~ City of Adak 

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May II, 2012 

Mr_ Dennis J. DeVany 

Chief, Essential Air Service Division 

Office of Aviation Analysis 

U.S. Department ofTransportation 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

RE: Peninsula Airways Proposal 

Docket DOT-OST-2000-8556 

Dear Mr. DeVany: 

City of Adak 

P.O. Box 2011 ·Adak, Alaska 99546 

(907) 592-4500 • Fax: (907) 592-4262 

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This letter serves to express the comments of the community regarding the proposal submitted for 

consideration to the U.S. Department of Transportation ("USDOT'') by Peninsula Airways ("'Pen 

Air'') on March 30, 2012. We recognize that though comments were not officially requested by your 

department, community input would be beneficial in your consideration of the aforementioned 

proposal. The City is cognizant that there are several positive and negative aspects regarding the Pen 

Air proposal and that the community seemingly has no other options to choose from, given the fact 

that only one response for Adak was received by the Division. 

On April II th' the City Council held a public hearing to solicit input regarding the Pen Air proposal. 

The majority of the testimony received relates to cargo and mail capacity, the problems that the 

community has previously experienced, and the ClllTent experiences of other communities with similar 

service. Another significant concern is Pen Air's ability to maintain the proposed schedule, as well as 

the related effects, again based on the community's previous experience with Pen Air as well as their 

performance in other communities, including Cold Bay, the proposed stopover point. 

The cargo capacity of Pen Air's aircraft, the Saab 340, is substantially smaller than what is available 

with our current can·ier and causes the most concern regarding this proposal. With the reopening of 

the local fish processing plant by Icicle Seafoods, we have seen firsthand the increased needs and 

capacity utilization by the community. In January 2012, the community saw an influx of 

approximately 150 personnel for the fish plant. With the Saab 340's capacity of30 passengers per 

tlight, a minimum of five flights would be booked with no mail and freight on the flights during this 

time period. With the proposed schedule, the community could realistically encounter a situation of 

having no mail and freight tor at least a week. If we multiplied this several times during the year, the 

effects seen would be severe. 

Furthermore. the City has seen an increase in cargo related activity in relation the operating of the 

local fish processing plant. Not only has the City seen an increase in inbound cargo/mail/passenger 
Comments on Essential Air Service Proposal 

May11, 2012 

Page2 

traffic, an increase of outbound traffic has also been observed. This season, encompassing JanuaryMarch, shipments of perishable fish products, some destined tor international markets, became a 

regular occurrence. On several instances, cargo shipments in excess of 8,000 lbs. each were tendered 

on our current carrier, which according to Pen Air would not be possible due to payload limitations. 

The City is confident of the expectation of those markets to grow, with resulting shipments increasing 

as well as the processing plant increases operations. 

The City is additionally concerned about freight screening given the aforementioned exportation and 

Pen Air's limitations for security screening. We understand that a process identified as "reverse 

screening" can and would be employed, however we are concerned about the practicality of this 

method and the potential problems that could arise from significant usage of this security protocol. 

It should also be noted that Adak Island does not have regular barge service and the community is 

entirely dependent on air service for all items, including but not limited to dry goods, groceries, 

medicine, perishable and other time sensitive goods. While the community expects regular barge 

service in the future, this is a long-term expectancy and is not something that can be relied upon at this 

point in time. In reviewing the Pen Air proposal, community members noticed there was no provision 

for a "food rate" or a rate that is based on identifying groceries as a specific commodity and 

corresponding rate. Our current air carrier has extended this rate to Adak (see attached airway bill), 

which has become an integral component to life and business on the island. 

- J.; . . ... 

Part of the necessity of a special rate for groceries is related to the U.S. Postal Service's Bypass Mail 

Program. At the time the bypass mail program was identifying communities that would become 

beneficiaries Adak was a Naval Air Facility with no such need of the program. Now that Adak is a 

civilian community we have a need tor this program but are not eligible to participate. Furthermore, 

given the financial state of the Postal Service, inclusion of Adak into the bypass mail program seems 

highly unlikely. In summary, with Pen Air's proposal community members could pay as much as 

three times more to obtain groceries, notwithstanding the costs to the local store that would be passed 

on to those unable to freight in their perishable goods. 

In addition, Adak is still in the process of being cleaned up by the U.S. Navy as required under the 

Base Realignment and Closure process. This year the U.S. Navy awarded contracts tor cleanup 

efforts leading to an expected increased tratlic level this summer not seen since approximately 2009. 

The U.S. Navy is expected to award another contract tor extensive work commencing during the 

summer of2013 of which extensive logistical efforts will be required, more so with Pen Air's 

proposal. It should be noted that some of the companies bidding on these contracts tor the U.S. Navy 

are quite concerned about obtaining seats and more so about their cargo shipments timely arriving on 

Adak. 

We understand that speculation is discouraged and not allowed, however with respect to historical 

data, the data is flawed due to the effects of having a tish processer in the community that went 

bankrupt in 201 0 as well as no active Navy contracts during the last EAS cycle. The effects of these 

situations were immediately felt and now the community is feeling the macro effects though steps 

have been made to reverse this trend to the extent practical on a local level. 
j • 

Comments on Essential Air Service Proposal 

May11, 2012 

Page3 

The community is furthennore concerned with the ability of Pen Air to complete its proposed 

schedule. It is no secret that the weather on Adak is fluid at best and for all intents and purposes 

unpredictable. We are concerned that the actual completion percentage will be similar to Atka 

(approximately 65%). As a result, the community is concerned that that flight cancellations will result 

in similar situations experienced in Dutch Harbor and Cold Bay with long standby lists and the 

unexpected financial costs travellers will incur. With a scheduled flight time of approximately 183% 

of the current flight time, citizens are concerned about having to return to Cold Bay, which could see a 

shortage of rooms if other circumstances caused rooms to be booked. If the plane goes back to 

Anchorage, a preferable option, passengers will have travelled tor approximately I 0 hours. 

There is one further aspect of the proposal we respectfully disagree with in regards to the costs 

associated with TSA agents. The community was finally able to have TSA accept a candidate to 

become a local agent, which has been a long tenn issue all stakeholders have been working on. 

Currently one other TSA agent is rotated in on a month-to-month basis, only because ofTSA's current 

inability to secure another candidate suitable to them. At present the loss of the community TSA 

agent could lead to a loss of at least two children from our small school of approximately 20 students. 

The City would be remiss if it did not disclose any benefits to acceptance of Pen Air's proposal. The 

City will, without a doubt, see an increase in sales tax receipts directly related to the money Pen Air 

would spend in the community. On the other hand, the City expects the expenses of operating the 

tenninal to increase substantially, thereby negating most of the financial benefits expected. 

Furthennore, the City would also lose State assistance for our providing a certified law enforcement 

officer as it would not be required for Pen Air service to Adak. 

Notwithstanding the above concerns, the City needs the Essential Air Service program and will work 

with Pen Air, if selected, to ensure the community is served successfully. We sincerely hope that the 

Division will take our comments into consideration as it follows the process of selecting an air carrier 

to serve Adak. 

Thank you for your time and please contact me with any questions you have in regards to our 

comments. I can be reached at (907) 592-4500 or at llockctt(a)adak-ak.gov. 

Sincerely, 

Layton J. Lockett 

City Manager 

City of Adak, Alaska 
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