Mr. Brandon M Belford Deputy Assistant Secretary for Aviation and International Affairs U.S. Department ofTransportation 1200NewJersey Ave., S. E. Washington, DC 20590 RE: DOT-OST-1996 1899 Orderto Show Cause Proposing Termination ofEssential Air Service (EfidS) Dear Mr. Belford: r····....::· Please accept this letter as anobjection to the tentative decisionthat the Department of Transportationproposes to terminate the subsidy eligibility ofKingmanunder the EAS Program. The City ofKingman is in complete agreement with the Kingman Airport Authority, Inc. letter ofDecember 10,2014 that identified numerous issues that have affected Kingman, Arizona's passenger countbeing a direct result, and the unanticipated consequences, related to Regulatory orCongressional Mandates ofthe DOT/Federal Aviation Administration:

• Effective August 1, 2013 Congress and the FAAmandatedthatall co-pilots of an airline have a minimum of 1500 hours total time hold and Airline Transport Pilot Certificate. In complying withthis mandate, Great Lakes Airlines lost a number ofco-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% ofscheduled flights) canceled flights. To meet schedules, Great Lakes Airlines had to remove 10 ofthe 19 seats in the Beech 1900'sthat 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 perday to fill. Itis impossible to meet 1 0 enplanements per day when less than4 seats are available.

# l Mr. Brandon M. Belford DOT-OST-1996-1899, Orderto ShowCause 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 expectthese communities will work with their EAS carriers to address any issues that contributed to their FY 2013 decline in enplanements." The City ofKingman supports the Kingman Airport Authority, Inc objection:

• Passenger enplanements cannot reach 1 0 per day when less than 4 seats per day are available. • Passengerconfidence in local airline service will notbe achieved when 25% ofthe flights are cancelled due to federal mandates. • Itis difficult to produce FY 2015 enplanementnumbers ifthe 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 communityhas 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 Orderto Show Cause to Terminate the EAS Subsidy April 30, 2015 when only 60 days prior there was an Order Granting Waiverextending the data collectionperiod until September 30, 2015. This ever-growing cloud ofuncertainty ofthe availability ofair service adversely influences customerchoices and participation. As a growing community with a significant industrial and manufacturing base located onthe Kingman Regional Airport, local air service will become an increasing priority. I urge youto reconsider any potential termination ofservice by helping workthrough conflicting and diametric policies that seemto result in only unintended consequences for struggling economies. Ifyou have any questions regarding the City ofKingman position, orifyou require additional information, please contact myself, or John Dougherty, Kingman City Manager, at 928-753-8101.

# ~7~ Richard E Anderson Mayor, City ofKingman Cc: Gary Watson, Mohave County Supervisor District#1 David French, Executive Director, Kingman Airport Authority, Inc.