Venango County 

Venango Regional Airport 

Chess Lamberton Field 

www .flyfranklin.org 

1560 Airport Road Franldin, PA 16323 814/432-5333 

July 18, 2014 

The Honorable Anthony Foxx 

Secretary of Transportation 

U.S. Department of Transportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

Commissioners: 

Timothy S. Bmoks 

Vincent L. Witherup 

Bonnie S. Summers 

Airport Manager: 

Otho C. Bell 

·.· J 

j·· ... .,::·· 

Re: Petition of Franklin/Oil City, PA for a waiver from the 10-enplanement statute, Docket-OST -DOT-1997 -25123 

Dear Mr. Foxx: 

The Venango County Regional Airport (FKL) was served on june 24, 2014, with the U.S. Department of Transportation 

(DOT) Order 2014-6-6 that we are being eliminated from the Essential Air Service (EAS) program due to our passenger 

enplanement numbers being less than 10 per service day. EAS service at FKL is incredibly important to the local 

economy of Franklin, Oil City, and Venango County. 

FKL formally requests an Exemption from 49 U.S.C. § 41731 (a)(1)(B) in order to continue air service at FKL. The 

reason for this request is that FKL has been relegated to poor, unreliable service for some time, but especially since 

Gulfstream International Airlines (now Silver Airways) took over operations in 2008. Gulfstream/Silver created a 

culture of poor operations and indifference toward their EAS communities. FKL specifically was impacted greatly by a 

culture at the airline, likely from the highest staffing levels, of overflying FKL whenever weather or conditions appeared 

to be marginal, in order for them to collect their EAS subsidies due to 

"weather cancellations". In fact, it was not uncommon for GulfstreamfSilver 

dispatchers to file flight plans that overflew FKL well in advance of scheduled 

arrival time, without any attempt to complete the flight. Indifference from the 

Gulfstream/Silver management forced FKL to spend thousands of dollars over 

the years paying for transportation for passengers stranded by 

GulfstreamfSilver to get to another airport to start their travels. 

Communication with Gulfstream/Silver was poor at best, and was nonexistent 

most of the time. 

As part of the order to eliminate FKL from the EAS program, a waiver process 

was established that enables the U.S. DOT Secretary to grant a waiver for an 

airport that has had a "temporary" reduction in passenger enplanements 

below 10 per service day. FKL, until2005, maintained approximately 10 

enplanements per service day, and had as many as 16.2. The turmoil that Air 

Midwest and US Airways went through in 2005 to 2008 caused passenger 

numbers to drop; however, the four-month hiatus in 2008 had severe longterm impacts (Table 1). We feel that those impacts could have been mitigated 

with an airline that was committed to providing a reliable product. 

Gulfstream/Silver consistently had major operational problems, especially 

dealing with the airport and weather conditions at FKL. 

Table 1 FKL Passenger Enplanements 

by Calendar Year 
U.S. Department of Transportation 

July 18, 2014 

Page2 

Immediately upon Gulfstream commencing operations in the fall of 2008; it became readily apparent that the airline 

was ill-equipped or prepared for operations outside of its Florida base of operations. The airline had no experience 

operating in northern climates, especially in an area of western Pennsylvania and northeastern Ohio, that can prove 

challenging due to icing conditions. Only two of their fleet of Beech craft B1900D aircraft had anti-ski brakes, which 

caused many of the cancellations and "overflights" of FKL. The issue stems from FKL's 5,200 foot runway and anytime 

the runway had contamination (water or snow for example). The braking action requirements and operational 

parameters of B1900Ds, without the anti-skid brakes, was inadequate for consistent winter use our runway. 

Numerous conversations with Gulfstream/Silver management, including an operational meeting at their Cleveland hub 

in 2009, failed to resolve the issue during their time here in FKL. This caused GulfstreamjSilver to cancel an average 

of 22.8 percent of flights during the December to February time period since 2008. While passengers had a nearly 

one in four chance of their flights being cancelled during the winter months, it was of no surprise that passengers 

continued to fall as passengers began booking away from FKL even during the summer months, and the efforts from the 

local community to reverse those trends were for naught. 

Due to the major issues being experienced, FKL became an active member in the Pennsylvania Air Service Committee 

(PASC), which was founded to help promote the commercial service airports within the state of Pennsylvania. As 

passengers at all five EAS markets that Gulfstream operated at in 2009 began to decline precipitously, the PASC, 

Pennsylvania Department of Transportation (PennDOT) and Pittsburgh International Airport (PIT) began working 

together to determine a solution. In 2010, a decision was made to pursue a statewide study to determine passenger 

demand, and the study formally began in 2011. This multi-year study was undertaken to quantify passengers in each 

catchment area and forecast potential enplanements if PIT became our connecting hub. More than 30 community 

meetings were held throughout the state including in each EAS community to discuss air service needs and gauge 

support for this service. This study found that reliable service on nine-seat aircraft to PJT, combined with a lowlocal fare structure can be just as successful at PITas it has been at Lambert-St. Louis International Airport (STL) 

for Cape Air and Air Choice One. See Appendix A for a discussion of the PIT Connector study. 

With the definition of "temporary" being "lasting for only a limited period of time; not permanent"; it is in the opinion of 

FKL that our decline, while being for eight years, is in fact temporary, and with the proper service will easily restore 

passengers above 10 enplanements per day. Untying FKL from other airports and eliminating the "overflight" issue 

would be a dramatic improvement to operations, while the low-fare, higher frequency model will bring passengers back 

from the road and their drive to PIT today. 

We are now close to implementing this multi-year study and plan and we are requesting that the U.S. DOT allow FKL to 

begin service to PIT and grant a waiver in order to allow us to prove that our concept is capable of increasing 

enplanements to and above the statutory minimums. Surely there are no other EAS communities in the country that 

have been a part of such a detailed study and have a fully executable plan on which to right the ship and excel with their 

EAS. Supporting this project, PennDOT and PIT have pledged significant funds for marketing and sales efforts in order 

to ensure air service remains at FKL while we implement the long awaited restoration of service to PIT. 

FKL respectfully requests a waiver to continue our air service for one year and quickly move to award our EAS contract 

to Sun Air so that we can begin to rebuild passengers to demonstrate to the U.S. DOT that our passenger reduction truly 

was "temporary" We look forward to working with you, the airlines, PIT, and the community to repair the damages to 

the air travel market at FKL. This plan is a practical solution to increase passengers to exceed the EAS minimums while 

ensuring access to the National Transportation System. 
U.S. Department of Transportation 

July 18, 2014 

Page 3 

Thank you. 

Respectfully submitted, 

Otho C. Bell 

Cc: Senator Bob Casey 

Congressmen Glenn Thompson 

Governor Tom Corbett 

Mr. Barry Schoch, P.E. 

Commissioners, County of Venango 
Appendix A: Discussion of PIT Connector and Midwest EAS Comparisons 

Pennsylvania Regional Air Service Plan 

Starting in 2012, Mead & Hunt was contracted to perform a statewide study to establish a baseline level of demand from 

the 13 commercial service airports in the state of Pennsylvania (excluded both Philadelphia International Airport (PHL) 

and PIT) and to determine the viability of connecting those airports to PIT. This was the first comprehensive air service 

development study completed in many of the EAS markets, and enabled the communities to have a better feel for what 

their air service demand actually is. As part of the study, representatives from Mead & Hunt performed more than 30 

community meetings around the state, allowing for direct discussions in each community of current air service, as well 

as discussion of the current airline industry trends. 

The study found that there was significant diversion (i.e. 

leakage) to the larger airports in the region. Leakage is not a 

phenomenon only associated with the smallest EAS markets and 

is experienced by most airports around the country. The study 

found that all13 of the commercial service airports in 

Pennsylvania leaked at a minimum of 40 percent of their 

passengers, while the EAS markets leaked as much as 99 percent 

of their passengers to surrounding airports (Table A.1). 

The study found that PHL and PIT were the main diverting 

airports, broken down geographically. For those markets in the 

eastern half of Pennsylvania, their main leakage was to PHL, 

while those in the western half of Pennsylvania predominately 

drove to PIT for their air service. This was true of the EAS 

Table A.1 Domestic and International Retention 

markets in the western half of Pennsylvania as well. Seventy-four percent of FKL area passengers drive to PIT today in 

order to utilize the lower fares and nonstop destinations. Connecting FI<L to PlT with low-fare service that people can 

rely upon will generate enough passengers to be above 10 enplanements per day and under $200 per passenger 

in subsidy. 

Through the leakage study and a comprehensive survey in each community, Mead & Hunt was able to determine that 

the majority of passengers diverted due to reliability, fares and schedules. Although PIT is not a hub as it was in the 

1990s and 2000s, it still offers more than 160 daily departures to 36 destinations. The study completed multiple 

forecasting models for service to PIT, involving aircraft from 50-seat regional jets all the way to nine-seat turboprops. 

The study ultimately found that the scenario that would work the best in today's environment would be a low-fare, 

high frequency service on nine-seat aircraft. 

The primary causes for leakage are the limited number of frequencies and high fares in comparison to the larger nearby 

airports. The study also found that the combination of markets in "tags" or "one-stops" created a major dissatisfaction 
Appendix A: Discussion of PIT Connector and Midwest EAS Comparisons 

with customers, as well as greatly decreased the reliability of the service, especially during the winter months when 

weather in one community frequently impacted the air service to the other community tied with it What the study also 

found is that the EAS communities currently around Lambert-St. Louis International Airport (STL) are very similar in 

size and proximity to EAS communities in western Pennsylvania. They had poor service that was unreliable, high priced 

and seldom used. Their service was switched to a similar low-fare, high frequency service on a nine-se<'lt aircraft, and 

passenger numbers improved five to 10 times their most recent levels. It is important to note that communities that 

had historically boarded less than five enplanements per day are now at more than 15 enplanements per day. 

Midwest EAS Community Comparisons 

Although every community is different and it's difficult to find perfect "proxy" markets for comparison purposes, the 

closest example for FKL and Bradford is the Midwest EAS communities that surround STL. Table A.3 shows the 

population comparisons and distance to either STL or PIT. When comparing to similar markets around STL, Franklin is 

similar in size and distance as Quincy, IL. While FKL is approximately40 minutes closer to the airport it's important to 

note that FKL's route involves the mountains of Western Pennsylvania which can be hazardous in the winter. The much 

larger population (61 percent higher population than Quincy) surrounding Franklin, would more than make up for its 

closer proximity to the hub. FKL today, however, boards almost 90 percent fewer passengers til an Quincy. 

When comparing passengers from 2009 to 2013, the communities in the STL area have experienced growth from 157 

percent to nearly 1,200 percent. Although FKL bas shown some growth in passengers since 2009, which is a testament 

to the local community's commitment to promoting the air service, even as the current carrier failed to uphold its 

obligation of reliable service. 

Due to the success in the partnership between Cape Air or Air Choice One, STL and the local communities, these 

Midwest EAS markets have seen an explosion in growth in passengers over the past five years with a model very similar 

to the one that is being contemplated for FKL. The commitment of PIT and Penn DOT, however, goes beyond what has 

been done in those markets, and will help to further guarantee the success of the new service. There is very little 

doubt, that FKL, as well as Bradford, would see dramatic growth in passengers with a similar/ow-fare, highfrequency operation to PIT, easily maintaining more than 10 enplanements per day.