JOHN H. COX III

Mayor

CITY COUNCIL

Tommy 1. Benson, III, Ward I

Lois Hawkins, Ward 2

Caroiyn WeaIhers,.Ward 3

Betty j. Walkins, Ward 4

Ann Hollowell, Ward 5

Etrick D. Simmons, Ward 6

CITY OF GREENVILLE

P.o. &lx897• 340MainSl• Grrenville, Mimippi38701• Thlephone: 662-373-1501 • Facillnile: 662-378-0276 • Email:johnoox@gnmvillems.org

May 9, 2014

Kevin Schlemmer, Director

EASProgram, U.S.Department of Transportation

West Building

1200 New Jersey Ave. SE

Washington D.C.20590

RE:Greenville Mid Delta Airport Order 2014-4-26

Dear Mr. Schlemmer,

Greenville, Mississippi is in receipt of Order 2014-4-26.

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This Order tentatively finds that Greenville, Mississippi (as well as 12 other cities) is within 175 miles

of a large or medium hub (Memphis) and is thus subject to the 10-enplanement statutory criterion.

Further, the Order finds that Greenville generated a total of 5,836 passengers in or out during the

fiscal year 2013, resulting in an average of 9.3 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) for fiscal year 2013 did not total an average of 10 enplanements 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.

We make this point because our numbers show a slightly higher total, and we want that noted for the

public record. The documentation of our challenge to the DOT traffic numbers is outlined in the

attached sheets as Appendix Ato this letter.

Although we understand that the corrected numbers, if accepted, do not get Greenville to 10

enplanements per day during fiscal year 2013, if the final Order terminating 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 via a request for a waiver 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 of our air service on October 1, 2012. Our failure to make 10 enplaneI11ents

www.greenvillems.org

www.gnmvillems.org
CITY OF GREENVILLE

p.o. Box 897 • 340 Main St • Greenville, Mislissippi 38701 • Thlephone: 662-378-1501 • Fac;imile: 662-378-0276 • Email: johnoox@grrenvillems.org

JOHN H. COX III

Mayor

CITY COUNCIL

Tommy L. Benson, Ill, Ward 1

Lois Hawkins, 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 Silver Airways provided

during that period.

Furthermore, we have numerous airlines interested in bidding to provide EASservice at our airport

and bids from those carriers to provide service will comply not only with the 10-enplanement

criterion but also with the $200 subsidy cap per passenger requirements of the EASprogram.

We will document our case for a waiver at the appropriate time and in the 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, City Attorney

Mike Mooney, Sixel Consulting Group

Josh Abramson, Tupelo Airport Executive Director

www.greenvillems.org

W\WI.grrenvillems.org
Appendix A

Silver Airways undertook a cutover from an Island Air reservations and GDS system to a Sabre 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%-0110.5% 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

For the entire six year 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 is somehow a total 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 is a serious deviation from norm in June of 2013 is very 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 a sabre IMeI'lICt cutover. During 1llIs _r there weill a number

01 reeetVa1lOnslI1at did 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 of Juna,

SlIvar Alrways hall a._ of 253 daplan\lmanls ami 234 enplanamenls.

Please feel free to _ me should you have any questions or ooncems.

Thank~

.A,f,L ~ ,

v

Sheryl Parker ISIa1Icn Manager

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 GDS crossover

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 DOT Order 2014-4-26.

CORRECTED GlH TRAFFIC FY 2013

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.