Spirit’s Confusing Request for a DCA Slot Pair

Spirit Airlines has decided to join American, Alaska, and Southwest in announcing their intentions of requesting one of the five new, perimeter exempt slot pairs at Washington D.C.’s Reagan National Airport (DCA). The Florida based ultra-low-cost carrier (ULCC) is proposing service to between DCA and San José Mineta International Airport (SJC).

a yellow airplane on a tarmac
Spirit has requested a slot pair to fly between Washington D.C. and San José

Like American’s joint request with the City of San Antonio, Spirit has partnered with the airport in requesting this service. Mookie Patel, Director of Aviation at SJC, had this to say about the proposed service:

We’re excited to partner with Spirit to secure highly demanded, nonstop service between SJC and DCA. DCA is a uniquely well-positioned gateway to both the center of federal decision-making in Washington and the booming tech center in the surrounding region. Together with SJC’s unmatched reliability and convenience for Silicon Valley – and Spirit’s low fares – this proposed service will provide travelers between two important markets with an exceptional customer experience end-to-end.”

Mookie Patel, SJC Director of Aviation

The announcement states that this proposed service would “introduce low-fare competition and create the only nonstop service between Silicon Valley and Washington, D.C”. This seems a tad disingenuous as Alaska and American both serve nearby San Francisco International Airport (SFO) from DCA.

Can Spirit Legally Obtain a Slot Pair?

One of the most confusing things about this request is the fact that Spirit likely can’t obtain one of the five new perimeter exemptions authorized as part of the FAA Reauthorization Act. The law outlines that of the five available exemptions, four must be awarded to “incumbent” airlines while one will be awarded to a “limited incumbent”.

If you really enjoy reading long government documents, you can find the full 1,069 page bill here. View from the Wing has a great breakdown and summary of the rule if you’re interested. Otherwise, I have pulled out the relevant definitions below (from Page 426).

Non-Limited IncumbentsOf the slot exemptions made available under paragraph (1), the Secretary shall make 8 available to incumbent air carriers qualifying for status as a non-limited incumbent carrier at Ronald Reagan Washington National Airport as of the date of enactment of the FAA Reauthorization Act of 2024.
Limited IncumbentsOf the slot exemptions made available under paragraph (1), the Secretary shall make 2 available to incumbent air carriers qualifying for status as a limited incumbent carrier at Ronald Reagan Washington National Airport as of the date of enactment of the FAA Reauthorization Act of 2024.
H. R. 3935

The five non-limited incumbents as identified in the law are American, Delta, JetBlue, Southwest, and United. The only limited incumbent that should be eligible is Alaska so one would think they can all but guarantee their request.

However, this is where things get interesting. While Spirit doesn’t currently serve DCA, they are still classified as a limited incumbent due to the fact they have served the airport in the past and therefore held slots.

It is Unlikely Spirit Will Be Granted Slots

With only one perimeter exemption slot pair being made available to limited incumbents, it isn’t likely that Spirit will be granted the pair. The airline is going head to head with Alaska which is requesting a slot pair to operate between DCA and San Diego International Airport (SAN).

Alaska Airlines Boeing 787-9 MAX
Alaska Airlines is also pursuing expanded service at Reagan National.

San Diego is currently the largest market without nonstop service to Reagan National Airport. The city is also home to Naval Base San Diego, the world’s second largest surface ship naval base and home to the United States Pacific Fleet. The addition of this route would likely make many service members and constituents very happy.

Up the California coast in San José, there is a large tech presence which Mayor Matt Mahan championed in the Spirit announcement. He stated;

“In today’s digital age, there is perhaps no place more important for our national leaders to access than the capital of Silicon Valley. San José is home to the experts and entrepreneurs at the forefront of AI, data privacy and CHIPs Act implementation who are writing the code for the future and establishing best practices to navigate that future.”

Matt Mahan, Mayor of San José

However, the Bay Area, and by default Silicon Valley, is well connected to Washington D.C. United operates hubs in both San Francisco and Washington’s Dulles International Airport (IAD). In addition, Alaska and United both use existing perimeter exemptions to fly between SFO and DCA.

United Airbus A320 at San Francisco International Airport
Silicon Valley and the Bay Area are already well connected to the D.C. area

Because of these factors, I believe it is highly likely that Alaska will obtain the available perimeter exemption pair over Spirit. Alaska’s request appears to better meet demand and unlock a previously unserved market.

Summary

Spirit shocked a lot of people, myself included, when they announced a request for perimeter exemption slots. While it will be up to lawmakers to determine if Spirit is even eligible for a slot pair, I find it highly unlikely that they can beat out Alaska’s bid.

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