Air Choice One 12300 oia Tesson Road 

Suite 200-F 

St. Louis, Missouri 63128 

Piione: 314-843-8501 

March 21, 2012 

Mr. Dennis DeVany 

Chief, Essential Air Service Program r~:; 

Office of Aviation Analysis ^~ ^ X; 

Department of Transportation ;]f Ij'-:^S 

1200 New Jersey Avenue, SE rsj -xjQ^t 

Washington, D.C. 20590 -^ §§ 3 

By email and filing in Docket DOT-OST-2009-0300 -^ p::^-' ^ 

fsJ CO 

I 

Dear Mr. DeVany: 

This letter responds to the letter that you received fi-om the City of Alpena, Michigan, dated March 

15,2012.' 

Air Choice One recognizes the importance the City places on finding a satisfactory replacement for 

Delta's scheduled air service. We have developed proposals for replacement service that will meet 

Alpena's needs and allow air services to thrive and promote the community economically. As you 

know, we have shown our ability to improve service and increase traffic, which is why the 

communities we serve enthusiastically support us. 

We are committed to continue to work with the City of Alpena and wish to set the record straight on 

two points. First, our proposed Option 4 - a service operating between Alpena and Chicago O'Hare 

International Airport three times a day using twin-engine equipment ~ exceeds the minimum 

requirements of basic essential air service. Second, Air Choice One has recently had its contract 

renewed for Burlington and Decatur, a one-year renewal with an uiducement of three years to follow 

if we implement an electronic ticketing agreement with a major carrier. The community's mistaken 

understanding of this lure as "probation" is wrong. 

1. Our Option 4 exceeds the minimum requirements for basic essential air service under 

current law. 

The City contends that our proposed option 4 does not meet the minimum EAS service definition. 

This is incorrect. The law guarantees a community air service to a hub airport with 12 round trips a 

week, using twin-engine aircreift.^ Our proposal would give Alpena our highly reliable, markettested 18 roimd trips per week with twin-engine aircraft to Chicago O'Hare Intemational Airport, 

one of the world's busiest airports, with thousands of connecting opportunities. 

Maximum Payload. The City questions whether our proposed equipment, the Piper Navajo, can 

carry more than four passengers with the fiiel required to travel from Alpena to Chicago on days 

with less than perfect conditions. We can assure the Department and the City that the Navajo can 

carry seven passengers, their bags, and all necessary fiael on such days. 

To the extent necessary. Air Choice One seeks leave to file this otherwise unauthorized response. 

See, Order 2012-1-6 at p. 4 n. 6. 

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Air Choice One has a highly skilled team of flight operation and maintenance experts who bring a 

combined resource of more than 60 years service to the industry. In preparing our Alpena 

proposal, we performed all the required calculations, using conservative performance estimates. 

Based on our experience in operating the Navajo, we expect to carry seven passengers between 

Alpena and Chicago O'Hare at standard airline weights with fiilly loaded aircraft. Our 

calculations assume that, in addition to seven passengers, we will carry 250 lbs. of passenger 

baggage. And, consistent with Federal Aviation Regulations and our FAA-approved manuals, we 

assumed that the Navajo would carry at least all/ 2 hour fiiel reserve with a fully loaded aircraft 

upon reaching Chicago O'Hare to ensure that it could reach an approved alternate airport on a day 

with less than perfect conditions. 

Scheduled Flight Times. The City suggests that our scheduled flight time is unrealistic. We 

operate a reliable, on-time professional service. In preparing a bid, we use a reasonable average 

flight time, based on our assessment of the flight times throughout the year. We consider the 

effect of weather and other factors. Published schedules for other cities with different stage 

lengths and traffic patterns cannot be used to evaluate a "Representative Schedule," since 

published schedules reflect day-to-day experience in the actual operating conditions. 

2. The Department has just offered us the lure of a 3-year renewal if we can implement an 

electronic interline ticketing agreement with a major carrier. We are not on "probation" and 

there is no threat to withdraw the award at the end of the year. 

The City contends that we are "on probation," citing the Department's decision to give Air Choice 

One an additional one-year contract for Burlington and Decatur. The Department's award said 

nothing of the kind. Instead, it recognized the critical importance of electronic interline agreements 

to reducing program costs and increasing efficiency and challenged us to continue our work toward 

that goal. Air Choice One shares that goal and has been working very hard to meet it. 

The Department did not threaten to revoke Air Choice One's authority, as the City's statement 

implies. Instead, it held out, as a carrot, the inducement of a further extension of three years if we 

can reach agreement with a major carrier. Department Order 2011-12-17 does not foreclose any 

option, including renewal. 

Indeed, the Department has long been aware that established carriers can block new entrant 

competition by refusing to interline with them - even in markets abandoned by major carriers. This 

has imposed costs on the EAS program, both by limiting valuable flow traffic and discouraging 

participation. As the Department recognized in its 1999 testimony on this topic, 

the majors are, at best, reluctant to have their commuter code-share partners involved in the 

program, and it is very difficult for prospective new entrants, without code-share affiliations, 

to gain a toehold in the market. Because a vital element of the program has been the 

competitive bidding process, the dearth of participating carriers has undoubtedly resulted in 

our paying higher subsidies than might otherwise be necessary."^ 

Hearing before the Senate Committee on Commerce, Science and Transportation, "The State of Scheduled Air 

Service at Small Communities," Testimony of Dennis DeVany, Chief, EAS & Domestic Analysis Division, U.S. 

Department Of Transportation, September 10, 1999. See also, HR Rep. 106-513, f 64, describing proposed requirements 

that dominant carriers dealing with EAS providers; Pub. L. No. 108-176, § 406, directing DOT to set up pilot program to 

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Against this background, it would not be in the Department's interest to further reduce an EAS 

provider's negotiating leverage by threatening to withdraw a route award if that provider were 

unable to conclude an interline arrangement with a major carrier. 

In any event, when the time comes to renew. Air Choice One will be prepared to review with the 

Department its efforts in achieving an interline agreement with a major carrier and is confident 

that the Department will reward those efforts by renewing our contract. 

We are gratefiil for this opportunity to correct the record and ask the Department to award us the 

EAS contract for Alpena, as it meets the statutory requirements and will meet the current air 

service needs in Alpena. 

Shane Storz 

CEO 

Air Choice One 

Cc: The Honorable Matthew J. Aligora, Mayor, City of Alpena, Michigan 

Robert S. Goldner, DOT 

require major carriers to interline with EAS providers, and DOT Notice dated February 1, 2006, establishing said 

program. 

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