### JOHN 

## H. COX 

## III Mayor CITY COUNCIL Tommy 1. Benson, III, Ward I LoisHawkins, Ward 2 Caroiyn WeaIhers,.Ward 3 Bettyj.Walkins, Ward 4 Ann Hollowell, Ward 5 Etrick D. Simmons, Ward 6 

# CITY OF GREENVILLE P. 

# o.&lx 897 •340 Main Sl•Grrenville,

Mimippi 38701 •Thlephone: 662-373-1501

•Facillnile: 662-378-0276

•Email: johnoox@gnmvillems.org May9,2014
KevinSchlemmer, Director EASProgram, U.S.Department ofTransportation West Building 1200 NewJersey Ave.SE Washington D.C.20590
RE:Greenville MidDeltaAirport Order 2014-4-26
DearMr.Schlemmer, Greenville, Mississippi isinreceipt ofOrder 2014-4-26. (:::;} 

### .t::' ':..- '



### This Order tentatively finds that Greenville, Mississippi (aswell as 12other cities) iswithin 175 miles ofalarge or medium hub (Memphis) and is thus subject to the 10-enplanement statutory criterion. Further, the Order finds that Greenville generated a total of5,836 passengers in or out during the fiscal year 2013, resulting in an average of9.3 enplanements per day, below the 10-enplanement requirement.
The Greenville Mid-Delta Airport and its community partners do not contest the fact that our passenger totals (on and off)forfiscalyear 2013 didnottotal an average of10enplanements per day. However, we do contest the passenger numbers which have been reported and believe that we generated more traffic than is reflected in the numbers the Department has tabulated. The DOT numbers show Greenville averaged 9.3 passengers per day. We submit the correct. number is 9.65. Wemake this point because our numbers show aslightly higher total, and we want that noted forthe public record. The documentation of our challenge to the DOTtraffic numbers is outlined in the attached sheets asAppendix Atothis letter. Although we understand that the corrected numbers, if accepted, do not get Greenville to 10 enplanements per day during fiscal year 2013, ifthe final Orderterminating our BAS eligibility is based on failure to make 10-enplenments per day during fiscal year 2013, it is our intention to vigorously contest that Order viaarequest forawaiver under 49 U.S.c.41731 (e).
We averaged 14,932 annual O&D(23.9 enplaned per day) for a nine year period prior to Silver Airways assuming control ofour air service onOctober 1,2012. Ourfailure to make 10 enplaneI11ents www.greenvillems.org www.gnmvillems.org

# CITY OF GREENVILLE

p.

# o.Box897 • 340MainSt • Greenville,Mislissippi38701 • Thlephone:662-378-1501 • Fac;imile: 662-378-0276 • Email:johnoox@grrenvillems.org JOHN 

## H. 

## COXIII Mayor CITY COUNCIL Tommy L.Benson, Ill, Ward 1 LoisHawkins, Ward 2 Carolyn Weathers, Ward 3 Belty]. Watkins, Ward 4 Ann Hollowell, Ward 5 Errick D. Simmons, Ward 6



### per day during fiscal year 2013 was due strictly to the poor air service that SilverAirways provided during that period. Furthermore, we have numerous airlines interested inbidding to provide EASservice at our airport and bids from those carriers to provide service will comply not only with the 10-enplanement criterion but alsowith the $200 subsidy capper passenger requirements ofthe EASprogram.
Wewill document our case forawaiver atthe appropriate time and inthe appropriate forum. Sincerely, 

# a~o~
M'ayor
CC: Council Member Tommy Benson

Council Member Lois Hawkins Council Member Carolyn Weather Council Member Betty Watkins Council Member Ann Hollowell Council Member Errick Simmons Draylan Gant, Greenville Mid Delta Airport Director Andy Alexander, CityAttorney Mike Mooney, Sixel Consulting Group Josh Abramson, Tupelo Airport Executive Director

www.greenvillems.org W\WI.grrenvillems.orgAppendix A

Silver Airways undertook a cutover from an Island Air reservations and GDSsystem to aSabre GDS system during June of 2013. Airline reservation system cut overs are very complex tasks and very difficult for any airline to accomplish without some, usually short-term, disruption of operations.
A review of Silver Airways traffic in and out of Greenville for the period October 2012 to September 2013 shows an unusual drop of traffic during June of 2013.
This significant dip in traffic is completely inconsistent with historic Greenville traffic demand by month patterns and was certainly inconsistent with Greenville traffic in the months just before and just after June'of 2013 where an identical Silver Airways service pattern was in effect.



# GREENVILLE TOTAL TRAFFIC: 2006 - 2011 Year JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC TOTAL 2006 1,380 1,108 1,359 1,303 1,533 1,391 1,556 1,424 1,194 1,220 1,240 1,404 16,112 2007 1,058 800 1,207 1,196 1,389 1,202 1,277 1,345 1,396 1,340 1,528 1,477 15,215 2008 1,057 887 996 998 1,134 1,022 1,146 899 734 851 957 999 11,680 2009 641 566 733 767 1,085 1,228 1,613 1,102 1,188 934 1,087 992 11,936 2010 645 584 914 784 951 1,091 1,223 997 1,184 1,184 1,215 1,233 12,005 2011 885 752 1,161 1,044 1,259 1,347 1,406 1,161 1,233 1,367 1,383 1,268 14,266 Total 5,666 4,697 6,370 6,092 7,351 7,281 8,221 6,928 6,929 6,896 7,410 7,373 81,214 %/Mo 7.0% 5.8% 7.8% 7.5% 9.1% 9.0".16 10.1% 8.5% 8.5% 8.5% 9.1% 9.1% 100.0"10 

# GREENVILLE TOTAL TRAFFIC SILVER; OCT 

# 2012 SEPT 2013



# __ I OCT

# I NOV

# I DEC

# I JAN 1 FEB

# I MAR

# I ARP 

# I MAY 1 JUN 

# I JUL 

# I AUG 1 SEP 

# I TOTAL Silver First 452 613 542 433 455 629 492 544 281 497 450 448 5,836 12Mo %/Mo 1-7-.7%-0

110.5%

# I 9.3% 1 7.4% 1 7.8% 110.8%

# I 8.4%

# I 9.3% 1 4.8%

# I 8.5%

# I 7.7% 1 7.7% 1100.0%

# I

Forthe entire sixyear and 72 month period of 2006 to 2011 Greenville had the same air service pattern, twice daily SF-340 service to Memphis under the Northwest and then Delta brand and code. The month of June typically generated 9% of total annual market traffic over this extended period with little year to year deviation.
In the first 12 months of Silver Airways one stop service to Atlanta the pattern of service was the same three trips per day with SF-340 aircraft. While there was significant deviation in operational performance during some months, June of 2013 was actually a relatively reliable month of service.
Yet Greenville traffic for the month of June 2013 issomehow atotal of 281 passengers or 4.8% of the first 12 months total. Further, that number is completely inconsistent with nearby months of March to August, which averaged 522 passengers each.
The evidence here that statistically there isaserious deviation from norm in June of 2013 isvery clear.Aprli " 2014 GreIlnvll!e Mid-Dalla Airport AIln: Oraylan Gent DlI'lIetor 166 Fifth A'/lIl1Ul1 araOllvUllI, MS 38701 On June 6, 2013, Silvar Airways In_ted asabre IMeI'lICtcutover. During 1llIs_r there weill a number 01 reeetVa1lOnslI1atdid no):get "" ••led over as a resutt 01human error. Although there were prooedures Implemented III minimIZe the ell'OlS,there wera stll many thet did not make the CUI. For the month ofJuna, SlIvar Alrways hall a._ of 253 daplan\lmanls ami 234 enplanamenls. Please feel free to

_ me should you have any questions orooncems. Thank~ 

## .A,f,L ~ ,

v 

### Sheryl Parker ISIa1IcnManager 

# OSilll.~.f

Email: sbaD1.pBrker@QQ3fbmr.com OIlIce,662.378-11620 Olrect: 662-5_35 Fox: flIl2.<l35-OO10 MollIIe: 662-695-5567

Quick Flight handled all Silver Airways ground handling in Greenville during the first 12 months of Silver service (and continuing today). The Quick Flight / Silver Station Manager does above testify to the difficulties encountered at Greenville in June of 2013 due to the Silver Airways GDS cross over. The station counted each ticket by hand for the month and concludes that Greenville generated 253 on and 234 off for a total for June of 2013 of 487 passengers, a number completely congruent with market averages, both historical and with Silver service.Based on the statistical evidence of passenger miscounts during June of 2013 due to the GDScrossover

and the careful manual recount of every passenger by the Greenville Quick Flight Station Manager the Mid Delta Regional Airport submits the following correction to the traffic reports that are the basis of the DOTOrder 2014-4-26.
CORRECTED 

### GlH TRAFFIC FY2013

Month Reported Actual Oct 452 452 Nov 613 613 Dec 542 542 Jan 433 433 Feb 455 455 Mar 629 629 Apr 492 492 May S44 S44 Jun 281 Jul 497 497 Aug 450 450 Sep 448 448 Total 5,836-- 6,042 b 313 18.65 19.30 by2 9.32 9.65

We appreciate the Department's consideration of this suggested adjustment to Greenville's Fiscal Year 2013 passenger counts.