July 2016
Frontiers record of abandoning markets casts serious doubt on its ability to

operate and maintain MIA-HAV service. However, even if it did remain in the market,
its service would not have a meaningful impact on Americans MIA-HAV fares due to its
de minimus size and high fee structure. As shown herein, Southwest has a significantly
greater impact on market fares with its low fare product and trusted brand.
Frontiers Denver Havana proposal is also extremely weak. In fact, the carrier
states that it must have the traffic support from Miami in order to operate to/from
Denver. That is hardly surprising given that there are only 4,439 Cuban Americans
living in the Denver area compared to over one million in the Ft. Lauderdale Miami
area (Exhibit WN-R-806). Excessive circuity would also impair Frontiers ability to serve
passengers beyond Denver (Exhibit WN-R-807 and R-808).
Denvers Limited Cuban American Population Does Not Warrant Nonstop HAV Service
1,200,000
1,061,180
1,000,000
800,000
600,000
400,000
200,000
4,439
0
Denver
Metro Area
43
There is nothing unique or compelling about Frontiers proposal, which is focused

on a market where it has a de minimus presence. For a carrier with Frontiers largescale history of in and out or lets see if it works air service, the requirements for
Frontier to qualify for one of the precious few HAV frequencies should be orders of
magnitude higher than is warranted for a highly stable airline like Southwest with
extraordinary success over a very long period of time. Given Frontiers erratic history,
its weak service proposal, and its serious consumer complaint problems (Exhibit WN-R813), the Department should not risk any of the Havana frequencies on Frontier.
In Contrast to Southwest, Frontier Does Not Provide
Good Service to the Traveling Public
Enplanements,
18.0
Southwest
Frontier
15.8
16.0
14.4
14.0
12.0
10.0
8.7
8.6
8.7
8.2
7.5
7.5
8.0
6.5
6.0
5.1
3.7
4.0
3.1
2.0
0.6
0.5
0.5
0.4
0.7
0.4
0.7
0.6
0.5
0.5
0.3
0.5
0.0
January
February
March
April
May
June
2015
44
July
August
September
October
November December
X.
Alaskas LAX-HAV Proposal Would Serve a Significantly Smaller Market

than FLL-HAV and Deserves At Most One Frequency.
Alaska Airlines has requested two daily LAX HAV frequencies with some flights
operating behind LAX to SEA and PDX. However, the notion of serving behind points
with single-plane service 31 is meaningless in the in-bound direction because of U.S.
Customs and Immigration and aircraft security inspections. These procedures require
the deplaning of passengers and all carry-on items plus inspection of the aircraft for
every international flight returning to the U.S.
The Seattle and Portland metro areas are home to very few Cuban Americans
5,323 in the case of Seattle, and 3,960 for Portland. 32 Both markets would generate
very low numbers of VFR traffic. In addition, Alaskas markets behind LAX would incur
severe circuity penalties. As shown below, only three markets have less than 35%
circuity (Exhibit WN-R-903 and R-905).
ANC
ANC
ANC
ANC
ANC
ANC
SEA
SEA
SEA
SEA
SEA
SEA
PDX
PDX
PDX
PDX
PDX
PDX
SLC
SLC
SLC
SLC
SLC
SLC
LAX
LAX
HAV
HAV
31
Alaska Application, pg. 1.

U.S. Department of Commerce, Bureau of the Census, American Community Survey, 2014-5 year
estimates.
32
45
Alaska Airlines has declined to present a forecast of the traffic it expects to carry.
However, without analysis or support, the carrier asserts there will be 159,000 local LAX
HAV passengers, or 190,000 on-boards when connecting traffic is included. 33 This is
Alaskas industry forecast, not an estimate of what it would carry with two daily
frequencies. Allowance must be made for other airline market shares, which naturally
would reduce Alaskas share.
American, United, Delta and Southwest all have significant operations at LAX
and their loyalty programs are a powerful draw. If Alaska is the only carrier with daily
nonstop service to HAV it will obtain, at most, 132,120, or 50% of the local market with
one flight, or 75% with the two flights. Alaska asserts that connecting passengers will
be 19.5% as great as the volume of local passengers. 34 Given the small market size in
SEA and PDX, coupled with Alaskas circuity disadvantage, it is not realistic to expect
more than a 10% connecting traffic add-on. As a result, a realistic projection of Alaskas
load factors does not exceed 66% for a single HAV frequency and 50% for two
frequencies. Accordingly, as shown below, under the best of circumstances, Alaskas
service proposal supports an allocation of no more than one frequency.
33
34
See Alaskas application at pages 8-9.

190,000 = 1.195 (Alaska Application, pages 8-9).
159,000
46
Alaska Airlines Service Proposal Produces

Very Weak Traffic and Low Load Factors
LAX - HAV
One
Two
Frequency
Frequency
159,000
159,000
AS Assumed Local Market

Assumed by Southwest
- AS share
- AS local passengers
-
On-board passengers (at 110% of local)
Alaskas Capacity and Load Factor

- One-way seats 35
-
Projected Load Factor
50%
79,500
75%
119,250
87,450
131,175
132,130
264,260
66.2%
49.6%
Alaskas application makes references to its low costs, but this is meaningful
only if it translates into low fares. Alaska provides no analysis to relate its fares to other
airlines in any markets. It simply asserts on page 11 that it will . . . offer low fares to
stimulate traffic. . . Southwest has compared its fare structure with Alaska in domestic
markets taken as a whole. The chart below shows that Alaskas average fare level is
23% higher than Southwests, and Alaskas unit costs (stage length adjusted) are 9%
higher than Southwest (Exhibit WN-R-902). Accordingly, Alaska cannot be relied upon
to deliver meaningful low fare competition in comparison to Southwest.
35
At 181 seats per departure (Exhibit AS-3).
47

$250
$225
$199.35
$200
$175
+23%
$162.01
$150
$125
$100
$75
$50
$25
$0
Southwest
Alaska
In sum, Alaskas service proposal clearly does not support an allocation of two
HAV frequencies. Further, it is questionable whether one frequency is even justified
since the Los Angeles Cuban American population is miniscule compared to South
Florida (Exhibit WN-R-101 and R-904) and would have numerous convenient
connecting options over South Florida.
48
The Cuban American Population in FLL/MIA Dwarfs Los Angeles

1,200,000
1,061,180
1,000,000
800,000
600,000
400,000
200,000
63,288
0
Los Angeles
Metro Area
XI.
Sun Countrys Less-Than-Daily Service is Not Viable and Would Divert

Valuable Frequencies from Important Daily Service Proposals.
Sun Country is proposing Ft. Myers Havana service twice a week with behind
service to Minneapolis, plus two Minneapolis Havana nonstops per week. It would
utilize B737-700 or B737-800 aircraft. The Company is advancing a weak 4 days-aweek proposal, and it must be assumed for purposes of this case that it would use its
small 126-seat B737-700.
Sun Country provides no evidentiary support for its Application. Nor does it even
attempt to show the size of the RSW HAV and MSP HAV markets. Furthermore,
Sun Country offers no network benefits, no daily service pattern, and there is no
mention of a low fare proposal. Sun Country also has a history of failure in a limited
entry market such as DCA.
49
In short, there is no basis to grant any of the limited Havana frequencies to Sun
Country not even 0.6 of one frequency (four days-a-week service) that would disrupt
the 7-day patterns other applicants are proposing to operate from more viable U.S.
gateways.
Sun Countrys application does not merit any of the scarce Havana
frequencies available and should be denied.
XII.
Silver Airways Proposes Service With Very Small Aircraft (34 Seats) and its
Application Should Be Denied on that Basis Alone.
Silver Airways entire service proposal contemplates the use of Saab 340 aircraft
with a maximum capacity of 34 seats, 36 and its projected load factor is only 59.5% after
adjusting for the payload restrictions. 37
Southwests forecast of average annual passengers per Havana frequency is
108,587 (Exhibit WN-100) while Silver projects an average of 14,740 annual
passengers per frequency (Exhibit 3M-13).
Allocation of a Havana frequency to
Southwest would generate 7.4 times as many passengers as a frequency operated by

Silver. Stated differently, Silvers small plane would deny 94,000 passengers the ability
to travel in the U.S. Havana market compared to Southwests proposal per frequency
(Exhibits WN-R-1001 and R-1002).
36
Due to payload restrictions over the U.S.-Havana segment, Silvers projected seats per departure
available for sale will be 31.1 (Exhibit 3M-13).
37
Actual projected load factor is 73,698 passengers (35 trips per week x 2 directions x 52 weeks x 34
seats) = 59.5%.
50

140,000
127,750
120,000
108,587
100,000
Additional Annual
Seats per
Frequency = 105,057
80,000
Additional Annual
Passengers per
Frequency = 93,847
60,000
40,000
22,693
20,000
14,740
0
Annual Seats per Daily
Southwest 737-800
Frequency

Silver Saab 340
Frequency
Annual Passengers per

Forecast Annual Silver
Daily Southwest 737-800 Passengers per Daily Saab
Frequency
340 Frequency
Silver also suffers from a small network that is unable to provide Havana service
to passengers in other parts of the United States. If U.S. - Havana frequencies were
unlimited, Silver would of course be free to compete even with its small aircraft and
limited network. However, under the severely limited frequency regime of the MOU,
there is no justification for awarding any Havana frequencies to Silver.
XIII.
Dynamic International Airways and Eastern Airlines are Unfit to Hold

Scheduled U.S. Cuba Authority and thus Ineligible in this Proceeding.
Dynamic is a charter airline with schedule authority pending before the DOT
(Order 2016-2-6). However, as of the date of its application in this case Dynamic was
not, and is not today, in possession of scheduled certificate authority. According to the
DOTs Order, Dynamic has a number of conditions to fulfill, including the acquisition of
51
FAA Part 121 authorization to conduct scheduled flights. 38 Furthermore, Dynamics

small fleet of four airplanes will not be able to provide any network benefits to the U.S.
Havana market. The application of Dynamic should therefore be rejected.
Eastern is certificated to provide charter service but similarly does not hold
scheduled authority. With only four planes in its fleet, it also would be unable to provide
any network benefits to the Miami Cuba market. Easterns application also should be
rejected.
CONCLUSION
For the reasons given above and in its Application, Southwests proposal to
provide FLL-HAV, TPA-HAV and MCO-HAV service will maximize public benefits in
this proceeding, as well as satisfy the Departments other decisional criteria.
Southwests proposal will offer and maintain the best service for the traveling public
and will have unmatched positive effects on the overall competitive environment,
including effects on market structure and competition in the U.S.-Cuba market.
Southwests service proposal therefore fulfills each of the Departments objectives in
this proceeding.
Accordingly, Southwest urges the Department to grant all the
frequency requests specified in its Application.

Respectfully submitted,
_____________________
Robert W. Kneisley
March 14, 2016
38
Order 2016-2-6, at page 1, footnote 1.
52
CERTIFICATE OF SERVICE
I hereby certify that on March 14, 2016, a copy of the foregoing was served via email on the following persons:
jeremy.ross@alaskaair.com (Alaska Airlines)
dheffernan@cozen.com (Counsel for Alaska Airlines)
bob.wirick@aa.com (American Airlines)
howard.kass@aa.com (American Airlines)
alex.krulic@delta.com (Delta Air Lines)
chris.walker@delta.com (Delta Air Lines)
nssparks@fedex.com (FedEx Express)
cefelts@fedex.com (FedEx Express)
slachter@cozen.com (Counsel for Frontier)
robert.land@jetblue.com (JetBlue Airways)
esahr@eckertseamans.com (Counsel for JetBlue Airways)
dderco@eckertseamans.com (Counsel for JetBlue Airways)
jyoung@yklaw.com (Counsel for Spirit Airlines)
dkirstein@yklaw.com (Counsel for Spirit Airlines)
thomas.ting@suncountry.com (Sun Country Airlines)
dan.weiss@united.com (United Airlines)
sseiden@crowell.com (Counsel for United Airlines)
john.varley@virginameria.com (Virgin America)
mlbenge@zsrlaw.com (Counsel for Virgin America)
jhfoglia@zsrlaw.com (Counsel for Virgin America)
rbtrinder@zsrlaw.com (Counsel for Houston Airport System)
jasilversmith@zsrlaw.com (Counsel for Houston Airport System)
susan.kurland@dot.gov
brian.hedberg@dot.gov
ben.taylor@dot.gov
brett.kruger@dot.gov
joseph.landart@dot.gov
EngleTS@state.gov
info@airlineinfo.com
__________________________
Leslie C. Abbott
53
BEFORE
THE U.S. DEPARTMENT OF TRANSPORTATION
2016 U.S. Cuba Frequency Allocation Proceeding

Rebuttal Exhibits Supporting the Answer of
Washington, D.C.
March 14, 2016
Docket OST-2016-0021
Page 1 of 5
Table of Contents
Exhibit
Number WN-R
Florida and Especially Ft. Lauderdale-Miami Warrants the Vast Majority of Available Havana Frequencies
101
Before Consideration of Convenient Connections, Ft. Lauderdale-Miami Has Nearly 700% More Cuban-American Residents than the Next Largest Proposed Gateway
102
Southwests Proposed Florida Points Are Very Convenient to Cuban-American Residents
103
Ft. Lauderdale is Much More Convenient than the Proposed Northeast Gateways
104
Ft. Lauderdale is Much More Convenient than the Proposed Non-Florida Gateways in the South
105
Ft. Lauderdale is Much More Convenient than the Proposed Gateways in the West
106
FLL and MIA Are By Far the Most Convenient Gateways for Cuban-American Residents Followed by Tampa and Orlando
107
The Large Emphasis of Charter Flights from Ft. Lauderdale-Miami Highlights How Important this Market is Relative to Other U.S. Markets
A Majority of South Florida Cuban-American Residents Will Prefer FLL over MIA
200
Ft. Lauderdale (FLL) Will Be the Airport Preferred by Most Cuban-American Travelers from South Florida
201
Over 60% of Ft. Lauderdales Domestic Seat-Departures are on Low Cost Carriers, Dwarfing Miamis Low Cost Carrier Share of Less Than Three Percent
202
Ft. Lauderdale has 23 Times More Weekly Domestic Low Cost Carrier Seat-Departures Than Miami
203
Ft. Lauderdale has Over 24,000 Weekly Low Cost Carrier Seat-Departures to the Caribbean Compared to Zero for Miami
204
MIAs Cost Per Enplaned Passenger is 252% Higher than FLLs Cost Per Enplaned Passenger
205
Ft. Lauderdale has 50% More Domestic Passengers than Miami in Markets where Both Have Nonstop Service
206
Southwests FLL Fares are Significantly Below Americans MIA Fares In Domestic Nonstop Markets
207
In Domestic Markets Where Both Airports Have Nonstop Service, FLL Fares are Significantly Below Those of MIA
208
FLL-SJU Fares Are 25% Lower than MIA-SJU Fares
209
The FLL-SJU Passenger O&D Market is More Than Twice as Large as MIA-SJU
210
In the South Florida - San Juan Market, Southwest has the Lowest Total Fare Paid
211
Based on South Florida-SJU, Southwest Will Have the Lowest South Florida-HAV Total Fare Paid
212
Eighty Percent (80%) of South Florida Cuban-Americans Are Within a One Hour Drive of FLL
213
Sixty One Percent (61%) of South Florida Cuban-Americans Are Within a 45 Minute Drive of FLL
214
A Majority of South Florida Residents Will Prefer FLL over MIA Because of FLLs Lower Fares and Costs to Passengers
Table of Contents
Page 2 of 5
Exhibit
Number WN-R
Rebuttal to American Airlines

301
Americans Current Domestic Fare Levels and Estimated HAV Fare Levels Are Over $45 Higher than Southwests Fare
302
Americans Average Domestic Fare is 42% Higher than Southwests
303
Americans Domestic Unit Costs Are 24% Higher than Southwests
304
American Lowers its Fares Significantly In Response to Southwests Competition
305
Americans Proposal Includes 8 International Connections at MIA That Would Block Seats to HAV and Provide No Benefit for American Consumers
306
The Ft. Lauderdale-Miami Cuban-American Population Dwarfs that of Both Dallas and Charlotte
307
FLL is a Much More Convenient Gateway for Cuban Americans than Either DFW or CLT
308
Over the Past Six Years, American has Significantly Reduced Its Service and Capacity Between the U.S. and the Caribbean
Rebuttal to JetBlue Airways

401
Southwests Effect on Reducing Market Fares is 43% Greater than JetBlues
402
In All But One Fort Lauderdale Domestic Market in Which Southwest and JetBlue Have Nonstop Service, Southwest Offers the Lower Average Fare
403
In Every San Juan Market in Which Southwest and JetBlue Have Nonstop Service, Southwest Offers the Lower Average Fare
404
JetBlues Unit Costs Are 20% Higher than Southwests
405
Southwests Unit Costs Have Been Consistently Below JetBlues Costs Over Time
406
Southwest is Larger than JetBlue at FLL to U.S. Points
407
JetBlues FLL-HAV Proposal Connects to 24 U.S. Points While Southwests FLL-HAV Proposal Connects to 27 U.S. Points
408
At TPA Southwest is Five Times Larger than JetBlue to U.S. Points
409
After Excluding Excessively Circuitous Routes JetBlues TPA-HAV Proposal Connects to Just 7 U.S. Points While Southwests TPA-HAV Proposal Connects to 33 U.S. Points
410
At MCO Southwest is More Than Twice As Large As JetBlue to U.S. Points
411
After Excluding Excessively Circuitous Routes JetBlues MCO-HAV Proposal Connects to Just 14 U.S. Points While Southwests MCO-HAV Proposal Connects to 32 U.S. Points
412
After Excluding Excessively Circuitous Routes JetBlues BOS-HAV Proposal Connects to Just 2 U.S. Points
413
FLL is a Much More Convenient Gateway for Cuban Americans than JFK, EWR or BOS
414
After Excluding Excessively Circuitous Routes JetBlues JFK-HAV Proposal Connects to Just 7 U.S. Points
415
The Ft. Lauderdale-Miami Cuban-American Population Dwarfs that of New York-Newark and Boston
Page 3 of 5
Table of Contents
Exhibit
Number WN-R
Rebuttal to Spirit Airlines

501
Southwests Effect on Reducing Market Fares is 58% Greater than Spirits
502
After Adjusting for Relevant Fees, Spirits Average FLL-SJU Fare is 11% Higher than Southwests
503
Southwest is 50% Larger than Spirit at FLL to U.S. Points
504
Spirits FLL-HAV Proposal Connects to 20 U.S. Points While Southwests FLL-HAV Proposal Connects to 27 U.S. Points
505
Southwest Would Carry at Least 21% More HAV Passengers per Nonstop Flight than Spirit
506
In the Last 10 Years Spirit Has Exited 16 International Routes, 12 of Them in Florida
507
Spirit Exited Service at Washington National Airport in 2012
508
Southwest Has One of Lowest Customer Complaint Levels in the Industry, While Spirit Has One of the Highest
Rebuttal to Delta Air Lines

601
Deltas Average Domestic Fare Level is 46% Higher than Southwests
602
Deltas Domestic Unit Costs Are 48% Higher than Southwests
603
Based on Empirical Data, Deltas Entry in the MIA-HAV Market Would Have Little if Any Effect on Fares
604
Southwest at FLL is More Than Twice Large As Delta at MIA to U.S. Points
605
Deltas MIA-HAV Proposal Connects to Just 7 U.S. Points Other Than New York and Atlanta
606
After Excluding Excessively Circuitous Routes, Deltas MIA-HAV Proposal Connects to Just 7 U.S. Points Other than New York and Atlanta While Southwests FLL-HAV Proposal
Connects to 27 U.S. Points
607
Southwest is Twice the Size of Delta at MCO to U.S. Points
608
After Excluding Excessively Circuitous Routes Deltas MCO-HAV Proposal Connects to Just 8 U.S. Points Other than New York and Atlanta
609
After Excluding Excessively Circuitous Routes Deltas MCO-HAV Proposal Connects to Just 8 U.S. Points Other than New York and Atlanta While Southwests MCO-HAV
Proposal Connects to 32 U.S. Points
610
The Ft. Lauderdale-Miami Cuban-American Population Dwarfs that of Both New York-Newark and Atlanta
611
FLL is a Much More Convenient Gateway for Cuban Americans than Either JFK or ATL
612
After Excluding Excessively Circuitous and International Routes Deltas JFK-HAV Proposal Connects to Just 8 U.S. Points
Page 4 of 5
Table of Contents
Exhibit
Number WN-R
Rebuttal to United Airlines

701
Uniteds Domestic Average Fare Levels Are 48% Higher than Southwests
702
Uniteds Domestic Unit Costs Are 44% Higher than Southwests
703
The Ft. Lauderdale-Miami Cuban-American Population Dwarfs that of New York-Newark
704
FLL is a Much More Convenient Gateway for Cuban Americans than EWR
705
After Excluding Excessively Circuitous Routes Uniteds EWR-HAV Proposal Connects to Just 19 U.S. Points
Rebuttal to Frontier Airlines

801
Southwests Effect on Reducing Market Fares is 88% Greater than Frontiers
802
Southwest at FLL is Ten Times Larger than Frontier at MIA to U.S. Points
803
Frontiers MIA-HAV Proposal Connects to Just 4 U.S. Points
804
Frontiers MIA-HAV Proposal Connects to Just 4 U.S. Points While Southwests FLL-HAV Proposal Connects to 27 U.S. Points
805
Since Starting Service to MIA in December 2014, Frontier Has Already Begun to Reduce Capacity
806
The Ft. Lauderdale-Miami Cuban-American Population Dwarfs that of Denver
807
FLL is a Much More Convenient Gateway for Cuban Americans than DEN
808
After Excluding Excessively Circuitous Routes Frontiers DEN-HAV Proposal Connects to Just 7 U.S. Points
809
Frontier Has Abandoned 13 International Stations in the Last 10 Years
810
Frontier Has Abandoned 73 Domestic Stations in the Last 10 Years and Re-Entered 8
811
Since 2005, Frontier has Abandoned Nearly 60% of the 134 Airports it Has Served
812
Frontier has Exited 283 Routes Since 2005
813
Southwest Has One of Lowest Complaint Levels in the Industry, Frontier Has One of the Highest
Page 5 of 5
Table of Contents
Exhibit
Number WN-R
Rebuttal to Alaska Airlines

901
Alaskas Average Domestic Fare Levels Are 23% Higher than Southwests
902
Alaskas Domestic Unit Costs Are 9% Higher than Southwests
903
After Excluding Excessively Circuitous Routes Alaskas LAX-HAV Proposal Connects to Just 3 U.S. Points
904
The Ft. Lauderdale-Miami Cuban-American Population Dwarfs that of Los Angeles
905
FLL is a Much More Convenient Gateway for Cuban Americans than LAX
Rebuttal to Silver Airways

1001
Southwest Would Carry 94,000 More Passengers and Provide 105,000 More Seats per Frequency than Silver
1002
Every Frequency Awarded to Silver for HAV Service Would Lose 94,000 Passengers
Florida and Especially Ft. Lauderdale-Miami

Warrants the Vast Majority of Available Havana Frequencies
Exhibit WN-R-101
Before Consideration of Convenient Connections,

Ft. Lauderdale-Miami Has Nearly 700% More Cuban-American
Residents than the Next Largest Proposed Gateway
Residents of Cuban-American Origin
1,200,000
1,061,180
1,000,000
800,000
+678%
600,000
400,000
200,000
156,514
120,826
63,288
56,821
22,115
15,382
13,413
7,305
Metro Area/1
1/ Combined Statistical Areas when available. Combines Sarasota and Lakeland with Tampa and Palm Bay/Melbourne Florida with Orlando.
Note: Includes gateways with proposed year-round daily or more large aircraft service.
Source: U.S. Department of Commerce, Bureau of Census, American Community Survey, 2014 5 year estimates.
4,439
Southwests Proposed Florida Points Are

Very Convenient to Cuban-American Residents
Exhibit WN-R-102
FLL (94%)/1
Each Dot Represents Relative Size of

Cuban-American Residents within
35% Circuity of the Airport Shown
FLL
HAV
TPA (43%)/2
MCO (41%)/3
MCO
TPA
HAV
1/ 94% of all Cuban-American residents in the U.S. can travel to HAV via FLL with less than 35% circuity.
2/ 43% of all Cuban-American residents in the U.S. can travel to HAV via TPA with less than 35% circuity.
3/ 41% of all Cuban-American residents in the U.S. can travel to HAV via MCO with less than 35% circuity.
Source: U.S. Bureau of the Census, 2014 American Community Profile
HAV
35% Circuity is an accepted analytical limit for forecasting traffic. Circuity in excess of 35%
introduces significant additional travel time that is inconvenient for many passengers.
Exhibit WN-R-103
Ft. Lauderdale is Much More Convenient than the Proposed Northeast Gateways
JFK
(12%)/2
JFK
FLL (94%)/1
HAV
EWR
(13%)/3
EWR
FLL
HAV
HAV
2/ 12% of all Cuban-American residents in the U.S. can travel to HAV via JFK with less than 35% circuity.
3/ 13% of all Cuban-American residents in the U.S. can travel to HAV via EWR with less than 35% circuity.
4/ 9% of all Cuban-American residents in the U.S. can travel to HAV via BOS with less than 35% circuity.
BOS
(9%)/4
BOS
HAV
Exhibit WN-R-104
Ft. Lauderdale is Much More Convenient than the

Proposed Non-Florida Gateways in the South
CLT
(26%)/2
FLL (94%)/1
CLT
HAV
ATL
(29%)/3
ATL
FLL
HAV
HAV
2/ 26% of all Cuban-American residents in the U.S. can travel to HAV via CLT with less than 35% circuity.
3/ 29% of all Cuban-American residents in the U.S. can travel to HAV via ATL with less than 35% circuity.
4/ 11% of all Cuban-American residents in the U.S. can travel to HAV via DFW with less than 35% circuity.
DFW
(11%)/4
DFW
HAV
Exhibit WN-R-105
Ft. Lauderdale is Much More Convenient than the Proposed Gateways in the West
DEN
(8%)/2
FLL (94%)/1
DEN
HAV
LAX
(7%)/3
FLL
HAV
LAX
2/ 8% of all Cuban-American residents in the U.S. can travel to HAV via DEN with less than 35% circuity.
3/ 7% of all Cuban-American residents in the U.S. can travel to HAV via LAX with less than 35% circuity.
4Source: U.S. Bureau of the Census, 2014 American Community Profile
HAV
Exhibit WN-R-106
Page 1 of 2
FLL and MIA Are By Far the Most Convenient Gateways for
Cuban-American Residents Followed by Tampa and Orlando
(Absolute Number of Cuban-American Residents)
U.S. Residents of Cuban-American Origin within
2,000,000
1,933,212
1,860,990
1,800,000
1,600,000
1,400,000
1,200,000
1,000,000
846,850
812,560
800,000
576,695
600,000
512,018
400,000
248,926
239,952
214,899
200,000
185,770
159,408
132,437
0
MIA
FLL
TPA
MCO
ATL
CLT
EWR
Gateway
Note: Includes gateways with proposed year-round daily (or more) large aircraft service.
JFK
DFW
BOS
DEN
LAX
Exhibit WN-R-106
Page 2 of 2
FLL and MIA Are By Far the Most Convenient Gateways for
Cuban-American Residents Followed by Tampa and Orlando
(Share of Cuban-American Residents)
% of U.S. Residents of Cuban-American Origin within
100%
97%
94%
90%
80%
70%
60%
50%
43%
41%
40%
29%
30%
26%
20%
13%
12%
11%
10%
9%
8%
7%
BOS
DEN
LAX
0%
MIA
FLL
TPA
MCO
ATL
CLT
EWR
JFK
Gateway
Note: Includes gateways with proposed year-round daily (or more) large aircraft service.
DFW
Exhibit WN-R-107
The Large Emphasis on Charter Flights from Ft. Lauderdale-Miami

Highlights How Important FLL/MIA is Relative to Other U.S. Markets
U.S. HAV Charter Passengers YE August 2015 = 631,993
California =5%
Florida = 68%
Ft. Lauderdale
- Miami
= 90%
FLL/MIA
Source: U.S. DOT, T-100 Data.
TPA
JFK
MCO
SJU
A Majority of South Florida Cuban-American

Residents Will Prefer FLL over MIA
Ft. Lauderdale (FLL) Will Be the Airport Preferred by

Most Cuban-American Travelers from South Florida
Exhibit WN-R-200
Page 1 of 5
Ft. Lauderdale (FLL) and Miami International (MIA) are 29 miles apart (by road) and it takes 39 minutes to drive
between them. It is a fact that the majority of Cuban Americans living in South Florida are closer to MIA than FLL measured by
driving time. It is equally true that FLL enjoys significantly lower fares than MIA, and this attracts passengers who will drive
further to save a considerable amount of money. Southwest Airlines has proven this to be true in many cities. Southwests
significant entry into BWI beginning in 1993 penetrated the Northern Virginia market that lives much closer to DCA or IAD.
When Southwest entered Providence and Manchester instead of Bostons Logan airport, it did so with the purpose of serving
the Boston metropolitan market and it did this effectively and successfully. In the South Florida situation, the low fares offered
by Southwest, JetBlue and Spirit attract hundreds of thousands of local passengers away from the higher fares and greater
congestion at MIA.
One of the considerations before the Department in this case is to combine passenger decisional considerations
of access time/cost with fare differentials between the two airports, in order to determine which airport will be preferred by the
majority of South Florida residents. In some respects this is a complex analytical question that demands a lot of data in order to
produce a precise numerical answer. Fortunately this case does not require such a degree of analytical precision. It is
sufficient to determine which airport, FLL or MIA, will be preferred by a majority of the Cuban Americans and other residents,
with comparative access times and cost, and comparative fares taken into account.
Exhibits WN-R-201 through WN-R-204 establish the fact that FLL is the center of low fare air service in South
Florida and MIA is not. Exhibit WN-R-201 shows the distribution of low fare service within each airport. Sixty percent (60%) of
FLLs seat-departures are operated by low cost carriers while only 3% of MIAs seat capacity is provided by low cost carriers.

Exhibit WN-R-200
Page 2 of 5
In absolute terms, FLL has 23 times as many domestic low cost carrier seat-departures as MIA (Exhibit WN-R-202); and when
service to the Caribbean markets is examined, one finds that FLL enjoys over 24,000 low cost carrier weekly seat-departures
and MIA has zero (Exhibit WN-R-203).
One of the reasons why FLL has attracted the low cost carriers, especially Southwest, Spirit and JetBlue is
because the airlines cost of operation/1 at the two airports is dramatically different $5.84 per enplaned passenger at FLL
versus $20.54 at MIA (Exhibit WN-R-204). This differential by itself allows airlines at FLL to charge $15 less per one-way
passenger than their counterparts at MIA. It should not be surprising that FLL has 50% more domestic O&D passengers in
markets served nonstop at both airports 13.5 million at FLL and 9.0 million at MIA/2.
The next step is to estimate what the fare differential is likely to be between Southwests proposed FLL HAV
service and Americans proposed MIA HAV service. This analysis is presented in Exhibits WN-R-206 through WN-R-211. In
domestic nonstop markets Southwests average fares at FLL are significantly lower than Americans fares at MIA. At the FLL
HAV distance of 255 miles Southwests average fare is $49 lower than Americans (Exhibit WN-R-206)/3. When all carriers are
included in this analysis, and not just Southwest and American, the average one-way fare differential in favor of FLL is $48
(Exhibit WN-R-207).
1/ Terminal plus air field charges.

2/ For the 12 months ended September 30, 2015. See Exhibit WN-R-205.
3/ All fares include baggage, cancellation and usage fees in the case of Spirit Airlines.

Exhibit WN-R-200
Page 3 of 5
Southwest analyzed fares in the FLL/MIA SJU/4 markets to determine current/5 differentials. Both airports enjoy
nonstop service to San Juan, a predominantly VFR and leisure market. For the most recent 12 months the average FLL oneway fare was 25%, or $50, lower than the MIA fare (Exhibit WN-R-208), and the FLL SJU O&D passenger volume was 103%
larger than the MIA SJU market (Exhibit WN-R-209).
Southwest compared the average one-way SJU fares paid by passengers of Southwest, Spirit and JetBlue at FLL,
and American at MIA. Baggage/cancellation and passenger usage fees (Spirit) must be combined with the base fare in order to
arrive at the price actually paid by the passenger. Exhibit WN-R-210 shows clearly that Southwest provides the lowest price in
the market by a large degree. If only the base fares are compared Southwest is still lower than American at MIA by 32.8%, and
lower than JetBlue at FLL by 16.0%. The average fare comparisons are as follows:
Average
One-Way
Price Paid
Average
One-Way
Base Fare
FLL - SJU
Southwest
Spirit
JetBlue
$124.00
137.46
156.14
$123.56
98.19
147.11
MIA - SJU
American
$197.81
$183.92
Source: Exhibit WN-R-210.

4/ San Juan, Puerto Rico
5/ For the 12 months ended September 30, 2015. See Exhibit WN-R-205.

Exhibit WN-R-200
Page 4 of 5
Based on this analysis it is reasonable to conclude that Southwest will have the lowest South Florida Havana
total fare paid - $45 lower than American, $21 lower than JetBlue and $9 lower than Spirit (Exhibit WN-R-211). The next step is
to reflect the fare differential between Southwest and American as a key decisional criteria for passengers choosing between
FLL and MIA for their trip to Havana.
A superficial view of the geographical distribution of South Florida Cuban American residents shows that most of
them live closer (in drive time) to MIA than to FLL, although 80% live within one hour of FLL because it is only 29 miles from MIA
(Exhibit WN-R-212). Furthermore, FLL is within 45 minutes of 61% of the South Florida Cuban American residents (Exhibit WNR-213).
Airport choice is much more complicated than a simple drive-time comparison. Comparisons of schedules
(frequency and time of day), airport facilitation time, parking cost, expected delay and risk allowance, and comparative fares all
play a part in passenger choice behavior. It is known for many other multi-airport regions that comparative air fares play a very
significant role in selecting an airport for travel.
To compare the value of drive time and fare differential, Southwests analysis is as follows/6:
1. The monetary value of passenger drive time was estimated assuming the market is 80% leisure and 20%
business, and the value per hour for leisure and business travelers was adopted from the DOTs current guide.
2. A weighted average value of time was determined from Step 1 above, and it is $38.70.
3. The average fare differential between Southwests FLL HAV and Americans MIA HAV services is estimated
from Exhibits WN-R-206 and R-211 to be $47.34.
6/ These steps are presented in Exhibit WN-R-214, page 2.

.

Exhibit WN-R-200
Page 5 of 5
4. Next, a conservative allowance for additional driving cost to FLL for the average traveler ($9.01) is deducted
from the estimated fare differential to yield a net savings at FLL of $38.33 per one-way passenger trip.
5. The difference of airport parking cost favors FLL significantly over MIA, and this is another passenger
consideration.
It should be concluded from Southwests analysis in Exhibit WN-R-214, coupled with the residential location of
Cuban Americans in South Florida, that a majority of Cuban Americans will prefer FLL over MIA for their travel to HAV, providing
Southwest Airlines is allocated sufficient frequencies to accommodate the demand.
Exhibit WN-R-201
Over 60% of Ft. Lauderdales Domestic

Seat-Departures are on Low Cost Carriers, Dwarfing
Miamis Low Cost Carrier Share of Less Than Three Percent
Ft. Lauderdale
Miami
Low Cost
Carriers
= 3%
Other Airlines
= 37%
Low Cost
Carriers
= 63%
Florida = 1,331,893
Note: Domestic seat-departures. Low Cost Carriers = Southwest, JetBlue, Spirit, Allegiant, and Frontier.
Source: Innovata schedule for week of March 7-13, 2016.
Other Airlines
= 97%
Exhibit WN-R-202
Ft. Lauderdale has 23 Times More Weekly Domestic

Low Cost Carrier Seat-Departures Than Miami
Domestic Low Cost Carrier Weekly Seat-Departures
200,000
186,032
180,000
160,000
140,000
120,000
2345%
178,424
100,000
80,000
60,000
40,000
20,000
7,608
0
Fort Lauderdale
Miami
Exhibit WN-R-203
Ft. Lauderdale has Over 24,000 Weekly Low Cost Carrier

Seat-Departures to the Caribbean Compared to Zero for Miami
Caribbean Low Cost Carrier Weekly Seat-Departures
30,000
24,486
25,000
20,000
15,000
10,000
5,000
0
0
Fort Lauderdale
Miami
Exhibit WN-R-204
MIAs Cost Per Enplaned Passenger is 252% Higher

than FLLs Cost Per Enplaned Passenger
Cost Per Enplaned Passenger (CPE)
$25
$20.54
$20
$15
252%
$14.70
$10
$5.84
$5
$0
FLL
Note: Fort Lauderdale CPE for Fiscal Year Ending September 30, 2015, Miami CPE for Fiscal Year Ending September 30, 2014.
Source: FAA Operating and Financial Summary Report 127.
MIA
Exhibit WN-R-205
Ft. Lauderdale has 50% More Domestic Passengers

than Miami in Markets where Both Have Nonstop Service
Annual
O&D Passengers
16,000,000
14,000,000
13,465,475
12,000,000
50%
4,494,038
10,000,000
8,971,437
8,000,000
6,000,000
4,000,000
2,000,000
0
Fort Lauderdale
Note: Domestic destinations in which both FLL and MIA have 250 or more nonstop roundtrip departures.
Source: U.S. DOT Domestic O&D Survey, YE Q3 2015, Innovata schedule, YE Q3 2015.
Miami
Exhibit WN-R-206
Southwests FLL Fares are Significantly

Below Americans MIA Fares In Domestic Nonstop Markets
Baggage/Cancellation Fees Paid,
YE Q3, 2015
$300

MIA AA Fare is $49 Higher on Average
AA MIA Fare Curve
$250
$200
WN FLL Fare Curve

= $49
$150
$100
$50
$0
0
250
500
750
1000
1250
1500
1750
2000
2250
Distance (Miles)
Note: Fare curves derived by regression analysis on yield and then converted to fare. Includes Domestic destinations in which Southwest (at FLL) and American (at MIA) have 250 or more
nonstop roundtrip departures. Includes fared passengers only. The abbreviation Avg. = Average. WN = Southwest Airlines.
Source: U.S. DOT Domestic O&D Survey, YE Q3 2015, Innovata schedule, YE Q3 2015 and Form 41 for fee data.
Exhibit WN-R-207
In Domestic Markets Where Both Airports Have Nonstop Service,

FLL Fares are Significantly Below Those of MIA
$300

MIA Fare is $48 Higher on Average
MIA Fare Curve
$250
$200
FLL Fare Curve

$150
= $48
$100
$50
$0
0
250
500
750
1000
1250
1500
1750
2000
2250
Distance (Miles)
Note: Fare curves derived by regression analysis on yield and then converted to fare. Includes Domestic destinations in which both FLL and MIA have 250 or more nonstop roundtrip departures.
Includes fared passengers only.
Source: U.S. DOT Domestic O&D Survey, YE Q3 2015, Innovata schedule, YE Q3 2015 and Form 41 for fee data.
Exhibit WN-R-208
FLL-SJU Fares Are 25% Lower than MIA-SJU Fares

$250
$198
$200
$148
-25%
-$50
$150
$100
$50
$0
Fort Lauderdale
(All U.S. Airlines)

Source: U.S. DOT Domestic O&D Survey, YE Q3, 2015, Fared Passengers.
Miami
(All U.S. Airlines)
Exhibit WN-R-209
The FLL-SJU Passenger O&D Market is More Than Twice as Large as MIA-SJU
Annual
O&D Passengers
500,000
472,055
450,000
400,000
103%
239,208
350,000
300,000
250,000
232,847
200,000
150,000
100,000
50,000
0
Fort Lauderdale
Source: U.S. DOT Domestic O&D Survey, YE Q3 2015.
Miami
Exhibit WN-R-210
In the South Florida - San Juan Market, Southwest has the Lowest Total Fare Paid
Avg. Fare Paid
$250
Avg. Bag/Cancellation Fee Paid
Avg. Passenger Usage Fee Paid
$197.81
$200
$13.89
$156.14
$150
$124.00
$0.44
$137.46
$9.03
$17.09 /1
$22.18
$100
$183.92
$147.11
$123.56
$50
$98.19
$0
SOUTHWEST
--
SPIRIT
10.9%
JETBLUE
AMERICAN
25.9%
59.5%
FLL-SJU
1/ Spirit Airlines Passenger Usage Fee of $17.99 marked down by 5% for passengers who purchase their ticket at the airport and do not pay the fee.
Note: Includes fared passengers only.
Source: U.S. DOT Domestic O&D Survey.
MIA-SJU
Based on South Florida-SJU, Southwest Will Have the

Lowest South Florida-HAV Total Fare Paid
Exhibit WN-R-211
Page 1 of 2

$140
Southwest Savings vs.

American = $45
$120
$126.43
$102.24
$100
$90.01
$81.19
$80
$60
$40
$20
$0
SOUTHWEST
--
SPIRIT
11.0%
Estimated FLL-HAV
Source: See next page for calculation.
JETBLUE
AMERICAN
25.9%
55.7%
Estimated MIA-HAV
Based on South Florida-SJU, Southwest Will Have the

Lowest South Florida-HAV Total Fare Paid
Exhibit WN-R-211
Page 2 of 2
Southwest
Spirit
JetBlue
American
$123.56
$98.19
$147.11
$183.92
South Florida-SJU Average Fares

Line
Average SJU One-way Fare Paid
Baggage/Cancellation Fee
$0.44
$22.18
$9.03
$13.89
Passenger Usage Fee
$0.00
$17.09
$0.00
$0.00
Total SJU Fare Paid
$124.00
$137.46
$156.14
$197.81
South Florida - SJU Distance
1,046
1,046
1,046
1,045
Total SJU Fare Paid Per Mile (Cents)
11.85
13.14
14.93
18.93
255
255
255
235
Calculation of South Florida- HAV Average Fares

7
South Florida - HAV Distance
Stage Length Adjusted South Florida-HAV

Total Fare Paid Per Mile (Cents)
31.84
35.30
40.09
53.80
South Florida-HAV Total Fare Paid
$81.19
$90.01
$102.24
$126.43
Line
1. For U.S. DOT, O&D Survey, YE Q3 2015 via, Diio. Fared Passengers Only.
+55.7%
2. Derived from Form 41 Data, YE Q3 2015.
3. From Spirits website. Spirit Airlines Passenger Usage Fee of $17.99 marked down by 5% for passengers who purchase their ticket at the airport and do not pay the fee.
4. Line 1 + Line 2 + Line 3
5. Nonstop Distance
6. Line 4 / Line 5 x 100
7. Nonstop Distance
8. HAV Adjusted Fare Per Mile = SJU Fare Per Mile x (HAV Distance/SJU Distance)-0.7
9. Line 7 x Line 8 / 100
Eighty Percent (80%) of South Florida

Cuban-Americans Are Within a One Hour Drive of FLL
60 Minutes
from FLL
Cuban Population in Ft. Lauderdale-Miami Metro Area

Time from FLL
60 Minute Drive
FLL
MIA
Each Black Dot Represents
100 Cuban-American Residents
Note: Total Ft. Lauderdale-Miami CSA Cuban-Americans = 1,061,180.
Exhibit WN-R-212
Cuban-American
% of Total
Residents
844,575
80%
Sixty One Percent (61%) of South Florida

Cuban-Americans Are Within a 45 Minute Drive of FLL
45 Minutes
from FLL
Cuban Population in Ft. Lauderdale-Miami Metro Area

Time from FLL
45 Minute Drive
FLL
MIA
Each Black Dot Represents
100 Cuban-American Residents
Note: Total Ft. Lauderdale-Miami CSA Cuban-Americans = 1,061,180.
Exhibit WN-R-213
Cuban-American
% of Total
Residents
650,881
61%
Exhibit WN-R-214
Page 1 of 2
A Majority of South Florida Residents Will Prefer FLL over

MIA Because of FLLs Lower Fares and Costs to Passengers
$80
$70
$66.83
$60
$28.50
/2
Savings in
Parking at FLL
Compared to MIA
/3
Average FLL Fare

Savings Net of
Additional Cost
of Driving to FLL
$50
/1
$40
$38.70
$30
$20
$38.33
$10
$0
U.S. DOT Value of 1 Hour of Time

Drive Time Between
FLL and MIA = 39 Minutes
Estimated Average Net Savings by Using FLL

Instead of MIA
1/ See page 2, this exhibit.

2/ The difference between economy parking at FLL and MIA is $9.50 per day. See http://www.broward.org/Airport/Parking/Pages/Default.aspx
and http://www.miami-airport.com/parking_rates.asp For this analysis Southwest assumed passengers to HAV would make an average visit of 3 days.
3/ Exhibits WN-R-206 and WN-R-211 show that expected fare savings for Southwests service at FLL for a 255 mile trip (FLL/MIA-HAV) ranges from $45.24 to $49.44 lower than Americans
service at MIA. The average differential in these referenced exhibits is $47.34. Deducting an allowance of $9.01 per trip to account for additional driving cost = $38.33. The additional
driving cost was calculated using the IRS mileage rare of $0.54 x the weighted average additional drive miles for South Florida passengers to drive to FLL.
Exhibit WN-R-214
Page 2 of 2
A Majority of South Florida Residents Will Prefer FLL over

MIA Because of FLLs Lower Fares and Costs to Passengers
Using DOT Standard Value of Time Shows that the Average South Florida-Havana
Passenger Would Drive an Additional Hour If Trip Savings Is More than $39
The DOT has developed metrics for forecasting the value that a passenger places on his/or her
time/1.
These values of passenger time are used in benefit-cost analyses and are based on the principle that
passenger choice behavior incorporates the monetary value of their time.
The DOTs standard average values per hour are $33.20 for personal travelers and $60.70 for
business travelers.
Assuming a distribution of 80% leisure and 20% business for travel to/from Havana, the weighted
average value of time is $38.70 per hour.
So, if a flight to HAV is more than $38.70 cheaper at FLL than MIA, the average passenger would
choose FLL even if it required driving an extra hour.
1/ See U.S. Department of Transportation, Office of Secretary, The Value of Travel Time Savings: Departmental Guidance for Conducting Economic Evaluations Revision 2 (2015 Update).
Rebuttal to American Airlines
Exhibit WN-R-301
Americans Current Domestic Fare Levels and Estimated HAV

Fare Levels Are Over $45 Higher than Southwests Fare
$180
$166.85
$160
+$49
$140
126.43
$117.42
$120
+$45
$100
$81.19
$80
$60
Southwest
At FLL
American
at MIA
Southwest
At FLL
American
at MIA
$40
$20
$0
Average Domestic FLL/MIA Fare at HAV Distance

Source: See Exhibits WN-R-206 and WN-R-211.
Estimated FLL/MIA-HAV Average Fare
Exhibit WN-R-302
Americans Average Domestic Fare is 42% Higher than Southwests

$250
$230.82
$225
+42%
$200
$175
$162.01
$150
$125
$100
$75
$50
$25
$0
Southwest
American
Notes: Derived from domestic yield curves for each carrier including fared passengers only and average baggage/cancellation/rebooking fees. Excludes local and federal taxes.
Average fares are calculated at Southwests average length of passenger haul of 932 miles.
Source: U.S. DOT Form 41 Data, YE Q3, 2015, and O&D Survey, YE Q3, 2015 via Diio.
Exhibit WN-R-303
Americans Domestic Unit Costs Are 24% Higher than Southwests

Stage Length Adjusted
Domestic CASM (Cents)
16.0
14.3
14.0
+24%
12.0
11.5
10.0
8.0
6.0
4.0
2.0
0.0
Southwest
American
Notes: Stage length adjusted using the square root of miles. All carriers adjusted to Southwests average stage length of 736 miles. Includes data for mainline only.
Source: U.S. DOT Form 41 Data, YE Q3, 2015.
American Lowers its Fares Significantly

In Response to Southwests Competition
Exhibit WN-R-304

$340
American Fares Without

Southwest or Other LCC
Competition
$320
$300
$280
$260
$240
American Fares with

Competition from Southwest
and no other LCC
$220
$200
$180
$160
$140
$120
$100
Distance
200
500
1000
1500
2000
$80
$60
$40
$20
AA without WN
Competition
$185
$229
$269
$295
$316
AA with WN % AA Fare Change with

Competition
WN Competition
$151
-18.7%
$186
-18.9%
$218
-19.0%
$239
-19.1%
$255
-19.1%
$0
0
100
200
300
400
500
600
700
800
900 1000 1100 1200 1300 1400 1500 1600 1700 1800 1900 2000
Notes: Fare curves derived by regression analysis. Fared passengers only. Includes average baggage and cancellation/rebooking fees paid by passengers. Excludes local and federal taxes.
Competitors based on nonstop service (500 or more annual one-way flights).
Source: U.S. DOT, O&D Survey and Innovata schedule data, via Diio, YE Q3, 2015.
Exhibit WN-R-305
Americans Proposal Includes 8 International Connections at MIA

That Would Block Seats to HAV and Provide No Benefit for American Consumers
LHR
LHR
LHR
LHR
LHR
LHR
CDG
CDG
CDG
CDG
CDG
CDG
YUL
YUL
YUL
YUL
YUL
YUL
MXP
MXP
MXP
MXP
MXP
MXP
YYZ
YYZ
YYZ
YYZ
YYZ
MAD
MAD
MAD
MAD
MAD
BDA
BDA
BDA
BDA
BDA
BDA
MIA
MIA
HAV
HAV
Proposed Route
International Connection
Source: American Application, Exhibit AA-1101.
BCN
BCN
BCN
Exhibit WN-R-306
The Ft. Lauderdale-Miami Cuban-American

Population Dwarfs that of Both Dallas and Charlotte
1,200,000
1,061,180
1,000,000
800,000
600,000
400,000
200,000
13,413
7,305
Dallas
Charlotte
0
Ft Lauderdale-Miami
Metro Area/1
Exhibit WN-R-307
FLL is a Much More Convenient Gateway for

Cuban Americans than Either DFW or CLT
U.S. Residents of Cuban-American Origin within 35% Circuity of Gateway
2,000,000
1,860,990
1,800,000
1,600,000
1,400,000
1,200,000
1,000,000
800,000
600,000
512,018
400,000
214,899
200,000
0
FLL
DFW
Gateway
CLT
Exhibit WN-R-308
Over the Past Six Years, American has Significantly Reduced Its Service
and Capacity Between the U.S. and the Caribbean
Weekly Departures
1,000
Nonstop Routes Served

100
140,000
95
903
90
900
120,000
800
-28%
-255
-19%
-21,519
100,000
700
-25%
-24
115,311
93,792
648
80
71
70
60
600
80,000
50
500
60,000
40
400
300
30
40,000
20
200
20,000
10
100
March 2010
March 2016
March 2010
Notes: American includes US Airways. Caribbean includes U.S. DOT Caribbean.

Source: Innovata schedule data for the weeks of March 15-21, 2010 and March 7-13, 2016.
March 2016
March 2010
March 2016
Rebuttal to JetBlue Airways
Exhibit WN-R-401
Southwests Effect on Reducing Market Fares is 43% Greater than JetBlues

Carrier Competition
Southwest
JetBlue
$0.00
-$5.00
-$10.00
-$15.00
-$20.00
-$25.00
-$30.00
-$28.91
43%
-$35.00
-$40.00
-$41.46
-$45.00
-$50.00
Note: Based on econometric model measuring the fare impact of each low cost carrier. The model controls for other factors such as distance and leisure markets in order to
assess the real fare impact of each low cost carrier. See WN Application Appendix 12 for more information.
Source: WN Application, Appendix 12.
Exhibit WN-R-402
In All But One Ft. Lauderdale Domestic Market in Which Southwest and
JetBlue Have Nonstop Service, Southwest Offers the Lower Average Fare
Southwest
JetBlue
$250
$197
$200
$186
$167
$160
$150
$156
$154
$147
$140
$139
$131
$127
$132
$124
$108
$100
$50
$0
AUS
BDL
LAS
PIT
PVD
Note: Baggage and Cancellation/Rebooking fee of $0.44 for Southwest and $9.03 for JetBlue.
Domestic destinations in which both Southwest and JetBlue have 250 or more nonstop roundtrip departures per year.
Source: U.S. DOT Domestic O&D Survey, YE Q3 2015, Innovata schedule, YE Q3 2015, Form 41 data for fees.
RDU
SJU
Exhibit WN-R-403
In Every San Juan Market in Which Southwest and JetBlue

Have Nonstop Service, Southwest Offers the Lower Average Fare
Southwest
JetBlue
$200
$180
$172
$156
$160
$155
$143
$134
$140
$124
$120
$100
$80
$60
$40
$20
$0
FLL
MCO
Note: Baggage and Cancellation/Rebooking fee of $0.44 for Southwest and $9.03 for JetBlue.
Domestic destinations in which both Southwest and JetBlue have 250 or more nonstop roundtrip departures per year.
Source: U.S. DOT Domestic O&D Survey, YE Q3 2015, Innovata schedule, YE Q3 2015, Form 41 data for fees.
TPA
Exhibit WN-R-404
JetBlues Unit Costs Are 20% Higher than Southwests

16.0
13.8
14.0
+20%
12.0
11.5
10.0
8.0
6.0
4.0
2.0
0.0
Southwest
JetBlue
Exhibit WN-R-405
Southwests Unit Costs Have Been Consistently Below JetBlues Costs Over Time
Southwest
JetBlue
16.0
14.0
13.7
14.0
12.1
12.0
14.8
14.2
12.5
12.3
13.8
12.4
12.0
11.5
10.6
10.0
8.0
6.0
4.0
2.0
0.0
2010
2011
2012
2013
2014
YE Q3 2015
Notes: Stage length adjusted using the square root of miles. Southwest and JetBlue adjusted to Southwests average stage length of 736 miles YE Q3 2015. Includes data
for mainline only.
Source: U.S. DOT Form 41 Data.
Exhibit WN-R-406
Southwest is Larger than JetBlue at FLL to U.S. Points

10,000
9,318
70
11%
9,000
30
62.3
8,360
60
5%
28
8%
26
59.3
25
8,000
50
7,000
20
6,000
40
15
5,000
30
4,000
10
3,000
20
2,000
10
1,000
WN
B6
Note: Includes all U.S. D50 service.

Source: Innovata schedule data for March 1-31, 2016.
WN
B6
WN
B6
Exhibit WN-R-407
JetBlues FLL-HAV Proposal Connects to 24 U.S. Points

While Southwests FLL-HAV Proposal Connects to 27 U.S. Points
Southwests Proposed FLL-HAV

(6 Daily RTs)
MKE
MKE
MKE
MKE
MKE
MDW
MDW
MDW
MDW
MCI
MCI
MCI
MCI
MCI
DEN
DEN
DEN
DEN
DEN
DEN
STL
STL
STL
STL
BUF
BUF
BUF
BUF
BUF
PHX
PHX
PHX
PHX
PVD
PVD
PVD
PVD
ISP
ISP
ISP
ISP
SFO
SFO
SFO
SFO
SFO
RDU
RDU
RDU
RDU
RDU
RDU
LAS
LAS
LAS
LAS
ATL
ATL
ATL
ATL
ATL
DAL
DAL
DAL
DAL
DAL
DAL
LAX
LAX
LAX
LAX
LAX
MSY
MSY
MSY
MSY
MSY
AUS
AUS
AUS
AUS
AUS
AUS
HOU
HOU
HOU
SYR
SYR
SYR ORH
ORH
ORH
DTW
DTW
DTW
DTW
DTW
BDL
BDL
BDL
BDL
SWF
SWF
SWF BDL
CLE
CLE
CLE
SWF
SWF
SWF
BOS
BOS
CLE
CLE
HPN
HPNBOS
LGA
LGAHPN
LGA
LGA
PIT
PIT EWR
PIT
PIT
PIT
EWRLGA
EWR
EWR
EWR
PHL
PHL
PHL
PHL
JFK
JFK
JFK
JFK
JFK
DCA
DCA
DCA
BWI
BWI
BWI
RIC
RIC BWI
RIC
RIC
RIC
RDU
RDU
RDU
RDU
RDU
RDU
ALB
ALB
ALB
ALB
ALB
ALB
BDL
BDL
BDL
BDL
PIT
PIT
PIT
PIT
PHL
PHL
PHL
CMH
CMH
PHL
PHL
PHL
CMH
CMH PIT
IND
IND
IND
IND
IND CMH
BWI
BWI
BWI
BWI
BWI
BWI
DCA
DCA
DCA
DCA
DCA
BNA
BNA
BNA
BNA
BNA
LAS
LAS
LAS
LAS
LAS
JetBlues Proposed FLL-HAV

(4 Daily RTs)
CHS
CHS
CHS
CHS
AUS
AUS
AUS
AUS
AUS
AUS
JAX
JAX
JAX
JAX
JAX
TPA
TPA
TPA
TPA
TPA
FLL
FLL
FLL
FLL
HAV
HAV
HAV
HAV
SJU
SJU
SJU
SJU
SJU
SJU
Proposed nonstop route

Connecting market (27)
Note: Circuity limited to 35%.

Source: Southwest Application, Exhibit WN-102 and JetBlue Application, Exhibit B6-104.
SJU
SJU
SJU
SJU
SJU
SJU

Exhibit WN-R-408
At TPA, Southwest is Five Times Larger than JetBlue to U.S. Points

14,000
100
13,195
90
40
89.1
37
35
12,000
80
30
10,000
70
574%
514%
8,000
20
50
6,000
429%
25
60
40
15
30
4,000
10
1,958
20
2,000
10
WN
B6

14.5
WN
B6
WN
B6
Exhibit WN-R-409
After Excluding Excessively Circuitous Routes

JetBlues TPA-HAV Proposal Connects to Just 7 U.S. Points
While Southwests TPA-HAV Proposal Connects to 33 U.S. Points
Southwests Proposed TPA-HAV
(2 Daily RTs)
DEN
DEN
DEN
DEN
DEN
DEN
MCI
MCI
MCI
MCI
MCI
LAS
LAS
LAS
LAS
LAS
FNT
FNT
FNT
MKE
MKE
MKEGRR
MHT
BUF
GRR
MHT
BUF
GRR
ALBMHT
FNT
FNT BUF
MKE
MKE
MKE
MHT
BUF
GRR
GRR FNT
ALB
ALB
ALB
BDL
BDL
BDL
MDW
MDW
MDW
BDL
MDW
MDW
MDW
CAK
CAK
CAK
CAK
CAK
CAK
ISP
PVD
ISP
ISP
PVD
PVD
ISP
PVD
PIT
PIT
PIT
PIT
PIT
CMH
CMH
CMH
PHL
PHL
PHL
CMH PIT
IND
IND
PHL
PHL
PHL
IND
IND
IND CMH
BWI
BWI
BWI
BWI
BWI
BWI
STL
STL
STL
STL
STL
STL
SDF
SDF
SDF
SDF
SDF
DCA
DCA
DCA
DCA
MEM
MEM
MEM
MEM
MEM
PHX
PHX
PHX
PHX
PHX
BNA
BNA
BNA
BNA
BNA
BOS
BOS
BOS
BOS
BOS
BDL
BDL
BDLBOS
HPN
HPN
HPN
LGA
LGAHPN
HPN
LGA
LGA
LGA
EWR
EWR
EWR JFK
JFK
JFK
EWR
DCA
DCA
DCA
DCA
DCA
RDU
RDU
RDU
RDU
RDU
ATL
BHM
BHM
ATL
BHM
ATL
ATL
BHM
BHMATL
DAL
DAL
DAL
DAL
DAL
DAL
AUS
AUS
AUS
AUS
AUS
HOU
HOU
SAT HOU
HOU
HOU
SAT
SAT
SAT
JetBlues Proposed TPA-HAV

(2 Daily RTs)
MSY
MSY
MSY
MSY
MSY
TPA
TPA
TPA
TPA
FLL
FLL
FLL
FLL
FLL
HAV
HAV
HAV
HAV
SJU
SJU
SJU
SJU
SJU

Excessively circuitous market (1)


Exhibit WN-R-410
At MCO, Southwest is More Than Twice As Large As JetBlue to U.S. Points

20,000
140
18,662
50
124.6
18,000
45
44
120
40
16,000
178%
100
14,000
12,000
159%
35
159%
30
80
25
10,000
60
8,000
48.1
6,708
6,000
20
17
15
40
10
4,000
20
2,000
WN
B6

WN
B6
WN
B6
Exhibit WN-R-411

JetBlues MCO-HAV Proposal Connects to Just 14 U.S. Points
While Southwests MCO-HAV Proposal Connects to 32 U.S. Points
Southwests Proposed MCO-HAV
(1 Daily RT)
OMA
OMA
OMA
OMA
OMA
OMA
DEN
DEN
DEN
DEN
DEN
MCI
MCI
MCI
MCI
MCI
JetBlues Proposed MCO-HAV

(2 Daily RTs)
SYR
SYR
SYR
BUF
BUF
BUFSYR
BUF
BUF
BUF
ROC
FNT
ROC
MKE
MKE
MHT
MHT
BUF
FNT
GRR
ROC
ROC
MKE
MHT
BUF
FNT
FNT BUF
GRR
ALB
ALB
MKE
MKEGRR
MHT
BUF
BUF ROC
GRR
GRRFNT
ALB
ALB
ALB MHT
BDL
MDW
PVD
PVD
BDLPVD
BDL
MDW
MDW
PVD
BDL
MDW
PVD
CAK
CAK
CAK
CAK
CAK
ISP
ISP
ISP
ISP
PIT
PIT
PIT
CMH
CMH
PHL
CMH
CMH
CMH PIT
PHL
PHL
IND
IND CMH
PHL
IND
IND
IND
BWI
BWI
BWI
BWI
BWI
STL
STL
STL
SDF
SDF
SDF
SDF
SDF
SDF
DCA
DCA
DCA
DCA
MEM
MEM
MEM
MEM
MEM
MEM
ORH
ORH
ORH
BDL
BDL BOS
BDL
BDL
BDL
BOS
BOS
HPN
HPN
HPN PVD
PVD
LGA
LGA PVD
LGA
LGA
LGA
EWR
EWR
EWR
JFK
JFK
BWI
BWI
BWI JFK
DCA
DCA
DCA BWI
DCA
DCA
DCA
SLC
SLC
SLC
SLC
SLC
BNA
BNA
BNA
BNA
BNA
ATL
ATL
ATL
BHM
BHM
ATL
ATL
BHM
BHM
BHMATL
DAL
DAL
DAL
DAL
DAL
DAL
AUS
AUS
AUS
AUS
HOU
HOU
HOU
HOU
HOU
SAT
SAT
SAT HOU
MSY
MSY
MSY
AUS
AUS
AUS
AUS
MCO
MCO
MCO
MCO
HAV
HAV
HAV
HAV
SJU
SJU
BQN
BQN
SJU
BQN
SJU
SJU
BQN
BQN
PSE
PSE
PSE
SJU
SJU
SJU
SJU
SJU



Exhibit WN-R-412

JetBlues BOS-HAV Proposal Connects to Just 2 U.S. Points
SEA
SEA
SEA
SEA
SEA
SEA
BOS
BOS
DTW
DTW
DTW
DTW
DTW
EWR
EWR
EWR
EWR
EWR
JFK
JFK
JFK
JFK
JFK
DEN
DEN
DEN
DEN
BWI
BWI
BWI
BWI
BWI
DCA
DCA
DCA
DCA
RIC
RIC
RIC
RIC
RIC
RIC
SFO
SFO
SFO
SFO
LAS
LAS
LAS
LAS
LAS
LAX
LAX
LAX
LAX
LAX
LAX
LGB
LGB
LGB
LGB
LGB
LGB
SAN
SAN
SAN
SAN
SAN
SAN
RDU
RDU
RDU
RDU
PHX
PHX
PHX
PHX
PHX
HAV
HAV


Source: JetBlue Application, Exhibit B6-104.
Exhibit WN-R-413

Cuban Americans than JFK, EWR or BOS
2,000,000
1,860,990
1,800,000
1,600,000
1,400,000
1,200,000
1,000,000
800,000
600,000
400,000
248,926
239,952
185,770
200,000
0
FLL
JFK
EWR
Gateway
BOS
Exhibit WN-R-414

JetBlues JFK-HAV Proposal Connects to Just 7 U.S. Points
SEA
SEA
SEA
SEA
SEA
SEA
PDX
PDX
PDX
PDX
BTV
BTV
BTV
BTV
BTV
ROC
ROC
ROC SYR
SYR
SYR
ROC
ROC
ROC
SYR
SYR
SYR
PWM
PWM
PWM
PWM
PWM
PWM
BUF
BUF
BUF
BUF
BOS
BOS
BOS
BOS
BOS
SLC
SLC
SLC
SLC
SLC
DEN
DEN
DEN
DEN
DEN
DEN
RNO
RNO
RNO
RNO
RNO
SMF
SMF
SMF
SMF
SMF
OAK
OAK
OAK
OAK
OAK
SFO
SFO
SFO
SFO
SFO
SJC
SJC
SJC
SJC
SJC
SJC
IAD
IAD
IAD
LAS
LAS
LAS
LAS
LAS
LAS
BUR
BUR
BUR
BUR
BUR
BUR
LAX
LAX
LAX PSP
PSP
LAX
LAX
LAX
PSP
PSP
PSP
LGB
LGB
LGB
LGB
SAN
SAN
SAN
SAN
SAN
SAN
JFK
JFK
RDU
RDU
RDU
RDU
RDU
ABQ
ABQ
ABQ
ABQ
ABQ
ABQ
PHX
PHX
PHX
PHX
PHX
PHX
HAV
HAV


Source: JetBlue Application, Exhibit B6-104.
Exhibit WN-R-415

Population Dwarfs that of New York-Newark and Boston
1,200,000
1,061,180
1,000,000
800,000
600,000
400,000
200,000
156,514
15,382
Ft Lauderdale-Miami
New York-Newark
Boston
Metro Area/1
Includes gateways with proposed year-round daily or more large aircraft service.
Rebuttal to Spirit Airlines
Exhibit WN-R-501
Southwests Effect on Reducing Market Fares is 58% Greater than Spirits

Carrier Competition
Southwest
Spirit
$0.00
-$5.00
-$10.00
-$15.00
-$20.00
-$25.00
-$26.13
-$30.00
58%
-$35.00
-$40.00
-$41.46
-$45.00
-$50.00
Exhibit WN-R-502
After Adjusting for Relevant Fees, Spirits Average

FLL-SJU Fare is 11% Higher than Southwests
Baggage/Cancellation and Passenger Usage
Fees Paid, FLL-SJU, YE Q3, 2015
$160
Avg. Fare Paid
Avg. Bag/Cancellation Fee Paid
Avg. Passenger Usage Fee Paid
$137.46
$140
$124.00
$0.44
+11%
$17.09
$120
$22.18
$100
$80
$60
$123.56
$98.19
$40
$20
$0
Southwest
Spirit
Note: FLL based on YE Q3 2015, Spirit Airlines Passenger Usage Fee of $17.99 marked down by 5% for passengers who purchase their ticket at the airport and do not pay the fee.
Source: U.S. DOT Domestic O&D Survey, fared passengers.
Exhibit WN-R-503
Southwest is 50% Larger than Spirit at FLL to U.S. Points

10,000
70
9,318
30
28
62.3
9,000
60
25
45%
8,000
7,000
6,427
6,000
33%
21
76%
50
20
40
35.3
15
5,000
30
4,000
10
3,000
20
2,000
10
1,000
WN
NK

WN
NK
WN
NK
Exhibit WN-R-504
Spirits FLL-HAV Proposal Connects to 20 U.S. Points

Spirits Proposed FLL-HAV

(2 Daily RTs)

(6 Daily RTs)
MSP
MSP
MSP
MSP
MSP
MKE
MKE
MKE
MKE
MKE
MDW
MDW
MDW
MDW
MDW
MCI
MCI
MCI
MCI
MCI
DEN
DEN
DEN
DEN
DEN
DEN
STL
STL
STL
STL
BUF
BUF
BUF
BUF
BUF
PIT
PIT
PIT
PIT
PIT
PHL
PHL
PHL
CMH
CMH
PHL
PHL
PHL
CMH
CMH PIT
IND
IND
IND
IND
IND CMH
BWI
BWI
BWI
BWI
BWI
BWI
DCA
DCA
DCA
DCA
DCA
BNA
BNA
BNA
BNA
BNA
LAS
LAS
LAS
LAS
LAS
PHX
PHX
PHX
PHX
ALB
ALB
ALB
ALB
ALB
ALB
BDL
BDL
BDL
BDL
ORD
ORD
ORD
ORD
ORD
PVD
PVD
PVD
PVD
ISP
ISP
ISP
ISP
DTW
DTW
DTW
DTW
DTW
CLE
CLE
CLE
CLE
CLE
BOS
BOS
BOS
BOS
BOS
LGA
LGA
LGA
LGA
LGA
ACY
ACY
ACY
ACY
BWI
BWIACY
BWI
DEN
DEN
DEN
DEN
DEN
LAS
LAS
LAS
LAS
LAS
RDU
RDU
RDU
RDU
RDU
RDU
LAX
LAX
LAX
LAX
LAX
LAX
ATL
ATL
ATL
ATL
ATL
DAL
DAL
DAL
DAL
DAL
DAL
PBG
PBG
PBG
PBG
PBG
PBG
IAG
IAG
IAG
IAG
PHX
PHX
PHX
PHX
PHX
DFW
DFW
DFW
DFW
ATL
ATL
ATL
ATL
MYR
MYR
MYR
MYR
MYR
MSY
MSY
MSY
MSY
MSY
AUS
AUS
AUS
AUS
AUS
AUS
HOU
HOU
HOU
TPA
TPA
TPA
TPA
TPA
MCO
MCO
MCO
MCO
MCO
TPA
TPA
TPA
TPA
TPA
FLL
FLL
FLL
FLL
HAV
HAV
HAV
HAV
SJU
SJU
SJU
SJU
SJU
SJU


Source: Southwest Application, Exhibit WN-102 and Spirit Application, Exhibit NK-CU-3.
BQN
BQN
BQN
BQN
BQN
BQN

Exhibit WN-R-505
Southwest Would Carry at Least 21% More

HAV Passengers per Nonstop Flight than Spirit
140,000
127,750
+21,900
+21%
120,000
105,850
108,587
+18,614
+21%
100,000
89,973
80,000
60,000
40,000
20,000
0
Southwest 737-800
Frequency /1
1/ From WN Application, Appendix 1, page 7.

2/ From Spirit Application, Exhibit NK-CU-2. 145 seats.
4/ Calculated onboard passengers at 85% load factor.
Source: Carrier Applications.

Spirit A319 Frequency /2
Annual Southwest
Passengers Per Daily
Southwest 737-800
Frequency /3
Annual Spirit Passengers

Per Daily A319 Frequency /4
Exhibit WN-R-506
In the Last 10 Years Spirit Has Exited 16

International Routes, 12 of Them in Florida
Florida
Route
Period of Service
Q1 05
Q1 06
Q1 07
FLL-NAS
FLL-ZSA
MCO-MBJ
LGA-NAS
FLL-GDT
FLL-GCM
FLL-PLS
TPA-CUN
MCO-NAS
LAX-GUA
FLL-FPO
FLL-POS
FLL-BAQ
FLL-TLC
DFW-TLC
IAH-TLC
Source: Innovata schedule data.
Q1 08
Q1 09
Q1 10
Q1 11
Q1 12
Q1 13
Q1 14
Q1 15
Q1 16
Q1 17
Exhibit WN-R-507
Spirit Exited Service at Washington National Airport in 2012
DTW
DTW
DTW
DTW
DTW
Peak
Daily Departures
614
Daily Seat-Departures
DCA
DCA
Now
MYR
MYR
MYR
MYR
MYR
MYR
FLL
FLL
FLL
FLL
Note: Peak schedule was in Q2 2005.

Source: Innovata schedule data
Exhibit WN-R-508
Southwest Has One of Lowest Customer Complaint Levels in the Industry,

While Spirit Has One of the Highest
Enplanements,
Southwest
Spirit
25.0
20.0
19.2
15.4
15.0
12.7
12.6
11.6
11.7
10.8
10.3
11.0
10.0
8.0
8.5
7.3
5.0
0.6
0.5
0.5
0.4
0.4
0.7
0.7
0.6
0.5
0.5
0.3
0.5
0.0
January
February
March
April
May
June
2015
Source: U.S. DOT Air Travel Consumer Report.
July
August
September
October
November December
Rebuttal to Delta
Exhibit WN-R-601
Deltas Average Domestic Fare Level is 46% Higher than Southwests

$250
$236.77
$225
+46%
$200
$175
$162.01
$150
$125
$100
$75
$50
$25
$0
Southwest
Delta
Exhibit WN-R-602
Deltas Domestic Unit Costs Are 48% Higher than Southwests

18.0
17.0
16.0
+48%
14.0
12.0
11.5
10.0
8.0
6.0
4.0
2.0
0.0
Southwest
Delta
Exhibit WN-R-603
Based on Empirical Data, Deltas Entry in the

MIA-HAV Market Would Have Little if Any Effect on Fares
Legacy Fares in Markets With

One Legacy Carrier Only
$380
$360
$340
$320
Legacy Fares With

Legacy Only Competition
$300
$280
$260
$240
Legacy Fares With

Southwest and No Other
LCC Competition
$220
$200
$180
$160
$140
Legacy Only,
Distance
1 Carrier
200
$188
500
$240
1000
$289
1500
$322
2000
$347
$120
$100
$80
$60
$40
$20
Legacy Only,
2 or 3 Carriers
$200
$245
$284
$311
$331
Legacy
with WN
Competition
$152
$192
$229
$249
$273
$0
0
100
200
300
400
500
600
700
800
900
1000 1100 1200 1300 1400 1500 1600 1700 1800 1900 2000
Notes: Fare curves derived by regression analysis. Fared passengers only. Includes average baggage and cancellation/rebooking fees paid by passengers. Excludes local and federal taxes.
Competitors based on nonstop service (500 or more annual one-way flights).
Source: U.S. DOT, O&D Survey and Innovata schedule data, via Diio, YE Q3, 2015.
Exhibit WN-R-604
Southwest at FLL is More Than Twice Large As Delta at MIA to U.S. Points

10,000
70
9,318
30
28
62.3
9,000
60
25
8,000
109%
7,000
6,000
50
113%
180%
20
40
5,000
15
4,453
29.2
30
4,000
10
10
3,000
20
2,000
10
1,000
WN-FLL
DL-MIA

WN-FLL
DL-MIA
WN-FLL
DL-MIA
Deltas MIA-HAV Proposal Connects to Just 7 U.S. Points

Other Than New York and Atlanta
MSP
MSP
MSP
MSP
MSP
DTW
DTW
DTW
DTW
DTW
LGA
LGA
LGA
LGA
LGA
LGA
JFK
JFK
JFK
JFK
JFK
CMH
CMH
CMH
CMH
IND
IND
IND
IND
IND
IND
RDU
RDU
RDU
RDU
RDU
LAX
LAX
LAX
LAX
LAX
LAX
ATL
ATL
ATL
ATL
ATL
MCO
MCO
MCO
MCO
MCO
MIA
MIA
HAV
HAV


Source: Delta Application, Exhibit DL-713 and DL-714.
Exhibit WN-R-605
Exhibit WN-R-606
After Excluding Excessively Circuitous Routes, Deltas MIA-HAV

Proposal Connects to Just 7 U.S. Points Other than New York and Atlanta
(6 Daily RTs)
Deltas Proposed MIA-HAV

(2 Daily RTs)
MSP
MSP
MSP
MSP
MSP
MKE
MKE
MKE
MKE
MKE
MDW
MDW
MDW
MDW
MDW
MCI
MCI
MCI
MCI
MCI
DEN
DEN
DEN
DEN
DEN
DEN
STL
STL
STL
STL
BUF
BUF
BUF
BUF
BUF
PIT
PIT
PIT
PIT
PIT
PHL
PHL
PHL
CMH
CMH
PHL
PHL
PHL
CMH
CMH PIT
IND
IND
IND
IND
IND CMH
BWI
BWI
BWI
BWI
BWI
BWI
DCA
DCA
DCA
DCA
DCA
BNA
BNA
BNA
BNA
BNA
LAS
LAS
LAS
LAS
LAS
PHX
PHX
PHX
PHX
ALB
ALB
ALB
ALB
ALB
ALB
BDL
BDL
BDL
BDL
DTW
DTW
DTW
DTW
DTW
PVD
PVD
PVD
PVD
ISP
ISP
ISP
ISP
JFK
JFK
JFK
JFK
JFK
RDU
RDU
RDU
RDU
RDU
RDU
RDU
RDU
RDU
RDU
ATL
ATL
ATL
ATL
ATL
DAL
DAL
DAL
DAL
DAL
DAL
LGA
LGA
LGA
LGA
LGA
CMH
CMH
IND
IND CMH
IND
IND
IND
LAX
LAX
LAX
LAX
LAX
LAX
ATL
ATL
ATL
MSY
MSY
MSY
MSY
MSY
AUS
AUS
AUS
AUS
AUS
AUS
HOU
HOU
HOU
MCO
MCO
MCO
MCO
TPA
TPA
TPA
TPA
TPA
MIA
MIA
FLL
FLL
HAV
HAV
HAV
HAV
SJU
SJU
SJU
SJU
SJU
SJU


Source: Southwest Application, Exhibit WN-102 and Delta Application, Exhibits DL-713-714.

Exhibit WN-R-607
Southwest is Twice the Size of Delta at MCO to U.S. Points

20,000
140
18,662
50
124.6
18,000
45
44
120
40
16,000
78%
100
14,000
12,000
10,488
113%
35
91%
30
80
23
25
10,000
58.6
60
8,000
6,000
20
15
40
10
4,000
20
2,000
WN
DL

WN
DL
WN
DL

Deltas MCO-HAV Proposal Connects to
Just 8 U.S. Points Other than New York and Atlanta
SEA
SEA
SEA
SEA
SEA
SEA
MSP
MSP
MSP
MSP
MSP
DTW
DTW
DTW
DTW
SLC
SLC
SLC
SLC
SLC
LGA
LGA
LGA
LGA
LGA
LGA
IND
IND
IND
IND
IND
IND
JFK
JFK
JFK
JFK
JFK
CVG
CVG
CVG
CVG
CVG
RDU
RDU
RDU
RDU
RDU
ATL
ATL
ATL
ATL
LAX
LAX
LAX
LAX
LAX
LAX
MCO
MCO
HAV
HAV
CUN
CUN
CUN
CUN
GRU
GRU
GRU
GRU
GRU
GRU

International market (2)

Exhibit WN-R-608
Exhibit WN-R-609
After Excluding Excessively Circuitous Routes Deltas MCO-HAV

Proposal Connects to Just 8 U.S. Points Other than New York and Atlanta
While Southwests MCO-HAV Proposal Connects to 32 U.S. Points
Southwests Proposed MCO-HAV
(1 Daily RT)
Deltas Proposed MCO-HAV

(1 Daily RT)
SEA
SEA
SEA
SEA
SEA
MSP
MSP
MSP
MSP
MSP
OMA
OMA
OMA
OMA
OMA
OMA
DEN
DEN
DEN
DEN
DEN
MCI
MCI
MCI
MCI
MCI
ROC
FNT
ROC
MKE
MKE
MHT
MHT
BUF
FNT
GRR
ROC
ROC
MKE
MHT
BUF
FNT
FNT BUF
GRR
ALB
ALB
MKE
MKEGRR
MHT
BUF
BUF ROC
GRR
GRRFNT
ALB
ALB
ALB MHT
BDL
MDW
MDW
PVD
PVD
BDLPVD
BDL
MDW
PVD
BDL
MDW
MDW
PVD
CAK
CAK
CAK
CAK
CAK
ISP
ISP
ISP
ISP
PIT
PIT
PIT
PIT
CMH
CMH
PHL
CMH
CMH
CMH PIT
PHL
PHL
IND
IND CMH
PHL
IND
IND
IND
BWI
BWI
BWI
BWI
BWI
STL
STL
STL
STL
STL
SDF
SDF
SDF
SDF
SDF
SDF
DCA
DCA
DCA
DCA
MEM
MEM
MEM
MEM
MEM
MEM
DTW
DTW
DTW
DTW
DTW
SLC
SLC
SLC
SLC
LGA
LGA
LGA
LGA
LGA
IND
IND
IND
IND
CVG
CVG
CVG
JFK
JFK
JFK
JFK
JFK
JFK
BNA
BNA
BNA
BNA
BNA
RDU
RDU
RDU
RDU
ATL
ATL
ATL
BHM
BHM
ATL
ATL
BHM
BHM
BHMATL
LAX
LAX
LAX
LAX
LAX
LAX
ATL
ATL
ATL
DAL
DAL
DAL
DAL
DAL
DAL
AUS
AUS
AUS
AUS
HOU
HOU
HOU
HOU
HOU
SAT
SAT
SAT HOU
MSY
MSY
MSY
MCO
MCO
MCO
MCO
HAV
HAV
HAV
HAV
CUN
CUN
CUN
GRU
GRU
GRU
SJU
SJU
SJU
SJU
SJU


Source: Southwest Application, Exhibit WN-106 and Delta Application, Exhibits DL-717-718.

Exhibit WN-R-610

Population Dwarfs that of Both New York-Newark and Atlanta
1,200,000
1,061,180
1,000,000
800,000
600,000
400,000
200,000
156,514
22,115
Ft Lauderdale-Miami
New York-Newark
Atlanta
Metro Area/1
Exhibit WN-R-611

Cuban Americans than Either JFK or ATL
2,000,000
1,860,990
1,800,000
1,600,000
1,400,000
1,200,000
1,000,000
800,000
576,695
600,000
400,000
239,952
200,000
0
FLL
JFK
Gateway
ATL
Exhibit WN-R-612
After Excluding Excessively Circuitous and International Routes

Deltas JFK-HAV Proposal Connects to Just 8 U.S. Points
EDI
EDI
EDI
EDI
EDI
EDI
DUB
DUB
DUB
DUB
DUB
MAN
MAN
MAN
MAN
MAN
MAN
LHR
LHR
LHR
LHR
LHR
LHR
BRU
BRU
BRU
BRU
BRU
CDG
CDG
CDG
CDG
CDG
SEA
SEA
SEA
SEA
SEA
PDX
PDX
PDX
PDX
PDX
YQB
YQB
YQB
YQB
YQB
YUL
YUL
YUL
YUL
YUL
YUL
YYZ
YYZ
YYZ
YYZ
YYZ
ROC
ROC
SYR
ROC
SYR
ROC
ROC SYR
SYR
SYR
BUF
BUF
BUF
MSP
MSP
MSP
MSP
MSP
MSP
SLC
SLC
SLC
SLC
SLC
ORD
ORD
ORD
ORD
ORD
DEN
DEN
DEN
DEN
DEN
DEN
SFO
SFO
SFO
SFO
SFO
SFO
LAS
LAS
LAS
LAS
LAS
LAX
LAX
LAX
LAX
LAX
SAN
SAN
SAN
SAN
SAN
PHX
PHX
PHX
PHX
PHX
PHX
ZRH
ZRH
ZRH
ZRH
ZRH
TLV
TLV
TLV
TLV
TLV
MXP
MXP
MXP
YHZ
YHZ
YHZ
YHZ
NCE
NCE
NCE
NCE
NCE
BOS
BOS
BOS
JFK
JFK
MAD
MAD
MAD
MAD
MAD
ATL
ATL
ATL
ATL
DFW
DFW
DFW
DFW
DFW
AUS
AUS
AUS
AUS
AUS
AUS
DTW
DTW
DTW
DTW
DTW
DTW
CLE
CLE
CLE
CLE
CLE
CLE
PHL
PHL
PHL
PHL
PHL
PHL
BWI
BWI
PIT
PIT
PIT BWI
BWI
BWI
CMH
CMH
CMH
CMH
CMH
CVG
CVG
CVG
CVG
IAD
IAD
DCA
IAD
DCA
RIC
RIC
RIC DCA
IAD
IAD
DCA
DCA
RIC
RIC
RIC
ORF
ORF
ORF
ORF
RDU
RDU
RDU
RDU
RDU
RDU
MSY
MSY
MSY
MSY
MSY
MSY
JAX
JAX
JAX
MCO
MCO
MCO
MCO
MCO
TPA
TPA
TPA
TPA
TPA
SAT
SAT
SAT
SAT
SAT
FLL
FLL
FLL
FLL
FLL
MIA
MIA
MIA
MIA
MIA
HAV
HAV
STI
STI
STI
STI
STI
STI
SDQ
SDQ
SDQ
SDQ
SDQ
SDQ
SJU
SJU
SJU
SJU
SJU
SJU
DKR
DKR
DKR
DKR
GUA
GUA
GUA
GUA
GUA
GUA
GRU
GRU
GRU
GRU
GRU
BOG
BOG
BOG
BOG
BOG
BOG

FRA
FRA
FRA
FRA
FRA
BCN
BCN
BCN
BCN
BCN
FCO
FCO
FCO
FCO
Rebuttal to United
Exhibit WN-R-701
Uniteds Domestic Average Fare Levels Are 48% Higher than Southwests
$250
$239.96
$225
+48%
$200
$175
$162.01
$150
$125
$100
$75
$50
$25
$0
Southwest
United
Exhibit WN-R-702
Uniteds Domestic Unit Costs Are 44% Higher than Southwests

18.0
16.6
16.0
+44%
14.0
12.0
11.5
10.0
8.0
6.0
4.0
2.0
0.0
Southwest
United
Exhibit WN-R-703

Population Dwarfs that of New York-Newark
1,200,000
1,061,180
1,000,000
800,000
600,000
400,000
200,000
156,514
New York-Newark
Metro Area/1
Exhibit WN-R-704
FLL is a Much More Convenient Gateway for Cuban Americans than EWR
2,000,000
1,860,990
1,800,000
1,600,000
1,400,000
1,200,000
1,000,000
800,000
600,000
400,000
248,926
200,000
0
FLL
EWR
Gateway
Exhibit WN-R-705

Uniteds EWR-HAV Proposal Connects to Just 19 U.S. Points
SEA
SEA
SEA
SEA
SEA
SEA
PDX
PDX
PDX
PDX
PDX
PDX
BTV
BTV
BTV
BTV
BTV
MSP
MSP
MSP
MSP
MSP
MKE
MKE
MKE
MKE
MKE
MKE
BUF
BUF
BUF
BUF
BUF
BUF
ORD
ORD SBN
ORD
SBN
SBN
SBN
SBN
OMA
OMA
OMA
BGM
BGM
BGM
BGM
DTW
DTW
DTW
DTW
DTW
CLE
CLE
CLE
CLE
CLE
CAK
CAK
CAK
CAK
CAK
CAK
CMH
CMH
CMH
CMH
CMH
IND
IND
IND
IND
IND
CVG
CVG
CVG
CVG
STL
STL
STL
STL
STL
ROC
ROC SYR
SYR
SYR
ROC
ROC
ROC
SYR
SYR
SYR
ITH
ITH
ITH
ITH
ITH
ITH
SDF
SDF
SDF
SDF
SDF
SDF
SFO
SFO
SFO
SFO
SFO
SFO
ALB
ALB
ALB
ALB
ALB
BDL
BDL
BDL
BDL
BDL
BDL
AVP
AVP
AVP
AVP
AVP
PIT
PIT
PIT
PIT
BWI
BWI
BWI
BWI
IAD
IAD
IAD
IAD
DCA
DCA
DCA
DCA
EWR
EWR
RIC
RIC
RIC
RIC
RIC
RIC
ORF
ORF
ORF
BNA
BNA
BNA
BNA
BNA
BNA
LAS
LAS
LAS
LAS
LAS
LAS
TYS
TYS
TYS
TYS
TYS
OKC
OKC
OKC
OKC
OKC
OKC
LAX
LAX
LAX
LAX
LAX
SNA
SNA
SNA
SNA
SNA
SAN
SAN
SAN
SAN
PHX
PHX
PHX
PHX
PHX
DFW
DFW
DFW
DFW
AUS
AUS
AUS
AUS
AUS
AUS
SAT
SAT
SAT
SAT
SAT
IAH
IAH
IAH
IAH
IAH
MSY
MSY
MSY
MSY
MSY
MSY
HAV
HAV


Source: United Application, Exhibit UA-132-133,136-137.
PWM
PWM
PWM
PWM
PWM
PWM
MHT
MHT
MHT
MHT
MHT
MHT
BOS
BOS
BOS
BOS
BOS
PVD
PVD
PVD
PVD
PVD
Rebuttal to Frontier
Exhibit WN-R-801
Southwests Effect on Reducing Market Fares is 88% Greater than Frontiers

Carrier Competition
Southwest
Frontier
$0.00
-$5.00
-$10.00
-$15.00
-$20.00
-$21.99
-$25.00
88%
-$30.00
-$35.00
-$40.00
-$41.46
-$45.00
-$50.00
Exhibit WN-R-802
Southwest at FLL is Ten Times Larger than Frontier at MIA to U.S. Points

10,000
70
9,318
30
28
62.3
9,000
60
25
8,000
848%
7,000
6,000
50
949%
367%
20
40
15
5,000
30
4,000
10
3,000
20
6
2,000
983
10
5.9
1,000
WN-FLL
F9-MIA

WN-FLL
F9-MIA
WN-FLL
F9-MIA
Exhibit WN-R-803
ORD
ORD
ORD
ORD
ORD
LGA
LGA
LGA
LGA
LGA
LGA
PHL
PHL
PHL
PHL
PHL
ATL
ATL
ATL
ATL
MIA
MIA
HAV
HAV


Source: Frontier Application, Exhibit C.
Exhibit WN-R-804


(6 Daily RTs)
MKE
MKE
MKE
MKE
MKE
MDW
MDW
MDW
MCI
MCI
MCI
MCI
MCI
MCI
DEN
DEN
DEN
DEN
DEN
DEN
STL
STL
STL
STL
STL
BUF
BUF
BUF
BUF
BUF
BUF
ALB
ALB
ALB
ALB
ALB
BDL
BDL
BDL
BDL
BDL
PVD
PVD
PVD
PVD
PIT
PIT
PIT
PHL
PHL
PHL
CMH
CMH
PHL
CMH
ISP
CMH
CMH
IND
IND
IND
ISP
ISP
ISP
IND
IND
IND
BWI
BWI
BWI
BWI
DCA
DCA
DCA
DCA
DCA
DCA
BNA
BNA
BNA
BNA
BNA
LAS
LAS
LAS
LAS
LAS
PHX
PHX
PHX
PHX
PHX
Frontiers Proposed MIA-HAV

(2 Daily RTs)
ORD
ORD
ORD
ORD
ORD
LGA
LGA
LGA
LGA
LGA
PHL
PHL
PHL
PHL
RDU
RDU
RDU
RDU
RDU
RDU
ATL
ATL
ATL
ATL
ATL
ATL
ATL
ATL
ATL
ATL
DAL
DAL
DAL
DAL
DAL
DAL
MSY
MSY
MSY
MSY
MSY
AUS
AUS
AUS
AUS
AUS
HOU
HOU
HOU
HOU
HOU
HOU
TPA
TPA
TPA
TPA
TPA
FLL
FLL
MIA
MIA
HAV
HAV
HAV
HAV
SJU
SJU
SJU
SJU
SJU


Source: Southwest Application, Exhibit WN-102 and Frontier Application, Exhibit C.

Since Starting Service to MIA in December 2014,

Frontier Has Already Begun to Reduce Capacity
Weekly Departures
45
8,000
42
7,056
40
7,000
-17%
-14%
35
6,080
35
6,000
30
5,000
25
4,000
20
3,000
15
2,000
10
1,000
July 2015
July 2016
July 2015
July 2016
Exhibit WN-R-805
Exhibit WN-R-806

Population Dwarfs that of Denver
1,200,000
1,061,180
1,000,000
800,000
600,000
400,000
200,000
4,439
0
Denver
Metro Area/1
Exhibit WN-R-807
FLL is a Much More Convenient Gateway for Cuban Americans than DEN
2,000,000
1,860,990
1,800,000
1,600,000
1,400,000
1,200,000
1,000,000
800,000
600,000
400,000
159,408
200,000
0
FLL
DEN
Gateway
Exhibit WN-R-808

Frontiers DEN-HAV Proposal Connects to Just 7 U.S. Points
SEA
SEA
SEA
SEA
SEA
SEA
PDX
PDX
PDX
PDX
PDX
MSP
MSP
MSP
MSP
MSP
MSP
MSN
MSN
MSN
MSN
MSN
CID
CID
CID
CID
CID
SLC
SLC
SLC
SLC
SLC
DSM
DSM
DSM
DSM
DSM
DEN
DEN
SFO
SFO
SFO
SFO
SFO
LAS
LAS
LAS
LAS
LAS
LAS
SNA
SNA
SNA
SNA
SNA
SAN
SAN
SAN
SAN
SAT
SAT
SAT
SAT
SAT
SAT
AUS
AUS
AUS
AUS
AUS
AUS
IAH
IAH
IAH
HAV
HAV


Source: Frontier Application, Exhibit C.
Exhibit WN-R-809
Frontier Has Abandoned 13 International Stations in the Last 10 Years

Period Served
Q1 05
Q1 06
Q1 07
MZT
PVR
SJD
ZIH
ACA
CZM
YYC
GDL
YVR
SJO
LIR
MBJ
HUX
Q1 08
Q1 09
Q1 10
Q1 11
Q1 12
Q1 13
Q1 14
Q1 15
Q1 16
Q1 17
Exhibit WN-R-810
Frontier Has Abandoned 73 Domestic Stations

in the Last 10 Years and Re-Entered 8
Period Served
Q1 05
Q1 06
Q1 07
Q1 08
Q1 09
Q1 10
Q1 11
Q1 12
Q1 13
Q1 14
Q1 15
Q1 16
ABQ
ANC
BIL
BOI
BWI
ELP
GEG
LIT
MDW
MSY
OKC
RNO
RSW
SJC
SMF
TUS
CAK
SAT
TUL
DAY
FAT
BDL
JAX
MEM
SDF
BTR
ICT
RAP
SUX
ASE
COS
DRO
FAR
GJT
JAC
HDN
BKG
FAI
GRB
GRR
LGB
PHF
SBA
ATW
BOS
CMH
EWR
FNT
HOU
PIE
PIT
RDU
IWD
MBL
PVU
RHI
PSP
RFD
ABE
BLI
BMI
GTF
MDT
AZA
COU
MOT
SBN
SHD
EUG
ILG
LAN
BFL
IDA
No Longer Served
Exited and Reentered
Exhibit WN-R-811
Since 2005, Frontier has Abandoned Nearly 60%

of the 134 Airports it Has Served
Airports Currently
Served
= 42% (56)
Florida = 1,331,893
Source: Innovata schedule data, 2005 2016.
Airports
Abandoned
= 58% (78)
Exhibit WN-R-812
Frontier has Exited 283 Routes Since 2005

ABE-MCO
ABQ-DEN
ABQ-PVR
ACA-DEN
ANC-DEN
ASE-DEN
ATL-IAD
ATL-ILG
ATL-MCO
ATL-MSP
ATL-MSY
ATL-ORD
ATL-PHL
ATW-MKE
AUS-BKG
AUS-CUN
AUS-MCI
AZA-DEN
BDL-DEN
BDL-MKE
BFL-DEN
BIL-DEN
BKG-DEN
BKG-MKE
BKG-PHX
BLI-DEN
BMI-DEN
BMI-MCO
BNA-CUN
BNA-MKE
BNA-TTN
BOI-DEN
BOS-DEN
BOS-MCI
BOS-MKE
BTR-DEN
BWI-DEN
BWI-PUJ
CAK-DEN
CLE-DFW
CLE-FLL
CLE-IAD
CLE-LGA
CLE-MKE
CLE-ORD
CLE-PUJ
CLE-TTN
CLT-IAD
CMH-MCI
CMH-MKE
CMH-TTN
COS-DEN
COS-LAX
COS-MCO
COS-PDX
COS-SAN
COS-SEA
COS-TUL
COU-MCO
CUN-CVG
CUN-IAD
CUN-IND
CUN-LAN
CUN-MCI
CUN-MKE
CUN-PIT
CUN-RFD
CUN-SAN
CUN-SLC
CVG-FLL
Florida = 1,331,893
CVG-IAD
CVG-PUJ
CVG-TTN
CZM-DEN
DAY-DEN
DAY-MKE
DCA-GRR
DCA-MCI
DCA-MKE
DCA-MSN
DCA-OMA
DCA-PHL
DEN-DRO
DEN-ELP
DEN-EUG
DEN-FAI
DEN-FAR
DEN-FAT
DEN-FLL
DEN-GDL
DEN-GEG
DEN-GJT
DEN-GRB
DEN-GRR
DEN-GTF
DEN-HDN
DEN-HOU
DEN-ICT
DEN-IDA
DEN-ILG
DEN-JAC
DEN-JAX
DEN-LGB
DEN-LIR
DEN-LIT
DEN-MBJ
DEN-MDT
DEN-MDW
DEN-MOT
DEN-MZT
DEN-OKC
DEN-PBI
DEN-PHF
DEN-PSP
DEN-PUJ
DEN-PVR
DEN-PVU
DEN-RAP
DEN-RFD
DEN-RIW
DEN-RNO
DEN-RSW
DEN-SBA
DEN-SBN
DEN-SDF
DEN-SJC
DEN-SJD
DEN-SJO
DEN-SMF
DEN-SUX
DEN-TUL
DEN-TUS
DEN-YVR
DEN-YYC
DEN-ZIH
DFW-LAX
DFW-MEM
DFW-MZT
DSM-MCO
DSM-MKE
DSM-STL
DSM-TPA
DTW-IAD
DTW-ILG
DTW-LGA
DTW-PHL
DTW-RSW
DTW-STL
EWR-MKE
FLL-IAD
FLL-IAH
FLL-MCI
FLL-MCO
FLL-MEM
FLL-MKE
FLL-STL
FNT-MKE
GRB-MKE
GRR-MKE
GSO-MCO
HOU-MCI
HUX-ORD
HUX-STL
IAD-LAS
IAD-LAX
IAD-MEM
IAD-MIA
IAD-MSP
IAD-PBI
IAD-RSW
IAD-SAT
IAD-STL
IAD-TPA
IAD-UST
IAH-ILG
Note: A route is categorized as exited if it does not have service in the third and fourth quarters of 2016.
Source: Innovata schedule data, 2005 2016.
IAH-MCO
IAH-MSY
IAH-PHL
IAH-PHX
ILG-MCO
ILG-MDW
ILG-RSW
ILG-TPA
IND-MDW
IND-MKE
IND-RSW
IND-TTN
IWD-RHI
LAN-PVR
LAS-MCI
LAS-MEM
LAS-RNO
LAS-SNA
LAX-MCI
LAX-MKE
LAX-OMA
LAX-PHL
LAX-SAN
LAX-SFO
LAX-SJD
LGA-MCI
LGA-MKE
LIR-ORD
LIR-STL
MBJ-MKE
MBJ-ORD
MBJ-PHL
MBJ-RFD
MBJ-STL
MBL-MKE
MCI-MKE
MCI-MSP
MCI-MSY
MCI-OKC
MCI-PVR
MCI-RSW
MCI-SAT
MCI-SEA
MCI-SFO
MCI-SJD
MCI-STL
MCI-TPA
MCO-MDT
MCO-MEM
MCO-MSN
MCO-OKC
MCO-OMA
MCO-SHD
MCO-TYS
MDT-MDW
MDW-TTN
MDW-TYS
MKE-MSN
MKE-MSP
MKE-OMA
MKE-PHX
MKE-PIE
MKE-PIT
MKE-PUJ
MKE-PVR
MKE-RDU
MKE-RHI
MKE-RSW
MKE-SAN
MKE-SAT
MKE-SDF
MKE-SEA
MKE-SFO
MKE-STL
MKE-TPA
MKE-TTN
MKE-TUS
MSP-PHL
MSP-TTN
MSY-TTN
OKC-TPA
OMA-PIE
OMA-SAN
OMA-TPA
ORD-PVR
ORD-RSW
ORD-SJD
ORD-TPA
PBI-TTN
PDX-SEA
PDX-STL
PHL-RSW
PIT-PUJ
PUJ-RFD
PUJ-STL
PVR-RFD
PVR-SJC
PVR-SMF
PVR-STL
RSW-STL
SFO-SLC
SFO-STL
SJC-SJD
SJD-SMF
SJD-STL
STL-TPA
STL-TTN
TTN-UST
Domestic
International
Exhibit WN-R-813
Southwest Has One of Lowest Complaint Levels in the Industry,

Frontier Has One of the Highest
Enplanements,
Southwest
Frontier
18.0
15.8
16.0
14.4
14.0
12.0
10.0
8.7
8.6
8.7
8.2
7.5
7.5
8.0
6.5
6.0
5.1
3.7
4.0
3.1
2.0
0.6
0.5
0.5
0.4
0.4
0.7
0.7
0.6
0.5
0.5
0.3
0.5
0.0
January
February
March
April
May
June
2015
Source: U.S. DOT Air Travel Consumer Report.
July
August
September
October
November December
Rebuttal to Alaska
Exhibit WN-R-901
Alaskas Average Domestic Fare Levels Are 23% Higher than Southwests
$250
$225
$199.35
$200
$175
+23%
$162.01
$150
$125
$100
$75
$50
$25
$0
Southwest
Alaska
Exhibit WN-R-902
Alaskas Domestic Unit Costs Are 9% Higher than Southwests

14.0
12.5
12.0
11.5
+9%
10.0
8.0
6.0
4.0
2.0
0.0
Southwest
Alaska
Exhibit WN-R-903

Alaskas LAX-HAV Proposal Connects to Just 3 U.S. Points
ANC
ANC
ANC
ANC
ANC
SEA
SEA
SEA
SEA
PDX
PDX
PDX
SLC
SLC
SLC
LAX
LAX
HAV
HAV


Source: Alaska Application, Exhibit 5.
Exhibit WN-R-904

Population Dwarfs that of Los Angeles
1,200,000
1,061,180
1,000,000
800,000
600,000
400,000
200,000
63,288
0
Los Angeles
Metro Area/1
Exhibit WN-R-905
FLL is a Much More Convenient Gateway for Cuban Americans than LAX
2,000,000
1,860,990
1,800,000
1,600,000
1,400,000
1,200,000
1,000,000
800,000
600,000
400,000
200,000
132,437
FLL
LAX
Gateway
Rebuttal to Silver Airways
Exhibit WN-R-1001
Southwest Would Carry 94,000 More Passengers and Provide

105,000 More Seats per Frequency than Silver
140,000
127,750
120,000
108,587
100,000
Additional Annual
Seats per
Frequency = 105,057
80,000
Additional Annual
Passengers per
Frequency = 93,847
60,000
40,000
22,693
20,000
14,740
0
Southwest 737-800
Frequency /1

Silver Saab 340
Frequency /2

2/ From Silver Application, Exhibit 3M-13. Annual Seats/ 5 proposed flight (113,463/5).
4/ From Silver Application, Exhibit 3M-13, Annual Passengers / 5 proposed flights (73,698/5).
Source: Carrier Applications.
Annual Passengers per

Forecast Annual Silver
Daily Southwest 737-800 Passengers per Daily Saab
Frequency /3
340 Frequency /4
Exhibit WN-R-1002
Every Frequency Awarded to Silver for HAV

Service Would Lose 94,000 Passengers
Cuba Passengers Lost Per Frequency Award to Silver Instead of Southwest
No. of Silver Frequencies
0
-50,000
-100,000
-93,847
-150,000
-200,000
-187,694
-250,000
-300,000
-281,541
-350,000
-400,000
-375,388
-450,000
-469,235
-500,000
Source: WN Application, Appendix 1, page 7 and Silver Application, Exhibit 3M-13.

Answer of Southwest Airlines Co (Cuba)

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Answer of Southwest Airlines Co (Cuba)

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BEFORE THE

U.S. DEPARTMENT OF TRANSPORTATION

CONSOLIDATED ANSWER OF SOUTHWEST AIRLINES CO.

Communications with respect to this

March 14, 2016

Southwests Proposal is Justified by Empirical Analysis as well as its

The Majority of Havana Frequencies Should be Allocated to South Florida

American Airlines Service Proposal Fails to Maximize Consumer Benefits

Frontiers Service Proposal Is Unsupported by the Evidence and Undermined by

CONSOLIDATED ANSWER OF SOUTHWEST AIRLINES CO.

Southwests Proposal is Justified by Empirical Analysis as well as its

DOT Order 2016-2-12 at 2.

The Majority of Havana Frequencies Should be Allocated to South Florida

Residents of Cuban-American Origin

% of U.S. Residents of Cuban-American Origin within

See Exhibits WN-R-102 through R-106.

Sixty-three percent (63%) of FLLs seat-departures are

FLL Has 50% More Domestic O&D in Markets With

Terminal plus airfield charges.

Southwest has analyzed what the fare differential is likely to be between

Americans Average MIA Fares are Significantly Higher than Southwests

At FLL-HAV Distance of 255 Miles the One-Way

AA MIA Fare Curve

WN FLL Fare Curve

Southwest also analyzed fares in the FLL/MIASJU 11 markets to determine likely

Average FLL-SJU Fares Are 25%

(All U.S. Airlines)

(All U.S. Airlines)

baggage/cancellation and passenger usage fees (Spirit) actually incurred by

San Juan, Puerto Rico.

Source: Exhibit WN-R-210.

Southwest Savings vs.

As the Department knows, airport choice is much more complicated than a

American Airlines Service Proposal Fails to Maximize Consumer Benefits

Avg. One-Way Fare Including Avg.

Average Domestic FLL/MIA Fare at HAV Distance

Estimated FLL/MIA-HAV Average Fare

American Fares Without

American Fares with

Fare Change with

Trip Length (One-Way Nonstop Miles)

In any event, Americans historical (and current) level of MIAHAV charter

Within 35% mileage circuity.

See Exhibit WN-R-306 and R-307.

Southwest Competition Reduces Fares an Average

Avg. One-Way Fare Including Avg. Baggage and

In the FLL SJU market, a predominantly leisure market with considerable

Average Southwest and JetBlue Fares in SJU Markets

Avg. One-Way Fare Including Avg. Baggage and

Southwests Has More Convenient Connections at FLL than JetBlue

Average Daily Seat-Departures

Due to its significantly larger operation, Southwests TPA-HAV service would

Southwests TPA Convenient Connections Compared to JetBlues

Average Daily Seat-Departures

Southwest Has Significantly More Convenient Connections at MCO than JetBlue

When comparing the two applications side-by-side, a totality of factors including

In conclusion, Southwests FloridaHavana proposals will provide greater public

Annual Seats Per Daily

Annual Spirit Passengers

Fare Impact of Low Cost

Southwests U.S. Service Compared to Spirit (NK) at FLL

Average Daily Seat-Departures

public (emphasis added). 26 It is therefore of decisional significance that Spirit has a

In contrast, as the chart below shows, Southwests