Mr. Brandon M Belford 

Deputy Assistant Secretary for Aviation and International Affairs 

U.S. Department of Transportation 

1200 New Jersey Ave., S. E. 

Washington, DC 20590 

RE: DOT-OST-1996 1899 

Order to Show Cause Proposing Termination of Essential Air Service (EfidS) 

Dear Mr. Belford: r···· .... ::· 

Please accept this letter as an objection to the tentative decision that the Department of 

Transportation proposes to terminate the subsidy eligibility of Kingman under the EAS 

Program. 

The City of Kingman is in complete agreement with the Kingman Airport Authority, Inc. 

letter of December 10,2014 that identified numerous issues that have affected Kingman, 

Arizona's passenger count being a direct result, and the unanticipated consequences, 

related to Regulatory or Congressional Mandates of the DOT/Federal Aviation 

Administration: 

• Effective August 1, 2013 Congress and the FAA mandated that all co-pilots of 

an airline have a minimum of 1500 hours total time hold and Airline 

Transport Pilot Certificate. 

In complying with this mandate, Great Lakes Airlines lost a number of co-pilots who 

lacked the 1500 hours, while also losing captains to larger legacy airlines. These impacts 

resulted in significant cancellations throughout the system due to "no crew." For 

Kingman, this amounted to 302 (25% of scheduled flights) canceled flights. 

To meet schedules, Great Lakes Airlines had to remove 1 0 of the 19 seats in the Beech 

1900's that serve Kingman in order to allow lower time pilot/co-pilot crews to fly under 

the 10 seat rules. This made planes available for service, but at a reduced passenger 

capacity. Since the route structure including Kingman also includes the community of 

Page, with Page averaging more than 6 seat fill daily to both Denver and Los Angeles 

over the past 12 months, Kingman has been left with less than 4 seats per day to fill. It is 

impossible to meet 1 0 enplanements per day when less than 4 seats are available. 
l 

Mr. Brandon M. Belford 

DOT -OST -1996-1899, Order to Show Cause 

December 14, 2014 

Page 2 

Order 2014-9-21, September 26, 2014 stated: "We wish to make it clear that the statute 

requires that communities exceed 10 enplanements per day during each fiscal year. 

Although these communities received a temporary waiver from this requirement, their 

traffic will be reassessed based on Fiscal Year (FY) 2015 data. We expect these 

communities will work with their EAS carriers to address any issues that contributed to 

their FY 2013 decline in enplanements." 

The City of Kingman supports the Kingman Airport Authority, Inc objection: 

• Passenger enplanements cannot reach 1 0 per day when less than 4 seats per 

day are available. 

• Passenger confidence in local airline service will not be achieved when 25% 

of the flights are cancelled due to federal mandates. 

• It is difficult to produce FY 2015 enplanement numbers if the EAS Program is 

terminated in Kingman April 2015. 

• The Kingman Airport Authority, Inc. continues to work with Great Lakes 

Airlines addressing issues contributing their decline in enplanements. Issues 

however, are primarily federal in which the community has limited input. 

• As a community, it is extremely difficult to implement correction efforts when 

the U.S. DOT, the Program Manager, issues in November an Order to Show 

Cause to Terminate the EAS Subsidy April 30, 2015 when only 60 days prior 

there was an Order Granting Waiver extending the data collection period until 

September 30, 2015. 

This ever-growing cloud of uncertainty of the availability of air service adversely 

influences customer choices and participation. As a growing community with a 

significant industrial and manufacturing base located on the Kingman Regional Airport, 

local air service will become an increasing priority. I urge you to reconsider any 

potential termination of service by helping work through conflicting and diametric 

policies that seem to result in only unintended consequences for struggling economies. 

If you have any questions regarding the City of Kingman position, or if you require 

additional information, please contact myself, or John Dougherty, Kingman City 

Manager, at 928-753-8101. 

~7~ Richard E Anderson 

Mayor, City of Kingman 

Cc: Gary Watson, Mohave County Supervisor District #1 

David French, Executive Director, Kingman Airport Authority, Inc.