July 23, 2014 ... ,~ p) 

,;.:_i'i 

The Honorable Anthony Foxx 

Secretary of Transportation 

U.S. Department of Transportation 

1200 New Jersey Ave., S.E. 

Washington D.C. 20590 

.!! .: i ~ ·~ '! mcrt 

middle georgia regional Airport 

= Lj 

Subject: Petition of Macon-Bibb County for Waiver from the 10-Enplanement Statute, 

Docket DOT-OST-2007-28671 

Macon-Bibb County, Middle Georgia Regional Airport 

Dear Mr. Foxx, 

Included with this letter is Macon-Bibb County's petition, which serves as a formal request for exemption 

from 49 U.S.C. § 41731 (a) (1) (8). The information contained in this document is evidence of viable 

commercial passenger service and that the decline in enplanement is temporary. We respectively request 

your consideration to exercise your authority and grant a waiver for continuance of Essential Air Service 

to the Middle Georgia Region. · 

Douglas M Faour 

Airport Manager 

Middle Georgia Regional Airport 

Middle Georgia Regional Airport • Macon Downtown Altport • TBI Airport Management Inc. 

1000 Terminal Drive • Suite 100* Macon, Georgia 31216 • (478) 803·0456 
Petition of Macon-Bibb County for Waiver from the 10 Enplanement Statute, 

Docket DOT-OST-2007-28671 

Title 49 CFR Part 5.11 (b) Filing of Petitions allows any person to petition the Secretary to issue, 

amend, or repeal a rule, or for a permanent or temporary exemption from any rule. 

Furthermore, 49 CFR Part 5.11 requires that each petition filed must set forth the text or 

substance of the rule or amendment proposed, or of the rule from which the exemption is 

sought, or specify the rule that the petitioner seeks to have repealed, as the case may be. 

These requirements are met in the following paragraph. 

This petition serves as a formal request, on behalf of Macon-Bibb County and the Middle 

Georgia Regional Airport, for exemption from 49 U.S.C. § 41731 (a)(1)(B) which requires an 

average of 10 enplanements per service day or more, as determined by the Secretary, during 

the most recent fiscal year beginning after September 30, 2012 to remain eligible to receive 

Essential Air Service. We request that the Secretary exercise the authority provided under 49 

U.S.C. § 41731(e) and grant a waiver from the aforementioned requirement as our failure to 

meet the 10 enplanement per service day is due to a temporary decline in enplanements. This 

document will describe the series of events which led to the enplanement decline and why it is 

temporary. 
Background 

The Middle Georgia Region has accessed commercial air service from MCN for over 60 years. 

Specific data regarding passenger enplanements for the entire period of time is not in our 

possession, but we do have data that dates back nearly 40 years. These records indicate that 

passenger enplanements greatly exceeded the requirement of 10 passengers per service day. In 

fact, there were years when nearly 100,000 passengers enplaned aircraft at the Middle Georgia 

Regional Airport (MCN). Passenger enplanements at MCN remained respectable after 

deregulation and less than 10 years ago, MCN recorded over 34,000 annual enplanements. 

Pacific Wings d.b.a. Georgia Skies 2008-2013 

The Middle Georgia Regional Airport experienced an extraordinary change in commercial air 

service near the end of 2008. Atlantic Southeast Airlines {ASA), a long-term carrier at MCN, 

terminated service and Pacific Wings (d.b.a. Georgia Skies) began subsidized ·essential Air 

Service. Initially they operated from FBO-to-FBO and not terminal:..to-terminal as passengers 

expected. Georgia Skies' deplaned passengers at the FBO in ATL where they collected their 

luggage and were required to take a shuttle to the commercial terminal. They were then 

required to check their bags and undergo TSA screening process for the second time in order to 

catch their connecting flight. The traveling public found this process unreasonable and thus 

pursued alternate means of entering the National Airspace System. 

Nearly one year after launching service from MCN, Georgia Skies was granted access to the ATL 

terminal facilities and began operating terminal-to-terminal, as well as improving their 

agreements with other airlines. This allowed passengers to deplane at the ATL terminal and 

avoid checking bags and security screening there. However, at this point, the public's 

confidence in Georgia Skies was damaged and passenger enplanements continued to fall as 

demonstrated in figure 1. 

On June 21, 2010 Georgia Skies submitted a 

proposal to continue subsidized Essential Air 

Service in Macon. However, they withdrew the 4o,ooo ---

proposal in December of the same year and 35,000 

Figure 1 

Enplanements 

offered to provide unsubsidized service. The 

DOT accepted their offer to operate 

unsubsidized and they were awarded the 

Macon EAS Contract. Georgia Skies continued 

operating from MCN for ~pproximately 17 

months before submitting a 90 Day 

Termination Notice on April 26, 2012. During 

30,000 

25,000 

20,000 

15,000 

10,000 

_._Enplanements 

5,000 

0 

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the unsubsidized period, flights were cancelled on a regular basis and passenger enplanements 

continued a downward spiral. Georgia Skies ceased operations at Middle Georgia Regional 

Airport on March 31, 2013 and were replaced by Silver Airways. 

Positive signs that passengers were willing to return 

to MCN were observed immediately upon Silver 

Airways' arrival. Figure 2 reveals increased passenger 

enplanements upon their arrival and continued to 

grow for the first few months. Just two months after 

250 

200 

150 

launching service, passenger enplanements reached a 100 

level not seen since 2009. In May 2013, so 

enplanements nearly doubled the numbers from May 

2012 and annual enplanements for CY13 increased for 

the first time in nearly 10 years. Silver Airways was a 

welcomed change at first, but it was not long before 

their service deteriorated. 

FY2013 (Eligibility Period) 

0 

Figure 2 

• Georgia Skies 

I 

11111. I • Silver Airways 

On June 24, 2014 the Middle Georgia Regional Airport received the Final Order Terminating EAS 

Eligibility. The order cited that Macon is no longer an eligible community under the EAS 

program as it failed to meet the statutory requirements set forth in 49 U.S.C. § 41731 (a)(1)(B). 

This rule defines the period of time to average 10 enplanements per service day October 1, 

2012 -September 30, 2013 (FY13). As mentioned above, commercial air service was provided 

at MCN for over 60 years. The period of time for which is used to assess the airport's eligibility 

captures a very small part of the airport's history and happens to be the most dismal era in 

regard to passenger service. 

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Figure 3 

Georgia Skies Flight 

Cancellations FV2013 

100 T ___ __.;. ___ _ 

·~ 1 •.•.•. 1.1 ... 

• Georgia Skies 

Flight 

Cancellations 

FY2013 

Figure 2 displays how MCN was served by 

Georgia Skies for the first six months and 

Silver Airways for the second half of FY2013. 

Very few passengers were choosing to fly 

Georgia Skies at the beginning of FY13. In 

addition, many potential passenger 

enplanements were lost during the first six 

months of the FY13 as a result of Georgia 

Skies flight cancellations (See Figure 3). Our 

records indicate approximately 300 flights 

were cancelled from October 2012 to March 2013. We also noted that there were 68 days that 

Georgia Skies did not fly at all. Our records do not specify why each flight was cancelled; 

however, for approximately three consecutive weeks Georgia Skies did_not fly at all. They cited 

mechanical issues with their aircraft as -the reason. As one may expect, meeting the 

requirements of 49 U.S.C. § 41731 (a)(1)(B) would be nearly impossible under these 

circumstances for any EAS community regardless of location or demographics. 

Even though MCN experienced a 170% increase in enplanements during the second half of FY13 

after Silver Airways arrived, it was not enough to meet requirements. Near the end of the six 

month grading period, Silver stated they were being ·negatively impacted by a shortage of 

pilots, which was causing them to delay or cancel a large number of flights. This resulted in a 

significant loss in enplanements as pa_ssengers were leaving the airport for shuttle buses to ATL 

Rebuilding commercial air service after it has been nearly decimated takes time and Silver 

Airways made it extremely difficult by cancelling flights and not maintaining 'their schedule. 

Robins Air Force Base (RAFB) is a major logistics center, located less than three miles away, 

which employs nearly 25,000 civilian and military personnel who are mobile in nature. 

Unfortunately, they cannot utilize MCN because Silver Airways is not Department of Defense 

Certificated. Military personnel and government contractors are forced to drive to other 

airports to access commerCial air service, which is extremely time consuming and not efficient. 

RAFB personnel frequently voice their displeasure with the current system and are hopeful that 

the airport return to service levels similar to those of 2008. 

In addition to poor on-time performance, Silver Airways does not offer a schedule to meet 

passenger needs. If the flight is on time and not cancelled, Silvers' daily flight to ATL does not 

leave MCN until 11:45 a.m. Therefore, there are minimal flights available for Middle Georgia 

passengers, as they cannot connect until1 p.m. or later. Since passengers typically try to avoid 

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connection layovers in excess of two hours, only 10% of ATL daily flights remain for this period 

of time. The chart below (Figure 4) depicts the number and times of daily departures from ATL. 

Approximately 40% of All's daily outbound flights have already departed by the time MCN 

passengers arrive. Therefore, the schedule that Silver Airways offers Middle Georgia 

passengers does not provide adequate access to the air transportation system. This is the most 

significant reason enplanements are not higher. Passengers have no option but to drive to ATL, 

to catch a flight that is compatible with their travel needs. 

Figure 4 

ATL Daily 

Departures 

120 .-~------------------------------------------------

100 +-------------~------------~=---------------------

::' 

60 +---------~.-~--~· -i·-.·~--~--~--~.---~--------

~ 

40 +----------~---~--------

20 +---------~---~--------

•oooo- o6oo 

•0600- 0700 

•0700- 0800 

•0800-0900 

•0900-1000 

•1000-1100 

•1100 -1200 

r•1200 1300 

-1300-1400 

•1400 1500 

•1500-1600 

•1600-1700 

•1700 -1800 

•1800-1900 

•1900- 2000 

• 2000-2100 

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Temporary Enplanement Decline 

Again, the Middle Georgia Regional Airport has a long history of obtaining a respectable 

number of enplanements. In fact, when analyzing the FAA enplanement history over the last - . 

ten years, we found the Middle Georgia Regional Airport obtained more enplanements than 

any of the communities recently declared "no longer eligible" to participate in the EAS program. 

As mentioned earlier, the decline in enplanements increased significantly when Georgia Skies 

began service. In an effort to fairly assess the decline in enplanements, Macon-Bibb County 

ordered a self-funded "True Market Study" from Sixel Consulting Group. The study dated 

100000 

90000 

80000 

70000 

60000 

50000 

40000 

30000 

20000 

10000 

0 

FAA 10 Year Enplanement Totals 

• FAA 10 Year Enplanement Totals 

• I • 

I I I I 

June 2014 revealed there are 1,167,491 total airline passengers per year that originate from 

MCN's catchment area and are leaked to other airports. The study also revealed there's a 

strong potential for hundreds more daily passengers that could utilize services offered at MCN. 

Therefore, by considering the airport's long history of exceptional enplanements, it is clear that 

the community's failure to average ten passengers per service day is no fault of its own. Yet the 

decline can be linked to the airlines inability to provide adequate service, and a reasonable 

schedule to make necessary connections. 

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Clearly the MCN catchment area has the passengers to support commercial air service. The 

airport's catchment area is comprised of 19 counties containing approximately 631,272 

MCN has a long 

history of exceeding 

requirements set 

forth in 49 U.S.C. § 

41731(e) and 

enplanements are 

below the minimum 

requirement, but only 

for a relatively short 

period of time as the 

Middle Georgia 

Region has a large 

market that is not 

being served and is 

too good not to 

attract a quality 

carrier. 

Figure 6 

.....:~ ... '·-~-"' '~"" 

? 

residents (See Figure 6). As 

mentioned above, this area 

generates over 1.1 million 

originating passengers per 

year. Figure 7 shows that 

545,956 passengers originated 

from the cities of Macon and 

Warner Robins, GA, which are 

both less than 30 minutes 

from the airport. This data was 

shared with industry leaders 

who agree that a quality 

carrier will likely be attracted 

to MCN due to the evidence of 

a viable passenger base. 

Figure 7 

-, 

'' \ 

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Economic Impact 

Macon was recently one of seven distressed cities selected to be a part of the Strong Cities, 

Strong Communities (SC2), an initiative launched by the White House. This program was 

designed to strengthen local capacity, coordinate federal investments, and spark growth in 

economically suffering communities. Transportation was identified as the programs top priority 

for Macon and improving MCN is essential to the City's revitalization. 

Losing Essential Air Service will severely impact the airport and set back the aforementioned 

program that was identified to aid in the city's resurgence. Signs of the airport's and the City's 

recovery are very evident. However, terminating Macon's eligibility to participate in the EAS 

progr'am will halt progress and render the community's most recent revitalization efforts in 

vain. 

The airport serves as one of the largest economic engines in the region, but it falls short of selfsufficiency. Unlike recent years, the airport does not generate enough revenue to cover its 

expenses and requires funding from the city's general fund. The airport's current economic 

condition is not healthy for long term operational stability and a transportation needs must be 

addressed in order resolve its issues. 

The immediate impact of discontinuance of EAS will result in the loss of numerous jobs ranging 

from airline employees to law enforcement. In addition, the airport will lose over $100,000 in 

revenues which will further devastate its current financial condition. Numerous businesses 

located at the airport will also be adversely effected and result into long-term hardships that 

will be nearly impossible to overcome. 

Requested Action 

In April 2014, Silver Airways submitted a 90-day notice to U.S. Department of Transportation 

(U.S. DOT) in which their desire to discontinue scheduled service between ATL and almost all 

EAS communities in their ATL system. The only EAS community they did not request to vacate 

was MCN, primarily due to its use as a maintenance bridge between their Washington D.C. and 

Orlando networks. However, Silver Airways will soon open a maintenance facility in DuBois, PA 

and will no longer need to utilize MCN as a bridge. In lieu of this acquisition, Silver Airways has 

expressed to airport management that they intend to vacate MCN promptly. 

In addition to requesting the aforementioned waiver, the County of Macon-Bibb has two 

additional requests. First, we ask that the U.S. DOT temporarily suspend EAS service at MCN 

effective no later than September 30, 2014. Due to Silver Airways' clear intention to vacate 

MCN, ties should be severed soon to prevent unnecessary expenses and to clear the way for a 

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new airline. Secondly, we request the U.S. DOT issue an RFP seeking a new carrier to provide 

subsidized EAS at MCN after October 1, 2014. 

Airport management utilized our recent True Market Study to demonstrate MCN's pr~mising 

potential for commercial air service from to a number of reputable airlines. Conversations with 

these airlines have led us to believe the likelihood that MCN will attract a quality carrier, to 

replace Silver Airways, if EAS is available to them. Therefore, if these requests are granted and a 

quality carrier is selected, the temporary decline in enplanements will end. If this occurs we 

have great confidence that MCN wilt then exceed the required amount of enplanements and 

healthy air service will return to the Middle Georgia Region. 

Conclusion 

The Middle Georgia Regional Airport has a long history of successful passenger service, yet was 

essentially destroyed when air carriers did not provide our citizens with viable options. Our 

recent True Market Study concluded that passengers still exist and the need for access to the 

national air transportation system remains strong. Much improvement has occurred over the 

past calendar year; therefore, discontinuance of the program would bring about greater 

devastation than all combined problems endured over the past decade. To summarize, the loss 

of this program would be devastating to the Middle Georgia Region and thus we must diligently 

strive to embrace the EAS program and help maintain the livelihood of those individuals directly 

affected. Please, strongly consider our appeal to uphold the EAS program at MCN as it is crucial 

to the sustainability of the airport and revitalization of our community. 

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