OST-98-2771 / Reno Air / Answer of American / High Density Rule - Chicago O'Hare / January 19, 1999

 

Applications of

RENO AIR, INC. / Docket 49743 and OST-97-2771

for an exemption from 14 CFR Part 93, Subparts K and S, pursuant to Section 206(c)(1) of the Federal Aviation Administration Authorization Act of 1994

(Reno-Chicago O'Hare slots)

 

ANSWER OF AMERICAN AIRLINES, INC. TO MOTION

OF UNITED AIR LINES, INC. TO REOPEN THE RECORD

 

American Airlines, Inc. opposes the motion submitted on January 7, 1999 by United Air Lines, Inc. which seeks to withdraw Chicago O'Hare exemption slots that the Department awarded to Reno Air, Inc. by Order 94-9-30, September 20, 1994 and Order 97-10-16, October 24, 1997, for the benefit of the City of Reno, Nevada.

American, which through a subsidiary has a controlling interest in Reno Air, has assured the City of Reno and other Nevada interests, including the Nevada Congressional delegation and the Governor of Nevada, that American and/or Reno Air will operate three daily roundtrips between Chicago O'Hare and Reno, using five of the seven exemption slots that

 

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the Department awarded for such service. /1 A letter from the Nevada Congressional delegation, reflecting American's commitment, is attached.

United's effort to destroy the City of Reno's critically important service link to O'Hare is simply one more episode in United's unrelenting campaign to maintain and advance its slot advantage at O'Hare. The compelling needs of the City of Reno and other Nevada interests for continued nonstop access to the Chicago hub should not be sacrificed to United's agenda for continued slot dominance at O'Hare.

While United asserts that American does not qualify as a "new entrant" at O'Hare, that is not relevant to the situation presented here. Reno Air was clearly a "new entrant" at the time of the Reno-O' Hare slot exemption awards in 1994 and 1997, and has long provided nonstop service in the Chicago-Reno market which American is now committed to continuing, using five of the seven exemption slots that the Department awarded for such service. Moreover, United's allegations about slot holdings of affiliated carriers ring particularly hollow in light of the shell games that United plays with United Express exemption slots. See, e.g., Order 98-10-28, October 30, 1998, transferring 10 O'Hare exemption slots from one

1/ One of the operations at O'Hare is outside slot controlled hours.

 

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United Express carrier (Great Lakes Aviation) to another (Atlantic Coast Airlines) for service in the Sioux Falls-O'Hare and Fargo-O'Hare markets.

As noted above, Reno Air presently holds seven O'Hare exemption slots, but only five are required for the Chicago-Reno nonstop service pattern that American is committed to continuing. In these circumstances, the Department should consider reassigning the two dormant slots for service from O'Hare to another city, such as Greenville/Spartanburg, South Carolina, for which American Eagle has an application pending in OST-98-4647.

For the foregoing reasons, the Department should deny United's motion which, if granted, would end nonstop service between Reno and Chicago O'Hare.

 

Respectfully submitted,

CARL B. NELSON, JR.

Associate General Counsel

American Airlines, Inc.

January 19, 1999