Chairman Marvin E. Miller, Jr. Vice Chairman Russell S. Howell
Treasurer Valerie Moul Secretary James J. Cunningham
Asst. Secretary & Asst. Treasurer G. Matthew Brown Airport Director David F. Eberly, Jr. Finance Administrator Cheryl L. Martin Facilities Administrator Austin J. Beiler Alliance Aviation Manager Mary G. Stauffer May 14,2014

Ms. Susan L. Kurland 

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### Lancaster Airport Authority 500 Airport Road • Suite G Lititz, PA 17543-9340 Phone: (717) 569-1221 Fax: (717) 569-1952

Assistant Secretary for Aviation & International Affairs United States Department ofTransportation

Dear Ms. Kurland, Please acceptthis letter as the Lancaster Airport Authority's formal response to the Department ofTransportation's Tentative Order Regarding Termination of EAS Eligibility: 2014-4-26 regarding eligibility for thirteen (13) EAS airports across the United States, including Lancaster, Pennsylvania.
As you are likely aware, inrecent years Lancaster Airport has suffered from a series ofsetbacks whichhave negatively impacted ourpassenger traffic and, most recently, resulted in LNS falling belowthe regulatory enplanement limits for continued Essential Air Service eligibility. I write you today to formally request that the Secretary grant a Waiverto our community such that we can continue rebuilding efforts and maintainthis critical element ofour local economic infrastructure.
Lancaster Airport is presently coveredunder a special provisionthat allows its continued eligibility for EAS until September 30, 2015. This legislation was passed several years ago with a primary objective ofproviding assistance to allow our communityto generate self-sustaining, non-subsidized commercial air service. We believe LNS has a plan ofaction, andthe right resources available to it, in order to effectthe goal ofself-sustainability. The keyto achieving this is allowing the currentEssential Air Service award to maintainprogram eligibility through its original termination date. LancasterAirport's objective is to retain commercial air service through a mix ofdestinations that provides the greatest likelihood ofenabling long term, subsidy-free operations. Historically, LNS has received intermittent air service and experienced multiple changes inairlines serving the community. Each time service was cancelled and thenrestarted, the market has experienced a decline inpassengers, followed by a period ofrecovery, onlyto incur another round ofservice cessation.



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## out!n FLY LANCASTER AIRPORTA snapshot ofthe enplanement history for the past 10 years provides ample evidence ofthis: 2004: No service until the last 4 months ofyear, when PIT flying began. 2005: Enp1anements grew to 16 per day with service to PITfor all12 months. 2006: Stabilitv with PIT service enabled the market to reach 21 enplanements per day. 2007: Service terminated. 2008: No commercial air service provided. 2009: Service re-instated mid-year, this time to BWI. 2010: Enp1anements grew by more than 50% from the prior year. 20II: Enp1anements grew another 17%. reaching a I0 year high. 2012: Sun Air took over flying to IAD. New destination, new airline again reduced enplanements. Sun Airwas, for all intents and purposes, a start-up when it began serving LNS. The company ran into difficulties arranging full crew and aircraft complements. As it beganto ramp up to full operation in early 2013, the Federal Sequester severely constrained its' ability to operate, due primarily to a lack ofavailable FAA resources to administerpilot check rides (thus resulting in a shortage of pilots) as well as a significant delay in approval ofimportant winter operations procedures. The combination ofthese two items resulted in onlypartial schedules being operated, and had a major negative impact onpassenger enplanements. Itwill take time to recover from the Sequester's effects. Since late 2013, Sun Air has brought in new senior management, and there has been a marked and consistent improvement inreliability. This provides the foundation for our efforts going forward. We now need to ensure that LNS' air service is on the properpathto long-term self-sufficiency. To that end, we request the Department: 1 ). Grant Lancaster a waiverfrom the minimum enplanement requirements for sustaining eligibility, acknowledging the clearly temporary nature ofour decline; and 2) Allow our existing airline to substitute flights to PIT and lAD, as opposed to lAD only, which we believe is the betteravenue to achieve long term, unsubsidized service. SunAir is willing to provide service to PIT at the same subsidy levels provided for lAD, in spite ofthe materially longer flight lengths.
Ourregion ofEastern Pennsylvania sorelyneeds more convenient and affordable access to WesternPennsylvania. We have manybusiness ties to that area, howeverthe drive to PHL, the closest service option, is lengthy and arduous. Once there, prices are relatively expensive, making business travel for our community exceedingly difficult. LNS is well positionedto remedythis problem, and this strong market need forms thebackbone ofour long term sustainabilityplan.
SunAirplans to work closely with our community to rebuild ourpassenger traffic, and is prepared to begin comprehensive marketing efforts to achieve that goal. We ask for an expedited review ofour request so that we canresolve the market uncertainties we face and concentrate on implementing our long termviabilityplans. Sun Air shares our confidence that passenger volumes will be restored to prior levels, and in our discussions, has indicated a willingness to committo target dates for achieving compliance with the daily enplanement requirements, as well as limiting any subsidyrequests to levels thatremain withinthe $200 per-passenger cap. These commitments should resolve concernsthe Department mayhave about our ability to maintain eligibility inthe future.
We are not disputing the DOT's calculations concerning our enplanement numbers for fiscal year 2013. This temporary decline in enplanements was due to the contractor's flight completion and serviceability, and not due to any action or inaction ofthe Lancaster Airport Authority, orthe Lancaster County communities' desire to use commercial air service.
Weherebyrequest the Department ofTransportation temporarily waive the tenenplanementprovision in order to permitthe LancasterAirport an opportunity to demonstrate its ability to increase its daily passenger loads.
I look forward to the opportunity to expound onthe details ofourtemporary decline in enplanements and howwe propose to increase passenger loads inthe future.

cc: Dennis DeVany Kevin Schlemmer Albert Muldoon

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