CONTINUATION of CERTAIN ) Docket DOT-OST-2020-0037 AIR SERVICE ) ) Under Public Law 116-136 §§ 4005 ) and 4114(B) ) ______)

BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

______) CONTINUATION OF CERTAIN ) Docket DOT-OST-2020-0037 AIR SERVICE ) ) Under Public Law 116-136 §§ 4005 ) and 4114(b) ) ______)

SPIRIT AIRLINES, INC. SUPPLEMENTAL REQUEST FOR EXEMPTION FROM SERVICE OBLIGATION ______

Communications with respect to this document should be sent to:

Joanne W. Young David M. Kirstein Kirstein & Young, PLLC 1750 K Street, N.W. Suite 700 Washington, D.C. 20006 (202) 331-3348 (telephone) [email protected] [email protected] July 17, 2020 Attorneys for Spirit Airlines, Inc.

BEFORE THE DEPARTMENT OF TRANSPORTATION WASHINGTON, D.C.

______) CONTINUATION OF CERTAIN ) Docket DOT-OST-2020-0037 AIR SERVICE ) ) Under Public Law 116-136 §§ 4005 ) and 4114(b) ) ______)

SPIRIT AIRLINES, INC. SUPPLEMENTAL REQUEST FOR EXEMPTION FROM SERVICE OBLIGATION ______

Spirit Airlines requests an exemption from continuing service for Latrobe, Pennsylvania

(LBE) from September 8 to September 30, 2020 due to the planned closure of LBE’s sole runway for construction. Because of this runway closure Spirit will be physically unable to provide service at LBE during this period.

The Westmoreland County Airport Authority (which operates LBE) began discussing its runway construction plans with Spirit, which is LBE’s sole carrier, over a year ago. Using FAA grant money, LBE is widening its runway from 100 to 150 feet to accommodate larger aircraft and possibly attract additional service. Work began several months ago on the runway widening at night between Spirit’s flights. Closure of LBE’s runway is required for this phase of the construction project, which is planned for September 8-25, 2020 (see Exhibit 1, “ARPA Runway

6-24 Widening and Strengthening Project Notification of Scheduled Runway Closure,” dated

February 27, 2020). Until recently, Spirit anticipated its reduced schedule would mitigate this closure, but Spirit has continued to operate at LBE and now requires an exemption. Docket OST-2020-0037 Supplemental Exemption Request of Spirit Airlines

Spirit, with the airport authority’s support, requests an exemption from September 8-30,

2020 to avoid disrupting passenger travel plans and operations if the work is not completed on time (see Exhibit 2, letter from the Westmoreland County Airport Authority in support of Spirit’s exemption request). Any delay in construction beyond September 30 will not require an exemption as the CARES Act requirement for service obligation exemptions expires on September 30, 2020.

Because LBE is located approximately one hour driving time from Pittsburgh International Airport

(PIT), passengers will have an alternative for air travel during the runway closure.

For the foregoing reasons, Spirit respectfully requests an exemption from continuing service obligation for Latrobe, Pennsylvania from September 8-30, 2020.

Respectfully submitted,

Joanne W. Young David M. Kirstein Kirstein & Young, PLLC 1750 K Street, N.W., Suite 700 Washington, D.C. 20006 (202) 331-3348 (telephone) [email protected] [email protected]

Attorneys for Spirit Airlines, Inc.

Exhibit 1

Exhibit 2 Westmoreland County Airport Authority 148 Aviation Lane, Suite 103 • Latrobe, PA 15650 (P) 724.539.8100 (F) 724.539.2441

06/17/2020

Letter of Support for Spirit Airlines to suspend service form LBE from Sept. 8, 2020 thru Sept. 30, 2020

Westmoreland County Airport Authority is writing this correspondence in support of Spirit Airline's request to suspend operations from Sept 8, 2020 until Sept 30, 2020 at the Arnold Palmer Regional Airport (LBE). The Airport Authority is finishing a runway widening project as part of a 13.2 million dollar Runway widening project FAA-3-42-0050-056-2019 (Main Project Grant). This project has been in development for several years and last year the Authority was able to acquire the Federal AIP funding to complete this critical safety project. Your consideration is requested in exempting Spirit Airlines in accordance with the CARES act funding rules. This exemption will allow us to finish this phase of the runway project. Questions concerning these actions may be directed to me and the above number, or by Email: [email protected] . Thank You for your consideration.

Gabriel E. Monzo Executive Director Westmoreland County Airport Authority (LBE)

Arnold Palmer Regional Airport Rostraver Airport CERTIFICATE OF SERVICE

I hereby certify that on July 17, 2020 I caused to be served by email a copy of the foregoing Request for Exemption on the following persons

______J. Michael Woods