While Wi-Fi on most U.S. airlines will remain off below 10,000 feet because of Gogo’s limitations, Southwest could gain a competitive advantage and have its Row44 Wi-Fi operational throughout most of the flight.

Row44, which provides service to Southwest, uses satellite-based Wi-Fi that is capable of working on the ground.

Southwest is “optimistic” that once it gets FAA approval then its Wi-Fi would be available for passengers below 10,000 feet, says spokesperson Brandy King.

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“There is still work to be done as we prepare and test but we are optimistic that our customers will be able to use the service below 10,000 feet,” King says.

Southwest, which is running a promotion for free access to DISH programming and use of iPad 2s from three airports, has yet to file a plan with the FAA on the new rules for portable electronic devices, but plans to do so as quickly as possible, the airline says.

Most of the U.S. airline industry uses Gogo’s air-to-ground-based Wi-Fi, which currently only works at 10,000 feet and above.

United is transitioning to satellite-based Wi-Fi on international flights and JetBlue is expected to start installing satellite-based Wi-Fi within a few weeks so these two airlines could potentially join Southwest with Wi-Fi capabilities beneath 10,000 feet.

Meanwhile, JetBlue and Delta report this morning that they are still awaiting feedback from the FAA on the plans for portable electronic devices and haven’t yet implemented new procedures.

Photo Credit: DISH is running a promotion for free access to its programming on Southwest flights, and its handing out iPad 2s at three airports, as well. Southwest Airlines