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 

. :~·. r 1 L .. 

Lancaster Airport Authority 

500 Airport Road • Suite G 

Lititz, PA 1 7543-9340 

Phone: (717) 569-1221 

Fax: (717) 569-1952 

Assistant Secretary for Aviation & International Affairs 

United States Department of Transportation 

Dear Ms. Kurland, 

Please accept this 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, in recent years Lancaster Airport has suffered from a 

series of setbacks which have negatively impacted our passenger traffic and, 

most recently, resulted in LNS falling below the regulatory enplanement limits 

for continued Essential Air Service eligibility. I write you today to formally 

request that the Secretary grant a Waiver to our community such that we can 

continue rebuilding efforts and maintain this critical element of our local 

economic infrastructure. 

Lancaster Airport is presently covered under a special provision that allows its 

continued eligibility for EAS until September 30, 2015. This legislation was 

passed several years ago with a primary objective of providing assistance to 

allow our community to generate self-sustaining, non-subsidized commercial air 

service. We believe LNS has a plan of action, and the right resources available 

to it, in order to effect the goal of self-sustainability. The key to achieving this is 

allowing the current Essential Air Service award to maintain program eligibility 

through its original termination date. Lancaster Airport's objective is to retain 

commercial air service through a mix of destinations that provides the greatest 

likelihood of enabling long term, subsidy-free operations. 

Historically, LNS has received intermittent air service and experienced multiple 

changes in airlines serving the community. Each time service was cancelled and 

then restarted, the market has experienced a decline in passengers, followed by a 

period of recovery, only to incur another round of service cessation. 

"Take the EASY w out!n 

FLY LANCASTER AIRPORT 
A snapshot of the enplanement history for the past 10 years provides ample 

evidence of this: 

2004: No service until the last 4 months of year, when PIT flying began. 

2005: Enp1anements grew to 16 per day with service to PIT for 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. 

20 II: Enp1anements grew another 17%. reaching a I 0 year high. 

2012: Sun Air took over flying to IAD. New destination, new airline again reduced 

enplanements. 

Sun Air was, 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 began to ramp up to full operation in early 2013, the Federal Sequester 

severely constrained its' ability to operate, due primarily to a lack of available 

FAA resources to administer pilot check rides (thus resulting in a shortage of 

pilots) as well as a significant delay in approval of important winter operations 

procedures. The combination of these two items resulted in only partial 

schedules being operated, and had a major negative impact on passenger 

enplanements. It will 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 in reliability. This provides the 

foundation for our efforts going forward. We now need to ensure that LNS' air 

service is on the proper path to long-term self-sufficiency. To that end, we 

request the Department: 

1 ). Grant Lancaster a waiver from the minimum enplanement 

requirements for sustaining eligibility, acknowledging the clearly temporary 

nature of our decline; and 

2) Allow our existing airline to substitute flights to PIT and lAD, as 

opposed to lAD only, which we believe is the better avenue to achieve long 

term, unsubsidized service. Sun Air is willing to provide service to PIT at the 

same subsidy levels provided for lAD, in spite of the materially longer flight 

lengths. 

Our region of Eastern Pennsylvania sorely needs more convenient and 

affordable access to Western Pennsylvania. We have many business ties to that 

area, however the 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 positioned to remedy this 

problem, and this strong market need forms the backbone of our long term 

sustainability plan. 

Sun Air plans to work closely with our community to rebuild our passenger 

traffic, and is prepared to begin comprehensive marketing efforts to achieve that 

goal. We ask for an expedited review of our request so that we can resolve the 

market uncertainties we face and concentrate on implementing our long term 
viability plans. Sun Air shares our confidence that passenger volumes will be 

restored to prior levels, and in our discussions, has indicated a willingness to 

commit to target dates for achieving compliance with the daily enplanement 

requirements, as well as limiting any subsidy requests to levels that remain 

within the $200 per-passenger cap. These commitments should resolve 

concerns the Department may have about our ability to maintain eligibility in the 

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 of the Lancaster Airport Authority, or the Lancaster County 

communities' desire to use commercial air service. 

We hereby request the Department of Transportation temporarily waive the tenenplanement provision in order to permit the Lancaster Airport an opportunity to 

demonstrate its ability to increase its daily passenger loads. 

I look forward to the opportunity to expound on the details of our temporary 

decline in enplanements and how we propose to increase passenger loads in the 

future. 

cc: Dennis DeVany 

Kevin Schlemmer 

Albert Muldoon 

446637.2