July 23, 2014

...**,~** p) ,;.:_i'i The Honorable Anthony Foxx Secretary ofTransportation U.S. DepartmentofTransportation 1200 NewJerseyAve., S.E. Washington D.C. 20590 

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Subject: Petition ofMacon-Bibb CountyforWaiverfrom the 10-EnplanementStatute, 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 thatthe decline in enplanement is temporary. We respectively request your consideration to exercise your authority and grant a waiver for continuance of Essential Air Service tothe MiddleGeorgia Region. ·

Douglas M Faour Airport Manager Middle Georgia Regional Airport

Middle Georgia RegionalAirport• Macon DowntownAltport•TBI AirportManagementInc. 1000Terminal Drive •Suite 100*Macon, Georgia31216 • (478) 803·0456Petition of Macon-BibbCountyforWaiverfromthe 10Enplanement Statute,
Docket DOT-OST-2007-28671 Title 49 CFR Part 5.11 (b) Filing of Petitions allows any person to petitionthe 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proposed, or of the rule from which the exemption is sought, or specify the rule that the petitioner seeks to have repealed, as the case may be.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 requirementsare metin 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 meetthe 10 enplanement per service day is due to atemporary decline in enplanements. This documentwill describe the series ofevents which led tothe 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 passengerenplanementsgreatlyexceededthe requirement of 10 passengers perservice day. In fact, there were years when nearly 100,000 passengers enplaned aircraft atthe Middle Georgia Regional Airport (MCN). Passenger enplanements at MCN remained respectable after deregulation and lessthan 10years ago, MCN recorded over34,000 annual enplanements. PacificWings 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 checktheirbags and undergoTSA screening process forthe second time in orderto catch their connecting flight. The traveling public found this process unreasonable and thus pursued alternate means ofenteringthe NationalAirspace System. Nearly one year after launching service from MCN, Georgia Skies was granted access tothe 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 infigure 

### 1. On June 21, 2010 Georgia Skies submitted a proposal to continue subsidized Essential Air Service in Macon. However, they withdrew the 

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--- 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



### 2the unsubsidized period, flights were cancelled on a regular basis and passenger enplanements continued a downward spiral. Georgia Skies ceased operations at Middle Georgia Regional Airporton March 31, 2013 and were replaced bySilverAirways.
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 twomonths 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 enplanementsfor CY13 increased for the firsttime in nearly 10 years. Silver Airways was a welcomed change at first, but it was not long before theirservice deteriorated.

FY2013 (Eligibility Period) 0 Figure 2

• Georgia Skies 

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# 11111.I • SilverAirways

On June 24, 2014the MiddleGeorgia Regional Airport received the Final OrderTerminating EAS Eligibility. The order cited that Macon is no longer an eligible community under the EAS program as it failed to meetthe 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 oftime forwhich 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 passengerservice.



### 3Figure 3 

# Georgia Skies Flight Cancellations FV2013 100 T

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... • 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 thatthere were 68 days that Georgia Skies did not fly at all. Our records do not specify why each flight was cancelled; however, forapproximatelythree 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 circumstancesforany EAS community regardless oflocation ordemographics. Even though MCN experienced a 170% increase in enplanements duringthe second halfofFY13 after Silver Airways arrived, it was not enough to meet requirements. Near the end ofthe 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 offlights. This resulted in a significant loss in enplanements as pa_ssengers were leavingthe airportforshuttle buses toATL Rebuilding commercial air service after it has been nearly decimated takes time and Silver Airways made itextremelydifficultby cancellingflightsand not maintaining'theirschedule. 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 airservice, which is extremelytime consuming and not efficient. RAFB personnel frequentlyvoice theirdispleasure withthe current system and are hopefulthat theairport returntoservice levels similartothose of2008. In addition to poor on-time performance, Silver Airways does not offer a schedule to meet passenger needs. Ifthe flight is on time and not cancelled, Silvers' dailyflight 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 tryto avoid



### 4connection layovers in excess oftwo hours, only 10% ofATL dailyflights remain for this period oftime. The chart below (Figure 4) depictsthe numberand times ofdailydeparturesfrom 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 tothe airtransportation system. This is the most significant reason enplanements are not higher. Passengers have no option but to drive toATL, tocatch aflightthat is compatiblewiththeirtravel needs.

Figure 4 

## ATL Daily Departures

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

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

::' 60**+---------~.-~--~· -i·-.·~--~--~--~.---~--------** **~**

40

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20

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## •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



### 5TemporaryEnplanement 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



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. ten years, we found the Middle Georgia Regional Airport obtained more enplanements than anyofthecommunities recentlydeclared "no longereligible"toparticipate 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 aself-funded "True MarketStudy"from Sixel ConsultingGroup. The studydated

100000 90000 80000 70000 60000 50000 40000 30000 20000 10000 0 

## FAA 10Year EnplanementTotals

• FAA 10YearEnplanementTotals 

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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 ofexceptional enplanements, it is clearthat the community's failure toaverage ten passengers perservice day is no faultofits own.Yetthe decline can be linked to the airlines inability to provide adequate service, and a reasonable schedule to make necessaryconnections.



### 6Clearly 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**.....:~**

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## ? 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 tothe evidence of aviable passenger base. Figure 7

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### 7Economic 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 programstop priority for Macon and improving MCN is essential tothe 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 ofthe 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 ofthe largest economic engines in the region, but itfalls short ofselfsufficiency. 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 healthyfor long term operational stability and atransportation needs must be addressed in order resolve its issues. The immediate impact ofdiscontinuance of EAS will result in the loss of numerousjobs 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 toovercome. Requested Action In April 2014, Silver Airways submitted a 90-day notice to U.S. Department ofTransportation (U.S. DOT) in which their desire to discontinue scheduled service between ATL and almost all EAS communities in theirATL system. The only EAS communitythey did not request to vacate was MCN, primarily due to its use as a maintenance bridge between theirWashington 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 ofthis acquisition, Silver Airways has expressed toairport managementthatthey intendtovacate 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 afterOctober 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 SilverAirways, ifEAS is available tothem.Therefore, ifthese requests are granted and a quality carrier is selected, the temporary decline in enplanements will end. Ifthis occurs we have great confidence that MCN wilt then exceed the required amount of enplanements and healthyairservice will return tothe MiddleGeorgia Region.



### Conclusion The Middle Georgia Regional Airport has a long historyofsuccessful passenger service, yetwas 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 overthe past decade. To summarize, the loss ofthisprogram would be devastatingtothe Middle Georgia Region and thuswe mustdiligently strivetoembracethe EAS program and help maintain the livelihood ofthose individualsdirectly affected. Please, strongly considerourappeal to uphold the EAS program at MCN as it is crucial tothesustainabilityofthe airportand revitalization ofourcommunity.

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