Frontier Airlines
has filed a motion for leave to file and supplement its objection to order to show cause, which was the United States Department of Transportation’s (DOT) order of granting five slot pairs to five airlines at one of the airports serving Washington, DC.
Additional objections
In a filing on November 26, Frontier Airlines asked the DOT to supplement its objection to the DOT’s order that assigned five slot pairs, or ten in total, at Ronald Reagan Washington National Airport
(DCA) to 
Alaska Airlines
, 
American Airlines
, 
Delta Air Lines
, 
Southwest Airlines
, and 
United Airlines
in October.
Photo: Vincenzo Pace | Simple Flying
Frontier Airlines pointed out that according to the DOT, its application did not specify the type of aircraft or start date for its flights from Washington-National to San Juan Luis Munoz Marin International Airport (SJU).
“However, the DOT’s tentative determination relating to Frontier did not rely upon this point. Frontier now requests leave to submit that information, even though this supplemental information is not relevant to the DOT’s determination of Frontier’s eligibility for a slot exemption.”
Providing background about its latest filing, the carrier said that it only operates the Airbus A320
family aircraft, including the A320neo and A321neo
.
Its initial application for two slots – landing and departure – included the merits of the proposed route from Washington-National to San Juan, Puerto Rico, and the fact that its application “best satisfied the policy considerations” for the operating conditions at Washington-National.
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Objecting to other airline’s applications
In addition, Frontier Airlines said that it was the only “incumbent air carrier […] qualifying for status as a limited incumbent carrier at Ronald Reagan Washington National Airport” when the FAA Reauthorization Act 2024 went into effect in May.
The airline argued that while the DOT dismissed its application due to issues related to the planned aircraft type and schedule, there were similar issues with United Airlines’ application, which the DOT overlooked.
“In the Notice, the DOT explained that carriers’ applications “should” (not “shall”) include, among other things, the aircraft type, a schedule showing proposed times, and an approximate start-up date.”
Photo: Andrew Mauro | Shutterstock
As a result, since the information on timings was irrelevant to the DOT’s determination – since airlines assigned the slots will be assigned by the Department following its final decision – good cause existed for the DOT to consider Frontier Airlines’ supplemental information.
This would remove any doubt about the incompleteness of its application. Frontier Airlines emphasized that it still remains the only incumbent airline that could be considered a limited incumbent carrier at the airport.
The carrier added that the DOT has recognized that status on multiple occasions. Thus, “any initial omission of proposed information could not foreclose Frontier’s Application.”
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Services from Washington-National to San Juan
As Frontier Airlines presented it, out of an abundance of caution, it has informed the DOT that it plans to fly from Washington-National to San Juan using an A320 with either 180 or 186 seats.
Ch-aviation data showed that the low-cost carrier’s A320ceos are configured to welcome 180 travelers, while the A320neos have 186 seats onboard. However, Frontier Airlines only has eight A320ceo aircraft remaining in its fleet.
Photo: The Toidi | Shutterstock
The airline would begin services on the route on March 6, 2025, with its aircraft arriving at Washington-National from San Juan at 16:30 local time (UTC -5) and departing on the return itinerary at 17:30.
“For the reasons stated above, Frontier respectfully requests the DOT grant leave to file information requested in the Notice and provided herein.”
In late October, Frontier Airlines, JetBlue, and Spirit Airlines expressed their objections to the DOT’s granting the ten slots to the five aforementioned carriers.
In its objection on October 30, Frontier Airlines first threw a stone out of its glass house at Spirit Airlines, which also did not receive any slots at Washington-National, saying that its fellow low-cost carrier was not an incumbent carrier at the airport on May 16, or the date when Joe Biden, the president of the US, signed the FAA Reauthorization Act 2024.
Photo: Ceri Breeze | Shutterstock
However, when it came to objecting to Alaska Airlines’ eligibility to receive slots at the airport, both airlines agreed that the carrier was not a limited incumbent airline.
Their argument was underpinned by the fact that American Airlines, which had 358 slots at Washington-National, and Alaska Airlines have a codeshare agreement, resulting in the two airlines combining for 376 slots at the airport.
“Alaska placing its code on even a small portion of American’s flights operated from DCA would give it via code sharing greater access to DCA than Frontier has with its limited number of slots.”
In a response filed on November 12, Alaska Airlines quoted the DOT, which concluded that the latter carrier does not display American Airlines’ flight code on itineraries it operates at Washington-National as it was legally bound not to due to the merger settlement agreement it reached when it merged with Virgin America in 2017.
Related
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